Representations Received at Proposed Submission Draft Stage

Response ID ANON-NRVC-BRUF-8

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-01 22:40:05

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):

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR 1 (Chapter 7); SSR 30; SSR SSR34 and SSR35. SSR27

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)

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 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. Currently our High Street and surrounding area is bucking the national trend, businesses are choosing to come to Steyning and open. The site just outside Steyning’s inclusion could stop or alter this trend.

The proposed inclusion of the Ham Farm site as one of the identified areas for soft sand ignores the extent to which its inclusion would impact on visitor numbers and amenities for residents. It will also have an unacceptable effect on the surrounding landscape and should be withdrawn as a potential site.

My representations

I object to the inclusion of the Ham Farm as one of the three selected sites. This is referred to in policies: SSR 1 (Chapter 7); SSR 30; SSR SSR34 and SSR35. SSR27 (New Para 7.1.7)

There are five six key 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. Ham Farm is recognised as Grade 3 agricultural land i.e. the best and the assessment notes that this seems likely to be lost in restoration. It fails this principle, no net-gain in biodiversity will be possible. SSR 27 (7.7.2.7) states the detailed technical assessment of the site has been undertaken that has not identified any overriding or fundamental constraints to the proposed forms of development on the allocated sites. I do not agree with several of these assessments, which also reflect the guiding principles

The technical assessment on Soil quality is amber. I rate this using the Framework as Red

• 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. The Site Selection Report records that the site is visually sensitive in views from the top of the scarp and accepts that there will be negative impacts for users of Wiston Park. The fact that the SDNP boundary is to the south of the road indicates the value of the landscape in this area. It will be highly visible to all users of the South Downs Way and Chanctonbury Hill and its surrounding downland. These are well-known and accessible tourist destinations in the SDNP. Views at these locations are of the highest sensitivity owing to the location being within a National Park, on a National Trail and at a viewpoint destination. There are an estimated 39 million daily visits to the National Park. Extraction would include structures, movement, noise, lighting etc and cumulatively these will have a serious impact on those seeking tranquillity, peace and stunning views; the very reasons why visitors come to this area. In our opinion you have undervalued the impact at Amber. Within the immediate area of the site are Alderwood Pond, Wiston House with Wiston Park and the Cow Shed Studio, all are visitor attractions. Alderwood Pond has 45 fishing points including 4 for disabled use. This is the only fishing pond in the area with disabled access and provides facilities for several major charities. The Cow Shed Studio, immediately adjacent at Hammes Farm offer courses, exhibitions which attract visitors from a wide area. Wiston House has an international reputation as a Conference Centre. The current tranquil setting is used for Weddings, Dining, Social Events and the park hosts events such as the Steam Rally, Big Church, Concerts and other gatherings. The setting of all these popular attractions will be adversely affected. Steyning often features in articles as an attractive place to live, work and retire to and all of the local features, in particular the immediate landscape of the SDNP area are all extremely well used. The economic wellbeing of Steyning relies on attracting people to visit and initial impressions driving-by matter. The approach by road to the Steyning area from the south is already adversely impacted by the disused cement works. The proposed development of the quarry will adversely impact the approach from the west. For all the above reasons I disagree with the report’s technical assessment of Amenity as Red/ Amber and have rated this as Red. For the above considerations I am of the opinion that the assessment of Ham Farm for Landscape is should be scored Red/Amber and not Green as indicated • 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. The Technical study for Transport and access is rated Green, indicating no highway concerns. This judgement appears to rely on the transport study arising from a planning application With approximately 96 vehicle movements – rated at 8, two way movements per hour, this seems a very crude assessment, when the rating has a strong effect as to a decision on the chosen site. In addition, the vehicle numbers are provided by the promoter. Assuming there is an even spread (which seems likely to be unrealistic) there will be a minimum of 4 vehicles turning across the traffic. This may appear minimal but with fast moving traffic it is bound to cause serious delays and increased risk of accident at busy times. This seems to ignore that removal of spoil and reinstatement in particular is likely to be in particular directions, also that this section of road has been identified as a dangerous stretch of road. The camber, flooding in the area and curves, which show straighter in any documents have not been taken into consideration. Taking these considerations into account implies that highway will need major improvements and lighting at the site entrance. (There seems some confusion in the technical assessment which refers to an addendum in October 2016 as opposed to the paper on Transport in 2019). These will impact on the visibility of the site from the SDNP and lead to a detraction in air quality which would be particularly disruptive when major events take place at Wiston Park. It will also be a departure from the current rural outlook at a point immediately before visitors enter Steyning. The technical assessment for Transport and access is Green. I refute this and for the above reasons the correct marking should be Red/Amber. • 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. The earlier comments highlight the impact on the highly sensitive views from the SDNP and national trail which are very popular as a tourist destination and residents alike. In addition, the site, as recognised in the report is only 125m from the ancient Great Alder Wood. The site is also adjacent to several listed buildings and historically important buildings: Horsebrook Cottage; the Old Rectory, buildings at Wappingthorne and importantly to the south of the Grade 1 Wiston House and a the 16th Century Barn at Hammes Farm. The development of this site, estimated to take 10 years, will have strong negative impact on all these buildings and amenities. The technical assessment of Historic environment designations is Red/Amber, which I agree with.

Fifth principle: A preference for extensions to existing sites rather than new sites, subject to cumulative impact assessments. Development of this site conflicts with this principle.

• Sixth principle: The need to avoid the needless sterilisation of minerals by other forms of development. There is no reason why this land would stay otherwise than Grade 3 agricultural land Conclusions Changes to the boundary of the Ham Farm site have not resulted in any amelioration of the adverse impacts on tourism. It will now have a greater frontage to the A283 and wider impact to the SDNP.

The January 2020 Soft Sand Review contains several development principles relating to screening and transport, but these will not improve the impact of development from the escarpment and the National Trail.

I remain of the view that the impacts on tourism have been undervalued and misunderstood. Steyning is one of the gateway towns to the SDNP and its main attractions include easy access to the SDNP. In this crowded part of the UK many visitors relish easy access to the South Downs which offer openness, naturalness, lack of noise and distant views.

The proposal will result in adverse visible disturbance to the natural landscape, noise and light pollution, all detractors to peace and tranquility. Visitors are also attracted by the views of the Downs and the surrounding countryside as they approach from the A283. This highly visible and busy site with structures will have a serious impact on the setting of this picturesque market town. For these reasons I continue to take the view that there will be an adverse impact on tourism which is an essential element of the local economy. These principles are underpinned by the Soft Sand Selection Report which assesses the individual sites in line with an Assessment Framework.

I ask that this site is removed from the Local Minerals Plan.

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: Removal of the Ham Farm Site is the only step to take.

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-BRU5-Q

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 12:26:29

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

Resident

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: 1,8,13,27,30,34 and 39

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)

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.: The LAA sets out the demand for soft sand to 2033, taking account of the previous 10 years sales (2008–2017), and the following assumptions; • Assumption 1: the construction of new residential dwellings in West Sussex is projected to grow by 26.8% I consider this huge growth in the housing stock in West Sussex is not compliant with the Paris Accord where the UK has signed up to holding the increase in global average temperature rise to well below 2°C above pre-industrial levels and to pursue efforts to limit warming to 1.5°C. Every new home produces a carbon deficit and with current transport use also results in increased carbon emissions. West Sussex, in particular Horsham District, is a largely rural area with little public transport available therefore people have to use private cars to undertake everyday activities.

In the non-technical summary of the West Sussex and South Downs National Park Joint Minerals Local Plan Proposed Submission Draft (Regulation 19) Sustainability Appraisal including Strategic Environmental Assessment, it says 'Traffic Growth Current forecasts estimate that the amount of traffic on the roads within West Sussex will increase during 2011-2026. Traffic growth will continue to affect the transport network and has exceeded planned capacity in some places. Increased traffic could have a detrimental effect on quality of life within the County. ' In the same document para 13 it says the aim is' To minimise transport of minerals by roads. Where road use is necessary, to reduce the impact by promoting use of the Lorry Route Network.

Would the option/policy/site: o Have the potential for rail or water-based access to and from mineral sites? o Lead to the production of traffic-derived pollutants, including CO2, NO2 and PM10 due to road transport to and from minerals sites? o Optimise the use of the Lorry Route Network and reduce the use of rural roads thus reducing the disruption and pollutants caused by HGVs? ' This fails to recognise that the Lorry Route Network includes the A283 to link the A27 at Shoreham Flyover with the A24 at Washington Roundabout. The A 283 is a rural single carriageway road and is totally unsuitable to be part of the Lorry Route Network. The impact of HGVs using the A283 is already considerable and will only increase over the next 5 years even without any additional use due to the quarrying of soft sand. The WSCC Traffic monitoring database already shows traffic flows have increased at site 035 A283 Washington Road west of B2135 by over 9% between January 2015 and January 2020, from an average of 14711 movements in January 2015 to 16056 movements in January 2020. The greatest increase has been in westbound traffic which would be exacerbated by the proposal to extract sand at Ham Farm. The A283 between the Shoreham Flyover and the Washington roundabout has had 16 accidents classified as KSI (ie killed or seriously injured) between January 2015 and December 2019 (source: Sussex Safer Roads Partnership). I am unclear that the traffic figures used in this review are the most up to date available, and include a forecast for the traffic impact of Planning Permission ref AWDM/1093/17 for the erection of new commercial buildings to provide up to 25000m2 of floorspace for Light Industrial (Use Class B1c), General Industrial (Use Class B2) and Storage and Distribution (Use Class B8) which was approved on 27th December 2019 and Planning Permission ref AWDM/0961/17 for erection of 249 dwellings with temporary access via Grinstead Lane, a Country Park, relocation and extension of the Withy Patch Gypsy and Traveller site, permanent access via a new roundabout on the A27, landscaping, two additional football pitches and other associated infrastructure (including pumping facility at the River Adur); (2) Outline planning permission (with only landscaping reserved) for a non-food retail store (Use Class A1); and (3) Outline planning permission (with all matters reserved other than access) for the erection of a further 351 dwellings, community hub, primary school, and landscaping, which was approved on 4 February 2020.

I have further concerns about the adverse impact of the Ham Farm and Chantry Lane sites on the South Downs National Park and its main purposes.

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 to make the review legally compliant it needs to demonstrate how the basic underlying assumption of huge housing stock growth in West Sussex complies with the UK's commitments to climate change under the Paris Accord.

