From: Anna-Marie Ferrier Sent: 21 January 2020 08:28 To: PL MWDF Subject: Publication of the Soft Sand Review of the West Sussex Joint Minerals Local Plan (Reg 19)

Thank you for the opportunity to comment on the above consultation. We can confirm that do not have any comments to make on the contents of the document.

Please continue to keep us informed of any further consultations.

With kind regards.

Anna-Marie Ferrier Planning Policy Officer Planning Policy Chichester District Council

Ext: 21065 | Tel: 01243521065 | [email protected] | Fax:

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2 From: Jason Mckewon Sent: 27 January 2020 15:00 To:

Subject: DTC : Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Follow Up Flag: Follow up Flag Status: Flagged

Dear Mr Dean

I refer to your email dated the 6 January 2020.

Thank you for consulting Durham County Council on the soft sand review of the West Sussex Joint Minerals Local Plan (Regulation 19). I can confirm that Durham County Council does not wish to provide any observations on this review as this consultation does not relate to the County Council’s strategic cross boundary mineral interests. However, I would be grateful if you could ensure that the County Council remains on your consultation database so that we can be consulted on future reviews of the Minerals Local Plan so that we can be kept informed of any future work in relation to Silica Sand as this is a mineral type which is also found in County Durham.

I have not completed the online response form as this email does not relate to soundness.

Regards

Jason Mckewon Senior Policy Officer Spatial Policy Team Regeneration and Local Services Durham County Council Telephone 03000 263 403 Email: [email protected]

1 From: Sent: 06 January 2020 09:52 Subject: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Dear Stakeholder,

In partnership, West Sussex County Council and the South Downs National Park Authority have prepared a Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan, as required by Policy M2 of the adopted Plan.

The Soft Sand Review is being published prior to its submission to the Secretary of State to allow representations to be made on its ‘soundness’ and legal and procedural compliance. Representations can be made up until 11.59pm on Monday 2 March 2020.

Attached to this email is a covering letter providing further information, as well as our Statement of Representations Procedure.

For further information on the West Sussex Joint Minerals Local Plan, please visit www.westsussex.gov.uk/mwdf.

Kind regards,

Planning Policy and Infrastructure Team.

This email and any attachments are confidential and intended solely for the persons addressed. If it has come to you in error please reply to advise us but you should not read it, copy it, show it to anyone else nor make any other use of its content. West Sussex County Council takes steps to ensure emails and attachments are virus‐free but you should carry out your own checks before opening any attachment.

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16 JANUARY 2020

Planning Policy & Infrastructure Team West Sussex County Council

Dear Sir/Madam

Re: Draft Soft Sand Review of the West Sussex Join Mineral Local Plan

Our Ref: LGW4073

Thank you for your email dated 06 January 2020, regarding the above mentioned planning policy consultation.

Aerodrome Safeguarding is a legislative requirement for officially safeguarded aerodromes of which Gatwick Airport is one. Aerodrome safeguarding is the process used to ensure the safety of aircraft while taking off and landing, or flying in the vicinity of aerodromes.

It is vital that their safe operation is not impacted upon by buildings, structures or works which infringe the protected Obstacle Limitation Surfaces (OLS), impact on navigational aids utilised by the airport or by development which has the potential to increase the number of birds or the bird hazard risk. Please not this list is not exhaustive.

We note that under Para 3.2 on page 18 that ‘Airport Safeguarding Zones’ have been included as key criteria when assessing sites, for which we thank you.

Other than the above we have no other comments to make on this document. Thank you for giving us the opportunity to comment.

If you have any queries please do not hesitate to contact me.

Yours sincerely

Amanda Purdye, Aerodrome Safeguarding For and on behalf of Gatwick Airport Limited

Email: [email protected]

GATWICK AIRPORT LIMITED, DESTINATIONS PLACE, GATWICK AIRPORT, WEST SUSSEX, RH6 0NP www.gatwickairport.com Registered in England 1991018. Registered Office Destinations Place, Gatwick Airport, West Sussex, RH6 0NP GRAFFHAM PARISH COUNCIL

Clerk: Tracy Rowe Chairman: Cllr. John Uphill Graffham Hill Cottage Summerfield Cottage The Street The Street Graffham Near Petworth Graffham Near Petworth West Sussex GU28 0QA West Sussex GU28 0NP Tel: 01798 867020 Tel: 01798 867373

27 January 2020

Subject: Re: WSCC/SDNPA Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan

Dear Sir/Madam,

I refer to the published Schedule of Main Modifications forming part of the above review recently circulated to Parish Councils for comment as to the “soundness of the Local Joint Minerals Plan”. My Council is concerned that there are a number of imprecise and ill-defined statements contained in the Modification Clauses which render the plan to be unsound and It is hoped that the following changes will help to clarify and remove the uncertainties:

MM1 Executive Summary There is no precise definition for the statement “exceptional circumstances" which is used to give justification for resourcing minerals from within the South Downs National Park and Areas of Outstanding Natural Beauty.

In line three of the Modification Delete: “in a manor which only sees minerals development within the South Downs National Park (SDNP) and Areas of Outstanding Natural Beauty take place in exceptional circumstances and where it is in the public interest“

Insert : “in a manor which only allows minerals development in areas outside the South Downs National Park and Areas of Outstanding Natural Beauty, if no other mineral resource exists and there is no objection received from the local Parish Council, then applications to resource minerals from areas within the South Downs National Park and Areas of Outstanding Natural Beauty may be submitted for determination by the Minerals Authority.”

Clause MM9 in line four of the Modification Delete “within the national park in exceptional circumstances and where it is in the public interest“

Insert: “within the South Downs National Park where there is no objection from the local Parish Council and no other mineral resource exists, then applications may be submitted for determination by the Minerals Authority.”

Continues.. Clause MM21 line 14 of the Modification Delete: “ National Park in exceptional circumstances and where it is in the public interest”

Insert: “ National Park where there is no objection from the local Parish Council and no other mineral resource exists, then applications may be submitted for determination by the Minerals Authority”

Clause MM40 Policy M7a Oil and gas wells Insert the following new clause: “Before commencing to bore any new oil or gas well, bore holes shall be drilled to enable groundwater samples to be taken to monitor the condition and quality of the groundwater over the whole intended working area of the well. In the event of any pollutants from the well being detected at any stage, immediate action shall be taken to close and seal the well by permanently grouting it solid with Portland cement PFA grout“

MM40 Exploration and appraisal (no hydraulic fracturing) Delete (a) (i) “With regard to the development ...... and in accordance with Policy M13” Insert (a) (i) “The site is located outside Designated Areas as defined in the footnote below and is in accordance with Policy M13. Horizontal extensions will not be allowed under Designated Areas and the surrounding area, where it is known to contain deeply faulted rock strata, which would allow pollutants to migrate to the aquifer and place public and private properties in danger.”

Insert: (a) (vi) ‘The storage and use of accelerators such as hydrochloric and hydrofluoric acid shall not be allowed at any time during the life of the well”

MM40 Activity beneath or proximate to designated areas Delete (c)” Proposals for exploration, exploration and production of oil and gas...... and other designated areas”

Insert (c) “Proposals for exploration, appraisal and production of oil and gas, not involving hydraulic fracturing, will only be permitted underneath or in close proximity to designated areas, assets and habitats, when there are no deeply faulted rock strata and special care will be taken to avoid harming these areas”

Insert at the end of footnote 1: “Ground water Source Protection Zone 1”

MM40 Production Delete: (b) (i) they accord with (a) (i)- (v) above

Insert: (b) (i) they accord with (a) (i) - (vi) above

Clause MM41 Policy M7b Oil and gas wells (involving hydraulic fracturing)

MM41 Exploration and appraisal

Delete: (a) (i) iv Any other area given specific protection from hydraulic fracturing in legislation

Insert: (a) (i) iv Any other area classified as “Designated” ( see note 1 above)

Insert : (a) (vi) “The storage and use of accelerators such as hydrochloric and hydrofluoric acid shall not be allowed at any time during the life of the well.”

MM41 Production Delete : (b)(i) they accord with (a)(i-v) above

Insert: (b)(i) they accord with (a)(i-vi) above

Activity beneath or proximate to designated areas

Delete (c) “Proposals for exploration, appraisal and production of oil and gas , involving hydraulic fracturing...... Groundwater Source Protection Zone 1”

Insert. (C) “Proposals for exploration, appraisal and production of oil and gas, involving hydraulic fracturing , underneath or in close proximity to designated areas, assets and habitats, will only be permitted when the underlying rock strata is not deeply faulted and there will be no harm to surrounding properties in these areas including the special qualities of the South Downs National Park and or the setting and intrinsic character and value of Chichester Harbour and the High Weald AONBs. Hydraulic fracturing will not be allowed in deeply faulted rock strata and at a depth shallower than 1200 metres underneath National Parks, designated areas, World Heritage Sites and areas covered by Groundwater Source Protection Zone 1 as described in Foot Note 1 “

Yours faithfully

Pp Cllr. John Uphill Chairman Graffham Parish Council

From: MWDF Sent: 06 January 2020 11:23 To: PL MWDF Cc: Vicky Perkin Subject: RE: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Dear Mr Dean,

North Yorkshire County Council have reviewed the Soft Sand Review of the West Sussex Joint Minerals Local Plan and have no comments to make.

Regards

Joan Jackson Planning Officer North Yorkshire County Council

From: Alexander Dean On Behalf Of PL MWDF Sent: 06 January 2020 09:52 Subject: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Dear Stakeholder,

In partnership, West Sussex County Council and the South Downs National Park Authority have prepared a Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan, as required by Policy M2 of the adopted Plan.

The Soft Sand Review is being published prior to its submission to the Secretary of State to allow representations to be made on its ‘soundness’ and legal and procedural compliance. Representations can be made up until 11.59pm on Monday 2 March 2020.

Attached to this email is a covering letter providing further information, as well as our Statement of Representations Procedure.

For further information on the West Sussex Joint Minerals Local Plan, please visit www.westsussex.gov.uk/mwdf.

Kind regards,

Planning Policy and Infrastructure Team. 1

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2 From: Catchment_Management Sent: 22 January 2020 15:26 To: Alexander Dean Subject: FW: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19) Attachments: Soft Sand Review Reg.19 Letter.pdf; Soft Sand Review Statement of Representations Procedure.pdf

Dear Alex,

Portsmouth Water have no comments on the Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19) as none of the proposed site allocations are situated in our area of supply.

Many thanks

Kind regards,

Beth

Miss Bethany Fairley Catchment Management Officer Portsmouth Water

Direct dial: 023 9224 9248 Email: [email protected]

1 From: Alexander Dean [mailto:[email protected]] On Behalf Of PL MWDF Sent: 06 January 2020 09:58 Subject: [EXTERNAL] Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Dear Stakeholder,

In partnership, West Sussex County Council and the South Downs National Park Authority have prepared a Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan, as required by Policy M2 of the adopted Plan.

The Soft Sand Review is being published prior to its submission to the Secretary of State to allow representations to be made on its ‘soundness’ and legal and procedural compliance. Representations can be made up until 11.59pm on Monday 2 March 2020.

Attached to this email is a covering letter providing further information, as well as our Statement of Representations Procedure.

For further information on the West Sussex Joint Minerals Local Plan, please visit www.westsussex.gov.uk/mwdf.

Kind regards,

Planning Policy and Infrastructure Team.

This email and any attachments are confidential and intended solely for the persons addressed. If it has come to you in error please reply to advise us but you should not read it, copy it, show it to anyone else nor make any other use of its content. West Sussex County Council takes steps to ensure emails and attachments are virus-free but you should carry out your own checks before opening any attachment.

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3 From: Christine Goudie Sent: 15 January 2020 14:05 To: PL MWDF Subject: Regulation 19 Soft Sand Review of the West Sussex Joint Minerals Local Plan

Follow Up Flag: Follow up Flag Status: Flagged

Dear Sir/Madam,

Thank you for giving Waverley Borough Council the opportunity to comment on the above consultation.

We have concluded that we do not wish to comment on any specific issues. However we look forward to hearing from you regarding future consultations.

Kind regards

Christine Goudie Planning Officer (Policy) Waverley Borough Council 01483 523191 Working Tuesday to Thursday If I am not available and you need assistance before my return please contact the Planning Policy Team on 01483 523291 or at [email protected] www.waverley.gov.uk

This email, and any files attached to it, is confidential and solely for the use of the individual or organisation to whom it is addressed. The opinions expressed in this email are not necessarily those of Waverley Borough Council. The Council is not responsible for any changes made to the message after it has been sent. If you are not the intended recipient of this email or the person responsible for delivering it to them you may not copy it, forward it or otherwise use it for any purpose or disclose its contents to any other person. To do so

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Response ID ANON-NRVC-BRPK-8

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-06 12:00:55

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mrs

First name: Jenny

Last name: Brooker

Job title (where relevant): Clerk

Organisation or affiliation (where relevant): Littlehampton Harbour Board

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name: Jenny Brooker

Address Line 1: Littlehampton Harbour Board

Address Line 2: Pier Road

Address Line 3: Littlehampton

Address Line 4: West Sussex

Postcode: BN17 5LR

Telephone number: 01903 721215

Email

Email address: [email protected]

Other (please specify below)

Other: Trust Port The Soft Sand Review has been submitted for examination, Consultation on any further changes to the Review

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR8

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: We consider the changes legally compliant and sound. The Littlehampton Harbour Board are supportive to proposals to investigate the use of marine sand subject to being consulted on the impact of any methodology on navigation channels and flora and fauna of the local area which Littlehampton Harbour Board covers.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BRPH-5

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-07 17:30:43

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name:

Address Line 1:

Address Line 2:

Address Line 3:

Address Line 4:

Postcode:

Telephone number:

Not Answered

Email address:

Other:

The Soft Sand Review has been submitted for examination, Consultation on any further changes to the Review, Date of the Public Examination, Publication of the Inspector's report, Adoption of the Soft Sand Review, Any further updates about Strategic Waste or Minerals Planning in West Sussex

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: all sites B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?:

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: In my view all the sites are set in beautiful scenic surroundings, this being the nature of nearly all the sandstone ridges in the weald of Sussex.

