Central and Eastern Berkshire
Joint Minerals & Waste Plan
Consultation Statement (Regulation 22) Annex 1
February 2021
Contents
Regulation 18 Issues and Options (2017) ...... 3 Issues and Options Consultation (2017) – Issues and responses ...... 3 Regulation 18 Draft Plan Consultation (2018) ...... 23 DM Policies ...... 23 Waste Policies ...... 42 Mineral Policies ...... 57 General Policies and other ...... 78 Berkyn Manor Farm ...... 106 Bridge Farm ...... 108 Datchet Quarry ...... 122 Ham Island ...... 126 Horton Brook Quarry ...... 136 Monkey Island Wharf ...... 140 Planners Farm ...... 142 Poyle Quarry ...... 159 Star Works ...... 161 The Compound ...... 177 Water Oakley...... 185 Additional (site specific) Regulation 18 Consultation on Bray Quarry Extension (2019) ...... 191 Focussed Regulation 18 Consultation (2020) ...... 205 Area of Search ...... 205 Land West of Basingstoke Road ...... 215 Area between Horton Brook and Poyle Quarry ...... 231 Policy DM15 ...... 239 Further Comments ...... 243
Issues tables
Regulation 18 Issues and Options (2017)
Issues and Options Consultation (2017) – Issues and responses
As a number of responses were relating to the same issue, the issues have been grouped together below allowing one single response to be provided.
Consultation Issue Raised Response from the authorities’ Question Vision Q2 • Expecting a loss of waste The National Planning Policy Framework management capacity in 2026 recommendations a 15-year time horizon for and the period allows enough Local Plan development. It is expected that time to resolve capacity issues the Joint Minerals & Waste Plan is adopted in (Environment Agency) 2021. • A Central & Eastern Berkshire- wide Plan would of necessity Both the UK leaving the European Union require an overarching timescale (“Brexit”) and the proposed expansion of in relation to unitary authority Heathrow Airport create a number of Plans. This period should give uncertainties for the future demand and sufficient time for implementation management of minerals and waste. and for monitoring to determine whether it is being applied with As such, it is proposed that the Joint Minerals optimum effectiveness (Clewer & Waste Plan will contain monitoring indicators Manor Area Profile) and triggers to prompt an early review of the • Suggestion of shorter period plan should changes arise from these issues, before reviewing the Plan and any others. (between five and 10 years (Wraysbury Parish Council, Horton Parish Council, Egon Environmental) • A 20 year Plan would seem more appropriate (it would avoid Plan slippage issues as well as enable long term planning of issues) (Grundon) • The plan also needs to indicate a start date to show the period and years the provision of mineral is being made for (Cemex) • The Plan should be for 20 years from the date of adoption and not 20 years from the date when the first stages of the update/consultation commenced. Plans should aim to include over and above the anticipated increase in housing numbers. Future housing increases will need to take
account of the future expansion of Heathrow airport (Parish Council) Q4 • The vision must focus on Noted – this information will be used to inform ‘ensuring the maintenance of a the Preferred Options. steady and adequate supply of minerals’ while aiming to The Vision is intended as an overarching maximise the contribution that statement/series of statements, describing minerals development can bring what the area will look like by the end of the to local communities, the Plan period in 15-20 years’ time. The economy and the natural objectives are more specific and set out what environment’ (Cissbury). the Plan is trying to achieve in order to help • Reference to be made to the make the ‘Vision’ a reality. Consequently, historic environment (Historic comments referring to specific ‘practical’ policy England) are dealt with within the objectives. • Support for references to the natural environment. Aim to be The Vision sets out the competing pressures of edited to include: ‘to minimise ensuring a necessary supply of minerals and impacts on the natural waste resources, whilst at the same time environment and ensure aiming to make those developments as environmental enhancement’. acceptable to local communities as possible. • Inclusion of recycled/secondary ‘Maximising the contribution to local aggregate (Environment communities’ is the vision to ensure such Agency) developments benefit communities, whether that is economically, through for example the • Reference to the closeness to London and London’s ability to role in local supply chains and house building treat waste (Environment industry, as well as environmental and social Agency) benefits through restoration and subsequent recreation opportunities. • Reference to infrastructure
projects and their requirements (Environment Agency) • Amendment: “Recognising the importance of the area as a source of minerals and a through route and destination for minerals coming from outside the area, Central & Eastern Berkshire….” (Clewer Manor Area Profile) • Support for references to the natural environment, but must be supported by sufficiently strong worded policy within final Plan (Colne Valley Park Community Interest Company) • Further emphasis on protection of existing biodiversity and enhancement in net-gain through habitat restoration (Royal Society for the Protection of Birds) • Vision must be broad and not limited to positive outcomes of minerals and waste (Swallowfield Parish Council)
• Reference to providing a steady and adequate supply of minerals, and sufficient production capacity (Grundon) • Contradictions between waste management of landfill within vision and Plan document (local vs regional management) (Biffa) • Explanation of ‘maximise the contribution that minerals development can bring to local communities’ and the Vision needs to be more spatial (Cemex). • Explanation of how the Plan area aims to be self-sufficient and parameters applying to this (Oxfordshire County Council). Q5 Would welcome a reference to Noted – this information will be used to inform environmental sustainability in the Preferred Options. Objective 6 such as there is in Objective 7 (Historic England) Q6 • Objective 2 – there was Sensitive Design and Sustainable Construction confusion over the methods of methods are covered within the Development ensuring ‘sensitive design and Management Policies of the Plan. sustainable construction Reference to flood risk included in Objective 2. methods’ (Cemex). Objective 3 amended to include wider impacts • Objective 3 – General support. and resilient networks. Include reference to flood Noted – this information will be used to inform storage. Objectives should the Preferred Options. include site’s impact on wider area biodiversity/establishing a coherent and resilient ecological networks. Support for Objective 3, and further information on enhancing biodiversity at the Preferred Options stage was provided (Environment Agency) • Objective 6 – reference to environmental sustainability. Include ‘…from appropriately located and environmentally acceptable sources’. Amendment to include ‘steady and adequate supply of minerals’ with sufficient production capacity. Suggestion to add that the objective will be achieved via safeguarding mineral resources and site allocations (Historic England, Grundon, Cemex) • Objective 7 – Replace ‘demand for’ with ‘supply of. Suggestion to Noted. All objectives should be considered move objective placement under together as stated in introduction. objective 3 (Mineral Products Association, Cissbury)
Objective 9 – Support for reducing mineral miles. Difficulties of rail movement were highlighted (Clewer Manor Considered that Objectives meet paragraph 17 Area Profile) as far as practically possible. Considered that • Objective 11 – Support for the Objective 3 meets the requirements of principle of the objective. Paragraph 110. Suggestion to ensure no conflict between Objective 11 and 12. Suggestion that Objective does not recognise the need for certain materials (inert material) which must be deposited in landfill. E.g. excavation arising’s which cannot be recycled. Noted. Considered to be covered by the Availability of void space during Objectives. Plan period is fundamental. Net self-sufficiency was supported in the right type of waste capacity. How will parameters of net self- sufficiency be defined? (Clewer Manor Area Profile, Quarryplan, Oxfordshire County Council) • Objective 12 – Support for the Plan area being ‘self-sufficient’. Inclusion of the phrase ‘…unless there is a conflict with other objectives such as quality of life or zero waste economy’ (Wraysbury Parish Council) • Reference should be made to the need for increased recycling provision to achieve target rates that are being promoted through Circular Economy Package (Biffa) • Suggestion objectives do not meet requirements of National Planning Policy Framework (paragraph 17 and 110). Therefore have recommended a specific objective which refers directly to allocating sites on land of least environmental value allowing net gain for nature and creating links for natural environment (Berks, Bucks and Oxon Wildlife Trust) • Mineral extraction should plan to reduce transport minerals miles and encourage the use of rail and water for transport. Recognition of the environmental impact of mineral extraction – objectives should include the site’s impact on biodiversity (Swallowfield Parish Council)
• Need further emphasis on the requirement to supply the construction industry with sufficient primary aggregate. Recognition also needed for the requirement to dispose of inert waste which has no other economic value (Savills on behalf of the Rayner Family Trust) • Would anticipate seeing the following included at the Preferred Options stage of the Plan (Royal Society for the Protection of Birds): o Protection of existing biodiversity o Promote a restoration- led approach o Deliver a net-gain in biodiversity o Contribute to national and local targets for the creation of priority habitat o Create a coherent and resilient ecological network by taking a landscape-scale approach o Encourage a simpler approach to habitat creation o Secure and promote the long term management of restored mineral sites with a biodiversity after use o Restoration of mineral sites in airfield safeguarding zones Q7 In agreement but 8.9 should read, Noted – this information will be used to inform “…building blocks in the area’s the Preferred Options buoyant economy; they unite…” and 8.10 should read, “…wider Thames Valley region. The area’s importance is highlighted…” Q8 • General support for principles Noted – this information will be used to inform • Principle vii: should be ‘in the Preferred Options locations that are acceptable’ Specific locations will be set out in Policy and (Minerals Products Association supporting text. & Cissbury) • Principle viii: high emphasis to Principles are designed to set out requirements be placed on this principle. of sustainable development, supported by the Change the word ‘limit’ in order Development Management Policy. Specific to strengthen the principle points relating to Minerals and Waste policy (Horton Parish Council). generally covered within the objectives. The
• Principle ix: suggestion to Principles are intended to act as the remove the word ‘most’, as all requirements on development, in delivering the sites should be protected. objectives. Include the word ‘unacceptable’ prior to ‘development’ (Quarryplan) • Unclear exactly what the spatial strategy is (Surrey County Council). • Recommended reference to recycled/secondary aggregates and promotion of such. The protection and enhancement of watercourses and their associated corridors should be also included. (Environment Agency) • Recommend reference to protecting/enhancing ecological networks through the landscape, wildlife and adaptation to climate change. • Reference should be made to the Colne Valley Regional Park in the Royal Borough of Windsor and Maidenhead (Colne Valley Community Interest Company) • The inclusion of a criteria which seeks to minimise road miles (Grundon). • The strategy must recognise the role of waste management to achieve sustainable development in line with para 14 of National Planning Policy Framework. The Plan must plan for all levels of the waste hierarchy, and meet ambitions of the Circular Economy (Biffa). • Recommendation to include specific points requiring sites to be located in areas of least environmental value, avoid impacts of re-location/re-design, mitigate unavoidable impacts, achieve measureable net gain, enhance links between natural habitats, timely restoration/aftercare allowing long term net gains (Berks, Bucks and Oxon Wildlife Trust) • Reference should be made to safeguarding future mineral resources and areas of future workable reserves (Cemex) • 8.9 should read, “…building blocks in the area’s buoyant
economy; they unite…” 8.10 should read, “…wider Thames Valley region. The area’s importance is highlighted…” (Clewer Manor Area Profile) Minerals Q9 Suggestions included Aggregate Noted – these information sources are already Monitoring survey, planning being taken into account. applications, mineral operator surveys (Oxfordshire County Council, Cemex, Quarryplan (GB) Ltd). Q10 Those who disagreed stated: the Noted – this information will be used to update mineral type is different to West the Minerals: Background Study and inform the Berkshire and therefore, serves Preferred Options. different markets (Cemex). Higher economic activity in Central & Eastern Berkshire than West Berkshire means demand will be greater (Savills on behalf of the Rayner Family Trust and Quarryplan (GB) Ltd). Q11 One response did not relate to the It is noted that there is a degree of uncertainty question asked. Projections should within the projections as issues such as the include sensitivity testing on proposed Heathrow Expansion are likely to underlying assumptions (Arborfield have impacts on the Plan Area. It is it is and Newland Parish Council) proposed that the Joint Minerals & Waste Plan will contain monitoring indicators and triggers to prompt an early review of the plan should changes arise from these issues, and any others. Q12 Not specific data, industry Noted. knowledge was offered, as was the offer of operator figures if helpful (Cemex, Egon Environmental, Quarryplan (GB) Ltd, Savills on behalf of the Rayner Family Trust). Issue of Colnbrook (Heathrow). Q13 Favour for this type of transport due Noted. to inadequate road network (anonymous Parish Council) Q14 No specific sites were identified; Noted – this information will be used to update however the current rail and river the Minerals: Background Study and inform the network was suggested for Preferred Options. investigation (Quarryplan (GB) Ltd, Binfield Parish Council). Additionally, the importance of Colnbrook was mentioned and its future (Slough Borough Council). Also the issue with existing rail lines and planning restrictions such as night movements Q15 Support for recognising the rail depot Noted – this information will be used to update in Sough (Colnbrook) and concerns the Minerals: Background Study and inform the over Heathrow (Slough BC), and Preferred Options. concern over how this could be
delivered as not in plan area (Cemex). Q16 Suggestions included housing and Noted – this information will be used to update population projections, planning the Minerals: Background Study and inform the permission development numbers, Preferred Options. borough local plans, MPA forecasts/scenarios of aggregate demand (Slough Borough Council, Egon Environmental Ltd & Cemex) and suggestion to include recycled and secondary aggregate figures to understand uses and means to reduce primary aggregate (Environment Agency). Q17 Local developments are considering Noted – this information will be used to update reducing imports of bulk material to the Minerals: Background Study and inform the the site by reusing/recycling Preferred Options. materials from demolition and other means. Aim to maximise amount of material on site and reduce reliance on imports (Heathrow). Q18 This question relates to imported Noted – this information will be used to update marine sand and gravel and crushed the Minerals: Background Study and inform the rock, both of which have increased Preferred Options. in consumption in Berkshire. However, the way the question is worded; it could be misunderstood to also include land-won sand and gravel, which appears to be increasingly exported, rather than imported (Oxfordshire County Council). Q19 Warning if plan for dependence on Noted – this information will be used to update imports that this could be self- the Minerals: Background Study and inform the fulfilling if provision for land-won Preferred Options. sources is reduced (Mineral Products Association). Plan should not rely solely on imports, as increases transportation and emissions (Quarryplan GB Ltd). Timeframe too short to confirm trend due to emission, advice to compare to wider South East (Grundon Waste Management). Heathrow expansion will impact rail depot and ability to handle same amount of aggregate. National Planning Policy Framework guidance stats MPA’s should plan for 7-year landbank (Savills UK on behalf of the Rayner Family Trust) Q20 Yes - unless a rail depot is found Noted. (Cemex) Q21 Possible expansion at Heathrow Noted. (Slough Borough Council) Environment Agency Waste Data Interrogator
Offers from local operators to provide figures (Environment Agency) Q22 One respondent suggested the Noted. information could be found from quarterly returns for Environment Agency permits (Environment Agency) Q23 One respondent questioned the Noted. word ‘more’, as the area should either be self sufficient or not with no in-between state (Oxfordshire County Council). Q24 No - not entirely, some material will Noted – this information will be used to update be transported by road on a back- the Minerals: Background Study and inform the haulage basis (Quarryplan (GB) Ltd). Preferred Options. Q25 Central & Eastern Berkshire should Noted. seek to find their own rail depot (Cemex) Q26 The marine won sand and gravel is Noted. not a big market for this area (Cemex) Q27 Also transported via Theale and Noted – this information will be used to update Woking rail depots (Cemex). the Minerals: Background Study and inform the Preferred Options. Q30 It appears that soft sand in Berkshire Noted – this exercise is already being is currently being supplied from undertaken. outside of the Plan area. As mentioned previously, an attempt should be made to quantify this need, and identify where the supply is coming from, in order to secure the steady and adequate provision of this aggregate for the Plan period. West Berkshire has included alternative methods of calculating need for soft sand due to confidentiality constraints in their recent preferred options consultation (Oxfordshire County Council). Q31 Geological resource is constrained Noted – this information will be used to update within Central & Eastern Berkshire the Minerals: Background Study and inform the (Quarryplan (GB) Ltd) Preferred Options. Q33 Sites in Bucks and West Berks can Noted – this information will be used to update supply Slough too (Cemex). the Minerals: Background Study and inform the Preferred Options. Q34 Information provided on sites which Noted. we are already aware of and therefore have not included within the reserves (Cemex). Environmental factors may affect the remaining reserve (Environment Agency) Q35 Highlighted a live planning Noted. application (Cemex)
Q36 As mentioned previously, the role of Noted – this information will be used to update Slough in the Plan needs to be the Minerals: Background Study and inform the clarified. It is not part of the Plan Preferred Options. area, and so any account of the mineral resources available will need to be identified and secured through the Duty to Cooperate (Oxfordshire County Council). They should be taken out of this plan area. The sites at Old Slade, Colnbrook and Manor farm, Slough should be removed (Cemex). Q37 Reserve may also come from West Noted – this information will be used to update London and South Bucks (Cemex) the Minerals: Background Study and inform the Preferred Options. Q38 Market knowledge - There are Noted – this information will be used to update substantial supplies of sand and the Minerals: Background Study and inform the gravel used within the area that Preferred Options. originate from Oxfordshire, south close to Reading (Quarryplan (GB) Ltd) Q39 One view - yes as reflects the fact Noted – these conflicting responses raise the that less mineral is produced in the same issue and this information will be used to area (Quarryplan (GB) Ltd) update the Minerals: Background Study and No - more likely to be exhaustion of inform the Preferred Options. existing reserves (Savills on behalf of the Rayner Family Trust) Noted – this information needs to be more It is queried where the assumption of clearly presented. a ‘decline in exports’ has come from. Table 2 appears to show that there has been an increase in exports of sand and gravel in Berkshire from 2009 – 2014, as consumption of sand and gravel has decreased, but sales have increased. This is supported by the Aggregate Monitoring 2014 data, which shows that 39% of aggregates were exported in 2009, and 72% in 2014 (Oxfordshire County Council). Q41 Sales data was provided from some Noted. operators (Egon Environmental and Cemex) Q42 Three year average does not Noted. account for substantial imports via surrounding rail depots (Quarryplan (GB) Ltd). Demand will be likely to grow (Savills on behalf of the Rayner Family Trust) Q43 Other relevant local information Noted – however, there is a lack of clear data regarding future demand trends and on trends associated with infrastructure major infrastructure projects (Surrey projects and what the likely mineral demand County Council). will be in relation to projects. Uncertainty of destination from sales (Arborfield and Newland Parish Council).
Not a true figure provided, plus projects such as Heathrow to create further demand (Egon Environmental). Q44 Soft Sand not naturally occurring in Noted – this exercise is already being Berkshire, has to be imported (Egon undertaken. Environmental). Look at West Berkshire methods (Grundon). Q45 Not if suitable reserves can be found Noted – this information will be used to update (Cemex). the Minerals: Background Study and inform the If imports of soft sand are solely to Preferred Options. be relied upon for the Plan area over the Plan period, then this will need to be identified and secured through the Duty to Cooperate. However, Minerals Background Paper paragraph 5.105 implies that provision will be made for soft sand in the Plan (Oxfordshire County Council). Q46 Suggestions included sites put Noted – this information will be used to update forward in Call for sites. Identify the Minerals: Background Study, Safeguarding Preferred Areas to allow flexibility Study and inform the Preferred Options. (Mineral Products Association). Soft Sand resources are constrained, existing reserves should be safeguarded (Surrey County Council). Are there reasons preventing sites coming forward (Cemex). Identify new areas of search for soft sand in the new mineral local plan (Savills on behalf of the Rayner Family Trust). Allocation of sites, policy criteria to enable sites to come forward and a recognition in policy that there is an ongoing requirement that can't be met from sand and gravel deposits (Grundon). Q47 No - supply is constrained by Noted – this information will be used to update availability of operational sites and the Minerals: Background Study and inform the reliance on imports (Quarryplan (GB) Preferred Options. Ltd). Historically, output has been constrained by limited number of sites and processing plants. Demand may be higher than supply (Savills on behalf of the Rayner Family Trust). Q48 Reliance on imports (Quarryplan Noted – this information will be used to update (GB) Ltd) the Minerals: Background Study and inform the A landbank of 8.8 years is a better Preferred Options. reflection of supply but historic output has been constrained by the limited number of sites and
processing plants within Central & Eastern Berkshire. Demand is likely to be considerably higher than supply (Savills on behalf of the Rayner Family Trust). Subject to assessment of other relevant local information (other than the 3 year average) that may influence future demand (Surrey County Council). Q50 Demand for sand and gravel will Noted - there is a degree of uncertainty within grow as the economy improves and the projections as issues such as the Heathrow as sites are exhausted (Quarryplan Expansion are likely to have impacts on the (GB) Ltd and Savills on behalf of the Plan Area. It is it is proposed that the Joint Rayner Family Trust). Minerals & Waste Plan will contain a Plan should be flexible to allow for monitoring indicators and triggers to prompt an additional resources to be developed early review of the plan should changes arise later in the plan period. Demand will from these issues, and any others. grow to meet construction needs; 9 million tonnes should be the absolute minimum Future reviews can continue if sites are not forthcoming now. (Savills on behalf of the Rayner Family Trust). Q51 Subject to the need to conserve Noted – this information will be used to update archaeological remains (Historic the Minerals: Background Study and inform the England). Preferred Options. Important to include previous preferred options. Identified a preferred area which was not identified in background papers (Quarryplan (GB) Ltd). Site 8 is housing, site 13 has lost half to railway standoff with a current Network Rail application (Grundon). Slough sites unlikely to be viable (Slough Borough Council). Not all remaining sites are available or within plan area (Cemex). Q52 Information regarding a few of the Noted – this information will be used to update preferred areas status was the Minerals: Background Study and inform the submitted (Cemex, Savills on behalf Preferred Options. of the Rayner Family Trust and Quarryplan (GB) Ltd). Q55 Other sources of sustainable Noted. material (Datchet Parish Council) Q57 Comment: The use of clay for lining Noted – it is recognised that there will be a waste pits means a demand for this need to monitor the use/sales of clay during has the potential to rise with the Plan period. increased development. Although the aspiration of the Plan is to reduce reliance on landfill sites, it would be short sighted to exclude from long-term planning for the Central and Eastern Berkshire area the possibility of new landfill sites and other mineral needs raised by
potential new development (Clewer Manor Area Profile). Waste Q71 Addition of local information may The Environment Agency Waste Data enhance this. E.g. new quarries Interrogator will continue to be the main source which have not accepted waste yet of information as local surveys will only identify (Environment Agency) tonnages processed within the planning area and will not account for processing outside of Central & Eastern Berkshire.
Local information where possible however will be sought. For example, a capacity survey is now being undertaken. Q74 Highlighted transfer sites do not Transfer tonnes for Non-hazardous, Inert and manage waste, only transfer. This Hazardous waste are specifically identified in was taken into account in figures Tables 8, 10 and 12 respectively. (Grundon). The use of waste received as a Agreed, please also see response to Q.71 proxy for waste management above. In addition, a number of sources for capacity should only be an interim waste capacity will be explored with reference position until more accurate data is to different confidence levels. obtained (Oxfordshire County Council) Q75 Waste Data Flow – Department for Waste Data Flow will be used to provide Environment, Food and Rural Affairs accurate arising figures for LACW, as a (DEFRA) (should be included in component within the Household Industrial and Environment Agency Waste Data Commercial waste stream. Interrogator) (Royal Borough of Windsor and Maidenhead) Noted, to be considered for the Preferred Greater recognition of smaller Options consultation. facilities in UK for specialist hazardous waste. Some sites are not regulated by Environment Agency so have no precise data. Environment Agency permitted void As above. data (Environment Agency). As per response to Q.71 above. Radioactive data (Grundon).
Lack of up to date data. Suggestion of annual surveys (Biffa) Q78 Support for method. Offer from other Noted. Mineral Planning Authority to compare if necessary (Surrey County Council). Noted. Weighting of capacity estimates will be explored as other Waste Planning Authorities Differing weight should be applied to have done. Please also refer to Q.74 comment different methods depending on their above. robustness (Biffa).
Q82 DEFRA’s published data “UK Other methodologies will be explored in the Statistics on Waste” (December Preferred Options consultation. 2016) and “Digest of Waste and Resource Statistics” (March 2017) (Biffa) Different growth rates will be applied. Household Municipal Waste from Waste Data
Various Commercial & Industrial Flow will be subtracted from Household surveys have been undertaken each Industrial and Commercial Environment producing different results due to Agency Waste Data Interrogator to give differing criteria and survey samples. Commercial & Industrial. There is only a need to separate the two if differing growth rates are being applied. If this is required subtracting household from Waste Data Interrogator data would give Commercial & Industrial (Grundon) Q83 Support for the facility in performing Noted. an important local role. Treatment of waste is encouraged in terms of the waste hierarchy. Replacement is essential as no other alternatives, and currently deals with 50% of tonnage in Table 6 (Heathrow, Grundon). Q84 The phrasing of the question is Noted. unclear (Clewer Manor Area Profile) Q85 If it is not possible to cater for the ‘Duty to Cooperate’ meetings are forthcoming. disposal needs of the Plan area over the Plan period, then provision from other areas should be secured through the duty to cooperate. The Plan could also include general landfill policy, should there be potential to meet disposal needs within the Plan area at some stage (Oxfordshire County Council) Q87 Highlights poorly operated inert Noted. landfill which can pose similar risks to non-hazardous landfill. Any protection of inert sites is less than non-hazardous - may impact (Environment Agency) Q88 Benefits were encouraged Noted. (Quarryplan) Q89 Environment Agency Waste Data Noted. Environment Agency Waste Data Interrogator, but recognises its Interrogator limitations included with the report. limitations (Grundon) Q91 Motor trade, construction & Noted. demolition firms, waste firms, healthcare (Grundon) Q92 Support from Thames Water. Noted, to be considered for the Preferred Many of the identified wastes will be Options consultation. covered by inert, non-hazardous, or hazardous waste streams already identified. Agricultural waste should be considered, as identified in planning practice guidance (Oxfordshire County Council) Q94 Environment Agency, Local Noted, these are all sources considered. authorities, Government agencies (Binfield Parish Council) Q95 Comment encouraging the Plan to As per response to Q.92 recognise importance of hazardous
landfill, a resource required throughout the Plan to manage certain types of waste where landfill is most appropriate (e.g. asbestos) (Biffa) Q96 Predicted economic/development A range of growth estimates will be applied to growth should factored into the satisfy several of the comments received. An assessment (Quarryplan) average would be considered if practical for the Preferred Options Consultation. Q97 Three years would be more accurate As per response to Q.96 (Savills on behalf of the Rayner Family Trust) Q101 Population and Industry Growth As per response to Q.96 (Egon Environmental)
Construction and Economy activity. Commercial and Industrial amounts are considered similar to municipal waste (Grundon)
Reduction in green waste per household. Changes in domestic ‘garbage’ waste from decreasing supermarket bulky packaging, and increase in packaging of pre-cooked food (Member of Green Party and Friends of the Earth).
DEFRA stats – Forecasting 2020 waste arisings and treatment capacity 2013 (Biffa) Q103 Refer to reduction in green waste as As per response to Q.96 household compost more with smaller gardens. Decrease in supermarket bulky packaging and increase in consumption of packaged cooked food.
Comparison with other local plan suggestions. Q104 Scenario 3 – ‘Recovery Scenario is ‘what could happen if we plan to Improvement’ is contrary to the divert as much as possible from landfill, waste hierarchy. It may impede the including through the provision of more Energy flow of waste to recycling facilities if from Waste facilities’. This scenario focuses on recovery capacity is maximised diverting waste from landfill to recovery. (Oxfordshire County Council) Q105 It is suggested that the last two Noted. scenarios appear to assume that there is scope for increasing the amount of waste diverted from landfill. It is not accepted that there is substantial scope for further diversion from landfill. Landfilling of wastes is a reduced activity apart from materials that cannot be dealt with by other
methods/uses such as non- recyclable arisings from construction and excavation projects (Quarryplan). Q106 Question as to whether these Noted. The need to drive waste management realistic scenarios based on current up the waste hierarchy and the objective of net national policy - i.e. the need to drive self-sufficiency are included within the options. waste management up the waste hierarchy and the objective of net- self sufficiency would seem to preclude most of these (Surrey Noted, aligns with Recycling improvement County Council). scenario.
Improving of recycling with better options including separation at source of domestic products - Noted. greater types of plastic accepted (Environment Agency).
Most likely is a combination of the 4 proposals which all provide benefits to meeting sustainable waste management. Landfill should be considered within the Plan. Especially as some material like particular hazardous material is required to be sent to landfill. Perhaps new inert landfill opportunities in coherence with new quarry sites (Biffa). Q108 The first two categories should be Design measures and location criteria would removed as all waste operations be used to mitigate impact on air quality; should be undertaken within bioaerosol emissions, dust and other buildings to ensure the operations do environmental planning issues are discussed not have a detrimental impact on air within the first two categories of Annex 3. quality. An additional category is required for deposit of waste for Deposit of waste for recovery (Deposit for recovery (Deposit for Recovery) Recovery) would be included in Categories operations (Environment Agency). Five and Six. Q109 Avoiding Source Protection Zone's, Noted. and noise/traffic/smell (Environment Agency). Q113 Inadequate road network (Parish Noted. Council) Q114 Slough and other principal rail heads Noted. (Resident).
Reading (Binfield Parish Council).
Support to encourage sites (Biffa). Accompanying Documents Final A preferred area was not included in Noted – this information will be used to update section the background study (not the Minerals: Background Study and inform the Q115 referenced the site as unsure if it is Preferred Options. confidential). (Quarryplan) The document assumes there are only aggregate sources within
Wokingham and Royal Borough of Windsor and Maidenhead, there are also resources within Bracknell. (Grundon) The air quality impact with regards to the transport of minerals is also a key consideration in the south east region. In the past air quality issues have focused on dust from mineral sites. A missing element of the background study is the potential to have future rail depots within the plan area. (Cemex) Q116 The only other answer, which in our Noted – this information will be used to update opinion is unacceptable, is to the Waste: Background Study and inform the continue with a fractured disjointed Preferred Options. approach that leads to dumping it on someone else. (Datchet Parish Council) Recommended to reference The Environment Agency’s approach to groundwater protection. The Environment Agency is likely to object to any new landfills within the Inner Source Protection Zone of a Wraysbury Parish Council – The authorities potable abstraction. (Environment have investigated the site mentioned and it is Agency) not within the Plan area. It seems to miss out a complete category of Waste Management sites, namely those defining themselves as waste recycling centres such as Fowles in Hythe End, Wraysbury (Wraysbury Parish Council) Preferred area 25 (North of Horton) is a saved policy from the waste local plan for Berkshire 1998. The site continues to enjoy the status of preferred area for inert waste disposal (Savills on behalf of the Rayner Family Trust). General comments made by Oxfordshire County Council on the following: Transfer Facilities Net Self-sufficiency Waste Management Targets The Role of Slough Unitary Authority Specific comments made by Oxfordshire County Council. Q117 Where archaeological remains are Noted – this information will be used to update known to exist, or there is a high the Sites Assessment Methodology and inform potential for such remains, further the Preferred Options investigation should be undertaken prior to a site being considered
suitable for allocation. (Historic England) The historic environment should include designated heritage assets, assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments and other non- designated assets such as historic Noted – this information will be used to update landscapes. The other assessments the Sites Assessment Methodology and inform referred to in paragraph 4.27 should the Preferred Options. include specific archaeological studies e.g. of Palaeolithic remains (Historic England). Within Appendix 2 – Traffic Light Scoring Criteria, in the Opportunity/Constraint column for Water Environment, the opportunities for enhancement of watercourses and their associated corridors should be included. It should be made clear that watercourses should not be included in the extraction areas, but instead should have buffer zones free from any activity/operation associated with development/extraction. This should be applied to all The reference to sites with ‘strong or the watercourses. (Environment Agency) strongest presumption against gravel Stage 1 Assessment is to be extraction’ refers to existing Policy set out in undertaken using a GIS layer but the Berkshire Replacement Minerals Local using Table 1, paragraph 4.17 and Plan. These areas were established as there Appendix 2 – seem to imply greater were allocations set out in the Plan which were knowledge of the sites and more required to meet mineral demand established detailed assessment work. at that time. As the Joint Minerals & Waste These criteria and assessment Plan is being prepared 16 years after the methodology appear more Replacement Plan was updated, mineral appropriate to Stage 2. A desk demand is being reassessed and all site based assessment is unlikely to be allocations and options are being re-examined able to include such value judgments and therefore, it is not practicable to rule out unless a site visit has been made? sites other than the remaining allocations in the (Cemex) 2001 Plan. In the Site Assessment Methodology Traffic Light screening process there is no mention that sites with strong or the strongest presumption against gravel should NOT be considered or should be flagged Red. We put it to the assessment team that this should be included in the initial screening method i.e. to eliminate or flag sites that have the strongest or strong presumption against gravel extraction. (Resident)
Q118 The South East Plan deals with the Noted – the assessments will be reviewed and Thames Basin Heaths special updated where necessary. protection area. Our concern is this has a chipping away effect on natural habitats, the Green Belt, and an unknown effect on flooding, this type of land can store copious amounts of water. The sites referred to must be protected as such within the Thames basin. (Datchet Parish Council) Detailed but generic document, explaining how the listed criteria will be assessed. Each site will obviously have its own unique constraints and detailed reports including forms of mitigation should be used to demonstrate the acceptance of a site. (Egon Environmental) The Sites Assessments methodology in Appendix 2 and the Landscape and Transport methodologies need to be consistent. (Cemex) Q119 This is essential, wherever it is Noted. relevant to the issues. (Resident and member of the Green Party and Friends of the Earth) General Comments General Historic England commented on the Noted – this information will be used to update Comments following paragraphs of the Issues & the evidence base and inform the Preferred Options consultation paper: Options. Paragraphs 2.3 and 2.6 Paragraph 3.4 Paragraphs 5.1 – 5.3 The Environment Agency commented on the following sections of the Issues & Options consultation paper: Glossary Section 3. Biodiversity (Flora and Fauna) Section 5. Water, under ‘Surface Water’, paragraphs 5.5 to 5.8 Figure 5.4 (Plan Area River Catchments) section 5.19 Savills on behalf of the Rayner Family Trust provided the following comments on the Issues & Options consultation paper: Preferred Area 12 retains its status in the Saved Replacement Mineral Local Plan and Preferred Area 25 in the Waste Local Plan and as such
should be referred to in the Minerals Background Paper.
Regulation 18 Draft Plan Consultation (2018)
DM Policies
General Issue Response The Policies need to be tightly worded to prevent a Noted. spread of development beyond that which is absolutely justified. DM2 – Support its important to have a positive view Noted. of environment protection, DM4 – Supported it provides a facility to ensure post extraction repair work, DM5 Support – Green Belt is very important. DM7 – Support It must always be managed intensively DM9 – Support Must have due deference to flooding issues as high risk DM10 – Very important
DM1 Issue Response Policy DM1 - support for the policy but those The Development Management (DM) Policies in implementing it have not complied with legal the Joint Minerals & Waste Plan will be used to requirements and 'Duty of care' [ref Star Works]. determine planning applications post-adoption (2020) and will be a material consideration in decision-making as the plan progresses. Policy DM1 – it fails to meet the test of soundness National planning policy requires the Central & as there should be a presumption away from Eastern Berkshire Authorities to prepare a plan development in Central and Eastern Berkshire [ref which sets out an overall strategy for the pattern, Star Works]. scale and quality of development, and make sufficient provision for both minerals and waste management. DM1 – Support this policy approach, but would Policy M2 iii states that development would be suggest that this needs to be extended to reflect the permitted in a mineral safeguarding area if it consideration of non-minerals development would be inappropriate to extract with regard to proposals within Minerals Safeguarding Areas in a other policies in the Local Development Plan. In manner that reflects the advice contained in addition, para 5.37 refers to ‘projects of Recommendation 9 of the Minerals & Waste overriding importance in the Central & Eastern Safeguarding Study. Berkshire Authorities’ Local Plans to proceed where this can be demonstrated’. Sustainable development (page 74 to 75) [DM1] - Policy DM1 states that the Central & Eastern The policy needs to be more pro-active and identify Berkshire Authorities will work ‘proactively with that the consequences of any decision will have an applicants’. The Plan will be monitored annually impact for decades. The current plan is based on to assess the effectiveness of the Policies. the past and not the future of how waste will not just Policy DM12 (High Quality Design of Minerals & be dealt with but also produced. There are no Waste Development) seeks to encourage more measures too incentivise 'green' behaviour. sustainable developments. Paragraph 7.4: Welcome a commitment within Noted. paragraph 7.4 for the minerals planning authorities to consult in a timely fashion.
DM2
Issue Response DM2 - Another useful metric to record would be the Para. 7.10 of the Draft Plan makes specific carbon cost/emissions of the transport and handling reference to Policy DM11 which seeks to permit of both Mineral and Waste, by category. The traffic sites with good connectivity. The need for routing of HGVs and their access to the SRN would carbon assessments will be considered as part have an impact to this and should be considered in of the review of this policy. site assessment. Policy DM2 Climate Change – Mitigation and Noted – the wording of Policy DM2, Para. 7.7 adaptation- This policy should state that and 7.8 will be reviewed. development should not result in increased flood risk elsewhere and where possible reduce flood risk The supporting text to the policy already cross- overall. references to draft Policy DM10 (Water Paragraph 7.7 - This paragraph needs to include a Environment and Flood Risk) which is where the sentence about the increase in flood risk as a result need for site-specific FRAs should be addressed of climate change. A reference back to the SFRA rather than repeated under Policy DM2. should discuss the impacts of climate change on flood risk and how this should be assessed in a site-specific FRA. Paragraph 7.8 - This says, ‘Opportunities for water storage in flood zones’. Generally, for additional floodplain storage to be created, land outside of flood zones needs to be lowered. Therefore suggest this is changed to ‘opportunities for increasing floodplain storage when sites are restored’. Climate change mitigation and adaptation [DM2] - Noted. Climate change requires that no trees are removed. The need is for more tree so that more CO2 can be removed from the atmosphere.
DM3 Issue Response Policy DM3 - against Star Works being included in Appendix A of the Draft Plan outlines the the plan for the following reasons: Linden Hill wood Development considerations which would need is an ancient and protected wood and the area has to be addressed by any further development been designated “a local wildlife site and within an proposals at the Star Works site and include area of special landscape importance” as described reference to the Local Wildlife Sites. in a legal search upon the purchase of our house and woodlands. We have a habitat that needs to be Further landfill is not proposed at the site. The protected, including active badger setts in the woods, site has existing planning permissions for waste great crested newts in the streams. I have seen a management uses. The allocation of Star great crested newt in our pond (pictures as evidence) Works considers an extension of these that would have come from the stream that runs from operations. Any proposals for development the top of the hill near the Star Works site. To create would need to comply with all relevant policies in more landfill area at Star Works would have a the Joint Minerals & Waste Plan including Policy detrimental effect on all this habitat and it needs to be DM3. looked after. This is a responsibility that needs to be taken seriously by you the councillors for the future of All information received regarding the proposed our increasingly precious land. site allocations will be taken into consideration in the preparation of the Proposed Submission plan. Policy DM3 - Flood risks, river contamination close to Flood risk issues would be addressed by Policy Thames water intakes, loss of habitat for endangered DM10 (Water Environment and Flood Risk). birds i.e. Kingfisher plus water voles. Noise and air Contamination issues would be addressed by pollution from large diesel engines with no exhaust Policy DM9 (Protecting Public Health, Safety filters. [ref Riding Court Farm, Ham Island] and Amenity). It is recognised that further
consideration needs to be given to the river corridors and this will be addressed in the Proposed Submission Plan.
All information received regarding the proposed site allocations will be taken into consideration in the preparation of the Proposed Submission plan. Policy DM3 – Change sought to policy - remove Ham Noted. Island and Riding Farm from site list. DM3 - The minerals and waste site allocations and Noted. activities have the potential to negatively impact the environment, however the draft plan sets out sound policies to ensure the natural environment is protected. Specifically, policy DM3 which sets out the criteria against which developments will be judged. DM3 - The layout of policy DM3 is confusing as the Noted – the format of Policy DM3 will be list is set out as a, b, a, b, c, c - Support the inclusion reviewed. of the second c, "features of the landscape that function as stepping stones, or form part of a wider Additional paragraph 7.22 added to supporting network of sites..." however, if these sites are not text. identified at the plan stage, then there needs to be a set of criteria which sets out whether or not a habitat or land parcel fulfills this function, and can receive subsequent protection. DM3 - Watercourses need to be specifically It is recognised that river corridors and mentioned here – the important habitats list doesn’t watercourses need to be addressed in more mention rivers etc. detail in the Proposed Submission Plan. NPPF references will also be amended to reflect the Nature conservation and river corridors - We have 2018 revision. As such, the points raised will be serious concerns with regard to the protection and taken into account. enhancement of river corridors, and that the Joint Minerals and Waste Plan could be more effective and New Para 7.17 and 7.23 re: river/river corridors reflect national planning policies (NPPF) 170, 174 added to supporting text. and 175. Within the plan there is no single clear message to developers on the standards which must Flood risk has been separated from the Water be met with regard to development in river corridors; Resources policy. a number of other policies deal with various aspects of protecting watercourses, but this gives us no 16 metre buffer zone requirement incorporated comfort that this Joint Minerals and Waste Plan in new paragraph in Water Resources Section. specifically addresses the exclusive requirements of river corridors. Watercourses are not covered in any detail in this plan. A specific river habitat policy is required to ensure the best possible outcomes for watercourses impacted by minerals and waste sites. This needs to cover the protection and enhancement of rivers and their corridors. Watercourses are important environmental assets and an undeveloped Text added to current para 7.17 to provide 16 meter buffer zone (Thames Region Land additional text based on NPPF para 170. Drainage Byelaws, as amended) should be required on both sides of a main river to promote strong and resilient ecosystems, green and blue infrastructure links, water quality and human health (pleasant amenity space). The policy should make it clear to applicants how the Joint Minerals and Waste Plan will expect protection and enhancement of all watercourses. This policy will reduce the likelihood
that new developments next to main rivers will contribute to the deterioration of the ecological status of the waterbodies and where feasible will contribute to raising their status while providing a pleasant living environment with the associated positive social and Addition text added o the importance of river health benefits. This will make the Joint Minerals and corridors. Waste Plan more consistent with paragraphs 170 and 174 of the NPPF, water framework directive (WFD) requirements and numerous tenets of HM Government’s 25 Year Environment Plan which will embed an “environmental net gain” principle for development and “recover nature” and “enhance the beauty” of landscapes. Paragraph 170 of the NPPF recognises that planning decisions should contribute and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. It states that development should, wherever possible, help to improve local environment conditions, taking into account relevant information such as river basin management plans. Paragraph 174 recognises that plans should promote the conservation, restoration and enhancement of priority habitats and ecological networks; and identify and pursue opportunities for securing measurable net gains for biodiversity. A good example of where a watercourse policy has been applied locally is in Wycombe District Council’s Adopted Delivery and Site Allocations Plan for Town Centres and Managing Development (July 2013), with the inclusion of Policy DM15 Protection and Enhancement of River and Stream Corridors. Alongside this sits Wycombe DC’s River Wye Advice Note giving advice to developers and landowners with land adjoining watercourses. Article 10 of the Habitats Directive stresses the importance of natural networks of linked habitat corridors to allow the movement of species between suitable habitats, and promote the expansion of biodiversity. River corridors are particularly effective in this way and the network of river corridors may help wildlife adapt to climate change by providing a migration corridor. Policy DM3 as presently proposed fails to comply The Draft Plan was prepared prior to the with the revised NPPF 2018. The first paragraph publication of the revised NPPF in 2018 and all requires rewording to be policy compliant. The NPPF references will be reviewed and amended requires for development to be permitted, that it must accordingly. avoid adverse impacts, mitigate for impacts that cannot be avoided, then as a last resort compensate Ancient woodland point actioned. for remaining residual impacts (NPPF paragraph 175a) and ultimately ensure a net positive impact on ‘Demonstrably and significantly’ added. biodiversity (NPPF paragraph 170d). There is a difference between the NPPF requirement to support ‘measurable net gain’ added. development whose primary purpose is biodiversity conservation (paragraph 175d) and minerals and Amended made in relation to SSSI. waste schemes in which there is a contribution to conservation, restoration or enhancement of
biodiversity (Policy DM3). We consider that the latter should not receive blanket support under Policy DM3. Policy compliant wording would be to replace "will be permitted" with "will be encouraged", in line with NPPF paragraph 175d.
In the list of sites, habitats and species to be protected, ancient woodland appears twice, with differing degrees of "relative importance". The NPPF give clear and specific policy guidance in relation to irreplaceable habitats including ancient woodland and aged and veteran trees. The NPPF requires development that may harm irreplaceable habitats to be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists (NPPF 175c). For Policy DM3 to be NPPF compliant, the Policy must include the wording "wholly exceptional reasons" in relation to harm to irreplaceable habitats. Similar to the statement above, but in relation to SSSIs, the NPPF is clear (paragraph 175b) that any development affecting SSSIs will not normally be permitted with the only exception being where the benefits of the development in that particular location clearly outweigh both its impact on that SSSI and the wider network of SSSIs. The wording in Policy DM3 is not sufficient to reflect this emphasis on refusing inappropriate development, and for demonstrating clearly that the merits of the development in that location outweigh adverse impacts on the SSSI and SSSI network. We propose that it is clearly stated that any development likely to harm a SSSI or the SSSI network will be refused unless the benefits as described above are clearly demonstrated. The list of ecological features that should be protected appears incomplete; in order to be compliant with the NPPF, this list should include (as per paragraph 174a) wildlife corridors and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation. It is considered that the statement: "1. In proportion to their relative importance (alone or as part of a wider network), that the merits of the development outweigh any likely environmental damage;" is not NPPF compliant. In order to be NPPF compliant, the following wording is proposed; "1. In proportion to their relative importance (alone or as part of a wider network), that the merits of the development demonstrably and significantly outweigh any likely environmental damage;" Policy DM3 as currently proposed makes no reference to the NPPF requirement to identify and pursue opportunities for measurable net gains in biodiversity (174b) and to encourage biodiversity enhancement for proposed development where this can secure measurable net gains for biodiversity (175d). This requirement should be added to Policy DM3 thereby ensuring that the
Plan is suitably compliant with the NPPF and that all allocated mineral and waste sites, plus those that may be proposed at a later date, provide adequate baseline data on biodiversity in a consistent format and propose habitat enhancements that can be quantified and monitored using a suitable biodiversity metric (i.e. based on the Defra biodiversity accounting methodology) in order to secure measurable biodiversity gains. In relation to paragraph 7.14, the statement to "avoid any net loss of biodiversity as a result of development" is insufficient and not compliant with the NPPF which talks in terms of protecting and enhancing the natural environment, and minimising impacts on and securing measurable net gains in biodiversity. This statement should be reworded as follows; "The Central and Eastern Berkshire Authorities will seek to secure measurable net gains in biodiversity as a result of development..." In relation to paragraph 7.15, the statement as it relates to "networks for biodiversity and green infrastructure" is superseded by the requirements in the revised NPPF to broaden this and, more specifically, include the hierarchy of designated biodiversity sites, wildlife corridors, stepping stones that connect them, areas identified by local and national partnerships for habitat management, enhancement, restoration and creation, priority habitats, ecological networks, and recovery of priority species. In relation to Monitoring (section 7.24); Additional Noted – Indicators added to document Monitoring Indicators are proposed: - the number of planning permissions granted in which a measurable net biodiversity gain is agreed - the increase in biodiversity units resulting from development (measured using a standard biodiversity impact assessment calculator based on the Defra methodology)
DM4 Issue Response Policy DM4 – seeking a change to the policy – Each of the designations listed has different protection should not just apply to 'AONB' but in this policy requirements. As such, these are regard also to: Green Belt, Sites of Special addressed in separate DM policies including Scientific Interest, Ancient Protected Woodland DM6 (Green Belt) and DM3 (Protection of [linked to comments on Star Works] Habitats and Species). Policy DM4 Protection of Designated Landscape: Noted – the implications of DM4 and its specific we support Policy DM4 in principle, although wording will be reviewed. The policy changes applying the criteria for the assessment of will align with adopted Reading BC policy. proposals for major development within AONBs to land outside the designated landscapes, even if within their setting, goes beyond paragraph 172 of the National Planning Policy Framework
DM5
Issue Response Policy DM5 – Change sought to policy - remove Noted. Ham Island and Riding Farm from plan. Policy DM5 – seeking a change to the policy – in Policy DM5 seeks to protect the countryside and order to protect the countryside, sites should only only permits development in particular be permitted in isolated or urban areas. circumstances which are in line with national policy. Policy DM5 - against Star Works being included in All information received regarding the proposed the plan for the following reasons: The area site allocations will be taken into consideration in surrounding the Star Works, Knowl Hill site has a the preparation of the Proposed Submission significant recreational use including bridleways, plan. public footpaths, and sustains cycle routes. However, it is already affected by the noise, debris The operation of the existing site is an on-going and odour from the site and on many occasions, I consideration for Wokingham Borough Council. cannot use the adjacent footpaths because of the extremely bad odour, the toxic rubbish that is lying *Linked to Star Works comments around (I have dogs and they have picked up contaminated nappy rubbish as an example). This will only get worse if an extension to the site is granted. This affects not only local people but also visitors who come from surrounding conurbations who to me have expressed surprise that there is a waste site so near and affects so many at the moment.
DM6 Issue Response Inappropriate development is deemed harmful to Noted. It is recognised that more signposting on the Green Belt and should not be approved, except this issue is required and more detail provided in in very special circumstances. It is accepted that it the Waste Proposals Study. is not possible to meet the anticipated waste management needs of the Plan area without developing waste management facilities on Green Belt land. Policy W4 allocates and supports sites for delivering waste management facilities, all of which are located in the Green Belt (and all but one sites allocated under Policy M4 for sand and gravel extraction are in the Green Belt). Through the preparation of the draft JMWP and evidence based assessments and study documents, 'very special circumstances' have been demonstrated in that these sites are: the most suitable locations in relation to arisings and recyclates markets; no other appropriate sites can be found outside the Green Belt; and suitable mitigation can be provided to ensure the development would not cause harm to the objectives and purposes of the Green Belt. Sites allocated under Policy W4 (or Policy M4), should be considered as a factor contributing to 'very special circumstances' under Policy DM6. Policy DM6 – seeking a change to the policy – no Due to the limited site options made available for future waste facility would supersede the harm waste management, it is considered that ‘very done to the Green Belt. How can a waste facility special circumstances’ exist for these sites. preserve 'openness'? However, it is recognised that more detail provided should be provided in the Waste Proposals Study.
Policy DM6 - against Star Works being included in All information received regarding the proposed the plan for the following reasons: The Star Works site allocations will be taken into consideration in site is situated in an area of green belt, and also the preparation of the Proposed Submission woodland which has a tree preservation order (no plan. 4/1951) on this mixed woodland. We own 20 acres of this mixed woodland (around the opposite end of Star Lane) and were notified that all the trees are protected and not to be felled. (Even remedial work needs authorisation). Further extension works to Star Works site would cause an effect on these trees and this is totally not acceptable, yet again another example of a flagrant breach of an order which has been in working practice for many years. Green belt [DM6] - The green belt is being eroded Noted. However, mineral extraction is not from many directions and the joint minerals and considered ‘inappropriate’ development due to waste plan contributes to further erosion. its temporary nature. Waste management sites are included in the Plan as it is considered there are ‘very exceptional circumstances’ due to the lack of available sites within the Plan area. Green Belt Policy [DM6] must be upheld and there All information received regarding the proposed do not appear to be any special circumstances to site allocations will be taken into consideration in enlarge this site [Star Works] into more greenbelt. the preparation of the Proposed Submission Areas outside the Green belt must be exhausted Plan. first and proven.
DM7 Issue Response DM7 – Welcome the inclusion of policy DM7 Noted – discussions are on-going with Historic outlining the importance of the historic environment England regarding policy requirements. and the need to conserve it. The policy wording identifies assets that are likely to require See Heritage Statement for details. preservation in line with the NPPF. The proposed allocations will require careful consideration as proposals are put forward. The policy wording needs to include a requirement for archaeological field investigations to be required pre-determination for a new site. Policy DM7 Conserving the Historic Environment: Noted – the wording of Policy DM7 will be Welcome Policy DM7 in principle. However, the reviewed. first and third paragraphs largely duplicate each other, but are contradictory as the first paragraph See Heritage Statement for details. does not allow harm but the third paragraph does. The reference to “benefits” in the final paragraph of the policy should be to “public benefits”, in accordance with paragraphs 195 and 196 of the National Planning Policy Framework (2018), that can only be delivered by the proposed development In addition. The paragraph should refer to the significance of heritage assets, as the term used in the Framework and the heritage sector for the value of a heritage asset, as well as their special interest, character and appearance (which are normally used when referring to conservation areas Policy DM7 the policy should include a requirement See Heritage Statement for details. to record assets to be lost and the recording to be deposited in a public archive, but to emphasise that
the ability to do this will not be a factor in Revised wording changes agreed with HE as determining whether or not permission will be part of the Proposed Submission preparation. granted. We also consider that paragraph 7.53 should be included in the policy.
We therefore suggest that Policy DM7 be reworded as follows:
Proposals for minerals and waste developments will be required to protect and conserve, and where possible enhance, the historic environment and the significance, special interest, character or appearance of the heritage assets of the Central & Eastern Berkshire Authorities, including both designated and non-designated assets and the settings of these sites.
Harm to that significance, special interest, character or appearance will only be allowed where it is demonstrated that the harm is minimised and the need for and public benefits of the development cannot be delivered in a way that does not cause harm (e.g. locating the development on an alternative site that would result in no harm to heritage interests) and clearly and convincingly outweigh these heritage interests.
Any planning applications for minerals and waste development should therefore be informed by an assessment, proportionate to the circumstances, of the significance, special interest, character and appearance of any heritage assets that would be affected by a development proposal, of the potential impacts on those qualities and how those impacts could be avoided or minimised. This should include an appropriate level of field investigation if necessary and a screening to be submitted with the planning application.
Where harm to or loss of heritage assets would occur in the circumstances set out above, the asset should be fully recorded and the results deposited in a public archive (however, the ability to record an asset will not be a factor in determining whether or not a proposed development will be permitted).
The following assets will be protected in accordance with their relative importance:
a) Scheduled Monuments; b) Listed buildings; c) Conservation areas; d) Registered parks and gardens; e) Registered battlefields; f) Sites of archaeological importance; and g) Other locally recognised assets.
Policy DM7 - It fails to meet or take into Policy DM7 makes specific reference to the consideration the Historic character of a settlement need to ‘preserve, and where possible, enhance area as mentioned in Neighbourhood plans, as in the character or appearance of historical assets’ the case of Brock Hill and Maidens Green with its which include listed buildings, conservation many Historic, listed buildings, and ancient fabric. areas and local recognized assets. Change sought to Policy DM7 - to widen and take into consideration Historic and Ancient Fabric in addition to policy DM7
DM8 Issue Response DM8 - There is a contrasting tone between the Noted – the wording of Policy DM8 will be Restoration Study document and policy DM8. reviewed. Although paragraph 7.68 of the Draft Plan references the restoration study, it is presumably Please note that the Supporting text is part of policy DM8 against which plans will be assessed. the policy. Whilst the Restoration Study is aspirational and contains a good principles which ensure high The Restoration Study will also be updated to quality restoration, it does not appear that Policy support the Proposed Submission Plan. The DM8 ensures this level of high quality restoration is Policy will be included in the Restoration Study. actually implemented. Suggest the wording of policy DM8 is strengthened to allow planning authorities to better ensure the quality of restoration plans. Policy DM8 Restoration of Minerals and Waste Noted – The word ‘setting’ has been removed Developments: support this policy, although we from the policy. are not quite sure what is meant by the “setting of the local area”. Policy DM8 - Restoration of Minerals and Waste Noted. Development This policy relates to how mineral and waste sites will be restored after their operational Catchment Partnerships are referenced in para. use. There doesn’t appear to be any consideration 4.19 of the Restoration Study. of link up with local catchment partnerships who It is recognised that river corridors and often do a lot of work in the environment and rivers watercourses need to be addressed in more sectors on environmental enhancement projects. detail in the Proposed Submission Plan. As There may be opportunities here to work with and such, the points raised will be taken into engage with local environmental groups to address account. WFD failures in waterbodies impacted by these sites. It would be encouraging to see this included Term ‘catchment partnership’ added to in the policy. supporting text. DM8 Restoration – This policy states that ‘Planning Noted – inclusion of this text will be considered permission for minerals extraction and temporary in the review of Policy DM8. waste management development will be granted only where satisfactory provision has been made for high standards of restoration and aftercare’ We also need the inclusion of the following text in this policy:- ‘that the type of material used in this restoration of a minerals extraction site should not impact on controlled waters’. DM8 – given the timing of cashflows from mineral Planning permissions contain conditions, and, in extraction, history of delays in restoration beyond some cases, legal agreements are formed to that approval in original planning permissions and ensure that schemes are undertaken. These recent examples of private sectors failure such as are enforceable by the relevant Planning Carillion and the East Coast Rail debacle any policy Authority. needs to include broader protections for the
community and the environment. This would be facilitated by: a. Any developer depositing with a council bodies sums for restoration as any sites are developed, so that any time the council will have access to capital for the restoration of all sites should there be any private sector failures. b. This would mean that over the extraction period amounts deposited would rise and a board of independent trustees could also ensure that restoration is guaranteed and not subject to the whims and potential credit quality of developers decades into the future. c. This is the only way that Central & Eastern Berkshire Authorities can ensure that sites are restored as required and detailed contractual monitoring indicators need to be developed to be included with any Final Plan. Policies for restoration [DM8] need to be developed Noted – further consideration will be given to the to sit within an area wide approach delivering delivery of green corridors / green infrastructure. interconnected green corridors. Term ‘green and blue infrastructure strategies’ added to supporting text. Restoration of minerals and waste developments Noted. [DM8] - The restoration of areas of historic natural wood land cannot happen. Although the expectation that tree felling can be somehow justified on the grounds that new trees will be planted when a site is being restored, this is not the case since the flare and fauna have been destroyed. DM8 - Policy DM8 is supported in principle, Planning permissions contain conditions, and, in however, it is considered that the Policy lacks the some cases, legal agreements are formed to necessary ‘teeth’ to effectively enforce the ensure that schemes are undertaken. These principles of the policy are carried out [ref Star are enforceable by the relevant Planning Works]. Authority. Paragraph 3.6 and Policy DM8 Noted. We support paragraph 3 in section 3.6 Strategic Plan Objectives and Policy DM8 Restoration in terms of biodiversity
DM9 Issue Response Policy DM9 - states the use of machinery and Noted – further consideration will be given to the lighting can result in noise, light and air pollution impact on air quality from minerals and waste and that development should not generate development. unacceptable impact upon public health, or release emissions to the atmosphere - but there is no specific reference to air quality. The policy does not include appropriate policy framework for considering the impact of proposed development on air quality and securing appropriate mitigation. DM9 – the policy should require, and its Detailed mitigation measures are required at the implementation should ensure the following planning application stages and need to be provisions: a. Consideration of particulate considered on a case-by-case basis. As these emissions from heavy goods vehicles in particular will be dependent on the circumstances at the given the harmful effects recently highlighted and point an application is submitted, it is not therefore all vehicles operating from sites should be appropriate to set specific mitigation
Euro VI compliant, or any subsequent improved requirements in a Plan which will guidance standard as part of any planning permission. b. decision-making up to 2036. Given the requirements not to have an unacceptable visual impact – this should be tested on a case by case basis and the 100m minimum buffer zone, should be an absolute minimum, and this should be increased as required to satisfy the policy objective from the perspective of the members of the community so affected. c. With respect to causing unacceptable noise, dust, lighting, vibration or odour, any implementation should consider permitted operating hours, to ensure that these are within normal working hours of a weekday to ensure that no operations are conducted at weekends, early in the morning or late into the evening on weekdays. Policy DM9 – strong objection to the proposal of Ham Island has been identified as a potential Mineral Extraction and Waste Land Fill on Ham borrow pit to supply the Heathrow Airport Island as Resident of Park Avenue Riverside. expansion. The implications of the airport Increased levels of noise pollution. This is on top of expansion are being closely followed to a proposed runway, and all the works associated determine the implications for the Joint Minerals with that before it gets built. And for the record & Waste Plan. along with my neighbours I did not vote for an expansion of Heathrow, and this was certainly not mentioned at any of the meetings I attended! Policy DM9 - Will cause increased flood risk with All information received regarding the proposed high water flows and increased water levels. [ref site allocations will be taken into consideration in Ham Island and Riding Court Farm] the preparation of the Proposed Submission Plan. Policy DM9 – change sought to policy - remove Noted. Ham Island and Riding Farm from site list. Any Final Plan should include sufficient directive These policies would be applied on a case-by- detail to ensure that policy objectives with respect case basis and will be dependent on the to public health Policy DM9 Protecting Public relevant circumstances. The successful Health, Safety and Amenity and Policy DM11 implementation of the policies in relation to a Sustainable Transport Movements are met, rather specific development will be dependent on the than as currently drafted which allows to much conditions and, where relevant, the legal scope for failure to meet such policy objectives. agreements applied. DM9 - The draft policy identifies that developments Noted. handling bio-waste need a buffer zone of up to 250 metres from sensitive human receptors. This may be breached in terms of the village hall which seems to be within this in relation to the Hydroclave building and expansion could even impact the primary school. DM9 - object to policy DM9. The phrase public Noted – the wording of Policy DM9 will be health is a wide term and difficult to assess in reviewed. relation to land use and development proposals. The NPPF at Section 8 paragraphs 91-95 refer to health. Request that policy DM9 is rephrased to reflect the health of individuals and communities adjoining or in the vicinity of the development rather than the undefined term public health. Draft Policy DM9 – It is recommended that draft Impacts on human health are considered in DM9 Policy DM9 requires that minerals and waste (b). However, further consideration will be given developments demonstrate how they would prevent to reference to vermin/pests.
nuisance (and potential hygiene issues) arising from the attraction of pests/vermin.
DM10 Issue Response Policy DM10 – strong objection to the proposal of All information received regarding the proposed Mineral Extraction and Waste Land Fill on Ham site allocations will be taken into consideration in Island as Resident of Park Avenue Riverside: the preparation of the Proposed Submission Replacing flood gravel with compacted waste will Plan. not aid in the current area being maintained as a flood plain. Additional concern from the increased On-going engagement with the Environment numbers of housing developments in the local area Agency is required on flood risk and impacts on impacting upon possible future flooding the river corridors. Who would be responsible for repairing damages made to privately owned pontoons and moored *Linked to Ham Island comments boats? It is one of the narrowest points of the Thames, and below the Jubilee River bypass which creates flood conditions for the local area. Damage to wild life will be considerable including recreational fishing. Visitors come and admire the natural nature of the area. Policy DM10 - Increased risk of flooding any sand All information received regarding the proposed or gravel is already under the average water table site allocations will be taken into consideration in level and all proposed workings, including, wharfs the preparation of the Proposed Submission and equipment that will be under water during high Plan. floods as the river is flat across the weir at the top end of Ham. There is a bund across Ham Island On-going engagement with the Environment that helps stop the water flow across the Island and Agency is required on flood risk and impacts on protect the sewage plant and houses. [ref Ham the river corridors. Island and Riding Court Farm] Policy DM10 – change sought to policy – remove Noted. Ham Island and Riding Court Farm from proposed site list Welcome the recognition within the text which Noted. accompanies Policy DM10 – Water environment and flood risk.
There is a need therefore to guard against adverse It is recognised that further consideration needs impacts such as environmental damage resulting to be given to the river corridors, flood risk and from changes to the water table; a safeguard which hydrology. These will be addressed in more is currently absent from this development detail in the Proposed Submission Plan. management policy. Accordingly, we suggest that a 3rd item is added to the wording of Policy DM10: Consideration will also be given to the inclusion Water Environment and Flood Risk so that it is on an additional criterion as suggested. clear planning permission will be granted for minerals and water development where proposals do not: (c) Have an unacceptable impact on the geophysical or hydrological properties of adjacent land. Policy DM10 – Water Environment and Flood Risk - It is recognised that river corridors and This policy and its supporting text covers flood risk, watercourses need to be addressed in more water quality and water resources. These three detail in the Proposed Submission Plan. As issues should all be covered by separate policies. such, the points raised will be taken into The following wording could be used as a flood risk account. policy: “Flood risk management Minerals and waste
development in areas at risk of flooding should: a) Apply the sequential test, exception test and sequential approach within the development site directing the most vulnerable development to the areas at lowest risk from flooding b) Not result in an increased flood risk elsewhere and seek to reduce flood risk overall; c) ensure development is safe from flooding for its lifetime including an assessment of climate change impacts d) Incorporate flood protection, flood resilience and resistance measures where appropriate to the character and biodiversity of the area and the specific requirements of the site; e) Include site drainage systems designed to take account of events which exceed the normal design standard; f) Not increase net surface water run-off; and g) If appropriate, incorporate Sustainable Drainage Systems to manage surface water drainage, with whole-life management and maintenance arrangements.” The following wording could be used for a water quality policy “Water quality Planning permission will be granted for minerals and waste development where proposals do not: a) Result in the deterioration of the physical state, water quality or ecological status of any water resource and waterbody including, rivers, streams, lakes, ponds, groundwater source protection zones and ground water aquifers. b) Include a hydrogeological risk assessment (HRA) where proposals are in a groundwater source protection zone. If the HRA identifies unacceptable risks then the developer must provide appropriate mitigation.” Water resources: Water resources is about The issue of hydrological connectivity to SSSIs availability of water and the supply. We do not want would be taken into consideration under draft the proposed site allocations to impact upon water Policy DM 3 (Protection of habitats and species). availability. The extraction of minerals can have an impact upon groundwater and surface water Draft Policy DM10 (Water Environment and supplies & therefore groundwater or surface water Flood Risk) addresses impacts on water quality fed features such as Sites of Special Scientific and groundwater protection zones. Interest (SSSIs). We can work with you on the Consideration will be given to including a wording of a suitable policy for this issue. reference to the availability of water resources in Policy DM10. DM10 - Horton is liable to flood and part of or some All information received regarding the proposed of the sites fall within the flood risk 3 category site allocations will be taken into consideration in (Berkyn Manor). Any proposal for infill must be the preparation of the Proposed Submission seriously assessed and controlled, particularly for Plan. infill of green waste. Change sought - We do not feel there is adequate Detailed mitigation measures would be required detail in the Draft Mineral Plan covering this as part of any planning application. proposal. DM10 - South East Water has reviewed this draft Noted. plan and would like to ensure that all risks to surface and groundwater quality have been adequately assessed and mitigated for as well as confirmation from the applicant that there is no intention to abstract or impinge upon groundwater level, flow or yield. We are requesting additional
details showing what will go into your hydrogeological studies and copies of these reports once completed for any sites where planning is submitted. This is due to the fact that many of the sites are located within Groundwater Source Protection Zones 1, 2 and 3 (as acknowledged at each site in your draft Plan). This is in line with your Policy DM10 which states that no application will be approved which causes an unacceptable impact on SPZ. Paragraph 7.82 - This may need to be revised in Para. 7.82 - noted. light of the suggested policy wording above. Paragraph 7.83 - This paragraph should be Para. 7.83 – Suggested wording is agreed. changed to: “Mineral extraction may provide opportunities for flooding to be alleviated by Para. 7.84 – Will be amended to more providing additional floodplain storage when the accurately reflect the Planning Practice area is restored.” Paragraph 7.84 - This paragraph Guidance. says: “Landfill and hazardous waste facilities will not be permitted in Flood Risk Zones 3a and 3b” Paragraph 7.85 - We are pleased to see that the Para. 7.85 – noted. sequential test and exaction test are acknowledge in this paragraph. It may need revising and Para. 7.86 – noted. reordering in light of the suggested policy paragraphs above. Paragraph 7.85 also says : “Where a flood risk is identified…….” This should be changed to “Where flood risk is identified…….” The ‘a’ is not necessary. Paragraph 7.86 For this paragraph you can refer to footnote 50 in the NPPF which sets out when a flood risk assessment is required.
DM11 Issue Response Policy 11 - poorly drafted, it does not deal with the Detailed mitigation measures are required at the impact of vehicle movements upon air quality, it planning application stages and need to be does not include the full range of possible mitigation considered on a case-by-case basis. As these measures and does not specifically cover the issue will be dependent on the circumstances at the of lorry routing. The policies in the plan are point an application is submitted, it is not generally worded to say that “proposals will only be appropriate to set specific mitigation requirements in a Plan which will guidance permitted where….” Policy DM11 does not include decision-making up to 2036. this wording but simply states that “A Transport
Assessment or Statement of potential impacts on Para. 7.93 recognises the potential for impacts highway safety, congestion and demand on air quality. management will be required”. The assessment should “explore” how movements will not be detrimental to road safety and would not have an unacceptable impact upon the environment or local community to determine whether highway improvements may be required. It does not set out the basis upon which applications will be approved or refused. The only mitigation referred to is highway improvements, however there are other measures that could be used to mitigate impacts. There is no mention of the need to control the type
of vehicle being used to reduce the impact on air quality.