For the review to be sound it neds to demonstrate that consideration of the impact of the proposals in SSR 34 (relating to the proposed extraction at Ham Farm) and SSR 39 (relating to the proposed extraction at Chantry Lane extension) has taken into account the evidence of traffic growth on the A283 and forecasted traffic growth which will result from the approved developments at Lancing. It also needs to demonstrate how the use of the A283, which is part of the approved lorry network, minimises the impact on rural roads, as the A283 is a rural road. It also needs to demonstrate clearly how the Ham Farm and Chantry Lane proposals will not have a negative impact on the main purposes of the South Downs National Park.

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-BRUH-A

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 13:06:55

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): Mr

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.: 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)

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.: Response to SSR 38 East of West Heath

• First principle: Places where there are opportunities to restore land beneficially, for example a net-gain in biodiversity. Concerned that no land has yet been restored – current status seems to be that the exhausted land has been left as a combination of barren flat areas & a deep water filled hole with no obvious greening efforts. Given this track record, what measures can ensure restoration starts in a reasonable timeframe.

• 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 The new area is separated from the existing sandpit by 3-500 metres across an area of common land. The conveyer/pipeline referenced to transfer the million tons of sand up to half a kilometre would thus be massive and cause a significant of dust, noise & nuisance over a considerable period of time. This represents a severe impact on Downpark common and nearby residents.

• 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. The existing access to/from the A272 to the north is a narrow width road with passing places, already a struggle with existing traffic and likely to become more busy as the recently approved deer park/farm shop is developed. In addition, walkers taking the Petersfield to Rogate footpath route must walk about 250m along this road. This is a bad mix of heavy lorries, cars and pedestrians in a narrow road with no separate walking zone. The historic monument bridge already suffers continual damage by heavy lorries, particularly the full length articulated type that are too long to easily navigate the bend resulting in regular damage to the capping stones. The junction at the north end with the A272, being particularly narrow, is often a cause for accident concern as any lorry entering the final 50 yards inevitably blocks the traffic trying to enter the road causing sudden tailbacks onto the A272.

• 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. The existing sandpit is clearly visible from the south downs way, this addition would spoil the vistor’s view even more. The extension agreed in 2010 removed a footpath and the conveyor envisaged in this proposal may impact or close the remaining NS foot path in the area (FP 861) Other areas for sand extraction are available outside the national park.

• Fifth principle: A preference for extensions to existing sites rather than new sites, subject to cumulative impact assessments. This is a separate site – 3-500 metres from the existing sandpit. It is not an extension.

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: a) Not allow the development of this additional area of the sand pit b) if it must go ahead then: - ensure there is a less impactful solution to the site-site transport than an above ground conveyor system - ensure there is a less impactful solution to the impact of large lorries lorries used on the road north to the A272 - e.g. not long articulated vehicles

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-BRUV-R

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 14:27:16

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, Local Business, Landowner

Other:

Part B - Representation

B1 Which part of the Soft Sand Review does this representation relate to? SSR Reference No.: SSR 34

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)

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.: The Ham Farm site allocation is against the Second Guiding Principle in that little or no acknowledgement of the existence of and effect on the 3 family homes and business of the Cow Shed Studio at Hammes Farm which is on the boundary of the proposed site. The proposed entrance is also on the boundary and in my view it will be impossible to sufficiently mitigate the adverse effects of traffic noise , vibration, dust, smell and general pollution which the quarry will generate. A detailed plan for how this mitigation could be achieved is required before the plan is allowed to proceed further. The entrance to the triangular field should be investigated as an entrance to the site allowing proper mitigation of the adverse effects of the proposal.

No mention is made of the various major public events held on the Wiston estate. Tens of thousands of the general public attend events during the Summer across the road from the site and inside the National Park with many hundreds of people camping.

A further traffic review is also required. A significant increase in traffic has occurred since the 2016 review at busy times due to the A283 being used as a Worthing bypass.

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: Withdrawal of the Ham Farm site from the review.

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

Yes, I wish to speak to the Inspector at the hearing sessions

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 think my comments and suggestions will be dismissed by WSCC and SDNPA.

Would you like to make another representation?

No Response ID ANON-NRVC-BRU9-U

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 14:57:29

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:

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.: 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, 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.: The inclusion of the extension to West Heath Quarry is unsound for the following reasons: - New development at this site is contrary to Paragraph 172 of the NPPF which states “that great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks… which have the highest status of protection in relation to these issues” - New development at this site is contrary to Paragraph 205 of the NPPF which states that " In considering proposals for mineral extraction, minerals planning authorities should provide for the maintenance of landbanks of non-energy minerals from outside National Parks. - As stated in SSR10, any application for soft sand extraction within the SDNP will be assessed to determine whether exceptional circumstances exist and whther it is in the public interst. Given that any new mining activity within the SDNP would be contrary to the stated aims of the NPPF it raises a question as to how development of this site could ever be considered to be int the public interest by the SDNP. As such it should not be included in the first place. - This site is not strictly an extension to the existing quarry anyway. Whilst the vehicle access and main facilities would be retained the proposed additional site does not physically abut the existing quarry and therefore there will be non quarried land between the existing pit and proposed site. The operator proposes to use a system of ' above or below ground' conveyor belts to transport the sand across non quarried land back to the main processing area. As such this must be considered a new site within the National park and therefore runs in contradiction to the stated strategy of the SSR. - The existing access route between the quarry and the A272 is not currently suitable for the current traffic movements associated with the current quarry activities and is therefore not suitable for any intensification from the proposed 'extension'. The route passes over a scheduled ancient monument in Durford Bridge which is displaying significant damage from the repeated lorry movements. The route is a single track rural lane and lorrys meet travelling both ways requiring dangerous reversing. WSCC Advisory Lorry Route shows that the access routes for all 'shortlisted' sites are via single carraigeway 'local' routes. Durford land is plainly not a single carraigeway (single lane in each direction) and therefore not suitable for continued use as an access to the quarry by such large vehicles. -

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: - Remove the land east of West Heath Common as an allocated site from the SSR entirely.

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-BRUC-5

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 15:01:51

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Job title (where relevant):

Organisation or affiliation (where relevant):

A2 Client Details if applicable

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?:

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.: Having lived in Durleighmarsh for the past 30+ years and with the continued deterioration of Durford Lane over this period originally the small jobs of cleaning up was carried out by the local farmer, but the 30 ton sand lorries are just too big for the design of the road and ancient bridge which they have to cross over. I have witnessed the deterioration of the road, which has in the last 10 years been destroyed and the bridge has been smashed so many times that I cannot believe that you are even considering allowing a further increase in its usage.

After the last extension to the sand pit which, we as locals believed was to be the end, with the sand pit being handed back to English nature to use as wildlife preserve and walk ways. The damage the bridge has suffered is getting beyond a joke and you only have to walk over it to see that the lovely stone work is being destroyed.

I fully understand that the farm vehicles will still have to use the bridge even though they are getting bigger and bigger plus the fact you granted permission for more traffic going to Sky Park Farm, much to the disagreement from the locals who voiced their feelings, but their feelings were sweep aside even though nothing has been done to improve the road. The part of the road known as Durford Lane has deteriorated so badly and the few jobs that have been done to fill in pot holes is just exactly that (just a few jobs).

The main road water runs from the A272 to the bridge is like a torrent on the surface as all the existing drains have been crushed and are not working. When will someone use some basic common sense come and see what the people are talking about. If you are going to allow more development such as Sky Park Farm and extended sand pit extraction you first need an infrastructure to allow for this traffic, which you don’t have and which is full of pot holes and a danger to anyone using it.

Either side of the bridge you will notice that there are large areas where the road has collapsed and just running mud where huge lorries pull over to allow each other to pass especially on the south side the drains are no longer in existence and the road completely crushed down. This area really needs a new road done completely with proper passing facilities built into it.

Having read previous reports regarding the use of this road I cannot understand the people who say that this is adequate. I am not an engineer but a very practical person and perhaps you should get some inspector with practical knowledge to look at this area. The turn in from the A272 is very narrow and is a restricted entrance and twice before, when my daughter owned Toll Cottage on the corner, it was hit by lorries and also because of the restricted entrance quite often you have two lorries meeting at the same point with the one trying to enter into Durford Lane from the A272 has to back out onto the busy A272 blind. I have mentioned this before, but it seems that powers to be seem to ignore this and accept it being quite normal, I am sorry but I disagree as this section of the A272 is high on the accident list. It is a major accident waiting to happen with articulated lorries/farm vehicles having to reverse back onto the A272 to allow traffic coming onto the A272 from Durford Lane.

This area which was known for its local beauty and lovely c1600 Grade II Listed stone brige which is gradually being torn to pieces doesn’t seem to be the way ahead for the South Downs National Park, which is supposed to protect and preserve our old and Listed ancient history. The way that the bridge is being treated by big industrial usage, perhaps the best way out would be to build a separate bridge to preserve the old. If we don’t do something soon another bit of our English heritage will be gone in the name of big business (doesn’t anyone really give a damn?).

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 this extension to West Heath is to go ahead, then alternative, more robust road arrangements have to be put in place to lead from the new quarry onto the A272. Durford Lane simply cannot cope with the existing, articulated vehicles which are using it today. You simply need to buy some land off the local farmer and you can build a direct road from the new quarry to the A272. Please do not refer to this as an "extension" to the West Heath quarry as it does not abut the existing quarry, it is a new 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 Response ID ANON-NRVC-BRUE-7

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 17:48:39

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mr

First name: Michael

Last name: Moore

Job title (where relevant): Senior Planning Officer

Organisation or affiliation (where relevant): Milton Keynes 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: Michael Moore

Address Line 1: Planning Department

Address Line 2: Civic

Address Line 3: 1 Saxon Gate East

Address Line 4: Central Milton Keynes

Postcode: MK9 3EJ

Telephone number: 01908-252352

Email address: [email protected]

Local Authority

Other:

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?: 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.: Milton Keynes Council supports the Soft Sand review and considers the document is sound and legally compliant. We are in support of the Soft Sand Review document, particularly the element of allocating sites for soft sand extraction. As by allocating sites in the plan it provides certainty to communities and the minerals industry about where mineral development can take place and will help ensure a steady and adequate supply of soft sand throughout the plan period.