On the other hand the county is blessed with excellent quality sand which is important to the economy both locally and nationally - and possibly internationally if there is a good export market.

Therefore WSCC must find the right balance between extraction and harm to the environment. It is essential that robust legally enforceable boundaries are set in place re eg restitution of sites after they have been worked out.

That said, WSCC should consent to as much extraction as is possible, given that even if it's phased over many years the sand will still be there in eg 50 years time.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

Not Answered

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Not Answered

Part C - About You (The Equality Act 2010) Response ID ANON-NRVC-BRPF-3

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-07 18:13:16

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant): Written as an individual, but I a a member of a number of boards and the South Downs Partnership

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name:

Address Line 1:

Address Line 2:

Address Line 3:

Address Line 4:

Postcode:

Telephone number:

Email

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.:

B2 Do you consider the Soft Sand Review to be: (tick as appropriate) Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: My main comment is that the plan minimises distribution distances which is essential to deliver a zero carbon economy. It must support WSCC climate change emergency responses

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BRP9-P

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-07 20:11:20

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.:

B2 Do you consider the Soft Sand Review to be: (tick as appropriate) Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation? Response ID ANON-NRVC-BRPC-Z

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-07 22:30:24

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?:

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: This online form is completely inappropriate for residents to have their right to ‘Haveyoursay’ it is a total joke!

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation? Response ID ANON-NRVC-BRP3-G

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-08 00:26:48

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: This process seems designed to prevent individuals making comments unless they have hours and hours to pore over your documents We should not be having such an industry in as this in a national park - end of

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Stop it

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Part C - About You (The Equality Act 2010) Response ID ANON-NRVC-BR1M-B

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-20 11:23:50

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Publication of the Inspector's report, Adoption of the Soft Sand Review

Part B - Representation B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: Paras. 2.5, 2.35, 2.36, 2.41

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Positively prepared, Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

1. Location. The name is misleading as the proposed site is not an extension of the existing site at West Heath. Policies Map 9 clearly show the proposed allocation is separated from the existing site by Downpark Common, a distance of approximately 300 meters. Development of the proposed site would inevitably impact on the common land. See point 4 below. 2. Yield and Extraction. Paras. 2.5, 2.35. It is estimated that the yield from the proposed site is 1 million tons of soft sand, but the demand in West Sussex is for 4 – 5.5 million tons of sand from 2018 – 2033. It is, therefore, almost certain that that the site will be fully exploited over the project period of 2018 - 2033. That means over 30,000 tons will be extracted per year, representing over 2,000 trucks, assuming a 15 ton load, more assuming a lighter load. (legal weight limit for a loaded truck is 32 tons). With empty trucks travelling to collect loads there would be over 4,000 truck trips per year. See also point 5 regarding access. 3. Impact. Para 2.36 presents a table showing potential impact of the development. As it is likely to be a major development there will be impacts on conservation and wildlife, while impacts on landscape and natural beauty, recreation and cultural heritage are not identified. To say the impact depends on scheme details is virtually meaningless at this stage. 4. Guiding Principles. Para 2.41 list the guiding principles for selection of the site. These include the opportunity to restore land beneficially, avoidance of areas with a sensitive natural environment, and protection of protected areas. Development of the site would not be consistent with these principles as it would severely impact on Downpark Common, a long- established area of common land. 5. Access. Another important principle is that the site should have good access to the Lorry Network Routes. The nearest LRN is the A272 but access to the existing site and hence to the proposed site would be along the narrow lane from the A272 towards West Harting. Approximately 300 meters from the A272 there is a narrow ancient bridge over the River Rother that would be a major obstacle to heavy trucks. In addition, since the sand is primarily for use in West Sussex, trucks reaching the A272 would turn east and have to travel through Rogate village, where existing truck traffic already causes problems at the narrow bends by Rogate church. Additional truck traffic would only exacerbate the problems there. Conclusion. The proposed site for extraction of soft sand would impact on this rural area, part of the SDNP, change the nature of an area of common land and possibly destroy an ancient bridge. The most significant direct impact on me as a Rogate resident would be the significant numbers of additional heavily laden trucks to the A272, creating further traffic difficulties in the middle of Rogate village.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Response ID ANON-NRVC-BR15-K

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-01-21 11:43:43

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: Issue 3 proposed sites

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Positively prepared, Justified, Effective

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: The plan appears to be largely based on providing soft sand to meet the requirements of the construction industry. Why are we continuing to plunder natural resources rather than finding new modern methods of construction which do not rely on harming protected sites (SDNP) and damaging local environments by extraction of this material. The Council should be demanding that developers demonstrate how they intend to achieve MMC in their future building plans.

The Council should be required to publish the actual costs incurred to date in the preparation of this SSR, together with the forecasted costs to complete the review. The cost to the taxpayer should be fully compensated for by the beneficiaries of the sand extraction if the scheme is approved. The residents and taxpayers of WSCC will otherwise be funding the bottom line of these companies , many of whom are not based in the county.

The developers and operators who benefit from the sand extraction must be made to provide employment for people directly from the local community. The employment plan should be enforceable as part of any contracts agreed within the WSCC. The plan should provide for apprenticeships, full and part time contracts of employment in the entire supply chain.

The lack of environmental assessment planning is extremely concerning, specifically in relation to the amount of carbon emissions likely to be generated in the removal of the proposed 1,000.000 tonnes from the Chantry Lane site. The impact of significant levels of transport will only go to further affect the already higher than acceptable air quality standards in Storrington (which the council has done little to address). The report is very concerning and lacks certainty with respect to the control of traffic from this site entering the village. A total exclusion is required with full monitoring to prevent further deterioration to the already excessive levels of pollution in Storrington. All efforts should be made by the operator of the extraction to develop electric transport options. a fully developed plan for transport is required given the life of the proposed site to ensure the minimum of impact from vehicle pollutants.

The impact on the Health of local residents is something which the Council fail to be prepared to address, other than in endless layers of bureaucracy and wasted effort with no meaningful action. Far greater assessment of the impact to the geology, hydrology, wildlife and most importantly the residents of this area needs to be undertaken to highlight the not inconsiderable impact which will be imposed on them all.

The council should also provide full transparency in any associated Section 106 agreement with the extraction operator. The full value of the Section 106 should be linked to the lifetime value of the site and index linked to market value. The full value of the Section 106 must be made public and the full benefit reinvested in the local community, with input from residents as to how this can be best utilised.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Response ID ANON-NRVC-BRJA-R

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-04 15:45:06

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR1-SSR43

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: I have lived in Durford Lane for the past 20 years, this is the lane which the aggregate lorries have to use to reach the existing West Heath Quarry from the A272. Over the years I have seen a massive deterioration in the local environment to which the lorries have contributed:

1 The amount of LITTER discarded from lorries, farm vehicles on a weekly basis is utterly unacceptable, particularly when the majority of this is EMPTY BEER CANS which suggests that potentially aggregate lorry drivers could be DRIVING WHILST UNDER the INFLUENCE. When you consider these vehicles are weighing between 20-30 tonnes, when loaded, this is a huge risk to pedestrians and other road users who are either driving or cycling along the lane and/or surrounding major roads. I have taken up this issue with the West Heath Quarry management but as yet have not had any response to my question of how they are ensuring that drivers are not under the influence of any alcohol. I understand they have a policy of zero tolerance but I would like to understand how they ensure that this is met in practise. Whilst the drinking/driving is the main issue here there is also an impact to the residents'/tourists' enjoyment of the area whilst also being a danger to local wildlife which is not in line with maintaining the natural beauty of a National Park.

2 DURFORD BRIDGE over which the lorries have to pass, to get to and from the A272, is GRADE II LISTED according to Historic England, see website links: https://historicengland.org.uk/listing/the-list/list-entry/1005842 https://historicengland.org.uk/listing/the-list/list-entry/1217009

This bridge was built c1600 to cater for "pedestrians, pack-horses and vehicular traffic" but not the types of traffic which are using it today ie. 15-30 tonne lorries and farm vehicles. It is a "SCHEDULED ANCIENT MONUMENT" As a result of the aggregate lorries/farm vehicles having got bigger/heavier over the years this has resulted in the bridge suffering badly. It now has a major crack from top to bottom as well as many other parts which have been broken away and many top stones either removed or made loose as a direct result of the vehicles being way too large to successfully manoeuvre across it without causing it any damage. I can supply pictures if you need them. This historic bridge simply was not designed to take this type of vehicular traffic and is falling into decay as a result. I cannot see anywhere in your documentation that Historic England has been involved in this consultation so I have made them aware of this proposal and asked them to comment.

3 DURFORD LANE now LOOKS A COMPLETE MESS with water continuously overflowing out of the storm drains because the aggregate lorries/farm vehicles have either broken drains and/or the sand which is deposited on the lane from the lorries has completely silted up and blocked the drains. This means that surface water can longer run down and along the storm drains and into the river nearby, it can only run along the surface of the lane which then results in the surface area being badly broken up and huge pot holes occurring. Every year my neighbour and I have to report the drain flooding to WCC which is money which has to come out of their local budget to fix but it is never fixed to last more than 1 year. It used to be a lane in which only 2 cars could pass but now two huge passing points have been dug into the sides by the continuous flow of lorries pulling over to accommodate the normal flow of cars. This, mixed with the surface water, means the lane is continuously muddy all year round. I don't believe this is in keeping with maintaining the natural beauty of a National Park and is also dangerous for pedestrians and cyclists.

4 Due to the sheer size and weight of these lorries I worry what IMPACT this could potentially have on the FOOTINGS of both mine and my neighbours' cottages. The aggregate lorries are passing our houses every weekday between 7am-5pm and 7am-12pm on Saturdays. This does not make for a pleasant environment in which to live. Durford Lane and Durford Bridge were simply not built to cope with this type of traffic.

I am already expecting the flow of traffic to increase with the SDNP's approval of the Sky Park Deer Farm last year which is to be turned into a tourist attraction which is situated just beyond the entrance to West Heath Quarry. Yet more traffic for both the lane and Listed bridge to cope with.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: More robust road alternatives need to be put into place to minimise the impact on local residents within the direct vicinity and the nearby village of Rogate. The aggregate lorries cannot continue to use the both the Grade II listed Durford bridge and Durford Lane - they simply were not designed to cope with either the size or weight of traffic. Both were designed for either pedestrians, pack-horses or vehicular traffic but not traffic of this size and weight!

The potential of drivers being in charge of lorries whilst under the influence of alcohol needs to be addressed to ensure zero tolerance is met and successfully maintained. The Grade II Listed Durford Bridge needs to be restored and repaired.

Durford Lane needs to be completely overhauled by a) fixing all broken and blocked up drains to allow surface water to run down the storm drains and b) having a total resurface of the lane from the A272 up to the bridge, not just a patching up. What people do not realise is that not only do the storm drains take the surface water but they are also a conduit for natural water sources to flow into the river.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No From: Clerk Sent: 10 February 2020 13:36 To: PL MWDF Subject: RE: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Members of the Planning & Services Committee reviewed your consultation and would like to comment as follows ‐ (this response is not applicable to be added to your representation form).

Members are concerned about the impact of HGVs going to and from these sites and suggested that the A24 or other dual carriageways should be used, rather than local roads.

Kind regards

Lisa Underwood Deputy Clerk Pulborough Parish Council Swan View Lower St Pulborough West Sussex RH20 2BF

01798 873532

This email may contain privileged and/or confidential information. If you have received this in error please notify the sender and delete the email immediately. You may not use or pass dit to a thir party. Whilst every care has been taken to check outgoing emails for viruses etc., it is your responsibility to carry out checks upon receipt of the email. Pulborough Parish Council does not accept liability for any damage caused. This email does not create any legal relations, contractual or otherwise and any view or opinions expressed are personal to the author and do not necessarily represent those of Pulborough Parish Council. The Council does not accept liability for any unauthorised/unlawful/statement by an employee or group. 1 Any personal information, such as name, postal address, telephone number and email address given to the Parish Council will only be used to provide a requested service and will not be disclosed to any third party without your prior permission or unless we are required to do so by law. If this email, message and or any attachment is incomplete or unreadable, please contact the Parish Clerk's office on 01798 873532 Email: [email protected]. Any reference to email in this disclaimer includes any attachment or otherwise.

Website ‐ www.pulboroughparishcouncil.gov.uk Facebook ‐ https://www.facebook.com/PulboroughParishCouncil/ Twitter ‐ https://twitter.com/PulboroughPC

Sent: 06 January 2020 10:04 Subject: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Dear Stakeholder,

In partnership, West Sussex County Council and the South Downs National Park Authority have prepared a Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan, as required by Policy M2 of the adopted Plan.

The Soft Sand Review is being published prior to its submission to the Secretary of State to allow representations to be made on its ‘soundness’ and legal and procedural compliance. Representations can be made up until 11.59pm on Monday 2 March 2020.

Attached to this email is a covering letter providing further information, as well as our Statement of Representations Procedure.

For further information on the West Sussex Joint Minerals Local Plan, please visit www.westsussex.gov.uk/mwdf.

Kind regards,

Planning Policy and Infrastructure Team.

This email and any attachments are confidential and intended solely for the persons addressed. If it has come to you in error please reply to advise us but you should not read it, copy it, show it to anyone else nor make any other use of its content. West Sussex County Council takes steps to ensure emails and attachments are virus‐free but you should carry out your own checks before opening any attachment.