Policy 11 - does not deal with the impact of Greater emphasis will be placed on the link increased vehicle movements upon air quality. The between vehicle movements and impacts on air text of the plan lists potential environmental impacts quality in the Proposed Submission plan. of traffic as noise, dust, vibration, congestion and Figure 7 to be replaced within Proposed carbon dioxide emissions. The only reference to Submission Plan. The STA will also be reviewed particulates and air quality is in the text which deals at section 2.16 to clarify that air quality will be assessed through environmental statements with the impact from the use of field conveyers. where required DM11 - paragraphs 2.15 and 2.16 of the Strategic Reference to ‘unacceptable transport impacts’ Transport & Traffic Assessment set out the guiding will be included in the supporting text to Policy principles which include that mineral and waste DM11. development should not result in unacceptable levels of traffic congestion and specifically should not have unacceptable transport impacts on the local environment, communities and road network. The reference to unacceptable impact on the road network is however omitted within the text of policy DM11. DM11 - paragraph 7.91 of the supporting text for The Proposed Submission Plan will take into the policy which refers to paragraph 32 of the NPPF account the most recent NPPF and as such, will (now paragraph 108 within the updated July 2018 ensure all requirements are met. If necessary, NPPF). As currently worded, the supporting text additional text will be included to address any states that the NPPF supports sustainable points currently omitted. development opportunities which utilise alternative methods of travel and where safe and suitable access can be achieved. These requirements form the first two of three bullet points within paragraph 108 of the NPPF. However, it is notable that this wording ignores the 3rd bullet point of paragraph 108 of the NPPF which adds that it should also be ensured that "any significant impacts from the development on the transport network (in terms of capacity and congestion) on highway safety, can be cost effectively mitigated to an acceptable degree". There are limited opportunities to increase the use of sustainable trips attributable to mineral and waste developments, as is rightly acknowledged within the supporting text of the policy. Consequently, it is important that the effects of the traffic movements, which are invariably road-based HGV trips, are properly appraised and, if necessary, mitigated appropriately. In order to address this concern and to reflect the guidance within the NPPF and the findings of the Strategic Transport & Traffic Assessment document which forms part of the evidence base, it is suggested that the 2nd paragraph of the wording of Policy DM11: Sustainable Transport Movements is amended as follows to provide greater clarity: Specifically, the assessment should explore how the movement of minerals and/or waste within and outside the site will not be detrimental to road safety and would not have an unacceptable impact on the environment, of the local community, or the highway network and
determine whether highway improvements are necessary to mitigate impacts associated with increased vehicle movements. DM11 - paragraph 7.94 of the supporting text would The Proposed Submission Plan will take into benefit from the following rewording so that it account the most recent NPPF and as such, will properly reflects the guidance within paragraph 108 ensure all requirements are met. of the NPPF: The NPPF supports developments where opportunities for sustainable transport have It is also recognised that the evidence base and been taken up, the provision of safe and suitable resulting policies need to be aligned and this will access can be achieved and any significant impacts be incorporated in the update to the evidence from the development in terms of capacity, base and Plan. congestion and highway safety can be cost effectively mitigated to an acceptable degree. Again, in order to reflect the NPPF guidance and the findings of the Strategic Transport & Traffic Assessment document which forms part of the evidence base, it is considered that the 3rd sentence of paragraph 7.92 of the supporting text would benefit from the following revision: Routing agreements may be required to ensure that access is not permitted on roads which result in unacceptable impacts on communities & the environment, or the highway network. For the same reasons, it is considered that para the 4th sentence of paragraph 7.93 of the supporting text would benefit from the following revision: In addition to potential capacity, congestion and safety impacts along the highway network, the potential and perceived impact of transportation on amenity may include vibration, visual intrusion and air quality. DM11 – to ensure that the policy objectives are met The movement of minerals does not recognise with respect to highway safety and also to ensure administrative boundaries and is market led. that newly permitted sites contribute to the land Central and Eastern Berkshire cannot supply all bank, the following should be considered in the mineral that it requires and therefore, is implementation: a. Planning should only release reliant on supply from elsewhere (including additional land for mineral extraction with the crushed rock from Somerset). As such, condition that the final destination for the use of restrictions cannot be placed on what market the such minerals be within the locality of Central & mineral should supply. However, at the point a Eastern Berkshire. Without this, there can be no planning application is submitted mitigation guarantee that any Final Plan will deliver the policy measures can be put in place to reduce impacts objective of the NPPF. b. With respect to highway on the highway and to the local safety – given the current peaks in traffic during the communities/environment. morning and evening rush hours, together with school traffic. There should be a presumption that truck movements should commence their journeys to / from a site after 09:30 hours and complete any journeys to / from site before 15:00. To do otherwise would add significant additional truck movements at times of capacity constraint Policy DM11 - The transport assessment proposes The comments on Planners Farm have been routes through Winkfield Row to accommodate an reviewed and changes to the proposed route will additional 50,000-75,000 tonnes of waste be incorporated in the revised STA accordingly, processing each year at Planners Farm. This will where necessary. require approx. 49 additional 2-way journeys to and from the site - 98 additional HGV journeys daily. 1. All information received regarding the proposed Braziers Lane is listed as a preferred route. The site allocations will be taken into consideration in road is unsuitable for HGVs as indicated in the the preparation of the Proposed Submission
current road signage "Unsuitable for HGVs" 2. Plan and will inform the update of the evidence Proposed routes pass 2 existing schools - base. Lambrook and Winkfield St Mary's - together with walking routes to both schools. There are 3 play *Linked to Planners Farm comments areas in the area of proposed routes. 3. There are two conservation areas - Winkfield Row and Winkfield Village. The conservation area appraisal for Winkfield Row describes its architectural historic interest and states "the character or appearance of which it is desirable to preserve and enhance'. This appears to be in conflict with increasing the use of HGVs within the area. 5. The consultation document does not appear to take into consideration proposals that are being considered under the Bracknell Forest Draft Local Plan - another school to be located in the Braziers Lane/Forest Road vicinity and closure of Braziers Lane with a new spine road running through a high- density residential area. 6. Lock's Ride has a very narrow footpath which is well used by pedestrians including children accessing the Lock's Ride Recreation area. Change sought to the policy - If this policy is to be ratified, alternative HGV routes MUST be found as it is my belief that the current proposals will violate environmental (emissions, noise and vibration pollution) regulations. Any Final Plan should include sufficient directive These policies would be applied on a case-by- detail to ensure that policy objectives with respect case basis and will be dependent on the to public health Policy DM9 Protecting Public relevant circumstances. The successful Health, Safety and Amenity and Policy DM11 implementation of the policies in relation to a Sustainable Transport Movements are met, rather specific development will be dependent on the than as currently drafted which allows to much conditions and, where relevant, the legal scope for failure to meet such policy objectives. agreements applied. Draft Policy DM11 – the Policy would require Star All information received regarding the proposed Works to avoid detrimental impacts on the local site allocations will be taken into consideration in community from “within and outside the site”. This the preparation of the Proposed Submission would include noise, light and dust disturbance from Plan. vehicles moving within the site, and again once vehicles enter and leave the site. The policy allows for instances where such impacts can be mitigated, such as highway improvements. It is important to note however that there is only one means of entry and exit onto Star Lane then Bath Road, and this access is shared by a number of residential properties. Appropriate mitigation has not been successful thus far, indicating that a continuation and intensification of the site would worsen the degree of impacts as a result of traffic movements. Policy DM11 - the policy fails to address or explain Guidance on the content of Transport how evidence is carried out on settlement areas Assessments or Statements is already provided and the effect caused by HGV'S to health and well via the Planning Practice Guidance. This being in a small concentrated area with difficult guidance is regularly updated and therefore, it is connectivity. not practicable to repeat the guidance in the Joint Minerals & Waste Plan.
Change sought to Policy DM11 - to add in depth evidence archer strips, police accident reports, local objection.
DM12 Issue Response DM12 - the current policy does not ensure that the The Joint Minerals & Waste Plan must be environment and residential issues take considered as a whole and therefore, Policy precedence over big business. DM12 will not be viewed in isolation but alongside policies such as DM9 (Protecting Public Health, Safety and Amenity).
DM13 Issue Response DM13 - Permission and structures to be temporary DM13 only seeks to permit development that is with a condition for removal of the structure when ancillary to the primary permission on the site. the site is no longer active. To avoid unnecessary Therefore, if the site has temporary permission and inappropriate buildings being erected whose this would also apply to the ancillary main purpose is to be converted into another use development. after the approved activities at the site cease. DM13 – Concerned that this is too open and could Noted – further consideration will be given to the lead to difficulty controlling developments, needs to wording of Policy DM13. be more assertive. Ancillary development [DM13] - This is a term that Examples of ancillary development are provided has no meaning. What ancillary development is in the opening paragraphs of that section (Para. proposed and how would it impact on the local 7.109 and 7.110). However, a definition will also environment and residents? Ancillary development be provided in the Glossary. could mean anything it is an insult to the intelligence of the local residents to use such a The Plan would be considered as a whole and vague term. therefore, the potential for impacts would be addressed by the other Development Management policies. If these cannot be complied with, permission would not be granted. Re-working landfills is a blanket term that needs to Re-working landfills is defined in 6.110 as be identified in detail. Re-working should mean removing existing landfilled materials in order to restoring to how it was before a landfill site was reuse the land or void, or to exploit benefits from used the in-situ material itself.
Restoration would be covered by Policy DM8 (restoration of Minerals and Waste Developments) and restoration to the previous land use would be one of the options.
*Linked to W5
Waste Policies
General
Issue Response Early closing of landfill sites means there is likely to be a move This is recognised and work is towards regionally strategic landfill sites and a need for progressing on relevant Statements Statements of Common Ground/ Joint Position Statements. of Common Ground. Agree with the consideration given to cross-boundary and Noted. cumulative impacts of waste development and other local developments. Waste management will change significantly through Agreed. To address this, Policy W2 technology as they have in the past twenty years. This will contains an exception where it can be make existing facilities and sites redundant and inappropriate. demonstrated that the waste management facility is no longer required. Are waste treatment works safeguarded? Policy states that all waste management facilities shall be safeguarded.
W1
Issue Response Policy W1 - Any waste site should not impact upon domestic The Development Management (DM) residences and in particular where the quality of life for policies seek to control the impacts of residents is impacted adversely. Examples of where this plan development and any proposed cannot be justified are the impact of noise, and in particular development will be considered in vehicle activity, pollution of the environment, proliferation of light of all the policies in the Plan. pests and potentially dangerous levels of carbon monoxide from exhaust emissions. It should also be noted that the site is All information received regarding the very close to Knowl Hill Academy currently increasing the proposed site allocations will be taken number of pupils. The detrimental environmental impact upon into consideration in the preparation young children can never be justified. Change sought to policy of the Proposed Submission Plan. – yes, to find an alternative, more suitable site [Star Works] [Site excluded as allocation, as existing site] W1 - Waste should not be buried, we need more incineration Agreed and the Plan proposes more and power production and better recycling facilities. additional recycling than recovery capacity. W1 - We need local govt to object to plastic packaging, return Noted. to paper, metal and glass. The Plan has to deal with the waste at its current and predicted levels and composition. W1 – Concerned that locating near to the sources of waste, or Locations near sources of waste or markets for its use appears so high on the list of criteria. markets for its use reduce the need Considering the population density in some areas, this needs to for the waste to travel and be stored, be caveated. There would a benefit in a cost benefit analysis of thereby reducing its environmental, sites. Although for example it would be better for green miles amenity and other impacts. This will etc to have a source of extraction, or a waste disposal centre need to be balanced with any amenity within the area, it may not necessarily be the best approach. impacts of a site in an area with high does not think that the cost to people of close encounters with population density. The Development waste sites has been properly costed in. The population Management (DM) policies seek to density of the area means that it could often be beneficial to control the impacts of development. finds sites external to the area. Any proposed development will be
considered in light of all the policies in the Plan and there will be a need to balance the requirements of different policies. Draft Policy W1 – Sustainable waste development strategy - Noted. despite not being able to accommodate all of its waste management requirements within the Plan area, the Plan must All information received regarding the not seek to allocate waste management sites in unsuitable proposed site allocations will be taken locations, for example those where impacts on residential into consideration in the preparation amenities would reach unacceptable levels. Such impacts are of the Proposed Submission Plan. already causing detriment to residents near Star Works, with continued planning permissions granted to Star Works on a [Site excluded as allocation, as reasoned weighted planning balance where decision makers existing site] have deemed the benefits of a restored former quarry void / landfill to outweigh the temporary impacts of the waste management activities required to complete that restoration objective. It would therefore conflict with the Councils’ Plan objectives and statements to support the allocation of Star Works as a waste management facility over the Plan period. In light of the above, there is support for Draft Policy W1 which, if applied to Star Works, would not support its allocation. W1 Sustainable waste development strategy - At point 6.6 it Noted, this will be reviewed. states that Central and Eastern Berkshire have 30 waste management facilities, however within Table 4, the Waste [Sites reviewed, Plan and evidence Operator survey has recorded 9 of 34 responding. base amended.] 6.15 states that the Central and Eastern Berkshire Authorities It is a requirement to plan to provide will plan to provide for new waste management facilities of the sufficient waste management facilities right type, in the right place and at the right time”. The use of and that is what the Plan seeks to do. the word “provide” could be considered misleading as the Plan The effectiveness of the Plan will be does not identify all the sites needed to meet the waste impacted by a variety of factors, management facility needs over the Plan period. Maybe a more including the availability of proposed appropriate word or phrase could be used. sites. Furthermore, provision does not necessarily have to be through allocation but can be through policies that enable appropriate sites to come forward when required. The current plan does not offer a sustainable solution. It Draft Policy W1 (Sustainable waste merely focuses on waste disposal. More emphasis needs to be development strategy) specifically placed on recycling initiatives. seeks to facilitate sustainable waste management.
Recycling initiatives are the remit of the waste management teams within each of the Central & Eastern Berkshire Authorities (note that Bracknell Forest, Reading and Wokingham work collectively through Re3). However, the Draft Plan does seek to encourage waste to be managed at the highest achievable level within the waste hierarchy (Draft Policy W1).
W2
Issue Response
Policy W2 - Policy is flawed when it is based on lazy The Development Management (DM) construction whereby any existing waste site is automatically policies seek to control the impacts of considered for development regardless of its suitability over development and any proposed actively seeking a more suitable location. An undue emphasis development will be considered in on one area under the waste and mineral plan is not light of all the policies in the Plan. sound. Change sought to policy – yes, to find an alternative, more suitable site [Star Works] Policy W2 safeguards waste sites from encroachment or loss to other forms of development, not from enforcement action should there be any issues with the waste activities conducted on site. Policy W2 - Individual sites should not be safeguarded but Policy W2 safeguards waste sites should be judged for suitability based upon the assessment from encroachment or loss to other criteria already established within the basic JCEB Site forms of development, not from Assessment criteria such as but not limited to: visual impact; enforcement action should there be geodiversity; historic environment; water environment; air any issues with the waste activities quality; soil quality; public rights of way; transport; health and conducted on site. amenity; cumulative impact; and green belt. In the case of existing waste management sites the history of However, it may be that past how the site has been run should be taken into account as this performance could be considered is a sure sign of how the site will be run if allowed to when making decision on future continue. planning applications – this option will be looked at in the Proposed Submission Plan preparation.
[In Plan – Policy DM15] Policy W2 - 6.23 refers to existing waste treatment and transfer Policy W2 safeguards waste sites facilities, but makes no mention of the reasons why these from encroachment or loss to other existing sites were originally granted use within the waste plan, forms of development, not from specifically Star Works. enforcement action should there be any issues with the waste activities conducted on site. Policy W2 – Existing waste sites should not receive any special Waste developments are regularly at protection or be automatically safeguarded from other risk of encroachment or development as this could encourage over landfill use or other redevelopment, which impacts the waste development in one place. ability of local authorities to meet waste management needs.
The Development Management (DM) policies seek to control the impacts of development including the cumulative impacts of proposed developments. Change sought to Policy W2 - 5.13 It would be appropriate for Amenity and environmental impacts draft Policy W2 to permit the removal of waste management from ongoing operations are handled facilities in instances where environmental impacts, including through regimes such as local those on residential amenity, are at unacceptable levels. The authority monitoring and enforcement following change is recommended to the first paragraph: “All of planning conditions, environmental waste management facilities and those which provide a health and the Environmental temporary specialist function shall be safeguarded from Agency. encroachment or loss to other forms of development., except where there would be environmental benefits from the loss of Safeguarding does not protect sites such a facility, including the alleviation of undesirable impacts from enforcement action or closure on residential amenity such as those arising from noise, odour, due to non-compliance with pests/vermin and vehicle movements.” environmental or other regulations.
W2 Safeguarding of waste management facilities We would Noted, this will be clarified. appreciate clarity of what the term “specialist temporary facilities” mean – how do you determine specialist? [Removed, as temporary permissions are safeguarded for life of permission, so distinction is not required]. Change sought to Policy W2 - The policy is helpful in that it Noted, the policy will be further removes ambiguity around the need to provide an alternative clarified. site prior to loss of the existing site. However, it is felt that more detail on what constitutes the capacity requirements is [Capacity defined in glossary, rest required. No information is provided on how the capacity of the addressed in 7.38 and 7.39] existing site is to be calculated or how this capacity can be reallocated within the plan area (for example could an uplift in capacity at an existing alternative site be appropriate)? Further detail within this policy would provide more clarify and make the policy more effective. The Plan notes that 70,000 tonnes of household waste from Noted. Bracknell, Reading and Wokingham will continue to be sent to Grundons at Colnbrook. This waste facility will be lost if the proposed third runway at Heathrow goes ahead. There are proposals to relocate it nearby and so it would be helpful if the Central and Eastern Berkshire Minerals and Waste Plan could explicitly support this and include this in the Statement of Common Ground between the Authorities. Also support the need to retain the Colnbrook rail depot in the Statement of Common Ground.
W3
Issue Response 6.60 Please note that planning permission for Sutton Courtenay Noted, the Plan and evidence base landfill expires in 2030 and that non-hazardous landfill facilities will be amended accordingly. in Oxfordshire have not been safeguarded and no further provision is made for non-hazardous landfill in the Oxfordshire [Plan and Waste Background Study Minerals and Waste Local Plan: Part 1 – Core Strategy. amended] Policy W3 - Processing of waste from outside of the Joint Waste does not stay within Minerals and Waste Draft Plan should be discouraged. Waste administrative boundaries, as no facilities in the 'Joint Minerals and Waste Plan' should only administrative area contains all the receive waste from within the four council boundaries to ensure facilities required to manage the that their required needs are met before any consideration is various types of waste. given to other areas. Furthermore, more waste leaves the Plan area than enters it. Policy W3 - The use of infill material to restore existing mineral The Star Works site is not proposed extraction sites is a legitimate use of such material. But sites, for infilling. such as Star Works, should not be used for such activity for longer than is necessary to restore the habitat. In preference, The use of brown-field land for waste processing sites should be brown-field sites that exist at places sites is encouraged through Policy such as Thames Valley Park and Slough Trading W4. Estate. Processing of any waste that is not identified in the Joint Minerals and Waste plan, or from outside of the area Waste does not stay within should be discouraged as far as possible so that as few sites administrative boundaries, as no as possible are needed within the area covered by the Plan. administrative area contains all the facilities required to manage the various types of waste.
Furthermore, more waste leaves the Plan area than enters it. Policy W3 - The waste capacity requirements for the recycling The Colnbrook (Tanhouse Farm) and recovery of non-hazardous waste over the Plan period MRF is noted in the EA WDI as a does not take into account the potential loss of capacity should Waste Transfer Station so has not the Colnbrook waste management complex (in Slough) fail to been included in treatment capacity, be relocated as part of Heathrow airport expansion and however the loss of further waste proposed additional runway. The waste management site capacity alongside the Lakeside EfW currently includes an Energy from Waste facility (Lakeside will be noted. EfW), as well as a recycling centre (Colnbrook Material Recovery Facility). These facilities manage a significant [Noted in 7.55-7.58 in Plan] amount of residual waste and recyclates (non-hazardous household as well as C&I waste streams) which originate from the Central and Eastern Berkshire area (the Plan area). The draft Plan (paras. 6.52 – 6.55) and the JCEB Waste: Background Study Draft Plan, June 2018 (para. 46 onwards) intimate the issue and possible loss of the EfW facility, which would have a significant impact on waste management in the region. However the assessments and reports omit to take similar account of the potential loss of recycling capacity currently managed by the Colnbrook MRF. The minimum waste capacity requirements figures, for non-hazardous recycling and non-hazardous recovery capacities, stated in Policy W3, rely on the retention of both these EfW and MRF facilities, and also assume the continuation of existing recovery capacity throughout the Plan period to 2036. The draft Plan acknowledges that the current waste site allocations (under Policy W4) already fail to meet the future waste management requirements of Central and Eastern Berkshire. Should Heathrow airport expansion and proposed additional runway go ahead without the replacement of the Colnbrook MRF and Lakeside EfW, then this would significantly exacerbate and bring forward the existing waste capacity gap, for both non- hazardous recycling and recovery, as early as 2023, when these facilities could both be extinguished. The sites currently allocated in the draft Plan should clearly be safeguarded, as a minimum, but also that the Plan should be monitored and likely be reviewed in the event that the Colnbrook complex (Colnbrook MRF and Lakeside EfW) is lost and not replaced. The plan acknowledges the importance of Lakeside ERF and Agreed. the impact the potential loss of the facility may have on the region. Given the nature of the facility in handling the waste produced by the authorities, it is suggested that the decision on its future may trigger a plan review. At present the plan is silent on what would happen if the facility is lost or in a period while the new facility is constructed. It would be helpful to have written into the plan that while the uncertainties remain about its future than once a decision is made this may require the plan to be reviewed to address possible capacity issues in managing the authorities waste. Policy W3 – no justification to support the capacity assertion. The capacity and other waste figure Many businesses are being encouraged to use less packaging calculations are contained in the and in 2036 the amount of waste produced may be Waste: Background Study document, substantially less. This has not been included in the plan and part of the evidence base for the Draft needs greater explanation. Plan. The predicted rise in waste quantities is in line with the evidence available and with predictions used by
other waste plans. The Plan will also be monitored and any changes to waste arisings should be considered through the monitoring process. W3 - support the allocation of Datchet Quarry for the delivery of To review. waste management infrastructure. Also suggest that the former Kingsmead Quarry, Horton which is currently undergoing [All sites that have been submitted as restoration is considered as a suitable allocation under this part of the call for sites and up to policy. spring 2019 have been considered. ] Policy W3 Thames Water support the policy in principle which Noted. Though wastewater is recognises and supports the provision of additional sewage mentioned in 6.77, an amendment to sludge treatment capacity. However, for clarity it is considered policy W3 and W4 or a separate that Policy W3 should specifically refer to “sewage” sludge. In policy on wastewater will be relation to supporting paragraph 6.67, the weights listed refer to considered. sewage sludge and not effluent/waste water which would weigh significantly more. Although Policy W3 refers to [sewage] [Policies W3 and W4 amended to sludge there is no reference to new infrastructure for cover waste water.] effluent/waste water treatment i.e. the liquid element of waste water which needs to be treated at a sewage treatment works before it can be safely returned to the environment. The Minerals and Waste Plan should also specifically refer to waste water [as well as sludge] treatment, as was done in the last adopted Waste Local Plan for Berkshire 1998 (Policy WLP18) and other Waste Local Plans. For example, the emerging West Berkshire Waste Local Plan will include Policy 12 as follows: “Specialist Waste Management Facilities. Planning permission will be granted for specialist waste management facilities, including facilities to manage agricultural and hazardous wastes and waste water where: Sites are proposed within the areas identified in the location of waste management facilities policy; or There is a clear proven and overriding need for the proposed facility to be sited in the proposed location; and The proposals and any associated equipment or operations do not have an unacceptable environmental impact or unacceptable impacts on communities.” The Adopted Surrey Waste Plan 2008 also has Policy WD6 on Waste Water and Sewage Treatment Plants which states: “Planning permissions will be granted for new waste water and sewage treatment plant, extensions to existing works, or facilities for the co-disposal of sewage with other wastes, where development is either needed to treat Surrey’s arisings or in the case of arisings from elsewhere the need cannot practicably and reasonably be met at another site. Wherever practical and economical, biogas should be recovered for use as an energy source.” A similar policy is to be included in the new Surrey Waste Local Plan due to be adopted in 2019. The submission draft version of the new Surrey Waste Local Plan dated December 2017 includes the following policy: “Policy 12 – Wastewater Treatment Works. Planning permission for the development of new Wastewater and Sewage Treatment Works or for the improvement or extension of existing Wastewater and Sewage Treatment Works will be granted where: i) Development is needed to treat wastewater or sewage arising where the need cannot be practicably and reasonably be met at another site. ii) As appropriate, biogas, for use as an energy source, will be recovered effectively using best practice techniques.” The adopted Wiltshire Council Waste Core Strategy, July 2009 also
identifies the central importance of the provision of waste water and sewage waste infrastructure as part of the management of growth. Policy WCS3 states: “WCS3: Preferred Locations of Waste Management Facilities by Type and the Provision of Flexibility Over the period to 2026, the Councils will seek to allocate the following types of waste management facilities in the following locations within Wiltshire and Swindon in line with Policies WCS1 and WCS2 to provide for: Waste Water Treatment Existing waste water treatment facilities or waste management facilities: New sites on brownfield or greenfield land where the proposal demonstrates that the development cannot feasibly be carried out within the capacity of existing waste water treatment sites and cannot feasibly be carried out at other waste management sites” W3 – Waste capacity requirements. There is no justification The capacity and other waste figure contained in the consultation to support this assertion. It is quite calculations are contained in the possible that it will be less or materially different. Waste: Background Study document, Page 58 of the Consultation Paper says “6.41 By 2036, the part of the evidence base for the Draft following estimated arisings are expected within Central and Plan. The predicted rise in waste Eastern Berkshire: • 725,000 tonnes per annum (tpa) non- quantities is in line with the evidence hazardous waste; • 30,000 tpa hazardous waste; and • 680,000 available and with predictions used by tpa inert waste.” There is no justification or explanation for this other waste plans. The Plan will also assertion. be monitored and any changes to waste arisings should be considered through the monitoring process. Policy W3 - It is noted that the capacity requirements in Policy Due to the shortage of available sites W3 assume the continuation of existing recovery capacity post and capacity it is preferable that inert 2030, and therefore the policy is expressed as a minimum waste is at least recovered rather requirement. However, the provision of 278,000 tpa of non- than disposed of or transported hazardous waste management capacity would not appear to considerable distances in order to be meet the identified capacity need of -291,881 tpa for non- recovered elsewhere. If there is a hazardous waste identified in the Waste Background Study. If choice of facilities in the future, Policy 278,000 tpa were the minimum capacity requirement, then a W1 includes encouragement to gap of 13,881 tpa could still exist. By combining the manage waste at the highest requirement for inert recycling and recovery capacity, this may achievable level in the waste not promote the management of waste in line with the waste hierarchy. hierarchy. This is because waste that could be recycled may be recovered instead, and still be in accordance with this policy. Policy W3 - Draft Policy W3 – Waste capacity requirements The Development Management (DM) 5.17 The Plan states that currently around 540,000 tonnes per policies seek to control the impacts of annum (tpa) originates from the Plan area, of which 450,000 development and any proposed tpa is treated outside the Plan area. The Plan, at paragraph development will be considered in 6.70 states that around 305,000 tpa of capacity for aggregate light of all the policies in the Plan. recycling, or recovery, would be required by 2036. 5.18 It is of concern that draft Policy W3, in stating where hazardous waste 6.99 specifies that proposals will be management facilities and non-hazardous landfill for residual supported where they are ‘in waste will be supported, is very light in terms of environmental appropriate locations’ and therefore, requirements, using the catchall phrase “in appropriate comply with all relevant policies within locations”. the Plan. Change sought to Policy W3 - it is important that the wording of The Development Management (DM) this policy is expanded to detail that where such proposals policies seek to control the impacts of would have unacceptable environmental impacts, including development and any proposed upon residential amenity, they will be refused. Given the development will be considered in complexity of potential environmental impacts, this policy light of all the policies in the Plan. should be expanded and required to comply with linked policies within the Plan.
6.99 specifies that proposals will be supported where they are ‘in appropriate locations’ and therefore, comply with all relevant policies within the Plan. Policy W3 & W4 - There are four sites in your draft plan that are The Strategic Transport Assessment either in or are adjacent to the parish of Colnbrook with Poyle – and policies state that each site would Poyle Quarry, Poyle Quarry Extension, Berkyn Manor Farm require a Transport Assessment or and Horton Brook Quarry. Notwithstanding the negative site Statement to address the impact of specific impacts which would be clearer when more detail is the site on the local highway. available than is currently in your draft, all of these sites and Cumulative impact of the sites is their haul routes will put huge amounts of traffic onto roads covered in from section 4.27 of the going through our parish, or adjacent to it. We object to the Strategic Transport Assessment. increased traffic congestion and air pollution that this will cause in areas that are already heavily congested and suffering poor air quality well below EU Directive minimum standards. Moreover, some of the sites are very close to residential properties, and all four are in the Colne Valley Park and will cause loss of amenity and openness, negatively impacting on the quality of life and landscape. W3 provides for non-hazardous landfill where there is a need. The lack of landfill sites is a regionally 6.60-6.61 clearly indicates that there will be a clear and recognised issue, reflected in the fact demonstrable need, yet the requirement isn’t identified within that there have been no non- the Waste capacity requirement of Policy W3. We would like to hazardous landfill proposals received see greater clarity of the waste arisings and projections over as part of work on the Draft Plan. The the plan period set out within the Plan. Plan enables such sites to come forward, as required, but also takes the opportunity to focus capacity requirements on recycling and recovery, as waste management options that are higher in the waste hierarchy.
W4
Issue Response Policy W4 - Contrary to; Policy EN8 of the Bracknell Forest Bracknell Forest Borough officers are Borough Local Plan and Policies CS1 and CS9 of the Core involved in the production of the Plan Strategy Development Plan Document and The National and provide advice on compatibility Planning Policy Framework. Policy M4 of the Bracknell Forest with the Local Plan. In principle, the Local Plan and CS6 and CS24 of the Core Strategy remits of the Local Plan and Minerals Development Plan Document. and Waste Plan are different, while also being complementary, so minerals and waste proposals will be determined in accordance with the policies of the Minerals and Waste Plan, while other developments will be determined in accordance with the policies in the Local Plan. W4 – object to site allocation of Star Works, Knowl Hill is not a Waste sites can be situated near suitable site for further waste operations due to its location in a residential properties depending on village and within 50 yards of residential properties. the type of site and mitigation measures used.
The Development Management (DM) policies seek to control the impacts of
development and any proposed development will be considered in light of all the policies in the Plan. [Site excluded as allocation, as existing site] W4 – The potential for further lorries already using a saturate The development considerations for A4 would pose unacceptable health and safety risks for users Star Works include a requirement for near Star Works. a Transport Assessment or Statement.
The Development Management (DM) policies seek to control the impacts of development and any proposed development will be considered in light of all the policies in the Plan.
[Site excluded as allocation, as existing site] Policy W4 Locations and sites for waste management: Safeguards for the natural, built and concerned that there are no safeguards for the natural, built or historic environment are considered historic environment – these are relegated to a reference to under the Development Management “adverse environmental impacts” in the supporting text. This is Policies. Paragraph 6.99 states that not consistent with the approach in Policy M6 which specifically all relevant policies will need to be includes “The proposal not having an unacceptable impact on complied with. the environment” within the policy and is therefore more robust. Consider that Policy W4 should include a requirement for Paragraph 6.98 states that ‘the development proposals for any of the allocated sites to take the locations could provide sustainable site-specific considerations in Appendix A into account. development subject to the relevant development considerations outlined in Appendix A’. However, it is agreed that this should be raised under the Implementation section.
[DM1 states that – “The policies in this Plan are to be regarded as a whole and proposals will be expected to conform to all relevant policies in the Plan.”] Paragraph 6.109: the monitoring indicators shown would only The Implementation section will be enable monitoring of Policy W4, not monitoring of appropriately updated. located waste management because Policy W4 is deficient in ensuring this, as we explain above. We therefore consider that [DM1 states that – “The policies in either Policy W4 needs to be amended as we indicate or the this Plan are to be regarded as a monitoring indicators need to include compliance with Policy whole and proposals will be DM7 expected to conform to all relevant policies in the Plan.”] Some of the proposed minerals and waste sites in policies M4 - Sequential testing will be undertaken Locations and Sites for water management and W4 Locations in the Strategic Flood Risk for sand and gravel extraction lie within Flood Zones 3 or 2 and Assessment which will support the therefore need to be sequentially tested. As this evidence has Proposed Submission Plan. not been produced then this plan is currently unsound as it is not consistent with national plan policy NPPF paragraphs 157 and 158 or justified. Policy W4 Locations and sites for waste management - Use of Noted, this will be considered as an the appropriate Pollution Prevention Control (PPC) measures addition to policy W4 and/or DM10. and regulation with an Environmental Permit will ensure the
protection of groundwater for those sites listed. However, we [Aquifers in Policy DM11] would like to see a sentence added to part 2 of this policy that says:- “The type of waste operation should be appropriate to the sensitivity of the underlying aquifers especially when the site is within a SPZ1 (see Position Statement F1 of GP3).” W4 – Does not include waste recycle centres The need for non-hazardous recycling capacity is discussed in policy W3. W4 – Impacts need to be considered for any new site or The Development Management (DM) enhancement, there is a danger of scope creep. policies seek to control the impacts of development, including cumulative impacts, and any proposed development will be considered in light of all the policies in the Plan. Policy W4 Thames Water support part 2 (e) of the policy in Noted, clarifying text will be principle which identifies land at or adjoining sewage treatment considered. works as being suitable for waste development which enables the co-treatment of sewage sludge with other wastes. However, [Added under W2, 7.36] clearly a key consideration will be that any such proposals must not detrimentally impact upon the existing Sewage Treatment Works operations and must be subject to an appropriate odour impact assessment. Change to Policy W4 sought - It is unclear to what extent the Noted, information in the Plan and/or proposed site allocations in Policy W4 will meet the identified background evidence base will be needs for waste management capacity over the plan period, as reviewed. there are no associated capacity tonnages included in this policy or in the Waste Background Study (except for Star [Information now part of Annex 4 in Works at 100,000 tpa and Berkyn Manor Farm at 50,000 tpa). Waste Background Study. Plan also Therefore it is not clear to what extent the plan will be relying makes clear that capacity on ‘windfall’ sites in order to deliver waste management requirements will not be met and capacity requirements. It is also not clear from the policy which further Preferred Waste Areas have waste stream the allocations will be managing (i.e. non- been included in policy W4.] hazardous recovery/recycling or inert recovery/recycling). Draft Policy W4 – Locations and sites for waste The Development Management (DM) management 5.20 It is confusing how, despite the recognition policies seek to control the impacts of that many waste management activities would not be development and any proposed appropriate within close proximity to residential properties due development will be considered in to the potential adverse impact on residential amenity, and the light of all the policies in the Plan. well documented conflicts between the Star Works operations and local residents, that the site has been listed as an allocated 6.99 specifies that proposals will be site for waste management under draft Policy W4. It is also of supported where they are ‘in significant concern that part 2) of the policy, in stating what appropriate locations’ and therefore, locations would be appropriate to accommodate waste comply with all relevant policies within management facilities, the Policy excludes any requirement for the Plan. the location to be appropriate in environmental terms and specifically in terms of the potential for such a facility to give rise to unacceptable impacts on residential amenity. Such an exclusion would be in direct conflict with the recognition of the Plan at paragraph 6.84 (and other references) that being within close proximity to residential properties is a reason why a proposed location would be deemed inappropriate. Change sought to Policy W4 - 5.21, it is recommended that the The Development Management (DM) following be inserted into the end of paragraph 2 of draft Policy policies seek to control the impacts of W4; f) would not cause unacceptable levels of impact on the development and any proposed environment as a result of noise, odour, pests/vermin, dust, development will be considered in traffic, pollution, visual impact, or general impacts upon light of all the policies in the Plan. residential amenity.” 5.22 Without the insertion of the above
into the Policy, the Plan will be ineffective in restricting 6.99 specifies that proposals will be proposed waste management facilities to appropriate supported where they are ‘in locations. appropriate locations’ and therefore, comply with all relevant policies within the Plan. Policy W3 & W4 - There are four sites in your draft plan that are We understand that the owners of all either in or are adjacent to the parish of Colnbrook with Poyle – three sites propose to bring these Poyle Quarry, Poyle Quarry Extension, Berkyn Manor Farm forward successively rather than and Horton Brook Quarry. Notwithstanding the negative site concurrently – therefore a cumulative specific impacts which would be clearer when more detail is assessment means that the highest available than is currently in your draft, all of these sites and level of movements is expected to be their haul routes will put huge amounts of traffic onto roads 156 (108 Poyle Quarry Extension + going through our parish, or adjacent to it. We object to the 48 Horton Brook Quarry) two-way increased traffic congestion and air pollution that this will cause HGV movements (78 HGVs) per day in areas that are already heavily congested and suffering poor maximum. The STA describes air quality well below EU Directive minimum standards. cumulative impact from Section 4.27. Moreover, some of the sites are very close to residential It has been updated to clarify this properties, and all four are in the Colne Valley Park and will point. cause loss of amenity and openness, negatively impacting on the quality of life and landscape. Planning approval for future of this site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Paragraph 4.4 of the STA strengthened to this effect. Policy W4 - This policy clearly states that ….the site ‘has good Within the Strategic Transport connectivity to the strategic road network’. b. Berkyn Manor, Assessment (STA) it is proposed that Poyle Quarry, and Poyle Quarry Extensions will all be Berkyn Manor Farm can use its dependent on a new road which will lead onto Poyle Road in existing access. Consideration can Colnbrook. This has not yet been agreed with Slough Borough be given to routing via Poyle Quarry Council, nor were Colnbrook Parish Council even aware of the and Poyle Quarry Extension. proposed road plan. Therefore this section of the policy is However this will depend on phasing clearly flawed. of proposed extraction operations. Change sought - We do not believe the policy can proceed until a proper road management policy has been consulted upon A planning application for Poyle and agreed with all the affected parties viz Horton, Slough Quarry has now been approved which BC/Colnbrook PC. Horton Parish Council specifically would secures a new access onto Poyle like to be properly consulted regarding road access to all the Road (approved by Slough Borough above sites. This should take place before any further plans Council). It is the preference of the are established for either mineral extraction or infill on any of developer to use this new access the sites within our Parish. instead of the existing access. Relevant site forms in the STA have been updated to this effect.
It should be noted that Horton Brook Quarry is under separate ownership.
Planning approval for future use of these sites would be require Transport Assessments or Statements in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as
required. Paragraph 4.4 of the STA strengthened to this effect. Most of the land is agricultural; the Horton Brook Quarry – Inert fill would not be incompatible currently in operation – was given permission on the express with restoration to agriculture in condition that the land would be worked for a limited period general. (already extended) and would be restored to agriculture as soon as minerals extraction ceases. The proposal in the draft Retaining the site as inert recycling plan to infill with waste after extraction violates this condition of may impact on the restoration permission and, generally, waste landfill will make return to proposals and this would need to be agricultural use less viable. considered as part of the detailed planning application. Policy W4 - The term 'active quarry or landfill operation' should Noted, definition of active site will be be clarified, does this include instances where there is an added to the glossary. active consent but the site has been mothballed? Does it include the period where restoration soils are being placed/the [Added] site is being actively restored or only where the void is being filled and capped? Policy W4 - BFBC local plan does not include the proposed The Joint Minerals & Waste Plan, Joint Mineral & Waste Plan or any agreed transport Haul alongside the Local Plan, makes up routes the Development Plan for an area. W4 Locations and sites for waste management. 6.92 states Noted. that there are insufficient sites to meet the future waste management requirements of Central and Eastern Berkshire up to the end of the Plan period and this will be left to market-led delivery. This may make it harder to meet the future needs over the plan period, however we acknowledge the difficultly in identifying deliverable sites for waste management. The identification of 'active' landfills suggests that once a Once a landfill is restored it will have landfill has been restored it no longer forms a suitable location, a new land use, usually reverting landfill sites can be suitable for some types of development as back to greenfield so any they provide the flexibility for activities (such as wood shredding development will be considered as activities) which would benefit from a more rural location. development on that new land use Landfill by their nature are also often well screened and located rather than development on a landfill. at a distance from residential dwellings so nosier activities This does not prevent new (such as wood shredding) would be appropriate in such developments with specific locations rather than on industrial or employment land. Further requirements coming forward, but the clarification wording would ensure that this policy is effective for old brownfield land use would likely its intended purpose. no longer be applicable.
W5
Issue Response Policy W5 – Remove Star Works from any list of waste sites There is no current list of waste sites considered for re working being considered for reworking.
Any proposals for reworking will need to be considered in light of policy W5 and all other policies in the Plan, including the Development Management (DM) policies, which seek to control the impacts of development. Policy W5 - Removal of Ham Island and Riding Court Farm Ham Island and Riding Court Farm from policy are not former landfill sites, so do not currently come under Policy W5.
Any proposals for reworking will need to be considered in light of policy W5 and all other policies in the Plan, including the Development Management (DM) policies, which seek to control the impacts of development. Policy W5 Reworking landfills If a landfill is to be re-worked Any development proposals, including within a SPZ1 a Risk Assessment should be carried out. This those of reworking landfill, will need to needs to be included within the text of this policy. satisfy the DM policies in the plan, including DM10, which requires a hydrogeological assessment when proposals are within Source Protection Zones. This may need to be clarified.
[All policies text added, HGA text added] Policy W5 - The principles in this policy purport to include The Development Management (DM) human health and environmental control. Change sought - policies seek to control the impacts of Horton Parish Council want to see clear evidence of pollution development and any proposed control for air quality, noise and vehicle disturbance. This has development will be considered in to involve realistic operational hours for the plants including light of all the policies in the Plan. limiting vehicle access to sociable hours. Operational hours for plants should be 08:00 – 17:00, Monday to Friday. There should be no operations at week-ends or on Public Holidays. Provision and enforcement must be made to stop vehicles from accessing sites before or after sociable hours (we take these to be 07:00 – 18:00 Monday to Friday with no access at weekends or on public holidays. Further, there should be absolute enforcement and controls to prevent vehicles from ‘stacking’ in roads around the curtilages of the sites before the operational hours. 6.70 states “Inert aggregate recycling”. Should this read “inert Noted, this will be reviewed. waste recycling” The figure of 305,000tpa does not appear to correlate with Policy M5. The targets of 6.82 are not reflected [Policy W3 now refers to inert within the suggested monitoring issues of 6.81 to enable future recycling or recovery capacity and monitoring of the policy. includes monitoring indicator.] Reworking of landfill should only be allowed / considered where The Development Management (DM) it can be shown that prior landfill operations have not blighted policies seek to control the impacts of the site’s surroundings and impacted adversely the health and development and any proposed lives of local residents, amenity areas, leisure routes. And they development will be considered in should be subject to stringent control and monitoring, should be light of all the policies in the Plan. time-limited and should only be considered for sites that have not dealt with landfill of hazardous chemicals, material and However, it may be that past substances including, but not limited to, clinical waste. performance could be considered when making decision on future planning applications – this option will be looked at in the Proposed Submission Plan preparation. [Added – Policy DM15]
Waste Background Study
Issue Response
We have reviewed the Central and Eastern Berkshire Joint Noted, the information will be Minerals & Waste Plan Waste: Background Study report dated reviewed and amended as June 2018. Table 15 provides a summary of the industrial appropriate. estates/areas that are considered to be potentially suitable to host waste management activities. This relates to Policy W4 [Aquifers addressed by Policy and we have already stated that the waste activity should be DM11.] appropriate to the sensitivity of the underlying geology. Lower Mount Farm has been identified as a suitable Category 3 site with activities requiring enclosed industrial premises (small scale). This site has been mis-identified as being within a Source Protection Zone (SPZ3). This site is in fact within a SPZ1 for the Cookham PWS that abstracts from the Chalk. The type of waste operation should be appropriate to the sensitivity of the underlying Gravel and Chalk Principal Aquifers (see Position Statement F1 of GP3). Please use the following link to this guidance https://www.gov.uk/government/publications/groundwater- protection-position-statements Waste Background Study comments - Waste Capacity Noted, this will be reviewed and Requirements The executive summary states that the main clarified. waste treatment capacity deficit identified is for non-hazardous waste (-291,881 tonnes per annum, Table 2a). However, Table [Capacity data in Waste Background 2a also identifies a treatment capacity gap for inert waste of - Study updated.] 287,906 tonnes per annum (tpa) in 2036, a similar capacity gap as non-hazardous waste. Table 3a identifies that 278,500 – 385,800 tpa of non-hazardous waste treatment capacity is required by 2036. The low end of this range (278,500) would not appear to meet the identified capacity need of -291,881 tpa for non-hazardous waste identified in table 2a. This figure (278,500) also differs from Table 16 and the technical working table in Annex 4. The upper end of this range (385,800) also differs from Table 16 (-399,256). The requirements for other waste streams such as inert and hazardous wastes have not been included in the Executive Summary. It may be helpful to do this in order to clarify the future management requirements for these waste streams. Waste Arisings Data It is not clear from Table 1 whether the Noted, this will be reviewed and waste arising data includes data from the Environment Agency clarified. Incinerator Returns. It is implied at paragraphs 3.16 and 3.22 that incinerator throughput data has been included, but Table 1 [EA incinerator data now listed as does not list this as a data source. source.]
Hazardous Waste Data Regarding the sources of hazardous Noted, this will be reviewed and waste, the Environment Agency’s ‘Hazardous Waste Data clarified. Interrogator’ is generally seen as a more accurate source of this data than the general Waste Data Interrogator. [HWDI now used and listed as source.] Non-hazardous Landfill Paragraph 8.10 – It should be noted Noted. that the Statement of Common Ground on Non-Hazardous Landfill between the South East Waste Planning Authorities has [Duty to Cooperate has been now been revised as a ‘Position Statement’. Therefore, existing conducted on an on-going basis and contractual arrangements involving the management/disposal Statements of Common Ground of non-hazardous waste may still need to be the subject of prepared where requested.] Statements of Common Ground with individual planning authorities.
Waste Proposal Study comments - Waste Site The potential capacity of each site will depend Capacity It does not appear to be clear from the site on the exact nature of the technology summaries what the additional capacity each of the employed and this information is not currently site proposals will be, and therefore what they will available. In light of the known capacity gap for contribute to the relevant waste stream capacity gap. waste management facilities, the sites were The justification for allocation in each site proposal considered as to their suitability in principle. does not appear to be linked to its ability to meet an identified need. Comment on Waste Proposal Study - Page 117 Noted. relating to Site Toutley Road Depot identifies that "SITA have a waste collecting site within this industrial depot". SUEZ (Formerly SITA) wish to confirm that no waste collection activity has taken place on this site since 2015.
Industrial Land Review It is unclear what the The Industrial Land Review was illustrating the relevance of the industrial land review is, as none of general availability of locations likely to be the potentially suitable areas seem to have been suitable for certain types of waste progressed any further through the site assessment management. As these sites are not currently process, nor been included in the draft plan being proposed for waste management uses, document. they cannot be allocated.
[Further work done with Preferred Waste Areas, now in Policy W4]
Mineral Policies
General Issue Response Support the consideration given to Soft Sand Noted reserves in the south east in the plan, however there is potential for supply issues in the near future. Agree with the consideration of cross-boundary impacts and cumulative impacts of minerals development with other local developments. The Colnbrook rail depot imports aggregates which Noted – this opportunity is outlined in the can be used in eastern Berkshire. This is potentially Minerals Background Report. However, it is not under threat as a result of the proposal to build the considered suitable for inclusion in the Plan at third runway at Heathrow. There are proposals to this time. refigure the Colnbrook rail depot so that it can continue to import materials by rail. It would be helpful if the Central and Eastern Berkshire Minerals and Waste Plan could explicitly support this and this could be included in the Statement of Common Ground between the Authorities. We are requesting additional details showing what Information submitted as part of a planning will go into your hydrogeological studies and copies application will be publicly available via the of these reports once completed for any sites where relevant local planning authority’s website. planning is submitted. This is due to the fact that many of the sites are located within Groundwater Source Protection Zones 1, 2 and 3 (as acknowledged at each site in your draft Plan). Sites are within close proximity of multiple of our All information received regarding the proposed WTW, in addition to also using waterways for site allocations will be taken into consideration in transportation and constructing a new wharf next to the preparation of the Proposed Submission a raw water extraction source on the Thames. Any Plan. applicant should be mindful of any works being proposed that may impact on aquifer yield or quality as well as that of surface waters in the Thames and Bray Lake in particular due to the shallow nature of the local aquifers. This should include the proposals for robust pollution protection measures and consideration of drainage design and ground disturbance to minimise potential impacts on groundwater quality and reduction in the availability of groundwater resources. Consideration should be taken of the sensitive nature of the site in the work and method statement for any development, especially in regard to any material and fuel storage on site and the movement of vehicles especially those involved in any fuelling processes for machinery, with particular reference to the proposed site at Monkey Island Lane Wharf, Bray and in transporting materials between Water Oakley Farm, Holyport to Monkey Island Lane We recognise the difficulties Central and Eastern The evidence base has been compiled with the Berkshire Authorities have in identifying most up-to-date information available. Where consumption and movement of aggregates as data possible, improved and updated evidence will be has been collected on a Berkshire wide level rather
than by each mineral planning authority. However, obtained to support the Proposed Submission we look forward to more accurate data collection for Plan. Central and Eastern Berkshire moving forwards. There has been a failure to obtain sufficient data, or There is limited and out-dated evidence on the to undertake any meaningful analysis of basic movements of aggregates as the last National supply and demand projections, including the survey on Aggregates was undertaken in 2014 marginal cost of alternative forms of aggregate, e.g. and was not recorded on a unitary level basis. to explain the current high levels of exports, and The NPPF states that sales should be used as a whether any additional permissions would result in basis for forecasting future levels of demand as any increase in the real land bank that would well as other relevant local information. benefit Central and Eastern Berkshire. Recycled aggregate data is unreliable and marine dredged material in Central and Eastern Berkshire is limited due to the lack of rail depots. The data presented in table 1 of the Draft Plan The Joint Minerals & Waste Plan is being shows that whilst the sales of land won sand and prepared using the best available data. gravel have increased by over 25% in the period from 2009 to 2014, the actual consumption in Due to the projected level of growth within the Berkshire has fallen by over 25% in the same Plan area, the provision rate of the Plan has period. On the basis of this data some 450,000 been based on the 3-year average of aggregate tonnes of land-won gravel and sand were exported sales (rather than the 10-year average). The in 2014, this raises a number of points. There is Draft plan also recognises that a change in local clearly an absence of complete data historically and circumstances (such as the delivery of the the fact that the last data presented is 4 years old Heathrow Expansion proposals) could have a underlines this deficiency. Any Final Plan that is significant impact on supply and would require a based on such poor data will necessarily be review of provision. deficient. There needs to be a much fuller understanding of the historical information of actual Consideration is being given to how any sales, exports and imports or all aggregates since improvements to the quality of data can be the time of the last assessment in 1995 and then achieved but it is not anticipated that more up- this can also serve as a basis for assessing the to-date movement data will be available prior to quality of the plans prepared as well as the period the submission of the Plan. covered by any Final Plan to 2036. There is no consideration within the plan of the It is recognised that the country is within a revised downwards estimates for growth prepared period of economic uncertainty which has by the IMF and also the recent stock market become more apparent in recent months due to corrections and early signs of housing prices Britain exiting the European Union (‘Brexit’). declines and sales that all support an assessment However, the Plan period is up to 2036 and of slowing economic growth with the early stages of therefore, it assumed that during this period the Draft Plan period. economic growth and the delivery of There is no discussion of future growth forecast as infrastructure will continue. recent lowering of estimated growth for the UK in general and softening of the housing market in The Proposed Submission version will be particular. At the time in the future when there is a updated to reflect the current market situation need to grant additional planning permission for but recognising the plan period. new sources of aggregates there should be a levy applied on any extraction to ensure that there is a fully funded independent provision of capital for any restoration work, without being reliant on the credit quality of a private sector entity some decades into the future. Resent examples of significant private company failures that have then had an impact on public sector finance serve as a timely reminder of need to address this point. It is clear, from the 2014 data that almost half the Discussion is based on Berkshire wide and consumption of land-won sand and gravel has been Crushed rock received at West Berkshire. Sales exported, whilst crushed rock imports have grown have increased (more recently) but that is significantly, and indeed present the majority of all partially due to increased capacity.
aggregates consumed in 2014 as they were in 2009. However, there is no discussion of why this is the case, the relative economics from a supply and demand and marginal cost to inform the future period.
M1 Issue Response Support Policy M1 – however there should be Further consideration will be given to an greater coordination between the Minerals and additional principle in M1. Waste Plan and Local Plans for non-minerals development. Recommend an additional policy principle: e) Take account of plans for non-minerals development, including allocations for residential and commercial development set out in Local Plans. Policy M1: this policy contains no reference to Noted – the supporting text will be reviewed to environment (natural, built or historic). It seems odd consider all pillars of sustainable development or to say “work with relevant minerals planning a sign-post to DM1. authorities” when it is their Plan. The reference to ‘working with relevant minerals planning authorities’ refers to mineral planning authorities outside of Central and Eastern Berkshire, when planning for the provision of aggregates from outside of the plan area that supply Central and Eastern Berkshire. Policy M1 – Object to this policy as written as it is Agreed – wording to be considered to align with not consistent with national planning policy NPPF wording guidance as set out in the NPPF. The wording of this policy is also inconsistent with the wording of this plan’s vision too. The phrase ‘sustainable supply of minerals’ in policy M1 should be replaced by ‘a steady and adequate supply’. For clarification and to avoid confusion with Policy Noted - consideration will be given to amending M1 b), within Policy M1 c) add in the word other so the wording as suggested in M1c) and para that it reads “Facilitate the supply of other minerals 5.22. to meet local demands”. 5.22 “Therefore, the Central and Eastern Berkshire Authorities will plan to provide for minerals of the right type, in the right place and at the right time”. The use of the word “provide” could be considered misleading as the Plan does not identify all the sites required to meet the mineral needs over the Plan period. Maybe a more appropriate word or phrase could be used, such as “maintain the supply of”.
M2 Issue Response
Policy M2 – refers on p26 to “Government Policy Typo to be corrected - makes reference to 32”. It is not clear which Government policy is footnote 32, which references para 143 of NPPF referred to. The Planning and Minerals Planning (2012). Guide was replaced by the Planning Practice Guidance (PPG). This reference needs to be All NPPF references will be updated in the corrected and the plan checked for other references Proposed Submission Plan. if an error or the plan updated to ensure it is based on up to date Government Guidance. Policy M2 – refers to a Policies Map, whilst a high- A proposals map will accompany the Proposed level key diagram is included on p20, a policies Submission Plan. map does not appear to have been provided as part of the consultation review. It is important stakeholders are able to review the spatial implications of the draft plan. The broad extent of mineral resources is available from other sources, an up to date Policies Map needs to show the extent of Minerals Safeguarding Areas as well as proposed allocated sites at an appropriate scale which permits analysis of the implications of the designations particularly for non-minerals development. Policy M2 – support this policy as the opportunity to Noted. extract sand and gravel from Bridge Farm has been lost because the ongoing residential development All information received regarding the proposed of the surrounding area makes the site wholly site allocations will be taken into consideration in inappropriate for the scale of the industrial works the preparation of the Proposed Submission that are envisaged. Furthermore, the proposed Plan. Arborfield bypass will traverse the site and interfere with the extraction of minerals from the site. *Linked to Bridge farm comments There are significant ongoing levels of housing Noted. need in Central and Eastern Berkshire, it is important that the Waste and Minerals Plan does Policy M2 refers specifically to having regard to not as an unintended consequence delay or other policies in the Local Development Plan prevent the delivery of new development, in which will address housing delivery. particular housing, where that housing is required to meet the needs of the relevant local area. This is especially important in Central and Eastern Berkshire where the spatial extent of minerals deposits affects a very broad area, including locations which are potentially suitable for future residential development. Pre-extraction of the particular mineral deposit may This is addressed in supporting Para 5.38 which not be viable and this should be recognised in the states that development proposals will be safeguarding policy [M2] assessed taking into account quantity, quality and practicality of extraction. There is a need for some level of protection of NPPF (2018) Para 204.(c) states that ‘known mineral assets, but the local policy framework that locations of specific minerals resources of local relates to this must clearly set out that this will be and national importance are not sterilised by suitably balanced against competing development non-mineral development where this should be needs. A positively framed mineral safeguarding avoided’. policy will be required to enable local planning authorities to make suitably balanced judgements The wording of Para 5.28 will be reviewed. on the positive or negative effects of a non-minerals development proposal as part of their wider plan making and their decision taking. There is an intention to safeguard proven mineral deposits of sharp sand and gravel; and, soft sand that are of
economic importance or that are around active minerals workings to prevent sterilisation and retain resources to meet longer term need. Paragraph 5.28 of the Plan refers to this being achieved by ensuring that development is steered elsewhere, or that extraction of the underlying minerals takes place prior to development proceeding. Any local policy intention to steer development away from Minerals Safeguarding Areas is considered contrary to national policy and this assertion within paragraph 5.28 of the Plan should be deleted. National policy does not advocate an approach that seeks to steer non-minerals development away from Minerals Safeguarding Areas. Soft Sand – acknowledge that Soft Sand reserves Noted within the authorities is variable and commercial viability of the reserves is unknown, making it hard to identify possible future extraction sites. Therefore the policy to safeguard soft sand resource in M2 and the opportunity for soft sand to come forward under policy M4 is welcomed. The “Minerals & Waste Safeguarding Study (June Noted. 2018)’ has been published as part of this consultation exercise. This document correctly highlights the importance of remembering that safeguarding areas do not prevent development from occurring and recognises that there will be circumstances where the need for development outweighs the benefits of protecting the mineral resource and that there may be opportunities to accommodate both through the use of prior extraction. The Study highlights that safeguarding is not necessarily a barrier to non-minerals development and indicates that early consultation on non-minerals and waste development proposals will allow safeguarding to be built into the scheme. This advice will need to be borne in mind both within the policies of the Minerals and Waste Local Plan and by the local planning authorities across the area more generally, for example in relation to development management decision taking and the consideration of site suitability through their housing and economic land availability assessments. The proposed wording of ‘Policy M2: Safeguarding Policy M2 iii states that development would be sand and gravel resources’ is led by the advice that permitted in a mineral safeguarding area if it is set out within Recommendation 9. However, a would be inappropriate to extract with regard to separate criterion is required that allows a positive other policies in the Local Development Plan. In approach to be taken in allowing non-minerals addition, para 5.37 refers to ‘projects of development to be permitted if the planning benefits overriding importance in the Central & Eastern of the non-mineral development clearly outweigh Berkshire Authorities’ Local Plans to proceed the need for the mineral resource. where this can be demonstrated’. Policy M2 – worried that by supporting this policy Policy M2 considers the safeguarding of mineral the site could be used for extraction just because it resources to prevent sterilisation. was not being used for development. In a densely populated area the emphasis must be on The Development Management (DM) policies safeguarding what parts of the environment we can. seek to control the impacts of development.
M2 Safeguarding sand and gravel resources We Para 5.34 will be reviewed in relation to the are pleased to see a commitment to the reference to ‘special consideration’. safeguarding of sand and gravel resources. We would like to see clarification of what “special consideration” means in relation to the deposits of soft sand (5.34).
M3 Issue Response Policy M3 needs more clarification, because at Noted - further consideration will be given to present, it is unclear as to why the monitoring monitoring indicators. indicators for policies M3 and M4 trigger policy review for the landbank being below 7 years after 5 consecutive years but an increase or decrease in sales would trigger a review after 3 consecutive years. Having a landbank lower than 7 years for 5 consecutive years can be particularly concerning to the industry especially with the lead in times needed for mineral extraction. Paragraph 5.57 of the Draft Plan fails to recognise It is recognised that greater clarification of the that paragraph 205 of the National Planning Policy Ham Island proposal is required as extraction is Framework requires minerals planning authorities not intended to impact on the Scheduled Ancient to “as far as is practical, provide for the Monument. maintenance of landbanks of non-energy minerals from outside National Parks, the Broads, Areas of Further information from HE raised concerns Outstanding Natural Beauty and World Heritage regarding present of peat and impact on the Sites, scheduled monuments and conservation SAM (therefore, site has been discounted as an areas”. The proposed allocation of Ham Island at allocation). Old Windsor contains the Early medieval and medieval palace and associated monuments of *Linked to Ham Island comments Kingsbury scheduled monument. Policy M3 – given the current land bank and the It is recognised that further permissions will very short lead times to grant planning permission increase supply but equally sites are also and commence any shallow extraction, the policy depleting and in 2017, two sites within the Plan should only release land once, based on current area closed. data the land bank has fallen below 3.9 million tonnes (being 7 years of average sales 555,163 More detail on minerals data is provided in the tonnes). Any permissions granted ahead of this will Minerals Background Report. Some information only serve to increase the existing 12.1 years of cannot be provided due to commercial land bank, which is not supported by the NPPF. sensitivity. However, further consideration will be Based on the current data this could suggest given to demonstrate the predicted shortfall. monitoring for the land bank falling below (say) 4.5 million tonnes as the monitoring indicator for any The decision on the Poyle Quarry (this was later future change in this policy. There should be no permitted) application is awaited. Riding Court pre-judging of any shortfall through the use of Farm is listed as an existing site, with permitted provision rates ahead of any actual shortfall as reserves already listed in Policy M4. suggested in 5.60. The conclusion within 5.65 of a shortfall is difficult to support given the lack of credible long term forecasting included to support the Draft Plan, in terms of long term supply and demand and marginal cost analysis of alternative forms of aggregate or the updated forecasts for lower near term economic growth in the early stages of the plan period. In any case any shortfall will, if it occurs, not be in the short term but rather towards the middle / end of the plan period for
which a monitoring indicator as suggested above would suffice. The outcome of the application for Poyle Quarry as well as sales from Riding Court Farm also contribute towards the permitted reserves and should also be considered. Policy M3- there is an implication the at minerals The Managed Aggregate Supply system should be extracted locally, it could be justified to requires mineral planning authorities to make an import given population density. appropriate contribution to national as well as local supply. Policy M3 - The difficulty in disaggregating the The high level of uncertainty is recognised not historic data has resulted in considerable only in relation to data but also the change in uncertainty being attached to the data which has local circumstances which could significantly emerged from the process of determining past impact supply such as Heathrow. Therefore, aggregate sales, the data should therefore be this issue has been outlined specifically in the reflected as a range, this should also be applied to policy. A significant change over a 3-year period future aggregate demand. would trigger the need to review the Plan. Policy M3 - object to this policy and request that it is It is considered that policy M3 is worded to be reworded to reflect the fact that the annual rate of sufficiently reactive to changes in demand within provision may need to be updated on an annual a 3-year period, but also to not be overly basis to reflect the latest Local Aggregate reactive to changes within a one-year period Assessment (LAA). The 0.71mt average rate of which could be due to a number of reasons such provision is based on previous sales and whilst this as a site closure, to a new site coming on is one indicator of future provision it is not the only stream, single major project. consideration. The joint authorities also need to consider the productive capacity of the quarries that Local circumstances are considered in the Local contribute to the landbank and ensure that the Aggregate Assessment (LAA) and the LAA permitted reserves that are not held in a few large would also be used to inform decision-making. quarries. This sort of factor should be considered in It is recognised that it would be helpful to make the LAA. Would like the words “subject to the reference to the LAA in the implementation text. impact of local circumstances on demand” to be replaced by “subject to the latest annual Local Aggregate Assessment”. Policy M3 - This policy does not specify a level of Paragraph 5.53 identifies the requirement for requirement for sharp sand and gravel and soft sharp sand and gravel is 7,520,380 tonnes. The sand, instead identifying a yearly production rate. provision rate of 0.71 million tonnes referred to Therefore, it is not clear how this policy, and the has been calculated based on the 3-year site allocations in Policy M4 will achieve an average sales to ensure a steady and adequate adequate supply of aggregate minerals over the supply of aggregates. plan period, as required by the NPPF. The site allocations in Policy M4 identify where the mineral could be extracted. However, it is recognised that the proposed sites are insufficient to meet the full requirements during the plan period and therefore, a criteria-based policy has been included to guide future developments. M3 Sand and gravel supply We support the There are no soft sand sites proposed in the commitment to maintain a landbank in accordance plan and therefore, a commitment of supply with the NPPF and the recognition that change in cannot be made within Policy M3. However, local circumstances will have an impact on demand Policy M1 (Sustainable Minerals Development and therefore the landbank. We acknowledge and Strategy) recognises the need to work with other support that the Plan has based its requirements for minerals planning authorities to enable supply. sharp sand and gravel on the 3-year figures rather than the 10 year figures. Policy M3 makes no reference to soft sand and how provision is to be made for the identified 1.5million tonnes required over the Plan Period as identified within the
Background Study, LAA 2017 and the Sustainable mineral strategy within the draft Local Plan. The soft sand issue should be addressed within this Policy. 5.52 - There is no proven need at this point in time, The granting of planning permissions is the remit to grant any additional planning for new sources of of the Central & Eastern Berkshire Authorities aggregates. The assessment of 12.1 years of and will be determined based on the landbank is significantly above the 7 years required circumstances at the time of application by the NPPF. Instead, the monitoring of the submission. landbank position should continue and should there be a proven requirement, after 3 successive years The Joint Minerals & Waste Plan seeks to of a shortfall, only then should there be a allocate and enable sufficient sand and gravel presumption for granting permission for new sites to enable a steady and adequate supply of sources be considered. minerals up to 2036. The monitoring of draft Policy M3 (Sand and gravel supply) states that if the provision rate cannot be met over 3 consecutive years or the landbank is below 7 years for a period of 5 years, the Plan will need to be reviewed.
A Local Aggregate Assessment is produced annually by the Central & Eastern Berkshire Authorities and will monitor the landbank.
Consideration needs to be given to the time it takes for mineral sites to come forward – the UK Minerals Strategy states that it can take up to 15 years between the discovery of a potentially workable deposit and actual production.
M4 Issue Response M4 – Spencer’s Farm site is allocated in the draft The Joint Minerals & Waste Plan is being version of the RBWM Borough Local Plan (BLP) prepared alongside the development of each for residential development (approximately 300 of the Central & Eastern Berkshire Authority dwellings). The site is also allocated for the Local Plans. Opportunities for prior extraction delivery of strategic infrastructure in the form of a will be outlined in the relevant Local Plan. 3FE primary school which RBWM intends should serve the town of Maidenhead not just the development at Spencer’s Farm. Policy 4 refers to locations for sand and gravel extraction, including a site called ’Sheephouse Farm, Maidenhead’. Land at Spencer’s Farm forms a small part of the area covered by Sheephouse Farm. There could be chance at the outset of this project to exploit any mineral reserves that could viably removed without adverse environmental impact. Concerns over the lack of reserve sites and all The shortfall of sites is acknowledged. The the future risks that entails. Draft Joint Plan included all sites nominated as part of the call for sites exercise. A further call for sites has been issued to try and increase the reserve. Policy M4 Minerals Sites: concerned that clause 4 Safeguards for the natural, built and historic of Policy M4 has no safeguards for the natural, environment are considered under the built or historic environment – these are relegated Development Management Policies. to a reference to development management Paragraph 5.69 states that all relevant policies policies in the supporting text. This is not will need to be complied with. consistent with the approach in Policy M6 which specifically includes “The proposal not having an Paragraph 5.66 states that the sites are unacceptable impact on the environment” within considered ‘appropriate for development the policy and is therefore more robust. We also subject to the relevant development consider that Policy M4 should include a considerations outlined in Appendix A’. requirement for development proposals for any of However, it is agreed that this should be raised the allocated sites to take the site-specific under the Implementation section. considerations in Appendix A into account. Some of the proposed minerals and waste sites Sequential testing will be undertaken in the in policies M4 - Locations and Sites for water Strategic Flood Risk Assessment which will management and W4 Locations for sand and support the Proposed Submission Plan. gravel extraction lie within Flood Zones 3 or 2 and therefore need to be sequentially tested. As this evidence has not been produced then this plan is currently unsound as it is not consistent with national plan policy NPPF paragraphs 157 and 158 or justified. Policy M4 - Removal of Ham Island and Riding Noted. Court Farm from plan. Policy M4 - Bridge Farm – P130 The adverse All information received regarding the effects identified do not include the specific proposed site allocations will be taken into impact on a restored bocage and wetlands consideration in the preparation of the restored as part of the South of the M4 Proposed Submission Plan including a review development. The Shinfield South Alternative of the Development Considerations. Natural Green Space (SANG) is adjacent to the proposed site and, as it is North, downwind of *Linked to Bridge Farm comments prevailing weather. It will therefore be subject to degradation of amenity and environment by virtue Bridge Farm was subsequently refused of dust. The policy neglects completely to permission by Wokingham BC and the provide for the impact on river ecology of landowner withdrew the site from adjacent quarrying. Turbidity as a result of dust consideration. and silt from riparian quarrying may compromise a sensitive chalk-stream type habitat that includes
native mussels. These are exceptionally vulnerable to turbidity and rely on salmonids for reproduction, which would be adversely affected by turbidity from dust. Photographs and grid reference available on request. Secondarily, the impact on amenity for fishing has not been considered. Most problematically, parts of the Loddon were specifically designated and protected with regards to Salmonids, Cyprinids and water quality under the Freshwater Fish Directive and Water Framework Directive. These impacts have been arguably illegally disregarded. I therefore propose that Bridge Farm be excluded from the policy, or its inclusion deferred until the viability of less sensitive sites is confirmed. Specifically, it conflicts with the amenity of new developments, and with housing policy and planned intensive development in Shinfield West and the South of the M4. In addition, road access via the new Shinfield relief road is through an area which is planned to be completely subsumed by housing which has been already approved. Lorry access via the Shinfield relief road and Arborfield will therefore be through housing. The consideration by the draft policy is therefore inadequate as it does not consider health and environmental impacts in both Shinfield and Arborfield's new housing developments, which were not, seemingly in existence when the policy was written. Policy M4 – changes sought to policy - It is too All information received regarding the late to extract sand and gravel from the Bridge proposed site allocations will be taken into Farm site given the extensive residential consideration in the preparation of the development that is ongoing in the surrounding Proposed Submission Plan. villages. Apart from the noise, dust and pollution from the site itself the impact on current and *Linked to Bridge Farm comments predicted traffic flows will be significant. And the late inclusion of a ready-mix concrete plant will Bridge Farm was subsequently refused significantly increase the impact of the site on the permission by Wokingham BC and the local area with increased danger on the roads landowner withdrew the site from and pollution of the natural environment including consideration. the river Loddon. Brown field sites and those where mineral rights Noted – non-minerals or waste development is granted decades ago are being exploited should considered through the preparation of the be considered for social housing before anything relevant Local Plan. else. The impact on the neighbourhood would be far less detrimental Policy M4 – Support the policy on the supply of Noted. recycled and secondary aggregates. This is a sustainable approach to sand and gravel working. Recycling of aggregates at quarry sites can enable blending of recycled aggregates with primary aggregates and allow the primary resource to be conserved for higher end product use. Paragraph 204 of the NPPF states that planning Noted. policies should provide for the extraction of mineral resources of local and national importance. The Draft Plan identifies draft allocations at Poyle Quarry (2 extensions), Water Oakley and Monkey Island Lane Wharf. All of the allocations are important for providing a steady
and adequate supply of sand and gravel in the local area, either directly via extraction or by enabling the sustainable transport of material for processing. The most recent data available (as published within the Draft Joint Minerals and Waste Local Plan) states that reserves of sand and gravel in Central and Eastern Berkshire with planning permission for extraction (permitted reserves) at 31st December 2016 were 6,723,000 tonnes. Based on the 10-year average sales of 555,163 tonnes, the landbank for sand and gravel sites within Central and Eastern Berkshire is 12.1 years. However, based on a 3-year average this decreases to 9.4 years which is not far from the required 7-year provision set out in the NPPF. The 3-year average is also likely to reflect the increase in demand suggested by recent sales figures. Therefore, the Central and Eastern Berkshire – Local Aggregate Assessment (LAA) for the period 2016, determined the expected Provision Rate for the Plan period as 0.71 million tonnes. The proposed Plan period is up to 2036. If the LAA rate is projected forward from 2016 to 2036 a total of 14,243,380 tonnes of sharp sand and gravel would be required over the course of the Plan. Taking into account that current permitted reserves for Central and Eastern Berkshire are 6,723,000 tonnes (not including Star Works Quarry2). This means that there is a requirement of 7,520,380 tonnes of sharp sand and gravel. The draft allocations at Poyle and Water Oakley will deliver approximately 3 million tonnes of aggregate over the plan period. The draft allocation for the wharf at Monkey Island Lane will also assist in the efficient movement of raised mineral to serve the existing processing site at Monkey Island Lane. We welcome the inclusion of the draft allocations within the plan, which will contribute to addressing the current shortfall and meeting the requirement described above. Paragraph 16 also states that plans should Noted contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals. Draft Policies M4 and M7 clearly identify that the named sites have been identified for future development. Managing the supply of aggregate (page 31 to Noted 33) - *Ref App A Poyle Quarry, Poyle Quarry Ext, Water Oakley Paragraph 16 of the NPPF also requires that plans be prepared positively, in a way that is aspirational but deliverable. All of the sites identified above are within the control of Summerleaze, as a result, the joint authorities should be satisfied that the draft allocations are deliverable within the plan period. It is considered that the draft plan has been prepared positively with the joint authorities identifying a need to ensure the steady supply of sand and gravel by allocating a number of sites for future sand and gravel extraction.