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-BRUS-N

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 21:57:17

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.: SSR 39 and 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?: 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.: I consider the review to be unsound because it is in direct conflict with the following policies:

SD2/3/4/6/7/9/11/12/13/15/17/20/21 and 25 of the South Downs Local Plan that has only recently been adopted. I am incredulous that it can even be considered possible to consider the Chantry Lane Extension when it is such an obvious breach of this plan.

The adverse impacts upon the National Park and its setting are incontestable. The proposed access road to be built off the A283 from the junction at Sullington Lane across the fields to the South Downs National Park will result in a huge scar on the landscape. This road will have a negative impact on the views from the A283 in to the National Park; the Sullington Conservation Park area; bridleways and footpaths; and the South Downs Way.

As well as the landscape and visual impact assessment being entirely detrimental there will also be a hugely negative impact on road safety. The Sullington Lane junction is already very dangerous as a result of the increased traffic generated by the landfill and housing development at the other end of Water Lane.

As a local resident I already feel that I am taking my life in to my hands when I try to cross the A283 from Water Lane to Sullington Lane. Increased pressure on this junction will inevitably add to the congestion, air quality and environmental issues that are already blighting the access routes in to Storrington.

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: Reject any proposals for an access road to Chantry Quarry from Sullington Lane.

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-BRUW-S

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 22:26:49

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

Title: Mr.

First name: Sid

Last name: Garner

Job title (where relevant): Chairman

Organisation or affiliation (where relevant): Wiston 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: Lucinda Woodage

Address Line 1:

Address Line 2:

Address Line 3:

Address Line 4:

Postcode:

Telephone number:

Not Answered

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.: SSR 1 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)

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.: 1)The Ham Farm Site being a new major development on a green field site with existing agricultural ties for the production of maize for biodigestion.

2) The geological data and bore results have not been published. The last published data is from the 1930's and was not specific to the area covered by the Ham Farm Site.

3) The published estimated traffic movement data for the Ham Farm Site clearly shows the vehicle movements exceed all reasonable levels for traffic flow on the A283. The air pollution generated at and around the site is glossed over, with vague reference to unspecified future mitigation of the pollution.

4)No calculation of the pollution caused by the on site machinery is given or estimated. This amounts to unacceptable environmental harm.

5) We also feel that the West Sussex Council officers charged with the production of the Soft Sand Review have been able to push the very real and present problems of this site into the future with the FAQs document, attempting to cover each of my earlier notes and comments on the unsuitability of Ham Farm as an open quarry, on a water course sited on an already overloaded highway.

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 Ham Farm Site should be removed from the review, the draft and the final plan.

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

Response ID ANON-NRVC-BRUP-J

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 22:32:34

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.: SSR27

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)

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 write following the Guiding Principles set out in para 2.41 of the Consultation Document.

The first principle : if the approval of this new site is adopted it is likely we will see a repeat of the unfortunate history at the existing site. Plans were agreed to turn the large inaccessible lake into an area of natural beauty offering recreational amenity to visitors when this site closed in 2025. Not only will this restoration be delivered at least 10 years late, but precedent suggests firm commitments should be made now to recreate this proposed new site as heathland.

The second principle : if adopted this proposal would add to the already considerable loss of amenity (several footpaths have already had to be closed). A pipeline or conveyor to link the two sites would cut across public rights of way and Long Distance routes.

The third principle : this proposal makes a mockery of this principle, which is meant to ensure proper regard to highway capacity and road safety. The well-known threat to the integrity of the extremely narrow grade 2 historic bridge over the Rother will no longer be reduced as was planned when the existing pit was supposed to be closed before 2025. Access to the A272 is via a single lane narrow road with almost no passing points over the bulk of this its 300 metre length leading from the bridge to the A272. Previous reports from the Highways Authority have been inconsistent and inadequate. There WILL be an increase in traffic when the Sky Park amenity comes on stream, and no prospect until 2033 of that dangerous bottleneck being relieved. There have already been a number of near accidents at the dangerous turn off the fast moving A272. Traffic backing up the lane to allow large sand lorries through the long narrow section can mean reversing onto the A272. Instead of the prospect of a reduction in the number of sand lorries, we local residents would be waiting for the big accident that is bound to happen.

The fourth principle : how does the proposed new site protect and enhance protected landscapes? The site is often waterlogged, the water table is high, yet a new quarry there would become yet another large lake, an eyesore in an area that the SDNP is supposed to protect. It would also require pathways for heavy plant to travel backwards and forwards, a noisy intrusion through an area of great tranquility and beauty.

The fifth principle : the proposed site can in no way be described as an extension, the preferred solution, with a journey of over 500 metres from one location to the other

The sixth principle : I am not qualified to comment

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-BR66-S

Submitted to Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan - Representations Period Submitted on 2020-03-02 23:23:26

Consultation Response Survey

Part A - Personal Information

A1 Personal Details

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 34

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

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 consider the SSR, with specific regard to Ham Farm, is not legally compliant. Local residents were not informed of the initial public engagement and stakeholder events that took place in 2014 when work began on the JMLP. This is contrary to the West Sussex Statement of Community Involvement, 3.2.2., which states that communities affected should be "able to engage in the plan making process in an informed manner and at an early stage". As a result local residents had no knowledge of this plan before the next stage when Ham Farm was proposed as a suitable site in April 2016.

In addition, the inclusion of Ham Farm is not sound; the evidence from the RAG assessment for amenity should have excluded the site. This identifies residential and business properties in very close proximity to the site and acknowledges that residents would be subject to high levels of harm from noise dust and light associated with mineral extraction. These properties are so close to the site boundary that no mitigation could prevent this.

This is contrary to the second guiding principle for site selection which seeks to protect the amenity of business and residents. The development principles listed for Ham Farm do not include any mention of mitigation for residents and business.

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 consider it necessary to remove Ham Farm from the list of sites allocated for soft sand extraction.

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

Yes, I wish to speak to the Inspector at the hearing sessions

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: As a local resident I would be significantly impacted by the development of the Ham Farm site for extraction of soft sand. I wish to ensure that my representation receives due consideration.

Would you like to make another representation?

Official use only PROPOSED SUBMISSION DRAFT SOFT SAND REVIEW Respondent No: OF THE WEST SUSSEX JOINT MINERALS LOCAL PLAN - REPRESENTATION FORM

If you would like more information about the Soft Sand Review or this process, please contact the Planning Policy and Infrastructure Team at: ŀ Planning Services (ref Soft Sand Review), West Sussex County Council, County Hall, Chichester, PO19 1RH ŀ [email protected] ŀ 01243 642118

This form should be returned by 11.59pm on 2 March 2020 to the above address. Additional copies of the form can be obtained from the County Council’s website: www.westsussex.gov.uk/mwdf. Photocopies of blank forms can also be made. There is also an online form available at www.westsussex.gov.uk/haveyoursay.

Late representations will not be accepted. Once the representation period closes, the Authorities will prepare to submit the review to the Secretary of State for examination, including all representations received and respondents details.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

ŀ Part A - Personal Details ŀ Part B - Your representation(s) – please fill in a separate sheet for each representation you wish to make. Only fill in Part A once and send all representations in together. ŀ Part C - An equalities form – this is voluntary and will be dealt with separately from Parts A and B

Data protection: Respondent details and representations will be forwarded to the Secretary of State for consideration when the Soft Sand Review is submitted for examination. All documents will be held at West Sussex County Council offices, County Hall in Chichester, and representations can be viewed by appointment and will be published online. They will be handled in accordance with the Data Protection Act 2018. West Sussex County Council is registered as Data Controller (Reg. No. Z6413427). For further details and information about our Data Controller, please see www.westsussex.gov.uk/privacy-policy. Personal contact details will be removed from copies of representations published electronically. West Sussex Soft Sand Review: Proposed Submission Draft

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

Resident Parish/Town Council SDNPA Member Local Business District/Borough Councillor Government Organisation Minerals or Waste Industry County Councillor Non-Government Organisation Landowner Local Authority Other (please specify)

If you submit a representation, your contact details will be used to automatically notify you of the following stages in the preparation of the Plan. Please tick the appropriate box if you DO NOT wish to be notified of the following:

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 West Sussex Soft Sand Review: Proposed Submission Draft

PART B: REPRESENTATION Please complete Part B for each representation that you wish to make. You only need to complete Parts A and C once. B1. Which part of the Soft Sand Review does this representation relate to? Please use the references set out in Chapter 4 of the Proposed Submission Draft Soft Sand Review document.

SSR Reference No SSR3

B2. Do you consider the Soft Sand Review to be: (tick as appropriate). Please read Sections 2 and 3 of the Guidance Note for guidance on legal compliance and soundness. B2.1 Legally compliant? Yes No B2.2 Sound? Yes No If you have ticked no to B2.2, please continue to B3, otherwise go to question B4.

B3. Do you consider the Soft Sand Review to be unsound because it is not: (tick as appropriate). Please read section 3 of the Guidance Note for an explanation of soundness. Positively prepared Justified Effective Consistent with National Policy

On the following pages, please explain why you think the review is unsound and/or not legally compliant, and set out any changes you feel should be made to the review to make it sound and legally compliant.

Please note: As there will not normally be a subsequent opportunity to make further representations based on your representation at this stage, please include all the information, evidence and supporting information necessary to support/justify your representation and the suggested change(s) to the review. After this stage, further submissions will only be invited at the request of the Planning Inspector, based on the matters and issues he/she identifies for examination. West Sussex Soft Sand Review: Proposed Submission Draft

B4. If you consider the Soft Sand Review to be unsound and/or not legally compliant, please explain why in detail and be as precise as possible. If you support the Soft Sand Review and feel it is sound and legally compliant, you can make comments to that effect.

The method of predict and provide is unsustainable when considering the finite nature of the resource of soft sand. Climate change is the biggest threat impacting biodiversity and soft sand extraction, and subsequent use of this resource, contributes significantly to this process. SWT cannot see how continued extraction based on the predict and provide model can comply with the legal requirement to achieve net zero emissions by 2050. We ask how this review considers this new legal framework?