2 bbWest Sussex Joint Minerals Local Plan: Single Issue Soft Sand Review – Proposed Submission Draft (Regulation 19) RESPONSE OF THE WIGGONHOLT ASSOCIATION

I Policy M2. This policy is unsound because not consistent with national policy

1. Sand extraction within National Parks can, and usually does, constitute major development. The Chantry extension allocation (Policy M11) has been designated Major Development. Major development in National Parks must be refused, according to NPPF 2019 para 172, other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest.

2. The major development test (MDT) applies to development inside English National Parks, the Broads, and Areas of Outstanding Natural Beauty. It does not apply “to major development which impacts on these areas’ statutory purposes and special qualities but which falls outside their boundary”.1 Since the Chantry extension proposal within the SDNP has been determined to be major development, the MDT applies. Sites outside the Boundary are not subject to the MDT. For such sites, the Environment Act 1995 s.622 applies. Section 62 requires relevant authorities only to “have regard to” National Park purposes if there is a perception that development of sites outside the Park will impact on the Park. This is a lesser test than the major development test.

3. Policy M2 of the draft Soft Sand Review (draft SSR) sets out conditions for refusing or permitting proposals for land-won soft sand extraction. In a document which allocates two out of three sites within the National Park3 the MDT should be the primary consideration of Policy M2, as set out in NPPF. Therefore:

(i) In the draft, sub-policy (c) (which contains the MDT) should be sub-policy (a) (ii) Sub-policy (a) (i) employs the word “ensure” whereas national policy (NPPF para 207) states that Minerals planning authorities “should plan for” [a steady and adequate supply

1 An Examination of the Development and Implementation of Planning Policy Relating to Major Development in the English and Welsh National Parks: Crowe et al. (Sheffield Hallam University, 2016) 2 Environment Act 1995 3 Draft Policy M11 1

of aggregates] indicating a less inflexible approach to minerals planning. The words of NPPF should be substituted here. (They should also be substituted in SSR 7.1.1.) (iii) Sub policy (iii) (b) covers proposals located outside the South Downs National Park. The test These proposals “must not adversely impact on its [the National Park’s] setting”. The s.62 test is rather different. Section 62 (1) reads (at sub-para (2)) that the relevant authority (in the this case the JMPA) “shall have regard” to National Park purposes “in any functions in relation to, or so as to affect, land in a National Park”. The words of the statutory test “shall have regard” do not equate to the words “must not”. They constitute a lesser test which does not dictate a compelling justification.4

The draft wording of Policy M2 is therefore not justified.

(iv) ‘Setting’ is one possible element which can “affect” National Park Purposes as envisaged by s.62, but it is only one of other potential elements. Draft clause M2 (b) narrows the policy by singling out proposals located outside the National Park which “must not adversely impact on its setting.”

(v) On the contrary “setting” is only one of a number of considerations envisaged by s.62 which could “affect” land in a National Park..5 This will be a material consideration (or otherwise) if an allocation goes forward to a future planning state.

Confining restrictive elements under s.62 to ‘setting’ is therefore not justified.

4. The wording of draft policy M2 is therefore unsound on the above scores. It would be beneficially amended as follows:

POLICY M2: Soft Sand (a) Proposals located in the South Downs National Park that constitute Major Development will be refused other than in exceptional

4 Environment Act 1995, s.62 (1) 11A (2). The High Court has found that the duty “to have regard to” guidance requires that guidance to be taken into account, and for there to be “clear” reasons for any departure from it, but that it does not go so far as to require a “compelling justification” for a departure. R (on the application of London Oratory School Governors) v Schools Adjudicator [2015] EWHC 1012 (Admin)

5 Emphasis added throughout 2

circumstances and where they can be demonstrated to be in the public interest. (b) Proposals for land won soft sand extraction, including extensions of time will be permitted provided that: (1) The proposal is needed to plan for a steady and adequate supply of soft sand and to maintain at a least a seven-year land bank, as set out in the most recent Local Aggregates Assessment, and (2) The site is allocated within Policy M11 of this Plan, or if the proposal is on an unallocated site, it can be demonstrated that the need cannot be met through the site/s allocated for that purpose; and (c) Where transportation by rail or water is not practicable or viable, the proposal is sustainably related to the Lorry Route Network (d) The Minerals Planning Authority will have regard to proposals located outside the South Downs National Park which accord with para (b) and do not affect National Park purposes as directed by the Environment Act 1995 s.62.

5. The word sustainably has been added to para (c) above, as reasoned in connexion with Draft Policy M11 (Section III below).

3

II PROVISION FOR SOFT SAND: land-won sand and its alternatives

6. The draft SSR states (at para 6.2.13) that “[l]and-won soft sand is of a particular quality that cannot be substituted by other minerals”. However there are deposits of soft sand available for dredging off the south coast in relation to which:

“[a]lthough they identify some issues that would need to be resolved, the Crown Estate “believe there is potential for marine sources to provide a viable ‘soft’ sand as an alternative to land based quarrying” [emphasis added] (The South Downs National Park Soft Sand Study 2012 (by Capita Symonds for four MPAs, para 9.13)

Moreover: “Marine sands are used in the production of mortar6 and the Crown Estates

indicate that there are areas of the sea bed in the South East that could provide raw

materials.” (9.12)”

Further:

“Options to be put forward for providing the desired products are: targeting particular sandbanks for the appropriate grades; screening for the appropriate grade at sea; or, screening on land” (ibid.)

7. The Minerals Site Selection Report for the West Sussex Joint Minerals Local Plan (Jan. 2017) (MSS) reviews alternative options for meeting soft sand requirements and states that:

“There are deposits of sand potentially suitable for mortar manufacture off the coast of Sussex which are not within licensed dredging areas but which could possibly be licensed in the plan period.” (Appendix 8 para 2.45)

Soft sand and ballast are often landed together from licensed areas off the South Coast onto South Coast wharves, but it is not at present practical to separate these categories.7 They are in consequence treated as ballast. There is therefore soft sand off the South Coast in licensed beds.

8. There are other more concentrated areas of soft sand in the Channel which are not yet licensed.8 However para 10.2 of Appendix A of the SA suggests that the potential lies outside the Plan period. Despite this, an annual average of 50,710 tonnes of marine soft sand is recorded as 1 being sold from South East wharves in 20179, while LAA 2019 asserts that “historically the aggregate available on the South Coast ha[s] been considered suitable for soft sand”. The Minerals Site Selection report (see above) also draws attention to the soft sand reserves in the Bristol Channel, reserves “potentially suitable for mortar manufacture off the coast of Sussex which are not within license dredging areas but which could possibly be licensed in the plan period” 10 and to marine deposits off the coast of The Netherlands which are “dominated by fine to medium sand”11. The reality of exports and imports is pointed out in our para 10 below.

6 Source BMPPA 7 Source: Crown Estates 8 ditto 9 SEEAWP South-East England Aggregates Monitoring Report 2017 10 ibid para 2.45 11 ibid para. 2.47

2 There seem to be considerable inconsistencies of evidence that need to be reconciled.

Meanwhile the availability of marine-dredged soft sand appears to be considerably downplayed in draft SSR SA 10.2.

9. Since NPPF para. 207 requires MPAs to plan for a steady and adequate supply, we find draft SSR SA Appendix 4 (para 10.2) unduly negative about the possibility of marine soft sand extraction, even though the Crown Estates consider that it has long-term potential.12 Given the long life of the present Plan (2033) it is not unrealistic to consider a “wait and see” policy about the amount of marine-dredged soft sand potentially available. As will be seen below, it is being landed and processed in other parts of the United Kingdom, an indication that the market will soon catch up. Marine-dredged soft sand appears to be on the bring of a break-through on various fronts.

The draft SSR analysis of marine-dredged sand is conflicted to the point of re-evaluation. It is therefore unsound.

10. Draft SSR para 6.2.13 unduly restrictive.13 It implies that only virgin land-won soft sand is acceptable to the MPA in filling any anticipated shortfall during the Plan period. Anecdotal evidence is that the market prefers land-won soft sand as it is “what they are used to”. This defends a position where the most-highly designated landscapes are put forward for sand- winning in circumstances where acceptable alternatives are available and could be vigorously pursued and promoted, whether as imports from the Channel via existing wharves or from other marine areas. LAA 2019 also suggests that the use of marine-dredged soft sand for mortar in the South East will become commonplace, as it is in other parts of England (2.2.9). It is noteworthy that Shoreham (now the only Sussex landing wharf for sand and gravel) lands just 38% of all primary aggregate dredged under licence off the South Coast14. The difference is accounted for by (a) small landings at Cowes, Langstone, Poole and Southampton, and (b) “the presence of the

export market and movement of aggregate to meet differing home market demands”.15 Yet the import/export equation of land-won and marine dredged material is not discussed in draft SSR, either in the main document or Appendix 4.

12 Source: Crown Estates 13 It “cannot be substituted by other materials” 14 Summary of Statistics 2018 The Crown Estate Licences, Marine Aggregates (2019) 15 Crown Estates ibid.

3 11. Offering only land-won virgin soft sand to a market which has traditionally dealt in it runs contrary to the imperative to maximise alternative aggregate supplies and to preserve designated landscapes. This scenario replicates the longstanding greenfield/brownfield tension which exists within land use planning. These options have not been adequately discussed or analysed in the Strategic Assessment of the draft SSR. The draft therefore runs contrary to NPPF 17 (204) (a) which stipulates that planning policies should:

so far as practical, take account of the contribution that substituted or secondary and recycled materials and minerals waste would make to the supply of materials before considering extraction of primary materials …

On the contrary draft SSR says that virgin soft sand “cannot be substituted by other materials” (para. 2.5.3) and in this it is at odds with NPPF. Marine-dredged soft sand is soft sand. It is a resource from water not land:

Marine sands are often formed by the same processes that have created terrestrial sand deposits and therefore comparable sands could be anticipated in an offshore situation. (Capita Symonds 2012 para 9.12)

On the basis of national policy, the 2012 Report by Capita Symonds, other information as set out above, and the lack of analysis within draft SSR, we conclude that the draft is deficient as regards the potential for marine-dredged soft sand to meet the need for soft sand in West Sussex. It is therefore unsound.

12. Secondary and substituted aggregate: Secondary and recycled aggregate are alternatives to the virgin product. They have not been considered in the draft SSR. LAA 2018 Table 20 shows that actual production of recycled aggregate in the County is at one-third of its capacity, while Table 17 shows a fall of nearly 50% in this material between 2010 and 2017. In the western world recycling is strenuously promoted as a practical and ethical imperative, so this under-production is startling. LAA 2018 para 2.5..3 admits that capacity is underutilised and attributes this to lack of “feedstock”. Perhaps there is little will to develop this material when virgin material is so readily to hand. On the contrary the draft Review (para 6.2.13) distinguishes

virgin soft sand as unique (“it cannot be substituted”). In the current climate there is an expectation that the MPA will promote secondary and recycled material, alongside marine-

4 dredged soft sand. These are both important resources where imports and modifications are appropriate.

13. National policy does not regard primary materials as unique and incapable of substitution. MPAs are bound to bring forward policies to:

“- take account of the contribution that substituted or secondary and recycled materials and minerals waste would make to the supply of materials before considering extraction of primary materials” (NPPF 2019 para 204 c))

The MPA (SA Appendix 4) has selected option E as determinant of how much land-won soft sand it needs to find during the Plan period.16 This option is said to include supply from alternative sources. Any shortfall from alternatives has to be found from land-won sources. It is not apparent how (or whether) these alternative sources have been quantified (if they have been included). The shortfall cannot be ascertained from draft SSR and we believe this makes it unsound.

5

III. DRAFT POLICY M11: Strategic Minerals Site Allocations and reasoned justification: Chantry Extension (Policies Map 10) This policy is unsound because it includes a proposal (Chantry Extension) which though

a major development does not pass the major development test of the Environment Act 1995 (section 62) with regard to landscape and visual impact, infrastructure and cumulative development.

14. The Chantry Extension is in the South Downs National Park. It is not in the setting of the National Park: it is a part of the Park itself. Different considerations apply to land inside the Park and to land outside the Boundary. The Boundary of the Park was the subject of intensive investigation and scrutiny by landscape assessors leading to public consultation and inquiries between 2003 and 2008. It follows that the land which forms the Chantry Extension was not included in the Park by accident but by long deliberation. The extension acquired its major designation, unlike the existing Chantry Quarry (a SSSI) when the Order for the Boundary was made in 2009.

16 Option E: B plus D (Sites within West Sussex including the SDNPA plus supply from alternative sources.

7 15. In 2005 WSCC considered a Minerals Development Plan Document to bridge a complex situation involving future Regional Planning and the advent of the National Park. The Chantry Extension was the subject of a report by the WSCC Landscape Architect., WSCC Landscape Response 22 July 2005: Potential Sites. This is interesting as an analysis of land outside the AONB but not yet within the proposed National Park Boundary. Yet this report compares extremely favourably with the more recent analysis which was commissioned in 2019 for the purposes of the Reg.19 consultation, SSR Landscape Assessment 2019.

(a) The 2005 assessment is derived from visual and other site analysis, and the recommendation for the Chantry Extension is as follows: 1) Removal of this section of land will open up views into existing extraction site;

2) extent of visual impact significant and unacceptable in context of AONB;

3) destruction of landform and consequent effect on landscape character

4) * OBJECTION/SITE OF LAST RESORT

(b) The 2019 assessment of the same site is considerably more muted. It is a desk-top exercise made without benefit of a site visit: • Pastoral fields with hedgerows and trees visible from South Downs Way.

• Within SDNP but displaying limited special qualities [emphasis added].

• Nearby nature and heritage designations

• Sensitivity: medium; Capacity: moderate

This is surprising. The site did not change between 2005 and 2019 except that it was selected by the boundary assessors for inclusion in the South Downs National Park. This was no arbitrary decision as the old Chantry quarry remained outside the Boundary. In the course of two public inquiries into the Boundary between 2005 and 2008 the Chantry extension site was not challenged, and in 2010 it was designated. This iterative process was long and thorough. Unless and until there is a Boundary review, subjective opinions about sites outside the Park do not put them on an equal footing with sites inside the Park.