Locations for sand and gravel extraction (page 34 Noted to 37) - *Ref App A Poyle Quarry, Poyle Quarry Ext, Water Oakley The specific future development considerations and requirements for each of the sites are set out at Appendix A of the plan. Sustainable Development (page 74 to 75) - *Ref Noted App A Poyle Quarry, Poyle Quarry Ext, Water Oakley Paragraph 16 of the NPPF states that plans should be prepared with the objective of contributing to the achievement of sustainable development. From the assessments provided for each of the sites as detailed in Appendix A of the draft plan, it is clear that the joint authorities have fully considered the impacts of the draft allocations and identified areas where mitigation or further information is required in order to ensure that development can proceed at the identified sites in a sustainable manner. Paragraph 204 states that policies set out criteria or requirements to ensure that permitted and proposed operations do not have unacceptable adverse impacts on the natural and historic environment or human health. Appendix A of the plan sets out development considerations which the developer should consider when preparing proposals for the draft allocations. The plan is therefore considered to accord with this requirement. The draft allocations are considered to accord with each of the three objectives which contribute towards the meaning of sustainable development (as defined by paragraph 8 of the NPPF). Protecting Public Health, Safety and Amenity Noted (page 95 to 97) - *Ref app A Poyle Quarry, Poyle Quarry Ext, Water Oakley In terms of the environmental role, the draft allocations represent the most efficient use of natural resources with future development proposals seeking to minimise waste and pollution. Each of the draft allocations will be subject to the requirements as set out in Appendix A of the draft plan, ensuring that future development can proceed at the sites without posing an unacceptable impact upon the environment. In terms of the social dimension, the Minerals Noted Products Association suggests that a house requires 200 tonnes of aggregate, a school may require 15,000 tonnes of concrete and a community hospital may require 53,000 tonnes of concrete. In addition, maintaining and improving the existing built fabric of the area can also requires large quantities of aggregate. One of the UK Government’s key aims is to increase housebuilding with a target of delivering one million new homes by 2020 announced by Housing Minister Brandon Lewis in September 20154. The Strategic Housing Market Assessment for Eastern Berkshire has an objectively assessed need for 2,015 new dwellings per annum between 2013 and 2036. A range of transport infrastructure and commercial
development are planned to take place during the plan period which will require aggregates. Crossrail, one of the largest construction projects in recent years, extends well into Central & Eastern Berkshire, with the current terminus planned to be at Reading. Town Centre developments are due to take place including areas allocated in Maidenhead Town Centre Area Action Plan comprising residential, retail (25,000 sq. m), office (79,000 sq. m), other employment (4,000 sq. m), public transport interchange, other uses including leisure and culture. Together these construction projects will require a range of aggregates amounting to on-going demand that will need to be met through the supply of sand and gravel, crushed rock and recycled aggregates in the years ahead. The supply of sand and gravel as a result of the draft allocations will be essential in meeting the needs of present and future generations in terms of the built environment, infrastructure and services. The draft allocations will also impact waste Noted growth in the years ahead. For example, the site at Water Oakley will provide an excellent facility for the deposition of inert material resultant from local construction projects. The draft allocations will offer long term, stable, Noted full-time employment prospects at a local level and will provide opportunities for promotion and advancement though training and experience. The development proposals resulting from the draft allocations will also allow our client to continue to invest in local communities in terms of training, educating, employment contributions, economic advancement, sponsorship and charitable support. The draft allocations appear to be based upon a Noted robust evidence base and would allow the joint authorities to deliver a steady and adequate supply of sand and gravel in a sustainable manner. We would urge the joint authorities to continue to progress with the allocations as the emerging plan continues to proceed to examination and adoption Policy M4 - It has already been noted in our The airport expansion scheme is being closely comments on the Minerals Proposals Study that followed to determine the implications for the several of the sites proposed for sand and gravel Joint Minerals & Waste Plan. Currently the extraction have been put forward as potential borrow pits are ‘proposals’ in the Heathrow borrow pits for the Heathrow Airport expansion. Airport expansion plans but their contribution is Therefore it is questioned whether these sites will uncertain. At this time, no further site options be available to meet the total mineral requirement are available and therefore, greater emphasis in Central and Eastern Berkshire over the plan will be placed on windfall opportunities. period, if they are being used to meet the specific requirement for the Heathrow Expansion. It is ‘Appropriate locations’ are guided by the site also questioned what an ‘appropriate location’ criteria listed in part 2 of Policy W4. In addition, would be, regarding windfall sites in paragraph 4. Para. 5.69 outlines that an appropriate site would comply with all the relevant policies in the Plan. However, it is recognised that reference to the development considerations in Appendix A should be made in the implementation section.
Policy M4 - There are four sites in your draft plan All information received regarding the that are either in or are adjacent to the parish of proposed site allocations will be taken into Colnbrook with Poyle – Poyle Quarry, Poyle consideration in the preparation of the Quarry Extension, Berkyn Manor Farm and Proposed Submission Plan. Horton Brook Quarry. Notwithstanding the negative site specific impacts which would be The proposal at Horton Brook is for aggregate clearer when more detail is available than is recycling within part of the site boundary and currently in your draft, all of these sites and their not for landfill. haul routes will put huge amounts of traffic onto roads going through our parish, or adjacent to it. We object to the increased traffic congestion and air pollution that this will cause in areas that are already heavily congested and suffering poor air quality well below EU Directive minimum standards. Moreover, some of the sites are very close to residential properties, and all four are in the Colne Valley Park and will cause loss of amenity and openness, negatively impacting on the quality of life and landscape. Most of the land is agricultural; the Horton Brook Quarry – currently in operation – was given permission on the express condition that the land would be worked for a limited period (already extended) and would be restored to agriculture as soon as minerals extraction ceases. The proposal in the draft plan to infill with waste after extraction violates this condition of permission and, generally, waste landfill will make return to agricultural use less viable. Policy M4 - This policy does not include provision The proposals outlined in Policy M4 would for suitable vehicle access. Clearly that should be need to be taken into consideration alongside a primary consideration for any mineral extraction all the other relevant policies in the Plan (as site. Policy W4 clearly states that ….the site ‘has per Para. 5.69). This includes Policy DM11 good connectivity to the strategic road network’. (Sustainable Transport Movements). a. Horton Brook Quarry access is directly from Horton Road through a dangerous junction in Poyle Quarry and its access road have Colnbrook which includes passing beside a recently been permitted by the Royal Borough children’s playground and housing estate before of Windsor & Maidenhead and Slough accessing the Bath Road. This is dangerous and Borough Council respectively (application disruptive to local residents. b. Berkyn Manor, 17/03426/FULL). Relevant site forms in the Poyle Quarry, and Poyle Quarry Extensions will STA have been updated to reflect this. all be dependent on a new road which will lead onto Poyle Road in Colnbrook. This has not yet The developer has indicated that Poyle Quarry been agreed with Slough Borough Council, nor will use this new access instead of the existing were Colnbrook Parish Council even aware of the one. Use of this access by adjacent sites will proposed road plan. Therefore this section of the depend on phasing of sites. It should be noted policy is clearly flawed. that Horton Brook Quarry is under separate Change sought - We do not believe the policy can ownership to Berkyn Manor Farm, Poyle proceed until a proper road management policy Quarry and Poyle Quarry Extension. has been consulted upon and agreed with all the affected parties viz Horton, Slough BC/Colnbrook PC. Horton Parish Council specifically would like to be properly consulted regarding road access to all the above sites. This should take place before any further plans are established for either mineral extraction or infill on any of the sites within our Parish. M4 - The identified sites provide for a total of There are no soft sand sites proposed in the 7,330,000 tonnes of sand and gravel, which is plan area. However, Policy M4 is worded to 190,380 short of the total required over the Plan support any sites that come forward containing Period. We note the contingency approach within soft sand. Consideration will be given to the Policy M4, however it would be preferable to
make full site provision for the identified need supporting text of the policy with regard to soft over the Plan period to provide greater certainty. sand. We would expect to see reference to soft sand within the supporting text, as it is included within the Policy (4). We support the inclusion of M4 4ci to allow soft sand sites to come forward if possible.
M5 Issue Response Policy M5 P39 – recycled and secondary Secondary aggregate are usually by-products aggregates – paragraph 5.81 “there is no of other construction or industrial processes secondary aggregate produced within Central and and this is outlined in Para. 5.78. eastern Berkshire”. Surely that is what the aggregate recovery sites in Annex 2 [Waste The aggregate recovery facilities listed in Background Report] are purported to be. Annex 5 Annex 2 of the Waste Background Report and [Waste Background Report] Current Site sites that process construction, demolition and Capacities - Unsure what capacity is meant to be construction material. However, not all addressing believes Wraysbury sites are being produce recycled aggregate. double counted. Would like these secondary sites included & monitoring functions provided. Annex 5 of the Waste Background Report outlines the permitted capacity at waste sites. Some sites have more than one operation (treatment or transfer) and will have different capacities for waste management for each of these operations. The disposal of recycled and secondary Policy M5 seeks to enable and encourage aggregates should not impact adversely on the aggregate recycling facilities. local environment, which this plan would. The Development Management (DM) policies seek to control the impacts of development. However, it is recognised that signposting it required in the implementation text. Change sought to Policy M5 - It is questioned ‘Appropriate locations’ are guided by the site what ‘appropriate locations’ are in relation to this criteria listed in part 2 of Policy W4. This policy (is this the spatial strategy for waste requires signposting in the implementation development in Policy W4?) section. M5 Supply of recycled and secondary aggregates It is recognised that there is a lack of reliable Should the Policy read 0.05 million tonnes per data on recycled aggregate. Further work is annum? Paragraph 5.19 of the Draft Plan and the being undertaken to try and improve on the Background Study, highlights that there is no data to inform the Proposed Submission Plan. reliable or comprehensive data on production or An update in figures is reported as more data use of recycled aggregates, and that historically is made available. The Draft Plan was these have been recorded on a Berkshire County published after the LAA and so contains the – wide level. For the County these figures show most update to date information. sales of recycled and secondary aggregates are increasing and 2016 saw 498,000 tonnes sold. The Central & Eastern Berkshire Authorities However, the Background study report (Table 5.4) will seek to maintain capacity by safeguarding shows that there has been a steady increase in aggregate recycling sites. However, only the amount of C&D waste arising and being permanent facilities can be safeguarded as treated within Central and Eastern Berkshire and temporary facilities are usually associated with also an increase in the amount exported out of the an operational quarry or a specific Plan area. The 2017 LAA also contains sales data construction project. Therefore, it would not for recycled and secondary aggregates for a be practicable to seek to maintain a higher three-year period which indicates an average of capacity figure as this may result in an 105Tt per year and that capacity survey extended period of time for temporary information indicates recycled and secondary facilities. aggregate sites are currently operating under capacity. In 2016 Central and Eastern Berkshire The policy encourages aggregate recycling had 379,800 tonnes of recycled aggregate and the figure quoted in a minimum.
capacity, some of which was temporary, and the LAA reports that this could potentially be even higher. Therefore, as a minimum within this Policy, we would expect a commitment to protect the existing sites and replace the temporary sites as and when required, in order to maintain the current capacity at 380000 tpa and enable sales to continue at least at the current level. The commitment to maintain capacity of only 10- 50,000 tonnes over the Plan period seems very insufficient. Rather than relying on exporting material to recycled aggregate facilities elsewhere, the Plan should look to provide facilities to deal with its own arisings. Within Table 7 of the 2017 LAA, Sales of Recycled aggregate for Central and Eastern Berkshire is given as 0.5million tonnes. Clarity is required as to where this figure comes from as this contradicts the sales figures within Table 5 of the LAA and the Local Plan/Background Study.
M6 Issue Response M6 - Proposals for the extraction of chalk and clay Noted – the issues raised would be addressed to meet a local demand will be supported, in by Policy DM10 (water Environment and Flood appropriate locations, subject to: i. The proposal Risk). not having an unacceptable impact on the environment and communities; and ii. There being no other suitable, sustainable alternative source of mineral available.” It is expected that the above policy requirements will be demonstrated in the planning application phase through pollution management plans and planned mitigation measures to prevent water laden with suspended solids entering the watercourses. Both above and below ground pathways from site to river need to be assessed in order to ensure appropriate mitigation measures are in place. This would help to ensure the application is compliant with the WFD objectives to prevent deterioration in status and ensure the development does not prevent the future target status of the water body being achieved. Water bodies can be both surface and ground waters. Site drainage strategies would identify what is proposed for foul, trade, and surface water and should be included in the application and available at consultation. M6 Chalk and clay We support this Policy Noted
M7 Issue Response Policy M7 - Fails to make environmental issues Environmental Issues are considered under top priority the Development Management Policies. Para. 5.119 states that all relevant policies will need to be complied with. M7 - The sequential test will also need to be Sequential testing will be undertaken in the applied to other development within Flood Zones Strategic Flood Risk Assessment which will 2 and 3 such as Policy M7 for the Proposed support the Proposed Submission Plan.
Aggregate wharves and rail depots. Monkey Island lies within Flood Zone 2 and this site will All information received regarding the need to be sequentially tested. Site allocations proposed site allocations will be taken into and river corridors - Monkey Island Lane Wharf consideration in the preparation of the The River Cut is not a “navigable waterway.” Proposed Submission Plan. There may be a right of navigation but this does not mean it is navigable. There is no mention of Development Proposals are set out in the River Cut in the ecology or water environment development Policies (W – waste and M- sections. This needs to be added to the text. minerals). The Development Management (DM) Policies seek to control the impacts but do not refer to specific proposals. Policy M7 – definition of appropriateness needed, It is recognised that signposting is required in more recognition of DM policies needs to be relation to appropriateness of sites in relation included, no connectivity should be even to Policy M7. considered if it is going to affect flooding risks for example. Para. 5.119 states that all relevant policies will need to be complied with. There is no co-ordination between the rail plan for Noted. passengers and for the movement of aggregates. The latter will piggy back off any changes made to improve commuting without contributing to the capital cost. The commercial sector will benefit without cost to themselves. Paragraph 16 also states that plans should Noted contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals. Draft Policies M4 and M7 clearly identify that the named sites have been identified for future development. The other provisions of paragraph 16 in relation to Noted engagement; accessibility and clarity also appear to have been met within the draft plan. The proposed development is considered to accord with the requirements of Paragraph 16 of the NPPF with respect to plan-making. With regards to the economic dimension, the proposed development will generate direct employment for full and part time staff. The proposed development will also help to sustain existing employment at the Monkey Island Lane Processing site. Development of the sites will result in a significant annual expenditure of millions of pounds on the likes of purchases, transport, wages, consumables, services, and business rates. This expenditure will directly and indirectly benefit the local economy. M7 Aggregate wharves and rail deports Support Noted this commitment towards aggregate wharves or rail depots.
M8 Issue Response Paragraph 204 of the NPPF states that planning Noted policies should safeguard existing, planned and potential sites for: the bulk transport, handling and processing of minerals; the manufacture of concrete and concrete products; and the handling, processing and distribution of substitute, recycled and secondary aggregate material. The
identification of the wharf at Monkey Island Lane directly accords with this requirement and will allow the operator to transport material via barge along the River Thames to serve the existing processing facility.
Minerals Background Study Issue Response Minerals Background Study comments The evidence base has been compiled with the most up-to-date information available. Sand and Gravel Data Where possible, improved and updated It is noted that Berkshire-wide data is used with evidence will be obtained to support the regard to consumption figures, and it is Proposed Submission Plan. This will include acknowledged that this is the best available data, updated LAAs of neighbouring authorities. as data down to individual Mineral Planning Authority level is very poor for Berkshire.
Sand and Gravel Sales Please note that West Berkshire have revised the sand and gravel sales figures for the previous 10 years, due to being able to publish actual production figures now (whereas estimates and publicly available information were used in the past). These are included in the West Berkshire 2017 LAA due to be published shortly. The method for estimating sales in the Central and Eastern Berkshire area prior to 2016 is reliant on sales figures in West Berkshire (Table 5.13). However, it is not expected that the revisions of Noted West Berkshire figures will affect the method for estimating sales in the Central and Eastern Berkshire area (Table 5.13). This is because the revisions to estimates would also affect total Berkshire sales to the same magnitude, as the It is recognised that further work is required on West Berkshire figures are a component of the soft sand supply in the plan area. Policy M4 is total Berkshire-wide sales. Therefore the worded to support any sites that come forward difference between Berkshire-wide sales and containing soft sand. West Berkshire sales (and therefore inferred Central and Eastern Berkshire sales) will still be the same. Please let us know if this requires any clarification.
Sharp Sand and Gravel Provision It is noted that the past three year sales average is to be used in determining the requirement for sharp sand and gravel over the plan period. Based on the trend of increasing sales over this period, it would seem appropriate to use this figure instead of the 10-year average.
Soft Sand Provision Estimates of soft sand consumption within the plan area is given in Table 5.14 and an average of approximately 0.08 million tonnes per year (or 1.5 million tonnes over the plan period) has been used as the basis on which to calculate need for this aggregate. It is noted that there are deposits of soft sand within the plan area, but that these The aggregate recycling capacity is informed deposits are of variable quality and it is not known by the Aggregate Monitoring Survey and EA the commercial viability of these deposits permit information and looks specifically as
(paragraph 5.97). It is acknowledged that no sites the supply of aggregate recycling. The Waste have been nominated for soft sand extraction, Background Study looks at the treatment and however, planning guidance does also identify transfer in relation to the management of that Preferred Areas, and Areas of Search may be CD&E wastes. appropriate ways to plan for mineral extraction (NPPG Minerals Paragraph: 008 Reference ID: Each of these data sets will be reviewed and 27-008-20140306), and paragraph 204 of the further work is to be carried out to try to NPPF states that planning policies should aim to improve the data on aggregate recycling. source minerals supplies indigenously. Consideration of these options could be complemented by a better understanding of the soft sand resource within the plan area. Paragraph 5.57 states that the only source of soft sand is land-won. However, this does not account Noted. The plan area is entirely dependent on for marine sand, which is understood to be able to rail depots in neighbouring areas, so the substitute in certain end uses1. Paragraph 5.100 situation at Theale will be followed to states that the need for soft sand will have to be determine the implications for the Joint secured from neighbouring authorities should Minerals & Waste Plan. insufficient resources be identified within Central and Eastern Berkshire. However, it would seem that no further investigation into the ability of the plan area to meet its demand for soft sand has Noted – the Vision, supporting text and been undertaken, including any assessment of strategic objectives will be reviewed. the resource within the plan area. West Berkshire would be concerned if reliance were placed on its supplies of soft sand, as there are very few permitted reserves remaining in the district, and further work is necessary regarding how future need will be met as the remaining deposits with operator interest are located within the North Wessex Downs Area of Outstanding Natural Beauty (AONB). This work is planned to be undertaken to support the preparation of the West Berkshire Minerals and Waste Local Plan. The authority does not anticipate being able to specifically provide for an unmet need of this aggregate in other authority areas.
Recycled and Secondary Aggregates Table 5.2 – The capacity estimate for recycled aggregate capacity in this table (379,800 tpa) differs from the equivalent capacity estimate in the Waste Background Study (242,500 tpa treatment and 108,500 tpa transfer (351,000 tpa total) – Table 5). It would be useful to know the reason for the differences in this data – for example, if different data sources or parameters have been used. Table 5.3 – These figures differ from those in Table 3.14 of the Berkshire Local Aggregate Assessment. It would be useful to know the reason for the differences in this data – for example, if different data sources or parameters have been used. Table 5.4 – Please note that the format of the table in the West Berkshire LAA that this table has been based on has been updated in the West Berkshire 2017 LAA due to be published shortly. This is because it is considered that inert material that is not ‘treated’ within an authority area may also be managed in another way (landfill, recovery) within the authority, and not all of it necessarily travels outside of the authority for ‘treatment’ elsewhere. It is considered that a more
accurate way to represent inert/CDE waste that travels outside of the authority for treatment, is to subtract the amount of inert/CDE waste arising and also treated within the authority from the total amount of inert/CDE waste treated within the authority (assumed exports = total C&D waste treated within authority minus C&D waste arising and treated within authority).
Rail Depot Safeguarding Support for the safeguarding of rail depots within West Berkshire is noted. The rail industry at Theale is proposed to be safeguarded in the new West Berkshire Minerals and Waste Local Plan (as set out in the consultation on Preferred Options). Paragraph 4.31 states that the operators at Theale show no indication at present of seeking to increase capacity. It could also be noted that in 2016 one of the rail depots at Theale previously importing cement also started to import aggregates for concrete production and for onward transportation.
Non-aggregate Minerals We note and accept the conclusions on non- aggregate minerals. Draft Local Plan Document Vision Paragraph 3.4 states that the Joint Minerals and Waste Plan will seek to (inter alia) maximise the recovery of waste. However, this would appear to be contrary to the Waste Hierarchy, which seeks to move the management of waste as high up the hierarchy as possible. Recovery falls below reuse and recycling in the hierarchy, and therefore to maximise the management of waste at this level would not push the management of waste further up the hierarchy. It is acknowledged that this sentiment is not translated into the vision of the plan, however, including it in the supporting text is at odds with the vision (and strategic objective 10), and the waste hierarchy. Strategic Objectives It is noted that there is no strategic objective relating to the provision of waste management capacity requirements. Waste plans are required to identify sufficient opportunities to meet the identified needs of their area (NPPW, para 3) and therefore including a strategic objective to support this would be appropriate. Specifically, Waste Planning Authorities in the South East have signed a Memorandum of Understanding, whereby they will aim to plan for net self- sufficiency, which assumes that within each waste local plan area the planning authority will plan for the management of an amount of waste which is equivalent to the amount arising in that plan area. Therefore this sentiment could be included in a strategic objective related to planning for net self- sufficiency. This is a response at officer level and has not gone through any formal sign off procedure in West Berkshire Council. Minerals Proposal Study comments - Borrow Pits The airport expansion scheme is being closely It is noted that several proposed site allocations followed to determine the implications for the
have been put forward as potential borrow pits for Joint Minerals & Waste Plan. Currently the the Heathrow Expansion. However, borrow pits borrow pits are ‘proposals’ in the Heathrow are generally classified as ‘windfall’ sites and are Airport expansion plans but their contribution used to support specific developments. Therefore is uncertain. At this time, no further site it is questioned whether these sites will be options are available and therefore, greater available to meet the total mineral requirement in emphasis will be placed on windfall Central and Eastern Berkshire over the plan opportunities. period, if they are being used to meet the specific requirement for the Heathrow Expansion. Agreed – Monkey Island Wharf should be Mineral Infrastructure Including the 1.4 million included in the list in Table 2 to show where tonne reserve for the Monkey Island Lane Wharf the site originated from. Table 3 will be site in Table 3 could be misleading, as this amended. reserve will be extracted from outside the plan area, and the nomination is for mineral It is recognised that further work is required on infrastructure only. In addition, this site appears soft sand supply in the plan area. No sites as a reasonable option in this Table, but it has not have been nominated for soft sand extraction. been identified in the long list of sites in Table 2. Due to the shortfall in sites, no buffer is Mineral Safeguarding - We support the intention achievable at this time. to safeguard deposits of sharp sand and gravel and soft sand at paragraph 2.9. Soft Sand Provision It is noted at paragraph 4.3 that there are no proposals for soft sand extraction to consider. However, in line with previous comments, further work could be done to identify Preferred Areas, or Areas of Search for this aggregate in line with National Planning Guidance (NPPG Minerals Paragraph: 008 Reference ID: 27-008-20140306) and Revised NPPF (2018) paragraph 204, which states that planning policies should aim to source minerals supplies indigenously. Sharp Sand and Gravel Provision It would be useful for this document to describe/quantify the extent to which the proposed allocations meet the identified requirement over the plan period, and whether any ‘buffer’ has been applied to take into account uncertainty or other factors influencing the deliverability of sites.
General Policies and other
General – Minerals & Waste The existing sites should be reclaimed, restored Existing permitted sites will have conditions and returned to safe land that has less and, where relevant, restoration plans already environmental impact. in place. The Draft Plan seeks to ensure that any future sites are restored to a high standard and in a timely manner as outlined in Draft Policy DM8. Objection to Section Three - The Evidence Base The evidence base has been compiled with (Appendix C) in the Draft Joint Minerals and the most up-to-date information available. Waste Plan. My objection is based on incorrect, Where possible, improved and updated incomplete, outdated and evidence that could be evidence will be obtained to support the considered to contain a vested interest. Summary Proposed Submission Plan. More detail on The evidence base is unsound, and given the what evidence is incomplete, incorrect or technical deficiencies this draft plan cannot move outdated is required to address these forward for adoption in its current guise. concerns directly. The overarching issue is that government and Point noted. councils should be working together to severely reduce what is being thrown 'away'. Further Waste reduction is the remit of the waste investment in recycling and stipulating only management teams within each of the Central recyclable packaging to & Eastern Berkshire Authorities (note that producers/suppliers/catering/etc is really the only Bracknell Forest, Reading and Wokingham way forward. The only way to apply pressure to work collectively through Re3). As waste is the government to introduce these measures produced, there is a need for it to be across the board is for councils to resist waste managed. However, the Draft Plan does seek dumps, to speak up and for financial implications to encourage waste to be managed at the to those not adhering to new policy to be brought highest achievable level within the waste in. hierarchy (Draft Policy W1). Processing of waste from outside of the Joint Waste management does not recognise Minerals and Waste Draft Plan should be administrative boundaries and is discouraged. Presently sites process waste from market/supply-led. At present, more of the outside of the area and priority should be given to waste arising (being generated) within Central our own capacity requirements. Tariffs, or other and Eastern Berkshire is being managed restrictions on waste from other Counties could be outside of the Plan area than within it. As imposed by policy to safeguard resource to meet such, the suggested restrictions would not be the Joint Minerals and Waste Draft Plan beneficial to the Plan area. capacities. There are a number of suitable sites within the The Central & Eastern Berkshire Authorities boundaries of the Joint Minerals and Waste Draft have received very few nominations of Plan that could provide suitable locations for new suitable sites for waste uses. Nominations for waste facilities, requiring restoration which could waste sites would be welcomed and can be be facilitated by landfill. These new sites should submitted to: [email protected]. not be safeguarded forever, but their life term should be based upon the time required to suit the Due to the lack of capacity within the Plan end purpose, the timescale required for area, all permitted sites are safeguarded to restoration. ensure that capacity is not further reduced. However, draft Policy W2 sets clear criteria for when the loss of a permanent waste facility would be considered. Minerals and waste operations are in a unique Noted. situation which enables them to deliver high quality restoration plans to benefit the natural environment at the end of their operation. The restoration plan correctly notes the large potential for high quality restoration programmes to significantly enhance the natural environment, specifically in the context of a suite of international, national and locally designated sites within the plan area. The study also includes good
examples of best practice from other places and sets out over-arching principles which should help to deliver high quality schemes. Processing plants should be sited in areas of Processing plants are most often located on brownfield development, or existing industrial use the associated extraction site to which it amongst other industrial usage i.e. large industrial relates or on a nearby quarry (or former estates such as Thames Valley Park, Slough quarry). Trading Estate, etc. Sites for aggregate recycling would need to comply with draft Policy W4 which set locational criteria for waste sites. The criteria include the use of previously-developed land and industrial estates. However, the potential for noise and dust impacts would need to be taken into consideration on surrounding land uses including other uses on an industrial estate.
Policy W4 has been subsequently updated to state a preference for waste facilities to be located on suitable existing industrial sites. Safeguarding of sites should not be automatic. Due to the lack of capacity within the Plan Unless they are deemed suitable by policies in the area, all permitted sites are safeguarded to document and there is a specific need for that ensure that capacity is not further reduced. site. However, draft Policy W2 sets clear criteria for when the loss of a permanent waste facility would be considered.
More detail on the criteria that a site needs to meet to be safeguarded is set out in the ‘Minerals and Waste Safeguarding Study’. Consideration will be given as to whether the basis for safeguarding should also be set out in the ‘Proposed Submission’ Plan. In the preparation of the current Draft Plan there The Central & Eastern Berkshire Authorities seems to have been no reference to any are working in collaboration with Hampshire assessment of the current plan and how this has Services to ensure that minerals and waste been implemented in practice and whether or not, planning expertise is applied to the given the significant time that has elapsed since preparation of the Joint Minerals & Waste the previous plan, what if any expertise exists for Plan. the preparation of the same within the respective authorities. The policies within the former Minerals & Waste Local Plans were reviewed as options to inform the reasonable policy options for the Sustainability Appraisal/ Strategic Environmental Assessment. Concern about setting a "hard" minimum The Joint Minerals & Waste Plan has to be requirement, as if insufficient suitable sites are considered as a whole and therefore, the identified, then unsuitable sites will be chosen, development policies (W and M policies) must regardless of policies that would otherwise rule be implemented in line with the control policies out the site. (DM policies). The minimum requirement is being sought over the plan period and stems from the current and predicted need for minerals and waste management facilities. The Plan has a duty to try to provide for these needs where possible. During a site’s operation any facility should be Draft Policy DM2 seeks to address the issue designed to help reduce greenhouse gases and of climate change including encouraging the encourage a sustainable use of resources. All sustainable use of resources. environmental impact should be mitigated against to acceptable levels. If this is not achievable, or limits are breached, the site should be
reassessed, the operator enforced to comply and, The monitoring of emissions relating to a site if proved to have failed repeatedly, have their would be covered by the Environmental licences revoked Permit provided by the Environment Agency.
Policy DM2 was subsequently updated to include a requirement for a climate change assessment which requires a carbon assessment of the proposal and how this will be monitored. The belief that waste disposal is sustainable is a Point noted. non-sequitur. The emphasis must be on reducing the production of waste at household and Waste reduction is the remit of the waste domestic level. Supermarkets must avoid using management teams within each of the Central plastics that cannot be re-cycled. & Eastern Berkshire Authorities (note that Bracknell Forest, Reading and Wokingham work collectively through Re3). As waste is produced, there is a need for it to be managed. However, the Draft Plan does seek to encourage waste to be managed at the highest achievable level within the waste hierarchy (Draft Policy W1). The suggestion that there can be a joint minerals The minerals and waste planning regime is and waste plan is illogical. The justification for covered by many of the same or similar mineral extraction on the grounds that it produces policies and guidance and is often the remit of landfill for waste does not take into account the the same authority and even team within that overall adverse environmental impact on the authority. Much of the evidence base, in terms environment and the wildlife, the local facilities of transport, environmental and other impacts and the quality of life for residents can also be shared. This makes it efficient to have a single Minerals and Waste Plan. The distinctions that exist between the two topics mean that there are separate policies for minerals and for waste as well as common ones (such as the development Management policies) that deal with impacts). The combined Minerals and Waste Plan does not carry a presumption that mineral extraction will be followed by non-hazardous landfill.
General Landscape Paragraph 170 of the National Noted. Planning Policy Framework (NPPF) highlights the need to protect and enhance valued landscapes Appendix A makes specific reference to the through the planning system. This may present landscape features that need to be taken into opportunities to protect and enhance locally consideration should a planning application be valued landscapes, including any local landscape submitted for the proposed allocations. designations. You may want to consider whether any local landscape features or characteristics In addition, protection of the landscape (and (such as ponds, woodland or dry-stone walls) setting of a site) is addressed in the following could be incorporated into the development in draft Policies: order to respect and enhance local landscape • DM4 (Protection of Designated character and distinctiveness, in line with any Landscapes) local landscape character assessments. Where • DM8 (Restoration of Minerals and Waste the impacts of development are likely to be Development) significant, a Landscape & Visual Impact • DM9 (Protecting Public Health, Safety and Assessment should be provided with the proposal Amenity) to inform decision making. The Landscape • DM12 (High Quality Design of Minerals Institute Guidelines for Landscape and Visual and Waste Development) Impact Assessment should be used for further guidance. Policy DM4 has subsequently been updated to make reference to the Guidance for
Landscape and Visual Impact Assessment (3rd Edition). Colne Valley Park Community Interest Company Ongoing engagement is pursued with asks for a dialogue before the draft Plan is turned statutory consultees and, where possible, with into a final Plan so the provisions in the Plan other interested parties. maximise the opportunity for environmental enhancement Subsequent meetings were held regarding Colne Valley Regional Park on the following dates: 19/12/2018 08/01/2019 18/05/2020
We are conscious that proposals associated with It is recognised that the Heathrow Expansion Heathrow expansion may also affect this area and will have a significant on the Plan area and a coordinated approach will be in everyone’s directly upon the demand/supply of minerals interests. This requires further discussion. and waste management capacity. Where relevant, this point has been highlighted and as more information is made available, it will inform the preparation of the Joint Plan. Evidence base documents contribute nothing to a Hampshire Services, part of Hampshire forward looking plan, but represents just a County Council, is working in collaboration historical review. Written by people who do not with Bracknell Forest Council, Reading live in the area and cannot gain a true realisation Borough Council, the Royal Borough of of what would occur in just a short site visit. Many Windsor & Maidenhead and Wokingham of the documents are political documents that fails Borough Council to produce the Joint Minerals to address the conflict of interest between & Waste Plan. The Central & Eastern commercial interests and those making the plans. Berkshire Authorities are the decision-making The Strategic Transport Assessment is a body. The Joint Plan is also being prepared to commercial assessment that does not take into align with the Local Plans of the Authorities to account the local priorities. This whole plan has ensure that local priorities are taken into been developed with commercial priorities given account. This is reflected in references to the top priority. The Council should be asked to make consideration of the ‘Local Development Plan’ a Declaration of Interest. (see DM2). It is clear that the supporting plans and studies were developed on the basis that we simply accept and accommodate, rather than manage and influence the key factors in the development and growth of the UK as a whole, where these factors include: A. The UK has and will continue to see population growth; which is a reasonable assumption based on historic trends etc, but hopefully is within some sensible, managed boundaries that take account of the UK capacity to absorb and support these growth numbers B. However, having accepted a level of population growth does not mean we should simply accept and plan for an ever growing population that wishes to work and live in the relatively “over- populated” areas of the UK C. Where this assumption has to date meant migration of people from abroad or across the UK to the South East, and in particular to the eastern towns and countryside of Berkshire D. A consequence of accepting this concentration in the South appears to be that we need more minerals and waste capacity in areas such as Eastern Berkshire, rather than in other less populated parts of the UK, presumably in order to minimise transport and other costs
E. Also, that it is acceptable to plan to extract all and any minerals believed to be located in existing rural and residential areas without question, and to process or dump waste in those same areas; thereby disrupting and devaluing these existing communities
People across the UK elect their Central and Local Government representatives to plan and manage the country at large in the best interests of our people and the country in the long-term, not to simply accept trends and developments that may be detrimental to the quality of life of some or all people today, and in the long-term future. By limiting housing development in overcrowded areas today – in particular the South East, including Eastern Berkshire - and at the same time by encouraging and incentivising business investment and expansion and housing development in these other generally less crowded and/or deprived areas of the UK will balance the environmental impact, quality of life and health of all parts of the UK. We desperately need a complete rethink of how we manage the use of space and resources across the UK to the benefit of all in the UK, and not simply take the easy routes. *Ref Appendix A Proposed sites crossed or in Noted. – recognition will be made to the close proximity to National Grid infrastructure: proximity to National Grid Infrastructure. Electricity Transmission: Horton Brook Quarry, Horton - VW Route – 275kv two circuit route from Poyle Quarry received planning permission in West Weybridge substation in Runnymede to Iver January 2019. substation in South Bucks (app ref ET252) Poyle Quarry, Horton - VW Route – 275kv two circuit route from West Weybridge substation in Runnymede to Iver substation in South Bucks (app ref ET253) Poyle Quarry (Extensions), Horton - VW Route – 275kv two circuit route from West Weybridge, substation in Runnymede to Iver substation in South Bucks (app ref ET254) Please see enclosed plan referenced ET252- ET254 at Appendix 1. The proposed Minerals and Waste sites are crossed by a National Grid high voltage electricity transmission overhead line. The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. To comply with statutory safety clearances the live electricity conductors of National Grid’s overhead power lines are designed to be a minimum height above ground. Where changes are proposed to ground levels beneath an existing line then it is important that changes in ground levels do not result in safety clearances being infringed. National Grid can, on request, provide to developers detailed line profile drawings that detail the height of conductors, above ordnance datum, at a specific site. Electricity Distribution SSE Power Distribution owns and operates the local electricity distribution network in Hampshire County Council. Contact details can be found at www.energynetworks.org.uk National Grid Asset
Guidance National Grid prefers that buildings are not built directly beneath its overhead lines. This is for two reasons, the amenity of potential occupiers of properties in the vicinity of lines and because National Grid needs quick and easy access to carry out maintenance of its equipment to ensure that it can be returned to service and be available as part of the national transmission system. Such access can be difficult to obtain without inconveniencing and disturbing occupiers and residents, particularly where properties are in close proximity to overhead lines. National Grid seeks to encourage high quality and well planned development in the vicinity of its high voltage overhead lines. Land beneath and adjacent to the overhead line route should be used to make a positive contribution to the development of the site and can for example be used for nature conservation, open space, landscaping areas or used as a parking court. National Grid, in association with David Lock Associates has produced ‘A Sense of Place’ guidelines, which look at how to create high quality development near overhead lines and offers practical solutions which can assist in avoiding the unnecessary sterilisation of land in the vicinity of high voltage overhead lines. Potential developers of the sites should be aware that it is National Grid policy to retain our existing overhead lines in-situ. The relocation of existing high voltage overhead lines will only be considered for projects of national importance which has been identified as such by central government. National Grid requests that any High Pressure Major Accident Hazard Pipelines (MAHP) are taken into account when site options are developed in more detail. These pipelines form an essential part of the national gas transmission system and National Grid’s approach is always to seek to retain our existing transmission pipelines in situ. National Grid may have a Deed of Easement for each asset which prevents the erection of permanent/temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally written permission will be required before any works commence within the National Grid easement strip, and a deed of consent is required for any crossing of the easement. In the first instance please consider checking with the Land Registry for the development area. Regarding the totality of the plan and confusion The Central & Eastern Berkshire Authority over how various parts of the planning process Local Plans are being prepared in parallel with join up. In recent months, comments have been the Joint Minerals & Waste Plan albeit at sought on both the Draft Local Plan for Bracknell slightly altered timescales. As such, as the and this Draft Minerals and Waste Plan. plans progress and more certainty on the Proposals have been made relating to the proposed development is gained, these will infrastructure of the area and have been detailed then inform each other. and radical. However, both sets of plans are very different and bear no relation to each other, Hampshire Services are working in despite them being produced in relation to the collaboration with the Central & Eastern same geographical area. There is no evidence Berkshire Authorities and officers from each the different sets of planners have consulted each
other, and the idea of fusing plans together is Authority reviews all documentation that is perceived to be too difficult. subject to public consultation. There is an expectation that the Waste Plan would show some evidence of Hampshire being briefed on the thinking Bracknell have done to date. So, in the proposals relating to transportation of waste from the Planners Farm site there is no mention of the suggestion in the Draft Local Plan for Bracknell to build a new spine road in Braziers Lane. Why not? Weren't Hampshire aware of it? How can the proposals in the Minerals and Waste Plan be taken seriously if they are based on assumptions that are likely to be invalid and out of date? Or is the whole thing, both the Waste and Local Plan, 'provisional'? In which case, how can one respond to the content in a sensible manner? These developments reflect a growing concern that the whole of the planning process is a done deal between politicians and developers (largely, if not wholly driven by money) who have little or no interest in listening to what the residents want. The potential for water containing high suspended Compliance with the Water Framework solids reaching water courses is fairly high due to Directive (WFD) is sought through the short pathway between the source (extraction) implementation of draft Polies: DM9 and the receptor (river). This could be over (Protecting Public Health, Safety and Amenity) ground flow or through the gravel deposits where which considers the release of emissions to it is determined to be in direct hydrologic water; and Policy DM10 (Water Environment connectivity to the rivers. Water with high and Flood Risk) which addresses deterioration suspended solids would have an impact on the of the water environment and groundwater fish populations of the receiving water bodies. sources. This could cause a deterioration in the ecological status of the rivers under the WFD. All sites would It is noted that all sites would need to be need to be compliant with the WFD. Operational compliant with the WFD and that in order that concerns would need to be addressed. It is vital an appropriate permit can be issued by the that all on site operational standards are complied Environment Agency, a site drainage strategy with regarding pollution prevention and is provided at the planning application stage. management, and any trade effluent discharges are appropriately permitted through the Environment Agency. At the planning application stage we would expect to see a site drainage strategy to highlight what is proposed for disposal of trade, foul, surface waters. This will ensure that all water leaving the site is considered and potential impacts identified and mitigated. Dewatering is now a licensable activity. In order Noted. for us [Environment Agency] to issue a licence we would need to ensure that any water dependent features impacted by any of these sites were protected. This could mean we would apply restrictions to the licence which may impact the viability of the scheme. Each scheme which requires dewatering will have to go through the normal licensing process, whereby each application is dealt with on a first come first serve basis and is determined on its merit, viability, and water availability. Groundwater Hydrology Noted – the Development Considerations will Appendix A – Proposed Sites be updated accordingly. The summary information listed in Appendix A for each proposed site allocation under the heading “Water Environment and Flood Risk” needs to
take proximity to major / minor aquifers, in addition to the proximity to SPZ, into consideration. This wording needs to be added for each site. Section 60 Accommodations Licence Noted – this is particularly relevant to Monkey The Environment Agency is the navigation Island lane Wharf and Ham Island. However, authority for the River Thames, a public river Monkey Island has existing infrastructure in regulated by statute. Successive Thames place and was formerly operational. Conservancy Acts have declared it unlawful for any person to install an accommodation in or over The applicants / operators will need to provide the public river without a licence from us. This the clarification on this issue as part of any licence is called an Accommodation Licence and planning application. is issued under Section 60 of the Thames Conservancy Act 1932. The term ‘accommodation’ applies to mooring piles, slipways, landing stages and other private structural encroachments in the public river. Any accommodation in or over the River Thames can affect the public right of access over public river space and may impact on normal river flow, flooding, the fishery and ecology of the river. Please consider this when allocating sites and this may affect the viability of some sites. We advise you to seek early consultation with us on any proposals that may affect the River Thames as set out above. Glossary & Acronyms Noted – the Glossary & Acronyms will be -Definition of Environment Agency Please note amended. that The Environment Agency only covers England. Natural Resources Wales is the body responsible for Wales. -Definition Sequential Test The sequential test needs to be carried out by the planning authority and not the Environment Agency. -Definition of Exception test This paragraph refers to “the Environment Agency’s sequential test” this needs to be removed as this is incorrect. The sequential test is carried out & applied by the planning authority. For the requirements of the exception test the Glossary needs to refer to paragraph 160 of the NPPF. Parts a and b need to be applied by the planning authority when considering their site allocations. -Definition of Flood Risk Assessment Add ‘the FRA should also demonstrate that the development will be safe for its lifetime and will not increase flood risk elsewhere.” Appendix A – Proposed sites All sites will likely The SFRA has been produced to inform the require some consideration of flood risk, although Plan preparation. It is not considered currently this has only been mentioned for some necessary because development proposals sites (e.g. Bridge Farm). The following sites have coming forward will in most cases (having more significant fluvial flood risk issues which will regard to the NPPF) require a Flood Risk need addressing: Poyle Quarry, Berkyn Manor Assessment. Farm, Horton Brook, Water Oakley Farm, Ham Island, Monkey Island Lane, Bridge Farm. We note that this is covered in the SFRA - perhaps there should be a note referring the reader to the SFRA for flood risk considerations. Environmental Permit Noted – reference will be included in the Joint Either the SFRA or the main Minerals & Waste Plan. Plan document should include an informative about sites which are adjacent to, or include, a
main river needing an environmental permit. Currently environmental permits are only mentioned in the glossary of the Plan. Suggested wording: “Developments may require an Environmental Permit from the Environment Agency under the terms of the Environmental Permitting (England and Wales) (Amendment) (No. 2) Regulations 2016 for any proposed works or structures, in, under, over or within 8 metres of the top of the bank of designated ‘main rivers’. This was formerly called a Flood Defence Consent. Some activities are also now excluded or exempt. An environmental permit is in addition to and a separate process from obtaining planning permission. Further details and guidance are available on the GOV.UK website: https://www.gov.uk/guidance/flood-risk-activities- environmental-permits.” Nature conservation and river corridors: We It is agreed that a greater emphasis should be have serious concerns with regard to the placed on the protection of river corridors and protection and enhancement of river corridors, watercourses. Consideration will be given to a and that the Joint Minerals and Waste Plan could standalone policy as suggested or whether an be more effective and reflect national planning amendment to draft Policy DM10 (Water policies (NPPF) 170, 174 and 175. Within the plan Environment and Flood Risk) will address the there is no single clear message to developers on issue sufficiently. the standards which must be met with regard to development in river corridors; a number of other A decision was made to separate the policies policies deal with various aspects of protecting into Flood Risk and Water Resources. watercourses, but this gives us no comfort that this Joint Minerals and Waste Plan specifically addresses the exclusive requirements of river corridors. Watercourses are not covered in any detail in this plan. A specific river habitat policy is required to ensure the best possible outcomes for watercourses impacted by minerals and waste sites. This needs to cover the protection and enhancement of rivers and their corridors. Watercourses are important environmental assets and an undeveloped 16 meter buffer zone (Thames Region Land Drainage Byelaws, as amended) should be required on both sides of a main river to promote strong and resilient ecosystems, green and blue infrastructure links, water quality and human health (pleasant amenity space). The policy should make it clear to applicants how the Joint Minerals and Waste Plan will expect protection and enhancement of all watercourses. This policy will reduce the likelihood that new developments next to main rivers will contribute to the deterioration of the ecological status of the waterbodies and where feasible will contribute to raising their status while providing a pleasant living environment with the associated positive social and health benefits. A good example of where a watercourse policy has been applied locally is in Wycombe District Council’s Adopted Delivery and Site Allocations Plan for Town Centres and Managing Development (July 2013), with the inclusion of Policy DM15 Protection and Enhancement of River and Stream Corridors. Alongside this sits
Wycombe DC’s River Wye Advice Note giving advice to developers and landowners with land adjoining watercourses. Article 10 of the Habitats Directive stresses the importance of natural networks of linked habitat corridors to allow the movement of species between suitable habitats, and promote the expansion of biodiversity. River corridors are particularly effective in this way and the network of river corridors may help wildlife adapt to climate change by providing a migration corridor. Suggested Policy POLICY – PROTECTION AND ENHANCEMENT OF RIVER AND STREAM CORRIDORS 1. Planning permission will only be granted for development proposals which would not have an adverse impact on the functions and setting of any watercourse and its associated corridor. 2. Development should seek to conserve and enhance the biodiversity, landscape and recreational value of the watercourse and its corridor through good design. 3. Opportunities for de-culverting of watercourses should be actively pursued. Planning permission will only be granted for proposals which do not involve the culverting of watercourses and which do not prejudice future opportunities for de-culverting. 4. Development proposals adjacent to or containing a watercourse should provide or retain a 16m buffer between the top of the river bank and the development, and include a long term landscape and ecological management plan for this buffer.
General – Consultation Issue Response Community Engagement - well publicised and The community engagement of the ‘Issues regular community engagement meetings with all and Options’ and ‘Draft Plan’ consultation has members of the public, together with relevant been carried to accord with the requirements parish / town and borough councillors at least of the Central & Eastern Berkshire Authorities’ once per year and that the content of such Statements of Community Involvement. A discussions are made public and kept on record record of the consultation and associated for the duration of the works events will be set out in the Consultation Summary. All meetings with relevant bodies and authorities will be recorded in the Duty to Cooperate Statement. These will be made available on the consultation webpage: www.hants.gov.uk/berksconsult. The consultation documentation is lengthy and full Some terminology is required to demonstrate of jargon (i.e. meaning of ‘Test of Soundness’ compliance with Planning Legislation. The etc), making the information difficult (at points) to ‘Tests of Soundness’ are a legal requirement fully comprehend. Deliberately made to be that need to be met. An explanation of these complicated to ensure as few people as possible Tests and other planning points was provided respond. in the ‘Frequently Asked Questions (FAQs)’ This consultation process is highly structured and and via a link on the on-line form. Further constraining, with the consequence that it limits options for explanation of the processes and one's ability to challenge or object to purely legal terminology will be explored for the ‘Proposed or process grounds Submission’ consultation. Consultation process means we will talk about it The comments received on the Draft Plan will then sites are put it in place regardless be used to inform the preparation of the Proposed Submission Plan.
Inadequate consultation process and the The community engagement of the ‘Issues publicising of the Waste and Mineral Plan in the and Options’ and ‘Draft Plan’ consultation has first stages. Even landowners and residents been carried to accord with the requirements directly adjacent to the proposed sites were not of the Central & Eastern Berkshire Authorities’ consulted, neither were local Parish Councils, Statements of Community Involvement. according to a recent Freedom of Information request. The current consultation has also been poorly advertised. Questionnaire is laborious and overly complicated The response form available via the and therefore excludes certain people e.g. elderly consultation webpage is the preferred method with arthritis, laymen of response and was designed to allow for a simple navigation of the Plan. Other methods for responses were also excepted including written responses and emails. The consultation channels responses based on A Glossary is provided in the Draft Plan and precise terms and criteria that it fails to define in each of the Evidence Base reports. Further the in the policy documents review of the glossaries will be undertaken in preparation of the Proposed Submission Plan and supporting reports. Many people living in the locality are older or do The community engagement of the ‘Issues not have internet access, making the consultation and Options’ and ‘Draft Plan’ consultation has process difficult. been carried to accord with the requirements This electronic survey must be one of the most of the Central & Eastern Berkshire Authorities’ inaccessible, non user friendly surveys we have Statements of Community Involvement. ever had to undertake. In fact many of our residents who wish to comment felt completely overwhelmed by the task. it seems to have been written for professional respondents only. accordingly we have advised our resident to send in their comments any way they feel they can but unfortunately without guidance many will not feel able to do so. Absence of representatives from Wokingham Representatives from Wokingham Borough Borough Council or Royal Borough of Windsor Council were present at the public exhibition and Maidenhead (RBWM) at public exhibition in at Knowl Hill Church in September. Officers Knowl Hill Church in September. from RBWM were unable to attend due to an exhibition also taking place within the Borough on the same date. Inadequate materials at public exhibitions e.g. Noted. Maps of the same scale were provided map of Knowl Hill was too small and was not at each public exhibition with a large-scale available elsewhere. It almost looked like a cover map showing the distribution of sites across up. the Plan area. The parties implementing the policy have shown The planning system has an expectation that that they have not complied with the legal other parts of the system, including the duties requirements and their duty of care. As such, of other agencies, will work as they should. there should be a change to the policy to ensure However, it may be that past performance that parties do comply with their legal obligations / could be considered when making decision on duty of care. future planning applications – this option will be looked at in the Proposed Submission Plan preparation.
It fails to meet the test of soundness as there National Planning Policy requires the Central should be a presumption away from development & Eastern Berkshire Authorities to prepare a in the Central and Eastern Berkshire. Plan which enables a steady and adequate supply of minerals and the sustainable management of waste. The plan makes it clear that development Noted. considerations will be assessed at the planning application stage. Early engagement with stakeholders would be mutually beneficial.
Confusion as to why Hampshire County Council is Hampshire Services, part of Hampshire driving this JMWP and not Wokingham Borough County Council, is working in collaboration Council. with Bracknell Forest Council, Reading Borough Council, the Royal Borough of Windsor & Maidenhead and Wokingham Borough Council to produce the Joint Minerals & Waste Plan. The collaboration allows for skills and knowledge sharing. Limited information on the Wokingham Borough Each of the Central & Eastern Berkshire Council and Royal Borough of Windsor and Authorities’ websites provided a link to the Maidenhead websites, which means limited main consultation page hosted by Hampshire information is available to the local communities Services: www.hants.gov.uk/berskconsult. who are most impacted by this Draft Plan. The webpage contained all the necessary information and was available to all. Which of the 56 preferred sites listed in the Draft The Minerals Proposal Study and Waste Plan were proactively found by Hampshire County Proposal Study set out the source of each Council? option in the Appendices. West Berkshire Council welcomes the efforts that Noted. The Duty to cooperate is an on-going have been put into meeting the Duty to Co- process and progress is being made on the operate to date. However, it should be noted that Statement of Common Ground. the Statement of Common Ground between West Berkshire and the Central and Eastern Berkshire Authorities drafted in September 2017 has not yet been finalised. West Berkshire would welcome further discussions to progress this to support the progression of the Central and Eastern Berkshire Joint Minerals and Waste Plan and the West Berkshire Minerals and Waste Local Plan in both plan-making areas We [Horton Parish Council] have asked for face Public events were held as part of the to face meetings with the Royal Borough of Regulation 18 consultation. Further meetings Windsor and Maidenhead officers for help in are subject to approval by the relevant ensuring our concerns are considered and actions planning authority. taken to help safeguard the Village. We would welcome the opportunity to discuss our concerns with you, as part of the on-going engagement between our two authorities under the duty to cooperate. We think it would be appropriate to do this before preparation of the Central and Eastern Berkshire MWLP moves on to the next stage. As part of this discussion, we would like to explore with you the possible need for and scope of a statement of common ground, as now required by the NPPF. The Parish of Horton is bounded on two sides by Invitations were distributed via the Local Plan Colnbrook Parish – part of Slough Borough consultation distribution lists of each of the Council – yet neither of these bodies have been Central & Eastern Berkshire Authorities and in included in the consultation as part of the Draft compliance with their Statements of Mineral Plan. The Draft Mineral Plan is not Community Involvement. inclusive of neighbouring Boroughs and resources. To be effective, there has to be proper Duty to Cooperate meetings are on-going with consultation and discussions with all the Slough Borough Council. neighbouring councils. The Royal Borough of Windsor and Maidenhead Compliance with existing permissions is the are aware that from previous planning responsibility of the relevant planning authority applications for mineral extraction in the Village of and outside the remit of the Joint Plan. Once Horton, there are still section 106 provisions adopted, new minerals and waste which have not been met by companies who form development will need to comply with the part of the Draft Mineral Plan proposals. This relevant policies. makes a mockery of the system and until and unless they can be compelled to meet their
commitments, any further such assurances cannot be taken seriously. Hampshire Services is simply the vehicle through Hampshire Services is part of Hampshire which Hampshire County Council takes on work County Council. for other public sector organisations, so the work is, in fact, being undertaken by staff from a Hampshire Services are working in neighbouring authority. At the consultation collaboration with the Central & Eastern meeting at Bohunt School in August, the lead Berkshire Authorities to help them prepare the technical officer was identified as Hampshire Joint Minerals & Waste Plan. Whilst County Council’s Head of Planning. This raises Hampshire Services is helping to prepare the two conflicts of interest: Plan, they are not a decision-making body and • Hampshire County Council is a neighbouring will not adopt the plan. authority and thus involved in minerals planning. Extraction sites in Hampshire, both current and Minerals and waste are strategic issues that future, will be involved in the local, regional and do not recognise administrative boundaries. national minerals market, alongside sites in The 2014 data suggests that Hampshire is a Central Berkshire. Given the considerable cross- key source of land-won sand and gravel. boundary supply evidence set out in the background documents (Hampshire was a National planning policy places a duty on local significant source of locally-used aggregates in planning authorities to cooperate with each both the 2009 and 2014 data), it is clear that other on strategic matters. It also states that extraction proposal in Central Berkshire will have effective and on-going joint working between a bearing on the future need for extraction in strategic policy-making authorities and Hampshire. relevant bodies is integral to the production of • As a neighbouring authority, Hampshire County a positively prepared and justified strategy. Council will be consulted on the emerging Plan in relation to impacts in their administrative area, Due to strategic nature of both minerals and and it is difficult to see how the HCC planning waste, (South east) regional level work is department can be on both sides of the process at being undertaken to mineral supply and waste the same time. management issues.
Taking into account wider soft sand supply and landfill provision issues, the relationship between Central & Eastern Berkshire and its neighbouring authorities will become increasing important. Therefore, the existing collaboration relationship between Central & Eastern Berkshire and Hampshire will strengthen the on-going cooperation required to address these issues rather than be considered a conflict of interest.
These sites need to be agreed by the The Plan is subject to extensive and ongoing communities that would be affected. This plan consultation with a variety of stakeholders and does not allow for that. interested parties.
It needs to balance the interests of communities that would be affected directly as well as the indirect impacts of poor mineral and waste management provision that would affect all the communities in the plan area.
Additionally, the Development Management (DM) policies seek to control the impacts of development and any proposed development will be considered in light of all the policies in the Plan. Strong objection to the statement in online The ‘Issues and Options’ consultation document that “the first stage in the plan considered the options for what issues should preparation was the Issues and Options be covered by the Joint Minerals & Waste Consultation conducted in Summer 2017.” Not Plan and the options for dealing with those one single local resident was ever consulted issues. The first public consultation on the
about the options, certainly not the option of using proposed allocations was at the Draft Plan Star Works to manage an additional 100,000 stage to which these comments relate. tonnes of waste per annum. This is an Comments received on the Draft Plan will be inexcusable lapse of duty of care to local used to inform the next plan-making stage – residents, who should be served and whose taxes Proposed Submission. The consultation the support your Authority. [relates to Star Works] Proposed Submission Plan will be in 2019. The complexity, specialist nature and length of the The on-line survey was prepared by a consultation document was frustrating. specialist on-line survey developer and was Attempting to fill in the online survey was designed to be as simple as possible and challenging - on several occasions, the document allow the user to select which part of the plan returned to the beginning and all completed they wish to comment upon. Feedback on the responses and work was lost, so it became usability of the system is welcomed and will be necessary to submit a response via email. It is taken into consideration for the Proposed unacceptable to make the process of commenting Submission consultation planned for 2019. - the alleged consultation process - so opaque and difficult as to ensure the general public - whom the plan most affects - find it virtually impossible to express their views.
Strategic Transport Assessment Issue Response Ensure good standards of amenity are retained Protection of amenity is outlined in draft Policy for local communities (both in close proximity to DM9 (Protecting Public Health, Safety and sites and along transportation routes), protection Amenity). Draft Policy DM11 (Sustainable and enhancement of the local environment and Transport Movements) also states that a impacts on the highway network. Transport Assessment/Statement will be required.
Existing reference will be reviewed to ensure it is in line with NPPF.
The impact assessment looks at the impact on the highway network – the scope of these will differ by each highway authority’s requirements. The TA/TS should discuss all related transport not just “transport of materials” e.g. staff too. The Transport Assessment consider the HGV The Strategic Transport Assessment seeks to haul routes; however, the draft plan does not address the potential transport impacts specify which routes will be used. associated with a site to determine the sites’ suitability for allocation. Once allocated, planning permission will be required and a detailed transport assessment or statement and, where relevant, routing would be required.
Specific HGV routes are identified in each of the site forms within the STA under “suggested routing” headings with the exception of Ham Island (CEB16) and Monkey Island Barge Wharf (CEB26) which intend to use waterways and/or existing routes. Routeing agreements would be expected to make up part of the planning application for each site. Any new sites that come forward or are predicted Noted. This point supports draft Policy DM11 to generate significant number of trips a detailed (Sustainable Transport Movements) and the Transport Assessment should be submitted with relevant Development Considerations set out any application. Any vehicle trips to/from the site in Appendix A.
should be encouraged to occur outside of the peak hours to minimise any impact on the SRN Sites must have good transport links that do not Draft Policy DM11 (Sustainable Transport involve roads which are already overloaded or are Movements) states that a Transport unsuitable to HGVs. Routing and transport Assessment/Statement and routeing operating hours should be used and be agreement will be required which will need to enforceable easily. outline the potential impacts on highway safety, congestion and demand management as well as any highway improvements where required.
HRA Issue Response Air Quality The plan is not likely to result in the Noted. construction of new roads, however increases in traffic, or changes to routes, especially of HGVs, Relevant guidance, publications, Technical could lead to impacts on the environment. Information Notes and advice will be taken Protected habitats can be vulnerable to the effects into consideration in the Habitats Regulation of a number of air pollutants such as nitrogen Assessment, Restoration Study and other oxides (NOx), ammonia (NH3) and sulphur relevant elements of the Plan as appropriate. dioxide (SO2). Impact can be caused when pollutants settle on to the ground (deposition) Additional section added on air pollution; causing nutrient enrichment of the soil relevant guidance documents referenced; and (eutrophication) or changes to the soil Ph conclusions of borough traffic assessments (acidification). These effects can decrease the included in site screening assessments. ability of a plant species to compete with other plants and can hinder the inherent capacity for self-repair and self-renewal under natural conditions. Nitrogen effectively acts as a fertiliser for plants which thrive on high nitrogen levels, which can then begin to dominate plant communities. This is likely to damage the interest features in protected sites which are notified for their plant communities (for example, the Thames Basin Heaths). Natural England’s publications: NECR200 – ‘Potential risk of impacts of nitrogen oxides from road traffic on designated nature conservation sites’ and the Atmospheric Nitrogen Theme Plan may help developers to ascertain what, how, where and when to target their efforts on sites of conservation importance and the areas surrounding them.
Theme plans can provide an overarching direction or outline approaches to achieve target conservation status of Natura 2000 sites in England, to complement work already underway on individual sites.
Air quality effects to European sites have been considered within the HRA Scoping Report. Natural England’s guidance on how to assess the impacts from air quality has been published here and may be useful. It should be noted that air quality effects can also impact SSSI’s, Local Wildlife Sites (LWS) and other areas of botanical interest. As indicated earlier, these can be considered at the plan stage. Our guidance above does not specifically cover nationally significant
sites such as Sites of Special Scientific Interest (SSSIs), which are covered by a different regulatory framework. However, the general principles for air quality assessment outlined here for European Sites are likely to be equally relevant for this and other designations. Best and most versatile agricultural land and soils Local planning authorities are responsible for ensuring that they have sufficient detailed agricultural land classification (ALC) information to apply the requirements of the NPPF. This is the case regardless of whether the proposed development is sufficiently large to consult Natural England. Further information is contained in Natural England’s Technical Information Note 049. Agricultural Land Classification information is available on the Magic website on the Data.Gov.uk website. If you consider the proposal has significant implications for further loss of ‘best and most versatile’ agricultural land, we would be pleased to discuss the matter further. Guidance on soil protection is available in the Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites, and we recommend its use in the design and construction of development, including any planning conditions. Should the development proceed, we advise that the developer uses an appropriately experienced soil specialist to advise on, and supervise soil handling, including identifying when soils are dry enough to be handled and how to make the best use of soils on site. Our other advice can be found at Annex A. Annex A Natural England offers the following additional advice: Protected Species Natural England has produced standing advice1 to help planning authorities understand the impact of particular developments on protected species.
You should consider the impacts of the proposed development on any local wildlife or geodiversity sites, in line with paragraph 174 of the NPPF and any relevant development plan policy. There may also be opportunities to enhance local sites and improve their connectivity. Specific information on local sites can be obtained from appropriate bodies such as the local records centre, wildlife trust, geoconservation groups or recording societies. Priority habitats and Species are of particular importance for nature conservation and included in the England Biodiversity List published under section 41 of the Natural Environment and Rural Communities Act 2006. Most priority habitats will be mapped either as Sites of Special Scientific Interest, on the Magic website or as Local Wildlife Sites. List of priority habitats and species can be found here2. Species data should be collected when impacts on priority habitats or species are considered likely. Consideration should also be given to the potential environmental value of brownfield sites, often found in urban areas and former industrial land,
further information including links to the open mosaic habitats inventory can be found here. You should consider any impacts on ancient woodland and veteran trees in line with paragraph 175 of the NPPF. Natural England maintains the Ancient Woodland Inventory which can help identify ancient woodland. Natural England and the Forestry Commission have produced standing advice for planning authorities in relation to ancient woodland and veteran trees. It should be taken into account by planning authorities when determining relevant planning applications. Natural England will only provide bespoke advice on ancient woodland/veteran trees where they form part of a SSSI or in exceptional circumstances. Environmental enhancement Development provides opportunities to secure a net gain for nature and local communities, as outlined in paragraphs 8, 32 and 170 of the NPPF. We advise you to follow the mitigation hierarchy as set out in paragraph 175 of the NPPF and firstly consider what existing environmental features on and around the site can be retained or enhanced or what new features could be incorporated into the development proposal. Where onsite measures are not possible, you may wish to consider off site measures, including sites for biodiversity offsetting. Opportunities for enhancement might include: Providing a new footpath through the new development to link into existing rights of way, Restoring a neglected hedgerow, Creating a new pond as an attractive feature on the site, Planting trees characteristic to the local area to make a positive contribution to the local landscape, Using native plants in landscaping schemes for better nectar and seed sources for bees and birds, Incorporating swift boxes or bat boxes into the design of new buildings, Designing lighting to encourage wildlife, Adding a green roof to new buildings. You could also consider how the proposed development can contribute to the wider environment and help implement elements of any Landscape, Green Infrastructure or Biodiversity Strategy in place in your area. For example: Links to existing greenspace and/or opportunities to enhance and improve access. Identifying opportunities for new greenspace and managing existing (and new) public spaces to be more wildlife friendly (e.g. by sowing wild flower strips) Planting additional street trees. Identifying any improvements to the existing public right of way network or using the opportunity of new development to extend the network to create missing links. Restoring neglected environmental features (e.g. coppicing a prominent hedge that is in poor condition or clearing away an eyesore). Access and Recreation Natural England encourages any proposal to incorporate measures to help improve people’s access to the natural environment. Measures such as reinstating existing footpaths
together with the creation of new footpaths and bridleways should be considered. Links to other green networks and, where appropriate, urban fringe areas should also be explored to help promote the creation of wider green infrastructure. Relevant aspects of local authority green infrastructure strategies should be delivered where appropriate. European Sites and Habitats Regulations Noted. Assessment Screening - There are a number of European sites within the plan area, and within 10k of the plan boundaries, which could be effected by the plan; Windsor Forest and Great Park SAC, Chiltern Beechwoods SAC, Thames Basin Heaths SPA , South West London Water Bodies SPA (and RAMSAR), Burnham Beeches SAC, Hartslock Wood SAC, Thursley, Ash, Pirbright and Chobham SAC/SPA. The applied methodology in the screening report is robust, and that likely significant effects, both alone and in- combination, to European sites arising from the plan have been considered. The scoping report makes reference to the Noted. possibility of allocated sites providing supporting The reference to “effective management” will (or functionally-linked) habitat for the South West be reviewed and amended/strengthened to London Water Bodies Special Protection Area. ensure that it is sufficiently precautionary. Special Protection Areas (SPAs) are classified for rare and vulnerable birds, and for regularly occurring migratory species. Annex 1 bird species associated with the SPA receive protection both within and outside of the SPA boundary. Sites outside of the SPA which support the Annex 1 bird species, often referred to as SPA supporting habitat or ‘functionally linked’ habitat, play an important role in maintaining the SPA bird population through the provision of additional roosting or feeding areas. Due to the importance of these off-site habitats in maintaining Annex 1 bird populations, the supporting habitat benefits from the same level of protection as the SPA itself. Therefore, any impact to, or loss of, SPA functionally linked habitat would need to be adequately mitigated against or compensated for. The specific restoration plans for proposals affecting the SPA should also be designed in order to serve the SPA species. If necessary, compensating for the loss of functional habitat would require that any compensatory habitat provision would have to be situated in close- proximity to the SPA or another SPA which supports the same species interest features to maintain ecological coherence of the network. The location of compensatory habitat would require careful planning due to the potential for bird-strike issues to arise. We would add that in accordance with the guidance on article 6 (4) any compensatory measures must be effective at the time the damage occurs on the site concerned. Paragraph 3.15 of the HRA Screening Report, relating to invasive species, correctly identifies the vulnerability of aquatic habitats to invasive non- native species (INNS). It goes on to say that
“effective management… should minimise the risk of spread”. INNS have the potential to cause LSE to European sites and so this aspect of the plan should be strengthened. As it is currently written, this paragraph suggests ‘effective management’ of an allocated site is assumed, which is not sufficiently precautionary
Archaeology Issue Response Paragraph 31 of the National Planning Policy The Historic Environment and Assets have Framework (2018) requires “The preparation and been taken into consideration in the review of all policies should be underpinned by preparation of the Plan. Advice, assessment relevant and up-to-date evidence”. Paragraph 1.2 and input has been provided on assessment of the Draft Plan refers to the evidence base as of the sites (as outlined in the Minerals set out in Figure 2. We note that the Figure does Proposal Study and Waste Proposal Study) not identify any evidence base for the historic and the drafting of draft Policy DM7. environment nor is there any reference in Appendix C or on the Joint Local Plan webpage to It is appreciated that this involvement is not any archaeological studies or historic impact explicit’ and this will be taken into assessments. consideration in preparation of the ‘Proposed At the very least the Berkshire Historic Submission’ Plan. Environment Record and East Berkshire Historic Landscape Character Assessment should have Subsequently, a Heritage Statement was been used in preparing the Plan and to be prepared to set out the source of the data and identified accordingly. the site assessments.
