HANSON UK HARTHAM BATH STONE MINE, NEW MINE ENTRANCE AND ANCILLARY SURFACE FACILITIES Construction of an inclined mine entrance from the surface into existing permitted mine workings, construction of ancillary surface facilities including access to highway, offices, workshop, covered storage, open storage, landscaping and restoration

PLANNING SUPPORTING STATEMENT JANUARY 2015 Wardell Armstrong Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom Telephone: +44 (0)845 111 7777 Facsimile: +44 (0)845 111 8888 www.wardell-armstrong.com

DATE ISSUED: January 2015 JOB NUMBER: ST13466 ELECTRONIC REFRENCE: REPORT NUMBER: RPT-010

HANSON UK

HARTHAM BATH STONE MINE, NEW MINE ENTRANCE

PLANNING SUPPORTING STATEMENT

December 2014

PREPARED BY:

David Bridgwood Technical Director

APPROVED BY:

Mike Walker Technical Director

This report has been prepared by Wardell Armstrong LLP with all reasonable skill, care and diligence, within the terms of the Contract with the Client. The report is confidential to the Client and Wardell Armstrong LLP accepts no responsibility of whatever nature to third parties to whom this report may be made known.

No part of this document may be reproduced without the prior written approval of Wardell Armstrong LLP.

ENERGY AND CLIMATE CHANGE ENVIRONMENT AND SUSTAINABILITY INFRASTRUCTURE AND UTILITIES Wardell Armstrong is the trading name of Wardell Armstrong LLP, Registered in No. OC307138. LAND AND PROPERTY MINING AND MINERAL PROCESSING Registered office: Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom MINERAL ESTATES AND QUARRYING UK Offices: Stoke-on-Trent, Birmingham, Cardiff, Carlisle, Edinburgh, Greater Manchester, , Newcastle upon Tyne, Penryn, Sheffield, Truro, West Bromwich. International Offices: Almaty, Moscow WASTE RESOURCE MANAGEMENT

HANSON UK HARTHAM BATH STONE MINE, NEW MINE ENTRANCE PLANNING SUPPORTING STATEMENT

CONTENTS

1 INTRODUCTION ...... 1 2 SITE DESCRIPTION ...... 3 3 BACKGROUND AND REASONS FOR THE PROPOSED DEVELOPMENT ...... 4 4 PRE-APPLICATION CONSULTATION AND SCREENING ...... 6 5 DESCRIPTION OF DEVELOPMENT ...... 11 6 ENVIRONMENTAL CONSIDERATIONS...... 13 7 PLANNING POLICY BACKGROUND ...... 19 8 PLANNING ASSESSMENT ...... 25 9 CONCLUSION ...... 28

APPENDICES Appendix 1 Noise and Vibration Assessment Appendix 2 Mine Entry Geotechnical Design Appendix 3 Landscape and Visual Impact Assessment Appendix 4 Preliminary Ecological Assessment Appendix 5 Archaeology and Cultural Heritage Initial Constraints Assessment Appendix 6 Construction Dust Assessment Appendix 7 Flood Risk Assessment Appendix 8 Mitigation Proposals Management Plan Appendix 9 Pre-Application Screening Report Appendix 10 EIA Screening Response dated 31 July 2014 Appendix 11 Pre Application Response dated 19 August 2014 Appendix 12 Public Consultation Leaflet and News release

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DRAWINGS ST13466-101 Location Plan ST13466-102 Zone of Theoretical Visibility ST13466-103 Photoview Location Plan ST13466-104 Designated Areas ST13466-105 Public Rights of Way Plan ST13466-106 Sensitive Receptors ST13466-107 Topography ST13466-110 Landscape Plan ST13466-111 Restoration ST13466-112 Site Setting and Permitted Mine ST13466-113 Site Plan ST13466-114 Existing Topographic Survey ST13466-115 Site Layout ST13466-116 Indicative Surface Water Drainage ST13466-117 General Elevation Figure 1 Identification of Noise Sources Figure 2 Noise Contour Plot ST13466-004 Habitat Plan ST13466-013 Noise Monitoring Locations Designated and Non-Designated Heritage ST13466-016 Assets ST13466-018 General Adit Roof Support Layout ST13466-020 Existing Dust Sensitive Receptors ST13466-021 Elevations- Office ST13466-022 Elevations- Workshop ST13466-023 Elevations- Storage Shed Visibility Splays at Site Access off Bradford ST13466-C3D024 Road

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1 INTRODUCTION

1.1 Wardell Armstrong has been commissioned by Hanson UK, trading as Hanson Bath and (HBPS), to prepare and submit a planning application for a new mine entrance and ancillary facilities to gain access to the existing dimension stone mine at . See drawings ST13466/101 and ST13466/115 for further details. The proposals will not involve an extension to the mine itself, nor will it require any variation to the existing permission for the winning and working of minerals.

1.2 Technical assessments have been completed for noise, mine entry geotechnical design, landscape and visual impact, ecology, construction dust, flood risk and archaeology and cultural heritage. These assessments are included as Appendices 1- 8. All drawings referred to in the appendices are included in the drawing section of this statement

1.3 The findings of the supporting assessments do not identify any constraints to development, although some mitigation measures have been proposed. Current arrangements for mine entry are considered to be sub-optimal in safety, environmental and commercial terms. There is an element of visual impact as a result of the proposed development, but this will be mitigated by the proposed site design coupled with sensitive landscape planting. The planting will offer enhanced ecological conditions on site as it matures, and this will continue once the use has been completed and the site restored.