16. It should also be noted that the Chantry extension site is visible from the South Downs Way although (exceptionally by contrast to other sites) this did not deter its proposed allocation.

We suggest that the 2019 landscape assessment is unsound and should be reviewed.

8

17. “Established infrastructure” (see SSR supporting text 6.2.27). The text reads that physical extensions generally benefit from existing infrastructure. A clear exception to this is the Chantry Extension site. When the permitted quarry was a working quarry it had access onto the A283 via Chantry Lane at the limit of what is now the Built Up Area Boundary of Storrington. (At this point the BUAB abuts the residential area of Sullington, which is well-populated to the north of the A283.) This access was considered acceptable until 199217, and it was still acceptable when the extension site was evaluated for the draft Minerals Development Plan Document (November

2005). Between the latter date and 2017, when the extension site was put forward for the present

Minerals Local Plan, the position changed. We have seen no rationale for this change, but neither the existing quarry nor the extension will not be allowed by the Highways Authority to use Chantry Lane. This is no doubt because of traffic growth on the A283 and the narrowness of the Lane which is prone to flooding. The effect is that there is no established infrastructure to serve the Chantry Extension.

18. A new haul road The proposed solution to the unavailable Chantry Lane is to create a haul road across the National Park from the extension site in an easterly direction onto Sullington Lane and the A283, thence onto the A24, a strategic lorry route. Because of the very long- established permissions and recent permitted development at the sandpits north of the A283 between Water Lane and Hampers Lane, this is likely to involve a major road scheme with traffic lights and attendant air pollution (see below). The private residential roads of Bracken Lane and Hampers Lane are already being used as rat runs to avoid this busy stretch of the A283. The sustainability of the A283 is assessed below.

19. The A283 through and on either side of Storrington: The question is whether the A283 is a sustainable route for more heavy traffic. The A283 is certainly in existence, unlike the proposed haul road, but we suggest that it already exceeds viable limits. Vehicle delay and congestion are notorious in the downland hot spot of Storrington which is an Air Quality Management Area. Traffic has grown steadily since 1996 when the long consultation leading to the Minerals Local Plan 2003 began. Already in 1996 traffic through Storrington on the A283 was thought to measure an unacceptable 12,000 vehicles a day. Flows have been building ever since and are unlikely to flatten or decrease unless special measures are taken. (Reports on the AQMA have not so far found these measures). Traffic including HGVs from the west (A27) and north (A29)

17 SG.4.92 when it was a planning condition of an IDO permission.

9 use Storrington to bypass the congestion at Arundel by way of the B2139 and the A283 respectively. The A283 through the village now takes 20,000 vehicles a day.18 As a result, Storrington experiences the worst traffic-generated pollution in the South East. “Air quality management areas are rare in such rural locations.”19 The traffic going east from Storrington/Sullington on the A283 passes through a long-established and extensive area of sand quarrying which has yielded soft sand for most of the past century. This area includes Sandgate Park and Washington Sand Pit with their HGV traffic moving in both directions. These sites are the subject of a very recent permission in the case of Sandgate, and at Washington site a predicted permission which will extend the life of operations well into the future, affecting traffic levels on the A283 and local roads to the further detriment of the local community.

20. Sandgate Park: Long-established sand extraction continues here, but the new permission (8

January 2020 – WSCC/044/18/SR) which has not been factored into the draft SSR. This is to import 1.8 million tonnes of inert waste onto the site over an eleven-year period. This procedure impacts upon Water Lane south and the A283 east. Journeys are subject to a s.106 routing agreement (December 2019). The operator Cemex has provided figures which predict an almost 11% increase in traffic along this stretch of the A28320 as well as a 50% increase in Water Lane

south. The additional movements of (mainly) large goods vehicles per hour, including Saturdays, total 30. Water Lane north and south have a new road scheme to the north, with traffic lights at their junction with School Hill, Storrington. It is predicted that a similar scheme will be required at the junction of Water Lane south and the A283 in order to get this extra traffic on and off an already congested stretch of the A283 when it leaves and enters Sandgate Park.

21. Washington Sandpit: A planning application has recently been submitted21 for an extension of sand-winning (two years) and inert waste infill (eight years). No figures are provided about the impact on local traffic but the addition to large vehicle movements based on figures provided22 is 18 movements an hour including Saturdays. (This figure does not include employee cars and no figures are available for the rat runs mentioned above.) A decision will be reached after 6 February 2020 but the application is unlikely to be refused because of the precedent set by recent

permissions of the same character. Sequential applications for short-term sand extraction and

18 West Sussex Traffic Statistics Year by Year: Storrington and Sullington; Highways England: Spotlight on Storrington. 19 Highways England: “Spotlight on Storrington” 20 Cemex Environmental Statement Vol 2-1 para 7.3.4 21 WSCC/001/20, 16 January 2020 22 Britannia Recycling Limited Traffic and Transport Addendum para 3.1

10 related imports of inert waste have been allowed since 2013, so this site will in all probability generate heavy traffic for years to come.

22. The combined movements from these two permissions will be in the region of 48 large vehicles an hour, involving Water Lane, Hampers Lane and the A283 (which leads to the A24 at the heavily congested Washington Roundabout).23 The effect of allocating the Chantry Extension via a new haul road will be to increase substantially heavy traffic between east Storrington/Sullington and the A24. In consequence the notorious Storrington Air Pollution Zone may be expected to spread east, intensified by anticipated traffic light systems at Water Lane/Sullington Lane and the junction of Hampers Lane and the A283. The standard objectives

1, 10 and 13 of the Strategic Assessment Grid Matrix (Appendix 4) have clearly not been explored in evaluating the Chantry Extension. As reasoned above, human health, air pollution and effect on transportation should be particularly prominent in the evaluation. Yet the site analysis (A4-2) mentions none of these consequences apart from “moderate transport impact”.

The SA site analysis is not justified in respect to the above constraints.

23. Impact of a new haul road.: As recently as 2005 access to Chantry Quarry by way of Chantry Lane was considered acceptable both for the old quarry and its possible extension24. This was before the coming of the National Park. By 2017 the Highway Authority’s assessment of Chantry Lane had changed, doubtless because of the growth, congestion and pollution of traffic travelling through Storrington/Sullington. Land within the National Park boundary was identified for the creation of a new haul road running from the Chantry Extension to Sullington Lane. This would effectively create a second highway parallel to the A283 within the National Park. In our view it is neither sustainable nor in conformity with National Park Purposes to build a haul road and junction expressly to bring minerals out of this designated land (and perhaps out of the old quarry too). Although the landscape assessment of 2019 does not comment on the possibility, it is clear that a new road for HGVs which runs along an open stretch of the Park framed by the Downs and the Sullington conservation area is in direct contradiction of the Purposes, which are to conserve and enhance the natural beauty, wildlife and

cultural heritage of the National Park. Further, any haul scheme which involves bringing HGVs

23 Drivers who are aware of conditions on the A283 avoid westward congestion by taking the first exit north of the A24 Roundabout into Rock Road and thence into Storrington or Pulborough. Alternatively some cut through the private Hampers Lane. 24 West Sussex Development Plan Issues and Options Consultation November 2005

11 into and out of Sullington Lane via the A283 will also need the kind of traffic scheme envisaged by the Sandgate Park permission ie four-way traffic lights.

24. Further impact of a new haul road: It has been suggested that allocating the Chantry Extension could be a trade-off for an extant permission covering the Chantry quarry. It is a small step to suppose that the new haul road could serve both the old quarry and the extension. However further evidence about the planning history of the site has recently been made available to public consultees. This is discussed in para 27 below in the context of unacceptably great cumulative development and its impact.

25. Cumulative impact: It is most surprising that the SSR Strategic Assessment table does not mention cumulative impact in relation to this site (see pp 36 and 37). This category features in seven other sites under consideration, including another proposal site (East of West Minsted). Just as astonishing, transport is not mentioned. By contrast a nearby rejected site (Buncton) which is undesignated “is likely to have the most severe cumulative impact, including transportation” (p36).

26. Minerals policy is a predictable candidate for the “impact” of cumulative development. Minerals are found in the ground so there is always a tension between their undisturbed presence and the impact of removing them. The areas covered by Sandgate Park and Washington Sandpit lie to the north of the proposal site, Chantry Extension, and the Chantry Quarry. There has been sand extraction at Sandgate Park since the 1920s, formally permitted in 1947. Other sandpits, notably Angell’s sandpit and the site of the RMC works have recently undergone development to housing, unaccountably losing their rural land use. The old Chantry Quarry was first permitted in 1947 sanctioning much earlier quarrying evident in its newly-published planning history. 25 The

traffic implications of cumulative development have been discussed above. This area of Storrington/Sullington has borne sand extraction for the best part of a century and has suffered long-term harm to its landscape and amenity. Although there are still hopes of a Sandgate Country Park north of the A283, this prospect is now compromised by the advent of extensive major development across the A283 in the South Downs National Park, consisting (as will be seen below) of two extraction sites, a further large extraction site, and a haul road through the Park within the setting of the conservation area of Sullington.

25 185A/620/29. C.2, partially permitted on appeal.

12 27. The South Downs Local Plan contains a policy “Major Development” which is (as noted above) directed towards certain forms of development within the South Downs National Park.

“The potential for significant adverse impact … will include the

consideration of both the impact of cumulative development

and the individual characteristics of each proposal and its context. (Core Policy SD3)

As noted in the draft SSR, significant adverse impact is a consideration at both the strategic and the development control stages of a proposal. It is therefore relevant in this case. The omission of cumulative development is all the more surprising for the Chantry Extension proposal in view of the planning history of the Chantry site. The site includes OS fields 110 and 140 (at present unworked) covering a deep and highly visible band runing east from the Quarry to Sullington Lane across the South Downs National Park. This part of the site was refused planning permission in 195326 and again in 198627 when the applicant proposed its the progressive extraction and infill of over a 20-year period by means of a haul road similar to the one now proposed. HGV movements over this period were not quantified but were likely to have been significant in view of two overlapping processes. The application was refused on the grounds of landscape damage, prejudice to the AONB, water protection, dis-amenity to open areas outside Storrington and adverse effect on the amenities of the locality. A subsequent IDO permission in 1992 for this enlarged site28 was made conditional on cessation of mineral working by 2042.

Notably, access to the site was only to be via Chantry Lane.

28. It is now clear that (as evidenced above) the allocation of the Chantry Extension with a new haul road to Sullington Lane is capable of opening up the whole IDO holding to sand extraction in the future, with all the effects and impacts noted in the 1986 refusal. With this history now available, we wish to reiterate most strongly the massive cumulative effect inherent in the proposal for the Chantry Extension. Once allocated and permitted, it would (as with the Sandgate sites) be the subject of repeated applications extending far into the future causing great environmental damage to the National Park, the community, traffic levels and air quality, in addition to all the grounds on which the 1986 refusal was based

26 SG/19/53 27 SG/39/86 28 SG/4/92

13 29. Effect of cumulative development on local communities: It is noteworthy that in 2009 a landfill application for Rock Common Quarry (to the east at nearby Washington and also on the A283) was refused. One of the grounds for refusal was that quarrying activities and more recently simultaneous quarrying and landfilling activities in the area “had been tolerated by the local community for over 80 years with unacceptable cumulative impacts of development in the area on the social and economic wellbeing of the local community”.29 As noted above, sand was first extracted at Sandgate Park in the 1920s and formally permitted (alongside the Chantry quarry) in 1947. The area and the local community at Storrington/Sullington are therefore in a very similar situation to that which led to the recent finding and refusal at Rock Common. Landfill activities at Sandgate have just been permitted for the next 11 years and there is the strong likelihood of similar extended activity at Washington Sandpit. Yet the draft SSR/SA evaluates no cumulative impact in connection with the proposed Chantry extension over the road from Sandgate, while only “moderate transport impact” is predicted in the section Assessment of Sites30.

On objective evidence, visual and statistical, and the evidence provided by the planning history of the site, there is no justification for omitting a finding of either substantial cumulative development/impact, or traffic impact, in relation to the Chantry Extension. It has not been demonstrated that there is public interest in allocating this clearly unsustainable site. It therefore fails the major development test and should be removed from Policy M11.