SWT also does not have confidence in the demand scenarios presented in the LAA. In particular there is considerable uncertainty in housing delivery, along with likely changes in building techniques (required to achieve net zero). West Sussex Soft Sand Review: Proposed Submission Draft

B5. Please explain what change(s) you consider necessary to make the Soft Sand Review legally compliant and/or sound and be as precise as possible. Explain why this change will make the Soft Sand Review legally compliant and sound. It will be helpful if you are able to put forward any suggested revised wording of the policies or supporting text. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

B7. If you wish to participate at the hearing part of the examination, please outline why you consider this to be necessary. SWT wish to attend the examination so that we can discuss our objections formally with the Inspector and respond to any additional evidence presented by other respondents. THIS PAGE HAS INTENTIONALLY BEEN LEFT BLANK. Official use only PROPOSED SUBMISSION DRAFT SOFT SAND REVIEW Respondent No: OF THE WEST SUSSEX JOINT MINERALS LOCAL PLAN - REPRESENTATION FORM

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR8

Climate change is the biggest threat impacting biodiversity and soft sand extraction, and subsequent use of this resource, contributes significantly to this process. SWT cannot see how continued extraction based on the predict and provide model can comply with the legal requirement to achieve net zero emissions by 2050. The most environmentally sustainable approach would be a move away from any extraction of new minerals and no allocations within the SDNP.

It is difficult to see how soft sand extraction complies with the purposes of the SDNP. Additionally, the LAA appears to show that West Sussex is a net exporter of sand, therefore it is hard to demonstrate that any sand extracted from within the SDNP will significantly contribute to the economic or social wellbeing of the local communities within the National Park as per the SDNPA's duty.

SWT is pleased that the Authorities have considered the exceptional circumstances test via the Major Development Paper before proceeding with the plan. This is an improvement since the Regulation 18 consultation. However, we are still concerned that so many sites within the SDNP have been deemed 'acceptable in principle' and/or allocated in the plan. The Major Development Paper states that the conclusions of the 4SR will help to inform decisions on applications. West Sussex Soft Sand Review: Proposed Submission Draft

Further work should be done to demonstrate true need in allocating soft sand sites within the SDNP. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR9

SWT supports the addition of this paragraph and agrees that the authorities should consider all options for supply from sources outside of protected landscapes. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

B7. If you wish to participate at the hearing part of the examination, please outline why you consider this to be necessary. SWT wish to attend the examination so that we can discuss our objections formally with the Inspector and respond to any additional evidence presented. THIS PAGE HAS INTENTIONALLY BEEN LEFT BLANK. Official use only PROPOSED SUBMISSION DRAFT SOFT SAND REVIEW Respondent No: OF THE WEST SUSSEX JOINT MINERALS LOCAL PLAN - REPRESENTATION FORM

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR10

SWT supports this paragraph and agrees that any proposal for major development within the SDNP must pass the 'exceptional circumstances test'.

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR11

Whilst SWT agrees that all planning applications for soft sand extraction in West Sussex should be assessed against policy M2. We are concerned that there is still no guidance or explanation within the plan or evidence documents as what constitutes a physical extension.

New paragraph 6.2.27 (SSR18) states that 'physical extensions generally benefit from established infrastructure (e.g. access roads, processing plant and offices) which means that it may be more appropriate to continue activities, rather than develop new sites'. Given that the fifth guiding principle is to show a preference for extensions to existing sites rather than new sites (subject to cumulative impact assessments), SWT feels that there needs to be clearer guidance on extensions.

It appears that a sites does not need to be physically connected to an existing site to constitute an extension as demonstrated at West Heath. Additionally, paragraph 6.2.27 indicates that whilst physical extensions 'generally benefit' from established infrastructure, this is not always the case.

West Sussex Soft Sand Review: Proposed Submission Draft

In order for the plan and its policies to be effectively applied, SWT would like to see some consideration of what constitutes a site extension, or alternatively the types of issues that will be considered when determining if a proposal should be judged as an extension. This could be included in the glossary or supporting text of the plan. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR13

SWT supports the changes to policy M2.

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR15

SWT supports the statement that 'for development proposals on unallocated sites a clear preference will be given to sites with the least impact on the SDNP'. This is consistent with national policy and in particular NPPF paragraphs 204f and 205a. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR17

SWT supports this additional paragraph and the requirement for the need for major developments within the National Park to pass the 'exceptional circumstances test'. This is consistent with national policy and the requirements of the adopted South Downs Local Plan. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR18

SWT agrees with the wording of this paragraph, however we are concerned that there is still no guidance or explanation within the plan or evidence documents as what constitutes a physical extension.

Paragraph 6.2.27 sets out that physical extensions generally benefit from established infrastructure, but this does not always have to be the case. SWT would like further explanation of what this circumstance might be. Could a site be considered an extension if it did not physically connect with an existing site and was not going to make use of established infrastructure? We feel that this information is needed given that the fifth guiding principle is to show a preference for extensions to existing sites rather than new sites (subject to cumulative impact assessments).

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR19

SWT strongly supports this additional paragraph and believe it is necessary to ensure compliance with the requirements of national policy, in particularly NPPF paragraph 204. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR23

SWT supports the first sentence of this additional paragraph. However, we do not support the second sentence which states:

'Restoration of sites within or nearby to the SDNP should consider their ability to contribute to ecosystem services and biodiversity net gain'.

SWT does not see why consideration of both ecosystem services and biodiversity net gain should only be restricted to sites within or nearby the SDNP or why they should only be considered in terms of restoration. All public authorities have a legal duty to have regard for biodiversity. Additionally the requirements of policy Policy M17: Biodiversity and Geodiversity applies equally to all sites within West Sussex. Consideration of both biodiversity and wider ecosystem services should include the current value of the site, not just what is achievable after restoration. This is particularly important for soft sand as the resource is primarily restricted to the Greensand Heaths, a rare and valuable landscape within the SDNP. SWT does not believe that net gains can be achieved when rare priority heathland habitat is replaced by open water which is often the only viable option for natural restoration. There should be consideration of the role of the sand within the site and therefore what is actually possible if all of this resource is extracted. West Sussex Soft Sand Review: Proposed Submission Draft

SWT recommends the following amendments to new paragraph 7.1.4 to ensure it is consistent with national policy:

Development within the SDNP will need to consider its impact on the purposes of the SDNP at each stage of development. Sites should consider their ability to contribute to ecosystem services and biodiversity net-gain, especially through phased restoration. The SDNPA will prepare a guide to restoration of mineral sites within the SDNP and proposals should take account of this in the preparation of any planning application.

This makes it clear that consideration of net gain and ecosystem services applies to all sites as per M17 and paragraph 170 of the NPPF. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR28

SWT supports this additional wording. The NPPF is clear that restoration of sites should be achieved at the earliest opportunity not simply when an entire site has been worked. West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR35

SWT does not believe policy M11 is robust enough to ensure that net gains to nature and natural capital are secured through the working of this sites as required by NPPF paragraphs 170, 171 and 175. In particular, working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved. We also do not believe that the criteria incorporates the recommendations within the Landscape Assessment. We therefore recommend a few amendments to the development principles.

West Sussex Soft Sand Review: Proposed Submission Draft

In order to ensure the development principles are effective in achieving biodiversity gains as per national policy, we recommend the following changes:

(vii) 'where possible' should be deleted

(xi) The hydrological assessment should seek to avoid impacts not minimise. This is in line with the requirements of the mitigation hierarchy.

Paragraph 7.2.6 refers to enhancement to the existing woodland but this is not reflected in the development principles. Principle (xxi) should be amended to ensure opportunities are taken to link and enhance surrounding hedgerow and woodland structure, not just link.

Additional principles that cover the following issues should be included to ensure compliance with national policy and better translation of the recommendations from the Landscape Assessment:

'working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved'.

'Create and retain appropriate buffers around the streams, woodland, copses and tree belts abutting the site and link new planting with this, and to the existing network of hedgerows and mature trees, to create continuous, interconnected belts of trees and vegetation' West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR38

SWT does not believe policy M11 is robust enough to ensure that net gains to nature and natural capital are secured through the working of this sites as required by NPPF paragraphs 170, 171 and 175. In particular, working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved. We also do not believe that the criteria incorporates the recommendations within the Landscape Assessment or reflects the biodiversity value of the site, particularly the site specific quality of 'well-drained sandy soils supporting heathland habitats (acid grassland, bracken, gorse)' or the connection to West Heath Common Local Wildlife Site.

It is not clear to SWT what the current state of West Heath Common LWS is, however if there are opportunities to enhance the LWS through this extension, they should be taken.We therefore recommend a few amendments to the development principles.

West Sussex Soft Sand Review: Proposed Submission Draft

In order to ensure the development principles are effective in achieving biodiversity gains as per national policy, we recommend the following changes:

(iv) 'where possible' should be deleted

(viii) The hydrological assessment should seek to avoid impacts not minimise. This is in line with the requirements of the mitigation hierarchy and particularly important given the proximity of the River Rother Local Wildlife Site.

SWT strongly supports the inclusion of development principle (xiii), however for clarity we believe the part about the site liaison group should be a separate principle.

We are concerned that there is no reference to the valuable habitats referred to in Landscape Assessment, particularly the site specific quality of 'well-drained sandy soils supporting heathland habitats (acid grassland, bracken, gorse)' or the connection to West Heath Common Local Wildlife Site. Additional principles that cover the following issues should be included to ensure compliance with national policy and better translation of the recommendations from the Landscape Assessment:

'Create and retain appropriate buffers around the woodland, copses and tree belts abutting the site and link new planting with this, and to the existing network of hedgerows and mature trees, to create continuous, interconnected belts of trees and vegetation.'

'working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved'.

'Opportunities to enhance West Heath Common LWS should be taken'.

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MsFirst Name JessLast Name Price

Job Title (where relevant) Conservation Policy Officer

Organisation or affiliation (where relevant) Sussex Wildlife Trust

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant)

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Ms Jess Price

Address Sussex Wildlife Trust Woods Mill Henfield BN5 9SD

Telephone 01273497511

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No SSR40

SWT does not believe policy M11 is robust enough to ensure that net gains to nature and natural capital are secured through the working of this sites as required by NPPF paragraphs 170, 171 and 175. In particular, working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved. We also do not believe that the criteria incorporates the recommendations within the Landscape Assessment or reflects the biodiversity value of the site, particularly the presence of adjacent ancient woodland.

There is also no reference to the geological SSSI on the existing (adjacent) extraction site. We therefore recommend a few amendments to the development principles. West Sussex Soft Sand Review: Proposed Submission Draft

In order to ensure the development principles are effective in achieving biodiversity gains as per national policy, we recommend the following changes:

(vi) 'where possible' should be deleted

(ix) The hydrological assessment should seek to avoid impacts not minimise. This is in line with the requirements of the mitigation hierarchy and particularly important given the proximity of the Arun Valley SPA.