1.4 The proposals for a new point of access would not lead to the release of more minerals. They would make working processes more safe and efficient by reducing the underground distance the material needs to be hauled before being brought to the surface. There would also be a reduction in carbon emissions as a result of reducing transport distances.

1.5 The proposed new access will not change the existing pattern of underground working. The proposed adit will intercept an existing operational roadway within the mine and allow for the removal of material from that mine from an alternative location. It will not result in a change to the pattern or extent of the existing underground working. As part of the operation the opportunity has however been taken to reconsider the surface arrangements and their impact on the environment.

1.6 The application will therefore include new surface facilities for the storage and maintenance of underground machinery and for product storage, as well as new

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office and welfare facilities.

1.7 An extensive pre-application consultation exercise was undertaken in 2014, responses to which have been addressed in this planning application. It is considered that there are no environmental or technical reasons why the development should not proceed.

1.8 On completion of mine working the site infrastructure will be demolished and taken off site. The areas of landscaping around the periphery of the site will be retained as by this time it will have matured, so soils will be imported to cover the infrastructure areas and achieve a restoration to a mix of agriculture and nature conservation as shown on drawing ST13466/111. Further restoration details are provided in the Report at Appendix 8.

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2 SITE DESCRIPTION

2.1 The new mine entrance is proposed in an area of agricultural land situated off the B3109 Bradford Road to the west of Corsham, and east of Box in as shown on drawing no. ST13466/113. To the north of the site are the properties fronting onto A4 Bath Road and to the north east is further agricultural land. To the south east is the B3109 Bradford Road and to the south west of the site lie the rear garden areas of properties fronting onto Toghill Crescent, and Long Close Avenue. To the north west, the site is bound by further agricultural land. The city of Bath lies approximately 7 miles to the south west.

2.2 The field within which the site is located lies within a belt of agricultural land which extends to the wider countryside north of Corsham and parkland to the south.

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3 BACKGROUND AND REASONS FOR THE PROPOSED DEVELOPMENT

3.1 Bath Stone is a strategically important building stone of national significance. It has been used extensively as a building material throughout southern England for churches, houses and public buildings such as railway stations. Mining of Bath Stone is important in the supply of refurbishment materials to sites of national and world heritage.

3.2 The core market since the UK recession began in 2008 has been mostly high end private development and refurbishment in London and surrounding counties. There are indications, however, that the general housing market is beginning to improve in and around the City of Bath. HBPS is the market leader in the core Bath Stone block market.

3.3 The size of the underground operation at Hartham Park now covers a 6 Ha area with current working faces moving further from the existing access. This expansion has gradually presented operational problems, as detailed below:

• The ventilation underground is provided by two downcast fans located on the surface to primarily remove the emissions by diesel powered machinery and to control Radon gas. The efficiency of the fans has significantly reduced as the working faces have moved further from the source and the extent of actual working becoming greater as the extraction progresses.

• With the workface now reaching 1km from the current entrance, further working of the site will only increase this distance [and time] for the workforce to travel. This not only creates operational inefficiencies but, more importantly, extends the time it would take for emergency services to reach the working area in the event of an underground emergency.

• The extended distance from the working face increases the use of underground roadways, with commensurate increases in road maintenance, wear and tear on haulage vehicles, fuel costs and vehicle emissions.

• The time taken to transport a single block of stone from the working area to loading area has increased threefold in the last 4 years.

• The existing power supply to the underground workings has now reached its maximum allowable voltage drop and further extension requires upgrade of the power supply to allow underground machinery to operate.

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be offloaded from specialist underground haulage vehicles and winched to the surface on tracked bogeys. This transfer operation is costly and time-consuming compared with a drive-in adit, as now proposed and adopted as common practice at other mine facilities.

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4 PRE-APPLICATION CONSULTATION AND SCREENING

4.1 A pre application report setting out the nature of the proposed development and seeking guidance as to the matters that the Council would wish to see dealt with was provided to the Council. The report also sought confirmation from the Council that the proposed development is not EIA development and that therefore an Environmental Statement was not required. A copy of that report is attached at Appendix 9. A negative screening response dated 31st July 2014, confirming the proposals are not EIA development, is attached as Appendix 10. A pre application response was received from the Council dated 19 August 2014 setting out detailed consideration of the matters that would need to be addressed in a forthcoming application. A copy of that letter is attached at Appendix 11.

4.2 A pre-application consultation submission setting out the nature of the proposed development and seeking guidance as to the matters that the Council would wish to see dealt with was provided to the Council. The submission included an explanation of the development and was supported with detailed technical reports and assessments. The submission also sought confirmation from the Council that the proposed development is not EIA development and that therefore an Environmental Statement was not required. A copy of that pre-application supporting statement (without the appendices and drawings) is attached at Appendix 9. A negative screening response dated 31 st July 2014, confirming the proposals are not EIA development, is attached as Appendix 10. A pre-application response was received from the Council dated 19 August 2014 setting out detailed consideration of the matters that would need to be addressed in a forthcoming application. A copy of that letter is attached at Appendix 11.

4.3 The letter included positive comments on various elements of the proposed development and offered useful suggestions on further issues to be addressed. It concluded that “If these matters can be addressed in a future planning application the principle of the proposed development could be considered acceptable.”