The Wiggonholt Association Registered charity No. 1129002 8 February 2020

29 DC/401/07 (WS) 13.2.09 30 Draft SSR 6.fig 8 p.36

14 Response ID ANON-NRVC-BRJY-G

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-10 16:29:14

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mr

First name: Neil

Last name: Ryder

Job title (where relevant): Clerk & councillor

Organisation or affiliation (where relevant): Trotton with Chithurst parish council

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name: Neil Ryder

Address Line 1: Steps

Address Line 2: Petersfield Road

Address Line 3:

Address Line 4: Trotton

Postcode: GU31 5EP

Telephone number: 01730207447

Email

Email address: [email protected]

Resident, Parish/Town Council

Other:

Part B - Representation B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR13

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: WSCC Soft sand review 2020 Comments on Site Selection Report 1. The quarry is in Harting Parish. In 2018 Harting objected; Rogate didn’t. However, the lorry route across West Sussex along the A 272 impacts Rogate far more than Harting. 2. A narrow strip of soft sand (the Folkestone formation) runs west-east through the centre of WSCC section of SDNP. Most of this sand in WSCC is in the SDNP. There is a general shortage of soft sand in the south east and supply outside WSCC insecure. Marine sand is not comparable. The WSCC report shortlisted 3 sites : West Heath East, Rogate, in centre of SDNP--extension Chantry Lane, Storrington, -- northern boundary of SDNP--extension Ham Lane, Steyning—new site.( Residents’ action group against it.) Just outside SDNP. 3. Any major development within or close to SDNP can only be allowed in EXCEPTIONAL CIRCUMSTANCES in the PUBLIC INTEREST. The public interest is ‘proved’ by assessing demand 2020-2033, and finding a shortfall of between 2-3 million tonnes ( there are reserves for 7 years but a need for 2-3 million tonnes for the 6 years to 2033—based on present sales and annual monitoring of need—input from ? . The SDNP is an asset protected in the public interest of the whole nation, a PUBLIC INTEREST that perhaps outweighs the provision of soft sand. The economic well-being of SDNP is unlikely to benefit. West Heath is owned by Mexican multinational Cemex, UK head office in Rugby. 4. West Heath East: 14—16 hectares can produce 950,000 tonnes when the west quarry is worked out. The ‘extension’ is not contiguous with the present quarry, therefore pipelines/conveyor belts will be used to cross agricultural land to old quarry machinery. This suggests West Heath East is a high sensitivity/low capacity site with processing problems. Chantry 2.5 hectares can produce 1million tonnes. Owned by Dudman, immediately available. Ham Lane 7.5 hectares can produce 750,000 tonnes. No problems with availability. Owner supports developers, Dudman. 5. The report woefully underestimates the transport, historic and environmental impact of this site: e.g. stating there will be ‘no severe impact on Midhurst’ and giving transport a ‘green ‘assessment. Transport : The route specified in the report is across West Sussex – Durford Mill Lane, A272 to Rogate/ Midhurst/ Pulborough to A 24 on the Advisory Lorry Network The site is therefore not well- located to the ALR. The quarry has been in operation for 50 years, but lorries have become bigger and heavier, traffic has increased and the landscape now has the highest protection within the SDNP. Lorry movements : 5 per hour x 8 hours per day = 40 x 5 = 200 journeys a week. Historic impact: Durford Bridge, already subject to lorry damage, and Trotton Bridge are listed, scheduled ancient monuments. There are nearby bronze age tumuli. The Durford Abbey site off narrow Durford Lane is a scheduled monument with a cluster of listed buildings. Eastwards along the A 272, the route passes through the Rogate conservation area with grade 1 and grade 2 listed buildings close to the highway, over Trotton Bridge to Midhurst. Environment: Rumbold’s Hill, Midhurst is now an Air Quality Management Area (AQMA). There is an important aquifer under the site, and a risk of groundwater flooding. The Rother SNCI is close by, and the Wealden Heaths II SPA and East Hants Hangers SAC. Footpath 866 here is both the Serpent Trail and Sussex Border Path and leads directly to the South Downs Way—an important footpath link which will be impacted. There is a mention in the report of ‘rich black sands’ which will be disturbed and suggests undesirable carbon release. Conclusion: West Heath East should not be further developed for these reasons: 1.West Heath East is in the centre of the SDNP. Such a major development in the SDNP sets an undesirable precedent. 2.The report has under-estimated the effect of the necessary heavy lorry movements along the A272 on the historic infrastructure, environment and amenities of the SDNP. 3. The report has allowed Cemex, the owners, to answer important points by stating ‘ …depends on scheme details’, leaving important issues undefined. 4.The site is not contiguous with the original quarry, and is not a simple extension. It will require a pipeline or conveyor across open land to West Heath quarry and its machinery. 5. The site will be less productive requiring at least double the land for a similar output.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No The Soft Sand Review has been submitted for examination, Date of the Public Examination, Publication of the Inspector's report

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR 35 7.2.7

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Para 7.2.7 of SSR 35 refers to vehicles associated with the Ham Farm site avoiding the villages of Storrington & Steyning. Consideration should be given to avoidance of other nearby villages such as Ashington, Washington, Wiston etc. Drivers will understandably look for nearby 'rest stops' and coming into nearby villages in search of these will have a detrimental impact on residential amenity. Drivers should be restricted to the Lorry Route Network and not 'local roads'.

Point 7.2.7 xii is essential as the A24/A283 Washington roundabout is already heavily congested at peak times. The cumulative effect of Ham Farm and Chantry Lane extension on the A24/A283 must be considered.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Yes Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR40 paragraph 7.2.11

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: Yes

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Para 7.2.11x of SSR 40 refers to vehicles associated with the Chantry Lane site avoiding the village of Storrington. Consideration should be given to avoidance of other nearby villages such as Ashington, Washington, Wiston etc. Drivers will understandably look for nearby 'rest stops' and coming into nearby villages in search of these will have a detrimental impact on residential amenity. Drivers should be restricted to the Lorry Route Network and not 'local roads'.

Point 7.2.11 xii is essential as the A24/A283 Washington roundabout is already heavily congested at peak times.

The cumulative effect of Ham Farm and Chantry Lane extension on the A24/A283 must be considered in terms of the wider local amenity and not just the very nearest settlement.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BRJR-9

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-10 18:34:11

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant): Director

Organisation or affiliation (where relevant): Sullington Manor Farm Ltd.

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Email

Resident, Local Business, Landowner

Other:

Part B - Representation B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR 39 SSR 40

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Effective

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: I am a resident in Sullington lane and a landowner immediately adjacent to the proposed chantry lane extension sand pit. I do not think the review is effective because it does not address the issue of access to the pit. As far as we are aware the owners of the sand pit propose putting in a new access road to the pit from the A283 at the junction with Sullington Lane. No matter what amount of screening is put in to try and hide this it will fundamentally destroy an important view of the South Downs and extend the urban area of Storrington to what is a quiet rural lane and I believe it would be impossible to restore it any meaningful way at the end of the sand extraction. Any new access road will be very visible from the south and particularly from the South Downs Way where it will appear as a scar on the landscape. i agree that there needs to be a long term solution to the whole in the ground which is the Chantry Lane sandpit but I cannot see why this cannot be achieved using the existing access from Chantry Lane which has been used for years. Surely the environmental cost of reopening this access is less than the loss of another green field site. The only other comment i would make is that looking at all the different sites under consideration it is clear that Chantry Lane is in the most built up area of them all and reopening this site will probably impact on more people in terms of pollution and noise than all the other sites put together.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: I think access to proposed sites has to be incorporated into the review. Leaving the question of access to be dealt with at a later stage to be dealt with by Planning and Highways is not effective or transparent.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BRJJ-1

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-12 14:44:54

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

The Soft Sand Review has been submitted for examination

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR1

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified, Effective

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: The extension of the Chantry Lane site will add to already heavy traffic flows on the A283. Although SSR18 refers to the benefits arising from established infrastructure these are questionable in this case given that heavy vehicles cannot turn in Chantry Lane which is single lane in places. The creation of a new access road joining Sullington Lane and coming out onto the A283 opposite Water Lane would not only be a substantial new infrastructure investment but would ruin the natural beauty of the land at the foot of the SDNP as well as creating a ‘choke point’ at the junction of Water Lane and the A283 which is already very difficult to navigate. More heavy vehicles coming into the area, those from the west having to come through Storrington itself in order to access the site will only add to the AQMA issues which already exist.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No STORRINGTON & SULLINGTON PARISH COUNCIL THE PARISH HALL, THAKEHAM ROAD, STORRINGTON, WEST SUSSEX, RH20 3PP www.storrington-pc.gov.uk Telephone: 01903 746547 e-mail: [email protected] Clerk: Mrs Tracey Euesden

Planning Services (Ref: Soft Sand Review) West Sussex County Council County Hall Chichester PO19 1RH

14th February 2020

Dear Sir/Madam,

Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan SSR39 AND SSR40 – CHANTRY LANE EXTENSION, STORRINGTON

Members do not believe the review has addressed any of the previous issues raised and therefore STRONGLY OBJECT to the above site being included on the following grounds:-

• The report (p 149), concludes: ‘The site is considered to be ‘acceptable in principal’ to be worked as an extension to the existing quarry’. However if all relevant assessments are marked red and amber, how can this site be acceptable in principle? • This review is not a small extension to the sandpit, the major effect will be from the access which could require digging out the corner field at junction of A283 and Sullington Lane in order to reach the bottom of the existing sandpit. Alternative access via Chantry Lane, although already used by goods lorries, is not ideal either and the proposed increase in traffic on top of the contouring of the sandpit on the other side of the A283 will be severely detrimental to the area. • It is particularly galling to see quoted in the submission draft, p10, para 172 of the NPPF referring to National Parks: ‘...planning permission should be refused for major development …other than in exceptional circumstances…demonstrated …in the public interest.’ This does not apply here. • One of the ‘attractions’ of Chantry is because it is claimed to be an extension with presumed benefits of existing infrastructure. Clearly a crucial bit of infrastructure, vehicular access, is not available or rather not acceptable. We don’t know what else is, which puts the classification of ‘available now’ in doubt. The new road: It seems reasonable from a lay view to assume the pit would be + 50m deep. How are vehicles to access the working level of the pit, or alternatively what industrial infrastructure would be erected to enable loading at surface level? Any grading of the new road for access would involve a substantial cutting, increasing the intrusion. This would not be a small lane across a field. • The proposed new access to the A283 would inevitably lead to increased urbanisation of the Sullington Lane to Water Lane Area. It is unclear if the additional traffic generated by the Water Lane accelerated extraction and infill has been taken into account, but it seems inevitable that laden vehicles crossing the A283 will affect traffic flow and it is unclear what effects this will have on the AQMA. • This acknowledged major development will affect access into the South Downs National Park and the impression of the Park as a natural area. In addition this will affect views to and from the only Grade I Listed Building in the entire parish, Sullington Church. It is surrounded by

1

Grade II Listed Buildings including one of the longest barns in Sussex (identified as the ‘finest’ by Nicklaus Pevsner) and will encroach on the nearby designated ancient woodland. • Policy 8 – Countryside Protection of our Storrington Sullington & Washington Neighbourhood Plan (now made) lists the views across the South Downs from the fields adjacent to Sullington Lane and the A283 as a prime example of an area worthy of protection. This was accepted by the Examiner.

• Page 16 of the Proposed Submission Draft 2.41, states that the guiding principles that have helped guide the selection of the soft sand sites are:  First Principle: Places where there are opportunities to restore land beneficially, for example a net-gain in biodiversity.  Second Principle: Places without a sensitive natural or built environment and away from communities, in order to protect the amenity of businesses, residents and visitors to West Sussex.  Third Principle: The new sites should have good access to the Lorry Route Network (LRN). Access from the site to the LRN should be acceptable “in principle”, that is, there should not be any technical issues, with regard to highway capacity and road safety, that cannot be overcome.  Fourth Principle: The need to protect and enhance, where possible, protected landscapes in the plan area, particularly ensuring that any major minerals development will only be considered within designated landscapes in exceptional circumstances and in the public interest.  Fifth Principle: A preference for extensions to existing sites rather than new sites, subject to cumulative impact assessments.  Sixth Principle: The need to avoid the needless sterilisation of minerals by other forms of development.

Members believe that this site fails on all of the above six guiding principles for proposed site allocations.

• It is not clear that all ‘reasonable alternatives’ have been considered e.g. marine-dredged soft sand. • This site has been on the list of potential sites for a long time, inhibited in recent years by being inside the National Park Boundary. • The site is very close to the built-up area boundary of Storrington, which this industrial development would in reality extend, presumably removing it from the Park? • The site is claimed to be an extension of a disused quarry. Because of its situation in the Lower Greensand this was mined in days when excavation was simpler and less obtrusive. The fact that this is an extension should in this case be considered irrelevant. • The operation of the site will have a significant noise impact on the large area of nearby residential homes of Storrington and Sullington. • The Green sand vein runs on the north side of the South Downs. Across the A283 are Sandgate Park, an historic and vast extraction site, abutting Hampers Lane Sandpit and the former Angels Sandpit. This is a vast area of excavation even if some is now filled with inert rubbish. The spread of extraction across the road to the Chantry should be unacceptable for this reason alone. This deep excavation requires special restoration, no restoration to agriculture is proposed. Although the site is deliverable immediately, being owned by the operator, the period of operation is not disclosed although it could be 10 years. The period of restoration, which is often open-ended, is also not disclosed. The type of restoration is only very vaguely described. • Once the sand is extracted: The site is close to competing markets. The A283 is a busy road leading to the strategic network formed by the A24. However there are problems. If traffic turns west into Storrington it enters an AQMA. If the traffic turns east, it would, as the commentary suggests, require significant highway improvement works. The junction of

2

Sullington/Water Lane and the A283 is already a difficult one and the recently approved infill of the Sandgate quarry, allowing 10 years of heavy goods vehicles to use the same junction, will make it significantly busier. Sand lorries frequently emerge from the pits in Water Lane (Sandgate) and Hampers Lane. The volume of traffic is additionally compounded by the high volume of HGVs and other vehicles diverting from the Arundel bypass through Storrington. In the segment between the above junction and the Washington Roundabout the road has recently accommodated new residential development. There are regularly heavy build-ups of idling traffic throughout the day, not just during peak hours, from east of Sullington/Water Lane to the mini-roundabout at the bottom of School Hill in Storrington. Many drivers divert via Thakeham and West Chiltington to pick up the traffic again beyond Storrington. Road conditions are critical without the added impact of further sand extraction. • Such highway improvements would have a further unacceptable landscape impact, but this does not take into account those long-established residences, including the original Sandgate Park dwellings, which are found all along the north side of the A283. Residents have seen this stretch of road deteriorate badly over the years, and the impact on their amenity should be inhibited rather than increased. • This operation will not have a “minor negative effect” on high quality farmland, as suggested, as it will completely remove the farmland in question. In the long term it may be converted to nature habitat, which national policy does not suggest should take precedence. The quality of existing wildlife in this area of grazing next to a designated ancient woodland and medieval pond system and tributary of the Stor has apparently not been assessed. An informal water- vole survey a couple of years ago found some areas of potentially suitable habitat, but the survey has not yet been followed up. Sullington Lane is known as a crossing point for toads, presumably from these adjacent ponds and bats are prevalent in the area. An ecological report survey must be undertaken to establish whether there are any protected species in this area. • St Mary’s church, Sullington is the only Grade I Listed Building in the entire Parish.