SWT strongly supports the inclusion of development principle (xvi), however for clarity we believe the part about the site liaison group should be a separate principle.

We are concerned that there is no reference to the adjacent ancient woodland or the need for a suitable buffer. Additional principles that cover the following issues should be included to ensure compliance with national policy and better translation of the recommendations from the Landscape Assessment:

'working and restoration plans should be informed by up-to-date ecological information to ensure a measurable net gains to biodiversity are achieved'.

'Ancient woodland must be protected from harm including a 15m buffer of suitable habitat as a minimum.' West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title Mr First Name Peter Last Name Earl, BTP MRTPI

Job Title (where relevant) Town Planning Consultant

Organisation or affiliation (where relevant)

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name (1) Michael CrawfordLast Name (2) Adrian Waddams

Job Title (where relevant)

Organisation or affiliation (where relevant) MINSTED RESIDENTS GROUP in association with STEDHAM WITH IPING PARISH COUNCIL

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Peter Earl, BTP MRTPI

Address

Telephone

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No Proposed Submission Draft (Regulation 19

In answer to question B4 the Soft Sand Review is not considered to be legally compliant with all relevant legislation and in other respects it is considered unsound.

Please see separate file attached: Representations 2 of 2 (PG Earl) Minsted Residents and Stedham with Iping PC f.pdf with pages numbered 1 to 19. West Sussex Soft Sand Review: Proposed Submission Draft

See pages below:

Comments on specific policies

SSR2- The first sentence is factually incorrect and should be deleted as has been shown in section 1 of this representation. There is an absence of understanding as to the uses to which land won soft sand is being used. It is apparent that marine won soft sand is being landed in the plan area and used as a substitute for land won reserves. It is apparent that processed sandstone has been used to substitute soft sand and that recycled materials are capable and being used to substitute for soft sand.

The second sentence should be extended with additional wording to make clear that this is a limited resource and should be used sparingly only where it is shown to be the only material clearly suitable for the stated purpose.

SSR3- This policy must be reworded to take into account all the issues raised in section 1 and the figures amended to reflect the evidence that has been presented. The average sales ‘value’ is not something which has been referred to and should not be introduced as it adds to the confusion. Rarer commodities will by their nature have higher values, but this should amplify the need for more constrained supply, otherwise the precious resource will not be available for future generations.

The NPPF prescribed 10-year rolling average guideline but has been replaced by a simple average of the last ten-year sales which does not identify a trend and does not produce the same results. Using a 10-year rolling (or moving) average calculation shows a long-term trend of falling sales. However, the simple average of the last 10 years sales of 313,210 shows the same annual sales for each year to the end of the plan period which, by the year 2033, will then be based on the same static data that is 15 to 25 years old. Whilst the lower soft sand sales figure is welcomed, extending the landbank it is still considered that it should be lower to meet the requirements of policy SSR4 in terms of the prudent and efficient use of minerals. For these reasons and the representations above there must be a more enlightened approach if the plan is to be seen as legally compliant, soundly based and relevant.

SSR4- The strategic objectives need to be revised. In the light of change to wording in paragraph 1 is generally supported, but it is considered that it must refer to’ need’ rather than ‘demand’ otherwise it is contradictory. The wording must also be consistent with the NPPF paragraph 204 b). and the approach the authority is taking with other minerals as indicated in paragraph 6.2.8 (2), concerning sharp sand and gravel. The revised wording should be:-

‘To require the use of substitute or secondary and recycled materials and minerals waste to be maximised before considering primary minerals, recognising their limited availability and finite supply.’ A new paragraph 2 should be inserted to place non land won sources in preference to land won primary minerals:

‘To research, promote and maximise the use of marine won soft sand reserves above land won sources utilising existing coastal wharfage and processing facilities which are well serving to meet the needs of coastal urban communities and the plan area.’

A new paragraph should be added, to reflect the concerns of the community at the number and harm from partially worked and abandoned soft sand mineral sites, and to take account of any sub national surplus of soft sand as indicated in section 1, particularly from Surrey and Kent towards the end of the plan period.:

‘Before the development of new soft sand reserves to ensure that all existing soft sand reserves within the plan area are fully worked and in restoration and full account is taken of the availability of surplus reserves of soft sand within the sub national plan area.’

Paragraph 3 renumbered as 4 should be deleted as being incompatible with the first and second and third strategic objectives, and in any case the need from outside the national park needs to be much more clearly defined as it can be read in two ways as worded. It is surely not the intention to meet a wider sub- national or national need within the plan area, but that is one interpretation of its reading. The objective should refer to soft sand, as sharp sand and gravel are covered separately in the Minerals Local Plan.

Paragraph 3 should be reworded to ensure it is compatible with the first two strategic objectives:

‘To only make provision for soft sand, to meet the clear and defined need within the plan area and from outside the South Downs National Park, unless all other opportunities have been fully considered in accordance with objectives 1 and 2 and only allow development within the national park in exceptional circumstances and in the public interest of the National park’.

SSR7-This policy needs to embrace flexibility and alternatives. Sites within the SDNPA will need to show that all the wider issues in section 1 have been exhausted, within existing sites fully worked and restored.

SSR8- The strategy must reflect the revised strategic objectives and therefore be consistent with the NPPF Para 203 and 204 to acknowledge the importance of finite reserves, their best use and to ensure compatibility with the wider sustainability and climate change tests. The order must reflect the strategic objectives and other policies. As proposed by the MPA, extensions to existing sites within the SDNPA would be resisted whilst outstanding restoration issues are resolved. This is vital to ensure the best use of land and avoid harm from large areas of mineral development within the plan area having a despoilt appearance. It must therefore be reworded as follows: ‘The strategy for the provision of land won soft sand is:

• to continue to work with Mineral Planning Authorities across the South East to identify potential alternative sources of soft sand (land won, marine won or substitute materials) to ensure that sites provision is made for soft sand outside of protected landscapes in the first instance

• to allocate a new site inside of West Sussex and outside of the South Downs National Park (see Policy M11)

• to allocate extensions to existing soft sand sites within the South Downs National Park (see Policy M11) only where such sites have been fully worked to the extent of their boundaries and where the restoration has been completed.

• to allocate up to two extensions to existing soft sand sites within the South Downs National Park (see Policy M11.

SSR13- This policy must be updated to reflect the strategic objectives and strategy for consistency revised as above.

SSR17- This policy must be updated to reflect the strategic objectives and strategy for consistency revised as above.

SSR18- This policy needs to be deleted or set out in a more balanced way recognising that ‘established infrastructure’ can be different in character and form, and that particularly, for smaller sites, the majority of plant is of mobile nature and can easily be relocated at a small cost. This policy also assumes that the existing operational arrangements are deemed satisfactory and that during the operation of the site there have been no material changes which would require different environemnatl criteria to be considered. As at Minsted the continuing operation of processing plant close to a Nature Reserve and residential properties would not be acceptable because of the level of harm. It is strongly suggested that this policy be deleted.

SSR19- This policy is strongly supported and is vital in the views of local communities to ensure the level of harm from mineral working is contained and that the objective of progressive restoration is achieved.

SSR20- The monitoring arrangements must become more transparent and include a better understanding of where minerals are being used and for what purpose to better inform the use of finite resources. It must also include information on the use of substitute or secondary and recycled materials and minerals waste.

SSR21- The strategic objectives must be altered to respond to the amendments requested above. SSR23- This policy is welcomed.

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

B7. If you wish to participate at the hearing part of the examination, please outline why you consider this to be necessary. To ensure that there is complete transparency in all the assessments undertaken by the MPA and to enable officers to be questioned on the various technical and environmental judgments that underpin the SSR and background documents and the conclusions they have reached.

Potentially, we would also wish to be able to question other participants who are taking a counter view to the MRG representations.

We wish to be able to amplify the representations we have made so that the local community views can be fully explained and the weight of public opinion confirmed in respect of the potential further mineral working at Minsted. THIS PAGE HAS INTENTIONALLY BEEN LEFT BLANK. THE FOLLOWING PAGES NUMBERED 1 TO 19 ARE TO BE ATTACHED TO:

Proposed Submission Draft Soft Sand Review of the West Sussex Joint Minerals Local Plan PART B REPRESENTATIONS By Peter Earl BTP, MRTPI on behalf of Minsted Residents Group in association with Stedham with Iping Parish Council 2 March 2020

SECTION 1

Legal compliance In answer to question B4 the Soft Sand Review is not considered to be legally compliant with all relevant legislation and in other respects it is considered unsound.

Legislative compliance. The SSR and the Sustainability Appraisal Main Report do not appear to have paid regard to other statements of government policy which are considered material to plan making, under paragraph 6 of the NPPF. The provisions of the Climate Change Act 2008 seek to ensure that the United Kingdom becomes a low-carbon economy and gives ministers powers to introduce the measures necessary to achieve a range of greenhouse gas reduction targets. The Climate Change Act 2008 (2050 Target Amendment) Order 2019 subsequent amendment brought forward in 2019 changed the minimum percentage by which the net UK carbon account for the year 2050 must be lower than the 1990 baseline from 80% to 100%.

The next ten years are considered critical if the UK is to build on the strong foundations it has laid through the Climate Change Act. Intensive action is required if the UK is to drive down its emissions right across the economy and meet its carbon targets into the 2020s and 2030s at least cost. The SSR covers the period from 2020 to 2033 and therefore there is clear expectation that minerals planning and the implications for climate change must start to be reflected in relevant policy work, particularly the volume of material to be handled, the reuse of building materials and the related maximisation of recycling.

The Act requires: a UK-wide assessment of the risks and opportunities arising from climate change which must take place every five years. The first assessment (UK Climate Change Risk Assessment: Government Report) was published in January 2012 and includes a programme for adaptation to climate change to address the identified risks so as to deliver resilience on the ground.

It is anticipated that more action will be needed to ensure the nation is adequately prepared for changing average conditions and more extreme weather; in the natural environment, built environment, infrastructure and through changing people’s behaviour. Urgent action is needed to flesh out current plans and proposals, and supplement them with additional measures, to meet the UK’s legally-binding carbon targets in the 2020s and 2030s.