The tributaries of the Middle Thames are very Essential issues. Palaeolithic archaeology is important for Palaeolithic archaeology. Where an important component of the archaeology of gravel extraction targets sand and gravels below the Thames gravels and a more explicit review the modern floodplain (for example of the River of this is needed. This period is largely Loddon at Arborfield) then there could also be represented on the HER as artefact recovery potential for important waterlogged archaeology, and provision for such can be made when especially relating to the Late Upper Palaeolithic appropriate within the determination of an and Mesolithic, as known from the nationally application (Controlled recovery of artefacts important archaeology in the nearby Kennet and would not be a constraint to allocation). Insitu Colne Valleys. Given that the true potential for sites might rarely emerge as a constraint but Palaeolithic archaeology is unlikely to be they are not predictable. They require represented on the Historic Environment Record, considerable ‘in the field’ research to find owing to depth of burial and lack of previous them. Beyond the resources of the Plan investigation, this aspect of archaeology is likely preparation process and beyond anything to require specific assessment by a specialist more than general consideration - this needs familiar with the period to provide a robust to be more explicit. evidence base It is not ‘reasonably possible’ to produce a Plan with allocations that has identified, in more than very general terms, the nature of the Palaeolithic potential. Such potential can be expressed according to ‘deposit models’ as currently understood before field work, but such commentary may need to be commissioned from a specialist if this concern is to be addressed beyond general statements. The tributaries of the Middle Thames are well- The construction of site by site geo known for the survival of well-preserved Late archaeological models is a specialist area of Upper Palaeolithic and Mesolithic archaeology work which might be argued to be beyond the found in association with waterlogged remit of the Plan preparation process. The environmental evidence, typically at the interface presence of waterlogging can be speculated of the sands and gravels and the overlying by reference to adjacent extraction but
alluvium on the floodplain. The evidence in accurate deposit modelling would require in support of any allocation site that lies on the field survey beyond the resources of the Plan floodplain would benefit from the construction of a preparation process. geoarchaeological deposit model, to identify the nature of the deposits that would be impacted and The presence of water-logged conditions does their archaeological significance. not rule out allocation, it will inform potential for local constraint and future archaeological burden. Such constraint and burden can be generally expressed where a site has such potential and the commentary can be more explicit on this.
More reference is needed to where waterlogging is a possibility. There is no reference in the Vision to the historic Noted. As the Vision refers to the ‘natural’ environment or heritage assets. There is a environment, this will be broadened to also reference to the natural environment, but the refer to the ‘historic environment’ to align with National Planning Policy Framework makes it draft Policy DM7. clear that the historic environment is a separate entity from the natural environment – in addition to references in the Framework to the natural, built and historic environment, it specifically defines the historic environment as “All aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, and landscaped and planted or managed flora”. There is no specific reference to the historic Noted. As the Strategic objectives and environment or heritage assets in the Strategic principles make reference to the ‘natural’ and objectives. Heritage is included in Principle ix of ‘built’ environment, this will be broadened to paragraph 3.14, which is welcomed, but not in also refer to the ‘historic environment’ to align Principle iv (the terms “built environment” and with draft Policy DM7. “historic environment” are not interchangeable). Paragraphs 5.75, 6.75, 6.76, 6.77/6.78: Consider The supporting text forms part of the Plan and that the considerations in paragraphs 5.75, 6.75, therefore, has the same weight as the policy 6.76, 6.77/6.78 should actually be set out in but provides more detail on how the policy policies, not the supporting text, which does not should be implemented. How the policy carry the same weight as the policies. should be implemented is clearly set out for developers and decision-makers. It is not considered necessary to include the implementation detail into the Policy. Paragraph 7.50: whilst it is true that minerals and Noted – Para. 7.50 will be revised to waste development can lead to archaeological acknowledge that the Plan ‘has an important investigations, mineral extraction is by its very role in conserving the most important heritage nature, a destructive process and such assets ….’ but that ‘where necessary investigations are usually required because of the extraction does result in damage or imminent destruction of archaeological remains. destruction it also plays a positive role in We feel the Plan should acknowledge this. securing archaeological recording to ensure that evidence is not lost to future generations’. This also recognises the point made below that the ‘option’ to record is not the ‘motive’ to record. We are not sure if “the record of historically or Noted – wording will be reviewed. As it is a architecturally significant structures” is meant to commitment to protect assets recorded in this refer to the National Heritage List for England (the way it should not include sites merely because only official, up-to-date, register of all nationally they are on the Berkshire HER. The HER protected historic buildings and sites in England) records the ‘great and the small’ whilst the or the Berkshire Historic Environment Record, National Heritage list records only the ‘great’ which includes non-designated heritage assets, or both. We consider that this should be clarified.
Whatever is actually meant by this reference, it is It is correct to say that the ability to record not itself a heritage asset, and therefore what is to be lost is not material in the decision “protecting heritage assets” does not include this as to whether extraction take place. ‘The most record. However, we would welcome a important’ should be conserved by the policy commitment to maintaining the Historic of the plan (via a balanced judgement) and Environment Record (although it should be taking a record prior to destruction is only remembered that paragraph 199 of the National considered once a judgement has been made Planning Policy Framework (2018) cautions “the that the need for the extraction outweighs the ability to record an asset will not be a factor in preparation of the heritage. None the less it is determining whether or not a proposed important to recognise the important role of development will be permitted”. We welcome the the plan policy to ensure that where last sentence of paragraph 7.50 destruction is allowed archaeological recording of the assts to be harmed is secured. Paragraphs 7.51 - 7.52: support these The Proposed Submission Plan will refer to paragraphs; although the revised National the recently revised NPPF which was Planning Policy Framework does not refer to core published shortly before the consultation on principles in the same way as the original the Draft Plan commenced and will be Framework, the principle that “heritage assets amended. should be conserved in a manner appropriate to their significance” is restated. Paragraph 7.56: we do not consider it accurate to Yes, the merits of a site will include say that “Minerals or waste developments will be compliance with policy, relevant legislation considered on their merits” – surely they will be and any relevant material considerations. considered in the context of relevant legislation, Policy DM7 and any relevant material There is a need for a balanced judgement considerations? between the merits/need for the extraction and the significance of the heritage assets (a balanced judgement). Paragraph 7.57: welcome the principle set out in In all cases it is a balanced judgement, the the paragraph that merits/need balanced against the significance. “Major historic features, such as Scheduled Ancient Monuments located or discovered on Consideration will be given to whether they sites proposed for minerals and waste are made reference to ‘or discovered’. If they development must be preserved as part of the exist, the impact of their presence on either development”, this is not consistent with the third allocation or constraint to extraction extent paragraph of Policy DM7 which allows for harm to within an allocation is clear. Reference to heritage assets where the need for and benefits of ‘discovered’ suggest discovered when the development decisively outweigh these preliminary archaeological survey is in hand or interests and impacts will be mitigated. We are during extraction. Where archaeological not clear why the paragraph states “as survey is prior to determination it should be appropriate” in reference to enhancement – this possible to ‘reasonably’ secure the protection should be “where possible”. of an archaeological site within the allocation extraction (see discussion about Palaeolithic). If an unexpected ‘discovery’ during extraction it may not be possible to secure preservation– but unexpected discovery will need its own provision. This is particularly important in relation to the concerns raised about Palaeolithic remains. Monitoring indicators; we suggest that these Noted - Further consideration will be given to should also include “Number of planning the Monitoring Indicators. permissions contrary to Council’s conservation and archaeological advisers’ advice”. Paragraph 7.62: we support this paragraph, Noted and ‘and character’ will be added to the although we suggest that it says “quality and first bullet point. character”. The wording also needs minor revision to fully make sense Paragraph 7.64: we welcome the seventh bullet Noted. Seventh bullet to be amended: point but we consider that the paragraph should ‘Presence of important archaeological have an additional bullet point: “historic landscape features, historic assets and historic character and other heritage assets”. landscape character’
Glossary and Acronyms: We are not clear to Noted. Reference to ‘Sites’ to be removed. what “Sites” in “Listed Buildings and Sites” refers. Replace ‘and sites’ with ‘and structures’ in definition. Appendix A – Proposed Sites: we welcome, in The supporting text forms part of the Plan and principle, the site-specific development therefore, has the same weight as the policy considerations relating to the historic environment but provides more detail on how the policy for each site, but as these considerations are not should be implemented. How the policy set out in any policy, nor is there any requirement should be implemented is clearly set out for in any policy for these development developers and decision-makers. It is not considerations to be satisfied, they would appear considered necessary to include the not to actually carry any weight for the implementation detail into the Policy. assessment of planning applications. We consider that Policies M4 and W4 should each include a The implementation of draft Policy W4 refers requirement for development proposals for any of to the need to specifically address the the allocated sites to take the site-specific Development Considerations set out in considerations into account. Appendix A. However, whilst the supporting Monkey Island Lane, Bray: whilst we welcome text of draft Policy M4 refers to the the recognition of potential archaeological issues Development Considerations in Appendix A, in relation to this site, we do not consider that this is not set out in the Implementation simply identifying them as a material section. Policy M7 does not refer to the consideration to be dealt with at the planning Development Considerations in Appendix A. application stage, particularly when there is no As such, to ensure consistency, both Policy requirement within the Plan to adhere to these M4 and M7 will be amended to refer to the site-specific considerations, will provide sufficient Development Considerations in Appendix A. protection for any archaeological remains. We consider that this requirement should be set out in a specific policy for Monkey Island.
Strategic Flood Risk Assessment Issue Response Flood Risk Management Sequential test and A Sequential test will be carried out to support flood zone compatibility with development. From the ‘Proposed Submission’ Plan. the submitted information a sequential test has not been carried out for the proposed site allocations. “Flood risk management Noted. Consideration will be given to the Minerals and waste development in areas at risk provision of separate policies for flood risk and of flooding should: protection of water quality. a) Apply the sequential test, exception test and sequential approach within the development site directing the most vulnerable development to the areas at lowest risk from flooding b) Not result in an increased flood risk elsewhere and seek to reduce flood risk overall; c) ensure development is safe from flooding for its lifetime including an assessment of climate change impacts d) Incorporate flood protection, flood resilience and resistance measures where appropriate to the character and biodiversity of the area and the specific requirements of the site; e) Include site drainage systems designed to take account of events which exceed the normal design standard; f) Not increase net surface water run-off; and g) If appropriate, incorporate Sustainable Drainage Systems to manage surface water drainage, with whole-life management and maintenance arrangements.”
The following wording could be used for a water quality policy “Water quality Planning permission will be granted for minerals and waste development where proposals do not: a) Result in the deterioration of the physical state, water quality or ecological status of any water resource and waterbody including, rivers, streams, lakes, ponds, groundwater source protection zones and ground water aquifers. b) Include a hydrogeological risk assessment (HRA) where proposals are in a groundwater source protection zone. If the HRA identifies unacceptable risks then the developer must provide appropriate mitigation.” We agree that a Hydrogeological Risk Noted. The SFRA Site Specific Analysis for Assessment will be required for risky sites. For relevant sites will also be amended to refer to example:- Water Oakley within Source Protection ‘Hydrological Risk Assessments’ as opposed Zone (SPZ3) for Bray public water supply where to ‘Hydrological Assessments’. water is abstracted from Shepperton Gravel Principal Aquifer. Strategic Flood Risk Assessment - The SFRA Noted. A section that defines the EA’s Flood should include a section which defines Flood Zones will be included as part of the sequential Zones 1, 2, and 3, and in particular discuss and testing of sites for the submission plan. define Flood Zones 3a and 3b. This is important as in the Planning Practice Guidance, developments which ‘less vulnerable’, i.e. most waste sites, should not be permitted in Flood Zone 3b. Flood Zone 3b (the functional floodplain) is usually defined as land with a 5% or greater annual exceedance probability (AEP). While the individual borough councils have defined this in their own SFRAs, it is important that the minerals & waste plan has a consistent definition. Sequential test and sequential approach - In the Noted. SFRA it is important to be clear on the difference between the sequential test and the sequential approach. The sequential test looks at steering development to sites at a lower risk of flooding. Some of the site allocations within this local plan are within Flood Zones 2 or 3. There need to be evidence that other sites at a lower risk of flooding have been considered and the reasons for discounting these sites will need to be clear. The sequential approach is applied after the sequential test and is carried out at the site level when looking at the flood risk across the site and where to allocate development within that site The SFRA needs to consider the impact of Noted. Section on climate change will be climate change, and should include the new added and climate change impacts considered climate change allowances as part of the SFRA as part of the assessment. assessment in order to be compliant with the NPPF. Paragraph 2.4 Table with Rivers - The Harveyford Para. 2.4 – Table will be amended. Ditch is repeated twice in this table. Paragraph 2.80 - In this paragraph should Para. 2.80 – typo will be corrected. ‘Winnerash’ be ‘Winnersh’? Paragraph 3.2 - It needs to be acknowledged in Para. 3.2 – to be amended. this section that while sand and gravel extractions are considered ‘water compatible’, ancillary
activities such as processing, stockpiling, amenity bunds and offices are not considered ‘water compatible’ and don’t have to be placed in flood plains in many cases. Paragraph 3.5 says: “All sites within flood risk Para. 3.5 – to be modified. zones will need a Flood Risk Assessment to be undertaken”. This should be modified to be consistent with NPPF. “An FRA is needed for developments: - in Flood Zone 2 or 3 - more than 1 hectare in Flood Zone 1 - less than 1 ha in Flood Zone 1 if it is a development type that results in a more vulnerable use, where they could be affected by sources of flooding other than rivers and the sea - in an area within Flood Zone 1 which falls in a critical drainage area as notified by the Environment Agency SFRA - The sequential test will also apply to any Noted. The sequential test will be applied to all proposed safeguarded land, borrow pits, oil, gas, sites identified in the submission plan. coal, chalk and clay sites, waste and minerals infrastructure, proposed landfill sites, transport infrastructure, restoration uses, hazardous waste and non-hazardous waste. If there is no sequential test then this could also impact on the following polices for development although these policies are more general and do not refer to specific sites they do refer to potential Noted. development. These polices are M6, M8, W2, W3, W5, DM8, DM11 and DM13.
Please be aware that some of these developments are more or less vulnerable and would not be compatible in Flood Zone 3b (Functional Floodplain) and we may have soundness points to make on site allocations that are not appropriate in certain Flood Zones as set out in Table 3 ‘Flood risk vulnerability and flood zone ‘compatibility.’ Please see table 1 ‘Flood Risk’ in the Planning Practice Guidance for the Flood Zone definitions and table 2 ‘Flood risk vulnerability classification’ for the different vulnerabilities for development types and table 3 for the ‘Flood risk vulnerability and flood zone ‘compatibility.’ This table sets out which vulnerability is appropriate in certain flood zones and which is not. You need to consider vulnerability of a development when allocating sites as some of the ancillary infrastructure or uses may be at a higher vulnerability than the sand and gravel extraction. This means that after the sequential test has been applied and passed and then in some cases the exception test, if some of the sites are in Flood Zones 2 and 3 then the sequential approach which looks at locations of least risk of flooding within the site will need to be applied. The sequential test has also not been included as Noted. The requirement for a sequential test a policy requirement in Appendix A of the local for relevant developments will be added to the plan which sets out the descriptions of the site Development Considerations in Appendix A. allocations. The sequential test needs to be included in a flood risk policy for this local plan. Typo noted regarding Para. 5.114. This so it its clear for developers that they need to apply this test if there are any developments
within Flood Zone 2 and 3. There are some The reference to the impact of tides on the exceptions to this. Please see 164 of the NPPF. navigation of the River Thames was taken Central & Eastern Berkshire Minerals & Waste from the report ‘The River Thames and consultation paper Paragraph 5.114 - This Connecting Waterways’. The reference will be paragraph number has no text within it. revisited to ensure that it is relevant. Paragraph 5.117 - While it is true that the River Thames upstream of Teddington Lock is less The reference to landfill and hazardous waste influenced by the tides, we are unsure as to what management facilities in Flood Zones 3a and this has to do with navigation of freight. This 3b is noted. needs clarification.
Please be aware that in the Planning Practice Guidance it says that Landfill and sites used for waste management facilities for hazardous waste are More Vulnerable and that should not be permitted in Flood Zone 3b but can be located in Flood Zone 3a following the application of the sequential test and exception test. Please also be aware that there are other development types that should not be permitted in Flood Zones 3a & 3b.
Sustainability Appraisal Issue Response Paragraph 3.51 This says: “CEB24 and 26 have Para. 3.51 – Text to be amended. scored negatively against flood risk” Do you mean CEB21 and 26? Sustainability appraisal - Interim SA/SEA Noted – the relevant references will be Report Table 3.7 For Planners Farm: under amended, references to site checked and constraints this should also mention high surface glossary updated. water flood risk around the site entrance. Bridge Farm: “the site is within a flood zone and susceptible to surface water flooding from the River Loddon” we think this should be changed to “the site is at risk of fluvial flooding from the River Loddon and as such parts of the site fall in Flood Zones 2 and 3. Ham Island: “Flood Zone 2&3 and susceptible to surface water flooding from the Thames” we think this should be changed to “susceptible to fluvial flooding from the Thames, site is in Flood Zones 2 & 3 and is at risk of surface water flooding”. Poyle Quarry: Flood Zone 2 and small areas of Flood Zone 3 need to be included in the considerations. Berkyn Manor, Horton: Under ‘considerations’ it needs to include that a small area of Flood Zone 3 is within the site. Paragraph 3.51 This says: “CEB24 and 26 have scored negatively against flood risk” Do you mean CEB21 and 26? Glossary Sequential test and exception test Please note that it is the planning authority that carries out the sequential test and exception test and not the Environment Agency. This needs amending in the glossary text.
Restoration Study Issue Response Restoration Study Paragraph 4.16 This says: Noted. “reduce flood risk on local communities” This Restoration Study para. 4.16 - text will be should say, “reduce flood risk to local amended as appropriate.
communities” You also need to add the following text to this paragraph, “Note that permanent open Para 4.16 and para 4.18 – Amended. water features will not normally provide much additional floodplain storage in times of flooding, since they will already be full of water. Generally, for additional floodplain storage to be created, land outside of flood zones needs to be lowered, but should remain hydraulically connected to the floodplain. Restoration Study Noted – Relevant wording will be Paragraph 7.15 This section needs to mention amended/strengthened, as appropriate. Blue Infrastructure Paragraph 7.62 Please remove the words These para numbers are not present in the “usually” and “wherever possible” within this Restoration study. However, amendments to paragraph. These words add great weakness to this effect have been made in the Executive the text and it just reads as a loophole Summary and para 2.1
Waste Proposal Study Issue Response Page 139 of the Waste Proposals Study – under The information contained within Table 2 (page category two, there is no precise information on 11) is the definition of Waste Category 2 as the type of waste and so making comments is not applied to draft site allocations and in the wider possible. context of the draft plan.
Existing Industrial Estates were also considered for their suitability for waste activities as part of the Industrial Land Review. The Outcome of the Assessment for this site included Category 2: Activities requiring open sites or ancillary open areas (not involving biological treatment). The definitions of the Waste Categories are included in Tables 1 – 7 (pages 9 – 22). Table 2: Category 2 – Activities requiring a mix of enclosed buildings / plant and open ancillary areas (possibly involving biological treatment) contains the relevant information.
Having reviewed page 139, it is noted that there is a discrepancy between the Waste Category 2 title description listed on page 139 and the title of Table 2 (page 11). This is an editing error contained only in the Industrial land Review section of the Waste Proposal Study and will be amended to reflect the same definition of Waste Category 2 which is applied across the draft waste allocation sites in the Waste Proposal Study and the draft Plan.
Minerals Proposal Study Issue Response Access to the site – p49 Minerals Proposal Study The assessment of the access arrangements “Transport (including access) Potential access for Bridge Farm were taken from the into the site: The access to the site is located on submitted planning application. These will be the Strategic Road Network via the A327.” reviewed in light of the comments received. Incorrect: The A327 runs from the site to the M3 (SRN) but 80% of the traffic would be routed via The A327 is PRN not SRN in line with the the A327 West Bound and on to the B3270. methodology. The Minerals Proposal Study
Background: The current A327 is a busy road and will be amended to say “the Site would the main entrance will be on a single carriageway access onto the A327; HGVs would access section that is approached by National Speed the SRN via B3270 at J11 of the M4.” The Limits and 40 mph respectively. The proposed STA itself does not refer to the A327 as the 250+ HGV movements a day will pose increased SRN. hazards for both right hand turns in and out of the site and left hand turns exiting the site. The site is Detailed assessment would be undertaken to approached via a blind bend from the Arborfield support an application and would be set out in side and slow turning lorries pose an increased a Transport Assessment or Transport collision risk. Statement.
Bridge Farm was subsequently refused permission and withdrawn as a proposed allocation. Transport Assessment Summary – p50 Minerals The assessment of the access arrangements Proposal Study Change in traffic volumes The for Bridge Farm were taken from the change in HGV traffic on the SRN would be less submitted planning application. than 1%. The magnitude of change from the existing conditions would be negligible and The Transport Statement submitted with the therefore the significance of impact of the new current valid planning application for this site proposals would be neutral. Incorrect: No (section 4.9.2) does consider most of these allowance has been given to the newly opened sites (although not the Science Park) based Reading University Science Park or substantial on those sites the developer was asked to housing developments completed, underway and consider at the time of submitting their approved for Shinfield and Arborfield. It should planning application. It is the case that the 1% also be noted that there are inadequate impact on the SRN (assessed by as part of pedestrian and cyclist facilities from the site the STA) does not include these new entrance all the way West and on the Eastern developments as no strategic traffic model, or Shinfield Relief Road. outputs were made available at that time. Since then, the four authorities have progressed with Local Plans and relevant models. Where data is available, Section 4.27 onwards of the TA describes cumulative impact of the sites against committed developments and Local Plan growth. The pedestrian and cycle facilities should be reviewed as part of required Transport Assessment/Statement.
Bridge Farm was subsequently refused permission and withdrawn as a proposed allocation. Summary – Justification for Allocation – p51 The draft allocations were all subject to Minerals Proposal Study The site has been technical assessments by Hampshire Services proposed for allocation in the Joint Minerals & technical specialists including both a Waste Plan as it was previously identified as a landscape assessment and a desktop candidate Minerals Preferred Area in the Joint ecological assessment. It is acknowledged Minerals and Waste Development Framework - that there are ecological and landscape Detailed Minerals and Waste Development constraints in terms of this site and that the Control Policies and Preferred Areas site is subject to a live planning application. It Development Plan Document Reg. 25 (2008): is also noted that this planning application is Proposed Minerals Preferred Area for extraction yet to be determined and so it is agreed that of sharp sand and gravel W M02; a planning the principle and detail of whether the impacts application has already been submitted to be of the proposal can be adequately mitigated in determined by Wokingham Borough Council; terms of landscape and ecology have not yet ecological and landscape constraints are been determined and / or approved in relation acknowledged but it is considered that they can to the planning application. However, in be mitigated; good connectivity to the strategic considering whether the site is appropriate in road network; and a phased approach to planning terms for a strategic allocation the extraction with restoration opportunities. Who has level of technical assessment conducted for considered that they can be mitigated? This is a the plan making process is considered to be statement that portrays fact but lacks any appropriate for a strategic plan.
evidence. If we were to consider planning application 170433 the following issues are Action: Remove “but it is considered that they unresolved by the applicants, and have been can be mitigated” from text, until planning since December 2017. application has been determined.
Bridge Farm was subsequently refused permission and withdrawn as a proposed allocation.
Berkyn Manor Farm
General
Issue Response Support Policy W1 Sustainable Waste development strategy Noted as it conforms with the NPPW and the Waste Management Plan for England. Support the allocation of Berkyn Manor Farm Horton as the Noted site is well located, able to service a wider area, divert waste form landfill and allow recovery of compost material and energy. Support Policy W5 Reworking landfills as it is a beneficial use Noted of land and of recovered material. The proposal here is for a Green Waste and/or an Energy The draft Plan and its evidence base Recovery site. Colnbrook already has a major incinerator on have considered the current waste the northern side of the Colnbrook bypass, and 3 or 4 other produced and what waste is expected small-scale energy recovery plants. We would object to this to be produced in the future, as well as type of new development unless there was a specific local what capacity is needed in order to need for such a development so close to the residential areas manage that quantity of waste. The of the Horton and Colnbrook villages. conclusion was that more sites are needed to address the capacity gap.
Amenity issues would be addressed by Policy DM9 (Protecting Health, Safety and Amenity). Should an application be submitted for the site, the proposal would need to comply with this policy and address any potential issues through mitigation measures. INFILL OF ALL SITES [Horton Brook, Poyle Quarry & Ext and There are no current proposals for Berkyn Manor] - The Horton Brook Quarry is obliged to infill non-hazardous landfill. with inert waste only and this should be a condition of each of the other sites. RESTORATION OF SITES These sites [Horton Brook, Poyle Noted. However, Berkyn Manor is not Quarry & Ext and Berkyn Manor] are, or have been, largely proposed as an extraction site but for agriculture in nature and should be returned as near as waste management. possible to their pre-development condition. Any planting made in order to preserve some resemblance to a rural scene Site restoration is covered by policy should be retained where possible in order to retain and DM8: Restoration of Minerals and protect the new ecology systems developed during extraction Waste Developments. Restoration / infill operations. plans will have been agreed for permitted applications and will be required for new planning proposals. Restoration is a balance of pre- extraction site character and opportunities for enhancement. The Berkyn Manor site should not be used for green waste or Noted. energy recovery.
Transport
Issue Response Road access to all of the above sites [Horton brook, Poyle The associated site forms for Poyle Quarry & Ext and Berkyn Manor] must be via a dedicated Quarry, Poyle Quarry Extension and private road across the landowner’s property onto Poyle Road Berkyn Manor consider a number of then directly to J15 of the M25. alternative accesses therefore do not solely rely on the delivery of the new
road, although this access has now been accepted (by Slough Borough Council as the access is within its boundary) via an approved application to WMBC for Poyle Quarry (17/03426/FULL). It should be noted that Horton Brook Quarry is under separate ownership.
Planning approval for future use of these sites would be require Transport Assessments or Statements in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required.
Paragraph 4.4 of the Strategic Transport Assessment has been strengthened to this effect. Currently Foundry Lane, off the Stanwell Road, is an unmade The Strategic Transport Assessment single track road leading to Tanners’ Waste recycling site. No states that Berkyn Manor Farm intends mention of this existing site is made in the Draft Mineral Plan. that related traffic use an existing There are many HGV vehicles which use this track every day, access onto Stanwell Road through an passing through the Village from all entrance roads to access industrial estate to the south of the it. It is imperative that no further vehicle movements are site, this is not the unmade single track allowed to use this road. In fact, it would be a far better road – it is a route through an arrangement for the protection of local residents and sites if industrial estate south of the site with the access to this site was made through the main proposed its own private access road off entrance in Poyle Road. In parallel with the Draft Mineral Stanwell Road. Plan, the expansion of Heathrow is also being discussed. It is known that this will involve heavy movement of building Appendix 1 of the Strategic Transport materials to enable the runway construction, M25 re-routing Assessment has been updated to and other planned works. Horton Village is already used as a clarify that the intended access is the ‘rat run’ for vehicle trying to avoid congestion on the M25. private access onto Stanwell Road and not the unmade road. We strongly request that RBWM insist on no HGV movements through the Village. This must encompass forcing It is unclear which village is being a new access for the proposed Berkyn Manor waste infill referred to. The suggested route site. We also note that although there are railway lines in provided in support of the allocated close proximity to the proposed sites (e.g. the track in the site is based on developer proposals. middle of the M25 / M4 interchange lately used for T5 In any event, a routing strategy will construction) there has been no suggestion of using the need to be agreed with the local existing resources to alleviate the HGV traffic in the Horton Highway Authority as part of area. One suggestion is that by adding a branch line it could consultation of any planning fork towards Colnbrook on the north side of the A4, and application coming forward. maybe reduce the heavy lorries moving gravel on the local Consideration can be given to routing roads. via Poyle Quarry and Poyle Quarry Extension, however this will depend on phasing of proposed extraction operations.
The opportunity to use rail is noted, however it would require significant additional rail infrastructure, the viability of which we cannot comment upon at present. This may be reviewed at the time of the relevant planning application submission.
Landscape
Issue Response It will industrialise an area that needs to be enhanced as part The Strategic Landscape and Visual of the wider green resource. Greater weight should be given Assessment suggests the impact is to the need to protect the fragile nature of this section of the likely to be neutral due to the poor Regional Park and Green Belt – for it to realise its condition of the area. Mitigation enhancement potential, as Para 140 of the NPPF calls for. measures are suggested which if taken on board as part of any future development, could improve the overall appearance of the landscape.
Flooding
Issue Response Berkyn Manor Farm Our historic flood map indicates part of Noted – the SFRA will be reviewed the site affected in January 2003. Along with the SFRA including the ‘Flooding history’ RAG referring to 2014 flooding this would be 2 flood events in last status. 20 years so ‘flooding history’ rating should be red. This site allocation is proposed for waste management, which could be The Flooding History for the site has classified as less or more vulnerable development in subsequently been changed to ‘red’. accordance with Table 2 ‘Flood risk vulnerability classification’ in the Planning Practice Guidance. There are areas of Flood Zone 3 within the site. Please note that only development classed as ‘water compatible’ or essential infrastructure (with exception test) will be permitted in Flood Zone 3b.
Archaeology
Issue Response According to our records there are no designated assets on Noted. this site. The Grade II listed dairy at Berkin Manor at North East corner of House is located to the south of the site. We do An amendment to the proposal not consider it likely that potential waste management boundary has been made to ensure development would have an unacceptable impact on the the setting of the listed dairy is not significance of this designated heritage asset impacted, following a site visit. The historic ‘Berkyn Manor’ house, already under threat from Noted. years of neglect, must be fully protected from the effects such as subsidence, pollutants, airborne contaminates etc. The Development Consideration in Appendix A states the setting of the Grade II buildings needs to be taken into consideration. There is potential for important waterlogged archaeology, Berkyn Manor is not proposed as an especially relating to the Late Upper Palaeolithic and extraction site but for waste Mesolithic (the draft SEA notes that the area has high management. archaeological potential). Evidence might not exist for such archaeology on the Historic Environment Record, owing to its The heritage value of the site is depth and the lack of past investigation. Accordingly, the considered in the Heritage Statement. evidence in support of this allocation site would benefit from the construction of a geoarchaeological deposit model, to identify the nature of the deposits that would be impacted and their archaeological significance.
Bridge Farm
This site was subject to a planning application which was subsequently refused and withdrawn. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out.
General Issue Response Support the allocation of this site. Noted. Cumulative infrastructure impacts of: The Joint Minerals & Waste Plan is being • Ongoing new housing development in prepared alongside the development of each of Shinfield and Arborfield, particularly Shinfield the Central & Eastern Berkshire Authority Local LDP Plans. • Subsequent local population growth • Through commuter growth from other outlying It is recognised that further consideration needs housing developments from further afield around to be given to the cumulative impact of the Reading proposed allocation alongside other • Existing plans and major developments (e.g. developments in the area and this will be set out new road systems, University Science Park, in the Sustainability Appraisal which will Shinfield Eastern Relief Road) accompany the Proposed Submission Plan.
• Other potential developments - Arborfield This site was subject to a planning application Relief Road, the University proposals that Hall which was subsequently refused and withdrawn. and Cedar farm sites be considered for Therefore, the site has been ruled out as an development) allocation in the Joint Plan and no further This is going to fall upon a road network that is assessments have been carried out. largely unchanged from when this area was almost wholly rural Cumulative traffic impacts of ongoing new housing development (Including testing traffic flows), existing plans and major developments such as new road systems, in Shinfield and Arborfield, particularly Shinfield LDP. Conflict between Minerals and Waste and economic development and other area plans, particularly neighbourhood ones. E.g. The location is completely surrounded on all sides by 3 areas of Wokingham’s "Strategic Development Locations" which seek to ensure that residential development is in an area having appropriate services, facilities and public transportation opportunities for substantial development. It is also an area already under threat from overdevelopment of housing stock, and the mere thought that a cement factory and gravel extraction site should be placed right in the heart of that strategic location is completely flawed, and in total contradiction with Wokingham's own development and planning policies Cumulative pollution impacts of ongoing new housing development, existing plans and major developments in Shinfield and Arborfield, particularly Shinfield LDP. There must be many other sites around the UK that The Managed Aggregate Supply system requires are not located near to substantial centres of mineral planning authorities to make an residential population, and it is these site which appropriate contribution to national as well as should be exploited in preference to an area such local supply. as Bridge farm. If there are not such sites anywhere in the UK, then the next option should be to import It is also important to recognise that there are no minerals from existing suppliers located around the aggregate rail depots (or wharves) in Central & world where these resources are already being Eastern Berkshire and therefore, all imported mined. Where taking this alternative approach to material would have to be transported by road. sourcing minerals were to lead to an increase in
minerals costs then these should be factored into the price of new housing, rather than accepting the impact of reducing the value of existing housing, Indeed I would be very surprised if taking a macro view to compare the increased cost of sourcing minerals from other sources was not significantly lower than the loss in value to the land and property impacted by this proposed development, not to mention when one includes the environmental and quality of life impact into the equation. The proposal does not restore the site to its former Noted - The Strategic Landscape & Visual condition. It modifies it to become a private Assessment concludes that the site will have a commercial inland fishery and deep quarry water Large Adverse impact on the landscape and park for Diving enterprise. recommends that the site is restored to agriculture rather than water bodies. Pollution impacts on growing infant population. The proposed allocation of the site in the Joint Farley Estates pitch themselves as custodians of Plan takes into account the draft Development the countryside and claim in their literature that Management (DM) policies which would control “looking after the natural environment is at the heart any impacts associated with the development of everything we do ..” A gravel quarry and ready- through mitigation measures or if the issues mix cement works hardly seems to fit this ethos? cannot be suitably address permission would not Even looking 15 years to the future, it is very clear be granted. that based on the other gravel extractions in the area towards Yateley, that remediation of extracted All information received regarding the proposed land and its return to ‘countryside’ takes very many site allocations will be taken into consideration in more years that this the preparation of the Proposed Submission Detrimental impact on the surrounding area plan. regarding housing, residents, amenity, walkways, traffic, noise, flood risk, air quality e.g CO2 This site was subject to a planning application emissions and effect on the natural environment. which was subsequently refused and withdrawn. Therefore, the site has been ruled out as an The effects on physical health of residents, e.g. allocation in the Joint Plan and no further incidents of asthma are on the increase, cement assessments have been carried out. dust is an alkaline irritant, silica dust and its links to cancers and other serious lung diseases e.g. chronic obstructive pulmonary diseases a group of lung diseases including bronchitis and emphysema, vulnerability of residents already with respiratory conditions. The dust risk and hazard is not fully considered, nor is the reduction in the dust particle size caused by lorry movements over time and how this influences deep lung penetration and subsequent potential toxicity. Concerns about the proximity of the site in relation to existing housing, two schools as well as it being in a rural area. What measures and safeguards would be put in place to protect the local communities from the pollution emitted from the proposed site? Ground sprays and wheel washing are inadequate mitigation steps for dust unless they are independently monitored as are steps which are “economically viable” or “reasonably practicable” unless they guided by independent opinion. The CEMEX site at Bramshill has left the road and road margins in a disgraceful condition and it is clear to see where the dust plume settles across the countryside. A proposal that allows similar poor management in a much more densely populated area must not be approved
Loss of footpaths and rights of way Residents are concerned and cannot understand any benefit that would be generated to offset such environmental devastation Is the quality of the gravel present good enough to justify the damage to the natural environment. The quality of life for the local residents will fall. The site comments state that additional planting and hedgerows would be needed in order to hope to restrict impact on local houses. Roads such as Hyde End Road do not have any space nor facility to plant these hedgerows to any meaningful affect, therefore this road cannot support any traffic relating to the site. There appears to be no ability to address factors such as the impact on the quality of life or the practical impacts of the proposals, where the studies supporting the proposal are highly technical and very costly, presumably funded by the proposer or a supporter to proved the soundness of his proposal. Sadly we are come to realise this is how big business and government works, to the detriment of the ordinary citizen; where he has to live with the real life consequences of some poor quality proposals and decisions. It appears this mineral extraction proposal consultation at Bridge Farm is a prime example of this kind of process. Inert infill needs to be defined and regulated. What It is proposed that ground levels will be restored is the source, is this pre-processed, will there be using inert material (rather than household processing on site, and critically, what monitoring wastes). will be implemented to ensure compliance? Environmental effects of infilling the gravel pits with The proposal includes a processing plant on the waste material site.
Planning permissions contain conditions, and, in some cases, legal agreements are formed to ensure that schemes are undertaken. These are enforceable by the relevant Planning Authority. This proposed site is in conflict with Policy DM6 Mineral extraction is not considered ‘inappropriate’ development in the Green Belt due to its temporary nature. The justification for this site, as there is currently a The Berkshire LAA considered the former landbank significantly in excess of the legal County area. The Joint Plan covers the requirements. According to the Berkshire Unitary administrative areas of Bracknell Forest, Authorities Local Aggregate Assessments of 2014 Reading, Windsor & Maidenhead and and 2015 there is already a land bank of 11 years of Wokingham. sharp sand and gravel stock which obviates the The proposed allocation of this site in the Joint requirement for the proposed quarry. Commercial Plan is based on the requirements set out in the pressure not genuine need. Minerals Background Study and the date Objection to the need to maintain the landbank and provided in the 2018 Central & Eastern Berkshire objection to the proposal being for a specific local LAA. requirement. Paragraph 3.18 of the Berkshire Unitary Authorities LAA (August 2016) identifies The NPPF also states that a landbank should be there is enough mineral resource capacity for the a minimum of 7-years. foreseeable future. Therefore, this proposal is premature and considered surplus to requirements. The only significant source of very high demand is identified as Heathrow expansion, which is highly uncertain.
Bridge Farm is not listed as a Preferred Area in the There is only one remaining allocation from the Replacement Minerals Local Plan 1995/2001 which existing Plan in the Central & Eastern Berkshire is described in the current plan and indeed this site and that has been submitted as an application was previously rejected as a suitable area for gravel (Poyle Quarry). The Joint Plan needs to allocate extraction in 1992 following the Minerals in sites to provide a steady and adequate supply of Berkshire Public Consultation. minerals up to 2036. The proposed site is disproportionate in size It is proposed that the site would be subject to compared to the size and character of the phased extraction and restoration. surrounding villages Local property values could decrease as a result of Property Value is not a material consideration in the proposed site being implemented determining minerals and waste proposals. Objections to proposals have been ignored by The Bridge Farm application is being determined Wokingham Borough Council. based on the adopted Berkshire Minerals Plan. The planning application, to date, has not demonstrated that the proposed allocation is As the Joint Minerals & Waste Plan progresses it capable of providing adequate overall protection of will be a material consideration in decision- the River Loddon, protection (as a minimum) to making. ecological and geological features as well as maintaining the overall quality of the existing The Joint Minerals & Waste Plan outlines sites landscape as a whole as well as individual features, that are in principle suitable for development namely the Ancient Woodland and special subject to planning permission. landscape features. Further to this, the application has not demonstrated the protection of the existing At this stage, it is considered that the issues recreational sites (Langley Mead SANG), existing identified through the Plan process are not PRoW's and protection as a whole to the overriding and the site contributes significantly to recreational value to the South of the M4 as a the identified aggregate demand. whole. Environmental and health mitigations in the planning This site was subject to a planning application documentation are inadequate and place too much which was subsequently refused and withdrawn. responsibility for their implementation and Therefore, the site has been ruled out as an compliance in the hands of CEMEX allocation in the Joint Plan and no further assessments have been carried out. Concern that comments made to Wokingham Borough Council on the Bridge Farm application not being considered for the Draft Plan Consultation Application Ref 170433 is premature and should not be considered in advance of the Minerals and Waste Policy currently under development. Bridge Farm at Arborfield has been included in the draft Plan as a site for mineral extraction, against a number of advisory provisions in the NPPF, contrary to existing planning policies, in contradiction with the draft Neighbourhood Development Plan for Arborfield and Barkham, and in spite of a damning landscape assessment. Comments made in relation to the Bridge Farm planning application (170433): • Concern that the objections and comments made on the Bridge Farm planning application (170433) have not been taken into consideration (including Hampshire County Council) for the Bridge Farm site allocation (http://planning.wokingham.gov.uk/FastWebPL/D ocuments/DocList.asp?AltRef=170433) The majority of comments have major environmental implications and they need to be independently evaluated as part of the site selection process. • The timing of the Bridge Farm proposed allocation (given that an application is validated) is a concern. As the proposed allocation is outside of a Preferred Minerals Area and lies in
an area of a strong presumption against minerals extraction, and in light of the landbank available and capacity at existing sites, we question the need for this development at this time • There is a substantial amount of information which is either missing from the planning application or considered to be out of date, and therefore the Minerals Planning Authority is not able to make an informed view. With this in mind, it is considered that the allocation should be assessed in light of the need for the sand and gravel deposits in this location at this time mindful of Wokingham Borough Council's concerns and lack of information available to be able to determine the relative impacts accordingly. • The application would have to demonstrate protection of the River Loddon, protection of geological and ecological features (ancient woodland and special landscape features), protection of existing recreational sites (Langley Mead SANG, PRoWs, recreational value to the south of the M4) • The application would need to demonstrate no negative impacts would be incurred to the water table • The 1992 Minerals in Berkshire Consultation documents demonstrates Bridge Farm was rejected as a preferred area after this consultation, so it is misleading for the Draft Plan to identify Bridge Farm as a Minerals Preferred Area. Any application outside the preferred area would need to demonstrate extraction need in relation to existing supply, whilst proving preference over others • Barton Willmore produced a response to the planning application on behalf of the University of Reading. The report highlighted the following (in addition to issues previously mentioned): o Transport o Ecology o Landscape, restoration and aftercare o Noice o Air quality o Hydrology • Wokingham Borough Council requested further information from Cemex in December 2017 about the planning application, but Cemex has not yet responded • In addition to the issues raised above from the Barton Willmore report on the Bridge Farm application, Arborfield and Newland Parish Council objected to the planning application due to dust, the visual impact of the site and the impact the site would have on Pound Copse (a local wildlife site gifted to the Parish in 1980) No evidence has been provided that this site is The site selection methodology is set out in the better than another for such a mineral extraction – Minerals Proposal Study and was available for how has Hampshire Services ensured due diligence comment. Any comments received on the and duty of care in this selection process and how methodology will be taken into consideration.
has every comment made on the consultation, been considered and investigated This site of Arborfield is not practical and should not The Arborfield Relief Road is noted as a even be considered until after the Arborfield relief Development Consideration in Appendix A. road has been delivered Objection to the relationship between Reading Wokingham Borough Council is the Minerals University and Wokingham Borough Council and Planning Authority and therefore, is responsible others who do not live in the affected area, making for preparing a minerals local plan and decisions about our future and our health determining applications within its administrative Lord Bearsted (Bridge Farm landowner) is a political area. supporter of, and has made financial donations to, John Redwood (MP for Wokingham) and enjoys a personal relationship with Head of Wokingham Council Charlotte Haitham-Taylor. Therefore both have advised that they are unwilling to get involved with local residents' concerns. This seems wholly inappropriate and gives unfair weight to the landowner's chances of getting the proposal passed. I hope you take the above into account before making any decision which will impact on the lives of many residents and may adversely affect the area for many generations to come Consideration be given that the land within the Appendix A states that the proposed restoration boundaries of the scheme within the Parish of of the site is to agriculture, lowland meadow and Shinfield be granted to them in perpetuity, for wetlands with enhanced public access. purposes of providing a Country Park for Community and Leisure Use, similar to Dinton The long-term management of the site would Pastures within Wokingham Local Authority. need to be determined at the application stage. The creation of a quarry contravenes all current strategic development planning codes drawn up by the parish councils to ensure there is sufficient rural land marking a clear delineation between the villages of Shinfield and Arborfield (and all villages within the parishes). The traffic light system in the SA/SEA shows two The comments received on the Interim SA/SEA red negative effects, five amber/neutral effects and will be reviewed and used to inform the SA/SEA four green/positive effects. It is therefore relatively to accompany the Proposed Submission Plan. poor scoring. This site was subject to a planning application which was subsequently refused and withdrawn. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out. There has been insufficient consideration to pre- There are no formal plans for the development of emptive extraction at Grazeley Grazeley. However, as the options for development in Wokingham become more certain, opportunities for prior extraction will be explored. Community Engagement - the landowner(s), The Draft Plan consultation was the first Public constructor(s) and operator(s) hold well publicised consultation stage. A further opportunity to and regular community engagement meetings with comment will be available at the ‘Proposed all members of the public, together with relevant Submission’ stage in 2019. parish / town and borough councillors at least once The consultation complied with the Statements of per year and that the content of such discussions Community Involvement of each of the Central & are made public and kept on record for the duration Eastern Berkshire Authorities. of the works. (no Borough Policy number quoted - there does not appear to be one). This site was subject to a planning application The process has been poorly advertised, bound up which was subsequently refused and withdrawn. in local government wording so no normal person Therefore, the site has been ruled out as an can understand and is fundamentally flawed.
This consultation has been difficult for the public to allocation in the Joint Plan and no further respond to, which breaches the Authorities Duty to assessments have been carried out. care. Wokingham Borough Council and Shinfield Parish Council failed to inform the local community that Bridge Farm was being proposed for inclusion in the Joint Minerals and Waste Plan. Local residents have not been considered
Transport Issue Response Noise impacts. Operation of heavy plant between Appropriate hours of operation to be agreed as 7am and 6pm Monday to Friday and from 7am and part of the planning process. Noise (and other 1pm on Saturday, coupled with a major HGV environmental impacts such as air quality, movements of around 250 trucks per day plus severance, etc) will be addressed as part of ancillary vehicular movements must have a major Environmental Statement. In any event, impact on noise levels and consequently on planning approval of proposed development will residents and users of the countryside. need to be supported by an appropriate Transport Assessment or Statement, which will address issues of road safety, capacity and transport demand and will include mitigation measures as required.
Paragraph 4.4 of the Strategic Transport Assessment strengthened to this effect. Paragraph 4.5 added to explain role of environmental statement.
This site was subject to a planning application which was subsequently refused and withdrawn. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out. Untested Evidence - p36 Transport Assessment The Strategic Transport Assessment considers “This application has yet to be determined but the suitability of the site in terms of the principles supporting planning documents including an of access and HGV routing. Whilst information Environmental Statement and Transport Statement submitted as part of the current application has are available and relevant information from these been used to provide background data and an documents has informed this review.” There have indication of the proposals, the STA assessment been a number of technical objections to the has been undertaken independently. planning application, the subsequent residential planning applications and approvals and you have not considered the supplementary questions raised by Wokingham in December 2017 Arborfield Road already dangerous to walk along Planning approval of proposed development will /cycle along need to be supported by an appropriate Transport Assessment or Statement, which will address issues of road safety, capacity and transport demand and will include mitigation measures as required. Cumulative traffic impact with M4 upgrade to Smart It is recognised that further consideration needs Motorway causing issues in the vicinity of Reading, to be given to the cumulative impact of the Wokingham Junctions 11 and 10 for the next 4 to 6 proposed allocation alongside other years. developments in the area and this will be set out
Cumulative transport related impacts from in the Sustainability Appraisal which will development within the South of the M4 Strategic accompany the Proposed Submission Plan. Development Location (SDL) and the Thames Valley Science Park remain a concern An assessment of safety would be required of a The road transport around this area is almost wholly full Transport Assessment or Statement for this of two carriage-way, relatively narrow rural roads, site, with proposals for mitigation as required. originally laid out and built in the 1950s or before to handle low density car traffic, farm vehicles and little The updated Strategic Transport Assessment heavy duty cargo or passenger traffic. The Hyde considers the cumulative impact of the proposed End Road is a classic example of this situation, minerals and waste site allocations in where disruption and accidents have increased conjunction with available data from each of the substantially in the past couple of years. These four authority’s Local Plans. problems will increase and the road will become much more hazardous as more housing This site was subject to a planning application development is completed and more bus and other which was subsequently refused and withdrawn. transport services increase e.g. home shopping Therefore, the site has been ruled out as an deliveries, public transport, taxi’s and heavy goods allocation in the Joint Plan and no further traffic. assessments have been carried out. Combined effect of ineffective public transport Public transport opportunities for staff accessing facilities. sites would be reviewed as part of Transport Assessment or Statement required at the time of planning. Proposed routing of facilities traffic, brings it in direct A routeing agreement would be necessary to conflict with the surrounding land use (housing, ensure that HGV traffic avoids sensitive routes domestic and recreational). in the local area. Outdated traffic assessment not done at peak A transport assessment is submitted by the times. developer to the local authority who will assess its suitability. The proposed Arborfield bypass will traverse the This is noted within the Transport Assessment. site and interfere with the extraction of minerals from the proposed site The development of the proposed site is not in line Assessment of road capacity or junction with the sustainable transport goals of the Plan. suitability would be undertaken through a Local roads do not have the capacity to deal with an Transport Assessment/Statement at the time of additional 250+ lorry movements a day. An planning. A Transport Assessment has already independent survey submitted to WBC has already been submitted to the Planning Authority for concluded that local roads "would be operating them to determine. above capacity by 2026” shows that this site and transport impact with over 100 heavy goods This site was subject to a planning application vehicles a day is unsustainable, and will impact too which was subsequently refused and withdrawn. heavily on an area with a recognised transport Therefore, the site has been ruled out as an capacity constraint. allocation in the Joint Plan and no further The proposed site entrance is also not wide enough assessments have been carried out. for two large vehicles to pass one another. The quality and type of the roads are inadequate for It is unclear which road this refers to. The everyday traffic i.e. they are too narrow and the Strategic Transport Assessment has reviewed surface is too worn. Many lorries mount the the suitability of the roads along the proposed pavements in the village and go up the curb when HGV routing and concluded these are suitable coming downhill towards pudding lane nursery. to support the Proposed Scheme. Nevertheless, planning approval of proposed development will need to be supported by an appropriate Transport Assessment or Statement, which will address issues of road safety, capacity and transport demand and will include mitigation measures as required. Higher volumes of traffic, especially larger lorries Safety concerns would be assessed through a causing safety concerns for children since there are Transport Assessment /Statement at the time of a number of schools within the specified area and planning. A Transport Assessment has already the pavements are too narrow been submitted to the Planning Authority for
them to determine. Working hours would be considered as part of the planning process. Strategic Traffic & Transport Assessment – Junction A high-level assessment of impact on accesses 10 and 11 of M4 presents daily traffic issues and to strategic road network has been completed there are further problems associated with the A327 as part of the Strategic Transport Assessment, Black Boy Roundabout which is already at full detailed assessment and a routeing strategy capacity would be expected of a full Transport Assessment or Statement. Nearby roads become dangerous e.g. due to poor An assessment of safety would be required of a visibility in the bends, as well as in the wet following full Transport Assessment or Statement for this mud spillages from lorries, vegetation is dying and site, with proposals for mitigation as required. signage is obscured Inadequate transport links, the site is not directly The proposed site access is onto the A327 and served by a major road network is considered suitable, subject to a Transport Assessment or Statement. Access point at Hyde End Road is inappropriate for As above, a routeing strategy would be required the projected 350+ daily lorry movements, this road at the time of planning to ensure that HGV traffic is already treacherous and it is near to a nursery, avoids sensitive routes in the local area. infant and junior school There is no consideration of more environmentally The Draft Plan seeks to encourage sustainable sustainable methods of transportation of the transport through Policy DM11 (Sustainable extracted material Transport Movements). However, the Joint Plan also recognises that there are limited opportunities. Poor choice of Hyde Road in set up stage of the The Strategic Transport Assessment has proposed site, due to Shinfield bends being reviewed the suitability of the roads along the unsuitable for HGV’s proposed HGV routing and concluded these are suitable to support the Proposed Scheme. Nevertheless, planning approval of proposed development will need to be supported by an appropriate Transport Assessment or Statement, which will address issues of road safety, capacity and transport demand and will include mitigation measures as required. Whilst the supporting studies to this planning Planning approval of proposed development will application may claim to prove that the addition of need to be supported by an appropriate up to 200 HGV movements per day will not have an Transport Assessment or Statement, which will adverse impact on traffic flows/local roads, these address issues of road safety, capacity and conclusions are not supported by the real life transport demand and will include mitigation experience of the 100s of local residents that drive measures as required. The scope of these these roads every day, theory is one thing but assessments will be agreed with the Local practical experience is fact. Highway Authority and will likely consider Wokingham Borough Council’s own forecasts of committed developments and cumulative future traffic show the A327 to be at and beyond impacts. practical capacity in 2026, let alone 2036. In addition, traffic to and from the site would be characterised by large numbers of heavy vehicles, with a disproportionately high impact on traffic congestion and road safety. Hyde End Road as an access route sends hundreds of HGVs a day past a nursery and two schools and putting the burden of further major HGV movements onto the A327, regardless of the Shinfield Eastern Relief road or the Arborfield Relief Road is unacceptable given the major congestion that already exists. Sustainable Transport Movements; the use of historic data to determine the traffic situation, does
not acknowledge the influence of ongoing housing development in the area Where is the statement that considers the conflict The alignment of the preferred option for the between the proposed quarry site and the approved ACCR will broadly follow the eastern boundary route of the Arborfield Relief Road? This needs of the site and the necessary safeguarding of clear definition before any further consideration of land will form part of the discussions between this proposal the developers and the Council as appropriate. Health and Safety - design, construct and operate This level of detail would be considered through the materials handling facility such that all delivery a review by the planning authority of the and removal vehicles are always moving in a planning applications – conditions could be forward gear and such that no use of reverse gear is applied as required. ever required. Borough policy CP1, CP3 6 refers
Ecology Issue Response The River Loddon and its corridor is not mentioned It is recognised that river corridors and in the ecology or water environment sections. There watercourses need to be addressed in more is a huge opportunity here for significant ecological detail in the Proposed Submission Plan. enhancement. The Draft Water Environment and Flood Risk policy was subsequently split into two separate policies and addresses river corridors. Inadequate assessment of wildflower and protected All information received regarding the proposed species, no publicly visible report. site allocations will be taken into consideration in Impact of the proposed site on: the River Loddon the preparation of the Proposed Submission (including river wildlife such as gravel fish spawning plan. beds, crayfish and fresh water mussels); rare and protected species (skylarks and lapwings); other This site was subject to a planning application wildlife (otters, grass snakes, slow worms, bats), which was subsequently refused and withdrawn. along with their natural habitats. Additionally, the Therefore, the site has been ruled out as an disturbance of invasive plants such as Himalayan allocation in the Joint Plan and no further Balsam and Oxford Ragwort which will increase the assessments have been carried out. spread of these notifiable species. It becomes SSSI designation further downstream from the site. The effect of the site on the local badger population who are already suffering - regular badger casualties on the nearby A327. Restoration does not include improving connectivity between existing ancient woodlands and there is no target specified for the proportion of the site to be dedicated to nature conservation. This target should be set in policy to enable the scheme at this site to contribute effectively to the objectives of the Loddon Valley South Biodiversity Opportunity Area. Destruction of over 150 hectares of GREEN land, including more fields, countryside and wildlife in an already overburdened area. This will have negative impacts upon flora and fauna (which are already under huge strain from other developments) Bridge Farm - There needs to be a biodiversity aspiration in the restoration section.
Ecological and environmental surveys are The ecological surveys referred to apply to the inadequate and out of date Bridge Farm application not the proposed allocation. Under Appendix A - Proposed Sites. Development Detailed mitigation measures are required at the Considerations for Bridge Farm refer to buffers planning application stages and need to be required for the Local Wildlife Site and ancient considered on a case-by-case basis. As these woodland habitats on the site, but the width of buffer will be dependent on the circumstances at the
is currently not specified and some habitats point an application is submitted, it is not requiring buffers (such as hedgerows) are not appropriate to set specific mitigation included. The Bridge Farm planning application has requirements in a Plan which will guidance proposed inadequate buffers of between 5 and 10m decision-making up to 2036. for hedgerow and woodland, respectively, 15m for Local Wildlife Site woodland, and 20m for the River Loddon - likely to risk significant permanent degradation of the habitats concerned. It should therefore be stated clearly in the site policy that buffer width should be fully evidence-based, should be composed of appropriate semi-natural habitat, and should not allow any operational or construction encroachment. No timescale for restoration is specified and no The long-term management of the site would mechanism for ensuring sufficient aftercare, need to be determined at the application stage. monitoring, and evaluation is included. The management and monitoring of restored areas should be continuous for at least 25 years following the end of extraction. The reason for shortlisting the site seems to be It is considered that there are no overriding based purely on the fact that there is a current environmental issues that mean that the site is planning application in the system. No not suitable for allocation at this stage. environmental concerns are raised at the shortlisting stage, despite the findings of the assessments
Landscape Issue Response Bridge Farm would suffer the highest level of Noted - The Strategic Landscape assessment destruction in terms of landscape and visual states that development on this site would have impact...regarding the Strategic Landscape and Large Adverse impact. Visual Assessment (page 2), it shows the Bridge Farm plan to be the least viable with large adverse comments/red outcome The effect of the site on the distinctive character of Noted - The Strategic Landscape assessment the Bridge Farm fields, which are an area of natural states that development on this site would have beauty, used for recreation. Large Adverse impact. Infringement on and destruction of 190 hectares of ‘green land’ The Strategic Landscape & Visual Assessment Impact of the development on the Loddon Valley as sets out proposed mitigation measures which a place of beauty. could be included as planning conditions and could alleviate some of these issues. Agreement in local plans there would be a minimum This would need to be addressed as part of the area of green space left between new housing planning application. developments to maintain the character of existing villages. However, the proposed site could well be contrary to this Proximity of the site to a rural community This is an issue the Local Planning Authority will Countryside Developments - To design, construct need to address in the planning application. and operate any and all facilities on site in a way such that there is nil detriment to the surrounding The Strategic Landscape & Visual Assessment rural landscape and neighbours. In this sense, nil- sets out proposed mitigation measures which detriment should apply just as much to the pleasant could be included as planning conditions and visual nature of the countryside. (Borough Policies could alleviate some of these issues. CP1, CP7, CP11)
Flooding Issue Response
There needs to be clearer definition of the impact of The suggested flaws in the Flood Management the water management. Flood management plans Plans to support the application are not relevant are included in the application but fail to consider to the proposed allocation of the site in the Joint the impact of housing developments either Plan. However, the information provided will be approved or currently in the construction phase. taken into account. During this last 2017/18 winter following 12 months of substantial housing development in Shinfield and This site was subject to a planning application Spencers Wood the road was subject to very which was subsequently refused and withdrawn. serious flooding that caused the road to be Therefore, the site has been ruled out as an impassable and closed for a period of a few allocation in the Joint Plan and no further days. This was unprecedented, and much more assessments have been carried out. housing development is still to be completed which is destroying the lands natural ability to absorb and cope with heavy weather. Destroying a vast swathe of rural land for the minerals site can only exacerbate the “flood” risk potential of the area. Impacts of landfill and restoration to aquifer and water table changes, potential interactions with increased housing and shifting the local floodplain. Have the drainage systems following the Policy DM10 (Water Environment and Flood construction of the Eastern Relief Road been future Risk) seeks to prevent an increase in flood risk proofed, as there would likely be excess water / or impacts on the water environment. flooding from the proposed site and other developments All information received regarding the proposed The site is within EA flood zone 3a and 3b site allocations will be taken into consideration in (referenced in JCEB SFRA Statement). the preparation of the Proposed Submission Impact on River Loddon from runoff and other waste plan. from site Impact on water courses - ground water infiltration This site was subject to a planning application and pollution. The application must demonstrate which was subsequently refused and withdrawn. that no negative impacts will be incurred to the Therefore, the site has been ruled out as an water table, including impacts to flow, features and allocation in the Joint Plan and no further the water environment as a whole. assessments have been carried out. History of flooding in the area due to the Loddon River. Given the many well documented issues with the Loddon floodplain, where is the assessment of the impact of potential water diversion down the Loddon from the proposed site and how this might impact on the new road and residential infrastructure being built? Given that the extraction of minerals will take place below the groundwater table, there is potential for the water table to reduce as a result. Because of the high permeability properties of sand and gravel strata, the resultant influence on the water table can extend over a significant area. Bridge Farm is stated to be within SPZ2 and that an HRA is required. But this abstraction is from the confined chalk Quarrying & aggregates extraction is likely to be far more acceptable to the residents of the Borough of Wokingham, the Royal Borough of Windsor and Maidenhead and other downstream communities if design and implementation are arranged so as to deliver a large-scale flood mitigation scheme for the whole of the River Loddon catchment area. Bridge Farm Our historic flood map shows that the It is recognised that river corridors and site was impacted by fluvial events in 1990, 1991, watercourses need to be addressed in more and 2007. This should also be added to the detail in the Proposed Submission Plan ‘Flooding history’ section. Site allocations and river
corridors - Most of the site allocations are situated in or adjacent to river corridors. A strong River The Draft Water Environment and Flood Risk Corridor Policy is required to protect and enhance policy was subsequently split into two separate these sites and networks. policies and addresses river corridors. In the Water Environment and Flood Risk section Noted – the text will be reviewed and this says: amended. “Site partly within Flood Zone 3 and Groundwater Source Protection Zone (2) – a Flood Risk This site was subject to a planning application Assessment and Hydrological Assessment will be which was subsequently refused and withdrawn. required.” Therefore, the site has been ruled out as an This needs to be changed to: allocation in the Joint Plan and no further “Site partly within Flood Zone 3 and Groundwater assessments have been carried out. Source Protection Zone (2) – a Flood Risk Assessment and Hydrogeological Risk Assessment will be required.”
Archaeology Issue Response The site is within an area of high archaeological Noted. potential; and contains or is adjacent to scheduled ancient monuments This site was subject to a planning application A moated site scheduled monument is located which was subsequently refused and withdrawn. outside the site to the south-east. Concerned at the Therefore, the site has been ruled out as an proximity of quarrying to the monument - whilst allocation in the Joint Plan and no further there would be no direct physical impact on the assessments have been carried out. monument (and the site and its archaeological potential would therefore stay intact), there may be an impact on its significance through development within its setting (paragraphs 190 and 194 of the National Planning Policy Framework recognise that development within the setting of heritage asset can affect its significance). According to our records there are no designated Noted. heritage assets on this site. The Grade II listed Bridge House is located just outside the site to north and the Grade II High End Farmhouse is located just outside the site to the south-west. This is not noted in Appendix A but we do not consider it likely that the proposed mineral extraction would have an unacceptable impact on the significance of these designated heritage assets. The proposed development appears from the The presence of a moat does not imply further mapping data to currently be located within a rural contemporary archaeological sites. The Historic landscape, characterised by open fields and divided landscape character is much degraded except by hedgerows, and amongst this it may be possible the area immediately adjacent the moat which to identity other elements or features of medieval lies outside the allocation. There is the potential settlement. There is therefore potential for that restoration could be used to improve the identification of related medieval archaeology in the setting of the scheduled moat. surrounding landscape, and they will also need to give consideration to the potential impact on This site was subject to a planning application landscape character, from development in such an which was subsequently refused and withdrawn. open rural landscape. Therefore, the site has been ruled out as an The proposed development may cause harm to the allocation in the Joint Plan and no further historic landscape character of the area and the assessments have been carried out. scheduled monument, by impacting directly on any associated archaeological remains, such as ridge and furrow, and impacting the understanding of the moated site and its relationship with the surrounding agricultural landscape.
This area has high archaeological potential - crop Noted – the site has been subject to survey and marks and geophysical survey suggest extensive evaluation sufficient to demonstrate that the prehistoric activity in the vicinity of the site and there significance of the archaeological remains does is good potential for associated waterlogged not outweigh the public benefit of allocation to archaeological remains within the alluvial floodplain win minerals. deposits of the River Loddon. River terraces exist on the site, representing ancient This response to this issue is outlined in more courses of the Rivers Loddon and Blackwater, both detail in the Heritage Statement. tributaries of the Thames. Elsewhere these river terraces have revealed significant Palaeolithic remains. Therefore, the potential of the sands and gravels for Palaeolithic archaeology should be considered. Evidence might not exist for such archaeology on the Historic Environment Record, owing to its depth and the lack of past investigation. Accordingly, the evidence in support of this allocation site would benefit from the construction of a geoarchaeological deposit model, to identify the nature of the deposits that would be impacted and their archaeological significance. We therefore consider that this site should not be taken forward without further investigation and assessment of the contribution of that part of the setting of the Scheduled Monument within the proposed allocated site to the significance of the Monument, and appreciation of that significance (in the form of a desk based assessment and setting analysis); of the potential impact of mineral extraction at this site on that significance, and of the significance and potential impact on the significance of other archaeological remains in this area.
Datchet Quarry This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out. General Issue Response Any waste dumped into Riding Farm will leach into Potentially harmful emissions to water are the river and who can tell what pollutants will be in controlled by the Environment Agency and the waste from the third runway build and there are would be subject to their regulation and two drinking water intakes down river from this site. monitoring. The planning system has an expectation that other parts of the system, including the duties of other agencies, will work as they should.
Furthermore, amenity issues would be addressed by Draft Policy DM9 (Protecting Public Health, Safety and Amenity), while water environment issues would be addressed by DM10 (Water Environment and Flood Risk). Should an application be submitted for the site, the proposal would need to comply with these policies and address any potential issues through mitigation measures. No further lakes are need in the area as the present Noted – at this time, none of the proposed ones are under used for pleasure use. allocations are to be restored as waterbodies.
Support the allocation of this site. Noted
Ecology Issue Response Datchet Quarry - Protection, enhancement and It is recognised that river corridors and buffer of stream corridor is mentioned for this site. watercourses need to be addressed in more However, the watercourse is not mentioned in the detail in the Proposed Submission Plan. water environment section. The Draft Water Environment and Flooding policy was subsequently split into two sperate policies and now addresses river corridors. No habitat or species protection has been Appendix A sets out the Development considered. Considerations that would need to be taken into account. The Development Considerations for Datchet Quarry include ecological considerations include relevant Special Protection Areas, Ramsars, and Local Wildlife Sites.
This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out.
Landscape Issue Response Protection of the countryside and green belt has not The site is an existing extraction site. Minerals been considered extraction is not considered inappropriate in the Green Belt.
The Strategic Landscape and Visual Assessment considers the sensitivity of the site as moderate / low due to the adjacent M4.
This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out.
Flooding Issue Response Riding Court Farm This site allocation is proposed Noted – this will be taken into account in the for waste management, which could be classified as updated SFRA. less or more vulnerable development in accordance with Table 2 ‘Flood risk vulnerability classification’ in This site was subject to a planning application the Planning Practice Guidance. There are large which was subsequently approved. Therefore, areas of Flood Zone 3 within the site. Please note the site has been ruled out as an allocation in that only development classed as ‘water compatible’ the Joint Plan and no further assessments have or essential infrastructure (with exception test) will been carried out. be permitted in Flood Zone 3b. In the Water Environment and Flood Risk section Noted – the text will be reviewed and amended. this says: Site largely within Flood Zone 3 and in Groundwater This site was subject to a planning application Source Protection Zone (3) - a flood Risk which was subsequently approved. Therefore, Assessment and Hydrological Assessment will be the site has been ruled out as an allocation in required. the Joint Plan and no further assessments have This needs to be changed to: been carried out. Site largely within Flood Zone 3 and in Groundwater Source Protection Zone (3) - a flood Risk Assessment and Hydrogeological Risk Assessment will be required. Any removal by water will increase the road distance Noted. The Development Considerations state to the third runway build not reduce it and cause that a Flood Risk Assessment would be further pollution environmental and air with diesel required to support any planning application. particulates. Increased flooding risk not just increased levels but high water flow streams. Objection to the plan because of its detrimental impact on flooding in the Datchet area and the fact that if even more gravel is removed, then this is putting residents and any new households at risk.