In summary:

• This proposal will severely harm the landscape and visual designations of the area. • This proposal will remove agricultural land from production. • This proposal will have a severe negative impact on the existing wildlife if the road has to be dug down to the level of the bottom of the sand pit. • This proposal will have a severe negative impact on noise and the quality of life of nearby residents including those on A283 east of Sullington Lane. • This proposal will have a severe negative impact on views to and from the South Downs. • This proposal will have a severe negative impact on the historic environment of the designated ancient woodland, medieval pond system and ancient causeway mentioned in 13th century records. • This proposal will have a severe negative impact on the historic buildings and conservation area of Sullington. • This proposal is highly likely to have a severe negative impact on the AQMA. • This proposal has a large cumulative negative impact.

Conclusion:

Members suggest that this proposal is not sustainable due to the negative impact on landscape character and the deliverability of the site and that the site should be excluded.

Yours faithfully

Anna Worthington-Leese (Mrs) Parish Council Chairman and Chairman of the Planning & Development Committee

3

Response ID ANON-NRVC-BRJ3-A

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-14 13:10:35

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Dr

First name: Mairi

Last name: Rennie

Job title (where relevant): Retired

Organisation or affiliation (where relevant): Rogate Parish Council

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name: Dr Mairi Rennie

Resident, Parish/Town Council

Other:

The Soft Sand Review has been submitted for examination, Publication of the Inspector's report Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.:

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?:

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified, Effective, Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: West Heath , Rogate. 'Exceptional circumstances' have not been proved for development of a NEW quarry in the heart of the National Park. Such a development in this central area will violate the Park's purposes. Transport: the quarry is not near the National Lorry Route, but will generate HGV journeys damaging scheduled ancient monuments, a conservation area, and add pollution to an AQMA. Local effect: The development of a new quarry to the east of West Heath will be some distance away across fields, and require a conveyor belt or other machinery to connect the new quarry with the present site. This will generate noise, dust and pollution. The Review does not clearly explain this. The new quarry will also effect nearby protected sites, and an underlying aquifer.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Chantry quarry near Storrington has planning permission to extract sand until 21 February 2042. While it is on the edge of the National Park, its development will not have such a deleterious effect as developing a quarry in the centre of the park, with poorer transport links.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Central Square South Orchard Street Newcastle upon Tyne NE1 3AZ

Our Ref: MV/15B901605 T: +44 (0)191 261 2361 F: +44 (0)191 269 0076

18 February 2020 avisonyoung.co.uk

West Sussex County Council and South Downs National Park Authority via email only

Dear Sir / Madam

West Sussex County Council and South Downs National Park Authority Joint Minerals Local Plan - Proposed Submission Draft Soft Sand Review – January – March 2020

Representations on behalf of National Grid

National Grid has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.

About National Grid National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. The energy is then distributed to the electricity distribution network operators, so it can reach homes and businesses.

National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.

National Grid Ventures (NGV) is separate from National Grid’s core regulated businesses. NGV develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States.

Response We have reviewed the above document and can confirm that National Grid has no comments to make in response to this consultation.

Further Advice National Grid is happy to provide advice and guidance to the Council concerning their networks.

Please see attached information outlining further guidance on development close to National Grid assets. Avison Young is the trading name of GVA Grimley Limited registered in England and Wales number 6382509. Registered office, 3 If we can be of any assistance to you in providing informal comments in Brindleyplace, Birmingham B1 2JB confidence during your policy development, please do not hesitate to Regulated by RICS contact us. National Grid 18 February 2020 Page 2

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect National Grid’s assets.

We would be grateful if you could add our details shown below to your consultation database, if they are not already included:

Matt Verlander, Director Spencer Jefferies, Town Planner [email protected] [email protected]

Avison Young National Grid Central Square South National Grid House Orchard Street Warwick Technology Park Newcastle upon Tyne Gallows Hill NE1 3AZ Warwick, CV34 6DA

If you require any further information in respect of this letter, then please contact us.

Yours faithfully,

Matt Verlander MRTPI Director 0191 269 0094

For and on behalf of Avison Young

avisonyoung.co.uk National Grid 18 February 2020 Page 3

Guidance on development near National Grid assets National Grid is able to provide advice and guidance to the Council concerning their networks and encourages high quality and well-planned development in the vicinity of its assets.

Electricity assets Developers of sites crossed or in close proximity to National Grid assets should be aware that it is National Grid policy to retain existing overhead lines in-situ, though it recognises that there may be exceptional circumstances that would justify the request where, for example, the proposal is of regional or national importance.

National Grid’s ‘Guidelines for Development near pylons and high voltage overhead power lines’ promote the successful development of sites crossed by existing overhead lines and the creation of well-designed places. The guidelines demonstrate that a creative design approach can minimise the impact of overhead lines whilst promoting a quality environment. The guidelines can be downloaded here: https://www.nationalgridet.com/document/130626/download

The statutory safety clearances between overhead lines, the ground, and built structures must not be infringed. 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.

National Grid’s statutory safety clearances are detailed in their ‘Guidelines when working near National Grid Electricity Transmission assets’, which can be downloaded here:www.nationalgridet.com/network-and-assets/working-near-our-assets

Gas assets High-Pressure Gas Pipelines form an essential part of the national gas transmission system and National Grid’s approach is always to seek to leave their existing transmission pipelines in situ. Contact should be made with the Health and Safety Executive (HSE) in respect of sites affected by High-Pressure Gas Pipelines.

National Grid have land rights 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’s 12.2m building proximity distance, and a deed of consent is required for any crossing of the easement.

National Grid’s ‘Guidelines when working near National Grid Gas assets’ can be downloaded here: www.nationalgridgas.com/land-and-assets/working-near-our-assets

How to contact National Grid If you require any further information in relation to the above and/or if you would like to check if National Grid’s transmission networks may be affected by a proposed development, please contact:

• National Grid’s Plant Protection team: [email protected]

Cadent Plant Protection Team Block 1 Brick Kiln Street Hinckley LE10 0NA 0800 688 588 or visit the website: https://www.beforeyoudig.cadentgas.com/login.aspx

avisonyoung.co.uk Response ID ANON-NRVC-BRJ9-G

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-16 10:37:15

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Part B - Representation B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: Chantry Lane Storrington

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: No

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Positively prepared, Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: Dear Sirs, I have been resident in Storrington for the last 58 yrs and seen the Village grow beyond recognition to the detriment of the air quality ( one of the worst in the country) and volume of traffic cutting through from the A27 to the A 24 ad forward to Gatwick. The site in question would involve destroying an area of outstanding beauty and within the National park if the intention is to cut a road through the fields south of the A283 from Chantry to the crossroads of Water Lane on the A283. Also the removal of established old treesa feature of the land up to the Downs. Some years ago a request for a temporary bubble to be erected at Sorrington Lawn Tennis Club in Greyfriars Lane was declined on the grounds it would spoil the view from the south downs National Park looking north. This proposal would be a far greater scar on the landscape and permanent. It would also involve the construction of a roundabout on the A283 at water lane crossroads. Another scar on the area. Finally there has been numerous extraction sites between Storrington and Washington which involves vast numbers of Lorry movements on already congested roads. In addition Eleven years of infill are planned for the Cemex site in Water Lane in the future. Enough is enough.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: I see no way it should proceed.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Response ID ANON-NRVC-BRJS-A

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-19 10:15:30

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mrs

First name: Hannah

Last name: Hyland

Job title (where relevant): Planning Specialist

Organisation or affiliation (where relevant): Environment Agency

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name:

Address Line 1:

Address Line 2:

Address Line 3:

Address Line 4:

Postcode:

Telephone number:

Email

Email address: [email protected]

Government Organisation

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR38

B2 Do you consider the Soft Sand Review to be: (tick as appropriate) Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Effective

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: This response refers to SSR 38 in relation to the new allocation of East of West Heath Common (Extension).

Overall we do not consider the allocation itself to be unsound and are pleased to see specific requirements for a hydrological risk assessment within the detailed requirements. However, we would wish to see this section expanded to highlight the potential limitations on yield the outcome of a hydrological assessment may require due to the proximity to the Harting Stream, a Main River, to the south and the surface water drains on site.

The site lies above Marehill Clay above Folkestone Beds (Principal Aquifer). The groundwater levels are likely to be high. The site boundary currently lies adjacent to Harting Stream, a Main River, and there are several surface water drains that also run through the site. We have previously suggested that to manage impacts of the development on the water environment the southern boundary of the site be realigned to the north of the east-west drain. It is possible that the outcome of the hydrological assessment would demonstrate that the workable area for the site would be as per that alignment.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: We recommend that para. 7.2.9 section (viii) is expanded to read as follows:

"(viii) A hydrological assessment should be completed, evaluating and seeking to minimise the impact from the proposals on ground water and watercourses. Where necessary, changes to the development boundary will be made to prevent impacts on the water environment"

We had previously advised that the southern boundary of the allocation was realigned to north of the east-west drain to overcome potential impacts from quarrying in this area. This has not happened and therefore we advise that the supporting text highlights that as a result of the hydrological assessment the developable area may be affected.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Response ID ANON-NRVC-BRJG-X

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-20 09:50:37

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name:

Address Line 1:

Address Line 2:

Address Line 3:

Address Line 4:

Postcode:

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR1 - 43

B2 Do you consider the Soft Sand Review to be: (tick as appropriate) Legally compliant or sound? - B2.1 Legally compliant?: No

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Positively prepared, Justified, Effective, Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: It is inconsistent with the aims and objectives of protection for National Parks

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: It is fundamentally flawed

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BR6X-U

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-23 14:15:33

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant): Director

Organisation or affiliation (where relevant): Steynig & District Community Partnership Ltd

A3 Contact Address Details

Other (please specify below) Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: Single Issue Soft Sand Review - Proposed Submission Draft(Reg19) Paragraph 7.1.7, Page 53; Soft Sand Selection Report, Point 3 Appendix 5 Pages 188, 189, 191, 193

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Positively prepared, Justified, Effective, Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: STEYNING AND DISTRICT COMMUNITY PARTNERSHIP – VISITOR & TOURISM GROUP Response to Single Issue Soft Sand Review – Proposed Submission Draft (Regulation 19), January 2020

Background The Visitor & Tourism Group of the Steyning and District Community Partnership (SDCP) promotes the area as a tourist destination together with ensuring that residents are attracted to and enjoy the area. We have been in existence for around 15 years, during which time we have promoted and devised numerous projects and events to benefit the local area to both attract visitors - vital to our local economy – and enhance the lifestyle of our residents. Our Committee has enjoyed and still enjoys members from the professional world, including tourism officers and tourism marketing consultants. The town and surrounding villages are acknowledged one of the most as beautiful and historic areas within West Sussex, positioned at the foot of the South Downs National Park. In common with many market towns the local economy is fragile and sensitive to change. Our first contention is that the assessment of the Ham Farm site has ignored the impacts on visitor numbers. This has two consequences. • The process for assessing sites for allocation in the Plan is unsound because no attempt has been made to assess impacts on visitor numbers.

• Because we consider that visitor numbers would reduce as a result of the workings, and because the assessment of the Ham Farm site does not recognise these impacts, we consider that the allocation of the Ham Farm site is unsound. Our second contention is that the Ham Farm site would have an unacceptable impact on the surrounding landscape, especially when viewed from the Downs. Our third contention is that inclusion of the Ham Farm site contravenes one the Guiding Principles. Our fourth contention is that several of the impacts of the Ham Farm site have been incorrectly scored. Impacts on visitor numbers The impact on green tourism has been undervalued and misunderstood. The table below, Table 53 extracted from the Tourism South East South Downs Visitor & Tourism Economic Impact Study in January 2013, shows the importance of the SDNP. In 2011/12, it attracted the highest number of trips (44.7 million) and the highest number of visitor-days (46.4 million), with visitor spend being the second highest at £464 million. Visitors buy goods and services from a wide variety of local businesses, ranging from accommodation providers, shops, pubs, restaurants, cafes to taxis and petrol filling stations. In 2011/12, the number of jobs supported by tourism in the SDNP, including full time, part time and seasonal, was estimated to be 11,706, of which 8,194 were estimated to be filled by people living within the SDNP. This clearly shows the importance of the South Downs area as a very major visitor attraction, making an important contribution to the local economy.

Steyning is a gateway town to the SDNP and its main attractions include easy access to the SDNP, offering openness, naturalness, lack of noise and outstanding views. Visitors come to Steyning to enjoy these amenities also then partake of the shops and cafes, thereby supporting the local economy. Any detraction from the scenic beauty of our area will, of course, reduce visitor numbers. Hilary Benn, the Environment Secretary at the time of the announcement of the South Downs to become a national park said: “National park status can be a real boost for the local economy, attracting new visitors, businesses and investment, but above all, the South Downs’ wonderful countryside will be protected forever for the enjoyment of everyone.” At the same time, Poul Christensen from Natural England stated: “National park status for the South Downs not only secures its place among England’s finest landscapes, but it is also great news for its people and wildlife. The South Downs are a critical green lung for the south-east, providing millions of people with unparalleled access to open countryside in a way that has incalculable benefits for their health, wellbeing and their appreciation of why the natural environment matters. Attracting around 39 million visitor-days every year, the South Downs was one of 12 areas in England and Wales identified in the 1947 Hobhouse report as being worthy of attaining national park status. Protected areas like this have played a vital role in helping our most treasured landscapes and wildlife withstand the pressures that our crowded island is throwing at them. Our wider countryside is faring less well and over the next 60 years we will need to shift our focus to ensure that the natural environment outside protected areas is better able to cope.” Accepting both these statements as fact, it follows that degradation of the SDNP, including degradation of views from the South Downs, will reduce visitor numbers from what they would otherwise be. Impacts on the landscape The South Downs National Park Authority Survey Final Report 2015, published in March 2016, found that visitors’ level of enjoyment stood at 77% for scenic landscape and breath-taking views. Views of this area are therefore of a high sensitivity and the degradation of such will have a serious impact on those seeking tranquillity, peace and stunning scenery. Prior to the SDNP being created, there were an estimated 39 million person-day visits to the South Downs, spurring the need to designate the Downs as a National Park to ensure safeguarding these precious amenities. Contravention of Guiding Principles Single Issue Soft Sand Review – Proposed Submission Draft(Reg19) Page 53

New Paragraph 7.1.7 states that there are six guiding principles that have been used to guide the identification of the allocated sites: These are:

First principle: Places where there are opportunities to restore land beneficially, for example a net-gain in biodiversity.