Mineral development and climate change The Climate Change Act provisions could reasonably be expected to be reflected in the approach to mineral planning and specifically the need to plan for future mineral needs and the consequent necessary replenishment of mineral sites set against the options considered. This legislation, including that set out in paragraph 20 of the NPPF, is not reflected in either the SSR or the LAA work in terms of mineral development. It would have been expected that MPA’s and the mineral industry would begin to focus on the need to adapt to climate change to address the identified risks so as to deliver resilience on the ground, both in terms of the carbon footprint of the minerals, their use and transportation. The plan making has not shown that it has positively

Minsted Residents Group in association with Stedham with Iping Parish Council Page 1 of 19 sought opportunities to meet the mineral needs of the area, taking full account of various changes, set out below. Accordingly, it is not considered that the approach is justified, fully consistent with national policy and therefore justified and effective.

Need for soft sand. The SSR is supported and relies upon LAAs, the last one dated January 2019. The soundness of the plan it seems is largely reliant upon a document that is entirely dependent on information provided by the minerals industry. The supporting document relating to the Duty to Cooperate Statement provides interesting reading in terms of the basis for estimating future need. It is noted that some mineral operators can be reluctant to provide authorities with relevant information on sales. The last WSCC annual monitoring report covering the SDNP is dated 2017/18 and does not include information on the reserves at each sandpit. There are no sales figures given for soft sand in the 2018 LAA which is apparently confidential, and reliance is placed on sales in 2016.

In any assessment there is an absence of transparency. It does not allow the reasonableness of this information to be publicly tested both in terms of the annual sales figure and remaining reserves. In our own experience at Minsted, a sandpit that was fully worked out in 2004 has continued in operation until 2015, with various estimates produced by the operator of the remaining reserves and considerable evidence of overworking. This situation is unsatisfactory and from a public standpoint does not allow the community to conclude that the plan has been soundly prepared or justified.

In terms of the LAA, and the estimates of future supplies of soft sand it cannot be concluded that the forecasts are reasonable.

The forecast for soft sand does not distinguish between demand (i.e. what quantities are being sought by the industry and the consumer) and actual need (the quantum of material necessary for building and infrastructure purposes). The process is led by the minerals industry without any balance seemingly applied to the wider environmental context. There are no details of where the material is being used and importantly whether or not it is being used within the plan area. In the Duty to Cooperate Statement (DTCS) in a letter dated 19th March 2019 Oxfordshire County Council stated ‘We do not know any publicly available sources of information specifically on the movement of soft sand between mineral planning authority areas.’

It is apparent that not only is there little understanding of the movement of material but also whether the soft sand is being used for mortar in built development or the surfacing of roads with tarmacadam as indicated in the assessment of future demands.

It is known from our own experience at Minsted and elsewhere that soft sand is being used for recreational, leisure and horticultural purposes, often mixed with soil. Clearly, such use will contribute to soft sand sales but it does not suggest that what is a precious and irreplaceable resource is being wisely used and it is necessary to excavate nationally important landscape for that purpose. The ability to substitute recycled waste materials, or use materials which are more readily available seems high. This is important because of the wider tests within the NPPF.

Sustainable development The purpose of the planning system under paragraph 7 of the NPPF is to contribute to the achievement of sustainable development. The industry-led historical based approach to the quantum of minerals that must be provided, fails to show it has not compromised the ability for future generations to meet their own needs. The provision of soft sand is not based on an objective assessment of need but on the basis of existing period of uncontrolled and unchecked consumption

Minsted Residents Group in association with Stedham with Iping Parish Council Page 2 of 19 over the last ten years. To meet tests of sustainability there must be much greater focus on the careful use of finite mineral resources and therefore a more sustainable approach to the working of soft sand particularly where it involves a nationally important landscape.

Achieving sustainable development is understood to mean meeting a number of objectives, including contributing to protecting and enhancing our natural, built and historic environment; such as making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

The expectation in the NPPF is that sustainable development will be pursued in a positive way with a presumption in favour of sustainable development at the heart of the Framework. It is not shown in this SSR or the LAA that the best use is being made of existing minerals to satisfy the test in paragraph 203 of the NPPF.

While much of the soft sand may be required to deliver housing, infrastructure and other key business needs, this is not evidenced in the assessment in a manner that can be verified. Furthermore, there is no clarity of where material is being taken to and whether it is needed within the plan area or elsewhere. The continuing absence of such information undermines confidence in the figures and therefore the soundness of the SSR.

On this basis it cannot be stated with any confidence that the proposed strategy, as a minimum, seeks to meet the area’s objectively assessed needs or that the plan is positively prepared in a way that is aspirational, seeking to realise actual sustainability in accordance with the NPPF (para16). It is only by aligning forecasts and need in a way that challenges industry to look and pursue alternatives will the government’s NPPF and other sustainability aspirations will be realised.

Alternative sources of soft sand Within the Duty to Cooperate Statement (DTCS), at the South East Mineral Planning Authorities Meeting on 27 September 2013, discussions indicated that ‘There is potential for supply of soft sand from marine won sources but the extent of this is currently unknown and more research would be needed to demonstrate the extent of this potential resource. This is likely to be a long-term issue and therefore, currently emerging plans are likely to need to plan on the basis of other sources. This is supported by the South Downs National Park Soft Sand Study.

The matter of marine won soft sand clearly warrants further investigation, but having regard to the 15-year plan period it does not appear to have been either investigated to any great extent or given weight as a potential source, even towards the end of the plan period.

The soft sand position statement (2019) at page 3 indicates again that ‘There is potential for supply of soft sand from marine won sources but the extent of this is currently unknown and more research would be needed to demonstrate the extent of this potential resource. Soft sands are commonly deposited in marine environments, where constant movement results in the rounding, polishing and sorting of the grains. This is likely to be a long-term issue and therefore currently emerging plans are likely to need to plan on the basis of other sources. This is supported by the South Downs National Park Soft Sand Study.

Paragraphs 3.28 to 3.31 of the Soft Sand Position Statement (2019) on page 15 refer to: -

3.28 Marine sands have mechanical, chemical and physical properties, identical to high quality land-based sands, therefore the end uses are no different. In England, marine sands are widely used in the production of:

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 Mortar for bricklaying and blockmaking  Screeds  External renders  Internal rendering  Masonry blocks  Paving blocks.

3.29 Marine won sand with properties akin to land-won soft sand is currently sourced from the Bristol Channel as there are extensive deposits of mobile sand across the upper Severn Estuary. The resource has been exploited as the terrestrial alternatives in South Wales are constrained and the depositional environment favours finer sand resources to be available.

3.30 Research carried out by the Crown Estate shows the extent of the potential sand and gravel resource in the English Channel and Thames Estuary. The report shows that there are likely to be areas of fine sand within the area, but that the ‘economic potential of individual sites can only be proved by a detailed evaluation programme’.

3.31 According to British Marine Aggregate Producers Association (BMAPA), marine deposits off the coast of the Netherlands are dominated by fine to medium sand7. The UK exports some coarse sand and gravel to the Netherlands and it is possible that this fine to medium sand could be imported into the UK’, and may be use the same vessel to return to reduce environmental impact further.

The Soft Sand Study p3.22 confirms that a total of 50,710 tonnes of marine soft sand was sold at wharves in 2017 with the majority (46,695 tonnes) sold at West Sussex wharves, and the rest from the Isle of Wight and Hampshire. Whilst this figure represents 3% of total soft sand sales from quarries and wharves in the South East in 2017, it indicates that there is a demand for this material, that it has qualities which allow it to be a substitute for land won sources. Accordingly, there is a reasonable expectation that it should be factored into the LAA. Even assuming that no additional volumes of marine soft sand can be imported annually this source would yield around 700,000 tonnes over the plan period.

The 2018 LAA makes reference in para 2.1.32 to the South Downs Soft Sand Study (2012) which states that the Crown Estate ‘believe that there is potential for marine sources to provide viable ‘soft’ sand as an alternative to land-based quarrying’. There are sources of marine-won aggregate being used, as a replacement, or through blending, to create mortar. In 2014, in England and Wales, 1.05mt of marine-won aggregate was used in mortar. Of this, 72,000 tonnes were sold in the South East.

The SEEAWP South-East England Aggregates Monitoring Report 2017 sets out that some 50,710 tonnes of marine soft sand were sold from South East wharves (table 8). Evidence collated via the annual Aggregate Monitoring Surveys shows that during the three-year period 2015 – 2017, an annual average of around 51,118 tonnes of aggregate sold from West Sussex wharves was sold as soft sand. The landing of additional quantities of soft sand would not give rise to capacity issues as there is mention in para 2.2.17 of the 2018 LAA of a theoretical minimum surplus capacity of 762,553 tonnes per annum at wharfs.

The landing of minerals close to the areas of population and development would reduce transport impacts. There is a clear and viable alternative to land won reserves with potentially less environmental impact, and therefore higher sustainability credentials.

The Soft Sand Review: DTCS includes reference to the outcome of correspondence in September

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2015. ‘The outcome of the responses is that there are reserves of soft sand outside the SDNP that could supply West Sussex and that none of the authorities that responded were relying on imports of aggregates from West Sussex. • ‘Surrey County Council confirmed that they can continue to supply soft sand to West Sussex at previous rates until 2031….’ ‘Kent County Council could have a surplus of soft sand and possibly a margin of flexibility for its anticipated plan period’. More recently Kent County Council have indicated that there is potentially 1,000,000 tonnes of soft sand that would be available to meet wider needs, including that within WSCC but it is unclear why this has not been factored into any forecasts.

The DTCS includes reference between 14 April 2016 to 17 June 2016 to views from Surrey County Council who were ‘supportive of the flexibility built into the Plan through Policy M2 and that it is essential that supply and demand is monitored carefully through the LAA so that soft sand provision to meet future demand in the South East can be provided in the most sustainable way.’

Additionally, Kent CC repeated the statement given in 2015 which suggests Kent could have a surplus of soft sand (14.24mt surplus), if the identified replenishment sites come forward. This surplus could meet West Sussex’s 3.724mt shortfall. However, there is no certainty that the replenishment sites will come forward or that Kent CC will be able to meet demand for soft sand within West Sussex. It is noted that a significant amount (8mt) of potentially replenishing material is tied up in one site (Shrine Farm).

The Soft Sand – Draft Position Statement by South East Mineral Planning Authorities (mpas) in May 2019 at para 3.26 ‘identified surplus of 0.7mt would make a meaningful contribution to maintain this position in the Parties collective area, that is the subject of this SOCG.’