4.4 Notably, the Council’s consultation response indicated that the proposal was unlikely to cause demonstrable harm to the residential amenity of the existing residential occupiers in the area. The Council’s Environmental Health Officer raised no adverse comments but did make some suggestions for how the scheme could be improved (included in the table below). Similarly, the Council’s Highway Officer raised no concerns with regard to traffic routeing or the small number of projected vehicle

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movements but recommended amendments to the site entrance layout. The Environment Agency were consulted and had no in-principle objections subject to the findings of a Flood Risk Assessment, which has now been prepared. The Council’s Landscape Officer was satisfied with the scope of the submitted LVIA report and found the proposed development generally acceptable but recommended some limited landscape improvements. The Council Archaeologist required no further assessment work above that which was included in the pre- application submission. The Council’s Ecologist recommended some detailed improvements but welcomed the site layout drawing and particularly favoured the ecological benefits of the swale to be created along the southern and eastern site boundaries.

4.5 The table below summarises the specific comments raised during the pre-application consultation exercise and how these have been addressed in this planning application.

Issue How Issue Has Been Refer to Addressed

Reference to W&SMCS DPD See Planning sections 7 and 8 Throughout and the W&SMDCP DPD below

Noise: Provide actual Machinery will be new to the Noise Assessment, machinery noise site once the mine portal has Appendix 1 measurements been developed, so no actual machine levels are available. However predictions of noise levels for the types of machinery to be used are sufficient for this exercise.

Noise: Install close boarded Included and incorporated Drawing ST13466- fencing to E and W into the final noise 110 and Noise assessment. Assessment Report – see para 8.3.3

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Dust: How will dust be Inclusion of Construction Dust Appendix 6 avoided during construction? Assessment

Lighting: Is external lighting External yard lighting will not Planning required? If so, provide details be required. The only lighting Supporting will be for site buildings Statement, and (offices etc.) and some Appendix 8 discrete lighting at the entrance to the adit.

Transportation: Revise access This has been included in the Drawing ST13466- to improve visibility splays revised layout. C3D024

Water: Flood Risk Assessment Inclusion of FRA Appendix 7 required

Landscape: Screen planting This has been included in the Appendix 8 and could be increased revised site mitigation plan. drawing ST13466- 110

Ecology: Improve biodiversity This has been included in the Appendix 8 and through use of seed mixes and revised site mitigation plan. drawing ST13466- planting 110

Ecology: Consider This has been included in the Appendix 8 and opportunities to augment SW revised site mitigation plan. drawing ST13466- woodland for benefit of 110 foraging and nesting birds

Ecology: Impact on bats Mitigation measures will be PEA Appendix 4 resulting from light spillage? put in place, such as careful design of on-site lighting, which mean that bats will be not disturbed by the proposed development

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This has been included in the Appendix 8 and Ecology: Biodiversity revised site mitigation plan. drawing ST13466- management plan required 110

Restoration: Future This has been included in the Appendix 8 and reinstatement scheme revised site mitigation plan. drawing ST13466- required 111

General: Uniformity of red line Resolved boundaries between plans

General: Plan required to Additional drawings included Drawing ST13466- show relationship between 112 and 113 proposed development and residential properties

General: Consider including Revised drawings and fencing Appendix 8 and details of fencing, walls and details included drawing ST13466- gates 110

General: What will happen to Utilised in screening banks, or Planning material generated from returned to mine Supporting construction of the new adit? Statement

4.6 A leaflet summarising the development proposals was distributed by hand to the local community, explaining the proposals and inviting comments. The leaflet was delivered to 67 homes:

• The houses on the B3109 Bradford Road from the A4 junction to Toghill Crescent.

• All the houses in Toghill Crescent, Leylands Road and Long Close Avenue, Rudloe.

• The houses on the A4 Bath Road from the junction with Bradford Road up to and including the Hawkstone bed and breakfast.

4.7 A news release was sent to the local newspapers Wiltshire Gazette and Herald and Bath Evening Chronicle and to broadcast media BBC Radio Wiltshire.

4.8 Copies of the leaflet and news release are included at Appendix 12.

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4.9 It is proposed to host a site visit for residents when the application is submitted.

4.10 A number of enquiries were made as a result of the leaflet distribution, and are summarised below:

• A request for more information on the precise location of the new facility. A copy of ta plan showing the location of the proposals was provided.

• A query relating to the possible use of existing shafts to access the workings, and requesting information on the distance from the new entrance to the existing mine workings. A reply to the enquiry was sent by email confirming the distance to existing workings, and explaining why a drive in adit in the proposed location is preferable to utilising existing shafts.

• A request for a site meeting for residents to enable better understanding of the proposed size and location of the site

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5 DESCRIPTION OF DEVELOPMENT

5.1 To overcome the problems associated with the existing site entrance in relation to its increasing distance from the underground working areas(as set out in section 3.3 above) it is proposed that a new drive-in adit is constructed to connect up to the current permitted working area. The new access and associated infrastructure will be built on part of a 6.5 Ha parcel of land owned by Hanson, situated approximately 900 metres to the west of the existing surface access site.

5.2 The proposed site layout is shown on drawing no. ST13466/115 and a site elevation schematic is provided as drawing ST13466/117. Typical conceptual elevations through the proposed buildings are shown on drawings ST13466/021, 022, and 023. These are indicative only. Detailed design drawings will be submitted for approval prior to construction. During the initial site construction and establishment phases temporary buildings such as containers and portacabins will be used to house contractors and welfare facilities.

5.3 The works will involve the construction of a new access off the B3109 Bradford Road, a new mine entrance, an office and welfare building, a workshop, an undercover storage building, small outbuildings for generator housing, etc, car park, loading and storage areas. The carpark, loading and main stone storage areas will be surfaced with either concrete or asphalt. An area of additional storage capacity for occasional use when stock levels are higher will be surfaced with compacted aggregate.