Second principle: Places without a sensitive natural or built environment and away from communities, in order to protect the amenity of businesses, residents and visitors to West Sussex.

Third principle: the new sites should have good access to the Lorry Route Network (LRN). Access from the site to the LRN should be acceptable ‘in principle’, that is, there should not be any technical issues, with regard to highway capacity and road safety, that cannot be overcome.

Fourth principle: The need to protect and enhance, where possible, protected landscapes in the plan area, particularly ensuring that any major minerals development will only be considered within designated landscapes in exceptional circumstances and in the public interest.

Fifth principle: The need to avoid the needless sterilisation of minerals by other forms of development.

Sixth principle: The need to avoid the needless sterilisation of minerals by other forms of development.

The last two are the same so this is presumably an error.

The second principle is clearly contravened. Residential and business properties adjoin the site and the area is visited by many people seeking the attractions of Steyning and the South Downs. Scoring of impacts The assessment of the Ham Farm site is given on pages 86 to 94 of the Soft Sand Sites Selection Report, January 2020 (4SR2020).

The basis for grading impacts as one of green, green/amber, amber, red/amber, and red is given on pages 28 to 32 of the 4SR2020.

The methodology explains that one red score would rule out a site from further consideration. The Ham Farm site has three red/amber scores but no red scores. The three red/amber scores are now considered, along with the score for landscape designations and visual impact. RAG Score – Point 3 Appendix 5 Landscape designations and visual impact (Page 188) The SDNP Survey in 2015 found that visitors’ level of enjoyment stood at 77% for scenic landscape and breath-taking views. Views of this area are therefore of a high sensitivity and the degradation of such will have a serious impact on those seeking tranquillity, peace and stunning scenery. In our opinion, the RAG score should therefore be red. Historic environment designations (Page 189) In the RAG score column, it says: “The site may cause moderate harm to a nearby Listed Building …. in the absence of mitigation measures.”

The key word is “moderate”. “Severe” harm would warrant a red score and “major” harm would warrant a red/amber score.

No explanation is given for the attribution of “moderate”. Indeed, given the number and proximity of the Listed Buildings listed in the middle column, one could easily argue that the harm would be “severe” and therefore warrant a red score.

It is possible that the impact has been downgraded to “moderate” by assuming that the impacts could be mitigated. Views of the workings from the Listed Buildings and properties can be obscured by earth bunds or fences. (Vegetation would take too long to grow and provide a complete screen.) Earth bunds and fences, and indeed anything else which obscures the workings, in themselves would impact adversely on the Listed Buildings. Earth bunds and fences would be appreciably visually intrusive compared with the current outlook from these properties.

We contend that there is no justification for the attribution of “moderate”. Moreover, we contend that the adverse impacts of the mitigation measures have been ignored.

We contend that the impact would be “severe”. The RAG score should therefore be red.

Soil quality (Page 191)

In the RAG score column, it says: “The site contains Grade 3 soils, which could be majorly impacted by mineral extraction.”

In the middle column, it says: “The site contains grades 3 best and most versatile agricultural land…”

(Agricultural land is classified from 1 to 5 (known as Agricultural Land Classification or ALC 1 to 5). ALC 3 has two subdivisions, one for “good” and one for “moderate”.)

A red score would be warranted where “the entire site contains best and most versatile land which could be severely impacted by this site.”

A red/amber score would be warranted where “Large parts of the site contain best and most versatile land which could be majorly impacted.”

Given that both red and red/amber scores require the land to be “best and most versatile”, and that the middle column on page 92 says that the site contains “best and most versatile agricultural land”, the allocation of either red or red/amber scores hinges on whether the best and most versatile soil covers the entire site or only a large part of the site.

We contend that, as there is no mention of part of the site (in the assessment on page 92 of the 4SR2020), the comments must apply to the entire site. The RAG score should therefore be red.

Amenity (Page 193)

In the RAG score column, it says: “A number of residential properties are in close proximity to the site. These residents may be subject to high levels of harm from noise, dust and light associated with mineral extraction from the site.”

A red score would be warranted where “The site contains or directly neighbours uses that could be severely impacted. No mitigation can be applied.”

A red/amber score would be warranted where “The site is in proximity to land uses that may be subject to high levels of harm. This includes impact of noise, dust and light. Mitigation measures would be required to deem this site workable.”

There is no mention of the possible or likely impacts of mitigation in either the middle column or the RAG score column. If it was thought that the impacts could be mitigated, then surely some comment to that effect would have been included in the assessment.

Residential properties directly abut the site. Their proximity can be no closer. Any attempt at mitigation, such as earth bunds or fences, would themselves constitute an intrusion. Amenity is bound to be severely impacted. The RAG score should therefore be red.

Conclusions We contend that process for assessing sites for allocation in the Plan is unsound because no attempt has been made to assess impacts on visitor numbers. Because we consider that visitor numbers would reduce as a result of the workings, and because the assessment of the Ham Farm site does not recognise these impacts, we consider that the allocation of the Ham Farm site is unsound. We contend that the Ham Farm site would have an unacceptable impact on the surrounding landscape, especially when viewed from the Downs. As this impact should be scored red, the allocation of the Ham Farm site is unsound. We contend that inclusion of the Ham Farm site contravenes the Second Guiding Principle and the allocation of the Ham Farm site is therefore unsound. We also contend that several of the impacts of the Ham Farm site have been incorrectly scored and four should be red: landscape designations and visual impact; historic environment designations; soil quality; and amenity. The allocation of the Ham Farm site is therefore unsound.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Withdraw the Ham Farm site for consideration for use as a soft sand quarry.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Not Answered

Part C - About You (The Equality Act 2010)

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR2

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: Within the context of an assertion that ‘Land won soft sand is of a particular quality that cannot be substituted by other minerals’ it is further stated that ‘The soft sand resource is heavily constrained due its location within or adjacent to the South Downs National Park.’ Given that the statement is about quality rather than other issues such as those of cost or ease of extraction, if soft sand of adequate quality is feasibly available from other sources then the statement that the soft sand resource is heavily constrained due to its location within or adjacent to the South Downs National Park would not be justified.

The ‘Statement of Common Ground on Soft Sand Supply in the South East’ 11 April 2017, of which WSCC was a party to, states at paragraph 1.5 that’ Soft sand is an important aggregate mineral that, for certain end uses, cannot be substituted by other materials’. Note that it does not specifically make that claim for land won soft sand. The Statement also recognises at paragraph 6.3 that there is no qualitative difference between land won and marine won sands. While currently marine won soft sands are sourced from the Bristol Channel (para 6.4) research by the Crown Estates shows potential economically viable deposits in the English Channel and Thames Estuary (para 6.5). There is potential for import of marine won soft sands from the Netherlands (para 6.6) and while there are considerations around the sourcing of marine won soft sands the conclusion reached by the Statement with regard to the sourcing of marine won soft sands was (para 6.7) ‘However, increasingly constrained land-won opportunities for supply soft sand may well provide a prompt for further investigation into these matters in the south-east.’

The significance is, of course, that given the availability of soft sand from other sources, including potentially from relatively close by in the English Channel, will have a bearing on the consideration of the Major Development Test for the allocated sites that fall within the SDNP

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: The assertion that marine won soft sands cannot meet the required quality standard should be removed.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Yes Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR40

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: There is an inconsistency between the description of the Development Principles and the actual wording of the Development Principles. Also the Development Principles listed fail to address all of the specific issues relating to the Chantry Pit extension.

The description of the Development Principles is given as “...... ‘development principles’ for the site, that is, specific issues that will need to be addressed at the planning application stage, as and when proposals come forward for the allocated site. “ Whereas, in the most part, the listed development principles are couched in terms of activities that ‘should’ be carried out. This could be interpreted as that while a potential issue is recognised the activity to identify the scope, the impact and the possible mitigation to address the issue, is optional. This is a concern due to the issues related to traffic congestion, air pollution, noise and other cumulative impacts on the local community arising from the prospect of 3 working sand quarries in close proximity. No development principle is included to address the issue of Chantry Mill SSSI. This SSSI extends across the entire original pit workings and beyond, but not into the proposed pit extension. The SSSI designation relates to a geological feature. From maps included in old planning applications for Chantry Pit it appears that the proposed extension would abut this feature so there is a possibility that workings on the extension could impact the feature.

No requirement for an assessment on the impact on historic buildings is included. The Chantry pit extension site is approximately 600m from the hamlet of Sullington which boasts a Grade 1 listed church, a Grade II listed Manor/Farmhouse and a Grade II listed tithe barn in close proximity, plus another Grade II listed building a few metres away.

Sullington hamlet is a tourist attraction due to its historic nature and setting on the scarp slope of the South Downs. Sullington Manor Farm provides tourist accommodation and a cafe within a Lottery Fund restored 16th Century barn - 'The Old Workshop' , which also serves as an exhibition centre and attracts users of the SDNP and local people from the area. The Grade II listed tithe barn is used as a wedding venue and other events. The development principles should also include an assessment of the potential economic impact on this community.

Development principle (v) suggests the use of native trees and shrubs to provide screening. It does say that "Any screening landform and/or planting should be designed to be consistent with local landscape character in order to minimise unintended additional impacts on landscape character from incongruous screening features;" . However the Chantry Pit extension site is listed on the Natural England Priority Habitats Inventory, as is the field at its southern boundary. This would suggest that any planting of trees and shrubs should have regard to maintaining existing habitats as well as the landscape character and visual impact of the site as down land pasture.

Development principle (ix) refers to a hydrological survey given the location of the far reaches of the River Stor to the Arun Valley SPA (at Pulborough Brooks). It should also take into account the potential impact of workings at the Chantry Pit site on the River Stor at its eastern end (near the source of its main tributary) when it is still classified as a chalk stream. While the Habitats Regulation Assessment reported the river to have poor water quality this is contradicted by a study by the Wild Trout Trust on behalf of Horsham District Council in 2015. Nothing has changed in the area since 2015 apart from habitat improvement work on a section of the Stor running through Meadowside. Meadowside is a HDC owned green space maintained with support by a local community group. The river flows from Meadowside into Storrington and the Mill Pond in the centre of the village. As well as being a public amenity and habitat the Mill Pond is a fishery for the Pulborough Angling Society.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: Wording of development principles be changes to indicate that they are required and not optional so that they are consistent with the definition given for development principles.

Include development principles that require assessments in relation to the adjacent SSSI and historic buildings as have been required for other allocated sites.

Include a development principle that requires an assessment of the economic impact on the local community in line with the duty of the National Park Authority to seek to foster the economic well-being of communities within the National Park.

Amend development principle (v) to require that any screening also has a regard to protecting priority habitats.

Amend development principle (ix) to recognise the value of the River Stor as a habitat and for recreational purposes to be consistent with the equivalent development principle for Ham Farm.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Not Answered

Part C - About You (The Equality Act 2010)

Response ID ANON-NRVC-BR6V-S

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-24 10:21:16

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR36

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: No

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified, Effective

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: As a resident of Durleighmarsh for over 25 years I have seen an increase in traffic due to the existing quarry and the subsequent damage to the local road surfaces and historic Durford Bridge.

1 .Durford Bridge This historic bridge built in the 16th century is Grade 2 listed and is used by every lorry egressing and exiting the quarry. Vehicles weighing 20-30 tonnes when loaded as well as farm vehicles are causing damage to this Historic Monument and damage in the form of a crack is now visible and top stones have been loosened and lost as a result of lorries having to manouevre to cross the bridge. With an increase in traffic already due as a result of permitted development at Sky Park Farm as a deer farm opening to the public, it is outrageous that continued heavy traffic should be authorised within the SDPN.

2. Pedestrian Safety and Litter Durford Lane is a narrow lane with limited passing spaces and an increase/continuation of heavy vehicle traffic to this road which has no pavement makes it difficult and dangerous for pedestrians and cyclists. The road surface is damaged with deep pot holes also causing potential damage to vehicles. Also as local residents we are continually picking up litter which is discarded from vehicles along Durford Lane.

3. Access The Durford Lane road surface is severely damaged with pot holes, damaged storm drains and persistent water flow due to drains becoming blocked with silt and underlying water springs adding to the potential for road surface erosion. Any interventions by WSCC are only ever a very short term measure and within weeks drains become blocked with a build up of silt and debris. The potential for accidents as result of vehicles trying to turn left from the A272 coming from the Midhurst direction is also high. On many occasion vehicles trying to turn left are forced to wait on the busy A272 to allow a lorry to negotiate the exit from Durford Lane onto the A272.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: 1. In order to preserve the integrity of the Durford Bridge a restriction on the size and weight of lorries should be put in place. Repairs need to be made to both the structure of the Bridge itself as well as the drainage and road surface in Durford Lane.

