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Response to the SDNPA Comments

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Response to the SDNPA Comments Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.1. INTRODUCTION 1.1.1. The following document provides a response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017). 1.1.2. Landscape and visual matters have been addressed and the comments are reproduced from page 3 and 4 of the SDNPA response. The comments have been reviewed in light of the amendment to the planning application and the removal of Stage 4. 1.1.3. The Landscape and Visual Impact Assessment undertaken by B&A is referred to as the 2017 LVIA. Reference is also made to the Addendum Report produced by B&A in February 2018. 1.2. TIDEMILLS AREA, LANDSCAPE CHARACTER OF THE AREA AND THE SETTING TO THE NATIONAL PARK 1.2.1. SDNPA Comment: ‘The significant visual effects of the proposal are clearly demonstrated in the photomontages and are most striking when viewed from the Tide Mills area of the National Park. This is likely the most significant view as the change here will be front and centre in views. The significance of these effects and the role that the site currently plays in the landscape character of the area and the setting to the National Park has failed to be drawn out in the LVIA’. 1.2.2. B&A Response: The Site represents a relatively small area and consists of industrial buildings (sheds) and large areas of concrete hardstanding. It is located in the port area of Newhaven which includes commercial and industrial land use. It is important to recognise that the current baseline situation encompasses planning consents in the vicinity including the Rampion building which is now completed to the west of the Site, the Newhaven East Quay and Port Expansion Area (consent reference LW/15/0034) to the south of the Site and the Newhaven Port Access Road (NPAR) which is broadly to the east and incorporates a bridge across Mill Creek and the southern extension. The changes to this situation as a result of the Proposed Development is very small. Viewpoint location 1: From Footpath No. N40b 1.2.3. In the 2017 LVIA, photomontages were prepared for five viewpoint locations, No’s 1 to 3, 8 and 11 and have been updated due to the removal of the Stage 4 development. 1.2.4. The above illustrate the baseline situation including the Newhaven East Quay and Port Expansion Area etc. and Stage 1 to 3 development. Bright & Associates Page PN1081, February 2018 1 Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) 1.2.5. Viewpoint location 1: From Footpath No. N40b is to the east of the Site and is located in the Tide Mills area on the edge of the South Downs National Park (SDNP). Receptor sensitivity is Medium to High (Footpath users) given the location is close to the existing industrial areas. Visual Pack Supporting Information (Fieldsheets) were provided in Appendix 4 of the 2017 LVIA and record features such as components and characteristics etc. at each Viewpoint Location. The industrial nature of the view including lighting towers and disturbed landscape experience in terms of tranquillity and management was noted by the assessor. 1.2.6. The Addendum Report concurs with the conclusions of the 2017 LVIA. The Proposed Development would be visible but viewed against existing development and rising ground on the western side of the River Ouse. In Stage 1, the aggregate processing plant and storage areas and in Stage 3, the concrete batching and cement silos would be seen, although this would constitute only a minor component of the wider view and would not affect the overall quality of the scene. In Stage 2, there would be glimpsed views of the conveyor and the storage areas. Consequently, in Stage 1 and 3 there will be a Small magnitude of impact and a resultant Minor- Moderate (neutral) significance of effect. For Stage 2 there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. Close Range Views 1.2.7. The beach area of Tide Mills is also examined through a narrative of close range views. Promoted recreational routes such as the Poppy Trail and the Bishopstone Walk together with the nature reserve which forms part of planning consent LW/15/0034 (Newhaven East Quay and Port Expansion Area) is also nearby and acknowledged in the 2017 LVIA. They may provide an additional attraction for visitors and will bring the public in close proximity to the Site (Section 7.5: Visual Impact Assessment (Close Range Views)). The port area and industrial uses form part of the current scene. 