At the sub national level, the South East – Mineral Planning Authorities Soft Sand Position Statement (2019) confirms at paragraph 3.25 that reserves of soft sand in the South East increased to 17.7 years during 2017 (from 14 years in 2016) although because of the change in sales in 2017 this reduces to 14.6 years. This figure can be expected to increase in 2018 and beyond because the first year of sales of the 10-year average on which sales are based was exceptionally high. Allocations and permissions are expected to add an additional 6 years of supply over time.

National planning policy confirms that sub-regional apportionments are flexible, and the opportunity should be provided, through the Local Development Framework process, to test practicality and environmental acceptability of the apportionment.

It is clear that there is a high likelihood of other authorities being able to maintain the necessary levels of soft sand supply across the South East, including within WSCC, where there is strong potential to divert a portion of soft sand recognising the nationally important landscape.

Factors of Change The demand for soft sand, and therefore justification for new sites, is over-estimated based on evidence in recent documents applicable to this Single-Issue Review of Soft Sand. The 2018 LAA and related estimates of demand do not adequately take account of the significant changes within the building industry with the increase in off-site production. This is evident in the need to address the increased resilience of our built environment and green infrastructure solutions. The Governments Clean Growth Challenge, as part of the industrial strategy to put the UK at the forefront of the global low carbon economy, places particular emphasis on the importance of transforming construction processes. The stated aim is to enable the building industry to build 50% faster, 35% cheaper and with 50% less carbon emissions over the lifetime of buildings. In consequence, much of the building industry focus is now concerned with the development of off-site solutions, reducing the need for

Minsted Residents Group in association with Stedham with Iping Parish Council Page 5 of 19 mortar and therefore soft sand.

Another increasingly dominant factor in estimating demand for building materials, including sand for mortar and cement, is Greenhouse Gas Emissions. These are being factored into national policies and in February 2019 the Committee for Climate Change published a report on future housing that referred to the need, ideally as soon as 2025, to: improve focus on reducing the whole- life carbon impact of new homes, including embodied and sequestered carbon. The report advocates using wood in construction to displace high-carbon materials such as cement (comprising large volumes of sand) and steel. On this basis there is already pressure to reduce consumption of sand, which is a non-renewable resource.

The formation of full-service modular building companies, such as Modern Boutique Ltd based in Newhaven, East Sussex and their recent delivery of affordable homes in Peacehaven is a clear example of this shift in housing delivery. This is not reflected in the LAA and must be adjusted to better relate to this significant change to building delivery.

There is not much emphasis on the use of secondary and recycled products or more sustainable alternatives in any part of the assessment and therefore no suggestion that the contribution of recycled products is being maximised to initiate change. The 2018 LAA shows that the use of recycled material is declining. No explanation is given as to the underlying reasons, but it would not be unreasonable to suggest that the over provision of primary minerals is directly correlated to this situation. Companies such as GlassTech Ltd have an open loop recycling process in which waste materials that cannot be recycled back into their original industry are treated and utilised as a resource for other industries e.g. insulation industry for loft insulation and sand replacement for laying block pavers & slabs, backfilling ground works, pipe bedding and ménages. It is therefore appropriate to reduce reliance on primary minerals, including soft sand to ensure recycling is increased. Again the 2018 LAA shows that in 2018 the 18 sites within the plan area have the ability to provide a total capacity of 848,000tpa for recycled aggregate production, which is more than double current levels.

At the regulation 18 stage it was requested that the WSCC/SDNPA should review the LAA and estimates of demand so that they are more closely aligned to the trends in building. This has not happened and therefore the plan is not considered to be positively prepared, effective or justified.

Accuracy of data. The accuracy of production data can only be guaranteed by independent, external monitoring of the information provided by individual quarry owners or operators. Declared mineral royalties to HMRC are unlikely to provide any more useful verification than either production figures or sales figures as the source for all is the same. Because this data is so vital to all mineral planning and future national policy it cannot simply be left for a myriad of on-site operators to provide or not as they wish; it must be monitored, verified and controlled by government centrally.

Current reserves in the plan area are indicated to be 2,754,000 tonnes (production figures, 2018 LAA). However, just one year earlier the West Sussex Joint Mineral Local Plan 20184 had indicated that the in 2017, the total permitted reserve of soft sand was 3,354,800 tonnes which at the time was considered to provide a landbank of 10.7 years. There is an unexplained 600,800 tonne difference in these figures, which is significant for the purposes of the landbank and is both unexplained and inconsistent with annual sales. The West Sussex Joint Mineral Local Plan 2018 at figure 2 shows that supplies of soft sand within

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West Sussex are 329,394Tonne averaged across a ten-year period of 2008-2015. At paragraph 6.2.13 of the same document the 10-year average sales value for soft sand is given as 313,210 tonnes (2007 – 2016) (based on January 2017 data). It is unclear why the sales figure and the supply figure is different. On this basis the supply and demand picture were considered to show that additional supplies of 2.36mt of soft sand are likely to be needed towards the latter half of the Plan period, against 2.754mt in the LAA 2019.

The accuracy of mineral production rates and reserves must be verifiable. It is questioned, with reference to Minsted sandpit, how a fully worked out quarry in 2004 has continued producing sand for 10 plus years undermining forecasts and indicating that quarry owners are not being open and honest with the information on the quantity of viable resources. To highlight this point, it is apparent that for the purposes of the JMLP it was suggested that the reserves at Minsted were in the region of 480,000 tonnes; but in October 2018 this figure had, without explanation or recent working at the sandpit, changed to 170,000 tonnes. Subsequently, a ROMP consent has been granted in November 2019 which assumes working until 2025 with a minimum of 120,000 tonnes available. The reasons for this need to be fully understood for the contribution of this and other sandpits to be given credibility. The quantity of available reserves needs now to include Minsted in any case.

At the regulation 18 stage WSCC/SDNPA were requested to review the information that underpins assessments over past plan periods and be in a position to fully confirm or clarify the extent of reserves. The British Geographical Survey UK Minerals Yearbook 2015 shows steadily declining UK production of sand and gravel (aggregates) including building (soft) sand in the period 1990/2014 with output becoming more constant at a lower level of approximately half the tonnage of that in 1990 for the years 2010-2014. In every year 2010-2014 the domestic consumption was less than production with the balance being exported. This includes land won and marine dredged products. In West Sussex 275,000 tonnes of sand and gravel was exported in 2014 (of which 96% is soft sand).

This suggests that the need for soft sand is reducing within the plan area and the large surplus produced is simply being exported to other parts of the South East. The reasons for this trend need to be understood. It was suggested that other Mineral Planning authorities are not providing adequate reserves within their plan area to meet their needs, or that the surplus from WSCC/SDNP plan area is being utilized for other (non-building) purposes elsewhere.

The NPPF at para 207 says “Minerals planning authorities should plan for a steady and adequate supply of aggregates by: a) preparing an annual Local Aggregate Assessment, either individually or jointly, to forecast future demand, based on a rolling average of 10 years’ sales data and other relevant local information, and an assessment of all supply options (including marine dredged, secondary and recycled sources); b) participating in the operation of an Aggregate Working Party and taking the advice of that party into account when preparing their Local Aggregate Assessment”.

However, in forecasting future sales, the NPPF-prescribed 10-year rolling average guideline has been replaced by a simple average of the last ten-year sales which does not identify a trend and does not produce the same results. Using a 10-year rolling (or moving) average calculation shows a long-term trend of falling sales. On the other hand, the simple average of the last 10 years sales of 313,210 shows the same annual sales for each year to the end of the plan period which, by the year

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2033, will then be based on the same static data that is 15 to 25 years old. For the reason above in the ‘factors of change’ there must be a more enlightened approach if the plan is to be seen as legally compliant, justified and sound.

Based on a clear trend of falling sales from at least 2000, in this scenario the simple average overestimates the need for soft sand in the Plan period by a considerable margin. The Engagement Outcome Report for Background Paper 2 in the WSLMP 2014 addresses this point as follows:

The South East England Aggregate Working Party (SEEAWP) has considered Local Aggregate Assessments produced by 20 Mineral Planning Authorities in the South East of England, including West Sussex County Council. Without exception, all of these Authorities have considered the meaning of the term ‘rolling average of 10 years sales data’ contained within NPPF para 145, concluding that it refers to the simple average of the sales that occurred during the most recent 10- year period. This conclusion has been supported by SEEAWP.

The Soft Sand Review at paragraph 2.3, also defends its methods of forecasting through having “AWP (Aggregates Working Party) ratification” and “no soundness or legal compliance issues raised through the examination of the JMLP with regards to the forecast for aggregates”.

The issue here is that it is not acceptable, without clear and valid reasons, to claim there was general agreement to replace the 10-year rolling average with a simple 10-year average when the NPPF, up to its latest revision, states otherwise. This is especially the case when, in the graph below, the yellow line showing the simple average indicates four times as much sand is required in the Plan period than either the red or blue rolling average forecasts.

Therefore, it needs to be explained why in the context of the SSR the AWP thought it appropriate for LAAs to discard the NPPF basis for forecasting, which demonstrates falling sand sales, in favour of an incorrect statistical method using the same static annual sales for the next 15 years which clearly overestimates the requirements for soft sand.

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Protection of the National Park. Within the Duty to Cooperate Statement and the AWP it is not clear whether any environmental criteria have been applied to take account of the implications of requiring mineral supplies within areas of nationally important landscapes.

Leaving this aside it is important to consider the impact of mineral planning policy in the past and how this has impacted on the use of land and particularly mineral working. The picture that is painted is that there is a succession of mineral sites where once one site is worked it is restored and working commences onto another site. This ensures that in overall terms the amount of despoilt land is of a limited footprint, recognising that mineral development should be of temporary duration.

Appendix B of the WSCC/SDNPA 2018 Monitoring Plan lists the operating sandpits, to which Minsted needs to be added as it still has reserves, according to the recent permission granted by the SDNPA.