5.4 A security fence will be erected around the perimeter of the site. At the new site entrance a sign, security gate and barriers will be erected and the road frontage will be landscaped to provide a discrete but attractive facade.

5.5 All soils from the area of the works will be stripped and used to create screen embankments and landscaped areas around the site. The proposed landscape works are shown on drawing no. ST13466/110. More details of the landscape and mitigation proposals are contained in Appendix 8.

5.6 The new mine entry will be cut through overburden and rock at an approximate gradient of 1 in 10 to intersect the existing permitted mining areas. Mineral from the permitted workings will enter the application site at the base of the incline as shown on the drawing ST13466/115, then brought to the surface using a combination of wheeled and track guided plant and machinery. This is a more modern and efficient means of recovering the mined material rather than the existing steep incline, which requires stone to be transferred from underground vehicles onto railed ‘bogeys’ and

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then winched to the surface.

5.7 The proposed operational hours of the mine entrance are between 7am and 5pm Monday to Friday and 7am to 1pm on Saturdays, which is consistent with the permitted hours for surface activities at the existing mine entrance.

5.8 It is estimated that at current rates of production approximately 4 loads per day of mineral will leave the site. All heavy road vehicles will access the site from the east, using the existing junction onto the B3109/A4 to the west of Corsham, which is considered to be adequate for this negligible level of additional traffic. These heavy vehicles currently access the existing mine site from Park Lane which leads to a junction with the A4. There will be no additional traffic on the A4 as a result of the proposed development.

5.9 There will be a number of private and light goods vehicles accessing the site for employees, visitors and deliveries. Private and light goods vehicles already use the B3109 for access to the existing site, so this use of the B3109 will continue, albeit to and from the new access further west.

5.10 The number of employees at the mine is currently 10, including support staff. This level will continue for the foreseeable future. The efficiency benefits associated with the proposed development will help to sustain these jobs and the wider economic benefits associated with the mine, including the applicant’s masonry works at Keynsham, which receives a significant proportion of the stone produced at Hartham Park Mine.

5.11 A full flood risk assessment has been carried out and is included as Appendix 7, summarised below. The design of the site layout as shown on drawing no. ST13466/116, has taken account of site drainage and flood risk.

5.12 The site access is shown on ST13466-C3D024. The access now includes for visibility splays of 2.4m by 160m and meets the requirements for the access required by DMRB to the B3109 Bradford Road. This will allow vehicles to enter and exit the highway safely and avoid potential inconvenience to other road users.

5.13 Sufficient space is available within the site to provide circulation to allow vehicles to manoeuvre safely within the site and to enter and leave the highway in forward gear. For the avoidance of doubt, there will be no loading or unloading of vehicles on the public highway.

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6 ENVIRONMENTAL CONSIDERATIONS

6.1 The principal environmental impacts have been considered further and individual reports are included as appendices to this statement as follows:

• Appendix 1 Noise and Vibration Assessment • Appendix 2 Mine Entry Geotechnical Design • Appendix 3 Landscape and Visual Impact Assessment • Appendix 4 Preliminary Ecological Assessment • Appendix 5 Archaeology and Cultural Heritage Initial Constraints Assessment • Appendix 6 Construction Dust Assessment • Appendix 7 Flood Risk Assessment • Appendix 8 Mitigation Proposals Management Plan

6.2 The conclusions from these assessments are summarised below.

Noise and Vibration (Appendix 1)

6.3 Given the distances between the construction activities and the nearest sensitive receptors, the assessment concludes that sensitive receptors are unlikely to experience noise and vibration impacts.

6.4 The potential noise impacts associated with the operation of the proposed mine entrance at Hartham Park Mine have been assessed at existing sensitive receptors.

6.5 Noise modelling has been carried out to determine the level of noise likely to be generated by the operation of the mine entrance facility during all times of operation. The noise modelling has taken into account the existing topography of the site.

6.6 In accordance with BS4142:2014 the noise from the proposed facility will be of less than marginal significance for all existing sensitive receptors. During the construction phase standard best practice measures will be employed. Based on the findings of the noise assessment, no mitigation measures are considered necessary for the operational phase of the mine entrance.

6.7 The new mine entrance will not affect the direction and method of working underground, so there will be no changes to any noise arising from underground activities apart from a theoretical noise reduction arising from reduced underground haulage.

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Mine Entry Geotechnical Design (Appendix 2)

6.8 A Geotechnical Assessment has been carried out and the adit design has been based on recommendations from that assessment. The assessment and design is detailed in the report titled Mine Entry Geotechnical Design at Appendix 2.

6.9 The strata in the mine are generally flat lying with a slight dip of 2° towards the southeast.

6.10 The roof support requirements have been designed for safety and are based on principles that have been developed for hard rock mining. Conservative values have been assumed in the assessments to present the worst case scenario.

6.11 The ramp down to the adit entrance will be formed in open cut to a maximum depth of 7m below ground level. The transition from open cut to underground will be supported by brickwork and a steel lintel at the portal face. Most of the stone will be removed from the mine by wheeled loader, but a pulley system will also be installed. The adit running surface will comprise reinforced concrete with inset narrow gauge rails. Guide rollers will be situated between the rails at 5m intervals to control the haul cables.