Archaeology Issue Response According to our records there are no designated Noted. The Strategic Landscape and Visual assets on this site. The Grade II Registered Historic Assessment will be amended to remove “and Park and Garden of Ditton Park lies a little way to part of site lies within the boundary of the the north (according to the National Heritage List for registered Ditton Park (currently an arable field)” England, part of the site is not the Registered Park (Page 47, final paragraph). as stated in the draft SEA) and the Grade Iisted
Riding Court Farmhouse is located a little way to the This site was subject to a planning application north-west. We do not consider it likely that the use which was subsequently approved. Therefore, of this site for aggregates recycling would have an the site has been ruled out as an allocation in unacceptable impact on the significance of these the Joint Plan and no further assessments have designated heritage assets. been carried out.
Known historic site from at least Saxon times Noted - Recorded archaeological sites in the vicinity have been considered in the assessment.
Ham Island
General Issue Response The compatibility of the restoration plan with the The proximity of the Sewage Works is recognised nearby sewage plant in Appendix A. The Proposed Restoration is the enhancement of natural habitats and local landscape including public access and amenity areas. Should an application be submitted for the site, the sewage works would need to be taken into account. Amenity space (used by visitors) at the ‘The Lock’ Amenity issues would be addressed by Policy will be impacted by the proposed site DM9 (Protecting Public Health, Safety and The effect of noise, dust, vibration, pollution and Amenity). Should an application be submitted for loss of privacy on general amenity of the area and the sites, the proposal would need to comply with health of residents and their homes (also this policy and address any potential issues applicable post extraction) through mitigation measures. This proposal within the consultation has been The Draft Plan consultation was the first Public poorly advertised and communicated with local consultation stage. A further opportunity to residents. Lack of information from the Council on comment will be available at the ‘Proposed this, when if a neighbour wants to add an Submission’ stage in 2019. extension to their property we get notified by letter, but not on an important proposal that affects a The consultation complied with the Statements of large area prone to noise, pollution and flooding Community Involvement of each of the Central & and without doubt will affect our well-being. Eastern Berkshire Authorities. There was no consultation with the parish council nor the ward councillors about the suitability of this An objection raised by Historic England could not proposed site before it was added to the draft be suitably addressed and therefore, the site is plan. ruled out for allocation in Joint Plan on this basis. We have concern regarding Duty to Cooperate as No further assessment work has been we, and residents, were not informed of the undertaken. inclusion of this site in the draft plan. Concerns about the restoration plan as well as A formal restoration plan would be submitted as how it would be ‘monitored’ in the longer term part of any application. The Draft Plan outlines without causing detrimental impacts on the the proposed restoration. Planning permissions residents contain conditions, and, in some cases, legal agreements are formed to ensure that schemes are undertaken. These are enforceable by the relevant Planning Authority. Detrimental impact of the proposed site in terms of Amenity issues (including light pollution) would be polluting the air as well as the site producing addressed by Policy DM9 (Protecting Public unnecessary light pollution Health, Safety and Amenity). Should an application be submitted for the sites, the proposal would need to comply with this policy and address any potential issues through mitigation measures. Safety of the boating public and other river users. The Environment Agency is responsible for Waterway used for swimming, paddle boarding, Navigation Licences and therefore, this issue is canoeing, rowing and powerboating as a outside the remit of the Joint Minerals & Waste recreational and safe area, free from heavy Plan. commercial traffic and pollution. How will this continue with commercial barges restricted in their ability to manoeuvre carrying large loads, pass? Social and financial impact including the Property Value is not a material consideration in devaluation of local properties determining minerals and waste proposals. However, amenity (and other issues) would be addressed by the Development
Management (DM) Policies which seek to control impacts. The practicality of removing minerals by Barge All information received regarding the proposed when the formation of a barge loading station is in site allocations will be taken into consideration in a known critical flood area and the locks have the preparation of the Proposed Submission plan. limited capacity and the locks close in winter for maintenance. Particular consideration will be given to the Cannot be used as a landfill as its part of the potential for flood risk associated with this site due Floodplain to the breadth of information received. Flooding has impacted the physical health of residents An objection raised by Historic England could not be suitably addressed and therefore, the site is ruled out for allocation in Joint Plan on this basis. No further assessment work has been undertaken. An astonishing lack of respect has been The proposed restoration of this site is outlined in demonstrated to the land, environment, wildlife, Appendix A as ‘Enhancement of natural habitats the residents and of course the future generation and local landscape including public access and of young River users amenity areas.’ Any waste dumped into Ham Island or Riding The proposed infill of land at this site is of inert Farm will leach into the river and who can tell what materials. Draft Policy DM9 (Protecting health pollutants will be in the waste from the third safety and amenity) would need to be complied runway build and there are two drinking water with as part of any proposal. intakes down river from this site. Unjust favour – difficult to obtain planning Planning permission would need to be sought permission to make small changes to residential prior to development of any proposed allocation dwellings on Ham Island, so how and why will site. Many changes to residential dwellings are permission potentially be granted for the covered by permitted development rights and construction of wharves and other associated liaison with the relevant planning authority is buildings be granted? encouraged. No further lakes are need in the area as the Noted – at this time, none of the proposed present ones are under used for pleasure use. allocations are to be restored as waterbodies. The fact that the area within the red lined The ‘red line boundary’ indicates the area which is extraction area includes a number of items of likely to be covered by the planning application sewage treatment plant of substantial concrete but is not necessarily the area that would be construction and huge settling lagoons which are worked. Details on how the site would be worked in current use. would need to be provided as part of any planning application. The escalated demand for housing demonstrates Thames Water have been consulted as part of the that extension of STW capacity will be even more Process and are willing to explore the feasibility of desperately needed rather than reduced by gravel the site for extraction provided that the proposal extraction does not detrimentally impact upon the adjacent Sewage Treatment Works operations. The only reference to residents on Ham Island is It is recognised that Appendix A should make in on page 135 under the Landscape & reference to amenity impacts and this will be Townscape reference to screen planting. addressed in the Proposed Submission Plan.
An objection raised by Historic England could not be suitably addressed and therefore, the site is ruled out for allocation in Joint Plan on this basis. No further assessment work has been undertaken. Appendix A – Proposed Sites Ham Island – Sand Noted. and Gravel The site is owned by Thames Water leased to a 3rd party. The site is adjacent to the The site was subsequently discounted as a operational Ham Island Sewage Treatment Works. borrow pit for the proposed Heathrow Expansion The site was also identified as a potential borrow as the project progressed. pit for gravel extraction in association with the Heathrow Airport 3rd Runway construction. An objection raised by Historic England could not Thames Water supported the identification of the be suitably addressed and therefore, the site is
site as a potential borrow pit site and are similarly ruled out for allocation in Joint Plan on this basis. willing to work with the Council in relation to No further assessment work has been assessing the feasibility of the site for gravel undertaken. extraction. However, a key consideration will be that any such proposals must not detrimentally impact upon the adjacent Sewage Treatment Works operations, and careful consideration will need to be given to potential archaeological remains at the site and the archaeological investigation work which will need to be undertaken. Believe the Ham Island site is undeliverable and Noted. should be removed from the allocation. There is no evidence of gravel on the site. While The presence of sand and gravel is indicated by constructing a replacement dwelling, as a result of the minerals data provided by the British flooding, a resident reported that they drilled down Geological Survey. 15m and the only material found was earth. There is no proof that it will deliver sustainable All proposals will need to comply with the Policies development or that it will not negatively affect outlined in the Joint Plan including the economic, social and environmental conditions. Development Management (DM) Policies and Policy M1 (Sustainable Minerals Development Strategy). Impact of the site on the nearby horse sanctuary Noted.
Transport Issue Response Limited transport links. Access to the site is All information received regarding the proposed restricted and unsuitable. Roads around the site site allocations will be taken into consideration in are small, congested, limited and with pinch points the preparation of the Proposed Submission plan. such as river bridges and rail crossings there will be significant traffic disruption The limitations of the site in relation to road Concerns about barges being used as the stretch access are appreciated and acknowledged in the of river is very narrow and regularly exceeds 20 Strategic Transport & Traffic Assessment as well Knots and rises 10 feet in height. It is also as Appendix A. It is not proposed to transport currently used mainly by small pleasure boat materials by road, it is anticipated that only staff owners and anglers. Additionally, the river has not vehicles may require road access. The been dredged recently and there are concerns construction of a suitable wharf is critical to the about it being too shallow delivery of this site and will need to be secured as Ham Lane is a private road (as per the Old part of any planning application. Windsor Enclosure act of Parliament 1813), currently with pedestrian right of way, therefore it is unclear regarding the legality of the access to the proposed site Concerns about access road – dangerous for larger vehicles to use as it is predominantly used by walkers, cyclists and horse riders. Too narrow for larger vehicles to use on a regular basis The access roads to Ham Island are in a bad state, full of pot holes and uneven surfaces. Fears they could worsen if the roads are being used more frequently by the proposed site’s associated traffic There is only a single track access to the island that has to service the residents, Thames Water Sewerage Treatment Works and an animal sanctuary. There are several level crossings in the area close to Ham Island and it is feared with the
implementation of the proposed site and the associated traffic could cause further congestion problems and gridlocking at peak times Concerns over how barges will navigate the The Environment Agency is responsible for narrow and shallow weir system. Navigation Licences and therefore, this issue is outside the remit of the Joint Minerals & Waste Plan. Concerns that there is not enough space to build a Noted. wharf. Any removal by water will increase the road Whilst the site has been identified as a potential distance to the third runway build not reduce it and borrow site to serve the Heathrow Expansion this cause further pollution environmental and air with has not yet been confirmed. The potential diesel particulates. impacts associated with the development would need to be addressed as part of any planning application.
The site was subsequently discounted as a borrow pit for the proposed Heathrow Expansion as the project progressed. The proposal that the area is regenerated as a Noted. local park is not possible as the Island access is a private road.
Ecology Issue Response The effect of the site on protected habitats and All information received regarding the proposed species (e.g. bird sanctuary), on the riverside, site allocations will be taken into consideration in Ham Island beach and River Thames the preparation of the Proposed Submission plan. Ham Island is considered a haven for wildlife and the proposed site would destroy the habitats and It is recognised that river corridors and disrupt the natural surrounding corridors. There watercourses need to be addressed in more detail are also distinctive tree species on the Island that in the Proposed Submission Plan. would be threatened by the proposed site The proposed wharf facilities would cause harm to An objection raised by Historic England could not the natural Island habitats be suitably addressed and therefore, the site is ruled out for allocation in Joint Plan on this basis. Reeds and willow trees lining the river’s edge No further assessment work has been provide important habitats for local wildlife and the undertaken. roots provide stability to the river bed. Without them, the threat of landslides would increase The overflow reed bed system provides important breeding grounds for various species and this could be jeopardised with the implementation of the proposed site Ham Island is home to a wide range of plants, birds and mammals including the Kingfisher and has been identified on many maps as a bird sanctuary. There are also trees that would indicate suitability for bat roosts. Please see Acorn Ecology report (sent by email) The effect of pollution on the nearby River Thames and its biodiversity Ham Island - The River Thames is not mentioned in the ecology or water environment sections. Arguably negligent to potentially allow pollutants The proposed infill of land at this site is of inert from a landfill to enter a river used throughout the materials. year for leisure activities including fishing, boating and swimming
Landscape Issue Response The effect of the site on the ‘wild’ character of the The Strategic Landscape and Visual Assessment area recognises that development of this site would The local landscape will be “devastated” by the have a Large Adverse effect on both landscape possible implementation of the site and visual elements. Protection of the countryside has not been considered The site has been identified as a potential borrow pit for the expansion of Heathrow and it was Ham Island is part of the designated 'Setting of the considered that the impacts identified could be Thames'. The area surrounding it is public open suitably mitigated. As such, the site was included space and includes the very picturesque and in the Draft Plan as a potential allocation. much love Old Windsor Lock. The 'Thames Path' runs parallel to the Island and is well used by All information received regarding the proposed residents and visitors alike due to the site allocations will be taken into consideration in attractiveness of the countryside. The Thames the preparation of the Proposed Submission plan. itself surround Ham Island and is very popular with boaters, canoeists and residents therefore any The site was subsequently discounted as a engineering construction (to transport material) will borrow pit for the proposed Heathrow Expansion have a very detrimental effect on Old Windsor's as the project progressed. amenity and that of Wraysbury (across the river). Although Old Windsor is classified as a Rural An objection raised by Historic England could not village we have very little easily accessible, be suitably addressed and therefore, the site is unspoilt countryside of our own. ruled out for allocation in Joint Plan on this basis. No further assessment work has been undertaken. Protection of the green belt has not been Noted. However, mineral extraction is not considered considered ‘inappropriate’ development due to its temporary nature.
Flooding Issue Response The Jubilee River that discharges upstream of old The Environment Agency response states “Under Windsor Lock and its associated weir stream ‘Flooding History’ the Jubilee River does not need around Ham Island, which happens to be one of to be mentioned. The area does not benefit from the narrowest points of the Thames, takes the full the scheme, but it does not increase the risk of brunt of the relief discharge in order to protect flooding either”. Maidenhead and Windsor from flooding. When flooding occurs the level in that weir stream rises This contradicts the perceived experience of local to 3 meters above the summer water level and it is residents in the area and needs to be considered at that point when Ham Island floods and prevents in the Strategic Flood Risk Assessment. further damage to Wraysbury. No mention or allowance been made of the An objection raised by Historic England could not combined increase risk of flooding due to the be suitably addressed and therefore, the site is Jubilee River and Extraction scheme ruled out for allocation in Joint Plan on this basis. No further assessment work has been undertaken. There have been three severe flooding incidents Noted – the SFRA will be updated to take the since 2000 necessitating evacuation of residents, additional information into account. e.g. flooding that took place in the area in 2014 The Environment Agency have acknowledged the An objection raised by Historic England could not critical flooding problem in Wraysbury and be suitably addressed and therefore, the site is surrounding areas have planned in the longer term ruled out for allocation in Joint Plan on this basis. for a by-pass river to alleviate the pressure, has No further assessment work has been the scheme taken this into account. undertaken. Under ‘Flooding History’ the Jubilee River does not need to be mentioned. The area does not benefit from the scheme but it does not increase the risk of flooding either.
Our historic flood map shows site was affected by events in 2000, 2003, and 2012, and 2013/14 in recent years. These flood events need to be included in the flooding history section. Our modelling indicates that around 1/3rd of the site is in Flood Zone 3b – i.e. the 5% AEP flood extent. This means that only development classed as ‘water compatible’ or essential infrastructure (with exception test) will be permitted in Flood Zone 3b. If flooding occurs during or post extraction, it will Flood risk issues would be addressed by Policy cause the water to drain through landfill and DM10 (Water Environment and Flood Risk). pollute the waterways. Contamination issues would be addressed by Concerns of river pollution Policy DM9 (Protecting Public Health, Safety and Amenity).
It is recognised that further consideration needs to be given to the river corridors and this will be addressed in the Proposed Submission Plan.
Policy DM10 was subsequently split into two policies and impacts on rivers were more explicitly addressed. The practicality of removing minerals by Barge The Strategic Flood Risk Assessment recognises when the formation of a barge loading station is in that the site is High Risk but that considering the a known critical flood area. type of development proposed, this should be Increased risk of flooding to Wraysbury, manageable. Sunnymeads and towns downstream, particularly properties in Wraysbury, due to the site being in It is recognised that further information is required the flood plain and a decrease in permeable regarding how flood risk would be addressed at surface area. How do you propose to mitigate the this site and this will be sought from the site flood risk that will rise? promoter in liaison with the Environment Agency. The removal of the mineral from the site would put the area at higher risk of flooding – the Island All information received regarding the proposed needs more protection; not for existing natural site allocations will be taken into consideration in barriers to be removed the preparation of the Proposed Submission plan.
Concerns the proposed modifications of the An objection raised by Historic England could not western end bunds for the construction of the be suitably addressed and therefore, the site is wharf and conveyor belt would compromise the ruled out for allocation in Joint Plan on this basis. flood defences No further assessment work has been There is a groundwater protection policy in place – undertaken. how on earth could this be protected particularly in run-offs from flood zone 2 to flood zone 3 The site is immediately adjacent to the River Thames so an appropriate buffer will be needed to ensure that development does not damage the river or destabilise the river banks. Extraction will disrupt the Jubilee River Operation Fearful of the damage future flooding (caused as a result of Ham Island development) could result in and the impact upon properties and the surrounding area This is an area of historic flooding it serves as flood plain for Wraysbury and also catchment for the whole of Old Windsor and the Great Park run off. Groundwater levels are very high and Ham Island will flood before anywhere else in the village. In the last 20 years we have had 3 incidents of serious flooding that has caused property damage.
Who will the contact be and who will take Permission will not be granted for proposals which responsibility for the flooding of the village and increase the risk of flooding as any development associated costs in the event that is directly will need to comply with Policy DM10 (Water attributed to the scheme? Environment and Flood Risk). Wraysbury home owners pay very high insurance premiums which now comes under the Financial implications are only taken into Government Flood Re Scheme because the area consideration in the implementation of the has been designated the highest possible flood Exceptions test which should cover any funding risk, has anyone ascertained how the scheme will arrangements for implementing mitigation be viewed by the insurers and will any resultant measures. increases be paid for by the Borough. Changes to our risk level increases when land excavation is near and this has cost elements and possible insurance refusal In the Water Environment and Flood Risk section Noted – text to reviewed and amended. this says: Site wholly within Flood Zones 2 and 3 and An objection raised by Historic England could not Groundwater Source Protection Zone (3) – a be suitably addressed and therefore, the site is Flood Risk Assessment and Hydrological ruled out for allocation in Joint Plan on this basis. Assessment will be required. No further assessment work has been This needs to be changed to: undertaken. Site wholly within Flood Zones 2 and 3 and Groundwater Source Protection Zone (3) – a Flood Risk Assessment and Hydrogeological Risk Assessment will be required. Under ‘Summary’ it says ‘Overall it has high flood risk but given the type of manageable’. Should this say, ‘Overall it has high flood risk but given the type of development it should be manageable’? Please note that any development of the site will Noted – The SFRA will be updated and will take need to take into account climate change. If into account Climate Change as required. development results in loss of floodplain storage it may be difficult to provide adequate compensatory Site Specific Flood Risk Assessments (FRAs) will storage. This is because once climate change is need to take into account Climate Change. taken into account there is likely to be little land outside the 1% flood extent, and land on the edge An objection raised by Historic England could not of the floodplain is usually required for be suitably addressed and therefore, the site is compensatory storage. ruled out for allocation in Joint Plan on this basis. Any impact on residential properties will need to No further assessment work has been be carefully considered, as the site is in close undertaken. proximity to a number of houses. Any proposal which increases flood risk to these properties will be contrary to national planning policy. Ham Island site has been historically identified as prone to flooding. The EA have not published their climate change adjustment figures yet, however do acknowledge that any planning applications in this area should take increased flooding due to climate change into account. The EA have established that there are no effective flood defences/mitigation that could be applied to this area. Ham Island is a flood plain which works to help Noted. protect Wraysbury Water levels rise it is extremely stressful and Noted. obviously even more so when it starts to damage your home and leads to unplanned cost and time to fix problems and increases to insurance costs. Increased flooding risk not just increased levels Noted. The Strategic Flood Risk Assessment but high-water flow streams. also considers fluvial flooding.
The STW’s treated effluent outfall crosses the Noted. nearby fields within the proposed mineral extraction area in an easterly direction to the Thames. This outfall currently also discharges partially treated effluent at frequent times when incoming sewage exceeds the capacity. There is a residential community immediately Noted. adjacent to the proposed area, any development will exacerbate the existing flooding issues. In the recent past the area was used as overflow Noted. Thames Water have been consulted as lagoons in times of capacity issues at the Works, part of the Process and are willing to explore the although we understand that this is being feasibility of the site for extraction provided that addressed there is no evidence to date that the the proposal does not detrimentally impact upon lagoons will not be needed in the future. the adjacent Sewage Treatment Works operations.
Archaeology Issue Response The effect of the site on the historic character of It is recognised that the Ham Island allocation the area as it partly lies within the Heritage potentially impacts a nationally important Category List Entry No 1006995, is within the area archaeological site and a better understanding is designated “Setting of the Thames” and the required of the basis for the extent of the “Thames Path”. Also the southern part of Ham scheduled site and the archaeological context of Island is a Scheduled Ancient Monument with the scheduling. many signs of Saxon habitat being found. Possibility of ancient relics, yet to be excavated, in The reference to “burdensome” will be clarified as and around the site which could be impacted by this relates to the point which may call into the proposed site question the reasonableness of using a condition This site includes the early medieval and medieval to secure mitigation. palace and associated monuments of Kingsbury scheduled monument and has high archaeological Liaison is on-going with Historic England potential. It is a large scheduling that includes a regarding the allocations including Ham Island. Saxon (9th century) settlement built on the site of an earlier Roman settlement, with a royal palace All information received regarding the proposed providing a seat of government. The monument site allocations will be taken into consideration in was partly excavated in the 1950s with a range of the preparation of the Proposed Submission plan. settlement-related and high status artefacts being discovered. There is however, still much about the An objection raised by Historic England could not extent of the settlement and nature of deposits in be suitably addressed and therefore, the site is this location that is not understood. ruled out for allocation in Joint Plan on this basis. No further assessment work has been The relationship of the monument within the undertaken. surrounding landscape and river is a crucial part of its significance, as it demonstrates why the Details are provided in the Heritage Statement. settlement was placed in this particular location in the first place. Whilst there has been some development encroachment from the adjacent sewage works etc. the peninsula of the island remains as open ground which makes it possible to orientate the monument within the surrounding landscape and in relation to the river. Removing the evolved landscape that surrounds the monument would not only change the whole character of the landscape to which the monument relates, but has the potential to impact directly on any associated buried archaeological deposits, though further research and investigation would be needed to asses this fully
It is possible that related archaeology is present in the non-designated area, though desk based study and field work would be necessary to establish this. The fields on the opposite side of the river also have high archaeological potential. Paragraph 193 and 194 of the NPPF require great weight to be given to the asset’s conservation and that any harm to the heritage asset requires clear justification. There are therefore major concerns over the proposed allocation of this site – indeed, as the allocation covers a significant area of the scheduled site, and the crucial part of the monument that connects the settlement site with the river, we consider that the it is likely that the proposed excavation would cause substantial harm to the significance of the scheduled monument. The site should not be taken forward, certainly not without further investigation and assessment of the significance of the scheduled monument; of the other archaeological interest and significance of the site; and of the potential impact of mineral extraction at this site on that significance, The allocation of this site should not be taken forward in the absence of clear evidence that extraction at this site would not be harmful to the significance of the scheduled monument or other archaeological remains in this area. Disappointed with the negative attitude towards this potentially nationally important archaeological remains which the authors describe as “burdensome”. Ham Island is the location of a significant Scheduled Ancient Monument site. Please see report - Oxford archaeology and document from Berkshire Archaeology (sent by email) that details the significance of the site and its potential. The draft SEA fails to recognise the harm – we do The ‘red line boundary’ indicates the area which is not understand how the authors of the SEA can likely to be covered by the planning application conclude that mineral extraction at this site would but is not necessarily the area that would be have a neutral or negligible effect on the worked. scheduled monument, although it is possibly because on page 235 the monument is described Details on how the site would be worked would as “adjacent” to the site, whereas it is within the need to be provided as part of any planning proposed allocation site, as recognised on page application. The proposed development would 236. exclude the SAM and it is recognised that this We note that Appendix K of the draft SEA does needs to be made clear in Appendix A and the not suggest any example mitigation measures for SEA. the likely substantial harm that mineral extraction at this site would cause to the significance of the The SEA considers the short- and long-term scheduled monument. impacts of the development and considers that following restoration the impact would be neutral or negligible. However, the SEA (including Appendix K) will be reviewed in light of the comments received.
An objection raised by Historic England could not be suitably addressed and therefore, the site is ruled out for allocation in Joint Plan on this basis. No further assessment work has been undertaken.
Horton Brook Quarry
General
Issue Response This quarry has recently been granted an extension to the Noted. extraction permitted time as it has been unable to sell the available aggregates. INFILL OF ALL SITES [Horton Brook, Poyle Quarry & Ext and There are no current proposals for Berkyn Manor] - The Horton Brook Quarry is obliged to infill non-hazardous landfill. with inert waste only and this should be a condition of each of the other sites. RESTORATION OF SITES These sites [Horton Brook, Poyle Site restoration is covered by policy Quarry & Ext and Berkyn Manor] are, or have been, largely DM8: Restoration of Minerals and agriculture in nature and should be returned as near as Waste Developments. possible to their pre-development condition. Any planting made in order to preserve some resemblance to a rural scene should Restoration plans will have been be retained where possible in order to retain and protect the agreed for permitted applications and new ecology systems developed during extraction / infill will be required for new planning operations. proposals. Restoration is a balance of pre-extraction site character and opportunities for enhancement.
Transport
Issue Response The A4 Bath Road at Brands Hill is already a pollution hot spot If required by the planning authority, with highly illegal levels of air pollution, and very high traffic an environmental statement, or other densities. The extension to the life of this quarry together with relevant reports would address any the infill years, will continue to blight Brands Hill for many years issues of noise, vibration and air to come. quality.
Paragraph 4.5 of Strategic Transport Assessment added to explain role of environmental statement.
Planning approval for future use of this site would be require a Transport Assessment or Statement in which road capacity issues will be assessed in detail, and mitigation proposed as required.
Paragraph 4.4 of the Strategic Transport Assessment strengthened to this effect. Road access to all of the above sites [Horton brook, Poyle The Strategic Transport Assessment Quarry & Ext and Berkyn Manor] must be via a dedicated states Poyle Quarry, Poyle Quarry private road across the landowner’s property onto Poyle Road Extension and Berkyn Manor then directly to J15 of the M25. consider a number of alternative accesses therefore do not solely rely on the delivery of the new road.
This access has now been accepted (by Slough Borough Council as the access is within its boundary) via an approved application to WMBC for Poyle Quarry (17/03426/FULL).
It should be noted that Horton Brook Quarry is under separate ownership.
Planning approval for future use of these sites would be require Transport Assessments or Statements in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required.
Paragraph 4.4 of the Strategic Transport Assessment has been strengthened to this effect.
Ecology
Issue Response Horton Brook Quarry - There is no mention of the Colne Brook It is recognised that river corridors or its river corridor. This needs to be included. and watercourses need to be addressed in more detail in the Proposed Submission Plan.
A specific reference has subsequently been added to the Development Considerations.
Landscape
Issue Response The harm to this section of the Park and the frustration to the The original planning application for delivery of much needed environmental improvements and this site included restoration to green ‘connectivity’ in the area its asked that greater weight is agriculture. given to the need to protect that fragile nature of this section of the Regional Park and Green Belt. Opportunities for increased connectivity within the area and consideration for the Colne Valley Regional Park will be addressed in the Proposed Submission Plan.
A specific reference has been subsequently added to the Development Considerations in relation to the Colne Valley Green Infrastructure Strategy. We contest the conclusions in the SEA (pages 14, 244 Noted – the SA/SEA will be reviewed onwards and page 272) that show positive or neutral impacts to support the Proposed Submission and which fail to give due weight to the landscape/ quality of Plan. life/ functionality of the Green Belt and CVRP in this area. The Strategic Landscape and Visual Assessment concludes neutral and slight adverse impacts. This is based on the fact that the site is currently in poor condition and the restoration has not been advanced.
However, if restoration was carried out it would have a positive effect on the landscape character and visual quality.
Planting around the site is also suggested as a mitigation measure. LANDSCAPING DURING SITE USE - in addition to bunds and Planting bunds can be an issue in the planting of native trees on the outskirts of each site, we that they are a temporary feature and would propose the tops of the bunds are densely planted with generally comprise the site topsoil, low (5 feet) growing bushes and shrubs in order to reduce the which is required for site restoration flight of sand during strong winds and reduce the noise travel after it is completed. Whilst they from plant during working hours. Land between the bunds and would look better if planted the boundary fencing must be more densely populated with a mix problems that might arise include of native trees, bushes and wild flowers to preserve and very successful establishment that encourage wildlife, and hide the unsightly weed covered local residents do not want to lose at bunds. This is not the case with the Horton Brook Quarry which the end of the works. Or it might is an eyesore on what is otherwise a country lane linking become an important wildlife habitat Colnbrook with Horton. Such planting of the areas between which is difficult to dismantle. the bunds and boundary fencing could provide nature walks for residents and local school children to offer some compensation Planting outside the bunds may be for the lack of views of open fields, grazing animals and crops. suitable if this was a new site, but it Colnbrook and Horton villages are remnants of farming has been extracted and can only be communities. subject to the existing conditions. These conditions could only be changed if a new planning application is proposed for the site. Landscaping must be greatly improved, as the Horton Brook The original planning application for Quarry is out of keeping with a rural setting in which it exists. this site included restoration to This will enhance the chances of a rapid reintroduction of wild agriculture. life upon the closure of the sites at the end of their life. As extraction on the site appears to be completed the restoration should be taking place on those parts of the site which are not subject to the recycling facility.
Flooding
Issue Response Horton Brook The historic flood map indicates a small part of Noted – the Strategic Flood Risk the site affected in January 2003. Along with the SFRA Assessment will be reviewed referring to 2014 flooding this would be 2 flood events in last including the ‘Flooding history’ RAG 20 years so ‘flooding history’ rating should be red. The site is status. immediately adjacent to a large reservoir. Any works will need to demonstrate that they do not impact on the structural The flooding is reported ‘in the stability of the embankment vicinity’ rather than within the site. However, a change in RAG status is not considered to impact the overall status of medium risk.
Archaeology
Issue Response According to our records there are no designated assets on Noted – the Sustainability this site. The Grade II listed Horton Lodge and the Grade II Appraisal/SEA will be reviewed and listed The Old Rectory are located outside the site to the south- amended. west and the Grade II listed Ashgood Farmhouse is located to the south. These are not noted in Appendix A but we do not The Sustainability Appraisal/SEA has consider it likely that potential waste management been amended to clarify that ‘green’ development would have an unacceptable impact on the refers to positive or neural impact. significance of these designated heritage assets. However, we do not consider that waste management development at this proposed site would actually result in a positive outcome for heritage assets as indicated in the draft SEA.
Monkey Island Wharf
General
Issue Response The site is identified as a draft allocation for housing Noted in the submission version of the Royal Borough of Windsor & Maidenhead (RBWM) Borough Local Plan 2013 – 2033 (Draft Policy HO1 and Site Proforma HA23). The draft allocation of the site as an aggregate wharf in JCEB Minerals and Waste plan would not jeopardise the housing allocation. It is envisaged that the site will be used as a wharf, associated with the Monkey Island Lane Processing site in the short to medium term. The housing allocation is a long-term allocation, which will seek to deliver housing during the latter part of the RBWM Local Plan period, by which time, the use of the site as a wharf will have been completed and the site can come forward to deliver housing as envisaged in the RBWM Local Plan. Any future policy with regards to the allocation of the wharf within the JCEB Minerals and Waste Plan should include suitable wording which makes it clear that the allocation will not be in perpetuity but rather, it will provide a short/ medium term function, before the site is brought forward for housing development as envisaged by the RBWM Local Plan. This is considered to be an efficient and sustainable use of land, delivering benefits associated with its use as a wharf before the site is brought forward to deliver the housing required by the RBWM Local Plan. Poyle Quarry, Poyle Quarry Ext, Water Oakley, Noted Monkey Island Wharf Summerleaze welcome the inclusion of the sites as draft allocations and welcome the acceptance in principle that the sites are suitable for working to commence during the plan period, subject to satisfying detailed planning requirements. The draft allocation for the wharf at Monkey Island Noted Lane will assist in the efficient movement of raised mineral to serve the existing processing site at Monkey Island Lane. We welcome the inclusion of the draft allocation within the plan, which will contribute to addressing the current shortfall and meeting the requirement The joint authorities have established that where Noted potential negative impacts have been identified, these can be mitigated and would be outweighed by the benefits associated with allocating the sites. As a result, the site has been put forward for allocation in the draft plan.
Flooding
Issue Response In the Water Environment and Flood Risk section Noted – the text will be reviewed and this says: amended. Site largely within Flood Zone 2/3 and Groundwater Source Protection Zone (1) – a Flood Risk
Assessment and Hydrological Assessment will be required. This needs to be changed to: Site largely within Flood Zone 2/3 and Groundwater Source Protection Zone (1) – a Flood Risk Assessment and Hydrogeological Risk Assessment will be required
Planners Farm
PLEASE NOTE - Due to fact that the land-use was already established, the decision was taken not to allocate existing waste sites (Planners Farm and Star Works) in the Plan. Any future proposals relating to these sites will be considered against the relevant policies in the Plan.
General
Issue Response The site is in close proximity of 2 existing schools and 3 Protection of amenity is outlined in draft play areas. Overall, there are 3 schools in the area - Policy DM9 (Protecting Public Health, Montessori on Brock Hill, St. Mary's C of E, Winkfield Row Safety and Amenity). and Lambrook, Winkfield Row. All information received regarding the Residents are already having to put up with unpleasant proposed site allocations will be taken odours, noise and increased pollution into consideration in the preparation of The increase in activities will have a detrimental impact on the Proposed Submission plan. the mental health on residents.
The current site poses a health hazard for residents when it generates an unacceptable amount of dust which is blown into nearby houses. Respiratory issues will worsen if activities at the site increase. The stench from Gary Shorts will quadruple with that amount of green rubbish dumped each day. Page 14 of the draft policy promotes the protection of the local community and the well being of those in the Plan areas. However, should any future application associated with this site be permitted, this objective would not be achieved. Object to the site being included due to the unsuitable The site benefits from planning location in a rural area. Waste management facilities should permission for the processing of green be in industrial or brownfield locations so that the impact waste. from HGVs does not ruin small villages and towns. The Consultation documents do not appear to have cross- The Joint Minerals & Waste Plan is referenced or considered proposals that are pending under being prepared alongside the the BFC Draft Local Plan, that will affect its current semi- development of each of the Central & rural status over the next 5-10 years. E.g. several large Eastern Berkshire Authority Local Plans. housing developments, another school to be located along Forest Road in the vicinity of Braziers Lane and the closure of Braziers Lane with a new spine road running through a high-density residential area. The site already has a negative impact on the nearby All information received regarding the existing settlements but any significant increase in traffic proposed site allocations will be taken and activities would be cause unacceptable further damage into consideration in the preparation of to properties and quality of life for residents. In terms of the the Proposed Submission plan increase in emissions (e.g. NO2, CO2), pollution, odours, noise, vibration and house shakes that occur throughout the day. Planting popular trees are not an acceptable solution. The Noted – the Strategic Landscape trees are tall, the leaves off the trees blow into gardens and Assessment outlines alternative need to be cleared to avoid blocking drainage, they do not planting. This will be a matter for the obscure buildings in winter and due to their height, they LPA to address with a detailed don’t obscure the view in summer too now. Trees don’t application reduce noise pollution or dust. The increase in activities at this site will eventually make Flood lighting is a planning flood lighting a necessity, affecting our dark Skies status consideration and would need to be considered by the mineral planning authority as part of any future planning application.
The proposal would be contrary to Policy EN8 of the The Joint Minerals & Waste Plan is Bracknell Forest Borough Local Plan and Policies CS1 and being prepared alongside the CS9 of the Core Strategy Development Plan Document and development of each of the Central & The National Planning Policy Framework. Eastern Berkshire Authority Local Plans.
I would also like you to take into consideration that amount The Joint Minerals & Waste Plan is of new homes that are being proposed for the area. being prepared alongside the Sommerton Farm on Forest Road, 400 homes, Romans on development of each of the Central & the Forest Road, 10 new homes. The potential increase in Eastern Berkshire Authority Local Plans. traffic from these proposed developments will also only add to the problem. There is evidence of residents in this area feeling strongly Noted. All comments received as part of that their opinions and concerns are not being listened to. A the public consultation on the proposed large petition in Wokingham plan are being considered and the Plan https://www.bracknellnews.co.uk/news/16958103.total-lack- will be amended accordingly. of-interest-councillors-slammed-for-not-not-listening-to- shinfield-residents-housing-fears/?ref=mr&lp=8 is focused entirely on this, and in Ascot there is a movement afoot to wrest local politics away from the mainstream political parties. These developments reflect a growing concern that the whole of the planning process is a done deal between politicians and developers (largely, if not wholly driven by money) who have little or no interest in listening to what the residents want. Advice at the event indicated that the proposed ‘biomass’ The Plan is not seeking to specify could be the woodier elements of composting material, and precisely what the site can be allocated the product could be wood chips, although it is not detailed for, as a number of different biomass in the draft plan. If the site is allocated, can the Plan specify technologies could be suitable for the precisely what the site can be allocated for? If not, what site. guarantees do residents have? Guarantees for protecting resident amenity stem from the Development Management (DM) policies, which seek to control the impacts of development. Given the proximity of the site to the settlement of Brockhill, The Plan specifies development heritage and conservation areas, and environmentally considerations for each of the sites. sensitive sites, can the Plan specify criteria that a planning application would need to meet before consideration, e.g. Additionally, the Development including a full assessment that demonstrates beyond Management (DM) policies seek to reasonable doubt that there are: i. No adverse social and control the impacts of development and environmental impact on Brockhill (e.g. noise/vibration, any proposed development will be smell, air pollution/emissions from processing, as well as considered in light of all the policies in HGV movements). ii. No adverse environmental impact on the Plan. the conservation areas and other built heritage, and environmentally sensitive sites including The Cut, All information received regarding the Chawridge Bourne SSSI, European sites (notably Windsor proposed site allocations will be taken Forest and Great Park SAC and Thames Basin Heaths into consideration in the preparation of SPA), and locally important sites. (Potential problems are the Proposed Submission Plan. listed in the Waste Proposals Study, p.39 on, with a few exceptions, e.g. invasive alien species, and N deposition on the SAC and SPA.) Polluting emissions from a large industrial site and numerous HGVs would be a health risk for all residents - especially children and the elderly or anyone with an existing respiratory condition. Air pollution is the biggest environmental health risk and contributes to 40,000 deaths each year in the UK. Children are more at risk because their young lungs are more permeable. The silent death toll from poisoned air is not acceptable. The UK government is already in breach of EU air quality limits and has warned 5 Councils outside of London that they have failed to meet
the deadline for dealing with air pollution. We must not let Bracknell join them The only people who will benefit from this proposal are Noted BFC, Gary Short and the people who live outside our area when all their green waste is sent to us. Roads - the T junction off Cricketers Lane with Brock Hill is All information received regarding the on a winding narrow road, with a blind corner, which is often proposed site allocations will be taken flooded and is icy in frosty weather. into consideration in the preparation of the Proposed Submission plan The existing site at Planners Farm would not be able to Noted. The site is currently proposed in handle 50,000 to 75,000 tonnes extra waste without some the draft plan. development, however, there has been no planning application to support this, as yet. All information received regarding the proposed site allocations will be taken into consideration in the preparation of the Proposed Submission plan. There would also be a need for a planning application to be submitted. Concerns about the potential pollution risks of uncontrolled Noted. All information received waste substances coming from far and wide with no audit regarding the proposed site allocations process in place. Contamination and health risks have not will be taken into consideration in the been adequately addressed in the past with such preparation of the Proposed Submission proposals. A clear statement of control and intent needs to plan. be provided in order to reassure local people If a site uses, recycles, treats or disposes of waste, it is likely to require an Environmental Permit from the Environment Agency. The permit is to ensure that the activity does not cause pollution, increase flood risk or affect land drainage. This regulatory system is separate but complimentary to the planning system. There has been no communication from the council or the This consultation was the first planners on this proposed site. opportunity to test the draft plan and policies. The information received as part of the consultation will help to form the next stage of the planning process as well as the overall plan. What are the financial aspects related to this project e.g. The financial aspects of proposed sites where is the funding coming from; where are the benefits are the responsibility of the site owner accruing and with whom? What is the local government and/or site operator. viewpoint on this? There are also wider benefits to ensuring that there are sufficient waste facilities to manage the waste we produce including: meeting legal and policy obligations, reducing the distance waste travels and ensuring waste is recovered or recycled rather than landfilled.
Concerned about the increase in tonnage of material Most changes to the use of a waste site handled. Concerned that the licence will be increased to are subject to planning permission and handle significantly more tonnage than currently authorised. so will be consulted on as part of a Recommendation - Assurance that there will be no increase planning application. to the current licence conditions regarding tonnage handled without a full public consultation. Changes to the environmental permit are handled by the Environment Agency, following their procedures. Possible Waste Transfer Operations. Concerned that going Most changes to the use of a waste site forward waste transfer operations will take place on this are subject to planning permission and
site. Recommendation - Any future change to the operation so will be consulted on as part of a at Planners Farm should take full account of the local planning application. community’s concerns. We are nearly all elderly on the High Pines and some need The Development Management (DM) carers, so their access will be limited. To gain access to policies seek to control the impacts of Parkers Lane could become very difficult development and any proposed Inadequate local infrastructure development will be considered in light Existing schools and play areas - The proposed routes pass of all the policies in the Plan. two existing schools - Lambrook and Winkfield St Mary’s and walking routes to school. There are also three All information received regarding the children’s play areas in the vicinity of potential routes. proposed site allocations will be taken Recommendation - Given the rural residential nature of the into consideration in the preparation of area and that children walk to the schools and play areas the Proposed Submission Plan. daily, it would also appear inappropriate to permit increased routing of HGVs along these routes. Site already in breach of planning conditions, with noise on Concerns over the operation of the the site starting as early as 7:00 am, heard by families who existing site should be raised with the lives a quarter of a mile away from the site and regularly Environment Agency. hear vehicle reversing alarms and other noises associated with plant and machinery, including loud occasional thuds. Conditions on existing planning Concern about the increase in odours being omitted from permissions should be monitored and, the site. Currently odours are evident during May and where appropriate, enforced by the September resulting from green wet grass. relevant planning authority Recommendation - Controls to be put in place to control odours. Noise: There are regular complaints about the noise from All information received regarding the this operation which currently breach the planning consent proposed site allocations will be taken 02/00839/FUL, vehicles exit the premises from 05.30 am. into consideration in the preparation of Regulatory controls are not adhered to. the Proposed Submission plan. Smell: This impairs residents enjoyment of their amenities throughout the neighbourhood. It is particularly noticeable during the summer months. Any increase in waste (not yet defined) could add to the existing issue making the situation unbearable for local residents. The increased volume of waste has not been defined - rock and mineral would be completely unacceptable in the confines of this premises. There seems to be potential for the site to develop into a waste transfer station which is completely at odds in this setting Will Planners Farm be used by Shorts as an overflow site Information provided by site for its Ascot waste transfer station in St George’s Lane? representatives decidedly states that it RBWM planning application 18/00945/out refers will not be used as a replacement for the With the closure of Shorts (Gary Short) at Ascot, St Ascot waste transfer station in St Georges Lane, is there intention of also moving the waste George’s lane. skip lorries to Planners Farm? This would mean even more HGV traffic in the area. Planners Farm is situated in a prime rural residential area The transport assessment was prepared having a permit ERP/BP3290LX a composting facility of with a worst-case scenario assumption 25,000 tonnes evidence referred in planning app of 75,000 tonnes of additional 18/00945/out states in 2016 it was underused by 16,900 movements, so the full scale of potential tonnes. Adding the suggested extra capacity under this joint impacts has been considered. waste plan and the site increases to a possible capacity to 50,000-75,000 tonnes [this comment was originally put under responses to Policy DM3. Moved to this document as comments refer specifically to Planners Farm] What are the waste categories for this site? Current The proposal is to increase the capacity descriptions are not clearly defined - to the ordinary person of the existing site and therefore, would there is not enough detail and information for them to make continue to receive green (garden) a considered assessment. More detail required. waste.
Bio-mass fuel and any safety issues that may be The proposal does not include the associated. Does this involve food waste? More detail receipt of food waste. required. Overdevelopment in the Green Belt. Waste management sites are included in the Plan as it is considered there are ‘very exceptional circumstances’ due to the lack of available sites within the Plan area
Transport
Issue Response Planners Farm is not a suitable location due to the The proposed route will retain the adjoining roads/preferred routes being already principle of avoiding Winkfield Row. It overloaded and causing issues. E.g. junctions of Locks will be revised in the Proposed Ride/Forest Road, Oaktree Garden Centre, The Stirrups Submission Plan to avoid Braziers Hotel, The B3022 and A330 at Maidens Green and Lane and to route via corridors that others in the area are heavily congested at peak have been designed to support HGVs periods. The Locks Ride/Forest Road junction is including A330/A332 corridor. The inaccessible for large vehicles turning right onto Locks proposals are for waste operations Ride ever since the council installed a safety island at similar to those already in place at this the junction - the net result is that large lorries that do try site and therefore whilst we do not to turn right onto Locks Ride often drive on the wrong have details of existing traffic and side of the road at that junction just to get around routing, it is not expected that future without hitting the island. These issues would increase if movements would differ in terms of the site activities increase. size and numbers of vehicles. The proposals at this stage would require up to 25 HGVs per day which is not considered significant. This assessment provides a worst-case assessment whereby no allowance has been made for the existing HGV traffic from existing operations at this site. In any event, planning approval for future use of this site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Working hours should be conditioned in any planning permission. The site would require a Transport Assessment or Statement in which safety issues will be assessed, and mitigation proposed as required. Most of the roads near to the site are relatively narrow Noted. Routing via Braziers Lane will country lanes and go through `pinch-points' or are be replaced in the Proposed restricted to one way traffic by parked cars – particularly Submission Plan. A routeing strategy in Brockhill: would be required at Planning. A route to the north is preferred and could be • The T junction of Cricketers Lane with Brock Hill either along the A330/Forest Road is on a winding narrow road with a blind corner corridor or by remaining on the which is often flooded and is icy in cold weather. A330/A332 corridor until it reaches the • The T junction at Brock Hill with Winkfield Row A329 in the south. The site would has a sharp curve and large vehicles often require a Transport Assessment or straddle the road. Statement in which safety issues will • The 4 way junction from Maidens Green onto be assessed, and mitigation proposed Church Road is a notoriously hazardous one as required. having a blind corner just before the junction.
• The Chavey Down Road is narrow • Braziers Lane is already signposted as not suitable for HGVs. The draft BFC Local Plan proposes closure of Braziers Lane anyway, to be replaced by a new road through a residential area - also completely unsuitable to route HGVs through The routes you have highlighted are not suitable for Forest Road is an A road. HGV traffic or (as stated in your own draft) the route via Working hours should be conditioned Lambrook School is highly sensitive and passes within in any planning permission. close distance of two junior schools. One of these The site would require a Transport school has regular foot traffic with children as young as Assessment or Statement in which four years old. Braziers Lane is not suitable for HGV safety issues will be assessed, and traffic. There are inherent difficulties with vehicles mitigation proposed as required. passing each other, particularly at the entrance of Forest Rd, where the road narrows. The junction of Braziers Lane and Forest Road is an accident hotspot and has the highest record of accidents within Winkfield. The Strategic Transport Assessment that you have submitted does not acknowledge concerns relating to access or routing, in fact it indicates a less than thorough assessment. If the same methodology has been used throughout, then the assessment of the site is open to debate The proposed vehicle routing compromises two The proposals are for waste operations conservation areas, Winkfield Row and Winkfield similar to those already in place at this Village. The arrangement would be far better placed site and therefore whilst we do not near an existing Highway structure in an Industrialised have details of existing traffic and area, rather than in an area surrounded by residential routeing, it is not expected that future homes, green belt land and structures of historic movements would differ in terms of interest. The existing Highway structure will not cope, size and numbers of vehicles with roads already crumbling under the weight of traffic. Drivers typically ignore the posted 30mph signs and This is an enforcement issue to be generally expect other oncoming traffic to move over addressed by the highway authority and the police, regardless as to whether or not this site comes forward The junction of the B3022 and A3022 and Maidens The revised proposed route intends for Green crossroads is notorious for the frequency of all vehicles from the site to remain on extremely serious collisions which arise from the the A330 corridor. Planning approval restricted vision of vehicles exiting the B3022, equally, for future use of this site would be several of the other junctions within the vicinity offer very require a Transport Assessment or little vision of oncoming traffic, which can be particularly Statement in which safety routing, air troublesome from residents exiting their driveways. quality and road capacity issues will be assessed in detail, and mitigation Past 5 year road accidents around the proposed routes proposed as required. which have been formally logged are shown as follows, with a further number of incidents yet to be logged: Braziers Lane junction with Forest Road – 8 personal injury accidents Bracknell Road junction with Malt Hill / Hayley Green – 5 injury accidents Lovel Road junction with North Street / Pigeonhouse Lane – 5 personal injury accidents Lovel Road junction with Hatchet Lane - 2 accidents. TOTAL NUMBER OF LOGGED ACCIDENTS 20 (4 a year, one every 3 months at these junctions alone). It is clear the current traffic volume along the local roads is already a dangerous problem. The exit at the junction with Church Road/Pigeonhouse Planning approval for future use of this Lane is quite dangerous due to restricted vision towards site would be require a Transport North Street. Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues
will be assessed in detail, and mitigation proposed as required. The B3022 is a rat run that is heavily used by commuter The proposals at this stage would traffic and has considerable HGV movements of waste require up to 25 HGVs per day (c.50 landfill being dumped at The Royal County of Berkshire movements) which is not considered Polo Club. This road is problematic for HGV's due to the significant. This assessment provides location of Stirrups Hotel on one side of the road and a worse case assessment whereby no Oak Tree Garden Centre on the other, both of which allowance has been made as the attract cars. And further up the road there are private existing HGV traffic from existing dwellings where cars are often parked on the road which operations at this site. In any event, causes problems to passing traffic. In winter there is planning approval for future use of this often flooding on the B3022 between Brock Hill and site would be require a Transport Hayley Green. Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Safety concerns regarding the crossroads where the The proposed operations would be A330 crosses Bracknell Road and Winkfield Lane. broadly similar to existing operations. Despite it being a very busy junction, used by Planning approval for future use of this pedestrians, motorists and horse riders, there are no site would be require a Transport traffic control measures in place. Assessment or Statement in which Requested a change to Policy DM9 - that there be no safety, routing, air quality, hours of further additional work or services at Planner's Farm and operation, and road capacity issues therefore no increase in HGV traffic in the Maiden's will be assessed in detail, and Green Area. mitigation proposed as required. The Requested a change to Policy DM11 - that there be no aim of the Transport Assessment or additional HGV visits to the Planner's Lane site. Statement will be to establish any net additional impact of the proposals.
Braziers lane is unsuitable for HGV’s to avoid Winkfield The revised proposed route intends for Row. It is not practical given the restricted width of this all vehicles from the site to remain on carriageway, with barely enough room for two cars to the A330 corridor. Planning approval pass let alone an HGV. Cars and lorries sometimes for future use of this site would be have to back up to allow oncoming traffic including require a Transport Assessment or lorries and buses to pass in the opposite direction. Statement in which safety routing, air There is also poor vision on several of its bends. quality and road capacity issues will be assessed in detail, and mitigation proposed as required. The existing speed cushions have proved to be totally Planning approval for future use of this ineffective against HGV’s, the axle width allowing the site would be require a Transport wheels to easily passing either side. Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Some large HGVs / trucks regularly hit the speed bumps If required by the planning authority, an causing serious vibration to their homes environmental statement or other relevant reports would address any issues of noise, vibration and air quality HGV’s are powered by large volume diesel engines, Planning approval for future use of this there would be a significant increase in the diesel site would be require a Transport particulates emitted in to the local atmosphere. The Assessment or Statement in which harmful effects of this pollution on human and safety, routing, air quality, hours of particularly young people’s health have been extensively operation, and road capacity issues documented. will be assessed in detail, and mitigation proposed as required. There are two primary/junior schools in Winkfield Row Planning approval for future use of this which consequently results in heavy traffic at key site would be require a Transport periods in the day, a situation made potentially more Assessment or Statement in which safety, routing, air quality, hours of
dangerous with the addition of a significant number of operation, and road capacity issues HGVs. will be assessed in detail, and mitigation proposed as required. Previous attempts at creating 'traffic calming' measures Planning approval for future use of this have been halted at the behest of 'Shorts' and Planners site would be require a Transport farm, due to the 'agreement' in place with the council to Assessment or Statement in which ensure 'Shorts' vehicles can safely return to the farm safety, routing, air quality, hours of and not be impeded by lane width restrictions, due the operation, and road capacity issues extensive size of some of the vehicles entering and will be assessed in detail, and leaving the premises. Now the idea/consultation is to not mitigation proposed as required. only 'forget/leave/fall back' on calming measures BUT introduce even MORE HGV traffic along the Bracknell Road' - a road that has still not had its 'Drain covers' repaired, (which when 'run over' by HGV, causes the homes to shake and do unknown damage to the properties - Continuation of failure to respond to this repair will require further investigation and any detrimental effect on the property will be then the fault of the governing parties responsible and compensation will be sought). The Council and its representatives should 'fix existing issues before trying to add any further issues which the expansion would bring The Lane strains to meet compliance with The Traffic Assume Braziers “Lane” – proposed Management Act (2004). route will be amended in Proposed Submission Plan The site is not in close proximity to the strategic road The STA considers suitability of sites networks in relation to their proximity to the SRN as a guiding principle but does not require these to be located on the SRN corridor. In this case, the proposed operations are unlikely to require access to the SRN and are likely to be more local. Notwithstanding, any appropriate routeing strategy will require HGVs to use appropriate networks i.e. Primary Road Network (A roads and some B roads) The plan details the intention that proposed sites should Any departures from plan policies will be located on major roads. Planners Farm is not. need to be considered at the planning approval stage. The road surface on B3022 has been damaged by the Damage to highways will be addressed current HGV traffic, as well as considerable damage to as part of the Highway Authority’s the roads and overhead electricity cables. The road has ongoing maintenance programme. not been designed or constructed to take the current volume of traffic. Church Lane has suffered 2 breaks to the Gas mains and 1 to the Water Mains in the past year alone due to HGV movements I notice that times of day are not mentioned within 98 The proposals at this stage would daily trips some of which must be after dark. require up to 25 HGVs per day (c.50 Closer to the site, immediately to its north when exiting, movements) which is not considered is a sensitive 30 mph limit with former farm cottages significant. The majority of movements either side. The road is blinded by parked cars and used are likely to be outside of peak hours, by families’ children when leaving / arriving home. It is hours of operation would be agreed already a concern to all residents in the neighbourhood. during the planning process. It is Large lorries / HGV’s will only add to these concerns. expected that traffic during peak hours There is already a need for traffic control would be restricted. implementation. If the site is to process 75,000 tonnes per year, based The proposals at this stage would on an eight-hour day this would mean HGV journeys to require up to 25 HGVs per day (c.50 and from the site every 4.7 minutes through Maidens movements) which is not considered Green village to the cross roads at Bracknell Road. This significant. is a dangerous junction with a number of recorded
accidents and fatalities. Additionally, with these extra road movements, the roads would quickly fall into a state of disrepair, thus causing further hazards for the road users. Local residents feel that they have no control over the Approval of this site will be subject to ever increasing volume and speed of traffic in the area. planning through which residents will be consulted. Because of the poor road surface and the dropped man Damage to highways will be addressed hole covers, HGV’s making crashing noises as they go as part of the Highway Authority’s over them, which make the local houses shake. ongoing maintenance programme. The proposed route will retain the principal of avoiding Winkfield Row. It will be revised in Proposed Submission Plan to avoid Braziers Lane and to route via corridors that have been designed to support HGVs including A330/A332 corridor. The HGV traffic using these roads currently is already Planning approval for future use of this causing structural damage to the properties south of the site would be require a Transport hump backed bridge on Winkfield Row, mainly due to Assessment or Statement in which the heavy lorries passing Lambrook school hitting the safety, routing, air quality, hours of speed bumps too fast. Add more lorries and you will operation, and road capacity issues exacerbate the problems. will be assessed in detail, and mitigation proposed as required. That information would be used to consider the To clarify, no relevant traffic studies proposal. I understand there have been many traffic flow were available for the area. The STA studies since I have lived from 2007. Furthermore, the provides a worse case assessment fact that there is often a police traffic car here checking whereby no allowance has been made for speeding indicates that the highways are aware that as the existing HGV traffic from a lot of traffic is generated on this stretch of road and existing operations at this site. that it exceeds the speed limit of 30 miles. 2. The This is an enforcement issue to be safety aspect of increased traffic along this stretch of B addressed by the highway authority road. Reading the review, it is clear that HGVs have no and the police, regardless as to alternative but to use B roads here as this a relatively whether or not this site comes forward. rural area. The road shakes when existing amounts of If required by the planning authority, an heavy traffic go by. Planners farm may have access and environmental statement or other clear visibility onto the 3022 but does not uphold the relevant reports would address any speed limit often. The conclusion that s the issues of noise, vibration and air inconvenience is minor ie less than 1% for the SRN may quality be the case but that is not the case for LRN which is the Damage to highways will be addressed one that is most directly affected. An increase of 98 trips as part of the Highway Authority’s a day is unacceptable and unsafe. The road is extremely ongoing maintenance programme. busy now. 3. The routes Explored. Braziers lane is The proposed route will retain the extremely narrow and has a restricted junction with principal of avoiding Winkfield Row. It Locks Ride and the Forest Road crossroads and this will be revised in Proposed Submission itself is a minor C class road an unsuitable for HGV Plan to avoid Braziers Lane and to along most of its length. In conclusion then my route via corridors that have been concerns are that the due diligence required to create designed to support HGVs including the review of Planners Farm did not happen re traffic A330/A332 corridor. information and its impact, the impact on safety on the The proposals at this stage would local roads, and the alternative routes offered. I would require up to 25 HGVs per day (c.50 like to know what traffic studies will be undertaken as in movements) which is not considered the document it clearly states that “Minerals and waste significant development should be expected to include a Transport Assessment or Statement of potential impacts on highway safety, congestion and demand management “ In the Strategic Transport and Planning Assessment it These documents were not provided states there is no Traffic model for the 4 counties “4.6 for consideration Therefore, a high level study has been undertaken to establish the suitability of each site in terms of transport”. The document clearly states that information has been provided by site promoters and where no
information has been provided, the impact of development has been considered based on the nature of the existing highway network. This does not the tally with the next comment highlighted here - Likely Traffic Flows and Site Operations - No information regarding existing levels of traffic from the site is available at this stage and therefore has been excluded from the assessment of net additional movements. I would like an explanation then of the contradiction here as I understand there have been many traffic flow studies since 2007 conducted by BFC. The Transport Assessment Document (TAD) is incomplete without considering the exiting traffic usage caused by Planners Farm or the existing traffic flow and congestion periods The Strategic Transport and Traffic Assessment dated The proposed route will retain the March 2018 appears to indicate the following on principal of avoiding Winkfield Row. It Planners Farm: will be revised in Proposed Submission "No immediate identified concerns relating to access or Plan to avoid Braziers Lane and to routing" in addition the document states: "Suggested route via corridors that have been routing aside from using the existing access road to designed to support HGVs including Planner’s Farm, waste traffic could travel north through A330/A332 corridor. Maiden’s Green, or south through Winkfield Row to Planning approval for future use of this connect with the B3017 which then leads on to the A329 site would be require a Transport east of Bracknell through North Ascot. Both are similar Assessment or Statement in which in terms of distance (3.3-3.6 miles) but the route south safety, routing, air quality, hours of would potentially affect the sensitive receptor of operation, and road capacity issues Lambrook School (high) and therefore the preferred will be assessed in detail, and routing would be north and then along Braziers Lane. mitigation proposed as required. Both routes avoid routing through major urban areas. " • Disagree with the above statements as there are immediate concerns that relate to access and routing. I would like to know what traffic studies will be Planning approval for future use of this undertaken as in the document it clearly states that site would be require a Transport “Minerals and waste development should be expected to Assessment or Statement in which include a Transport Assessment or Statement of safety, routing, air quality, hours of potential impacts on highway safety, congestion and operation, and road capacity issues demand management “ will be assessed in detail, and mitigation proposed as required. The conclusion that the inconvenience is minor ie less The proposals at this stage would than 1% for the SRN may be the case but that is not the require up to 25 HGVs per day (c.50 case for LRN which is the one that is most directly movements) which is not considered affected. An increase of 98 trips a day is unacceptable significant. Impacts on the local road and unsafe. network would be addressed through a Transport Assessment or Statement, and mitigation proposed as required. The Transport Assessment Document is vague and Noted difficult to understand The Transport Assessment Document states that the The proposed route will be revised in proposed route – via Maidens Green, avoiding the Proposed Submission Plan to route via Lambrook ‘sensitive receptor’ avoids urban areas – corridors that have been designed to again incorrect due to the amount or building in the area support HGVs including A330/A332 the urbanisation of the northern area of the BFC area corridor. has increased. If required by the planning authority, an environmental statement or other relevant reports would address impacts on Sensitive Receptors, alongside a Transport Assessment or Statement Proposed routing seems to have been done from an OS Route inspection was carried out. map, not through route inspection However, the routeing strategy will be
revised as part of the Proposed Submission Plan The existing speed bumps (in Winkfield Row) do not This is an enforcement issue to be slow down the traffic (both cars and lorries). addressed by the highway authority and the police, regardless as to whether or not this site comes forward The location of Planners Farm means that access is The proposed route is not via Winkfield through small villages, through conservation areas and Row, the routeing strategy will be alongside narrow footpaths (some of which are school revised as part of the Proposed walking routes and recreational areas), none of which Submission Plan are suitable for use by HGVs. There is also a bridge which is unlikely to be able to cope with this level of HGV usage. The TAD also states that the road surface of the Damage to highways will be addressed northern route is in good order – it is not, and its as part of the Highway Authority’s deterioration rate has increased since the recent ongoing maintenance programme. increased use by fully load 35-Ton HGVs removing aggregates from the Berkshire Polo fields, also building work around the Binfield/Blue Mountain areas. The road (which has no pedestrian pavement) is also The proposed route will retain the shared with pedestrians and dog walkers as 2 public principal of avoiding Winkfield Row. It footpaths exit onto the road a few hundred metres apart, will be revised in Proposed Submission resulting in a dangerous area to work with just regular Plan to avoid Braziers Lane and to traffic. In addition, the BFC Draft Local Plan has pending route via corridors that have been proposals for a school to be located near Braziers Lane designed to support HGVs including and for Braziers Lane to be replaced with a road running A330/A332 corridor. through a high density residential area. There would Planning approval for future use of this also be additional traffic and associated issues site would be require a Transport generated by a proposed new development in North Assessment or Statement in which Bracknell committed developments, safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required.
The draft Plan preferred HGV routes are flawed, The STA is a high-level assessment. possibly (as acknowledged at the event) because they Planning approval for future use of this are the output of a largely desk job. site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Route inspection was carried out. However, the routeing strategy will be revised as part of the Proposed Submission Plan to avoid Braziers Lane The Transport Assessment Document regarding The purpose of the STA is to assess Planners Farm has intentionally been left incomplete or the principals of the suitability of the vague to enable a favourable perception of the low site, any planning approval for future impact and minimal environmental damage that this site use of this site would be require a would have on the surrounding human population and Transport Assessment or Statement in animal life which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Should it be decided to go ahead with this site using a Approval of this site will be subject to ‘so far unidentified route‘, would residents be consulted? planning through which residents will be consulted The Forest Road / Chavey Down Road is dangerous The proposed route will retain the and does not lend itself to further heavy goods vehicle principal of avoiding Winkfield Row. It
traffic as it is frequently used by families with small will be revised in Proposed Submission children accessing Winkfield St. Marys school and the Plan to avoid Braziers Lane and to recreation ground. Winkfield Row should be bypassed route via corridors that have been and / or weight limits should be imposed due to the designed to support HGVs including sensitive nature of this area. It is too narrow, and the A330/A332 corridor. roads are dangerous as a result. The traffic increase would be far greater than 1%. The The STA considers the percentage new home development at Warfield Street has already impact of the site on the SRN as a increased the traffic considerably and with the additional guiding principal. The proposals at this 49 two-way HGV movements the Bracknell Road will stage would require up to 25 HGVs per become gridlocked from the junction at Church Road day (c.50 movements) which is not back to Planners Farm. considered significant. This assessment provides a worse case assessment whereby no allowance has been made as the existing HGV traffic from existing operations at this site. Impacts on the local road network would be addressed through a Transport Assessment or Statement, and mitigation proposed as required. Sensitive receptors would not be medium but high due The proposed route will retain the to the intersection of Braziers Lane and Church Lane. principal of avoiding Winkfield Row. It This junction is very dangerous. Furthermore, at the will be revised in Proposed Submission cross roads of Church Road and Bracknell road, there Plan to avoid Braziers Lane and to have been many accidents, with some fatalities. This route via corridors that have been junction is extremely dangerous. designed to support HGVs including A330/A332 corridor. Planning approval for future use of this site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required.
Maidens Green residents, the hotel and also the High Impacts on the local road network Pines would be affected by the proposed route would be addressed through a Transport Assessment or Statement, and mitigation proposed as required. The proposed development planned for the rear of the Planning approval for future use of this Cricketer’s Pub will only add to the high volumes of site would be require a Transport traffic that exist along the B3022. The road is also Assessment or Statement in which heavily used by large agricultural vehicles too. safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. There are several dangerous crossroads and T junctions Planning approval for future use of this with impaired sight lines. site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Damages to verges are common Noted HGVs speed up and down the road to the site from Planning approval for future use of this 05:00 hrs site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. Any existing issues relating to speed of
vehicles are enforcement issues to be addressed by the highway authority and the police, regardless as to whether or not this site comes forward There are plans for another school to be built in the Committed developments would be a area, which again would exacerbate existing issues with consideration of any detailed roads in Winkfield. assessments as part of the Transport Assessment/Statement at Planning, and additional mitigation proposed as required Braziers Lane is to all intents and purposes a national The proposed route will retain the speed limit single-lane track. While it is technically has principal of avoiding Winkfield Row. It two-way traffic, it is extremely tight and dangerous for will be revised in Proposed Submission car users. HGVs would be a seriously unsafe addition. Plan to avoid Braziers Lane and to route via corridors that have been designed to support HGVs including A330/A332 corridor. Increased HGV vehicle movements and resulting noise If required by the planning authority, an and pollution particularly to nearby schools. Detail - environmental statement or other Planners Farm sits within a residential area adjacent to relevant reports would address any a conservation area. Local residents in Brockhill and issues of noise, vibration and air Winkfield Row already suffer with increased vehicle quality. movements on the immediate roads which cause disruption and disturbance from early morning. There are speed humps on the B3017 and when HGV Planning approval for future use of this pass over these they create a lot of noise and cause site would be require a Transport vibration to the adjacent properties. Recommendation - Assessment or Statement in which Routing of the HGV vehicles to cause the least safety, routing, air quality, hours of disruption to the local area. operation, and road capacity issues will be assessed in detail, and mitigation proposed as required. The B3017, Winkfield Row, and Braziers Lane is an The Proposed Submission Plan will inappropriate route – in Winkfield Row there are speed amend the proposed vehicle route to humps and 20mph speed restrictions applying as there avoid Braziers Lane. are two schools in close proximity, and Braziers Lane is an accident black spot at its junction with Forest Road. The road signage at the entrance to Braziers Lane states ‘Unsuitable for HGVs’. The B3022 Bracknell Road northbound to Maiden’s Green is also an inappropriate route due to the narrow road and on-street parking of cars at Brockhill. The road network system immediately surrounding the The proposals at this stage would Farm is less than ideal to support this business. The require up to 25 HGVs per day (c.50 area is considered at least semi-rural if not rural and the movements) which is not considered roads were not built to take heavy traffic and HGV significant. This assessment provides vehicles. The area has numerous dangerous T-junctions a worse case assessment whereby no and crossroads with impaired sightlines. A new road allowance has been made as the should be built to take the traffic from the Planners Farm existing HGV traffic from existing junction with Bracknell Road which would better serve operations at this site. Planning the problems currently experienced from the HGV approval for future use of this site vehicles plus take the additional traffic resulting from the would be require a Transport advent of Crossrail and indeed the substantial additional Assessment or Statement in which developments across the area. Any new road needs to safety, routing, air quality, hours of be planned to link up with the NDR to facilitate traffic operation, and road capacity issues bypassing the unsuitable Winkfield through roads will be assessed in detail, and mitigation proposed as required.
Safety of residents e.g. Locks Ride has a very narrow Planning approval for future use of this footpath which is used by pedestrians, cyclists and site would be require a Transport horses, as well as children accessing Locks Ride Assessment or Statement in which Recreation Ground. There are many young families who safety, routing, air quality, hours of live in the area and there is also a sizeable elderly operation, and road capacity issues
population. Residents feel unsafe whilst walking children will be assessed in detail, and to nearby schools, due to the high speed of cars, vans mitigation proposed as required. and HGVs, some having to mount the pavements to pass one another as they are too wide for the local roads. The Conservation Area Appraisal for Winkfield Row The proposed route will retain the states it is desirable to protect and enhance the area but principal of avoiding Winkfield Row. It this is in conflict with the proposed increased routing of will be revised in Proposed Submission HGV’s. It will affect the special architectural/historical Plan to avoid Braziers Lane and to character of both conservation areas that are near the route via corridors that have been site (Winkfield Row and Winkfield Village). designed to support HGVs including A330/A332 corridor. If required by the planning authority, an environmental statement or other relevant reports would address any issues of noise, vibration and air quality There are two conservation areas located on the The proposed route will retain the possible routes – Winkfield Row and Winkfield Village. principal of avoiding Winkfield Row. It Recommendation - The Conservation Area Appraisal for will be revised in Proposed Submission Winkfield Row describes its special architectural / Plan to avoid Braziers Lane and to historic interest and states that the character and route via corridors that have been appearance is desirable to preserve and enhance. It designed to support HGVs including would therefore seem inappropriate to permit increased A330/A332 corridor. routing of HGVs through Winkfield Row.