1.2.8. The 2017 LVIA described aspects of the Newhaven East Quay and Port Expansion Area which includes a fenced boundary and results in a baseline of visual amenity including industrial buildings, related noise and activity and other built form. The 2017 LVIA noted that the Proposed Development would add to the amenity rather than causing new adverse effects and this assessment also applies to the Addendum Report. 1.2.9. For such close range views, when looking in a westerly direction, the Proposed Development is viewed against rising ground on the western side of the River Ouse, with residential development at a higher elevation and existing commercial and industrial activities evident in the port area. Given that the proposed built form is generally similar to that currently in situ and can be successfully integrated, the scale of the change from the baseline situation is minor. Stages 1 to 3 are located within a cluster of existing development. A Small level of change was noted for the 2017 LVIA and the Addendum Report concurs with the findings of the 2017 LVIA. Bright & Associates Page PN1081, February 2018 2 Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) Other Viewpoint Locations within the SDNP 1.2.10. In terms of other photomontages, Viewpoint location 8: From Footpath No. Sh18b is located within the SDNP and is a long range view to the north- east of the Site. 1.2.11. For the 2017 LVIA and Addendum Report, views of the Stage 1 aggregate processing plant and storage areas and Stage 3, concrete batching plant and cement silos may be available albeit, this would constitute only a minor component of the wider view. In Stage 1 and 3 there will be a Small magnitude of impact and a Minor-Moderate (neutral) significance of effect. During Stage 2, there will be a Very Small magnitude of impact and a Minor (neutral) significance of effect. 1.2.12. Viewpoint Locations 5, 6, 13 and 14 are also within or on the edge of the SDNP. Viewpoint Location 5: From the A259 (Seaford Road) assesses views for road users (Low sensitivity) and footpath users/other public accessed areas (Medium sensitivity). For the 2017 LVIA and Addendum Report, magnitude of impact is recorded as Small or Very Small for the individual Stages (1 to 3). At Viewpoint Location 6: From Footpath No. S3, footpath users would have a Medium sensitivity. Results for the individual Stages 1 to 3 would be slightly lower overall with a Very Small or Negligible magnitude of impact. 1.2.13. Viewpoint Locations 13 and 14 are distant views north of the Site from within the SDNP. Receptor sensitivity is Medium for bridleway users and restricted byway users respectively. The Addendum Report concurs with the conclusions of the 2017 LVIA. Viewpoint Location 13: From Bridleway No. N32e records either a Very Small or Negligible magnitude of impact. The higher elevations of the aggregate processing plant may be visible, albeit the change will not be prominent given the existing view and current baseline situation of the Newhaven East Quay and Port Expansion Area and Newhaven Eastside, the latter being closer to the viewer. At Viewpoint Location 14: From a Track Near South Heighton (Restricted Byway No. Sh4b), the Proposed Development is mainly hidden due to intervening built form located near the Site and it will not materially alter the existing view. In Stages 1 to 3 there would be a Negligible magnitude of impact. 1.2.14. In the Addendum Report, the Desk Review Figures and Viewpoint Analysis Figures have been updated. See Section 7: Assessment Of Visual Effects Review which includes a description of close range views and Table 2: Addendum Report Visual Impact Assessment Summary. 1.3. CONSIDERATION OF MITIGATION MEASURES 1.3.1. SDNPA Comment: ‘As a result of the astonishingly poor quality LVIA, there is a significant lack of mitigation measures - particularly in response to the adverse visual effects on the National Park’. 1.3.2. B&A Response: For the 2017 LVIA and Addendum Report, mitigation measures for Stage 1 to 3 of the Proposed Development primarily relate to their grouping which is close to or within existing buildings. See Section 2: Bright & Associates Page PN1081, February 2018 3 Brett Aggregates Ltd. B&A Response to the South Downs National Park Authority (SDNPA) Neighbouring Authority Consultation Comments, Ref SDNP/17/05659/ADJAUT (Dated 5 December 2017) Introduction in the Addendum Report. No further mitigation is proposed in this instance or considered necessary. 1.4. ASSESSMENT OF LANDSCAPE AND VISUAL IMPACTS 1.4.1.
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