6.12 To manage the potential surface water run-off down the portal ramp, intercepting channels and gullies will be installed across the ramp. The clean water collected will be discharged back into the surface drainage management system of the hard standing area

Landscape and Visual Impact Assessment (Appendix 3)

6.13 The sensitivity of the landscape character within the Study Area has shown it to be of medium sensitivity to this type of development and the magnitude of landscape change as low to medium. Therefore, slight to moderate effects on landscape would be generated by the scheme. These effects will have a slight to moderate adverse impact in terms of loss of agricultural land and the introduction of development in land between settlements, but also beneficial impacts due to the reinforcement and strengthening of field boundaries through the introduction of woodland and hedgerow to the edges of retained agricultural land.

6.14 The visual impacts on Public Rights of Way, roads and adjacent residential properties occur in close proximity to the site. Longer, more distant views of the site are limited by the existing topography or screened by the residential developments of Corsham and Rudloe. Existing trees and woodland add to the screening of the site.

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6.15 The existing screening of the site is enhanced by the roadside wall and field boundary. Mitigation planting along this boundary would further screen the site. In addition, buildings within the site would be set back from the roadside, and finished floor levels set below the existing levels within the wider falling topography, further reducing their visibility. It is anticipated that with these simple measures visual impacts caused by the development would not exceed ‘slight adverse’.

6.16 The proposed mitigation planting would screen views from the single and two storey residential properties within Rudloe, however views from some third floor flats would overlook the development until the proposed woodland planting becomes established. Internal planting within the development would serve to break up and reduce these potential impacts. These views from third floor flats are a mix of living space - possible kitchens and balconies, along with smaller windows, probably bathrooms. However the majority of views would be oblique, with few oriented directly towards the site.

6.17 The siting of the proposed mine adit, associated buildings and stone storage within open land would result in a slight to moderate adverse effect to the landscape and visual amenity of the surrounding area, primarily due to the proximity of the three storey residential flats within Rudloe.

6.18 The proposed mitigation planting would add a beneficial impact upon the landscape in the vicinity of the proposed development and strengthen existing woodland and field boundaries, although this will take time to take full effect

6.19 The activities at the surface will be very light such that visual impact from vehicles will be low.

Ecology (Appendix 4)

6.20 The site consists principally of part of an arable field. There is a small area of broadleaved woodland to the SW corner of the site that will be retained as part of the development. This habitat will be protected in accordance with BS5837:2012 – Trees in relation to construction, during the development of the site.

6.21 There is potential for badgers, brown hare and hedgehog to be disturbed during construction works on site. There will therefore be a need for standard mitigation measures to be employed to deal with excavations on the site. These species, if present, may be temporarily displaced from the site during construction works. However, there are suitable habitats in the surrounding area which are likely to form

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part of their wider territory and these species will be able to continue using the habitats within the site once the site is operational.

6.22 Although no suitable roosting habitats have been recorded for species within the proposed development site, it is considered likely that habitats within the site such as arable farmland, hedgerows and woodlands are likely to be used by foraging bat species.

6.23 External yard lighting will not be required. The only lighting will be for site buildings (offices etc.) and some discrete lighting at the entrance to the adit. Mitigation measures will be put in place, such as careful design of on-site lighting, which mean that bats will be not disturbed by the proposed development. Once the additional tree and hedgerow planting has been completed, this will begin to provide net improvements to the site in terms of bat habitat.

6.24 Vegetation clearance will take place outside the bird breeding season to minimise temporary disturbance or displacement effects upon breeding birds, especially ground-nesting birds during construction. The bird breeding season is generally taken to be between March and August inclusive.

6.25 Great crested newts and other amphibians may potentially be present within the waterbody located approximately 300m to the north of the site. However, the A4, which is located between the site and the pond, is considered to be a significant barrier to their dispersal. Therefore, it is considered unlikely that great crested newts or other amphibians will be present on site and therefore harmed by the proposed development.

6.26 Suitable reptile habitat is limited within the site to the broadleaved woodland and scrub, which is not directly affected by the proposed development. The site is not considered likely to support significant numbers of reptiles, however, if present, there is a risk that a small number of common reptiles may be disturbed by construction activities. As a precaution, tall vegetation within the working area will be cut to approximately 10-15 cm above the ground two weeks prior to construction and maintained in this condition up until construction commences in order to discourage reptiles from the working areas. Any debris which could be used by reptiles as refuges, e.g. rubble, logs, will also be removed from the working areas. Debris will not be removed during reptile hibernation season.

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Archaeology and Cultural Heritage (Appendix 5)

6.27 With regard to impact on statutory designations, there will be no physical impact to designated heritage assets. Given the small footprint and limited impact of the proposals, it is considered that the development will have ‘no impact’ on the setting of designated heritage assets.

6.28 No non-designated HER heritage sites will be impacted on by the proposed development.

6.29 During the pre-application consultation, comments were received from the Council Archaeologist concerning the proposal and its likely impact on archaeological interests in the area. On the basis of the Heritage Assessment submitted with the pre-application submission the Council Archaeologist concluded that it is unlikely that any further archaeological assessment would need to be undertaken in relation to the proposed development.

6.30 Based on the above it is considered that further site investigations are not required and that a watching brief during the initial soil stripping as part of the construction process will be appropriate.

Construction Dust Assessment

6.31 A construction dust assessment has been carried out and is included as Appendix 6.

6.32 The construction phase assessment has been undertaken to determine the risk and significance of dust effects from earthworks, construction activities and trackout from the proposed development. The assessment has been undertaken in accordance with the guidance on assessing the impacts of construction phase dust published by the Institute of Air Quality Management (IAQM).