Ecology
Issue Response Chawbridge Bourne Site of special interest as well as Any new proposal would need to local wildlife at Stirrups not considered. comply with DM3 (Protection of The wildlife will suffer, there is a SSSI nearby Habitats and Species). The site is inappropriate since it is adjacent to a SANG Further development of Planners Farm would potentially All information received regarding the endanger the SSSI of Chawridge Bourne in addition to proposed site allocations will be taken the local wildlife sites nearby into consideration in the preparation of the Proposed Submission Plan. Habitats Regulations Assessment, Windsor Forest & Noted. These issues will be given Great Park SAC – the context, Planners Farm – planned further consideration, particularly in increased composting + biofuel processing using garden light of the Sweetman case. waste transported by HGV. Up 75,000 t/year. A major external threat to Windsor Forest and Great Park SAC is invasive alien species (IAS). Noting that IAS are addressed in the HRA with the conclusion that “all European and Ramsar sites included … are at risk … However effective management of … sites should minimise the risk of spread”: i. Does the acknowledgement that management of risk is necessary imply mitigation sensu Sweetman? ii. Regarding reference to “site management”, transport is acknowledged as a significant pathway for IAS spread. HGV traffic carrying plant material destined for Planners Farm on roads through or near the SAC could pose a real risk which does not seem to be included in the site assessment. Should it be? Japanese knotweed (JK). HRA paragraph 3.15: “The spread of invasive species is an issue particularly associated with mineral extraction but could also result from compost waste sites where garden waste is being processed. Wetland sites will be particularly vulnerable
to the spread of invasive aquatic and terrestrial plants, such as Japanese knotweed.” i. Surely JK should not be processed as compostable material? See www.gov.uk/guidance/prevent- japanese-knotweed-from-spreading ii. ii. This seems the only mention of JK in documentation. Could you clarify how you will deal with garden waste in relation to this invasive weed? Does the JWMP need a policy/text for management of JK & also potentially JK-contaminated material? iii. iii. JK contamination seems to have been missed as a constraint for Planners Farm. Can it be addressed as potentially serious for The Cut watercourse & nearby residences. 3. The HRA. a. Consistency query. The HRA refers to a 5-km distance in paragraph 3.10. The Waste Proposals Study p.40, says for Planners Farm: “European designations: None within 2km of the site”. This seems an error, perhaps generic? b. ‘Wealden’ judgment (EWHC 351), paragraph 4: “the north-eastern boundary of [Lewes District Council] is approximately 5-6 km from the nearest point on the south-eastern boundary of the [Ashdown Forest] SAC.” The relevant Lewes proposed sites and stretch of the A26 are some km more distant (west and east) than this. The potential impact was N deposition. The number of additional daily vehicle journeys within 200 m of the Ashdown Forest SAC was the issue, not the distance from proposed development. There is more on this in the judgment. c. HGV movements: Some sites are screened out in the JWMP HRA partly on basis of distance from SPA, SAC or Ramsar sites. Given the importance of HGV transport to waste/mineral management in the Plan, is the Wealden judgment relevant? E.g. Planners Farm is 3.35 km from Windsor Forest & Great Park SAC and 5.59 km from Thames Basin Heaths SPA – both less than the distance at issue with ‘Wealden’. d. Planners Farm is estimated to generate 98 extra HGV journeys/day (only a proportion near/through the SAC, though HGV journeys are ‘weighted’ for daily traffic estimates). N deposition is a threat to the SPA and SAC. The HRA says of potential traffic-related pollution on the SAC, “As the site is 3.35km from the European site, the hazard is considered to have negligible potential to cause a likely significant effect.” Is this sound? e. In-combination effects. A (small) potential for in- combination effects was ‘flagged’ in the HRA for RBWM BLP (near the A332/B383 roundabout). It specified potential impact in relation to the BFC BFLP, presumably relevant for any Plan generating relevant traffic. i. Should the RBWM BLP HRA ‘flag’ be dealt with in the JWMP HRA? ii. Is it sound to screen out sites without summing impact of (notably) BFC’s and other LPAs’ plans/projects? iii. As the RBWM BLP HRA in- combination assessment does include some other LPAs, would it be helpful to use this information in the JWMP HRA? f. Threats: Could threats to European and Ramsar sites (e.g. for SACs and SPAs, as listed in JNCC documentation) be included in the JWMP HRA,
particularly major external ones? This would ensure they are not missed in assessment.
Landscape
Issue Response Responding to the consultation is hampered by lack of The Plan can only set out mitigation detail in the Plan. The proposal concerns a site on the principles. edge of Brockhill (Green Belt settlement) although documentation indicates that this type of waste At this stage there are no details, and management is “not normally appropriate … close to the applicant would need to deal with villages” these in an Environmental Assessment The site is in relevant proximity to an SSSI, European which would form part of an sites, and various locally important undesignated sites application. It is up to the applicant to (LWS, etc.). It seems unreasonable to allocate until and ensure that no harm will occur. unless adverse social and environmental impacts on these have been ruled out. For the European sites it may be a regulatory issue.
Flooding
Issue Response Flooding is commonplace and problematic, when large Policy DM10 (Water Environment and vehicles accessing the site make the situation worse by Flood Risk) seeks to prevent an the displacement of flood water from the road into increase in flood risk or impacts on the properties. The current flooding issues need to be totally water environment. resolved before any consideration is given to increase HGV volume. All information received regarding the Rainwater from both the local houses and the road is proposed site allocations will be taken drained using natural 'soakaways'. The substantial into consideration in the preparation of increase in HGV traffic causing vibration and general the Proposed Submission plan. damage to the road would potentially reduce the effectiveness of the 'soakaways' and cause an increase in flooding issues. Planners Farm - There is no mention of River Cut and its It is recognised that river corridors and corridor in water environment section. This needs to be watercourses need to be addressed in added to the text. more detail in the Proposed Submission Plan In the Water Environment and Flood Risk section this Noted – the text will be reviewed and says: amended. Part of site within Groundwater Source Protection Zone (3) – a Hydrological assessment will be required.” This needs to be changed to: “Part of site within Groundwater Source Protection Zone (3) – a Hydrogeological Risk Assessment will be required.”
Archaeology
Issue Response According to our records there are no designated assets Noted – the SA/SEA will be reviewed on or in close proximity to this site. However, we do not and amended. consider that waste management development at this proposed site would actually result in a positive outcome for heritage assets as indicated in the draft SEA.
Poyle Quarry This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out. General Issue Response Support Poyle Quarry site allocation and we Noted. welcome the inclusion of the draft allocation within the plan, which will contribute to addressing the current shortfall and meeting the requirement within the plan area. Poyle Quarry, Poyle Quarry Ext, Water Oakley, Noted. Monkey Island Wharf Summerleaze welcome the inclusion of the sites as draft allocations and welcome the acceptance in principle that the sites are suitable for working to commence during the plan period, subject to satisfying detailed planning requirements. The joint authorities have established that where Noted. potential negative impacts have been identified, these can be mitigated and would be outweighed by the benefits associated with allocating this the site. As a result, the site has been put forward for allocation in the draft plan. INFILL OF ALL SITES [Horton Brook, Poyle Noted. However, Berkyn Manor is not Quarry & Ext and Berkyn Manor] - The Horton proposed as an extraction site but for waste Brook Quarry is obliged to infill with inert waste management. only and this should be a condition of each of the other sites. RESTORATION OF SITES These sites [Horton Site restoration is covered by Draft policy DM8: Brook, Poyle Quarry & Ext and Berkyn Manor] Restoration of Minerals and Waste are, or have been, largely agriculture in nature Developments. Restoration plans will have and should be returned as near as possible to been agreed for permitted applications and will their pre-development condition. Any planting be required for new planning proposals. made in order to preserve some resemblance to a Restoration is a balance of pre-extraction site rural scene should be retained where possible in character and opportunities for enhancement. order to retain and protect the new ecology systems developed during extraction / infill The proposed restoration of Poyle Quarry is to operations. agriculture at original ground levels.
Transport Issue Response Road access to all of the above sites [Horton The associated site forms for Poyle Quarry, brook, Poyle Quarry & Ext and Berkyn Manor] Poyle Quarry Extension and Berkyn Manor must be via a dedicated private road across the consider a number of alternative accesses landowner’s property onto Poyle Road then therefore do not solely rely on the delivery of directly to J15 of the M25. the new road, although this access has now been accepted (by Slough Borough Council as the access is within its boundary) via an approved application to RBWM for this site - Poyle Quarry (17/03426/FULL).
It should be noted that Horton Brook Quarry is under separate ownership.
A planning application for this site has now been approved. A transport statement was submitted by the developer in support of this
application. The highways response from RBWM states that “in highway terms the previous submissions proposed the introduction of a new junction on Poyle Road to be constructed in the form of a roundabout with Mathisen Way. This application seeks permission to construct two vehicular accesses off Poyle Road, negating the need for the roundabout.
These works are to be secured by a Section 278 Agreement between the developer/landowner and Slough Borough Council.” The Council Decision states that “prior to the commencement of development a plan showing full details of the access road and layout of the site shall be submitted to and approved in writing by the Local Planning Authority.”
The Council Decision also includes conditions relating to noise levels and working hours.
Ecology Issue Response Poyle Quarry - There is no mention of the Colne Noted. This will be addressed in the Brook or its river corridor. This needs to be added Proposed Submission Plan. to the text. This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out.
Flooding Issue Response There is no section for Water Environment and Noted – Appendix A Proposed Sites: Poyle Flood Risk under this site allocation. Quarry will be reviewed and amended to This needs to add the following text under Water include the ‘Water Environment and Flood Environment and Flood Risk. Risk’ issues. “Both sites partly within Flood Zones 2 and/or 3 The site is not located within a Source Protection This site was subject to a planning application Zone (SPZ), but the closest SPZ is located to the which was subsequently approved. west of the site approximately under 1km away. A Therefore, the site has been ruled out as an Flood Risk Assessment and Hydrogeological Risk allocation in the Joint Plan and no further Assessment will be required.” assessments have been carried out.
Star Works PLEASE NOTE: Due to fact that the land-use was already established, the decision was taken not to allocate existing waste sites (Planners Farm and Star Works) in the Plan. Any future proposals relating to these sites will be considered against the relevant policies in the Plan.
General
Issue Response Litter and clinical waste from the site have been carried All information received outside of the site, by wind, birds and other pests that have regarding the existing site will be not been controlled. Landfill Waste has been left uncapped, taken into consideration in the whilst clinical waste vessels are stored in the open air around preparation of the Proposed the perimeter of the Star Works site. Submission plan. This is a clear abandonment of the Duty of Care from Wokingham Borough Council and its understanding of the The operation of the existing site Planning History surrounding the site, resulting in the council is an on-going consideration for not being able to effectively enforce or monitor the site. Wokingham Borough Council. Wokingham Borough Council have failed in their 'Duty of Care' to residents. They have failed to: enforce planning breaches; obtain any knowledge of the history of the site; maintain an awareness of existing businesses operating without permissions; retain key documentation relating to extant planning permissions; understand the fundamental principle of ‘Full Restoration of the Landscape’ and protect residents’ health and welfare (clinical waste, litter and needles have been found in residential gardens or along public footpaths) - there are no apparent controls in place to prevent this from happening During their tenure, Grundon have been found guilty of a number of infringements / breaches of their operating licences Permission should not be granted for further operations to take place on site as the premise for extension was only temporary. There have already been several documented pollution incidents surrounding the Knowl Hill site due to its activities. Already an unacceptable risk, further operations or development could endanger the life and health of residents even further. The water table has disappeared and as such 40 trees have died and need to be felled. This has caused ‘songbirds’ to exit the area and only crows remain. It is a matter of record that Star Works activities have created unacceptable environmental impact relating to (a) & (c) of policy DM9 affecting areas including Knowl Hill, Bowsey Hill, and Warren Row Just because something exists in a place is not a good enough reason to keep it and/or extend its use. This assumes that the original decision to grant it and promises made regarding its operation at the time were sound and kept. Just by modifying the area of legislation the new facility falls under does not affect the fact that Wokingham Borough Council have broken a direct promise given to residents, that when the landfill was completed that there would never be any further extensions to landfill in Knowl Hill. Impacts of the site on nearby residents has been raised with the EA. Detailed correspondence including photographs can be found in the paper responses collection tray [should we upload these or not? There is a lot]
This Green Belt site has been the subject of extensive scrutiny in terms of its landfill and waste operation both at Local and Central Government levels which resulted in a definitive conclusion. Therefore, planning conditions relating to the restoration of the site are consistent with the national guidance (NPPW para 7) and should be robustly applied without exception Star Works has had a well-documented impact upon the local environment creating anxiety for a generation of local residents. Site not managed well - it produces litter; there have already been several documented pollution incidents (and prosecutions), pests, noxious smells on several occasions has extended not just in the lane and along the local footpaths but also along the A4 as we approach and leave our home. This causes unacceptable emotional upset and anger. There is also noise, vibration and lights at antisocial hours and these will worsen if the site increases its capacity. The blight on the surrounding villages and their occupants has, to a degree been accepted, based upon the agreement that works would cease in 2021, when a new restored landscape and woodlands would be available for all to enjoy. For this reason many local residents have reduced their complaints about the recent history of noise, odour etc, believing the end was in sight. The landfill – in July 2007 there was a huge landslide of waste from a prepared cell into an unprepared cell. This caused monumental problems for residents as the smell was pretty unbearable. The residents all over Knowl Hill and beyond suffered for months with no windows open – no sitting in the garden – no putting clothes out – no children being able to play out etc. Children were vomiting, people had headaches and, in some cases, more severe ailments. Prevailing winds carry unpleasant odours (they are often acrid and burn the back of your throat), noise and litter and debris, including plastics, across a wide radius of the site amongst others including: Warren Row, Bowsey Hill and Knowl Hill The smells produced from the site make you feel unwell. It is not possible to keep windows open as the site smells then enter your home. Managers of the site have not communicated well with residents with regards to the giving of information and their commitments Wokingham Borough Council and Grundons have broken their promises regularly in terms of time scale, restrictions on smell, dispersal of windblown waste and noise. Also, because the site should be fully restored by 2021. Wokingham Borough Council and the Environment Agency do not appear to have enforced planning conditions and environmental laws (respectively), and so it would appear Grundon has breached a number of these regulations that should have been enforced, regarding the operations at Star Works Star Works is coming to the end of a 20 year “time-limited” development and restoration, as in accordance with Policy DM5 Ancillary operations required to support landfill restoration should be removed following completion of restoration, as stated by the Secretary of State.
Concerns over previous pollution of the woodland and watercourse. Why would that same site be supported as appropriate for a permanent waste facility? The current operations pose a threat to Cayton Park Stud with regard to the health and wellbeing of horses on the estate and the proposals are not appropriate given the implications for animal health and welfare. The maintenance team within the estate as well as vets tending to the animals are gravely concerned regarding the planned extension, as the current operations have already caused damage to a number of horses and foals with a number of these animals found choking on lumps of plastic and other bits of waste which have blown across or been picked up by birds and dropped on the land. The Environment Agency issued Grundon with at least one non-conformity notice in August. It is essential that Grundon take some permanent steps to stop these odour releases. A Borough Councillor for the adjoining Ward met with the MP All information received and the Director of the RBWM and outlined the seriousness regarding the existing site will be of the detrimental issues from this site to residents. A motion taken into consideration in the was put forward to Full Council requesting representatives preparation of the Proposed from the Royal Borough work with Wokingham Borough Submission plan. Council, Grundon, the two Parish Councils, residents and the EA to ensure there is a modicum of closure of the detrimental The operation of the existing site issues (it is noted by the EA that there will always be odour is an on-going consideration for from a landfill) and to ensure all authorities work in the best Wokingham Borough Council. interest of residents relating to this site. This motion was unanimously agreed and regular meetings took place. However, there followed a fire at the Hydroclaves and a new abatement system was put in. There followed many years of pushing for the Hydroclave building to be a double skinned operation after it was decided just to plug the holes in the old brick building with DIY expandable foam. Even after all this work there is still unfortunately more than too often a very strong smell of urine that permeates over the area and this can especially affect the residents in the surrounding area and the walkers on the public footpaths. No resident in the nearby region can plan for entertaining in their garden they can’t sit outside or have windows open. Walkers have mentioned that their walk was not pleasant due to the urine smell. All this has occurred with the belief that an end date was in sight. Any consideration of Star Works for waste management All information received facilities would need to align with paragraph 6.25 of the Plan regarding the existing site will be which states that; “It is important that existing and potential taken into consideration in the waste sites are not hindered by ‘encroachment’ of preparation of the Proposed inappropriate development in close proximity in order that the Submission plan. operational potential of the waste site is not negatively impacted.” 5.12 Star Works operations as a waste The operation of the existing site management facility are clearly hindered by their proximity to is an on-going consideration for residential properties, with a daily high probability of Wokingham Borough Council. conflicting activities which cause detrimental impacts on residential amenity. It is clear therefore that it is not an appropriate site for this activity in the long term and would suffer from significant ‘encroachment’ It is pertinent to note that the Councils state that appropriate locations (paragraph 6.102 of the Plan) which involve open areas, will only be supported if they do not have adverse environmental impacts, and noise and emissions are controlled by effective enclosure and other techniques. Compared against such requirements, it is apparent from the
attached report that measures thus far at Star Works have not been effective. Once the landfill is complete, the site should be vacated. The former factory units should then be repurposed for a non- waste use, where impact on adjacent Residential properties and heritage assets can be minimised. Star Works itself dates back to the 1820s. Grundon bought All information received the site in 1994 – when brick making stopped. However, it is regarding the proposed site now two separate operations. Landfill and a waste to energy allocations will be taken into plant for medical waste. The majority of the site is covered consideration in the preparation we believe by a 1947 planning application. Landfilling started of the Proposed Submission in 1999. No commercial waste has been delivered to this site plan. since April of this year. The site now only imports inert waste (soils and clays) used to restore the site to areas of grassland It is recognised that further and woodland. This will be complete by January 2021. The clarification is required regarding waste to energy plant has a capacity of some 10,000 tonnes the proposed operations within per annum and sorting takes place for an additional 3,000 the allocation. tonnes per annum which is sent elsewhere. All the site is in the Green Belt. It has a complicated planning history which needs to be available so that it can inform the Plan. At the moment much of the planning history is unavailable. The Proposition “Grundon is promoting the permanent industrial area into the updated Waste Plan, to continue its use as an integrated waste management facility. The landfill area is not included in the promotion, as that is already being restored in line with our planning permission.” Grundon we believe is deliberately not seeking to explain what that integrated waste management facility might be or what engineering works or buildings may be required to exercise it. They no doubt feel such an approach provides them with greater flexibility and therefore less protection for local residents. Grundon seeks to argue that it has had historic permissions to do a variety of industrial applications and that those permissions survived the current permissions that it exercises. “It further argues that historic applications resulted in the site currently generating some 90,000 tonnes equivalent of lorry movements per year, which is similar to what which was put forward in our submission to the draft Plan. As such no significant change in lorry numbers from the site and onto the local road network is anticipated. “The 80,000 tonnes Grundon currently claim to have authority for include 70,000 tonnes related to the landfill permission which finishes in 2021. We believe that only 10,000 tonnes survive as permitted. This needs to be clarified within the process. With regard to the proposal that the site could handle 100,000 tonnes of waste on an annual basis, based on the fact that the two sites had handled 80,000 tonnes, is a little incredulous. Only once in the years from 2010 to 2017 was the combined tonnage 80000, and that was 2017 the average tonnage going into the 2 sites in that period was 67100 tonnes. Consequently we are talking about an increase of 32900 tonnes which is a 49% increase. The increase in lorry traffic would be disruptive to both the A4 and to residents. The waste was also going into 2 sites and the landfill site was much further away from human habitation, and this was still disruptive. The new proposal would put 100000 tonnes into a site that at present is dealing with 12000 tonnes and is only a few metres away from houses, and this alone should make any right thinking person doubt the validity of the plan. Have the RBWM policies, in which there is a strong Locational guidance is provided presumption against locating any waste facility/ treatment by the National Planning Policy for Waste (2014) which
plant in or close to residential areas, been considered in supersedes the Berkshire Waste choosing this site? Local Plan policies.
The site is located within the borough of Wokingham. Many residents had expected the waste movements to cease The landfill operation adjacent to within 5 years and this has been communicated to residents the proposed allocation has by Grundons themselves in the recent past. ceased and the site is now being Has the planning history of Grundon’s been considered in restored. choosing this site? The end date is in sight for the landfill BUT the treatment of The waste operations within the waste which should have come to an end with the landfill is proposed allocation have looking to continue. Not just to continue as it is but with the separate permissions which are huge increase from 10,000 tonnes per year to 100,000 not linked to the landfill. tonnes per year. No information has been submitted as to how the waste is to be treated. It is recognised that further The current operator, Grundon's, stated they have had clarification is required regarding insufficient landfill waste to allow them to complete their the proposed operations within restoration works in the permitted time, due to the lack of the allocation. waste and increase in recycling. Wokingham Borough Council has previously committed to residents that when the Canhurst Farm Canhurst Lane, Knowl Hill Berkshire. RG10 9XT - landfill was completed that there would never be any further extensions to landfill in Knowl Hill. Wokingham Borough Council committed to residents that when the landfill was completed that there would not be any further extensions to landfill in Knowl Hill. These proposals break that commitment. The restoration of minerals and waste developments [ref Policy DM8] should reinforce or enhance the character and setting of the local area and should contribute to the delivery of local objectives for biodiversity, landscape character, historic environment or community use. Little or next to no weight has been given to the above in relation to the site allocation of 'Star Works'. Any prior uses of landfill at Star Works should not be classed as existing, because the site is currently going through restoration. The waste management activities at Star Works are intrinsically linked with the restoration of the former quarry / landfill, and should not be seen as a separate entity. Therefore, if Star Works were to be allocated for waste management operations through the Plan period, beyond the completed restoration of the former quarry void / landfill, it would need to be assessed as a new site. Further, given its temporary nature in assisting restoration activities, Star Works as a waste management facility could not be deemed an existing permanent operation and as such should not benefit from safeguarding under draft Policy W2. The Council granted permission for the site to be restored after current planning permission expires (2021), however it’s proposed continued operations contravenes this Introduction, first paragraph, second and third sentences, Noted – the text will be should read: “Lutmans Haven lies to the east of Star Lane reviewed. Works. Existing waste sites should not receive any special protection Due to the lack of waste or be automatically safeguarded from other development as management provision in the this could encourage over landfill use or other waste Plan area it is important to development in one place and puts too much pressure in one maintain the existing capacity area.
The Secretary of State concluded in 1994 “landfilling of waste levels through appropriate is not recognised as appropriate in the Green Belt, in general safeguarding. national policy but is acknowledged in the statutory Development Plan to be, in principle, an acceptable method The landfill at Star Works is of restoring mineral excavation sites.” So restoration of a currently being restored and is Green Belt site, damaged by industrialisation, was the sole therefore, not safeguarded. reason for an existing waste facility being permitted. The granting had clear time limits, which have not been met and also clear details regarding quitting the site and final care, as outlined in Condition 3 of Recommendations 153171 that the committee authorise the grant of planning permission subject to the following - Conditions and Informatives: 'the use of the site as a security compound, skip container store, aggregate store and vehicle park shall cease on completion of the Knowl Hill landfill site - Reason : to restrict the period of operations in the interest of amenity and in accordance with the application' As such safeguarding existing facilities as a whole is flawed. Each site should be assessed on the historic reasoning behind granting of its use as a waste facility and not assume a permanent grant of use. This will have a negative effect on the value of our home and Property value is not a material would imagine that it will also make it difficult if we wanted to consideration in determining move, as who wants to live next to a dump in a rural area. minerals and waste proposals. However, amenity (and other issues) would be addressed by the Development Management (DM) Policies which seek to control impacts. Further extraction of soft sand, with further landfill to follow Noted – it is recognised that cannot be tolerated in this residential area where work must there is an existing permission cease as promised once restoration is complete in 2021. for extraction at the Star Works Planning permission for extraction granted under an Interim site. However, the area of the Development Order in July 1947 (ref.no. 184/87), permission site proposed for safeguarding renewed (ROMP) and subsequently granted in September does not include the extraction 2006 allowing excavation of minerals from 32 hectares of areas and is not being promoted land north of Star Works until 2042. Estimated reserve of for mineral extraction. 1.2m tonnes of minerals (clay and sand) from the site. Confusion over how the soft sand reserves identified at the site would be extracted, given the majority of the existing site has waste deposited on top of it Concern that there further clay extraction at the site will only be taking place in order to provide further landfill ‘space’ Support the inclusion of the site as an allocated site for waste Noted. management infrastructure. Concerns about the lack of consultation during the earlier The Draft Plan consultation was stages of the Plan production, particularly in relation to the first Public consultation residents, those representing residents or local bodies stage. A further opportunity to (Parish Councils). This was confirmed by an FOI request. comment will be available at the The responses provided in the first consultation appear to be ‘Proposed Submission’ stage in inadequate and lack meaningful detail or general 2019. understanding of what was being asked. This is due to the inadequate consultation process and the publicising of the The consultation complied with Waste and Mineral Plan during the early stages of the Plan the Statements of Community making process. Involvement of each of the A lack of formal communication from any of the councils Central & Eastern Berkshire involved in this consultation. I’d like to know what Authorities. communication strategy has been used to advertise this to the residents because I have received nothing via post or email. How can you be sure you’ve properly advertised this consultation to the local residents, a lot of whom are elderly and live in relatively isolated properties if someone
essentially 3 doors down has received nothing as part of the consultation? The consultation was only open for a short time with an end date of 12 October 2018, but in the interests of transparency and proper process, this date should be extended. It is also incumbent on Wokingham BC and Windsor and Maidenhead to provide information which may be relevant to allowing consultees sufficient time to respond in full. In the absence of a planning application which may be years away, publication notes of meetings or correspondence between Grundon or their agents with local councillors and officers may be helpful. Will these be made available? The W2 policy is flawed. It is based upon poor and A number of ‘call for sites’ uninformed selection criteria. By HCCs own admission (at the exercises have been carried out Knowl Hill presentation) that no attempt was made to visit the to encourage minerals and site or engage with local residents; it was purely a theoretical waste operators, landowners, exercise. developers and agents to There was not a good enough investigative approach to nominate suitable sites for finding alternative sites within the boroughs for waste minerals and waste treatment/handling on this scale. development. A review of The selection of an existing facility is perhaps indicative that industrial land has also been research into alternative (and more suitable) sites has not undertaken for suitability for been carried out in full as it should have been. waste management uses. Processing plants for the landfill should be located on brown field sites in pre-existing industrial areas in the Thames Valley Park or Slough Trading Estate. Bringing waste to process before taking it off site again would The site is an existing waste be environmentally detrimental in terms of the carbon management facility and these footprint and vehicle movements. uses will continue in the future. 'Star Works' does not meet any of the required criteria to run as a waste site (as set out in Policy W2) so the land needs to be returned to its previous restored state. Objection to star Works being included in the Draft Plan since it does not meet the 'test of soundness' or any of the criteria required in order to run as a waste facility. How can four different councils deem Star Works to be a suitable waste site, if it is not known how the site will be used? The prospect of the site being used for the recycling of hazardous electrical goods, e.g. fridges and freezers is especially worrying and would exacerbate the problems. Cannot see how there is a satisfactory or acceptable policy which justifies the continued use of the Star Works site. The fact that there is an existing facility does not provide empirical evidence that future usage is appropriate. Site is in contrary to policy W1 as it is not located near to the sources of waste or markets for its use and it is unlikely for Star Works to substitute or deliver the 70,000tpa capacity that will be lost when the Landfill Restoration complete in January 2020 due to planning policies restricting storage & Treatment Facilities The plan states that there is insufficient treatment capacity, The existing operation treats yet the current Star Works facility treats waste from the whole clinical waste which is a of the UK, not just Central & Eastern Berkshire. specialist waste and therefore, Processing of waste from outside of the Joint Minerals and serves a wider market. Waste Draft Plan should be discouraged. Presently sites process waste from outside of the area and priority should be given to our own capacity requirements. This could be achieved with the introduction of tariffs out on waste coming from outside of the Central & Eastern Berkshire Authorities’ jurisdiction.
Safeguarded sites should be judged on Central & Eastern Safeguarding waste Berkshire Authorities’ Site Assessment criteria and any infrastructure is to prevent existing sites should be judged on any previous prosecutions, encroachment of activities which infringements and pollution incidents should also be could impact the existing considered with regards the viability of continued use and the operation and seeks to maintain existing Operator’s suitability to retain both the site and its waste management capacity. operating licences. In the case of Star Works these prosecutions / incidents are: 2010 - Guilty of Breaching The site has existing conditions of held waste permit 2009 - Pollution Incident - environmental permits to Atmospheric pollutants and effects - Smoke & firefighting run- operate. off 2007 - Pollution Incident - Atmospheric pollutants and effect - other 2004 - Pollution Incident - Atmospheric pollutants and effects - Landfill Odour 2002 - Guilty of deliberately pumping 500,000 Gallons of Stagnant Water from a Quarry Lagoon into Woodland surrounding the Watercourse. There is significant recreational use of the area surrounding All information received Knowl Hill Star Works including use of bridal ways, footpaths, regarding the proposed site The Chiltern Way, Knowl Hill Bridal Way Circuit and Sustrans allocations will be taken into Cycle Route. Further development would negatively impact consideration in the preparation these amenities. At times it can be very dangerous for of the Proposed Submission numerous walkers trying to enjoy the walks access the plan. footpaths. Residents suffer from the environmental consequences of Amenity and environmental living right next to a waste site. As an example of the issues would be addressed by problems, waste appears to be stored against the fence the Development Management separating the site from residents' properties rather than in (DM) Policies. the appointed buildings. The Hydroclaves – all the others in the world had been Should an application be placed well away from residential areas. These were placed submitted for the site, the within 50 metres to the nearest resident as can be seen in proposal would need to comply the picture [picture provided] with these policies and address Knowl Hill is a residential village in the Green Belt and there any potential issues through should be a general principle that waste facilities should not mitigation measures. be located near residential family properties. Star Works is located in close proximity to Grade II listed buildings, and this is one reason why it should not be permitted to continue operating as a waste site The access to the Star Works site is via a privately-owned restricted byway, which is adjacent to listed residential heritage assets and leisure and recreational routes. Cumulative Impact is one of the criteria that site suitability is judged upon, and safeguarding existing sites would increase the cumulative impact on residents, where the original premise of use was granted based upon “the considerable long term benefit to be derived from the restored landscape and public access.” Star Works, Knowl Hill is clearly unsuitable for further waste operations due to its location within a village, within 50 yards of residential property and subsequent increase in traffic. Waste facilities should never be located near residential properties. The landfill at Star Works is now in the restoration phase and in the process of being restored back to woodland. Any further development would be detrimental to the village and the landscape. Environmental concerns at a local level should predominate decision making for this site This is an area of beauty, and a place where people walk to gain health.
This site is in a residential area and following the recent renovation of the seven stars properties this has now moved the immediate surrounding area into residential use. Prior to this the commercial use of the Seven Stars area meant the impact from the Grundon's site was proportionate given the adjacent land use. However following the renovation and change of use the site now finds itself nestled within residential area, affecting quality of life. New development which would surely be necessitated to manage an additional 100,000 tonnes of waste would be incalculably detrimental to the village, residents and the surrounding area. By having a landfill site so close to residential properties it will result in the fall in the quality of life for those residents. Proximity of the site to residential properties (within 50 yards) is undesirable and impacts residents’ quality of life, health and wellbeing and has done so for 20+ years for some residents. Mental health is affected. Residents have many personal examples of how the landfill site has negatively contributed to the emotional and psychological health of our families and neighbours Current arrangements, and any future permitted works, be re- structured in such a way that vehicle movements, and the movements of material within the site, will take place within strictly controlled operational hours and days of work, to reduce the noise impact at anti-social times. Future waste treatments, if permitted, should be restricted in such a way to protect residents and the nearby school from pollutants (including vehicle movements) and odours. The National Planning Policy for Waste, October 2014 states that in identifying suitable sites and areas waste planning authorities should assess the suitability of sites in terms of, amongst other things: "the cumulative impact of existing and proposed waste disposal facilities on the well-being of the local community, including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential" Contradicts with draft Policy DM3 of the JMWP which suggests that waste development should not be located in areas that could impact Ancient Woodland and local interest sites for biodiversity or priority habitats and species listed in the national and local Biodiversity Action Plans, unless: the merits of development outweigh any likely environmental impact; the development could be reasonably located on another site; or appropriate mitigation or compensation measures for impact to biodiversity could be provided. These have not been adequately demonstrated in relation to the Star Works site, due to its absence from the Habitats Assessment and Screening report in the evidence base There was only ever a need for landfill due to a large hole Noted. created from clay extraction from 1994. In light of the Government’s decision to support the third Central & Eastern Berkshire are runway at Heathrow, which would result in the demolition of already reliant on the Lakeside Grundon’s Lakeside energy from waste facility, it would make Energy from Waste Plant. more sense to review the capacity of the proposed replacement facility in the immediate vicinity of that site in The Plan recognises that order to accommodate more of Wokingham’s waste. The additional waste management social and environmental impact of expanding the capacity at capacity is required during the the replacement Colnbrook facility would be far less than Plan period above and beyond utilising the Star Works site for waste treatment. This should the current reliance on Lakeside be thoroughly considered as an alternative option. Bearing in or any replacement facility.
mind that the Lakeside EfW facility is in the same ownership as the Star Works site, you would expect that the draft Minerals & Waste Local Plan should be able to address this matter in more detail than the brief statements on page 60. It could also be considered that it is premature to proceed with the draft Plan before there is more certainty about the future of the Lakeside EfW facility. The preferred option of WBG7 is redevelopment of the site, Noted. underlining the conclusion that current proximity to dwellings within a Green Belt location severely limits potential. All information received Following the completion of the Landfill Restoration, the regarding the proposed site remaining hydroclave activities make a minor contribution to allocations will be taken into the Plan's capacity requirements unless new waste consideration in the preparation management treatments can be accommodated. The site of the Proposed Submission constraints make this a difficult implementation plan. Star Works poses a fire risk Theresa May has previously campaigned for its closure and has been opposed to further expansion of the site. Areas of land, ancillary to the Landfill operations now appear to have been included in the plans for a permanent waste facility, however these areas are already designated as areas for restoration and completion by 2021. The current ancillary areas included a security compound, skip/container store, aggregate store and vehicle park under permission 344446 were to be removed within 6 months of their cessation of use, ancillary to the Landfill. Expansion of the treatment works would be at odds with the potential restoration use on the landfill next door. Star Works does not need to be maintained or expanded for you to meet the needs of the boroughs covered in the report. The potential intensification of waste activity suggested for Star Works represents a significant increase over current levels. This upsurge is far greater still when taken in the context of the current baseline including a substantial level being attributable to the site’s landfill restorative works which are due to conclude soon. Based upon cumulative policy decisions, the impacted local community and environment has held a predictable expectation of reduction not exacerbation. The inclusion of Star Works within Policy W4 does not accord with the National Planning Policy for Waste (NPPW) as detailed below: i) The cumulative impact of the existing and potential waste facility would be detrimental to the well-being of the local community including environmental quality contrary to paragraph 5. ii) The site does not support the sustainable movement of waste by use modes other than road transport. iii) Any expansion of the site would be inappropriate development in the Green Belt contrary to paragraph 6. iv) Expanded operations at this site would conflict with the locational criteria of Appendix B (paragraph d – nature conservation) including a site with a nationally recognised designation and protected species. v) Noise and vibration from goods vehicle traffic movements to and from the site, Appendix B (paragraph j – noise light and vibration). Additional adverse considerations in relation to the NPPW are: • air emissions and the close proximity of sensitive receptors (humans); • the reliance on local roads for access; • odours and the close proximity of sensitive receptors. Star Works does not comply with the statement that, “some waste, such as large-scale facilities requiring an open site are difficult to accommodate in urban areas. Waste uses not
requiring a more isolated location and minerals developments that are not specifically linked to the natural occurrence of a mineral, should be located in urban areas”. This is because Star Works is neither urban nor isolated. 5.36 It must be reminded that the promotion of Star Works as a waste management facility over the Plan period suggests that it could manage all types of waste category. A simple analysis of the locations the Councils consider inappropriate for such development/uses provides stark reading. [ALL SUPPORTING EVIDENCE OF THIS RESPONSE CAN BE FOUND VIA https://www.muckmentum.co.uk/important- information/supporting-documents-for-opposition] In conclusion, the operational contribution that the Star Works site has provided to the waste strategy for the area is 21 years with a preceding mineral extraction dating back to 1947. It is considered that this site has served its purpose and more than adequately made its contribution as a waste and minerals facility to an area much wider than the locality in which it is situated.
Transport
Issue Response Increase in heavy goods vehicles would be an The Strategic Traffic and Transport unacceptable health and safety risk to our community. Assessment concludes that the Concern that an increase in HGVs would not be change in HGV traffic on the SRN sustainable and would impact A4 commuters, including would be less than 1%. The magnitude major facilities such as Castle Royle with over 3000 of change from the existing conditions members. on the SRN would be negligible and Traffic on the A4 road is already congested, also the A4 is therefore the significance of impact of the main diversion when the M4 is out of use as it will the new proposals would be neutral. intermittently be until 2022, so this will get worse if the site expands, coupled with other proposed housing Should an application be submitted for development in the area. Currently, accessing the A4 from the sites, the proposal would need to Warren Row Road heading eastbound can be extremely comply with Policy DM11 (Sustainable difficult with the volumes of traffic using this key highway. Transport Movements) and address The A4 I more likely to be grid locked affecting residents any potential issues through mitigation commuting time if capacity at Star Works was significantly measures. increased. No consideration has been given to the actual road traffic Planning approval for future use of this movements associated with Grundon’s previous peak site would be require a Transport operation, which are much lower compared with their Assessment or Statement in which stated volume of 100,000 tonnes at peak. safety, routing, air quality, hours of The assessment will need to take into account actual operation, and road capacity issues vehicle movements, rather than current permitted will be assessed in detail, and movements, as local residents judge their current levels of mitigation proposed as required. disturbance on actual movements. If the Star Works site is granted planning permission to continue to function as a waste site in the future, what measures will be implemented to mitigate the effect of the traffic increases on the residents of Star Lane? Many parts of the A4 have had speed restrictions imposed Appendix A states that a Transport over the past few years with many stretches now 40 mph. Assessment or Statement would be The access point for Grundon's is terrible – the site lights required as well as a new routing are not good from the entrances and the narrow width of agreement (or continuation of the the road makes it dangerous for large lorries to pass. At existing) should an application be the narrowest point Star Lane is 507cm wide [picture submitted. provided]. Some residents’ drive entrance is tucked behind entrance to Star Works and they cannot see the All information received regarding the entrance easily and show no courtesy. proposed site allocations will be taken into consideration in the preparation of
Knowle Hill Bridleway Circuit crosses the A4 at Knowle the Proposed Submission plan and will Hill and continues along north past Star Works. The route inform the revised Strategic Traffic & is marked on the RBWM definitive map as a restricted by Transport Assessment. way ref 41. Concern about any increase in traffic or size of vehicles delivering waste. Horses frighten easily in the If required by the planning authority, an vicinity of large vehicles, especially if accelerating from environmental statement, or other the A4 junction going uphill, consideration needs to be relevant reports, would address made to this important Bridle way circuit. You might impacts on Sensitive Receptors, consider having a Pegasus crossing across the A4 where alongside a Transport Assessment or the bridle way circuit crosses this very busy road Statement The site does not have good connectivity as the access is via a privately owned restricted Byway (forming a part of the Knowl Hill Bridleway circuit, Leisure Routes, PROW and the Sustrans National Cycle Network). Current site permissions related to vehicular movements are limited, but are breached daily. The transport links in the area are neither suitable nor sustainable. There is a significant recreational use of the area surrounding the Knowl Hill Star Works which include bridle ways, footpaths, The Chiltern Way, Knowl Hill Bridal Way Circuit and Sustrans Cycle Route; further development would impact considerably on these amenities and activities. HGVs arrive uncovered / unsheeted in breach of Conditions and all HGV traffic shares the same Restricted Byway with children, cyclists, dogs, horses and walkers of all ages. The main suggested route into the works goes past several high sensitivity receptors including directly past a primary school and other community facilities. The A4 (particularly between the Maidenhead Thicket Appendix A states that a Transport roundabout and the Wargrave roundabout) is a known Assessment or Statement would be dangerous road and has seen multiple injuries and required should an application be fatalities over the last 10 years submitted. The Statement of (http://www.crashmap.co.uk/search). M4 "smart" Assessment would need to address alterations will exacerbate this. Heavy lorries using the safety. site cause danger e.g. frequent near misses between vehicles exiting Star Lane and the Star Works traffic If required by the planning authority, an Village centre location within 1 mile of two primary environmental statement, or other schools, which poses danger to the pupils. The pupils, relevant reports, would address any parents and staff face ever growing numbers of vehicles issues of noise, vibration and air and the dangers associated with this entering and leaving quality. the school, not to mention the higher levels of air pollution affecting the children, parents and staff. Young children All information received regarding the are particularly vulnerable e.g. asthma proposed site allocations will be taken Drivers should be compelled to adhere to the speed limits into consideration in the preparation of and anything that increases the risk of reckless driving the Proposed Submission plan and will (such as payment by the load) be strongly discouraged inform the revised Strategic Traffic & Concern for people safety due to high number of recent Transport Assessment. collisions and fatalities on roads surrounding the site. Encourage consultation with the school local to Star Works as it should be able to provide information on recent incidents relating to parents and / or children attempting to arrive at school safely, despite the local roads presenting several hazards and risks. The road from the A4 to Star Works is narrow. There is no room for a lorry and a car to pass each other. There is an ongoing safety risk caused by lorries not giving right of way to cars. This must be addressed if Star Works is to continue operating vehicle movements.
Many cyclists who join the westbound A4 coming out of Bottle Lane then try to cross the flow of traffic to turn right onto Warren Row Road where they will be particularly vulnerable to lorry traffic. The car park at Flics Café is regularly used by Grundon The use of facilities by HGV operators waste vehicles (sometimes it’s full of them). The smell cannot be controlled by the Joint caused by the vehicles impacts the use of private gardens Minerals & Waste Plan. as it is very potent. No consideration is shown, by the drivers of the HGVs for the local neighbours of Flics Café and the vehicles produce so much dust (in the cafe carpark), it is not possible to dry washing outside or sit peacefully in gardens. Current transport assessments are not based on existing Traffic Modelling across the Plan area traffic movements and not site specific so do not take into is not available to inform the Joint account the changes in operation of the site post 2020 Plan. Therefore, the Strategic Traffic (increased traffic movements out once their own landfill and Transport Assessment was based site closes). on traffic flow information obtained It is unclear from the presentations given whether any from the Department of Transport consideration has been made to integrate plans with other (TRADS database), estimates of high impact road traffic implications such as the plans to forecast development traffic generation substantially increase housing in and around Twyford just and an indication of preferred routing. 2 miles further along the A4. Appendix A states that a Transport Assessment or Statement would be required as well as a new routing agreement (or continuation of the existing) should an application be submitted.
Future Waste Management sites should be located where The Draft Plan seeks to encourage there is direct access to the rail network as a more sustainable transport through Policy sustainable transport solution than the road networks. DM11 (Sustainable Transport There is very poor sustainable vision for suitable transport Movements). However, the Joint Plan links in the area. also recognises that there are limited opportunities.
Ecology
Issue Response Star Works incorporates a Wildlife Heritage site, where Appendix A outlines the presence of there are several protected species including great the Local Wildlife Sites, Woodland and crested newts, cattails, bats, badgers plus a wide Protected Species within the selection of Butterflies, some of which have reduced Development Considerations for the significantly in numbers over the past 10-20 years. site. The location of the proposed site is within a Greenbelt, which contains many different species of animals (deer, All information received regarding the foxes, badgers, owls, newts, grass snakes, lizards and proposed site allocations will be taken bats) who need places for them to live, thrive and survive. into consideration in the preparation of Knowl Hill is in an important area of particular scientific the Proposed Submission plan. interest. The possibility of increasing capacity at Star Works for commercial waste facilities in this area would have a detrimental impact and on the area’s protected species, flora and fauna of six local wildlife sites, due to loss or threat to habitat from pollutants, development, noise and light The site sits within protected woodland which has a tree preservation order on it (no 4/1951). 'Star Works' lies within an area that holds 'Sites of special Scientific interest' status, has protected species including Great Crested Newts/Cattails and the ancient woodland which has blanket protection. It is vital that this is
preserved. This beautiful protected area has already been impacted by the Grundon facility when gallons of polluted water (500,000) was emptied into the woodland. Berkshire Nature have identified our open woodland areas of significant importance having been established in Roman times beside the Ancient Woodland. Increasing the intensity of use of the Star Works and site prejudices this historic environment. Protection should be afforded to other areas of designation, such as sites adjacent / nearby to Sites of Special Scientific Interest, nationally protected species, and Ancient Woodland (e.g. Linen Hill to the north of the site). There seems to be no full assessment of the Habitat. The need for an Environmental Impact Unable to understand the justification for the extension of Assessment (EIA) would likely be the site in relation to the threat to woodland and trees, the required as part of a planning majority of which are protected and subject to TPO. application with details of mitigation Concerns raised over the wholescale destruction of measures. protected trees in order to facilitate the justification for the extension and intensification of operations at Star works. We conclude that habitat assessments are not appropriate for the allocation and expansion of the site.
Landscape
Issue Response Any further development would be detrimental to the The Landscape and Visual Impact village and the landscape Assessment recognises that the full extent of the proposals is unknown at present, but visibility of the development contained to the area around the existing buildings is limited.
An Environmental Impact Assessment would likely be required as part of a planning application with details of mitigation measures. Knowl Hill is surrounded by designated important Noted - Appendix A recognises the landscapes - Linden Hill Wood and Bear Wood is ancient presence of the Local Wildlife Sites, and protected, Knowl Hill Brick Pits LWS and Cayton Woodland and Protected Species Park Woodland LWS, Bottom Boles Wood LWS, Square within the Development Wood LWS, Common South-east of Warren Row LWS. Considerations for the site. Knowl Hill is a large residential village in the greenbelt Due to the limited site options made and waste sites should not be located here available for waste management, it is The site is in Green Belt, but this could be compromised considered that ‘very special with an increased site capacity and operations as further circumstances’ exist for these development (and associated infrastructure) may sites. However, it is recognised that eventually result. more detail may need to be provided As a new waste facility within the Green Belt, it does not in the Waste Proposals Study. meet the required criteria based upon its location, ecology, landscape, proximity to residential properties and the community's health, safety and welfare. The development of Star Works within a green belt is unacceptable, because the processing plant is unlikely to preserve openness, owing to its size, height and industrial appearance. The site itself was an area of outstanding natural beauty, The landfill operation adjacent to the it is time that it is restored to this state proposed allocation has ceased and the site is now being restored.
Flooding
Issue Response Star Works/Knowl Hill We suggest that rather than saying Noted – the SFRA will be updated to ‘fluvial flooding risk – none’, this should say that there is take the additional information into ‘low risk of fluvial flooding’ as there are some small account. watercourses in the vicinity of the site. Site allocations and river corridors In the Water Environment and Flood Risk section this says: “Within Groundwater Source Protection Zone (3) - a Hydrological Assessment will be required.” This needs to be changed to: “Within Groundwater Source Protection Zone (3) - a Hydrogeological Risk Assessment will be required.” The site is within Groundwater Source Protection Zone (3) If the Hydrological risks cannot be —this critical public health issue seems to have been suitably addressed by the dismissed by suggesting a Hydrological Assessment Hydrological Assessment permission would be required at planning application stage. The will not be granted. proposals must therefore be contrary to draft Policy DM10 which states that development should not have an unacceptable impact on groundwater Source Protection Zones.
Archaeology
Issue Response According to our records there are no designated assets It is considered that the archaeological on or in close proximity to this site. We note the draft SEA remains in the vicinity, the assessment of this site against SEA objective 3 that it is archaeological potential in that likely that archaeological remains will be encountered. At landscape and the extensive degree this stage we do not know the extent, nature or to which the site is compromised by significance of these remains and we consider that the existing development do not suggest allocation of this site should not be taken forward in the an overring archaeological constraint absence of clear evidence that waste management at this is likely. However, liaison is on-going site would not be harmful to the archaeological with Historic England regarding the significance of this area. allocations. We are not sure what is meant by “extraction is likely to The text will be reviewed. overcome the constraint through archaeological mitigation” – the Plan proposes to allocate this site for waste management, not excavation. Nevertheless, we are still unsure as to what archaeological mitigation there could be - we note that Appendix K of the draft SEA just suggests “historic environment schemes” as an example of mitigation measures which rather suggests that the authors are not sure themselves as to what mitigation measures there could be. Access to the Star Works site must retain the rural open Should an application be submitted for landscape and historical setting compatible with adjacent the sites, the proposal would need to Grade 2 listed buildings. comply with Policy DM7 (Conserving the Historic Environment) and address any potential issues through mitigation measures.
The Compound
General
Issue Response The site is located in the Green Belt. This is noted in the site proposal study. Due to the limited site options made available for waste management, it is considered that ‘very special circumstances’ exist for this site. RBWM have been unable to confirm that other ancillary It is expected that any planning buildings would not be additional requirements for the application that comes in will cover successful operation of a waste treatment facility on this all the buildings required for a Green Belt site. successful operation.
Any planning proposals will need to comply with all the Policies outlined in the Joint Plan including the Development Management (DM) Policies, which seek to control the impacts of development. This site triggers the Environment Agency 250m rule on The planning system has an detailed risk assessment for bio aerosols due to the close expectation that other parts of the proximity of residences and school (Beech Lodge) at less system, including the duties of than 250m. Bio aerosols are a major risk factor other agencies, will work as they should. It will be the Environment Agency that regulates and monitors bio aerosols.
Open windrow composting has been ruled out as a potential activity on this site due to this issue. If there was a fire smoke would blind the motorway, causing The planning system has an serious danger. There is always a severe risk of spontaneous expectation that other parts of the combustion with garden waste. system, including the duties of There are well documented issues with garden waste other agencies, will work as they spontaneously combusting in Heat. The site is south facing should. The site will require an with no shielding from the sun given and so makes it a bad Environmental Permit from the site for processing of this kind. Environment Agency. There is a new school / co-educational facility, designed for The school is located on the other children and young people with additional needs, and it is in side A404 with no physical or close proximity to the proposed site. The impacts of the visual connection between the two. proposed site on the school (and those using it) would be detrimental Objection to the site as there must be more suitable, The preparation of the draft Plan alternative sites has included an extensive search for sites, as detailed in the Waste proposals background document. The sites proposed in the draft plan are the ones considered most suitable and sustainable. Objection due to the potential health risks presented from the Potentially harmful emissions to air potentially harmful organic material that would be processed are controlled by the Environment at the proposed site, and the fumes / waste products Agency and would be subject to circulated into the atmosphere as a result of the processing. their regulation and monitoring. Additionally, the proposal study does not evidence a risk The planning system has an assessment to the nearby residents and pupils due to expectation that other parts of the potential emissions of bacteria, spores and fungi that such system, including the duties of
composting could produce. Indeed, the proposal does not other agencies, will work as they specify the exact nature of the potential waste operation so should. therefore there is no fully evidenced and researched justification for allocation of this site. Surely there are laws to Furthermore, amenity issues would control exposure of nearby residents and pupils to hazardous be addressed by Policy DM9 bioaerosols. (Protecting Public Health, Safety and Amenity). Should an application be submitted for the site, the proposal would need to comply with this policy and address any potential issues through mitigation measures. Alternative sites should be considered in rural areas that are The preparation of the draft Plan not populated at all. Such sites may, by virtue of the fact that has included an extensive search they are more isolated, offer a much larger area for green for sites, as detailed in the Waste waste processing than the two hectares proposed here. proposals background document. The sites proposed in the draft plan are the ones considered most suitable and sustainable. It would be detrimental to the area as a local amenity for Noted. ramblers, dog walkers, and equestrians who are all frequent users of the National Trust Woodland and regularly use All information received regarding Stubbings Lane to access Maidenhead Thicket and to follow the proposed site allocations will the Berkshire Loop footpath. be taken into consideration in the It is not a 'compound' but a field which was only used for preparation of the Proposed accommodation works temporarily for the A404 construction Submission plan. about 15 years ago for a short period. It’s questionable to whether the site is viable, because the Joint Waste Proposal Study refers to the consideration of site of 2ha or more, whereas Stubbings Compound is 1.2ha. The site is totally inappropriate due to its small size (3 acres), odd shape, lack of useable space and poor vehicular access. The site, which measures 1.2 hectares, is too small for such an intensification of use. The proposed green waste recycling site is actually located in Stubbings Village (not Pinkneys Green as stated) on Green Belt agricultural land, adjoining Stubbings Lane. The landowner was recently granted planning permission to build a barn and create hardstanding on the basis that it was necessary for agricultural use. This permission was on the strict understanding that it would not result in any intensification of use of the site. Waste management and treatment do not represent private agricultural use. The site is currently covered by hardstanding and has planning for a barn. The area should have been restored to its agricultural status, as required by R.B.W.M. following a temporary planning consent for storage of road works equipment, which has so far been ignored. The entrance to the proposed site is shared with Stubbings House (a building of very significant local historic importance), a local Garden Centre, and the new school. This does not seem to be a suitable mix of neighbours for a waste recycling plant Oppose and object to the proposed Stubbings Compound All information received regarding site as a waste recycling facility as being inappropriate the proposed site allocations will (petition signed by 61 residents) be taken into consideration in the preparation of the Proposed Submission plan.
The site would have a detrimental impact upon the prices of Property Value is not a material nearby residential properties consideration in determining minerals and waste proposals. However, amenity (and other issues) would be addressed by the Development Management (DM) Policies which seek to control impacts We already have the purpose built R.B.W.M Recycling The draft Plan and its evidence Centre at Stafferton Way Maidenhead, SL6 1AY, which is base have considered the current just 2.5 miles by road from Stubbings, so there is no need for waste produced and what waste is another site. expected to be produced in the future, as well as what capacity is needed in order to manage that quantity of waste. The conclusion was that more sites are needed to address the capacity gap. The proposed waste recycling plant would be adjacent to a Noted. nursery which provides healthy plants and sells them to consumers from a very wide area; these plants are at present All information received regarding healthy and they include perfectly edible salad and root the proposed site allocations will vegetables; the proposed waste recycler is much too anti- be taken into consideration in the social to be near household consumers; faults do occur preparation of the Proposed which can be life threatening. Submission plan. Processing of green waste on this site, in bulk and in close proximity to residential properties will make the lives of those Amenity issues would be with respiratory problems very difficult and be a detriment to addressed by Policy DM9 their wellbeing. (Protecting Public Health, Safety There are two schools in the vicinity of the The Compound. and Amenity). Should an One of these schools is on Stubbings Lane, the only access application be submitted for the road to the Compound. This school offers specialist provision site, the proposal would need to for very vulnerable children who have considerable sensory comply with this policy and address and neurological needs. Special planning consent was given any potential issues through by the planning Inspector at a recent Tribunal because of the mitigation measures. unique aspects of the site and the needs of the children. The operation of a green waste management and treatment plant adjacent to the school would severely compromise the wellbeing of these vulnerable children. The proposed site would have negative impacts upon quality of life for those living in close proximity to it, within 50m of some gardens and homes Objection to the proposed site, since several residential dwellings are located at approximately 83 metres from the site boundary (using the scale provided in the proposal study). Oppose due to environmental issues including noise of recycling plant, heavy machinery and heavy lorries all of which have to have reversing buzzers fitted as standard for safety would have a devastating effect on a quiet residential and woodland area. Also the smell (green waste processing plants are notorious for release of odours, whether enclosed or not), possibility of Rodents will increase dramatically and flood lights. The site is directly under the approach and take off routes Noted. from White Waltham airfield with light aircraft crossing above at very low altitudes. The landowner has logged numerous All information received regarding complaints to Bisham Parish Council and RBWM about this the proposed site allocations will low flying activity. The processing of Green waste on this be taken into consideration in the site will attract an abundance of birds feeding on waste and preparation of the Proposed vermin that the processing of that waste will attract. This Submission plan. includes gulls which have collected in large numbers in our area recently and predatory birds (there is a large number of
Red Kites in the area). This could create a hazard for the Aircraft safeguarding issues would aircraft on takeoff and approach to the airfield. be addressed by Policy DM9 (Protecting Public Health, Safety and Amenity). Should an application be submitted for the site, the proposal would need to comply with this policy and address any potential issues through mitigation measures. Drowning the public in information that masquerades as The concern regarding the volume consultation does not serve the public and is not of information is noted. consultation. The production of minerals and waste plans is subject to a variety of legislation, policies and guidance that have to be adhered to. This includes the production of a robust evidence base that has been subject to public consultation. The size of the evidence base can make consultation difficult but is generally necessary in order to fully support and justify the plan.
Transport
Issue Response Oppose and object to the proposed Stubbings Compound Planning approval for future use of site as a waste recycling facility as being inappropriate for the this site would be require a following reasons: increased traffic along the Henley Road Transport Assessment or (which cannot easily support heavy goods vehicles and plant Statement in which safety, routing, and machinery), air quality, hours of operation, and Object due to potential congestion and increased danger road capacity issues will be from Henley Road onto Stubbings Lane (which serves assessed in detail, and mitigation Stubbings Nursery, cafeteria and business centre, Beech proposed as required. Lodge School and the Compound) Paragraph 4.4 of the Strategic Transport Assessment has been strengthened to this effect.
There would be a major increase of heavy goods traffic along As set out in the STA, the the narrow country roads of the village of Burchetts Green, a estimated vehicle numbers are residential area close to the proposed site unknown at this stage. Planning approval for future use of this site would be require a Transport Assessment or Statement in which safety, routing, air quality, hours of operation, and road capacity issues will be assessed in detail, and mitigation proposed as required.
Paragraph 4.4 of the Strategic Transport Assessment has been strengthened to this effect.
Objection as there would be an increase in traffic on The preferred route avoids Pinkneys Drive, a narrow lane with dangerous blind bends, Pickneys Drive. A routing strategy which has a 7.5 ton weight limit in place. Pinkneys Green would be required as part of a Village is a designated conservation area and this could be planning application for future use of this site.
jeopardised by commercial vehicles using the small local roads regularly as a short cut to the proposed site. Residents struggle getting out of drives, the road is already Planning approval for future use of too fast for these people as drivers do not adhere to the this site would be require a speed limits even though some of the road has recently Transport Assessment or changed to 40 at this junction. Statement in which safety, routing, The increased traffic along Henley Road would pose a air quality, hours of operation, and danger to cyclists and walkers/the commuting public whose road capacity issues will be numbers have significantly increased over the last couple of assessed in detail, and mitigation years. proposed as required. A routing Heavy lorries coming and going to the site will cause major strategy would be required of all congestion on the A4. The A4 is a very busy road with sites. serious traffic incidents and fatalities in the past 10 years. It is especially busy when there are traffic problems on the M4, Paragraph 4.4 of the Strategic which is also about to undergo major works over the next few Transport Assessment has been years, causing even more chaos for people who live along strengthened to this effect. the A4 and the many side roads trying to exit onto it. People ride horses along Henley Road and this is already becoming quite problematic with such heavy traffic. Increased risk of accident and injury for both vehicle occupants, other road users and pedestrians. The junction of Henley Road and Stubbings Lane would become too congested and dangerous, and because of the topography of the Compound site it can only be accessed at this junction. JCEB have even stated, "an adequate routing strategy would need to be agreed and works to the site junction." Cumulative impacts of traffic and pollution on the Henley Road and Stubbings Lane as a result of the Beechwood School (planning permission granted for construction on the other side of the A404, also on green belt land) in addition to the green waste processing site will be unacceptable Concern regarding additional private traffic using the site to deposit green waste If emergencies occur, reversing and forward moving traffic will be chaotic and quickly turn to a halt The access to the site is also not directly from Henley Road but via the road to Stubbings Estate. It is difficult to see how this access can be made safe for HGVs - the site entrance is immediately on the right after the Stubbings Estate turning and the entrance itself is also not entirely suitable for HGVs on an ongoing basis. Concern about the increase in air pollution which would be If required by the planning generated by the additional vehicle movements associated authority, an environmental with the site statement or other relevant reports would address any issues of noise, vibration and air quality.
Paragraph 4.5 has been added to the Strategic Transport Assessment to explain role of environmental statement.
The proposed site of 1.2 hectares (not 2 hectares as stated) These details would be assessed has insufficient space to accommodate the necessary through a transport assessment or access, turning and parking areas, let along the recycling statement through the submission operation. of a planning application for future use of this site. The site is allegedly used for storage and there is nothing to As set out in the STA, the show that HGV traffic for a recycling plant would be neutral. estimated vehicle numbers are
unknown at this stage. Any further information made available with regard to vehicle numbers will be reflected within the Proposed Submission Plan. There would be a sizeable increase in regular heavy goods Planning approval for future use of vehicles and plant and machinery. this site would be require a Difficult access on to A404 at either end of Henley Road, Transport Assessment or exacerbated by the additional waste movements. Statement in which safety, routing, Sustainable Transport Movements The Compound is air quality, hours of operation, and accessed by Stubbings Lane. This lane is very narrow and is road capacity issues will be already very busy as it services a school, a busy plant assessed in detail, and mitigation nursery open to the public and public tearooms. The heavy proposed as required. A routing truck movements the Waste Management and Treatment strategy would be required of all Site will generate all day will create an intolerable strain and sites. put these current users at risk. RBWM has been unable to confirm that the Waste Management and Treatment Site Paragraph 4.4 of the Strategic would not be open to the general public. Further public use Transport Assessment has been on top of the heavy truck movements will further endanger strengthened to this effect. current users. Stubbings Lane runs from a junction with the Henley Road. As set out in the STA, the This road is already causing Bisham Parish Council concern estimated vehicle numbers are because of the heavy use and the speeds at which cars unknown at this stage. Any further travel down this stretch. Bisham Parish Council spent three information made available with years successfully campaigning for a speed restriction on this regard to vehicle numbers will be road. There are a number of well used footpaths and routes reflected within the Proposed used by horses which run close to the entrance of the Submission Plan. proposed site. An increase in traffic movements and in particular heavy traffic movements could cause the users of the footpaths and horse riding routes to come into conflict with deadly ramifications. Henley Road is also used extensively by walkers and horse riders, particularly around the junction with Stubbings Lane and Footpath 35. Heavy traffic movements in and out of the proposed site would not be consistent with road safety at the junction. increased congestion and danger at Stubbings Lane junction with the Henley Road (60 mph speed limit immediately east of the lane).
Ecology
Issue Response Stubbings ancient woodland is in close proximity to the Noted. proposed site and the area is enjoyed by the local community. This could be jeopardised by the operation of All information received regarding the proposed site the proposed site allocations will Increased smoke, unhealthy fumes and dirt would have a be taken into consideration in the great effect on soil pollution, and atmospheric oxygen for all preparation of the Proposed living animals and beings within an immeasurable area. Submission plan. The Compound is in close vicinity to a number of Local Wildlife Sites (LWS). These include; • Maidenhead Thicket Amenity and environmental issues (already under severe pressure from the A404), • Carpenters would be addressed by the Wood • Dungrove Hill • Temple Golf Course. All of these sites Development Management (DM) have been mentioned as concerns in the consultation Policies. Most notably, Policy DM9 document. These sites would be placed under severe threat (Protecting Public Health, Safety should The Compound be developed as a Waste and Amenity) which addresses Management and Treatment site. pollution concerns and DM3 (Protection of Habitats and Species). Should an application be submitted for the site, the proposal would need to comply
with this policy and address any potential issues through mitigation measures.
Landscape
Issue Response The proposed site is surrounded by National Trust land and The National Trust land is the whole area is protected countryside. The proposed separated from this site by the development would have detrimental impacts upon these access road to Stubbings House protected areas. and Henley Road to the North. This proposed waste disposal and recycling plant would be This plot is isolated and it’s use as touching an area designated National Trust, and would also a green waste site would not be within The Green Belt, both of which surely discourage impede the use of the open access waste industry within their areas. land.
However, greater recognition of the National Trust Land will be made in the Strategic Landscape and Visual Assessment. The small and idyllic village of Stubbings with its ancient The Development Considerations Parish Church and large detached houses would have its in Appendix A state that enhanced rural character destroyed by siting such an operation in its screening would be required as centre. Stubbings sits between the communities of Pinkneys well as a Routing Agreement which Green and Burchetts Green - both local Conservation Areas. would seek to address the concerns raised. When the current planning permission was granted for the The isolated location adjacent to storage barn, one of the conditions of consent was the very noisy and busy A404 makes removal of permitted development rights. The reason given the land unattractive for many was, "in this case given the isolated location of the site in the uses. Green Belt and the potential effects of additional development, the removal of PD rights in this regard via The conditions placed on the condition is considered to be justified". How can you justify current permission would need to the use of the whole site now? be addressed as part of any future permission for waste uses.
Flooding
Issue Response In the Water Environment and Flood Risk section this says: Noted – the text will be reviewed “Site in Groundwater Source Protection Zone (3) – a and amended. Hydrological Assessment will be required.” This needs to be changed to: [Amended in Plan.] “Site in Groundwater Source Protection Zone (3) – a Hydrogeological Risk Assessment will be required.” A further concern detailed in the proposal is the management Potentially harmful emissions to of waste water and the prevention of its encroachment water are controlled by the through the mature boundaries of the neighbours. The Environment Agency and would be proposal provides no details about containment and subject to their regulation and management strategies and is creating huge distress for the monitoring. The planning system neighbouring residents. has an expectation that other parts of the system, including the duties of other agencies, will work as they should.
Furthermore, amenity issues would be addressed by Policy DM9 (Protecting Public Health, Safety and Amenity). Should an
application be submitted for the site, the proposal would need to comply with this policy and address any potential issues through mitigation measures.
The Development Considerations in Appendix A also state specifically that consideration should be given to surface water discharge to ground pollution.
Archaeology
Issue Response According to our records there are no designated assets on Noted – the SA/SEA will be or in close proximity to this site. However, we do not consider reviewed. that waste management development at this proposed site would actually result in a positive outcome for heritage assets [The SA/SEA was updated to as indicated in the draft SEA. clarify that ‘green’ also represents neutral impact]
The proposed waste site (if implemented) would be a great Robin Hoods Arbour is separated discourager for access to the historic Robin Hood's Arbor. from the site by the A404 and screened by Maidenhead Thicket.