2. The impact of the continuation of heavy lorry traffic from the proposed Quarry extension should be properly assessed as this affects not only the safety of the residents and other users of Durford Lane but also the local villages of Rogate as lorries continue their route along the A272.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BR68-U

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-24 12:40:54

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

- Representation B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR39 Chantry Lane (Extension)

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: 1. Landscape and History: The review ignores the effect of the major earthworks necessary for easterly access and subsequent scarring by sand extraction on a, not only beautiful, but uniquely special view of, and approach to, the medieval enclave of Grade I listed Sullington church and Manor farm, and the view of the Downs. 2. Disturbance: Chantry Lane is one of the the most urban sites of the nine in that it has the largest number of surrounding residences. In consequence, extraction and transportation works would cause more disturbance to people than other sites, in contravention of your second principle (Review para. 4.9). 3. Congestion: The A283, through the village, is already frequently backed up with stationary traffic, sometimes beyond the Water Lane junction. The addition of regular lorries laden with sand would only exacerbate this. 4. Pollution: The A283 through the village is already one of the most polluted in the country. 5. Congestion and practicality: It is already difficult for cars to egress Sullington Lane and Chantry Lane onto the A 283. It is hard to imagine just how much harder this would be for large and heavily-laden sand lorries to do this. Any attempt to ease this at Sullington Lane would require major Earthworks and related land take, as commented in 1. above

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: The Chantry Lane (Extension) should be permanently removed from the potential extraction list

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Not Answered

Part C - About You (The Equality Act 2010)

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR 6.2.22: Draft Sub-policy M2: Soft Sand: (a), (i),

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: Policy M2. This policy is unsound because not consistent with national policy:

Policy M2 of the draft Soft Sand Review (draft SSR) sets out conditions for refusing or permitting proposals for land-won soft sand extraction:

SSR 6.2.22: Draft Sub-policy M2: Soft Sand: (a), (i), uses the word “ensure” (“ensure a steady and adequate supply of aggregates”) whereas national policy (NPPF paragraph 207- Maintaining supply) states that minerals planning authorities “should plan for” a steady and adequate supply of aggregates, indicating a more flexible approach to minerals planning. The wording of policy M2 (a), (i), should be substituted for “should plan for a steady and adequate supply of aggregates” as per NPPF wording (paragraph 207) .

The draft wording of Policy M2 is not consistent with national policy and therefore unsound.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: The wording of policy M2: (a), (i), should be substituted for:

“should plan for a steady and adequate supply of aggregates”

This wording would be consistent with national policy as per NPPF wording (paragraph 207).

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

Yes

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: SSR 7.1.1

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: SSR 7.1.1 Uses the word “ensure” (“ensure a steady and adequate supply of aggregates”) whereas national policy (NPPF paragraph 207- Maintaining supply) states that minerals planning authorities “should plan for” a steady and adequate supply of aggregates, indicating a more flexible approach to minerals planning. The wording of SSR 7.1.1 should be substituted for “should plan for a steady and adequate supply of aggregates” as per NPPF wording (paragraph 207)

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: The wording of SSR 7.1.1, should be substituted for:

“should plan for a steady and adequate supply of aggregates”

This wording would be consistent with national policy as per NPPF wording (paragraph 207).

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Part C - About You (The Equality Act 2010) Response ID ANON-NRVC-BR6H-B

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-25 11:49:34

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title:

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Name:

Resident

Other:

Consultation on any further changes to the Review, Date of the Public Examination, Publication of the Inspector's report, Adoption of the Soft Sand Review

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR36 East of West Heath Common

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: East of West Heath Common

The Site. The proposed site is not really an extension site but is a new site close to an existing site, about 300 metres away. Transport of the sand from the ‘extension’ to the existing site would inevitably create noise and dust and adversely impact the common land in-between the existing and ‘extension’ locations (Downpark Common). The site is on the very western edge of Sussex, only 300 metres from the Hampshire border. If the sand is for Sussex (which is 75 miles across west to east) then this will result in high transport mileage and associated pollution.

Traffic. The yield from the proposed site over 15 years would equate to roughly 80 lorry trips per week. Though the site is close to the A272 access to the road is over an ancient Grade II bridge over the Rother.

If the sand is for Sussex it is likely that lorries would want to head east on the A272. Although that it is an A class road it has several problems for lorry traffic, all within 7 miles of the site: • There is a very narrow bend in Rogate near the church. Large vehicles need to cross the centre of the road into oncoming traffic, even though vision around the bend is restricted by a high stone wall. • The sandstone bridge in Trotton is Grade I listed and dates to about 1600. It is controlled by traffic lights because it is too narrow for two vehicles to pass. • There is regular congestion in Midhurst, where the A272 east/west traffic has to join the A286 north/south traffic, and together go through the town centre on the town’s main shopping road. • Where this road enters Midhurst from the south it is again too narrow for a lorry to pass oncoming traffic easily, and has narrow pedestrian pavements. This has directly resulted in the death of a pedestrian (July 2014).

In summary, the proposed site for extraction of soft sand would impact common land within the SDNP, increase wear and tear on two listed ancient bridges, and impact me as a local resident through increased lorry traffic through Rogate and further east.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: If the proposed site does go ahead I would request that there is a requirement on the extracting company to prohibit traffic using the A272 to the east of the site (instead using the A272 to the west, which soon reaches the more suitable A3 road).

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No Response ID ANON-NRVC-BR6J-D

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-25 12:54:02

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mrs

First name: Elaine

Last name: Hunt

Job title (where relevant): Assistant Clerk

Organisation or affiliation (where relevant): West Chiltington Parish Council

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant): West Chiltington Parish Council

A3 Contact Address Details

Name: Assistant Clerk

Address Line 1: West Chiltington Parish Council

Address Line 2: The Reading Room,

Address Line 3: Church Street

Address Line 4: West Chiltington

Postcode: RH20 2JW

Telephone number: 01798817434

Email

Email address: [email protected]

Parish/Town Council

Other: Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.: 39 & 40

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?:

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified, Consistent with National Policy

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: West Chiltington Parish Council supports Storrington and Sullington Parish Council's STRONG objection on the following grounds:-

• This proposal will severely harm the landscape and visual designations of the area. • This proposal will remove agricultural land from production. • This proposal will have a severe negative impact on the existing wildlife if the road has to be dug down to the level of the bottom of the sand pit. • This proposal will have a severe negative impact on noise and the quality of life of nearby residents including those on A283 east of Sullington Lane. • This proposal will have a severe negative impact on views to and from the South Downs. • This proposal will have a severe negative impact on the historic environment of the designated ancient woodland, medieval pond system and ancient causeway mentioned in 13th century records. • This proposal will have a severe negative impact on the historic buildings and conservation area of Sullington. • This proposal is highly likely to have a severe negative impact on the AQMA. • This proposal has a large cumulative negative impact.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound: The complete removal of the Chantry Lane Extension site proposal.

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Planning Services Our ref: PL00 539645 West Sussex County Council Your ref: County Hall Chichester Telephone 020 7973 3700 West Sussex PO19 1RH Fax 01483 252001 Email [email protected]

By email only to [email protected] Date 25 February 2020

Dear Sir or Madam

Soft Sand Review of the West Sussex Joint Minerals Submission Local Plan Consultation (Reg ulation 19)

Thank you for your email of 6 January 2020 inviting comments on the above document.

As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process and welcomes the opportunity to comment upon this key planning document.

Questions of identified need and supply strategy are largely beyond the remit of Historic England.

In terms of identification of potential sites is of interest to us and we are supportive of the site selection methodology and the inclusion of the historic environment as one of the key criteria.

We have comments to offer on two of the allocated sites:

East of West Heath Common – a scheduled medieval moated site in Parlour Copse to the south and two scheduled bowl barrows south of Wenham Cottage to the north-west of the proposed extraction site may be impacted in their setting by the quarrying of soft sand. The ongoing impact of heavy vehicle traffic on the nearby grade II listed and scheduled Durford Bridge should be assessed and means of avoidance or mitigation of damage sought as part of any scheme to extend the quarry.

Ham Farm - the setting of the grade II listed Horsebrook Cottage, located just outside the proposed site to the north west, will potentially be impacted, and the Rectory and Round House listed buildings (both grade II) may be also affected by, e.g. noise, dust, traffic.

Historic England, 4th Floor, The Atrium, Cannon Bridge House, 25 Dowgate Hill, London EC4R 2YA Telephone 020 7973 3700 HistoricEngland.org.uk Please note that Historic England operates an access to information policy.

Correspondence or information which you send us may therefore become publicly available.

Historic England would strongly advise that the Council’s own conservation advisers are closely involved throughout the preparation of the draft Plan, as they are often best placed to advise on local historic environment issues and priorities, sources of data (including the Historic Environment Record) and, consideration of the options relating to the historic environment locally.

These comments are based on the information provided by you at this time and for the avoidance of doubt does not reflect our obligation to advise you on, and potentially object to, any specific development proposal which may subsequently arise from this or later versions of the plan and which may, in our view, have adverse effects on the historic environment.

Yours faithfully,

Alan Byrne Historic Environment Planning Adviser

Historic England, 4th Floor, The Atrium, Cannon Bridge House, 25 Dowgate Hill, London EC4R 2YA Telephone 020 7973 3700 HistoricEngland.org.uk Please note that Historic England operates an access to information policy.

Correspondence or information which you send us may therefore become publicly available.

Response ID ANON-NRVC-BR6F-9

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-25 16:45:34

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Organisation or affiliation (where relevant):

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR 39/40

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?: Yes

Legally compliant or sound? - B2.2 Sound?: No

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

Justified

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.: A road running parallel to A283 from Chantry Lane to Sullington Lane is preposterous. The visual intrusion to the landscape, affording one of the finest views of the South Downs from the Findon gap to Kithurst Hill, would be sullied for a generation. The idea that HGV's can ever access this site from Sullington Lane should be killed off once and for all. The lane is totally unsuited to use by HGV's however it may be configured. As it is currently formatted there is quite a steep pull up to the the T junction with A283/Water Lane, and HGV's would be negotiating a difficult and busy junction. The usual problems with sand spilling onto the carriageway would be replicated here as they are at the Britannia Crest pit less than a mile to the east. We have been told that Britannia Crest have applied for further permission to extract sand from that pit further delaying the restoration of that area to the people of Storrington and Sullington. It is claimed by the operator that the sand has not been exhaustively worked out due to a lack of demand for the product. So why the need for extraction from Chantry quarry? As the Britannia Crest model shows once planning permission is granted operators keep asking for extensions. The BC Hampers Lane pit should have have been restored to nature years ago. The unique and historic Saxon enclave of Sullington Manor, Church and Tithe Barn is closeby and would be perilously close to the line of any new access road and would no longer occupy the same remoteness, at the foot of the Downs, that it does now. With all the work carried out by various agencies involved in the Storrington Low Emissions project ( including WSCC) to improve the air quality locally it would surely be unthinkable to compromise that by encouraging more HGV'S into this area so close to the village.

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

No, I wish to communicate through written representations

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions:

Would you like to make another representation?

No

Response ID ANON-NRVC-BR6M-G

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-02-25 17:17:25

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: mr

First name: thomas

Last name: aubrey

Job title (where relevant): chair

Organisation or affiliation (where relevant): the steyning society

A2 Client Details if applicable

Title:

First name:

Last name:

Job title (where relevant):

Organisation or affiliation (where relevant):

A3 Contact Address Details

Email

Email address: [email protected]

Resident

Other: retired Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to?

SSR Reference No.:

B2 Do you consider the Soft Sand Review to be: (tick as appropriate)

Legally compliant or sound? - B2.1 Legally compliant?:

Legally compliant or sound? - B2.2 Sound?:

B3 Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate)

B4 If you consider the Soft Sand Review to be be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.

Reasons why plan is believed to be unsound and/or not legally compliant.:

B5 Please explain in the box below what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound. Please be as precise as possible.

Changes needed to make the Plan legally compliant and/or sound:

B6 Do you consider it necessary to attend and give evidence at the hearing sessions during the examination? (Tick as appropriate)

Not Answered

B7 If you wish to participate at the hearing sessions during the examination, please outline why you consider this to be necessary.

Reasons why respondent wishes to attend hearing sessions: I do not want to participate at the hearing sessions

Would you like to make another representation?

No

Dear Sir/ Madam As chair of the Steyning Society I am writing to express the dismay felt by the Community of Steyning for the suggested siting of the proposed sandpit at Ham Farm Steyning.When it was first proposed about 2 years ago there was the largest protest meeting I have ever attended in Steyning; so much so, one could not get into the Steyning Centre.

The Steyning Society fully endorse the well argued case made by the Visitor and Tourism Group of The Steyning and District Community Partnership.It certainly needs to be considered carefully. However we wish to make further points.

The Folkestone Beds , which provide the soft sand , underly a large area of West Sussex particularly in the Western half.The A23,A24 and A29 all cross the Folkestone Beds and also blight their immediate surroundings. It is at these points that the sand ought to be worked causing no environmental damage and being on a trunk road for distribution. In fact road improvements could well release large amounts of sand. Is WSCC thinking strategically?

IF the Ham Site were developed WSCC must be aware of the serious impact there would be on the A283— already an inadequate A Road—— narrow twisting and congested as a major By-Pass for the A27 together from Chichester to the Brighton Conurbation. Pollution Levels in Storrington already exceed the legal amounts and delays at the A24 roundabout at Washington are regular. All this will be made worse as the new IKEA opens and more people abandon the A27 for the A283.

It does seem WSCC pays little regard for the future or Tourism in Sussex. A major growth industry; and Steyning has claims to be the major Gateway into the South Downs National Park. Chanctonbury Ring is the highest point of the South Downs and the iconic landmark of Sussex highlighted by poetry and painting.Ham Farm Sand Pit will spoil the view from Chanctonbury and change its environs and atmosphere.

We very much hope WSCC will read and heed these warnings Yours sincerely Tom Aubrey Chair The Steyning Society

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