6.33 The risk of dust soiling effects is classed as high for earthworks and construction activities and medium for trackout. The risk of human health effects is classed as low for earthworks, construction activities and for trackout.

6.34 With site specific mitigation measures in place, such as those detailed in Appendix 6, the significance of dust effects from earthworks, construction activities and trackout are considered to be ‘not significant’

Flood Risk (Appendix 7)

6.35 An assessment has been undertaken to consider both the sustainable drainage of the site and the potential for development of the site to have an impact on other

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sensitive receptors. A copy of this assessment is included as Appendix 7.

6.36 An indicative surface water management plan, which assumes that infiltration across the site will be feasible, is presented on Drawing No ST13466-116 ‘Indicative Surface Water Drainage Strategy’.

6.37 The application site forms part of the catchment of the River Avon, approximately 2.2km from the site. No named watercourses cross the site or will be directly impacted by the proposed development. A foul water sewer is located beneath Bradford Road, and will be used for drainage of the site offices and welfare facilities. This will not be disturbed by the proposed development. A water main passes beneath the southern boundary of the site. An appropriate stand-off (5m) has included within the design of the site to protect the main.

6.38 The site is identified on the EA flood risk map as Zone 1, low vulnerability to flooding and mineral extraction is regarded as less sensitive to flooding. It is considered therefore that the proposal is appropriate for the site in flood sensitivity terms.

6.39 The site is currently undeveloped agricultural land and is therefore regarded as being completely permeable. The proposed development will introduce impermeable elements totalling 1.03Ha. It is proposed to drain the site to a swale which will allow the surface water to drain by infiltration. This is shown on drawing ST13466-116 and will be capable of accommodating a 1 in 100 year plus climate change rainfall event. It is therefore considered that the site will not present a risk of offsite flooding.

Mitigation Proposals Management Plan (Appendix 8)

6.40 An assessment of the potential impacts resulting from the proposed development and recommendations for mitigation has been carried out and is included at Appendix 8.

6.41 To mitigate against the potential impacts caused by the proposals a landscape scheme including woodland and tree planting, grass seeding, bio diversity improvements and habitat creation has been prepared.

6.42 The Mitigation plan includes references to biodiversity and proposals for restoration (drawing ST13466-111).

6.43 Upon completion of decommissioning of the mine, a restoration plan (ST13466-111) has been prepared which illustrates the proposals to retain established woodland and return the site compound to agricultural land.

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7 PLANNING POLICY BACKGROUND

7.1 The following policy is relevant for this application:

• National Planning Policy Framework (NPPF) • Wiltshire Minerals Local Plan • Wiltshire Minerals Core Strategy • Wiltshire and Swindon Minerals Development Control Policies DPD

National Planning Policy Framework

7.2 The National Planning Policy Framework (NPPF) came into force on 27th March 2012, replacing all Planning Policy Statements (PPS), Planning Policy Guidance notes (PPG) and Mineral Policy Guidance note (MPG) with the exception of PPS 10 Planning for Sustainable Waste Management.

7.3 The NPPF sets out the Government’s planning policies for England and how these are expected to be applied. Local Planning Authorities (LPAs) are required to take this guidance into account when formulating planning policy and when determining planning applications.

7.4 The NPPF emphasises the need for sustainable development and explains under paragraph 14 that at the heart of the NPPF is a presumption in favour of sustainable development. There are three dimensions to sustainable development; economic, social and environmental with each element contributing to sustainability and being included within the decision making process.

7.5 In terms of decision making the NPPF highlights that:

• Development proposals that accord with the development plan should be approved without delay ; and

• Where local development plans are absent, silent or relevant policies are out-of-date the permission should be granted unless:

o Any adverse impacts of doing so would significantly or demonstrably outweigh the benefits, when assessed against the policies of NPPF as a whole; or

o Specific policies in the NPPF indicate development should be restricted

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minerals.

7.7 As a result, it is important that there is a sufficient supply of material to provide the infrastructure, buildings, energy and goods that the country needs, whilst ensuring that permitted mineral operations do not have unacceptable adverse impacts on the natural and historic environment or human health.

7.8 The NPPF also recognises that, since minerals are a finite natural resource, and can only be worked where they are found, it is important to make best use of them and to secure their long-term conservation through the mechanism of mineral safeguarding.

7.9 The main planning policy within the NPPF that relates to minerals is contained within Section 13 Facilitating the Sustainable Use of Minerals.

7.10 Paragraph 142 - The NPPF indicates that minerals are essential to support sustainable economic growth and outlines the importance of ensuring a sufficient supply of material is available to provide the infrastructure, buildings, energy and goods that the country needs.

7.11 Paragraph 144 - The framework indicates that when determining planning applications, local planning authorities should, amongst other matters, consider the key matters which include:

• Give great weight to the benefits of the mineral extraction, including to the economy;

• as far is practical, provide for the maintenance of landbanks and non-energy minerals from outside of National Parks, The Broads, Areas of Outstanding Natural Beauty and World Heritage Sites, Scheduled Monuments and Conservation Areas;

• ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites and/or from a number of sites in a locality;

• ensure that any unavoidable noise, dust and particle emissions and any blasting vibrations are controlled, mitigated or removed at source, and establish appropriate noise limits for extraction in proximity to noise sensitive properties; ST13466 /RPT -010 Page 20 JANUARY 2015

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• provide for restoration and aftercare at the earliest opportunity to be carried out to high environmental standards, through the application of appropriate conditions, where necessary;

• not normally permit other development proposals in mineral safeguarding areas where this might constrain potential future use for these purposes;

• consider how to meet any demand for small-scale extraction of building stone at, or close to, relic needed for the repair of heritage assets, taking account of the need to protect designated sites; and

• recognise the small-scale nature and impact of building and roofing stone quarries, and the need for a flexible approach to the potentially long duration of planning permissions reflecting the intermittent or low rate of working at many sites.