Water Oakley This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out. General Issue Response Concerns about the potential for significant Although the site has a long frontage with adverse impacts upon residential amenity if an A308 which could offer multiple possible access is located opposite, or in close proximity locations for site access. to, land controlled by Farmglade Limited; the although the site has a long frontage with approach to screen planting along the A308 A308 which could offer multiple possible frontage of the Allocated Site and the potential locations for site access. adverse impacts that will arise in Green Belt, Landscape (and other environmental impacts landscape and amenity terms; and the conflicts such as noise, air quality, severance, etc) will between anticipated timescales for the extraction be addressed as part of the Environmental of minerals from the Allocated Site (and Statement. In any event, planning approval of associated use of the processing plant at Monkey proposed development will also need to be Island Lane), and the expected timescales for the supported by an appropriate Transport redevelopment of the processing plant site at Assessment or Statement, which will address Monkey Island Lane as outlined within the RBWM issues of road safety, capacity and transport Borough Plan (site allocation HA23). demand and will include mitigation measures Monkey Island Processing Plant 17. The detailed as required. The scope of these assessments policy wording for the Allocated Site (HA23) will be agreed with the Local Highway outlines that mineral processing will take place at Authority and will likely consider committed an existing plant at Monkey Island Lane. It is developments and cumulative impacts. however important to note that the Draft RBWM Borough Plan allocates the processing plant site Monkey Island Lane has been submitted for for 100 dwellings, with an expected delivery housing with the expectation that the site timescale of 11+ years. We note that the mineral would be available towards the end of the extraction from the Allocation Site is expected to Plan period. take 8 years from commencement with infilling by inert waste over a similar 8 year period, albeit An application to extract the Water Oakley site commencing approximately two years after the has been submitted to RBWM and is yet to be start of mineral extraction. determined. Farmglade Limited controls land adjacent to the Allocated Site to the north of the A308 Windsor This site was subject to a planning application Road. This benefits from extant planning which was subsequently approved. permission for 69 dwellings in total and is also Therefore, the site has been ruled out as an subject to a current outline application for up to allocation in the Joint Plan and no further 127 dwellings with associated open space, assessments have been carried out. landscaping, community pavilion and other infrastructure (RBWM planning ref. 18/01804/OUT). A plan showing the extent of land controlled by Farmglade Limited can be found at Appendix 1 [see email]. The JMWP must be subject to a Proposed Submission consultation, which is expected to take place in 2019, and then Examination in Public in 2019/2020. Accordingly, adoption is unlikely to take place until 2020 at the earliest. Given the above, by the time a planning application is prepared, submitted and approved on the Allocated Site following the adoption of the JMWP, extraction is unlikely to commence until 2021/22, perhaps even later. Assuming an 8 year extraction period (which could in reality be even longer) and then allowing for the processing plant site at Monkey Island Lane to be vacated and remediated, this leaves little or no time for housing allocation HA23 of the RBWM Borough Plan to be delivered before the end of the plan
period (2033). Accordingly, HA23 would neither meet the definition of deliverable or developable as set out within the NPPF and would therefore be unsound, having regard to the requirements of paragraph 35 of the NPPF. This is a significant conflict which requires resolving, either through the deletion of the Allocated Site or HA23 in the RBWM Borough Plan. It should however be noted that the latter would present significant issues for RBWM, given that it is currently midway through the examination of its Borough Plan and simply deleting a site would render the Plan unsound Given processing will be undertaken at Monkey Use of a conveyor has been explored and rule Island Lane, it would appear that a clear out by the operator for the following reasons: opportunity exists for the use of a conveyor over - Access would still be required for the or under the A308, particularly given that HGVs to import inert infill. Summerleze, the owners of the Allocated site and - A bridge would be required to take the the processing plant at Monkey Island Lane, own conveyor over the A308 (a tunnel would land to the north of the A308, opposite the not be feasible due to a high-water Allocated site. Paragraph 7.96 of the Draft JMWP table). supports this approach noting that “in particular - A bridge would have a landscape and the use of field conveyors and/or site haul roads visual impact and would be expensive. at mineral sites, could be implemented in - A further bridge maybe required to combination with road transport, in order to help access the Monkey Island Lane site. reduce the impacts from road transport.” Whilst - The bridge would need to cross a SSSI. we appreciate that the provision of a conveyor - Third party land ownership would be over the A308 could present some temporary required. adverse visual impacts, this must be balanced against the substantial benefits that would be achieved in environmental and sustainability It is recognised that this information needs to terms through the removal of significant HGV be provided in the Minerals Proposal Study. movements off the A308, particularly given the presence of an Air Quality Management Area at This site was subject to a planning application Bray Wick. Indeed, paragraph 7.95 of the Draft which was subsequently approved. JWMP notes that “alternative methods of Therefore, the site has been ruled out as an transport may provide opportunities to reduce and allocation in the Joint Plan and no further manage impacts of traffic and reduce potential assessments have been carried out. carbon emissions associated with HGV movements. This may help to offset potential impacts on the climate. Alternative methods may include the use of field conveyors…” We would suggest that the detailed policy wording for the Allocated Site on pages 149-151 of the Draft JMWP should be amended to state that if access is proposed off the A308, this should be located as far west as possible, and that consideration should be given to the use of a conveyor across the A308. [relates to paras 5, 6, 7, 8, 9, 10]. Accordingly, we consider that the detailed policy wording should be amended to state that screen planting along the A308 frontage should be significantly enhanced, including the introduction of a bund, for the lifetime of the development. Without such a change, the allocation would be unsound. [relates to paras 12, 13, 14, 15] Support the Water Oakley site allocation and we Noted welcome the inclusion of the draft allocation within the plan, which will contribute to addressing the current shortfall and meeting the requirement within the plan area
Poyle Quarry, Poyle Quarry Ext, Water Oakley, Noted Monkey Island Wharf Summerleaze welcome the inclusion of the sites as draft allocations and welcome the acceptance in principle that the sites are suitable for working to commence during the plan period, subject to satisfying detailed planning requirements. The joint authorities have established that where Noted potential negative impacts have been identified, these can be mitigated and would be outweighed by the benefits associated with allocating this site. As a result, the site has been put forward for allocation in the draft plan. The location of the allocations will allow the Noted company to operate in an efficient manner. For example, the proximity of the draft allocation at Water Oakley and the Wharf at Monkey Island Lane, within close proximity to the company’s existing processing site at Monkey Island Lane will allow the operator to manage fuel consumption, emissions etc associated with transporting material.
Transport Issue Response The Draft JMWP outlines that access to the Routeing agreement would be expected at the Allocated Site is required from the A308. In this time of Planning submission, alongside a context, it is important to note that vehicular Transport Assessment or Statement which access onto land controlled by Farmglade, which would consider the best location for an access benefits from planning permission for residential based on pertinent information at the time of development, is located directly off the A308. In planning. No amendment to STA required. fact this access benefits from planning permission for the introduction of right hand turn filter lane This site was subject to a planning application into land controlled by Farmglade. Where mineral which was subsequently approved. and waste sites are located in close proximity to Therefore, the site has been ruled out as an sensitive receptors, paragraph 7.92 of the Draft allocation in the Joint Plan and no further JMWP advises that “routeing agreements may be assessments have been carried out. required to ensure that access is not permitted on roads which result in unacceptable impacts on communities or the environment.” Accordingly, any access serving the Allocated Site should be located to the west, furthest away from the greater concentration of sensitive residential receptors. Given that the detailed policy wording for the This is noted and the HGV routing strategy Allocated Site establishes that processing will be may be revised once details of a planning undertaken at Monkey Island Lane (to the application are coming forward. In any event, northwest of the site), locating an access as far planning approval of Allocated Site will need west as possible would reduce operational road to be supported by an appropriate Transport miles and therefore the overall perceived impact Assessment or Statement, which will address of transportation. This aligns with paragraph 7.93 issues of road safety, capacity and transport of the Draft JMWP, which advises that “the demand and will include mitigation measures potential and perceived impact of transportation as required. No amendment to STA required. on amenity may include vibration, visual intrusion and air quality. It is therefore beneficial for mineral This site was subject to a planning application and waste development to be located either close which was subsequently approved. to the Strategic Road Network, or where there is Therefore, the site has been ruled out as an potential for the sustainable movement of
materials and/or where operational road miles can allocation in the Joint Plan and no further be minimised” (my emphasis). assessments have been carried out. At the peak of activity on the Allocated Site, the Appendix 1 of the Strategic Transport and Traffic Assessment outlines that there will be up to 162 HGV movements per day. Whilst the A308 experiences fairly high traffic flows in any given day, the introduction of such a large number of HGV movements undoubtedly raises a clear prospect of harm arising to the amenity of future residential occupiers of Farmglade’s site as a result of the inevitable noise, dirt, and dust that would be generated. The severity of this issue would only be exacerbated if a vehicular access into the Allocated Site is proposed opposite or in close proximity to Farmglade’s existing site access (which would be retained and approved as part of the extant planning permission for the site), particularly given it would not be possible to screen mineral extraction activities at the site entrance.
Landscape Issue Response Policy DM9(d) of the Draft JMWP advises that The Strategic Landscape and Visual minerals developments should not “have an Assessment concludes that the site would unacceptable visual impact”. Paragraph 7.73 have a slight adverse impact. further notes that the “screening of sites and other mitigation measures are often required to ensure The Assessment also highlights that the an acceptable degree of potential impact of screening will improve with each year’s minerals and waste developments on the habitats, growth. However, it is considered that the landscape, townscape and local communities.” Footpaths Bray/51A/A, 53/1 and 57/2 require We are aware that there is some existing screening. landscaping along the boundary of the Allocated site fronting the A308 which was planted relatively It is suggested that a ‘tunnel effect’ should be recently and we note that the detailed policy avoided if bunds are used for screening. wording for the Allocated Site states that “existing screen planting around the site should be retained This site was subject to a planning application and protected”. Whilst we support the general which was subsequently approved. approach of the JMWP in seeking to screen the Therefore, the site has been ruled out as an Allocated Site from the A308, we consider that the allocation in the Joint Plan and no further existing screening along the A308 is wholly assessments have been carried out. insufficient as it has failed to establish in many locations and does little, if anything, to obscure views of the Allocated Site from the A308 and nearby sensitive receptors.
Flooding Issue Response In the Water Environment and Flood Risk section Noted – the text will be reviewed and this says: amended. “Part of site within Groundwater Source Protection Zone (3) – a Hydrological Assessment will be This site was subject to a planning application required.” which was subsequently approved. This needs to be changed to: Therefore, the site has been ruled out as an “Part of site within Groundwater Source Protection allocation in the Joint Plan and no further Zone (2) – a Hydrological Assessment will be assessments have been carried out. required.
A Hydrogeological Risk Assessment will be required.”
Archaeology Issue Response According to our records there are no designated The site has been subject to an archaeological heritage assets on this site but it is known to have evaluation and a geo archaeological survey. high archaeological potential. Some pre- This has identified the presence of some application archaeological evaluation has already archaeological sites and confirmed the nature been done at Water Oakley, which lies just across of the archaeological potential of the site. the river from Eton Rowing Lake, where a lot of significant prehistoric remains were found in a No waterlogged deposits were found waterlogged floodplain environment eliminating the possibility of the sorts of The Water Oakley site was found to lie on less- archaeological remains found at nearby Eton significant valley-side deposits, however, and Rowing lake, which is further into the flood appears to be of lesser potential but nevertheless plain, and the geo archaeological deposit we consider that this site should not be taken model does not suggest a potential for forward without further investigation and Palaeolithic sites. assessment of the archaeological interest and significance of the site and of the potential impact There is no overriding archaeological of mineral extraction at this site on that constraint to allocating this site. (A planning significance. application has been submitted with the The allocation of this site should not be taken supporting archaeological information and the forward in the absence of clear evidence that archaeological advisor to the planning extraction at this site would not be harmful to the authority has not raised any overriding archaeological significance of this area. archaeological objection and has indicated that archaeological matters might be conditioned to post determination stage).
This site was subject to a planning application which was subsequently approved. Therefore, the site has been ruled out as an allocation in the Joint Plan and no further assessments have been carried out.
The draft SEA refers to an archaeological Noted – the SA/SEA will be reviewed and evaluation of the site but we are not sure if this is amended. the pre-application evaluation to which we refer above or further assessment. The draft SEA This site was subject to a planning application rightly acknowledges that a considerable range of which was subsequently approved. archaeological material has been found in the Therefore, the site has been ruled out as an vicinity and that the location should be regarded allocation in the Joint Plan and no further as having a high archaeological potential. Given assessments have been carried out. that likelihood, and the fact that the extent, nature and significance of these remains may not be fully understood, we do not understand how the authors of the SEA can conclude that mineral extraction at this site would have a positive effect on heritage assets Unsure what is meant by “extraction in similar Terminology to be reviewed. Intended point Thames floodplain contexts have been able to was: ‘archaeological issues close by of a overcome constraint through archaeological similar nature to those predicted at the mitigation” – what mitigation is there for potential allocation site have been successfully total loss (given that the ability to record evidence addressed by mitigation secured by condition of our past is not a factor in deciding whether and there is no reason to suppose a similar such loss is acceptable) ? We note that Appendix response would be inappropriate in this case’. K of the draft SEA does not suggest any example mitigation measures for the potential harm that This site was subject to a planning application mineral extraction at this site would cause to the which was subsequently approved. significance of the archaeological remains Therefore, the site has been ruled out as an
allocation in the Joint Plan and no further assessments have been carried out.
Additional (site specific) Regulation 18 Consultation on Bray Quarry Extension (2019)
Bray Quarry Extension and proposed development considerations Comments supporting the proposal Summary of comments made supporting the Response / action site proposal
The site proposal will be beneficial to the local Noted. area.
The Bray site would provide an additional Noted. resource of sand and gravel without the need for a new processing plant, HGV movements, silt disposal or infilling on the site.
Additional comments made regarding the site proposal Additional comments made regarding the site Response / action proposal (neither supporting nor objecting)
No objection to the proposed site based on the Noted. consultation not having been carried out in compliance with legal requirements
Summary of comments made on how the proposed site does not meet the Test of Soundness Summary of comments made on how the Response / action proposed site does not meet the Test of Soundness
Unacceptable impact upon the amenity value of Concerns are noted. Consideration of the village / area of Bray. Issues include blight on alternatives is set out in the Minerals Proposal property, noise and impact on the environment. Study. Any proposal would need to comply Little evidence given on what alternatives there with all other policies in the Plan to ensure might be. there is no unacceptable impacts.
Bray is a quiet village and the proposed The proposal involves movement of the excavation area is within only a few hundred material via conveyor which would reduce the meters of accommodation for the elderly as well noise caused by vehicles. Measures to ensure as village allotments. The noise (even with noise is kept at an acceptable level would buffers) will be intrusive. need to be included as part of the proposal.
The proposed site and surrounding area is within The flood-risk is noted, and a proposal would an existing flood zone. After extraction has need to be accompanied by a site-specific commenced, the land would be returned to Flood Risk Assessment as well as a visually pleasing lakes, in the meantime, the Hydrogeological Risk Assessment. water-absorbency capacity in the local zone 3 flood plain would be reduced still further.
There are highlighted risks to water quality in the plan and inadequate support that the proposal will not alter the risk of flooding for properties in Bray village.
The local area is full of wildlife including deer and The comment is noted. is an area of natural beauty.
The proposal will significantly decrease the A proposed development at this site would diversity of local habitats. have to be accompanied by an assessment of the site’s ecological value, how this value would be impacted and how any impacts would be mitigated. A proposal would also have to comply with Plan policies, including Policy DM3: Protection of Habitats and Species and may also require an Environmental Impact Assessment (EIA).
Another example of the use of a “false extreme Mineral extraction is not considered need” being used to justify the erosion of the inappropriate in the Green Belt, but openness Green Belt. needs to be maintained.
The people living in Bray near the proposed site Suitable screening would be required as part will be looking onto an open quarry. People of any planning application. Currently, the should not be subjected to the misery and proposal outlines bunds to provide screening. annoyance that such work will cause. People House value is not a material consideration. living nearby will find their house values sinking.
If the proposed site goes ahead, compensation to Compensation is not a material consideration local residents must be paid and the following in determining an application or consideration may be relevant; of a proposed allocation. https://www.gov.uk/guidance/landcompensation- manual-section-4-disturbance/part-1-disturbance http://www.environmentlaw.org.uk/rte.asp?id=239
The proposed development is too near Bray Historic England have raised an objection to Village which is a conservation area. Concern the proposal. The impact on the Conservation about the damage that would be caused to the Area and Listed Buildings would need to be rural setting of a historically important village, with addressed as part of any planning application. a large epicurean, and tourist trade. Follow up liaison with Historic England is set out in the Heritage Statement. Their objection was subsequently withdrawn. The development should either be smaller or The mineral planning authorities are required elsewhere. Extraction plans are still to ensure a steady and adequate supply of compartmentalising the demand and supply minerals. planning into areas where individual operators have land rights, and installed plant & machinery, Consideration of alternatives is set out in the which prioritises their responses to calls for new Minerals Proposal Study. site towards extending current operations. For example, Barge Farm, which is situated on the eastern side of the River Thames opposite Bray, has huge known deposits of such materials, and has been identified by its owners, within the past 5 years, as being available. Because it falls into the South Bucks Council area, by virtue of an oddity of area mapping, it is not being considered within this context. The demands of Runway 3 at Heathrow, and its associated road and building development, will surely call for these more extensive opportunities to be examined, so why not now?
The trees on the site provide vital protection / It is agreed that retention of the trees around shelter from air, noise and light pollution from the and across the site is highly desirable and it
M4, which has got much worse over the past year will need to be addressed as part of a detailed due to the road widening works. planning application
The Royal Borough of Windsor and Maidenhead The consultation has been carried out in has not taken appropriate steps to engage with accordance with the Statement of Community local residents who will be impacted by this Involvement. proposal.
Sustainability appraisal of the proposed new site Summary of comments made on the Response / action Sustainability Appraisal (incorporating Strategic Environmental Assessment) on Bray Quarry Extension The proposal cannot be justified. The site scored Noted. 'amber' or 'red' on 8 out of the 11 SA/SEA objectives, which is an indication the this is not a suitable site for gravel extraction.
Fully support and well reasoned. Noted. Reference is made to Bray Wick AQMA and The assessment considers the onward vehicle routing, however this is irrelevant as no movement of the material which may impact HGVs will visit the Bray site. All HGVs will visit the the AQMA. Monkey Island Lane processing plant site which has permanent and unrestricted planning Whilst it is recognised that extraction has taken permission to import, process and export sand place adjacent to the site, insufficient and gravel. Objective 2 ground/surface water information is provided to demonstrate that quality - it is not accepted that the SA/SEA there would not be an impact on water quality. judgement should be red. The adjacent Bray Triangle extraction has clearly demonstrated that The SA/SEA assessment on impact on sand and gravel can be worked without any residents is based on proximity. As noted, impact on the water regime. Objective 5 quality of these issues can be resolved by suitable life - it is not accepted that the impact on mitigation measures. residential dwellings should be red or the amenities should be amber. A suitable standoff is Your comments regarding air quality are noted proposed between extraction and residential and the scoring will be reviewed. properties and screenbanks are also proposed. The adjacent Bray Triangle extraction area was a similar distance from residential properties without causing unacceptable impact. The restoration of the site has considerable potential to improve public access and biodiversity. Objective 6 air quality - it is not accepted that the SA/SEA judgement should be amber. The mineral will be transported to the processing plant on conveyors. The processing plant has a permanent and unrestricted planning permission. If Bray mineral was not to be processed at Monkey Island Lane then mineral from somewhere else would be. Objective 7 emissions/greenhouse gas - it is not accepted that the SA/SEA judgement should be amber. There are no HGVs or dump trucks to be used to transport mineral to the processing plant. An electric powered conveyor would be used. Emissions would be minimal. Insufficient weight has been given to the fact that Historic England have raised an objection to the site is too close to residential property, Bray the proposal. The impact on the Conservation village, and its conservation area. Area and Listed Buildings would need to be Bray is an historic village with Grade I and II listed addressed as part of any planning application. buildings including a number of houses which are
more than 100 years old. The area is semi rural Follow up liaison with Historic England is set and is protected from much of the M4 noise by out in the Heritage Statement. Their objection this area. If the area is quarried and the minerals was subsequently withdrawn. extracted are replaced by water, then the environment will suffer badly, the semi rural aspect will go and the noise of the M4 will be worse. Many of the benefits of those fields (the wildlife and calm) will be lost. Within the Sustainability Appraisal Extract, Development considerations for the site Appendix C, there is acknowledgement of the include the requirement for a Hydrogeological proposed location being situated “Adjacent River Risk Assessment. Thames Protected Drinking Water Area”. It is also noted within the Site Specific Assessment, that The Environment Agency have objected to the “Potentially there could be risks to surface water proposed due to their concerns over the and groundwater quality”. However, there is no impact on the public water supply. mention of methods of mitigation, or evidence that the risk to abstraction is fully understood. Follow up liaison with Environment Agency Appendix C states, “The site scored negatively for was undertaken. However, it was not possible SA/SEA Objective 2 (water quality). However, to resolve the issues regarding potential Policies DM9 (Public Health, Safety and Amenity) impact to the public water supply at the and DM10 (Water Environment and Flood Risk) allocation stage. Therefore, the site was ruled would prevent emissions from operation impacting out from further consideration. on water quality”. This is concerning, wherein air- borne emissions may be considered, however there is no apparent consideration mitigation for the risks and potential impact on the shallow water table, beneath and adjacent to the proposed site. Needs to be much more clearly stated including The SA/SEA was carried out in accordance analysis of "sustainability". with the methodology set out in the Scoping Report.
Summary of comments on Habitats Regulations Assessment Summary of comments made on the Habitats Response / action Regulations Assessment: Screening on Bray Quarry Extension Fully supportive. Well reasoned. Comment is noted Insufficient screening to Bray Allotments resulting Comment noted. However, the HRA in a loss of amenity value. Screening Assessment is undertaken in relation to European sites, not for allotments or amenity value. Screening only achieves a limited amount of Comment noted. However, the HRA sound and dust attenuation. Screening Assessment looks at potential effects on European sites. Physical screening against sound and dust cannot be considered at the Screening stage (following legal precedent) and must be considered at the Appropriate Assessment stage. However, the site was screened out of the need for Appropriate Assessment. Rehabilitating the site post extraction is positive Comment noted. The Restoration Study however as a Biodiversity Opportunity Area, the highlights the importance of Biodiversity wildlife in the area during extraction should be Opportunity Areas and the opportunities that addressed as well as the potential disruption to restoration provides for nature recovery at natural habitats. Consideration should be given to the landscape-scale. the proposed site being in The Green Belt. The Plan has an effective Restoration Policy – DM8. Policy DM3: Protection of Habitats and Species is also relevant with a requirement for at least 10% biodiversity net
gain. Policy DM6 covers the issue of Green Belts. On the site there are mature trees covered by tree Development Considerations for the site protection orders, but many of these will be felled. include the need for mitigation tree planting The trees also provide vital protection from air, to replace any mature trees that are removed noise and light pollution from the M4. from the site for operational purposes. The impact of any development on existing trees and vegetation and requirements for additional trees / vegetation to provide screening for noise and light pollution would be considered in detail at the planning application stage. The Habitats Directive Assessment shows Comments noted. One of the Development consideration for water pollution and potential Considerations for this site acknowledges changes to surface/groundwater hydrology with that the site is in a Groundwater Source the following statements respectively, “the site is Protection Zone and a Hydrogeological Risk located 3.63km from the SAC, and is not Assessment will be required. connected to the European site by any vectors that may carry pollution. Therefore, the European The Environment Agency have objected to and Ramsar site will not be impacted from water the proposed due to their concerns over the pollution” and “As the site is 3.63km from the impact on the public water supply. European site, the hazards are considered to have negligible potential to cause a likely Follow up liaison with Environment Agency significant effect”. However, while these was undertaken. However, it was not statements may apply to designated SAC and possible to resolve the issues regarding European and Ramsar sites; there is no specific potential impact to the public water supply at reference or apparent consideration to South East the allocation stage. Therefore, the site was Water licenced public water supply abstraction, ruled out from further consideration. located immediately adjacent to the proposed site. Reference of the proximity of the proposed mineral extraction to the South East Water’s operation, risks to public water supply and appropriate measures to safeguard this source must be considered. Further, the proposal document states that following mineral extraction activities, the current plan is, “…restoration to lakes and wildlife habitats with no backfilling, recovery or recycling”. This option must consider the water quality risks that may impact upon the groundwater, and may result in a future need for South East Water to enhance our water treatment facilities to consider a greater proportion of surface water, within the current groundwater abstraction area. The limited mitigation measures listed in the document provided in relation to this proposal make no reference of groundwater protection. Insufficient detail provided. Noted. Further detail is provided in the full Habitats Regulation Assessment documentation, which the Bray Quarry Screening Assessment is a component of.
Summary of comments made on the Strategic Flood Risk Assessment Statement Summary of comments made on the Strategic Response / action Flood Risk Assessment Statement on Bray Quarry Extension Fully supportive. Well reasoned. Noted. By allowing worked-out sections of land to infill The flood-risk is noted, and a proposal would with water, reduces the ability of the land it need to be accompanied by a site-specific displaces, to absorb more water in times of Flood Risk Assessment as well as a flooding. All technically competent bodies now Hydrogeological Risk Assessment. seem to agree that flooding risks will increase in future, and that the Jubilee River relief scheme cannot be relied on to alleviate the worst outcomes. There are highlighted risks to water quality in the plan and inadequate support that the proposal will not alter the risk of flooding for properties in Bray village.
Summary of comments made on the Strategic Traffic and Transport Assessment Summary of comments made on the Strategic Response / action Traffic and Transport Assessment on Bray Quarry Extension Fully supportive. Well reasoned. Noted. The gravel will be moved by conveyor to the A Transport Statement or Assessment and processing plant, which is a positive step, as far Routeing Agreement would be required as as the village itself is concerned, but the eventual part of any planning application. transportation by lorry will be over increasing congested roads, which will be servicing up to 80% more domestic housing under the Local Plan’s aim to meet Objectively Assessed housing numbers. Commend improvements to access and Public Rights of way and public access form part of Rights of Way post extraction. the proposed restoration proposals. These proposals need to consider the other It is intended that the proposal would proposed work to increase the usage of the commence following the completion of a Monkey Island plant, in particular how the hours current operation and therefore, there would of operation and amount of heavy haulage traffic be no increase in traffic but a continuation of using the lane. present numbers. Operational details would form part of any planning application. Roads already overloaded with health hazards The material would be moved by conveyor to from diesel polluted air. the processing plant in order to reduce vehicle movements.
Summary of comments made on the Landscape and Visual Impact Assessment Summary of comments made on the Response / action Landscape and Visual Impact Assessment on Bray Quarry Extension The Ecological Assessment Summary and the The Development Considerations highlight Ecological Development Considerations both refer those issues which would need to be to "Impacts on Bray Meadows SSSI and Bray specifically addressed as part of any planning Pennyroyal Field SSSI". This suggests that there application. These have been identified will be an impact. This is not correct or justified. through assessment. It is recognised that The wording should be changed to "Potential these can be mitigated through suitable impacts on Bray Meadows..." The Landscape measures, but these would be detailed as Development Considerations state operational part of any planning application. hours will be limited to 08.00 to 16.00. These hours are unnecessarily restrictive and are not The comments regarding working hours are justified. No mention is made of the days in the noted and will be reviewed.
week that these hours relate to. The adjacent Bray Triangle site was not so constrained and did not result in any unacceptable impacts. The site is immediately adjacent to the M4 Motorway. The operating hours need to be 0700 to 1800 Monday to Friday and 0700 to 1300 on Saturday. Why is a Transport Statement required when they are no HGVs involved? This is not justified. The Monkey Island Lane processing plant is permanent and unrestricted in terms of hours or HGVs. Other more suitable sites (which have not been The mineral planning authorities are required brought forward) be examined for appropriateness to ensure a steady and adequate supply of and, if necessary be acquired compulsorily for this minerals. purpose. Secondly that the process of compartmentalising sub-areas within this deposit Consideration of alternatives is set out in the rich county be re-examined for appropriateness. Minerals Proposal Study. No consideration has been made to the impact of The Monkey Island Lane plant has an the Monkey Island Lane plant and surrounding existing planning permission. neighbourhood. The measures suggested for the main extension in the village of Bray should also Concerns raised regarding the operation of be extended to include the lesser and currently the site have been forwarded to the RBWM inadequate noise and disruption rules. In Environmental Health Team. particular, I would like to see similar enforced times of operation and noise reduction measures enforced at the Monkey Island site. The wording of the current plan is very 'woolly' The inclusion of rights of way and mitigation using words like 'opportunity to include rights of planting will need to be addressed as part of way' and 'should' or 'could'. There needs to be a a detailed planning application. positive commitment to include 'Rights of Way' and for the landscaping of the area. Removal of any trees would be detrimental to the Every effort should be made at the detailed landscape and air quality since they are mature planning stage to ensure retention as much trees which cannot be replaced. mature vegetation as possible. Where this is not possible, mitigation and replacement of existing features will need to be part of the application. Forward planting can help to reduce impacts.
Further comments Further comments summary Response / action How much is the Royal Borough of Windsor and Mineral planning authorities are required to Maidenhead going to make to of this as it seems ensure a steady and adequate supply of yet more of our land is being sold off for Council mineral. RBWM is not the landowner of the profit. Bray site. Concerns over noise and air quality during the Any proposal would need to comply with all operational period. The proposed site is close to relevant policies within the Plan to ensure residents and this could have a major impact on there was no unacceptable impact quality of life. The proposed site is too close to the historic Historic England have raised an objection to village of Bray and its conservation area. Tree the proposal. screening would hide the attractive view from Old Mill Lane and give a feeling of enclosure. Bray is Follow up liaison with Historic England is set in danger of becoming an island. No alternative out in the Heritage Statement. Their appears to have been considered. objection was subsequently withdrawn. Concerns over the proximity of the proposed site to listed buildings, such as Jesus Hospital, and the impacts that could result on both the physical buildings as well as the elderly residents who live in the almshouse.
Strong encouragement that the Royal Borough of Windsor and Maidenhead conservation staff are closely involved in the preparation of the plan, as they are best placed to advise on local historic environment issues and priorities, sources of data, and consideration of the options relating to the historic environment. In particular, they should be consulted on the potential impacts on the setting of nearby listed buildings, such as the Jesus Hospital Almshouses, and the Bray Village Conservation Area. The consultation at Bray Village Hall did not Your comments are noted. provide adequate opportunities for residents to Response forms were also available via the communicate with operators, local authority on-line consultation website. Comments and representatives or local councillors. Additionally, questions were welcomed via email or post there were not enough printed response forms as well as at the event. available at the public exhibition. The response form included complicated Your comments are noted. (planning) language (such as “sustainability”, Frequently Asked Questions (‘FAQs’) were “soundness”) which was not fully explained. As made available to help explain some of the such, this hindered some respondents as they felt language but further efforts will be made unable to respond in a simple and straightforward address this for future consultations. way. The consultation has not been carried out with Your comments are noted. The consultation due care and in the fairness of all interest parties. was carried out in line with the Statement of Community Involvement. The proposed site is adjacent to the Bray Historic England have raised an objection to conservation Area and within the Green Belt. The the proposal. aim of the conservation area designation is to protect the wider historic environment. The village Follow up liaison with Historic England is set has a history dating back to mediaeval times and out in the Heritage Statement. Their there are a number of listed properties within the objection was subsequently withdrawn. area. By permitting Bray Quarry Extension site to be included in the Joint Minerals and Waste Plan, The bunds would be temporary features and there would be a significant change in the area's the site would be operational for a limited 3- historic ambiance which will impact and degrade year period and therefore, the impact on the Bray Conservation Area. This will have a openness of the Green Belt is unlikely to be negative impact on the residents of the village, significant. However, this would need to be particularly those who live on Old Mill Lane and addressed as part of any planning adjacent roads, as householders currently enjoy a application. view over open space. If the allocation of the Bray Quarry Extension is permitted, this will be lost. The proposal would need to comply with the The site's location is within the Green Belt and proposed Development Considerations and whilst mineral extraction is not listed as an the relevant policies in the plan in order to inappropriate development for Green Belt, there gain planning permission. The policies seek was concern the use of the site would hinder the to ensure that there are no unacceptable preservation of the openness of the Green Belt. impacts associated with the development. Although the proposal includes the removal of sand and gravel from the Bray Quarry Extension BOA is not a designation. Restoration of site by linking to conveyor infrastructure at Bray minerals sites provides an opportunity to Triangle, thus limiting the volume of road traffic to enhance biodiversity in line with BOA the site, the extraction process would still cause objectives. significant noise and particulate pollution. This associated noise and particulate pollution will Proposal seeks maintain the TPOs and damage the quality of life for residents in the ensure that the extraction does not impact village as well as having an impact on the local the relevant trees. environment. The Bray Quarry Extension site is closely located Further liaison with the Environment Agency to two Sites of Special Scientific Interest (SSSI), and South west water have taken place. Bray Meadow (0.7km) and Bray Pennyroyal Field (1km). As a result, there is a SSSI Impact Zone in It has not been possible to address the the surrounding area and this includes the concerns raised at the allocation stage and
proposed Bray Quarry Extension site. This means an objection from the Environment Agency that significant changes to the local environment stands. Therefore, the site has been in this area could potentially damage conservation discounted as an allocation in the Plan. efforts in the SSSIs, which are protected because of their distinctive flora. Furthermore, part of the site is located in a Biodiversity Opportunity Area (BOA) - a designation which indicates there are substantial opportunities to make positive changes for biodiversity including habitat creation and restoration. The identification of BOAs considers existing concentrations of habitat, important areas for rare species of principal importance and land with potential for habitat restoration. Using the site for mineral extraction would be at odds with the aims of the Biodiversity Opportunity Area (BOA) to enhance natural habitats in the area and therefore I cannot support the proposal. Moreover, there are a number of visually significant tree belts crossing the site which would be impacted if the site is used for mineral extraction. Several of these are mature oak trees which are protected by Tree Preservation Orders (TPOs). Mature trees are a much more valuable environmental resource than young, newly planted trees and removing and replacing trees would impact the local ecosystem. For example, the removal of the trees could potentially impact roosting and foraging bats - a protected species. Additionally, the Bray Quarry Extension site lies within Drinking Water Safeguard Zones - partly in Zone I, Inner Protection Zone and partly in Zone II, Outer Protection zone. The site is also immediately adjacent to the boundary of the River Thames Drinking Water Protected Area. It is important that this is adequately considered during the decision-making process as there is a potential risk to surface water and groundwater quality. A number of serious concerns are raised, against Further liaison with the Environment Agency which further information and assurance is sought and South west water have taken place. that all risks to surface and groundwater quality have been adequately assessed and mitigated It has not been possible to address the for, as well as confirmation from the applicant that concerns raised at the allocation stage and there is no intention to abstract or impinge upon an objection from the Environment Agency groundwater level, flow or yield. stands. Therefore, the site has been It is understood the proposed mineral extraction discounted as an allocation in the Plan. will permanently and irreversibly, remove a large area of the shallow aquifer near to the public water this source, and as such have concerns that all risks to surface and groundwater quality must be adequately assessed and mitigated for, along with confirmation from the applicant that there is no intention to abstract or impinge upon groundwater level, flow or yield. It is strongly advised the applicant consult with the Environment Agency, and ensure they consider and comply with the Environment Agency’s approach to the management and protection of groundwater as outlined within their GP3 document ‘Groundwater Protection: Principles and Practice’ and take all measures and
precautions necessary to avoid deterioration in the quality of groundwater below the site. The consultation documents identify that the development will be within a Groundwater Source Protection Zone, and therefore a Hydrological Risk Assessment will be required for flood risk. There is no mention of the adjacent public water supply abstraction boreholes operated by South East Water. Therefore, adequate consideration must be made for the protection of, and mitigation of risk to the groundwater, both in regards to quality and availability which, to address this risk of impact upon the public water supply. Within the Sustainability Appraisal Extract, Appendix C, there is acknowledgement of the proposed location being situated “Adjacent River Thames Protected Drinking Water Area”. It is also noted within the Site Specific Assessment, that “Potentially there could be risks to surface water and groundwater quality”. However, there is no mention of methods of mitigation, or evidence that the risk to abstraction is fully understood. Appendix C states, “The site scored negatively for SA/SEA Objective 2 (water quality). However, Policies DM9 (Public Health, Safety and Amenity) and DM10 (Water Environment and Flood Risk) would prevent emissions from operation impacting on water quality”. This is concerning, wherein air- borne emissions may be considered, however there is no apparent consideration mitigation for the risks and potential impact on the shallow water table, beneath and adjacent to the proposed site… …Further, the proposal document states that following mineral extraction activities, the current plan is, “…restoration to lakes and wildlife habitats with no backfilling, recovery or recycling”. This option must consider the water quality risks that may impact upon the groundwater, and may result in a future need for South East Water to enhance our water treatment facilities to consider a greater proportion of surface water, within the current groundwater abstraction area. The limited mitigation measures listed in the document provided in relation to this proposal make no reference of groundwater protection. A robust hydrogeological assessment that fully considers the interests of South East Water, and the risks to the public water supply, is required. South East Water would like to reiterate that our primary concern is the aquifer from which we abstract groundwater for public supply purposes, and therefore seek assurance that appropriate consideration and measures have been made to ensure that the availability and quality of the groundwater is not adversely affected by the proposed development. No mention of any changes to the water table in A Flood Risk Assessment and the Bray village environs has been included in the Hydrogeological Assessment would be consultation document. The digging of an required as part of any planning application. extraction pit could lower the water table, and or cause an increased flow of water through the
ground strata. Both of these events could cause settlement to some very old and historic buildings in Bray village. The proposed bunds would have to be large The impact of bunds on the floodplain would enough to ensure, that for nearby properties the need to be taken into account as part of the maximum quarry noise level would meet World site-specific Flood Risk Assessment. Health Organisation guidelines. The size of such bunds would be inappropriate development in the The bunds would be temporary features and floodplain and Green Belt. It is not believed that the site would be operational for a limited 3- these bunds would act as significant pollution year period and therefore, the impact on barriers. openness of the Green Belt is unlikely to be significant. However, this would need to be addressed as part of any planning application.
Any proposal would need to comply with all relevant policies within the Plan to ensure there was no unacceptable impact. Councillors believe this site is not ready to go into It is not proposed that the site would the plan. Previous sites owned and worked by this commence before 2029. However, the need company have a seven metre deep track of trees for prior planting is noted. planted 15 to 20 years prior to the sites being put forward for excavation, but this has not happened at the proposed Bray Quarry Extension site. Concerns about the potential loss of the protected Many of the trees have Tree Preservation trees, which form an important aspect of the Orders and the proposal would need to take village, along with the loss of valuable farm land. this into account and prevent the removal or damage of these trees.
The farmland is not categorised as ‘Best and Most Versatile’. Disbelief there will be any potential gains from Details of after-care and management would working this site. Furthermore, there is no need to be addressed as part of any planning proposal for the transfer of the land following application extraction to either the Local Authority or the Parish Council, which means that the management of the land, post extraction, cannot be guaranteed. At the other end of the proposed conveyor system Concerns regarding existing issues are noted is the existing Monkey Island Lane gravel and the Environmental Health Team have processing plant. This plant has been in operation been informed. for more than forty years and when it started there were very few houses in close proximity to the In response to concerns raised, a new Policy plant. Over time, this situation has changed and (DM15) to consider Past Operator there are now a number of houses directly Performance as a material consideration in adjacent. decision-making is proposed in the Joint The operation at the gravel works has intensified Minerals & Waste Plan. over the last year with the addition of the ready mixed concrete operation. In addition to this, the gravel company has removed a one hundred metre long, 20 or 30 metre wide screen of trees separating the plant from the neighbouring houses. The removal of this screen has resulted in increased pollution for residents (light / noise / dust etc). When asked to consider remedies to resolve the many issues of noise, dust, air quality, other pollution, traffic volumes etc, we are consistently told by our local RBWM councillors that as inadequate permissions were granted ‘before their time’, there is nothing they can now do about the problems currently evident/created by the
processing plant because of these prior permissions - their (councillor) hands are tied? We do not believe it nor that no action can be taken! Was it to be so, how then can the processing plant be considered a modern and efficient plant if there are no environmental controls in place to protect us residents? This issue needs to be urgently addressed by your team in conjunction with RBWM councillors to avoid subsequent repercussions. (*photos submitted with this full response but they have not been included in this report*) Given the current shortage of housing in the UK, Housing proposals are considered as part of consideration should be given to a sympathetic the RBWM Local Plan. The site has not housing development would be more beneficial to been proposed for housing. both the RBWM and the UK in general. The Thames Valley is littered with lakes created from exhausted gravel pits, a large proportion of which provides no benefit to society. I really think we do not need yet another one. The United Kingdom Minerals Yearbook 2018, Mineral Planning Authorities are required to produced jointly by The CBI, the British plan for a steady and adequate supply of Geological Survey and the Mineral Products mineral. The Joint Minerals & Waste Plan Association records the 2017 extraction of covers for mineral planning areas and seeks aggregates to have been 193 millions tonnes. to enable supply up to 2036. Therefore, how does an approximate increase of 0.1% of overall UK aggregates production have Demand for sand and gravel is set out in the any significant benefit to either the local residents Local Aggregate Assessment and the of RBWM or the United Kingdom in general. Minerals Background Study. Estimated total sales value of the 600,000tonnes of sand and gravel to be of the order £10 millions during the three year period. (Not all the extracted materials are suitable for an end use). How will the top soil be removed from the site? Details of this nature would need to be addressed as part of any planning application. This will be terrible for the village of Bray – Noted. glaringly obvious why. Our interest is the middle one of the three sites, The comments regarding Monkey Island with the extension and dredging of the ‘Cut’ to Lane Wharf are noted and impacts on local allow extract material from Taplow area to be businesses and users of the marina would processed in the Monkey Island Lane site. This need to be taken into account as part of the directly impinges upon our tenants and business proposal. and also has health and safety issues needing to be addressed as a result of fuel tanks and pumps The Bray Quarry Extension proposal includes in the same proximity. Concerns about the access movement of the material to Monkey Island along Monkey Island Lane to Bray Marina. Lane by conveyor to reduce traffic Bertholders (circa 400 berths) already have lorry movements. movements to contend with, alongside the disrepair of the road surface and the dust plus noise associated with the gravel distribution. I understand that there is talk of a conveyor belt from the site to the sorting depot on Monkey Island Lane and we would encourage this as keeping lorry movements as low as possible. Obviously health and safety and noise then take precedent, but no doubt would be fully monitored by you. If the conveyor can get all the way between the sites then that must be encouraged. The same comment also applies to the Bray Consultation.
I can see how money is made from extracting Mineral Planning Authorities are required to gravel and sand from the land near Bray. I can plan for a steady and adequate supply of also see how this enables Berkshire to meet its minerals. obligations for extraction of building materials. However, I cannot see how the residents of Bray Details of after-care and management would are going to benefit. There are no SPECIFIC need to be addressed as part of any planning proposals for: 1. Why a company can extract application. resources, make a profit, and not share that wealth with the residents who have to live with the noise, and the long term consequences 2. Long term compensation for the decrease in value of our homes (or increased insurance premiums) due to increased flood risk 3. Perpetuity-based financial plans for the upkeep of the lake. The lake that will be created is forever, and will need maintaining forever. There are no firm commitments for how this is to be funded. Certainly the residents of Bray should not have to fund it. 4. Community projects In other words, I think the division of wealth from the quarry operations is not equitable. The residents – who have to put up with the operation of the quarry, and who have to live with the long-term consequences of the extraction – are not receiving anything like a fair deal. There is one further, separate, comment. The proposed land for the quarry seems to be exceptionally fertile arable land. Carrots are currently grown, and although I am not the farmer, the land appears to produce three crops a year. Surely we should not be destroying fertile arable land and replacing it with another lake – FOREVER ? The strategic road network (SRN) is a critical Further liaison has taken place with national asset and as such Highways England Highways England. Amendments to the works to ensure that it operates and is managed Development Considerations for the proposal in the public interest, both in respect of current were agreed with Highways England to activities and needs as well as in providing ensure the concerns regarding potential effective stewardship of its long-term operation impact on the M4 were addressed. and integrity. We will therefore be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN, in this case the M4. We have reviewed this consultation and its supporting documentation and whilst we understand that there will be no change in traffic volumes resulting from these proposals we are concerned about the proximity of the southern boundary of the proposed quarry extension to the M4 and the potentially significant impact it could have to the M4 and its assets. We also highlight that Smart motorways is proposed for this section of the M4; please see link below for more information: https://highwaysengland.co.uk/projects/m4- junctions-3-12-smart-motorway/ Due to this we will require a meeting with Royal Borough of Windsor and Maidenhead to discuss and identify the viability of this site
Focussed Regulation 18 Consultation (2020)
Area of Search
Summary of comments made supporting the Action / comment proposal With regard to the development of the “area of Noted. search” method and its accompanying map (Figure 1) as part of Policy M4 this on the face of it makes sense in as much as it does narrow down where the authorities are expecting to see applications come forward and as such should speed up the process for those applying. Providing, as stated in the consultation document, the sites are all still assessed under the regular policies once they come forward. (NE) The principle of an Area of Search for sand and gravel and soft sand is supported. It is considered that an Area of Search policy would provide sufficient flexibility to meet any shortfall in aggregate provision during the Plan period. Efforts to plan for a steady and adequate supply of aggregates as required by the National Planning Policy Framework (NPPF) are supported. As such, the concept of an area of search for new reserves of sand and gravel - in response to an identified shortfall in supply - is supported. The plan lists designations to be avoided in defining this area of search and this list appears to be appropriate. CEMEX supports Policy M4 – Locations for Sand Noted. Policy M4 contains criteria for which and Gravel Extraction and the inclusion of areas of non-planned opportunities would be search for new sites within this policy given the considered alongside all other relevant policies shortage of preferred area allocations within the within the Plan. plan. These sites may either be new sites or sites which can be worked as extensions through The prior extraction opportunity is noted and existing sites – within or close to the plan boundary. should be considered as part of the housing The areas of search should be for sand and gravel development. It is also noted that this is not and soft sand reserves. being promoted as a stand-alone quarry. CEMEX would welcome a criteria based policy to a possibility which enable new sites or extension sites which come forward during the plan period to be encouraged and assessed against a series of criteria. This policy should set out environmental and community criteria and how need will be assessed. CEMEX also considers it important to enable the working of sand and gravel under new development sites – housing and commercial before deposits are sterilized. CEMEX is aware of a screening request to Royal Borough and Windsor and Maidenhead for 150 dwellings on land between the M4, London Road and Riding Court Road – “18/01506/EIASCR | EIA screening request for the construction of 150 dwellings with associated access, open space, landscaping and other infrastructure ("the proposed development"). | Land Bounded By M4 And Riding Court Road And London Road Datchet Slough”
CEMEX support that the need for a viability study of working the mineral within this site must be undertaken. Workable sand and gravel should not be sterilised by new development within areas of search. CEMEX consider that this site may contain circa 200,000-300,000 tonnes of sand and gravel. This site could be worked as an extension through Datchet Quarry. The approach to identifying an Area of Search, as a Noted. means of encouraging applications for minerals development in appropriate locations, is sensible and supported. Noting the difficulty for the steady and adequate Noted. provision within the Plan, BCC [Buckinghamshire County Council] are supportive of the Area of Search approach the joint plan is proposing. We consider the approach to be an appropriate method to ensuring that sand and gravel provision within the Central and Eastern Berkshire area is provided for. With consideration to the Area of Search extending to the border of Buckinghamshire we are happy to see that any proposed applications will be assessed against the development management policies in the Plan and so considering any potential cross boundary implications. We would also wish to ensure that the future Unitary Buckinghamshire Council are consulted as an interested party for applications which may have cross boundary implications for example on the transport network or public health. As stated within the adopted Buckinghamshire Minerals and Waste Local Plan, Buckinghamshire does not have a substantial soft sand resource however, we do recognise the need and importance for strategic cooperation between neighbouring authorities and within in the South East when planning for minerals. The Consultation document therefore defines an No comment. ‘Area of Search’ for sand and gravel provision. This includes all of the mineral bearing land to the south of Slough. Policy M4 then states that proposals for sand and gravel extraction will be supported within the Area of Search provided they are needed to maintain the land bank and maximise opportunities of existing infrastructure and available mineral resources. With regard to the development of the “area of Noted. search” method and its accompanying map (Figure 1) as part of Policy M4 this on the face of it makes sense in as much as it does narrow down where the authorities are expecting to see applications come forward and as such should speed up the process for those applying. Providing, as stated in the consultation document, the sites are all still assessed under the regular policies once they come forward.
Summary of comments made on how the Action / comment proposed does not meet the Test of Soundness
In summary the policy is too open ended and fails The term ‘appropriate locations’ is defined to provide sufficient tests. within the supporting text and the We object to this policy as the support it offers to consideration of environmental or other sites (both specifically identified and within the area impacts would addressed through of search) is too open ended and needs to refer not implementation of the other relevant policies only to ‘in appropriate locations’ but also to ‘where within the Plan. adverse environmental or other impacts can be satisfactorily mitigated’. Concern the current criteria for identifying ‘Areas of The Area of Search criteria includes those Search’ is sufficiently broad as to enable locations designations that are specifically referenced in currently designated as Suitable Alternative Natural the NPPF. It is recognized that some Greenspace (SANG) to form part of the search area proposals may come forward in areas which (which is set out in the map on page 12 of the may ultimately be considered unsuitable for consultation document and by way of example, development. However, these should be incorporates Shepherd Meadows SANG, which is reviewed on a case-by-case basis against the located within the most south westerly part of relevant policies within the Plan. Bracknell Forest). SANGs are expected to be maintained for that use in perpetuity and as such, there is the expectation these areas should be excluded from the area of search at the outset, with mineral extraction highly likely to compromise the capacity of SANGs to fulfil their function. This oversight of including SANGs within the area of search is something that needs to be addressed in future consultations. Proposed development sites crossed or in close It is recognized that proposals that come proximity to National Grid assets: Following a forward within the Area of Search may have review of the above Development Plan Document, constraints that need to be taken into we have identified one or more National Grid assets consideration. However, these should be within the area of search. Due to the number of reviewed on a case-by-case basis against the National Grid assets within the area, an exhaustive relevant policies within the Plan. list is not provided in this response. A map showing the location of National Grid assets within the area of search is included with this response [map not included in Appendix B but available for review as and when required] To be considered ‘sound’ the Central and Eastern It is noted that the Jealott’s Hill site is currently Berkshire Joint Minerals & Waste Plan (the “Joint being promoted for development. However, Plan”) needs to be positively prepared, justified, until such time that it is developed, it is effective and consistent with national policy as set considered that the site should remain within out within the NPPF (paragraph 35). the Area of Search as the deposits remain in In terms of the NPPF need to be ‘justified’, the situ. policies within the Joint Plan need to be based on proportionate evidence which demonstrates the The consideration of the suitability of the chosen strategy is appropriate, which, in this mineral deposits for prior extraction as part of instance, would need to demonstrate that it is the development proposal is currently on-going appropriate to define an ‘Area of Search’ for sand and is outside of the plan-making process. and gravel provision which includes land within the ownership of Syngenta at Jealott’s Hill [the ownership plan is referred to but not attached to Appendix B. It can be made available as necessary]. The mineral resource comprises sand and gravels associated with the residual River Terrace Deposits. Whilst the lateral extent of the resource has been identified the quality of the sand and gravel has not been fully investigated. Our clients (Taylor Wimpey, CEG and Syngenta) are jointly promoting a science and innovation park as part of a sustainable new community based on garden village principles at Jealott’s Hill, through the emerging Bracknell Forest Council Local Plan. The case for the proposals for the site is set out
within submissions to the Bracknell Forest Local Plan and are based on clear exceptional circumstances. The site being promoted includes modest areas of land which would, if the Joint Plan were adopted with the approach put forward for consultation, fall within the draft Area of Search for inclusion within draft Policy M4 as shown on Figure 1 (page 12) of the consultation document (Focussed Regulation 18 Consultation: Sand & Gravel Provision and Operator Performance) (February 2020). Planning Practice Guidance (PPG) at paragraph 008 (Reference ID: 27-008-20140306) defines an Area of Search as: “Areas where knowledge of mineral resources may be less certain but within which planning permission may be granted, particularly if there is a potential shortfall in supply.” Although Areas of Search are locations where knowledge about the mineral resource is less certain, the NPPF (paragraph 31) is clear that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence, which should be adequate and proportionate. In this case, to provide a greater degree of certainty about the mineral resource. In order to evaluate the potential mineral resource available within the Jealott’s Hill site area, our clients appointed RPS to prepare a Mineral Resource Assessment (MRA - April 2019) to review of the potential quantum and quality of mineral resource available based upon the available evidence (attached). The MRA primarily relied upon regional geological mapping supplemented by the available site- specific geological data associated with BGS boreholes. The use of geological logs obtained from the British Geological Survey (BGS) found that whilst there is mineral reserve within the site, deposits from these bores were clayey sandy gravel, with RPS describing the findings to indicate a mineral resource mixed in nature, namely sands, gravels and finds. This mix adversely affects the quality of the available mineral resource. Further, based upon the borehole data, the mineral is only a thin unit comprising about 2 metres in thickness. The MRA also looked at factors which may constrain the quantum and quality of resource potentially available, including Buffer Zones to protect existing buildings and roads. These Buffer Zones reduced the potential area of the extractable mineral resource. Through applying appropriate buffer areas, RPS found that such zones cover around 80% of the River Terrace Deposits mineral resources within the Areas of Search within the site. The MRA conducted by RPS estimated that the total overall mass of River Terrace Deposits (including fines) covered by the Area of Search within the site could be in the region of circa 1,387,000 tonnes. However, once Buffer Zones are applied there would be a reduction of extractable resource by circa 80%. This reduction in extractable area would then result in a corresponding reduction
in the total available mineral to about 264,000 tonnes (a mixture of sand, gravel and fines). Accordingly, RPS’s assessment identifies that the available mineral resource is not significant and being a mixture of sand, gravel and fines the quality of the mineral resource is not a high quality resource. Further, RPS is clear that extracting the mineral resource may be uneconomic due to the limited quantum and poor quality of and gravel available and the potentially high processing and sorting costs. The mineral resource is, therefore, of limited economic value and unlikely to be of commercial interests, especially after the Buffer Zones have been applied. The MRA demonstrably provides more certain evidence about the mineral resource at Jealott’s Hill compared to the draft Local Plan. It is recognised that the NPPF (Paragraph 203) makes it clear that it is essential that there is a sufficient supply of minerals and that policies should encourage the prior extraction of minerals (NPPF; paragraph 204), where “practical and environmentally feasible” (our emphasis), if it is necessary for non-mineral development to take place. As already identified, the application of the Buffer Zones for environmental reasons around existing buildings and structures breakup the mineral resource into 5 small areas where the mineral deposit is thin, typically linear in nature and often situated along the periphery of poorly constrained mineral resource areas. These Buffer Zones significantly reduce the volume of viable River Terrace Deposits mineral resource within the site. Whilst RPS state that this may not represent a significant constraint on extraction itself, it does highlight the limited practicable value of extracting the mineral resource. The RPS assessment concludes from the available evidence there is greater certainty that a quantum of mineral resource, which is of mixed type quality and depth, is significantly reduced by required Buffer Zones and is spread across 5 small areas of potential extraction. Given the environmental considerations required alongside any mineral extraction activity, the. extraction of the poor quality sand, gravel and fines from the proposed Area of Search would not represent the sustainable extraction of sand and gravel. Instead, there are other locations identified in the Joint Plan where the quantum, quality and absence of environmental constraints are such that they represent better options for sand and gravel extraction when compared to Jealott’s Hill. Paragraph 3.20 of the Joint Plan refers to “Proposed future development areas have not been excluded, as there may be opportunities for prior extraction of sand and gravel, in line with other policies in the plan.” However, the MRA states that, in the case of Jealott’s Hill, prior extraction before development occurs is unlikely to be economically viable when the quantum and quality of the
resource is considered, the need to process the mineral and the need to reinstate the resulting voids are considered together. The limited value of the resource brings into serious doubt the practicality and commercial viability of extraction prior to development, primarily due to the depth of the mineral, its quality, the sub-division into 5 smaller areas, the high processing and sorting costs. Accordingly, the attractiveness of the potential mineral resource to an operators to extract is very limited. It is clear that the site, a draft allocation within the Bracknell Forest emerging Local Plan for a science and innovation park as part of a sustainable community based on garden village principles, would not present a realistic source of mineral (sand and gravel) in contribution towards the Joint Plan providing for its needs. The inclusion of Jealott’s Hill within the Area of Search identified in Policy M4, on the basis of the findings of the RPS report, would not be practicable and, as such, it would not be justified as required by the NPPF at paragraph 35. Following on from the above, the inclusion of the site within the Area of Search identified by draft Policy M4 would also not be effective as required by the NPPF (paragraph 35). In order to be effective, the inclusion of the site within an Area of Search would need to have some reasonable prospect of coming forward, otherwise, it would give the impression that there is more realistically potential mineral resource than is actually the case. The Joint Plan should make use of information, such as the RPS report attached with these representations, where it provides greater clarity on whether there is any merit at all in the inclusion of land (such as the site) within an Area of Search. The Policy would not be effective by including such land. In summary, our clients’ objections to the Joint Plan are that inclusion of the Jealott’s Hill site within the draft Policy M4 Area of Search would also not therefore be consistent with national policy and would not represent sustainable development. The proposed inclusion of parts of the site at Jealott’s Hill within the Area of Search illustrated on Table 1 of draft Policy M4, would not be sound when considered against the soundness tests within the NPPF at paragraph 35, particularly in that it would not be justified, effective or consistent with national policy. [A number of additional documentation submitted in support of this response. These can be made available upon request]. The Draft Plan does not meet the Tests of The Draft Plan is based on up-to-date Soundness - primarily it relies upon areas of search information which supersedes that of the 2001 where there is no evidence that further sand and adopted Plan. gravel could be extracted. Through draft Policy M4 and the accompanying It is recognized that there are insufficient map (figure 1) provides an indication of the areas of allocations within the Plan to meet future search for sand and gravel reserves. demand. Without local resources, the demand The current Replacement Minerals Local Plan for will have to be met from elsewhere which Berkshire (incorporating Alterations adopted in increases travel. The Area of search is December 1997 and May 2001) illustrates the seeking to demonstrate that suitable resources
current areas of search through showing where are located within the Plan area and there are sand and gravel deposits alongside those encourages proposals which meet the criteria locations subject to a strong or strongest (and comply with all relevant policies within the presumption against extraction on its Proposal Plan). Sheet. The Proposal Sheet also illustrates through a diagonal hatch those reserves which have already been extracted or with planning permission for its removal. In comparing the maps of reserves within the Focused Consultation and the current Replacement Minerals Local Plan, it is clear that the Areas of Search include locations where sand and/or gravel has been extracted. Unless the Joint Minerals Authorities have clear evidence that further reserves can be extracted from these areas, they must consequently be omitted from the Areas of Search shown on figure 1. Comparisons of the extensive tracts where minerals have been or will be extracted occur across Central and East Berkshire are shown below alongside that of the areas of search within the Focused Regulation 18 Consultation document. [maps referred to not included but can be made available upon request]. The examples illustrate the extensive locations within the Areas of Search across Central and East Berkshire where minerals had or were approved to be extracted at the time that the Replacement Minerals Local Plan was prepared. Since then, the areas approved for extraction are likely to have increased through subsequent permissions by the minerals planning authorities and this will consequently further reduce the locations which can be included in an Area of Search. Additionally, the Areas of Search will also include locations where subsequent adopted or submitted Local Plans since adopted on the Replacement Minerals Local Plan will have allocated for non- minerals development. These areas would also not consequently be suitable for extraction. Once these adjustments are made (unless the minerals planning authorities demonstrate the realism of further extraction from earlier sand and gravel workings), a robust conclusion on suitable Areas of Search will be found. With the acknowledgement in the Focused Consultation of the ceasing of the promotion of land south of the A327 between Arborfield and Shinfield in Wokingham Borough for sand and gravel extraction, in order to maintain the minimum 7 years land bank required by the NPPF (paragraph 207), it is essential that the areas of known reserves are not sterilised by non-mineral development. Whilst the preparation of non-minerals related local plan by the authorities in Central and east Berkshire will continue, in order to avoid sterilizing mineral reserves by allocating sites for other uses, these should be focused in areas without these resources to enable future extraction to maintain the minimum 7 year land bank. In summary it is essential that any consideration of the Areas of Search consider the achievability of
extraction within the identified areas, after acknowledging the impact of sand and gravel already quarried. The areas of search maps should therefore be revised to exclude locations where sand and gravel have been quarried. The Plan fails to adequately provide sufficient mineral to meet the areas need or make a contribution towards that of the wider area. Health and safety environment, particularly for Draft Policy DM12 (Sustainable Transport young and old. The roads cannot cope with traffic Movements) states that a Transport now so additional HGVs is daft. Assessment/Statement and routing agreement will be required which will need to outline the potential impacts on highway safety, congestion and demand management as well as any highway improvements which are where required. Unnecessary project for our infrastructure and it The demand for minerals is outlined in the does not lend itself to sustainable development. As Minerals Background Study. The Managed such there is no requirement for this infrastructure Aggregate Supply systems requires that in the locality and thus it can only be considered to mineral planning authority areas which have have failed the positively prepared test. adequate resources to make an adequate contribution. The challenge on effectiveness is self explanatory - All proposals have been considered as set out there is no implementation plan at all. The currently in the Minerals Proposal Study. The only proposed strategy has clearly not considered all alternative is for resources to be resourced possible alternatives and is a reaction to the elsewhere. However, the Managed Aggregate rejection (and subsequent withdrawal of) the Bridge Supply systems requires that mineral planning Farm application. authority areas which have adequate resources to make an adequate contribution. The consultation is being rushed through in The consultation has been carried out in inappropriately short timescales (spanning a school accordance with the Statements of Community holiday period no less) and hence the communities Involvement. most affected will have limited time to review and respond. Duty to Cooperate conversations haven't been had with neighboring authorities (according to the consultation document), and assumptions have been made about the response they are likely to receive.... assumptions which haven't been validated. There is mention of the Aggregate survey taking Aggregate monitoring is undertaken each year, place later this year - surely it would also be but the national survey is undertaken prudent to wait until that has been completed? approximately every 4 years. The latest survey is expected to take place in 2020 but the results of the survey will not be available in time to inform the next stage of Plan-making. Locations that are currently being put forward are The Area of Search criteria includes those residential areas and no tests are being taken into designations that are specifically referenced in account of the damage that will be inflicted on the the NPPF. It is recognized that some communities, wildlife and people in the areas being proposals may come forward in areas which affected negatively. may ultimately be considered unsuitable for development. However, these should be reviewed on a case-by-case basis against the relevant policies within the Plan. I moved 3000 miles away from the country I was Health effects of proposals will be considered born and brought up in, because of the construction under Policy DM9 (Public health, safety and in preparation for the 2022 FIFA world cup. The amenity). health concerns we had for our children could not be ignored any longer. I left my job, my entire family, social structure and friends, to come here so my kids could get a better, healthier future, only for a sand and gravel area to move close to our home and their school. This is NOT acceptable. The
fineness of this type of sand has caused 1000's of respiratory illnesses in adults and kids in Qatar for years. With Acute respiratory infections being number 4 on the 2003 report for Top 10 causes of Mortality/Morbidity. The sand becomes so fine that the nasal passage is unable to prevent these from entering into the lungs. 2 out of 3 woman give birth to children that either suffer from Eczema or Asthma. In 2017, Sidra Medical Center for Children in Qatar, published a report regarding health issues created in children related to this type of sand. I didn't make such a big sacrifice to bring my children here, only for them to continue to suffer all the same health issues they had before. This is not fair.
Summary of comments made on how the Action / comment proposed should be changed Seek gravel extraction locations outside of It is recognized that proposals that come residential areas / away from schools to avoid road forward within the Area of Search may have congestion and detrimental health impacts constraints that need to be taken into No gravel extraction in suburban areas consideration. However, these should be Sand and gravel extraction point should be situated reviewed on a case-by-case basis against the near rail heads so as to remove the product relevant policies within the Plan efficiently and with minimal disruption to the locality with regard to traffic. Withdrawal / rejection of the proposal Noted. There should be a fuller search for sites, not to There have been numerous ‘calls for sites’ as include a site that the BGS maps as having no documented in the Minerals Proposals Study. mineral and the inclusion of the Reading Beds as The Area of Search includes both soft sand an area of search to provide for potential building resources and sharp sand and gravel. sands. The Reading Beds are a deposit that comprises of clay, silt and sand. This geological description from the BGS sets their order quantitively. So that whilst the potential for sand is rare any potential would be ruled out by the current wording of M4 as the deposit is excluded from the AoS. It is not considered that there any objections to the Noted. principle of the policy but the wording could be clearer. To reduce HGVs on Basingstoke Road and Draft Policy DM12 (Sustainable Transport enforce, so routes are tracked and fines enforced Movements) states that a Transport by the council similar to Somerset Council. Assessment/Statement and routing agreement Managing HGVs for building sites in HPC to reduce will be required which will need to outline the pollution levels. potential impacts on highway safety, congestion and demand management as well as any highway improvements which are where required. The Local Planning Authority will normally require a Traffic Management Plan to be submitted and approved before granting consent which will detail the agreed routing strategy (and other issues such as timings, weight restrictions where necessary etc.). This would be completed as a planning condition, which would be enforceable under the planning regulations.
Inclusion of an additional test "where adverse Any proposal would be considered alongside environmental or other impacts can be satisfactorily other relevant policies within the Plan which mitigated" would address adverse environmental or other impacts. The removal of Syngenta’s land ownership at It is noted that the Jealott’s Hill site is currently Jealott’s Hill from the Area of Search. being promoted for development. However, until such time that it is developed, it is considered that the site should remain within the Area of Search as the deposits remain in situ.
The consideration of the suitability of the mineral deposits for prior extraction as part of the development proposal is currently on-going and is outside of the plan-making process. An area of search criteria-based policy to ensure Consulting statutory bodies such as Historic adequate supply - England is a requirement of the planning Historic England notes that this type of approach is process and is part of the planning application advocated in the Planning Practice Guidance, procedures. Therefore, it is not felt that it is where sufficient allocated sites cannot be identified. necessary to outline this within the Plan. We do not object to this approach being taken on the understanding that we are always consulted on all minerals applications in this area. We would like to see wording to this effect included in the supporting text of the policy. This is because it is often difficult to determine the impact a site may have on the setting of a heritage asset. The areas of search are revised to exclude Areas where mineral have been excluded locations where sand and gravel has already been should be removed from the Area of Search. extracted or is proposed to be outlined in However, where development is proposed, accompanying letter [letter not included but can be these areas will not be removed until the made available if required] development has taken place.
Land West of Basingstoke Road
Further assessment or detail of this site has not been carried out following the consultation as insufficient detail was provided by the site nominee. The viability and deliverability of the site could not be demonstrated (as highlighted by the comments raised in the tables below), and therefore, the site has been ruled out as a potential allocation in the Joint Plan.
Summary of comments made supporting the Actions / comment proposed site In the interests of maintaining a viable supply of sand Noted. and gravel and the associated landbank, the additional two sites being promoted are fully supported and go some way to plugging the gap as a consequence of refusal of planning permission at the Arborfield site. We do comment that the actual impact on the landbank is difficult to quantify given the estimated reserves at the Spencer’s Wood site but understand that this is a credible estimate. One of these sites is land and west of Basingstoke Noted. Road, Spencers Wood which is within the Borough of Wokingham and has the potential to provide sand and gravel. The site does not have any impact on Slough. The council supports identification of land west of Basingstoke road for extraction of sand and gravel as this contributes to meeting the need.
Additional comments made regarding the Action / comment proposed site (neither supporting nor objecting) We don’t believe broadly that there are any show Noted. stopping issues for the two sites proposed… The larger site adjacent the Stanford End Mill and River Loddon SSSI (Land West of Basingstoke Road) will need to be adequately assessed with regard to hydrological impacts upon on the SSSI river in order to ensure that there aren’t potential impacts on the flood regime, groundwater flow or water quality.
Summary of comments made on how the Action / comment proposed site does not meet the Test of Soundness General Why is Hampshire County Council involved in Hampshire Services are working in producing a Minerals and Waste Plan for Central and collaboration with the Berkshire Eastern Berkshire? Authorities to assist in the preparation of their Plan. The quantity of aggregate the proposed site would An estimate of the quantity of the provide is currently NOT identified, and there are mineral was provided by the operator three areas of likely negative impact (Table 3.8). and the consultation document was Therefore, I do not understand how site CEB29 meets subsequently updated to include this. the tests of "justification" and "effectiveness" and the document does not explain this to me in clear and simple terms. The mineral survey from 1980 and a local borehole Noted. search on the British Geological Survey website both show mineral extraction at the proposed site is very likely to be unviable.
There is a huge risk this will become a brownfield The proposal included restoration to development after the site has finished operating agriculture and/or wetland habitat. It has been suggested that the site [Land West of Basingstoke Road] could be used for housing but there are concerns that the back-fill material which is claimed to be inert could be toxic and harm new residents. This first background point raises concerns about The forecast for mineral demand and demand for minerals in highly populated areas which I the issues that impact that are set out in acknowledge is beyond the scope of this consultation, the Mineral Background Study. but nevertheless important and highly relevant. It is therefore incumbent on those responsible for mineral extraction planning to challenge the demands placed upon them by existing and potentially misguided policies. It is not surprising that it is proving difficult to identify suitable sites for mineral extraction in this area. That is because it is already highly developed. Under these conditions we should all question the need for mineral extraction within such regions. Connected matters include (a) the validity for additional major development in these areas which might use these minerals, based on the clear need to manage population density, slowdown climate change and be less dependent on globalisation; (b) in the context of these, how can it be an unwritten assumption in the plan documents that it is acceptable to use farmland for purposes other than farming? A local conclusion from these and similar questions about broader policy should suggest reduced expectation and need of major construction activity and that any associated reduced mineral extraction requirements should be conducted well away from existing settlements. I pay rates of a high figure and don’t expect to Noted. experience this sort of application We didn’t want a Gravel Extraction (Farley Farm) in Shinfield and we don't want one in Spencers wood for the same reasons The proposal adds no value to the community, and House prices are not a material would decrease house prices in the area if consideration in decision-making. implemented Bringing disruption to local community, to line the The extraction would provide a local pockets of those who do not live or contribute to this source of construction aggregate. area A quarry would be completely out of character with Quarries are temporary developments the locality and represents a major identity shift in the and can only take place where the area resources are present. The dust generated from the proposed site would Any proposal would need to comply damage and stain nearby buildings, vehicles and with the relevant policies within the Plan trees / hedgerows and where required, mitigation measures can be implemented such as dust suppression. The proposed site is too close to a number of schools The impact on local sensitive receptors and too close to residential areas, including Loddon such as schools and care homes would Court Park Homes for the elderly be taken into account as part of the proposal. The effect of any gravel and sand extraction would Noted. have an impact not only during the time of extraction but prior to it when the infrastructure is being built to allow digging and after when all the gravel has been extracted.