7.12 These key principles have been considered and taken into account in the formulation of the proposals that are the subject of this application. It is considered that in terms of location and design, the proposals meet the thrust of the key considerations.

7.13 In more general terms, the NPPF highlights the need for all new developments to have good design. Paragraph 56 states that good design is indivisible from sustainable development and should be a key consideration for decision making. The site compound and associated buildings and apparatus have been designed to the smallest possible scale, within operational requirements. The options for the location of the compound has been restricted by the need to find an appropriate location to intersect the existing underground roadways. It is considered that, within the operational requirements, the optimal location has been selected.

Local Policy

Wiltshire and Swindon Minerals Local Plan

7.14 The Wiltshire and Swindon Minerals Local Plan was adopted in November 2001. In September 2007, most of the policies were 'saved' and remain extant until replaced by policies in the Minerals and Waste Development Plan Documents.

7.15 The overall aim of policies set forth within the Minerals Local Plan is:

“To strike an appropriate balance between meeting essential human needs and protecting Wiltshire and Swindon’s environment, especially non-renewable natural

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resources, including the best and most versatile agricultural land; and the amenity of its residents”

“Fundamental to this aim is the need to establish criteria against which planning applications for mineral operations can be assessed, thereby bringing potentially important considerations to the attention of a developer at an early stage in the development process.”

“Essential needs for minerals have to be met and mineral resources can only be extracted where they are found. As resources are used up they have to be taken from more environmentally sensitive locations. The extraction of minerals can generate adverse impacts because of the nature of mineral working - digging, processing and distribution, and some of these impacts can result in permanent damage to the environment. Accordingly, there is a need to control mineral development in order to minimise its adverse impacts and conserve resources for the future.”

Policy 1: Assessment of Minerals Development Proposals

“Where mineral operations give rise to material planning objections which outweigh planning benefits, planning permission will only be granted when: The need for the mineral outweighs any adverse impact the development is likely to have; and the requirement for the mineral cannot be met from an alternative source with less adverse impact.”

Policy 2: Minimising the Impact of Minerals Development

“Planning permission will be granted for minerals development only when all its likely adverse impacts will be kept to an acceptable minimum.”

“All possible adverse impacts of minerals proposals on the wider environment will be considered under Policy 2 including those on people (e.g. amenity, safety, recreation), the natural environment (e.g. landscape, rivers, flora and fauna), natural resources (e.g. water, high quality agricultural land) and the scientific and cultural heritage (e.g. sites of historic, geological and ecological importance). In accordance with the “holistic” approach to minerals development promoted through this Plan, any references to “environmental” impacts should be taken to include not only the natural environment, but also amenity, highway and other impacts, which collectively constitute the “environment”.”

Policy 11 (Plant and Ancillary Structures)

“The erection of mineral processing or manufacturing plant, or structures ancillary to

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a minerals use at a mineral extraction site or a rail aggregate depot not already authorised as ‘permitted development’ will only be permitted when development will not generate significant adverse environmental impacts and;

1) In the case of processing plant, the plant is required to process material extracted from the mineral site at which it is located (or extensions or satellite sites to it) or brought into the depot by rail, unless mineral imports have been permitted under Policy 12; or, 2) In the case of manufacturing plant the greater part of the minerals used in the manufacturing process are extracted from the mineral site concerned (or extensions or satellite sites to it) or brought into the depot by rail, unless mineral imports have been permitted under Policy 12 or, 3) In the case of ancillary development, the development is used solely in connection with the administration or servicing of the mineral site or depot concerned; and 4) In all cases the development will be removed and the site satisfactorily restored within an agreed timescale following the cessation of mineral extraction from the site, unless mineral imports have been permitted under Policy 12; and, 5) The proposal complies with all relevant policies of the Plan”

Chapter 3: Controlling the Impact of Mineral Working

7.16 Policy 13 states that “ minerals development will only be permitted when the proposals safeguard the amenity and character of any nearby dwellings and settlements by including:

1) A scheme of working to minimise the period of operations in sensitive areas 2) Provision of adequate buffer zone to the workings incorporating landscaping and planting, appropriate to the existing landscape and consistent with the proposed afteruse of the site that would be necessary to minimise any significant adverse amenity impacts”.

Wiltshire and Swindon Minerals Development Control Policies Development Plan Document (DCP)

7.17 This document was adopted in September 2009. It sets out the key considerations in terms of the operation of mineral sites that will be required.

7.18 Policy MDC1 sets out a general principle that minerals development must contribute

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to the delivery of sustainable development in Wiltshire and Swindon by ensuring that the social, economic and environmental benefits of minerals development are maximised, and adverse impacts are kept to an acceptable minimum. There then follows a series of 9 criteria for consideration.

7.19 MDC2: Managing the impacts of minerals development, requires that proposals avoid or mitigate for impacts associated with noise, dust, air emissions, lighting and vibration, and where necessary provide technical reports to demonstrate this. It also requires that plant and machinery installed on sites are limited to the life of the site.

7.20 MDC3: Managing the impact on surface water and groundwater resources, requires controls to be put in place to protect grand and surface water resources. The policy requires applications to be accompanied by a Flood risk Assessment, and to make use of SUDs techniques.

7.21 MDC5: Protection and enhancement of Wiltshire and Swindon's landscape character, requires assessment of the impact of proposals on landscape character, particularly in designated areas (which the proposal falls outside. Further advice is given on landscape character assessment and safeguarding of the setting of settlements.

7.22 MDC6: Biodiversity and geological interest, provides advice on the objective assessment of biodiversity and geological interest. It confirms development will be permitted where adverse impacts are avoided or adequately mitigated.

7.23 MDC7: The historic environment, confirms that development will be approved where historic assets are protected, enhanced or preserved, and confirms that identified remains should be either preserved in situ or recorded in accordance with an approved mitigation scheme.

7.24 MDC8: Sustainable transport and minerals development, places a focus on sustainable means of transport of minerals by minimizing transport distances and prioritizing more sustainable means of transport. It confirms that some development may require a Transport Assessment.

7.25 MDC9 – Restoration, aftercare and after-use management of minerals development, requires provision to be made for the appropriate restoration of sites, employing phased restoration where appropriate. Appropriate aftercare is required, as is agreement in relation to after-use, where appropriate.

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8 PLANNING ASSESSMENT

8.1 In line with the guidance contained within the NPPF, which post dates the documents contained in the Development Plan, the goal of the planning system is to achieve sustainable development. There are three elements to sustainable development, environmental, economic and social.

8.2 For this proposal the main considerations are clear:

• Impact on the Environment • Supporting the Function of Existing Mining Operations

Impact on the Environment

8.3 It is necessary to consider impact upon any environmentally designated sites, in particular conservation areas.

8.4 Hartham Park is not located within a designated area such as a conservation area, AONB or an area of archaeological importance. These matters have not been specifically addressed.

8.5 Appropriate assessment have been prepared, and summarised above, dealing with relevant environmental considerations. The proposed development, being essential and relatively minor in nature, is considered to have a very limited local impact.

8.6 An Ecology Survey has been carried out to support the application. This demonstrates that there will be no significant adverse impact on any ecological considerations in the short or medium term. In the long term the planting proposals and facilities are likely to have a beneficial effect on the local environment. The development is considered to be acceptable on this basis.

8.7 The proposed Adit at Hartham Park will improve the health and safety of existing mining operations. As existing, the distance for operatives to travel through existing tunnelling to reach the working areas is increasing to a distance of 1km between entering the mine and reaching the building stone for excavation. This has implications upon the health and safety of employees, particularly in the event of a

medical emergency and results in inconvenience and a greater level of CO 2 emissions than otherwise need be the case. The proposal for the new adit will reduce this distance.

8.8 The increasing distance for electrical supply from the current mine entrance to the working areas results in a drop in voltage and therefore increased power

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consumption within the mine. By moving the mine entrance closer to the workings, electricity use will be more efficient.

8.9 By allowing a larger and shallower sloping mine portal to allow drive in access for vehicles, there will be improvements in energy efficiency, particularly in gaining access to and removing stone from the mine.

8.10 The siting of the proposed mine adit, associated buildings and stone storage within open land would result in a slight to moderate adverse effect to the landscape and visual amenity of the surrounding area. This is dealt with in section 6 of the statement and in Appendix 3. This concludes though that with the mitigation planting proposed there would be a beneficial effect on the landscape. These are considered to be significant benefits in both environmental and economic terms.

Supporting the Function of Existing Mining Operations

8.11 The proposed operational area will support the existing mining operations through the provision of improved office and welfare facilities, as well as buildings containing operational plant and machinery. This sets the development in accordance with NPPF Policy 142, as both the facilities within the new site compound and new adit access will ensure the continual supply of building stone which is an essential mineral to meet the need for specific building stone and products.. In particular the stone produced has a valuable role to play in the maintenance of historic buildings, both locally and further afield, some of which are of considerable historical significance.

8.12 The NPPF (Paragraph 144) highlights the need for minerals planning authorities to adopt a flexible approach to building stone quarries, and recognise the small scale nature of such operations. The proposed development, comprising a site compound and new mine access, is minor in nature, and is required to support the functions of the existing building stone excavation at Hartham Park. This will ensure the continued supply of raw materials to meet Wiltshire’s requirements for building stone.

8.13 Also in agreement with NPPF 144, it can be demonstrated that the proposals will adopt appropriate mitigation measures to ensure that any noise, dust and particle emissions are controlled. A noise survey was conducted by Wardell Armstrong in November 2013, which demonstrated that with the implementation of best working practice, noise and vibration impacts are unlikely at existing receptors from the earthworks, construction or operational phases.

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8.14 The new entrance will be designed with adequate visibility splays, existing traffic movements will not increase and will have a negligible impact on the highway network.

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9 CONCLUSION

9.1 The benefits of constructing a new access will address the issues raised, as summarised below;

• The reduced haulage distance will result in environmental improvements and cost savings on fuel usage and running costs of machines underground. • The shallower drive-in access will be more efficient way of transporting blocks. • This ease of access and proximity to the work face will greatly improve response times for emergency services should the need arise. • The relocation of the ventilation fans to the vicinity of the new access will have significant impact on improving the air quality underground. • Similarly, a new power supply from the new mine entrance in close proximity to the working area will overcome existing problems with voltage drop.

9.2 Overall it is considered that the proposed development is acceptable in terms of planning policy.

9.3 It is considered that that there are no environmental, technical or practical constraints on the proposed development. Consequently it is considered that the proposed development is in accordance with Development Plan and national policy and should therefore be supported.

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