The loss of open spaces and use of land suitable for The proposal included restoration to (food) crop production. As climate change concerns agriculture and/or wetland habitat. are around the reduction in the consumption of meat, there is a greater need for land to be used productively to provide an environmentally friendly food source. The destruction of farmland would also mean fewer plants to absorb carbon This proposal has been submitted in the spirit of The views of the local community are complete disregard for the local community being sought through this consultation process. It is estimated activities at the proposed site will last Draft Policy DM12 (Sustainable for at least seven years. But, by the calculations of Transport Movements) states that a what fits in a lorry, they will not have finished in this Transport Assessment/Statement will time and an application for an extension will be be required which will determine how submitted to the local mineral planning authority the transport of materials will not have an unacceptable impact on the environment or local community based on the developers’ proposals at the time of submission. Acknowledgement that the materials for future The Draft Plan does include proposals development should be sourced as locally as to expand an existing site, but no possible, but why not expand other existing, local further extensions have been submitted sites (e.g. Blackwater Valley pit)? for consideration. This may be due to a lack of suitable remaining resources. There are solar panels across from the proposed site Noted. that would be affected by the dust from the quarrying. Berkshire Unitary Authority’s ‘Local Aggregate There is a requirement for a minimum Assessments’ in 2014 and 2015 concluded that there 7-year landbank. The Plan is seeking to was already a 11-year land bank for gravel and sharp provide aggregate supply up to 2036. sand in the area, which brings into question why this application is even being considered? Insufficient information is available at this stage to Noted. determine whether the site should be taken forward as a potential allocation in the Plan. This proposal is opportunistic and does not accord Noted. with current national planning policies. It is no coincidence the consultation is being run alongside that of the important Local Plan Update for Wokingham Borough Council. The area around Swallowfield and Spencers Wood Extraction of mineral does not exclude has been designated a “strategic development development from taking place. location” by Wokingham Borough Council. The However, this proposal included inclusion of an extraction site goes against restoration to agriculture and/or wetland Wokingham’s own local and core planning policy. habitat. I am a resident of Beech Hill, which is in the West Noted. Berkshire area. Although West Berkshire is not officially included in the consultation, Beech Hill is less than 2 miles from the proposed site. During the live consultation period, the consultation The information on reserves at the site document was amended and republished with were not made available until the additional information on the likely volume of gravel consultation had commenced. The present at the site. This is considered as extremely consultation dates were agreed by the improper. The document should have been locked four authorities, with the additional throughout the consultation period, not least because information provided as it was available people who have based their submissions on the first to aid consultation responses. The version of the document and submitted their estimated reserve only forms one part objections have no opportunity to revise them in the of the site’s information. light of the additional information contained in the second version. The fact that you were willing to do this at the behest of the applicants merely suggests that you are deep in their pocket. It damages your
credibility as an impartial player and calls into question the whole process. It should not have been done and I deplore that fact that you made these changes. Some would surely wish to explore the legality of this action. Please go down to the Kingsbridge and look at the Noted. beauty that this would destroy. It isn’t even one of the three principal sand and gravel areas on Wokingham’s own maps of the geology, and I suspect it just happens to have come up for consideration because the foreign owned pension fund that bought it wants to make quick money. Please be aware that the environmental permits for, Noted. new quarrys, extensions to quarrys and further extraction to quarrys may need new or renewed environmental permits including those that concern waste disposal or recovery at these sites. AWE Burghfield DEPZ - The proposed site falls within Noted. the Detailed Emergency Planning Zone for AWE Burghfield which increases from 1.5km to 3.16km and will be implemented in May 2020 under the new Radiation (Emergency Preparedness and Public Information) Regulations 2019 Nearby yards / areas with horses, donkeys and Noted. alpacas needs to be considered. The noise and air pollution of a quarry will seriously impact the health of the animals and cause them great distress. Local Planning developments are being refused Noted. because of unsustainable infrastructure so it is important that permission for this quarry is not allowed Negative impacts on local businesses such as Lambs Noted, the impact on local businesses Lane Business Park, local liveries sheep bridge farm, would be taken into account. Yvols Farm, The Mill House Hotel (which is also a wedding venue). They support the community (employment wise and / or are integrated into the community) and provide revenue to Wokingham District Council in the form of business rates. Can the Council afford to lose those rates, either when the business folds due to reduction in trade, or move on when the lease expires as it is no longer a desired, safe place to do business? There are many reasons why the plan is not sound. Noted. National Planning policy (NPPF) paragraph 182 introduces the ‘agent of change principle’ and requires that: Planning policies and decisions should ensure that new development can be integrated effectively with existing businesses and community facilities (such as places of worship, pubs, music venues and sports clubs). Existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. Where the operation of an existing business or community facility could have a significant adverse effect on new development (including changes of use) in its vicinity, the applicant (or ‘agent of change’) should be required to provide suitable mitigation before the development has been completed. The assessment of the local population has been There is more detail provided in the trivialized, as described at Objective 5 on p43 of the Sustainability Appraisal (from which this document. What is considered to be the "immediate is an extract). vicinity" or a "low" population number? Any reference
to such matters has to be quantified before it can be argued that they have been “justified”…There needs to be a definitive description of the phrase “immediate vicinity”. Air Quality Mining for sand and gravel has a detrimental impact Any proposals would need to comply on the air quality in the surrounding area. Studies with Policy Draft DM9 (Protecting suggest some particles can travel up to 400m and so health, safety and amenity) which seeks a number of schools / childcare settings including to address air quality issues. Lambs Lane Primary School (370m from the site), Wise Owls Nursery (550m from the site) and Warrens Mitigation measures such as dust Croft Play Area (600m from the site) would be suppression can be required as part of impacted by reduced air quality. Swallowfield pre- a permission. school and the village recreation ground are 750m away from the site There is an increase in suspended particulate matter near sand and gravel extraction sites, and dust from a quarry can cause visible dust plumes and dust soiling. Particles up to 10 micrometres in diameter are fine enough to be breathed in and can cause detrimental health effects. Larger particles can cause soiling and staining damage when they deposit onto property, vehicles and trees. Intermediate-sized particles may travel up to 400m. CEMEX haven't mentioned dust pollution in their air quality reports. How will good governance of the proposed site be implemented and exercised? Diminishing air quality due to the CO2 emissions from HGVs and other associated site traffic Ancient woodland is 0.7km from the site and is very sensitive to changes in air quality The reduced air quality would be incompatible with Any proposals would need to comply Wokingham’s recent climate change emergency with Draft Policy DM 2 (Climate change declaration and the authority’s aim of becoming – Mitigation and adaptation). carbon neutral This proposol promotes carbon dioxide production. It This policy has subsequently been does not give due consideration to the UK’s updated to require new site proposals commitments to reduce carbon emissions under the to be accompanied by a climate change Paris Agreement. assessment which needs to include The generation of aggregates is one of the highest carbon reduction measures and carbon emitting activities that can be undertaken and I monitoring. would expect the Council to have developed a detailed local carbon offsetting plan, consistent with the government's legal commitment to achieve carbon neutrality by 2050, before opening a new site. Even better would be to explore more sustainable alternatives to coarse aggregates to reduce emissions. Traffic / Transport / Highways The local roads, including the proposed site access Draft policy DM12 requires a transport road are narrow, windy and on an incline, all of which assessment for each site which would are unsuitable for use by HGVs. Traffic would quickly consider the impacts of the build if an HGV got stuck behind a cyclist or if an HGV development on the highway network came across another large vehicle using the road and agree an appropriate routing strategy. CEMEX haven't measured traffic pollution particles of There will be a planning requirement for PM10 and PM2.5 - these two are small enough to get an Air Quality Assessment report to be into lungs and trigger or worsen respiratory diseases. submitted with any application alongside the Transport Assessment or Transport Statement which will deal with Air Quality issues.
The section of the road where the proposed site Draft policy DM12 requires a transport access would be has two solid white lines down the assessment for each site which would centre of it. Therefore, when leaving the site, HGVs consider the impacts of the would undoubtedly cross these two lines, creating a development on the highway network hazard and entering into the path of oncoming traffic and agree an appropriate routing strategy, Alongside highway mitigation works and measures to provide appropriate access and egress. Increased risk of accidents posed by the increased Draft policy DM12 requires a transport numbers of HGVs using the surrounding roads. One assessment for each site which would narrow pavement is the only designated path for consider the impacts of the pedestrians along the B3349. It is used (as bus development on the highway network services have decreased) by vulnerable people and agree an appropriate routing including the elderly (some of whom live in nearby strategy. This assessment would sheltered housing), school children and their parents. include any impacts on road safety. With increased traffic movements because of the proposal, these people would be put at an even higher risk Lorries have, in the past, mounted the pavement Draft policy DM12 requires a transport along the B3349 and there are concerns this would assessment for each site which would worsen with the increased volume of lorries on the consider the impacts of the road with the potential implementation of the site development on the highway network and agree an appropriate routing strategy to ensure safe operation. The Transport Assessment or Transport Statement will also require developers to consider highway improvements to provide appropriate mitigation Further frequent HGV movements on all surrounding Noted. roads will quickly degrade the already poor road surfaces The report contends the increase in the number of Draft policy DM12 requires a transport HGVs would amount to 1%. However, they would assessment for each site which would pose a significant hazard, particularly to cyclists, when consider the impacts of the turning in and out of the site as they will block almost development on the highway network the whole road whilst turning and probably not allow and agree an appropriate routing clearance for on-coming or following cyclists. strategy. Site access design would be included in this assessment and would require tracking drawings to demonstrate safe operation can be achieved. Houses along Basingstoke Road rattle and shake as Protection of amenity is outlined in draft HGVs drive by Policy DM9 (Protecting Public Health, Safety and Amenity). Risk that Lambs Lane and Whitehouse Lane would be Draft policy DM12 requires a transport used as a ‘short cut’ by site traffic, including HGVs assessment for each site which would consider the impacts of the development on the highway network and agree an appropriate routing strategy. Some [HGVs] may, whether forbidden or not, turn The Local Planning Authority will south which leads to the bridge over the Loddon. This normally require a Traffic Management bridge has already needed serious work over the last Plan to be submitted and approved two summers and was not built for frequent use by before granting consent which will detail larger vehicles the agreed routing strategy (and other issues such as timings, weight restrictions where necessary etc.). This would be completed as a planning condition, which would be enforceable under the planning regulations. The document contains no suggestion of the number Information regarding HGV movements of HGV movements, but it is noted that it is intended was not made available to the
to fill the diggings with ‘inert’ materials, so the number authorities, and it was therefore not of movements will be approximately twice the number possible to include it as part of the required to remove the gravel. consultation. There is a requirement to produce and provide a No comment required. Transport Assessment / Statement and an HGV Routing Agreement, and consult as necessary under the Duty to Cooperate on these documents The junction where the Basingstoke Road joins Draft policy DM12 requires a transport Swallowfield Street is already an accident blackspot. assessment for each site which would consider the impacts of the development on the highway network, including road safety, and agree an appropriate routing strategy. There is no access point to the site that is safe with Draft policy DM12 requires a transport good visibility spays. assessment for each site which would consider the impacts of the development on the highway network and agree an appropriate routing strategy. Site access design would be included in this assessment and would require tracking drawings to demonstrate safe operation can be achieved. The increase in traffic should be judged along with the The Strategic Transport Assessment already rapidly increasing volumes of traffic using the has considered traffic impacts with local road network, especially Basingstoke Road and regard to all information available at the around Junction 11 of the M4. There are also time of completion. In relation to traffic proposals to build 15,000 new homes in the local flows, this includes available area, so this should be considered – in terms of information from the authorities’ Local volumes of traffic – alongside the proposed minerals Plans. site. General increase in background growth of traffic outside of Local Plans has not been included in the assessment – if it were included, the proportionate impact of motor traffic generated by the proposed sites would be lower than the assessment. The assessment therefore represents a robust, worse-case impact assessment. Highway safety risks are on a rising trajectory and Draft policy DM12 requires a transport cannot be ignored. Excessive speeding along B3349 assessment for each site which would is a constant problem and the proposed entrance consider the impacts of the adjacent to the footpath by Mill House will only make development on the highway network, matters worse. including road safety, and agree an appropriate routing strategy. The plans are inconsistent with the Highways Draft policy DM12 requires a transport planning policy insufficient access to the site. assessment for each site which would consider the impacts of the development on the highway network and agree an appropriate routing strategy. Site access design would be included in this assessment and would require tracking drawings to demonstrate safe operation can be achieved. Lambs Lane that runs round half the site is a safe Draft policy DM12 requires a transport route for the many horse riders in the area. assessment for each site which would consider the impacts of the development on the highway network, including road safety, and agree an appropriate routing strategy. Flooding
The site lies within Flood Zones 1, 2 and 3b in Noted. accordance with our [Environment Agency] flood map for planning. Flood Zone 3 is defined as having high probability of fluvial flooding in accordance with Table 1 ‘Flood Risk’ of the Planning Practice Guidance. The Loddon main river lies adjacent to the site running along the south eastern boundary of the site. The site lies on top of a secondary aquifer. Fluvial flood risk management - Sequential Test – We A Sequential test will be carried out to [Environment Agency] have reviewed the paper for support the Proposed Submission Plan. the site allocation at Land west of Basingstoke Road and the application of the sequential test needs to be Further assessment or detail of this site included for this site. In accordance with paragraphs has not been carried out as insufficient 157 and 158 of the National Planning Policy detail was provided by the site Framework (NPPF) the sequential test will need to be nominee. The viability and deliverability applied for all development in Flood Zones 2 and 3 of the site could not be demonstrated, regardless of its use. and therefore, the site has been ruled We have read the revised wording for policy M4. out as a potential allocation in the Joint Please apply the sequential test to the new quarry Plan. sites and extensions to quarrys within Flood Zones 2 and 3. You will also need to apply the sequential approach to different types of development with the minerals extraction sites such as locating more vulnerable equipment and buildings associated with minerals extraction in the areas of lowest flood risk such as offices and processing equipment. Please refer to tables 1,2 and 3 concerning flood risk and flood risk vulnerability in the Planning Practice Guidance. Flood Risk Assessment - A detailed flood risk Noted. assessment of the site needs to be provided which needs to include how the site will be operated but if Further assessment or detail of this site we were consulted on this local plan we could not find has not been carried out as insufficient the site unsound. Appendix A, Table 3.7 of the SEA detail was provided by the site needs to be amended to state the Land west of nominee. The viability and deliverability Basingstoke Road is located in FZ3b. We are pleased of the site could not be demonstrated, to see a commitment to not increase flood risk and therefore, the site has been ruled elsewhere and to design to reduce flood risk out as a potential allocation in the Joint Plan. The water table is low in places and the smell from it Noted. abominable in a dry Summer. A number of flood warnings have been issued Noted. recently and this proposed site (if it goes ahead) will only going to compound the issue If barriers were built to prevent the area flooding whilst Noted. the site was being excavated, this would change the ecology of the SSSI and be detrimental to the animals, birds and plants that currently inhabit the SSSI and flood plain. Flooding at the southern end of the site is an annual Noted. event. There is also surface flooding and a higher than normal water table at the northern end from the soakaways of ground and roof rain water from the adjacent business park. Vast areas of natural drainage are being removed and Noted. the area cannot cope with a further decimation of this drainage. The inability of the local landscape to absorb rainwater will result in the water being directed elsewhere along the River Loddon leading to flooding further downstream including built up areas. Water Quality
It is strongly recommended you cover pollution This information is noted. prevention and water supply for this site allocation in order to be consistent with NPPF paragraphs 20 and Further assessment or detail of this site 170. has not been carried out as insufficient Pollution prevention of the River Loddon groundwater detail was provided by the site aquifers and water resources are issues which need nominee. The viability and deliverability to be included in the Development Considerations and of the site could not be demonstrated, the Site Description tables. and therefore, the site has been ruled The water framework directive (WFD) and water out as a potential allocation in the Joint quality - The River Loddon has a Moderate ecological Plan. status for Water Framework Directive (WFD). The main reasons for this are barriers and habitat, and pollution from agriculture and sewage treatment works. Given the rivers location and SSSI status, we would have various concerns surrounding the protection of this waterbody. There is a great risk of runoff from the site reaching the Loddon, which would impact on water quality as well as increased sedimentation. There is the potential for this proposal to be highly detrimental to the waterbody and its ability to reach good status by 2027. This river is also in the Safeguard Protection Zone for drinking water and scheme assurances would be required that this would not impact the quality of the drinking water. In order to make this site appropriate, work must be undertaken to ensure that there are no adverse effects from the site to the river, and a Net Gain approach would be recommended. We would welcome a WFD element to be included within the hydrological assessment. Groundwater and hydrogeological risk assessment - a detailed hydrogeological assessment will need to be carried out for this site. The assessment must include the following: o Impacts on the near-by abstraction licence TH/039/0024/004/R01 o Impacts on the Stanford End Mill and River Loddon (SSSI) o If there are plans for dewatering at this site, an abstraction licence may be needed and therefore an impact assessment will need to be carried out. We need to know that groundwater quality and supply will not be adversely impacted as a result of the proposed sand and gravel extraction Environment The land is currently farmland adjacent to the River This information is noted. Loddon with Footpath 19 crossing the site from Kingsbridge Hill to Basingstoke Road Further assessment or detail of this site The proposed site is in an environmentally sensitive has not been carried out as insufficient location as recognised in Wokingham Borough detail was provided by the site Council’s evolving Local Plan Update. The river nominee. The viability and deliverability Loddon is at the southern end of the site and to quote of the site could not be demonstrated, from the LPU “watercourses are vital to the borough; and therefore, the site has been ruled they provide a range of habitats, act as wildlife out as a potential allocation in the Joint corridors and are rich in biodiversity. They form a key Plan. aspect of the borough’s ecological network. There are three lowland river valleys across the borough: the Thames, Loddon and Blackwater. They make a significant contribution towards the character of the landscape”.
Amenity Loss of the amenity of the footpath during This information is noted. development Increase in noise pollution (from both the operational Further assessment or detail of this site site and the associated site traffic) which could has not been carried out as insufficient exceed existing levels in a rural setting. The WHO detail was provided by the site suggest levels of 55dB can cause health issues for a nominee. The viability and deliverability community. The current average for this countryside of the site could not be demonstrated, setting is 29dB. A quarry of this type will have noise and therefore, the site has been ruled levels of 55dB with spikes to over 70dB. out as a potential allocation in the Joint Dust generated from the proposed site would Plan. decrease visibility and would increase mists and fogs as the dust becomes seeds for droplet formation. Concerns regarding light pollution from the proposed site I am surprised that the lessons have not been learnt from the recent rejection of mineral extraction plans at Bridge farm between Shinfield and Arborfield. Fortunately, sense prevailed there. Given what ought to be a general conclusion that mineral extraction should be planned well away from existing settlements, it is extremely surprising that this planning proposal (CEB29) makes a neutral assessment on "lifestyle impact"…How can such a fundamental planning assessment criterion not be seen as negative in the context of a structured planning document? Not to do so when it is so obvious would seems like an act of desparation to comply with the demands of overriding (and probably outdated) mineral extraction policies such that planners are prepared to consider jeopardising the lifestyle of residents in this area Local families, drive and walk this stretch of road constantly for access not only to and from the Infant and Primary School but also to the doctors' surgeries, the village halls - for toddler groups, meetings, clubs/sport/leisure activities, hall hire and access to recycling facilities. There is much social contact maintained throughout these villages, the various local shops and pharmacy are also close to this proposed gravel pit and the use of local facilities like the childrens' playgrounds, tennis clubs and tea rooms would be adversely impacted. Walks around this beautiful area will be gone - they must be protected for future generations Negative (physical and mental) health impacts, including (but not limited to): o Vulnerable groups including those with existing respiratory illnesses (such as asthma) and those with existing mental health problems; o Vehicle pollution – diesel emissions; and Site pollution risks including the implications associated with exposure to crystalline silica and quarry operations potentially causing heart attacks, strokes, hypertension and autoimmune diseases Landscape The site is highly visible from the road and footpath This information is noted. and this development would cause a loss of visual amenity
The site is a landscape of distinctive character which Further assessment or detail of this site would be lost has not been carried out as insufficient The site is located between Spencers Wood and detail was provided by the site Swallowfield and provides a green gap for these nominee. The viability and deliverability settlements. In doing so, it allows each village to of the site could not be demonstrated, maintain its own identity as well as safeguarding and therefore, the site has been ruled against any further urban sprawl from south of the M4 out as a potential allocation in the Joint through the villages of Three Mile Cross and Plan. Spencers Wood. Additionally, it keeps in check the prospect of Lambs Farm Business Park expanding south towards the Loddon Valley. Without question this is a very sensitive location that should be preserved. This whole area has been subject to very significant development through building, such that any green farm land or amenity land should be retained The proposal is likely to negate benefits of establishing SANGs as part of the South of the M4 development, encouraging people to travel, by car, for recreational purposes to other sensitive environments which the SANGs are intended to protect. Ecology The site is currently farmland and is home to a range This information is noted. of wildlife including (but not limited to) herons, bats, badgers, skylarks, tree creepers, water voles and Further assessment or detail of this site protected species including barn owls, red kites and has not been carried out as insufficient great crested newts. There are also invertebrate detail was provided by the site species such as white admiral, small heath and stag nominee. The viability and deliverability beetles of the site could not be demonstrated, The site borders the highly sensitive Standford End and therefore, the site has been ruled Mill and River Loddon SSSI. Even working the site out as a potential allocation in the Joint with a buffer zone to the river, flash storms could Plan. easily wash site material into the river harming wildlife. There is real concern of pollution of the river and leeching from the “inert” materials used in backfill once the site working life has completed The site is part of a sensitive ecosystem and it has been identified that rivers can act as corridors for wildlife. This development would have extensive and far reaching impacts on wildlife along the river – not just at this location. Strategies to try and work around this are not practical as the site is directly beside the river The site is a haven for birdlife as well as records of sea trout having been identified recently. It is an important local bird habitat for linnets, stone curlews (these have nested on the site), buzzards, kingfishers and redwings and a foraging area for barn owls and bats You will need to include snakes head fritillary (nationally rare), and Loddon pondweed (very rare, and this is the national stronghold) in your ecological assessment of this site. (We are pleased to see that you have included the River Loddon and the SSSI as part of the site considerations). Standard base line assessments will be necessary (plants, badger, bats, reptiles, water voles and otters) and incorporating the recommendations for protection and enhancements into the scheme; a biodiversity calculator should be provided to demonstrate net gain and the loss/disturbance of each type of habitat
An ecological buffer zone will need to be provided from the top of the riverbank for the River Loddon. We are pleased to see that you have stated that a 20 metre wide buffer zone will be required and that existing vegetation here will be protected. There are also opportunities for enhancement such as, deculverting of the watercourse that runs from Lamb’s Lane to the Loddon, creation of wetland areas (which increase biodiversity and contribute to net gain and habitat improvements for water voles drains and ditches). An otter survey should be carried out in addition to the ones suggested as populations are expanding. The allocation of this site does not align with the biodiversity mitigation hierarchy, which requires potential harm to biodiversity to be avoided in the first instance (NPPF 2019, para 175a). The environmental damage that could be caused to the Loddon Valley is contravention of existing EU directives on the aquatic environment The local fishing club has done a lot to renovate the gravel spawning areas in the river and the dust and spillage from a quarry would swamp these with mud and silt and seriously degrade the health of the river. The proposed site is underlain with a network of springs – how will pollution be managed from this perspective? The area and it's natural flora and fauna will never recover if the proposal goes ahead Swallowfield Fishing Club have undertake substantial habitat improvement works to it's waters which start within 50 meters of the downstream boundary of the proposed works. These works have involved consented in stream habitat improvements involving the establishment of spawning reds and off line flood attenuation pools and leats for the encouragement of fish refuge points and natural breeding points. The Loddon catchment is considered to be under severe stress due to the existing permitted developments in the area already. Restoration The restoration opportunity should be designed to This information is noted. achieve a significant biodiversity uplift (at least 20% against the baseline) and enhancements should be Further assessment or detail of this site ensured permanently and seek to meet the objectives has not been carried out as insufficient for the Loddon Valley South Biodiversity Opportunity detail was provided by the site Area nominee. The viability and deliverability Any restoration of the area to agricultural land use of the site could not be demonstrated, should be to High Nature Value farming and therefore, the site has been ruled Design for restoration should increase habitat out as a potential allocation in the Joint connectivity across the area. Plan. What is to happen to the site when it no longer supplies gravel? Landfill, wasteland would be the next eyesore Does the gravel company or Wokingham Borough Council take financial responsibility for returning the used site back to an acceptable view? If the Council can confirm this, will this come from local taxpayers? In Fill of Quarry - contamination risk indications are that building materials will be used to infill the quarry yet most of the materials used in the building industry
are not in themselves inert containing many impurities. What is the method of containment of infill materials being adopted to prevent leaching into surrounding areas? Archaeology / Historic Environment The location is an Area of High Archaeological This information is noted. Potential. There is a WW2 Pillbox and anti-tank ditch within site, part of a pattern of artefacts set along an Further assessment or detail of this site historical defence line. Three listed buildings are has not been carried out as insufficient located near the site, as well as the Scheduled detail was provided by the site Ancient Monument of Island House with its medieval nominee. The viability and deliverability moat at Sheepbridge Court Farm. A nationally of the site could not be demonstrated, important archaeological site, quarrying nearby could and therefore, the site has been ruled have an indirect impact on the archaeological out as a potential allocation in the Joint significance of this monument. Plan. During archaeological digs at the Langford Park development nearby, a Romano-British field system was discovered revealing the possibility of Roman remains in the wider area. If this proposal is to proceed, it will directly lead to the damage and alteration of the moat and fishponds at Sheepbridge Court by accelerating their silting and eventual disappearance by them filling with increased soil runoff from the quarry. The site is close to Beaumy’s Castle, an area of high archaeological importance This site is located very close to both a scheduled monument (MOATED SITE AT SHEEPBRIDGE COURT) and three listed buildings, (MILESTONE NORTH NORTH WEST OF SHEEP BRIDGE, GII; BARN APPROXIMATELY 80 METRES NORTH OF SHEEPBRIDGE COURT, GII*; and SHEEP BRIDGE COURT, GII*). Most of the site is also within an area of high archaeological potential. The above-listed heritage assets, as well as the area of high archaeological potential, have been identified in the table associated with the site, but the scheduled monument has been included within the listed buildings section. These are different types of heritage assets and for clarity should be listed separately. Historic England has some concern about the prospect of this site being allocated for the extraction of sand & gravel, on the basis of the currently available information, mainly in relation to archaeology. We also have some concerns in relation to the aforementioned listed buildings. The impact on the significance of the scheduled monument, as contributed to by its setting, will need to be fully assessed. There is a considerable amount of screening, but noise will also have to be considered. We agree with the comments made about restoration and setting in the focussed consultation document. Because this site lies within an area of high archaeological potential, archaeological remains may exist which are of equivalent significance to designated assets, that is, of national importance. Footnote 63 of the NPPF states that: “Non-designated heritage assets of archaeological interest, which are demonstrably of equivalent significance to scheduled monuments, should be considered subject to the policies for designated heritage assets.” NPPF para 194 states that: “Any harm to, or loss of, the
significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: … b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.” Historic England therefore strongly recommends that the next stage of detailed assessment for the allocation should include at least geophysical survey and possibly, depending on the results of the geophysical survey, field evaluation (trial trenching). Within the Historic Environment Assessment Summary section of the site assessment, it is stated: “However, such sites are likely to be discrete and of regional importance and as such unlikely to constrain the allocation. Preliminary archaeological survey prior to the determination of any future planning application is recommended.” With respect, we do not agree with this. Geophysical survey and possibly, depending on the results of the geophysical survey, field evaluation (trial trenching) should be carried out prior to allocation. The wording is also unsatisfactory in that ‘Preliminary archaeological survey’ is too vague. Possible dewatering of waterlogged archaeological deposits in the areas around the site, including the scheduled monument, should also be assessed, as noted in the consultation document. While the aforementioned listed buildings have been identified in the summary table accompanying this site, there is no further analysis of the impact on them in the more detailed Historic Environment Assessment Summary. These heritage assets are screened to some extent from the proposed site, but the impact on settings still needs to be considered. An appropriate buffer may be required, especially in relation to the grade II* assets, which are assets of the highest significance, according to the NPPF.
Summary of comments made on how the proposed Action / comments site should be changed Considerably more detailed information regarding the Further assessment or detail of this area’s hydrology is needed to inform this stage. site has not been carried out as The inclusion of a water framework directive (WFD) insufficient detail was provided by the element within the hydrological assessment would be site nominee. The viability and welcomed / advised. deliverability of the site could not be A detailed hydrogeological assessment will need to be demonstrated, and therefore, the site carried out for this site. has been ruled out as a potential The application of the sequential test needs to be allocation in the Joint Plan. included for this site. A detailed flood risk assessment of the site needs to be provided which needs to include how the site will be operated. To be consistent with NPPF paragraphs 20 and 170, it is strongly recommended you cover pollution prevention and water supply for this site allocation.
This river is also in the Safeguard Protection Zone for drinking water and scheme assurances would be required that this would not impact the quality of the drinking water. To make this site appropriate, work must be undertaken to ensure that there are no adverse effects from the site to the river, and a Net Gain approach would be recommended. You will need to include snakes head fritillary (nationally rare), and Loddon pondweed (very rare, and this is the national stronghold) in your ecological assessment of this site. Standard base line assessments will be necessary (plants, badger, bats, reptiles, water voles and otters) and incorporating the recommendations for protection and enhancements into the scheme; a biodiversity calculator should be provided to demonstrate net gain and the loss/disturbance of each type of habitat An otter survey should be carried out in addition to the ones suggested as populations are expanding An ecological buffer zone will need to be provided from the top of the riverbank for the River Loddon. This site is located very close to both a scheduled monument (Moated Site at Sheepbridge Court) and three listed buildings, (Milestone North North West of Sheep Bridge, GII; Barn approximately 80 metres north of Sheepbridge Court, GII*; and Sheep Bridge Court, GII*). Most of the site is also within an area of high archaeological potential. The above-listed heritage assets, as well as the area of high archaeological potential, have been identified in the table associated with the site, but the scheduled monument has been included within the listed buildings section. These are different types of heritage assets and for clarity should be listed separately. The impact on the significance of the scheduled monument, as contributed to by its setting, will need to be fully assessed. There is a considerable amount of screening, but noise will also have to be considered. Because this site lies within an area of high archaeological potential, archaeological remains may exist which are of equivalent significance to designated assets, that is, of national importance. To remain in line with the NPPF (Footnote 63 and paragraph 194), Historic England therefore strongly recommends that the next stage of detailed assessment for the allocation should include at least geophysical survey and possibly, depending on the results of the geophysical survey, field evaluation (trial trenching). The wording is also unsatisfactory in that ‘Preliminary archaeological survey’ is too vague. While the aforementioned listed buildings have been identified in the summary table accompanying this site,
there is no further analysis of the impact on them in the more detailed Historic Environment Assessment Summary. These heritage assets are screened to some extent from the proposed site, but the impact on settings still needs to be considered. An appropriate buffer may be required, especially in relation to the grade II* assets, which are assets of the highest significance, according to the NPPF. Do not proceed with the gravel pit; the proposal needs to be refused / rejected. Re locate the gravel pit away from schools, residential areas and areas of green land. Explore the possibility of locating it closer to Basingstoke (allowing site traffic easier access to the A33) or somewhere close to the RE3 recycling centre Consideration needs to be given to those who live and This is the purpose of the consultation. pay to live in the local area To cease the desire to cover our land with further There is a requirement for mineral buildings and extract vital minerals from the land planning authorities to provide a steady and adequate supply of minerals. The proposal does not meet air quality, traffic, flooding, Any Proposal would need to comply environmental, ecology and archaeological with the relevant policies in the requirements of the area. Minerals & Waste Plan.
Area between Horton Brook and Poyle Quarry
Summary of comments made supporting the Action / comment proposed site The inclusion of this area as a Preferred Area in Noted. the Joint Minerals and Waste Plan is supported. The area was originally included within the Preferred Area 12 North of Horton site which is included in the existing Replacement Minerals Local Plan for Berkshire as an area suitable for mineral extraction and subsequent infilling. This was prior to the Preferred Area being developed in two parts. Because extraction operations at Poyle Quarry Noted. have yet to commence to the east of the area it would be straightforward to work the area from the east. If the sand and gravel between the two sites was not extracted it would be permanently sterilised as it would be almost impossible to revisit the area to extract the mineral once the Horton Brook and Poyle sites had been worked and restored. It is the logical candidate since it is an extension of Noted. existing quarrying activities and therefore less intrusive than that associated with a greenfield site. Mineral extraction is temporary in nature. The Noted. No comment or amendment required. proposal will provide for diversion of the bridleway during the period of extraction and restoration. The bridleway will then be reinstated to its former route. Sympathetic restoration through improvements to amenity and increased biodiversity will lead to a long-term gain. This will be achieved through the planting and maintenance of trees and hedgerows either side of the route. Noted. Both quarries have suitable vehicle access No comment or amend required. and the development will not result in an increase in daily traffic movements which are limited by existing condition. Mineral extraction is an acceptable form of Noted. development within the greenbelt as it does not impact upon its long term “openness”. Inclusion of this area will help provide a steady and Noted. adequate supply of locally extracted sand and gravel. This conforms with the guidelines set out in the National Planning Policy Framework. In the interests of maintaining a viable supply of Noted. sand and gravel and the associated landbank, the additional two sites being promoted are fully supported and go some way to plugging the gap as a consequence of refusal of planning permission at the Arborfield site. All sand and gravel would have to be transported Noted. No comment or amend required. by dump truck either to the Poyle Quarry processing plant, which is in Slough, or else to the Horton Brook processing plant to the west. This would result in additional HGV movements on roads within Slough but it is claimed that the magnitude of change on the roads would be negligible. The Plan recognises that a Transport Assessment or Statement will be required and an
HGV Routing Agreement will be needed. As a result it is considered that any mitigation measures that may be necessary can be agreed at the planning application stage. A temporary diversion will have to be provided for Noted – an amendment made to the bridleway which forms part of the Colne Valley Development considerations. Way It will be important to maintain and enhance the Colne Valley Way bridle way. This is described as being not very attractive at present with the user hemmed in between two fences. The Council, along with the Colne Valley Park, RBWM and the Buckinghamshire authorities have been examining how the public footpath network and accessibility in the area can be approved as part of the work that has taken place in response to the proposed expansion of Heathrow. As a result we have agreed a Joint Connectivity Statement. This identifies a network of alternatives routes that run along the north and south boundaries of the existing and proposed gravel extraction sites. Some of these new routes could be implemented regardless of whether or not the expansion of the airport takes place. As a result it is suggested that there should be a requirement for the applicant to have to work with the Colne Valley Park and relevant Local Authorities to secure an enhanced bridleway network within the area Subject to these [two above] requirements being met it is considered that this Council [Slough Borough Council] has no objections to the proposal to identify the area between Horton Brook and Poyle Quarry as a site for sand and gravel extraction.
Additional comments made regarding the Action / comment proposed site (neither supporting nor objecting) We wouldn’t have any major concerns, given the No comment or amendment required. location between two existing quarries. The right of way realignment would have to be agreed in theory with the authority and with the Colne Valley Regional Park before anything can be formally proposed. Provided that an agreed alternative route can be decided upon then the proposals for extraction here would have minimal additional impacts given the material can be processed at the adjacent processing plants for the existing quarries. The main issue to highlight here would be the need to ensure the HRA assessment was robust with regard to impacts upon the South West London Water Bodies SPA / Ramsar site and that the potential impacts are given appropriate weight when considered fully in combination with other identified plans and projects as highlighted within appendix B.
Summary of comments made on how the Action / comment proposed site does not meet the Test of Soundness General No requirement for a gravel pit and it doesn’t lend The mineral planning authorities are required itself to sustainable development. to provide a steady and adequate supply of minerals. For decades, Horton land has gradually been Minerals can only be extraction where they eroded: agriculture replaced by vast mineral are geologically present. extraction sites, reservoirs, commercial and housing development. We therefore acknowledge The Draft Plan contains a number of that our objections to the further mineral extraction development management (DM) policies are generally disregarded. However, neither the which seek to control the impacts of original draft plan, nor this new proposal provide development. adequate infrastructure safe-guards for our Village which is part of the Green Belt and contains many Mineral extraction in the Green Belt is not historical sites. considered inappropriate.
It is hoped that the proposal could result in improved public access. Air Quality We have seen no evidence of any air pollution Air Quality would need to be address through measurements being documented by the RBWM. the implementation of Draft Policy 9 It is clear that mineral extraction and particularly (Protecting public health, safety and amenity). infill cause substantial air pollution, as do the As such, this matter would be addressed in multiple traffic movements involved with this work. more detail at the planning application stage. We urge the Borough to undertake controlled and careful investigations into this before any planning is approved to ensure that only safe limits of air quality are allowed in Horton. Road cleaning – Horton Parish Council have The detail of mitigation measures would need regularly had to make contact with the owners of to be addressed as part of any planning the existing commercial operators to ask for road application. Any conditions are then cleaning. Please see our Parish Council minutes enforceable by the relevant mineral planning for evidence of this. The mud and dirt from the authority. sites is carried by the wheels of the vehicles leaving the sites. Whilst we are assured that wheel washing takes place each time, clearly it is ineffective as the roads still have to be cleaned. This cleaning process is not nearly regular enough and only covers certain roads. Particularly in wet conditions, mud and dirt is further moved into the centre of the village by vehicles coming past the mineral sites. Once again we regard this as evidence that the operational history of all the companies involved in this work is far from exemplary. The Royal Borough of Windsor & Maidenhead is urged to undertake investigations into air quality at the proposed site before any planning is approved to ensure that only safe limits of air quality are allowed in Horton. Ecology Concern that hedgerows, trees / woodland could The need to consider the local ecology is be lost and wildlife connectivity adversely outlined in the Development Considerations. impacted. As stated on page 26 of the Focussed Any proposal would need to comply with all Regulation 18 Consultation document this corridor relevant policies in the Plan including Draft [Colne Valley Way] provides refuge habitat with Policy DM3 (Protection of Habitats and quarries close by. Species). Traffic / transport / highways
The consultation quotes: ‘There are residential Protection of amenity is outlined in draft properties adjacent. Consideration will need to be Policy DM9 (Protecting Public Health, Safety given to impact of development on factors such as and Amenity). Draft Policy DM12 noise, dust, and air quality.’ Traffic Movements: In (Sustainable Transport Movements) also the past, we have asked, on behalf of residents, states that a Transport that the operational hours be restricted. This has Assessment/Statement and routing been rejected on the grounds of commercial agreement (which can include restrictions on considerations. This is an unacceptable response. operating hours) will be required which will Operational hours should be limited to 07:00 – need to determine how the transport of 17:00 Monday to Friday and no earlier than 08:00 materials will not have an unacceptable until 13:00 on Saturdays. No working on Saturday impact on the environment or local afternoon, Sundays or Bank holidays. The area is community and any highway improvements already bombarded with noise from aircraft. are required. Further noise from HGV vehicles and heavy plant machinery have a severe impact on residents’ quality of life. HGV movements may be restricted to operational hours, but this doesn’t take into account the ‘stacking’ of vehicles whilst waiting for the gates to open. This can either occur immediately outside an operational site or, in many cases, in side-roads or laybys nearby. This must be prevented. Even if such a limitation is agreed, there remains an outstanding issue of enforcement. Historically, and going forwards, the RBWM neither has the resources nor budget to enforce planning restrictions on vehicle movements. Page 27 Transport Assessment Summary: Active Comment unclear – draft policy DM12 travel routes, and the Colne Valley Way (CVW) is requires a transport assessment which will an important one, are part of the transport network assess the impact of the proposal on the and the considerations in that regard should come highway network. Where the highway out in this assessment. It is not merely about network includes cycle facilities or signed vehicular traffic. routes the assessment should refer to this and any relevant impacts. Amenity / Public Rights of Way The harm to the public right of way (the Colne It is hoped that the proposal could result in Valley Way) outweighs any benefit from the improved public access. increased supply of minerals. The Colne Valley Way (CVW) affected by this Additional wording has been added to the proposal is part of a strategic route but there is no Development Considerations to encourage clarity around how the diversion of the route will be improvements to public access/the Colne handled and opportunities taken to improve its Valley Way. alignment / natural environment context. On page 24 of the Focussed Regulation 18 Consultation document it states “The public footpath would be temporarily diverted to one side of the extraction area and reinstated.” This level of mitigation for the CVW, even on a temporary basis, is unacceptable. More imaginative and beneficial diversion proposals are required if this is to be considered further. We [Colne Valley Park Community Interest Company] are open minded about how long term betterment for this part of the Colne Valley Regional Park (CVRP) could come about and see scope for a temporary and permanent bridleway broadly following the Colne Brook corridor with suitable crossing point(s) over the river to include facilitating easy access to the Arthur Jacobs Nature Reserve. However, in the absence of a clear policy and strategy for achieving that the very small contribution this site could make to the
supply of minerals is outweighed by the disruption that would be caused. We cannot see how diversion within the confines Horton Brook Quarry to the west of the site is of, or adjacent to, the red lined ‘CEB30’ area could currently operational and has commenced provide an attractive CVW route, together with restoration on some parts of their site. The extraction. status/condition of the surrounding area would need to be considered at the time of any planning application. Page 27 Landscape Assessment Summary: Noted. This is not an issue that can be Reference is made to an active recycling site and addressed by the Plan. the route “hemmed in by scruffy screen mounds on one side and a flat open landscape on the other. The overall condition is moderate/poor.” There are issues with the existing arrangement and impacts on the CVW. The local authority needs to address this, not compounding any errors previously made and regard the impact as highly sensitive. Page 28 Development Considerations: Reference Noted. No amendment required. is made to a possible CVW diversion via the Eric Mortimer Rayner Memorial lakes area. Whilst this is a welcome idea to explore it is at odds with statements made elsewhere in the consultation about diversion and falls outside the current ‘red line’ area, reinforcing the need for a holistic approach to the whole Horton / Poyle area. We welcome reference to the 2019 Colne and Crane GI Strategy and this can inform future dialogue / policy finalisation. Page 39, Table 3.8: it is not accepted that, when The Colne Valley Way would not be closed assessed against SA / SEA objectives, none of the but would be temporarily diverted. factors show a negative position. Paragraph 1.1 (following table 3.8) clarifies the assessment is without mitigation so, when the Colne Valley Way (CVW) is a key part of a long distance active travel route within the CVRP, there surely must be negative scores recorded? The proposal is to extract sand and gravel from the Comment does not require a response. existing bridleway. Whilst re-instatement is promised, we hold no hope that this will be honoured and would ask the Royal Borough of Windsor & Maidenhead to help protect the Village of Horton from further infringement. Flooding The site lies within Flood Zone 1 in accordance Noted with our [Environment Agency] flood map for planning. Flood Zone 1 is defined as having low probability of fluvial flooding in accordance with Table 1 ‘Flood Risk’ of the Planning Practice Guidance The site lies on top of a landfill Noted The site also lies on top of a principal aquifer. Noted.
A requirement for a Hydrological and Hydrogeological Assessment have been added. Biodiversity and watercourses The following is supported by paragraphs 170 and Noted. 175 of the National Planning Policy Framework (NPPF) which recognise that the planning system The need for Net Gains is outlined in the should conserve and enhance the environment by supporting text of DM 1 (Sustainable development).
minimising impacts on and providing net gains for biodiversity: o there is the potential to enhance ordinary watercourses and deculvert sections through this proposal. o Standard base line assessments will be necessary (plants, badger, bats, reptiles, water voles and otters) and incorporating the recommendations for protection and enhancements into the scheme; a biodiversity calculator should be provided to demonstrate net gain and the loss/disturbance of each type of habitat Water Quality and pollution prevention We strongly recommend you cover pollution This issue is already addressed by policies prevention and water supply for this site allocation and development considerations. in order to be consistent with NPPF paragraphs 20 and 170. This site is very close to two water framework Such impacts will be identified at the planning directive (WFD) waterbodies (Horton Brook application stage and by assessments GB106039023040 and Colne Brook required as part of the development GB106039023010). The document list identifies considerations. These issues are also that there may be constraints of this proposal of covered by Plan policies. runoff and water quality impacts to nearby SSSI. There may also be cumulative impacts with the other schemes such as the River Thames Flood alleviation scheme. This should be investigated further due to cumulative impacts of different schemes. The two waterbodies are in a Safeguard Protection Zone and assurances would be required that this proposal would not impact the quality of the drinking water. A groundwater and hydrogeological risk Noted. assessment of all potential impacts in the area will need to be produced. This is to include impacts on: A requirement for a Hydrological and o Near-by abstraction licences Hydrogeological Assessment have been o Risk to the principal aquifer added. o Cumulative impacts of the neighbouring quarry sites o Groundwater quality in relation to impacts on neighbouring potable abstractions and the adjacent waste sites We should also be provided with details for a long- term groundwater monitoring programme (including maintenance plan for the groundwater boreholes, contingency action plan) in respect of groundwater contamination and resources, including a timetable of monitoring and submission of reports. This monitoring will need to be carried out to demonstrate that there will be no impacts to the water environment. This is also, to prevent and cause further deterioration of the drinking water protected area in the principal aquifer. If there are plans for dewatering at this site, an This would need to be addressed as part of abstraction licence may be needed and therefore any planning application. and impact assessment will need to be carried out. Archaeology / Historic Environment The area has high archaeological potential but the Noted. This is addressed within the large excavated areas adjacent to the proposed Development Considerations. allocation should allow the broad nature of the archaeological deposits to be predicted with reasonable accuracy for the purposes of the
detailed allocation assessment. A programme of geophysical survey and, depending on the results of the geophysical survey, evaluation (trial trenches) should take place prior to the determination of any planning application. The impact on the significance of the conservation The impact on the Colnbrok Conservation area at Colnbrook, as contributed to by its setting, Area was not raised as an issue by the should be also be assessed and responded to as landscape or heritage assessments. appropriate. The site would be operated as an extension to the permitted Poyle Quarry and would be a temporary impact. Utilities The proposed site either crosses or is in close Noted. proximity to one of National Grid’s assets. Details as follows [National Grid plan available upon This has now been added to the request]: Development Considerations. o Electricity Transmission - Asset Description - VW ROUTE: 275Kv Overhead Transmission Line route: IVER – LALEHAM Restoration The restoration of this site can be integrated into Noted. No amendment required. the quarry schemes on either side including the Colne Brook river corridor to promote habitat connectivity and natural recovery.
Summary of comments made on how the Action / comment proposed site should be changed An appropriate suite of protected species surveys Noted. will need to be carried out in advance of determination around this site, and full and appropriate habitat compensation for the loss of linear woodland in this area will need to be provided before any habitat clearance occurs. Compensatory habitat provision designed to serve Noted. a similar woodland corridor function will be needed and it should be ensured that provision for this in the vicinity of the extraction site is possible prior to approving this site. Habitat enhancement should also meet the Noted. The Biodiversity Opportunity Areas objectives of the Colne Valley Gravel pits and are specifically referenced in the Reservoirs Biodiversity Opportunity Area. Development Considerations. We [Colne Valley Park Community Interest Noted. Company] ask for: • Early dialogue around the Colne Valley Way The Development Considerations have been (CVW) diversion as part of a strategy for wider updated to make reference for the need to restoration and improvement of the area and work with the relevant planning authorities the quality of connectivity it offers for people. and the Colne Valley Regional Park in the Subject to there being a satisfactory outcome consideration of the diversion and re- to that dialogue that this be reflected in the instatement of the Colne Valley Way. final policy wording • The policy wording requires provision of the agreed CVW diversion and related mitigation as a first step, in advance of any extraction taking place. Standard base line assessments will be necessary Noted. (plants, badger, bats, reptiles, water voles and otters) and incorporating the recommendations for protection and enhancements into the scheme; a
biodiversity calculator should be provided to demonstrate net gain and the loss/disturbance of each type of habitat We strongly recommend you cover pollution This is covered by draft Plan policies and prevention and water supply for this site allocation development considerations. in order to be consistent with NPPF paragraphs 20 and 170. A groundwater and hydrogeological risk Noted. assessment of all potential impacts in the area will need to be produced. A requirement for a Hydrological and Details for a long-term groundwater monitoring Hydrogeological Assessment have been programme should be produced. This should added. include a maintenance plan for the groundwater boreholes and a contingency action plan (in respect of groundwater contamination and resources), a timetable of monitoring and submission of reports. The proposal should be rejected / refused No response required.
Policy DM15
Summary of comments made supporting the Action / comment proposed policy The policy will, as it states, encourage existing Noted. operators to “do the right thing.” The proposed policy is welcomed as it would help Noted. ensure that operators were better held to account when putting in applications for other sites where they are known to have been less than forthcoming previously (whether that be in terms of not fulfilling promises to complete restoration in time or in relation to commitments to carry out works as agreed at the time of permission being granted etc). The intent behind the policy is appreciated and it is Noted. noted the NPPF provides an element of support for it. Support the policy and the principle of closely Noted. monitoring operators’ performance in adhering to site conditions and good practice. The Policy would empower residents and bodies Noted. (particularly Parish Councils) in the enforcing and investigating role of the Planning Authority and would allow for sensible dialogue to be maintained. It would also put the minerals and waste operators on notice that their activities are being observed and recorded on behalf of local people, and hopefully create, where necessary, an improved culture of compliance. It will benefit all parties if the new culture of compliance can recognise that circumstances can and do change over time. This is an unusual policy and it is not clear on what The policy has been prepared in response to basis it is being justified. The only reference to issues raised in previous round of Regulation being able to consider past performance in the 18 engagement and consultation and seeks NPPF is in paragraph 76 which deals with housing to address issues raised that are not permissions not starting. Nevertheless, it is otherwise addressed by local or national considered that the Council should support the policy. proposed policy on Past Operator Performance. The support is noted.
Summary of comments made on how the Action / comment proposed does not meet the Test of Soundness New operators *should* be judged based on a It would be harder to evidence such an lack of track record; to do otherwise is foolish (it is approach. Should studies or other evidence inevitable that a new operator will experience arise of the typical issues new operators fail to "teething issues" when establishing their resolve adequately, this can be taken into processes and this needs to be taken into account in the future. account). The policy may provide a small benefit, by not The policy does not focus on not granting granting planning applications to operators who planning permission, but on enabling have a poor track record. However, it will do development that will meet planning and other nothing to guarantee the future performance at a requirements (e.g. through the use of site for which planning approval is being sought. appropriate conditions).
Future performance then needs to be considered under the monitoring and enforcement regime. This policy appears only to deal with the Monitoring and enforcement are separate appointment of an operator, not with monitoring planning legislation and policy issues that are their subsequent performance or enforcing that not usually dealt with by Minerals and Waste performance. It will therefore offer little protection Policy Plans. Therefore, the Plan seeks to to the environment and residents in the vicinity of only provide policies where these are absent a new site, unless regulations are enforced better from a local or national level, such as for the than at present. Financial pressures on operators consideration of past operator performance. naturally push them to follow the cheapest course of action, to maximise output and meet targets; if this means breaching regulations, less scrupulous operators will do so if this yields profits in excess of any paltry fines subsequently imposed. Thus a policy that just restricts their prior appointment is of little use. Any breach of regulations should be met by massive fines or even enforced site closure, ie. something so punitive that it outweighs any benefit gained from breaching regulations. This will be the only driver that seriously improves operator performance. Support would ONLY be given to the policy IF it is The planning system deals with applicants legally worded so as to ensure that the "applicant and operators and does not generally look or operator" it speaks of includes individuals, not into past company history. Case by case just companies; AND includes consideration of decisions will need to be made, for example any previous companies with which those where an operator has changed name or is individuals were associated. If this is not done, now part of another company. there is nothing stopping unscrupulous companies or individuals trading under a new name. I could not see any explicit provision for this in the wording as it stands. The proposed policy on operator performance is Planning history and past behaviour are setting a test that has no measure and is not a briefly mentioned in National planning material consideration in decision making. Justice guidance. National planning practice guidance needs to be blind. In a Court of Law the jury is not (PPG) states that the “planning history of a told of an offenders past offences as it would likely site may be a relevant consideration in the prejudice the current case and render it unlawful. I determination of an application”[1]. PPG further see no difference here. states that “it is for the decision maker to decide what weight is to be give [sic] to the material considerations in each case”[2].
The Policy clarifies what planning history will be relevant and what weight will be given to these issues, thereby increasing the confidence of both the planning authority and applicants as to how these issues will be treated.
[1] Paragraph: 010 Reference ID: 21b-010- 20190315, Revision date: 15 03 2019 https://www.gov.uk/guidance/determining-a- planning-application [2] Paragraph: 009 Reference ID: 21b-009- 20140306, Revision date: 06 03 2014 https://www.gov.uk/guidance/determining-a- planning-application
While MPA members will operate and manage The policy has been prepared in response to their sites to a high standard, reflecting issues raised in previous round of Regulation commitments in the MPA Charter, we are 18 engagement and consultation and seeks to concerned how the policy may be implemented.
In reality, objections may be lodged, enforcement, address issues raised that are not otherwise and in some circumstanceslegal action, taken on addressed by local or national policy. technicalities rather than due to harm caused, which may be challenged by an operator. This The summary response highlights key issues may be in the mineral planning authority area or raised, furthermore it is a planning principle elsewhere, and may reflect a range of that the weight of an issue raised is of greater circumstances. importance than the number of times it has The justification for the policy (para 6.1) that the been raised. issue was raised in response to the consultation on the previous draft plan does not appear to be a A policy gap was identified, as the issues sufficient reason for inclusion of a specific policy. raised could not be resolved through existing Reviewing the Consultation planning or other policies, so a new policy has Summary Report reveals that this was not a been drafted. The purpose of a local minerals common response and appears to be raised and waste plan is to respond to and take into mainly in connection with a waste site, relying on account local circumstances, otherwise anecdotal evidence and perception. national policy could be relied upon for all decisions.
The concerns for implementation are noted. It is agreed that careful consideration will be required on a case by case basis and that the monitoring assessment should reflect the relevant circumstances. It is also agreed that as a new policy there may be need for future refinement or explanation, which the authorities could undertake in different ways (e.g. through a Supplementary Planning Document). The reference to the recent amendments to PPG National planning practice guidance (PPG) (in para 6.7) that is used to justify the policy is not states that the “planning history of a site may valid, as the paragraph cited specifically concerns be a relevant consideration in the the planning history of a site in the context of determination of an application”[1]. It then goes bringing housing development forward, rather than on to say “In particular, when considering performance of a developer or operator. applications for major development involving Planning permission is with the land, not the the provision of housing”, therefore the applicant or operator. Therefore it would not be mention of a housing development can be sound to consider the behaviour (perceived or considered an example of where this principle actual) of an applicant rather than the merits of the is applicable. That does not exclude the use application itself. of planning history as material consideration in other circumstances.
Furthermore, as the PPG asks for the reasons a site has not come forward to be considered, this may well include operator behaviour and decision-making.
It is noted than planning permission is with the land, however that cannot be reason enough to ignore an increased risk of planning breaches which could be harmful to people or the environment.
[1] Paragraph: 010 Reference ID: 21b-010- 20190315, Revision date: 15 03 2019 https://www.gov.uk/guidance/determining-a- planning-application
Summary of comments made on how the Action / comments proposed should be changed
The principle of local liaison panels (paragraph Agreed, the policy text will be amended 6.17) is supported, but the wording should be accordingly. changed to indicate the key role of Parish Councils, as locally elected and accountable bodies, in helping to bring these together and co- ordinating action. Parish Councils are also in a position to broker excellent relationships with responsible minerals and waste operators. This is not a major point, but should the word Agreed. Wording from para 6.7 in the “accept” in line 2 of paragraph 6.7, should be consultation document will not be part of the “expect”? policy text.
The policy needs to address the issue of Monitoring and enforcement are separate enforcement, making it less financially viable for planning legislation and policy issues that are operators to breach regulations. It needs to be not usually dealt with by Minerals and Waste legally worded so as to ensure that the "applicant Policy Plans. Therefore, the Plan seeks to or operator" it speaks of includes individuals, not only provide policies where these are absent just companies; and include consideration of any from a local or national level, such as for the previous companies with which those individuals consideration of past operator performance. were associated. The planning system deals with applicants and operators and does not generally look into past company history. Case by case decisions will need to be made, for example where an operator has changed name or is now part of another company.
New operators *should* be judged based on a lack Should studies or other evidence arise of the of track record typical issues new operators fail to resolve adequately, this can be taken into account in the future. The site should be rejected / refused It is unlikely that issues raised through this policy alone would be sufficient to reject a planning permission. They may tip the scales, in combination with other issues or, more likely, be a starting point for working with the applicant or operator to address the issues an designing the planning permission, including any planning conditions, so as to make a positive outcome more likely.
Further Comments
Summary of comments which have not been Action / comment picked up elsewhere in the consultation We [Environment Agency] have made comments A Sequential Test will be carried out to about the sequential test in our response dated 19 support the Proposed Submission Plan. October 2018 to the Regulation 18 consultation. If the sequential test is not applied to the minerals and waste sites then the proposed site allocation at Bray Quarry is unsound as it is not consistent with national policy, justified or effective Comment from EA - Policy M4 – Locations for sand and gravel extraction - Revision We have read the revised wording for policy M4. Please apply the sequential test to the new quarry sites and extensions to quarrys within Flood Zones 2 and 3. You will also need to apply the sequential approach to different types of development with the minerals extraction sites such as locating more vulnerable equipment and buildings associated with minerals extraction in the areas of lowest flood risk such as offices and processing equipment. Please refer to tables 1,2 and 3 concerning flood risk and flood risk vulnerability in the Planning Practice Guidance. Please also be aware that the environmental permits for, new quarrys, extensions to quarrys and further extraction to quarrys may need new or renewed environmental permits including those that concern waste disposal or recovery at these sites. Please note that there is a typo in Policy M4. Noted. Under point number 4 it is stated that proposals for new sites will be supported inappropriate locations. The text should be proposals for new sites will be supported in appropriate locations. The Parish Council [Bray] has in particular much Comments received regarding the operation correspondence with the Planning Authority about at Monkey Island Lane have been provided activities at Summerleaze Gravel Works at Monkey to the relevant planning authority. Island Lane, in Bray. 3.3 Residents’ experience with the Monkey Island Lane site is that changes to operations have been instituted by the operators without consultation with nearby homeowners, sometimes with great detriment to people’s amenities. Whether or not those changes have been permitted by, or eventually regularised, by the Planning Authority, they have been made without consideration for local residents on the basis that people should not choose to live near a processing plant unless they are ready to accept the consequences. This is not how sustainable and conscientious business should operate in the twenty-first century. While the principle of a policy on operator Noted. performance would appear to be sensible care needs to be exercised when enforcing such a 1 is agreed and the policy includes wording policy. The following should be considered: on considering how an operator has 1. Even the most carefully operated and addressed issues in the past, not merely meticulously managed site can experience whether issues have arisen. unexpected problems or a genuine mistake can occur or even go unnoticed. This should not be
sufficient to affect how the operators performance 2, 3 and 4 are noted and will need to be part is assessed. of the policy implementation. However, 2. Issues identified within a Monitoring Officer these seem too detailed to include at a Plan Assessment can be used only as a guide as these policy level. issues will vary in terms of seriousness, complexity or ease of rectification. 5 is noted and the policy does not seek to 3. Unjustified or malicious complaints about site penalize new operators, in the absence of operations should not be considered. information the policy will not be able to be 4. The level of improvement in the performance of applied. The policy is related to operator and an operator should be recognised. An operator may applicant performance so should avoid have had a poor performance record historically but issues with a change of operator. a greatly improved performance more recently. 5. What would happen when a new operator proposes to develop a site or takes over an existing site where the new operator may not have a track record at all and the site may have a poor track record. New operators should not be penalised because of a lack of a track record or because of previous operators track records. These comments refer to restoration following Further assessment or detail of this [Land extraction on the land near Spencer's Wood to the west of Basingstoke Road] site has not been west of Basingstoke Road. There is potential for carried out as insufficient detail was provided creating a substantial nett gain in biodiversity by by the site nominee. The viability and restoring all or a large part of the site as wetland deliverability of the site could nature reserve. (1) The site is close to the not be demonstrated, and therefore, the site epicentre of the nationally significant lower Kennet has been ruled out as a potential allocation Nightingale (red list) population, whose preferred in the Joint Plan. habitat is scrub surrounding water bodies on old gravel workings. Creation of suitable habitat would encourage growth of this threatened population. (2) Creation of reed-beds and marshy areas would provide habitat for a wide range of other scarce and charismatic bird species and much other wildlife. The Berkshire Ornithological Club, which holds an extensive database of birds in the county, collaborates with developers and landowners on conservation work of this type. This irresponsible behaviour cannot continue; Mineral planning authorities are required to allowing endless deterioration in the area as well as provide a steady and adequate supply of surrounding neighbourhoods…This is atrocious but minerals. I wonder if the council will listen or we are just being humoured to complete complicated paperwork with very difficult technical terms in order to be seen to have consulted the public. I’m disgusted by this process in itself. Stop allowing proposed sites in residential areas! Do better research into the impact to the area. We need sand and gravel but that must be It requires mineral planning authorities which available elsewhere and railed in. have adequate resources of aggregates to make an appropriate contribution to national as well as local supply, while making due allowance for the need to control any environmental damage to an acceptable level.
There are no rail depots within the Plan area. Any increase in air and noise pollution would These issues would be addressed by Draft significantly impact both the teaching and the Policy DM 9 (Protecting health, safety and learning/experience of those attending the local Tai amenity). Chi school. Thank you for inviting Highways England to No requirement for comment or amend comment on this Consultation. Highways England
has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity. We will therefore be concerned with proposals that have the potential to impact the safe and efficient operation of the SRN, in this case the A404(M), M3, M4 and M25. We have reviewed this document and supporting evidence and we understand that there are two new sites , CEB29 - Land west of Basingstoke Road, Spencers Wood and CEB30 - Area between Horton Brook and Poyle Quarry, both of which are in response to the ‘Call for Sites’ during October/November 2019. The document advises that a Transport Assessment or Statement will be required along with a HGV routeing agreement and due to the locations of these sites and because of these requirements we have no comment on this consultation. However, please do continue to consult Highways England as this Joint Minerals and Waste Plan progresses and we wish to be consulted if planning applications are submitted for these sites. Thank you for consulting The Gardens Trust (GT) Noted. in its role as Statutory Consultee with regard to proposed Central and Eastern Berkshire Authorities Joint Mineral and Waste Plan. The Berkshire Gardens Trust (BGT) is a member organisation of the GT and works in partnership with it in respect of the protection and conservation of historic sites, and is authorised by the GT to respond on GT’s behalf in respect of such consultations within Berkshire*. One of the key activities of the Berkshire Gardens Trust (BGT) is to help conserve, protect and enhance designed landscapes within Berkshire. This wide-ranging Plan affects a number of sites within Central and Eastern Berkshire. We are therefore grateful for the opportunity to comment. Our comments are restricted to the two new proposed sites set out in the Consultation Document. Having considered those sites we do not want to make any objections to either of them being used for gravel extraction. Neither appear to affect directly any registered Garden or Parks, but we do draw attention to the need to ensure that any permission includes requirements for reinstatement at the conclusion of the works. *The Gardens Trust, a national body recently published a guidance leaflet to explain the place of historic designed landscapes in the planning system, the importance of assessing significance, the statutory consultation obligations, and the role of County Gardens Trusts, in raising awareness of historic designed landscapes as heritage assets.
‘The Planning System in England and the Protection of Historic Parks and Gardens’ can be downloaded at www.thegardenstrust.org. BGT’s own website: www.berkshiregardenstrust.org The continued use of the consultation process with Noted. regards to the development of the overall Plan is welcomed. The Berks, Bucks and Oxon Wildlife Trust Noted. No amendment required. (BBOWT) does not hold an in-principle objection to appropriately designed and phased sand and gravel extraction that minimises biodiversity impact, followed by exemplary ecological restoration. However, we have the following concerns [see specific sections] about the two sites that are the subject of this focussed consultation. We trust these comments are useful and would be happy to provide more information or clarification as needed. Thank you for consulting CEMEX on the Focussed Noted. Regulation 18 Consultation. CEMEX is searching for potential new mineral sites in the plan area. Thank you for consulting CEMEX and we would like to be involved and attend any future Examination in Public held for this Plan. Although we have asked for this consultation to be Noted. extended due to the Covid-19 situation, our request was turned down…As stated in the first paragraph, this should be considered additional to our former response. Clause 4b: It would be helpful for the supporting Noted. text to also make it clear that ‘maintain the landbank’ means that the minimum landbank of 7 years of reserves needs to be maintained (defined as ‘keep in existence, not allow to become less’) throughout, including at the end of, the Plan period. In line with PPG, it should also be made clear that a landbank above the minimum required level will not be a reason for refusal of otherwise appropriate applications for additional reserves. Paragraph 3.8: Demonstrates the need for strategic Noted. planning across planning authority boundaries (for sharp sand and gravel and soft sand), particularly those smaller in area and so with fewer options and resources. Bray Parish Council would like you to continue to Protection of amenity is outlined in draft take into account our previous comments, and in Policy DM9 (Protecting Public Health, Safety particular those dated 12th August 2019, and Amenity). Draft Policy DM12 responding to the Additional Regulation 18 (site (Sustainable Transport Movements) also specific) consultation on the potential allocation of states that a Transport Bray Quarry Extension. Assessment/Statement will be required Bray Parish Council is very concerned about the which will need to determine how the number of vehicle movements, especially HGV’s transport of materials will not have an (and including movements to and from locations for unacceptable impact on the environment or mineral extraction and processing) which currently local community and requires that alternative take place throughout the Parish and beyond. We modes of transporting materials are are particularly concerned about vehicle considered. movements on the A330, and, especially, the A308. We are very pleased that the Royal Borough of Windsor and Maidenhead has indicated sufficient concern about traffic conditions in the “A308 Corridor” that it has agreed to work with other stakeholders to produce a study, in order to
improve conditions and accommodate any necessary future development. We are also disappointed that, although the study was announced in 2018, there has been little apparent progress to date. Our concerns about traffic conditions on these major roads relate to their inadequate capacity; the resulting frequent conditions of congestion; and the impact of the vehicle movements (and indeed vehicle queuing) on air pollution. We consider that the improvement of quality of life for our residents, in terms of elimination of noise and air pollution, as well as improving journey times, should be a priority. These concerns are redoubled as we begin to understand the effects of Climate Change. We must oppose developments which bring about more congestion and pollution when what is required is mitigation of present conditions. The Parish Council is therefore very concerned that the future will bring further demand for mineral extraction and processing in order to serve new developments both locally and further afield (a major example being the expansion of Heathrow Airport), and that, unless careful consideration is given and careful judgement applied, these will bring further HGV movements, congestion and pollution for our residents to experience. In the context of the current Plan therefore, and recognising the realism of paragraph 3.6, the Parish Council continues to advocate that wherever possible, alternative methods of transporting the products of mineral extraction are employed, including rail, barge, and conveyor. Buckinghamshire County Council has no specific Noted. comments to make on the proposed additional policy. We note the gap in national policy and guidance on this particular matter within the decision-making process and will be interested in how the policy develops with the framework, legal jurisdiction and industry… As previously mentioned, Buckinghamshire County Council will no longer exist from April 1st, 2020 as the new unitary Buckinghamshire Council is established. Please can the contact details for the minerals and waste planning authority be amended to the new email address [email protected]. One query in relation to Policy M4 “Location of The term ‘sand and gravel’ includes soft sand and gravel”, specifically point 4d i) which sand in this context as the type of sand is not refers to soft sand. Should this point refer to sand specified. and gravel as the policy is about the location of sand and gravel or does it relate to soft sand? This is a representation in full SUPPORT of the Noted. approach set out in the focussed consultation document. We accept that the Councils’ find themselves in the unenviable position of planning for the future supply of minerals, with limited options given that little interest has been expressed by industry through the various calls for sites.
These comments respond to the Focussed Your comments are noted, and liaison has Consultation in relation to the effect on the Colne taken place throughout the plan-making Valley Regional Park. process with the Colne Valley Regional Park. The Colne Valley Regional Park (CVRP) is the first Your aspirations for the area and concerns large taste of countryside to the west of London; an over the proposals are noted. area for people, wildlife and many uses, including farming and angling. The Park, (founded in 1965) The Development Considerations have stretches from Rickmansworth in the north to subsequently been updated to outline that Staines and the Thames in the south, Uxbridge and liaison needs to include the Colne Valley Heathrow in the east, and to Slough and Chalfont Regional Park as well as the relevant in the west. The Parishes of Wraysbury and Horton planning authorities in relation to the and part of Datchet are located within the Regional diversion and re-instatement of the Colne Park. Valley Way. It is championed by the Colne Valley Park Community Interest Company (CVPCIC), which is submitting these comments. The CVPCIC is mindful of the potentially significant impact minerals and waste works have on the Park. The CIC's locus is to protect and enhance the Regional Park through the six objectives of the Park, which are: 1. To maintain and enhance the landscape, historic environment and waterscape of the park in terms of their scenic and conservation value and their overall amenity. 2. To safeguard the countryside of the Park from inappropriate development. Where development is permissible it will encourage the highest possible standards of design. 3. To conserve and enhance biodiversity within the Park through the protection and management of its species, habitats and geological features 4. To provide opportunities for countryside recreation and ensure that facilities are accessible to all. 5. To achieve a vibrant and sustainable rural economy, including farming and forestry, underpinning the value of the countryside. 6. To encourage community participation including volunteering and environmental education. To promote the health and social well-being benefits that access to high quality green space brings. It is relevant to highlight that the boundary of the Park significantly coincides with the Metropolitan Green Belt, as do the six objectives with national planning policy. We would highlight paragraph 141 in the 2019 NPPF: “Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.” (Para 141, NPPF) This policy context is particularly relevant to the draft proposal in the Focussed Consultation for a new area of minerals extraction along the line of the Colne Valley Way (CVW), a strategic active travel route that provides opportunities for outdoor recreation and access to the countryside/ natural environment. The difficulties people may currently
experience enjoying such access heightens the importance of getting right the protection and enhancement of the route. This is a particularly fragile and critical part of the Metropolitan Green Belt area with a strategic role for local communities and London generally. We are mindful that the area around Horton and Poyle has been the subject of minerals and waste proposals and approvals for many years and yet we have seen no comprehensive improvement plan and the area suffers from ‘planning blight’ that degrades the local environment. The proposals in this 2020 consultation must be considered in conjunction with those others in the Draft Plan and we refer to our representations to the 2018 consultation. We await a substantive response to our 2018 representations and strongly believe that individual site proposals for this critical part of the Colne Valley Regional Park (CVRP) can only be considered in the context of a clear strategy (followed by the finer detail) for restoration and improvement of the area. With the current proposal involving diversion, whether temporary or permanent, of the Colne Valley Way seeing this wider strategy is vital.