In the list of sandpits below the current situation at all the sites is highlighted including reference in

Minsted Residents Group in association with Stedham with Iping Parish Council Page 9 of 19 some cases to lapsed consents that would allow further working. A small piece of research based on experience at Minsted lists below a number of mineral sites in the SDNPA/WSCC area, some active and others that are currently inactive:-

1. Chantry Lane Quarry, Sullington, Dudman Aggregates Ltd. Inactive -no restoration – still operating under planning permission SG/7/93 and continuing to extract, albeit slowly. Restoration has not begun. 2. Hampers Lane Sandpit, Washington Quarry, Sullington Britannia Crest Recycling Ltd. Permission lapsed (ref: WSCC/104/13/SR) but could be reopened with suitable consent. Site operating under planning permission WSCC/009/18/SR allowing extraction to 31 December 2019, and infill/restoration to 1 May 2020. Restoration 70% complete. 3. Rock Common Sandpit, Washington, Pulborough. Dudman Aggregates Ltd. active. No restoration. 4. Sandgate Park Quarry, Water Lane, Sullington, Storrington CEMEX UK Operations active with restoration to landscaped lake for fishing and nature conservation anticipated in 2042. No restoration to date. 5. West Heath Quarry, West Harting, Petersfield CEMEX UK Operations Extension expires – 2025. Older part of the site expires in 2042-no restoration. – still operating under planning permissions SDNP/16/00525/CONDC and SDNP/16/00492/ROMP. Restoration has begun with approximately 30% of the site restored. 6. Heath End Quarry, Duncton, Petworth Dudman Aggregates Ltd. Permission granted on appeal in September 2016 with restoration in 2021- operating under planning permission APP/Y9507/C/15/3133267. Restoration has begun with approximately 40% of the site restored. 7. Minsted Sandpit, Minsted Common, Midhurst Dudman Aggregates Ltd. ROMP permission 2019 and restoration details awaited. 15% restoration only with extensive overworking to be addressed. 8. Pendean Quarry, Oaklands Lane, Pendean, Midhurst. Inert Recycling UK Ltd. Site is operating under planning permissions WSCC/029/10/WL, SDNP/16/00631/CW; SDNP/16/01136/NMA and SDNP/17/01816/FUL. Whole site now falls under the importation of inert material for restoration. Approximately 30% of the site is completed. 9. Coates Sandpit near Petworth dormant with some remaining reserves. Site is currently dormant and limited restoration has taken place. The situation is little better at the only operating site within East Sussex, also within the National Park: 10. Novington, Near Plumpton East Sussex. Dudman Aggregates Ltd. Site inactive. – site is operating under planning permissions LW/386/CM and SDNP/13/01933/ROMP. Approximately 30% of the site has been restored.

The list above indicates a disturbing absence of progressive restoration and a lengthy period of time when the sites could be left unrestored if the Soft Sand Study does not adopt a proactive approach to their restoration and resists the release of new soft sand reserves at new sites.

This is a clear consequence of the market led approach which to cause the allocation of too many sites leaving developers to move on to the next site without restoring an existing site.

The legacy of unrestored sandpits within the National Park at Minsted (West Sussex) and Novington (East Sussex) and elsewhere, where only small quantities (if any) reserves are deemed to remain must be addressed. By identifying new sites, the WSCC/SDNPA are simply exacerbating this

Minsted Residents Group in association with Stedham with Iping Parish Council Page 10 of 19 situation and prolonging the timescale when restoration will eventually take place, creating unnecessarily eyesores within the nationally protected landscape. The plan must develop conditions where existing sites are fully worked and restored at the earliest opportunity in accordance with Policy M24 of the adopted joint Mineral Local Plan, and para 204 (h) of the NPPF. Compliance with national and local policy will avoid unnecessarily safeguarding mineral sites for long period of time and the sterilisation of land.

Conclusion In terms of the calculation of need the detailed points above have set out a number of issues which need to be considered and reflected in the assessment of the rolling forecasts, actual need, the revised calculation of sales, the true availability of soft sand from different sources and alternatives, and the actual extent of the current landbank within the plan period. It is only then that this Single- Issue Review of Soft Sand can be made legally compliant and sound. We believe that this will have significant change on the overall need for soft sand within the plan area.

SECTION 2

Supply strategy issues Having regard to the conclusions in Section 1 above it is considered that a revision to the forecast in para 2.5 of the SSR and the figure included within modified Policy SSR3 is necessary. Therefore, an increase in the landbank beyond the current 9.3 years would be expected, which would allow the selection of options to be revisited. It is submitted that in consequence the preferred strategy will not require sites within the National Park to be identified, protecting the nationally important landscape.

This would also be consistent with the SDNP decision as MPA to rule out hydraulic fracturing operations within the SDNP for shale gas and oil. The MPA have recognised the harm that such development would cause. We would expect the same approach from more damaging mineral developments where there is a greater nuisance and damage with considerable above-ground impacts from any sand extraction, and which are significantly more detrimental to the landscape, local communities and amenities people cherish in the National Park. Sand extraction involves the use of more diesel, dust pollution, and noise from onsite earthmoving, processing machinery and lorry traffic. Fracking activity is below ground, with relatively small discrete sites for boreholes and wellheads that are more easily screened. Fracking, unlike sand extraction, does not involve the removal and transportation from much larger sites of millions of tonnes of overburden and sand which create deep water-filled pits in the ground. High value gas and oil products from fracking are produced in much smaller volumes than bulky lower value sand products, and therefore require fewer HGV movements to and from sites. Fracking sites do not destroy landscapes permanently as no significant amount of material is removed from the landscape.

Option B conflicts with objective the of para 205 of the NPPF and the sustainable use of Minerals, as far as is practical MPAs should maintain landbanks outside National Parks and other valued landscapes and conservation areas. The above sections above reaffirm that there is not a proven need for soft sand sites within the National Park and that any need should be met from reserves outside the park, and indeed other counties, which is more sustainable, providing reserves nearer to the areas of demand.

Option C is considered to be a viable option given the recorded information on sand reserves throughout the South East region and the information in the Mineral Planning

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Authorities Soft Sand position paper 2019. This is reinforced by and information from Surrey County Council which show they have a current landbank of 14.4 years with potential for additional reserves from further extensions and new soft sand sites.

Option D involving the use of Marine won sand is a viable option especially given the wharf capacity and available reserves. The location of wharfs is well located to the urban coastal areas where the requirement for soft sand and related derived products is highest.

The preferred option can therefore be changed to consist of Option E comprising option A (within non SDNP part of WSCC), Option C (outside WSCC (taking account of the wider availability of soft sand within the region) and Option D (increasing marine won soft sand). This is consistent with paragraph 7.9 of the Draft Statement of Common Ground on Soft Sand Supply in the South East (Version 4.0 FINAL).

This approach represents a more enlightened, sustainable and proactive approach to meeting the soft sand needs of the plan area taking account of section 1 of this representation. If the approach remains unaltered this element of the plan cannot be considered sound as it is not positively prepared, justified, effective or consistent with national Policy.

SECTION 3

Potential site selection Having regard to sections 1 and 2 it is considered that much of the site selection work does not need to be considered, except in terms of sites situated outside the boundaries of the SDNP. Nevertheless, and without prejudice to the representations above it is considered that the Soft Sand Site Selection Report (4SR) with the use of the RAG scoring system is largely sound and robust. The MRG and Stedham and Iping Parish Council do not have the resources to examine the entire assessment of sites but have considered the assessment of the Minsted West site with which the local community is familiar and greatly value because of its tranquillity of this area of open landscape with views towards the South Downs and all the local wildlife.

In terms of the assessment of the Minsted site, the previous observations have been updated and need to be taken into account in the assessment of the site to ensure its soundness.

Cumulative impact: We note the element of the assessment that considers the cumulative impact of proposals. The NPPF states that policies and proposals should take account of existing activity and impacts, the duration and nature of proposals for new or further workings, and the extent of impacts that a particular site, locality, community, environment or wider areas of mineral working can reasonably be expected to tolerate over a particular or proposed period. In this context it is anticipated that considerable weight will be placed on the existing situation with the Minsted sandpit and the inability of the SDNPA to secure its restoration in a timely manner, the dereliction and confirmed harm that this has caused to the amenity of the area. This, together with the SDNPA’s failure to address the extensive breaches of planning control at the existing Minsted sandpit, confirms that this is a site with multiple and cumulative impacts giving rise to considerable harm to an area that has already under stress. The RAG assessment should be ‘red’.

Site availability: We note that additional information about all sites is required to determine whether a site can be delivered during the plan period and that sites which cannot be so

Minsted Residents Group in association with Stedham with Iping Parish Council Page 12 of 19 demonstrated will be excluded. Having regard to the 16 years of delay in the existing Minsted sites restoration, and the 7 years to submit a ROMP application, we consider that this is more than enough evidence to indicate that the present site is unlikely to be restored by 2033. As matters stand, no restoration scheme has been submitted and is still awaited after almost 22 years. Therefore, on the basis of this situation and the failure to comply with Policy SSR 19, there is no prospect of a change in this position and accordingly the site should be excluded from further consideration.

Landscape and visual impact: The site is visible from many local viewpoints and distant elevated locations to the south from The Downs, including The South Downs Way. The site is unsuitable for mineral development because of the open nature of the weald which would have a detrimental impact on the special qualities and character of this part of the SDNP, inconsistent with National Parks’ purposes and duty. The importance of local well used public rights of way and views across it are recognised in the recent Stedham with Iping Neighbourhood Development Plan for the period 2018 – 2033. The tranquillity of the area is also a particular quality of the location. Again, the impact is substantial and should be scored as ‘red’ on the RAG.

 Nature Conservation. The site is in close proximity to important nature conservation areas with rare habitats, including Iping and Stedham Common Local Nature Reserve and SSSI, Henfield Wood Site of Nature Conservation Importance (SNCI), Stedham Common (east of Minsted Road) SNCI, and the Severals Rare Mires. The high biodiversity of the area is recognised being home to much valued and often rare species of animals, plants, birds, bats, reptiles, amphibians and insects as recorded in the Sussex Biodiversity Record Centre, all of which require protection. A detailed report attached to the previous consultation as (Appendix 1) which is centred on the Footpath and Bridleway 907 that divides Minsted Sandpit from Minsted West. As part of the ongoing ROMP determination, a Mitigation and Enhancement Strategy for Minsted Quarry, dated 17 December 2018, by The Ecology Co-op – Environmental Consultants was submitted on behalf of the operator. This refers to the restoration plan, which includes restoring wildlife habitats which would extend the conservation value up to the proposed Minsted west site boundary. The Mitigation and Enhancement Strategy for Minsted indicates that the use of the processing area (taken from page 19) of the strategy is unavailable as “It is understood that the most important area for invertebrate assemblages (the land to the immediate north of the existing quarry) will be retained, however with this being located within Area 8 (the working yard), it is possible that some important areas (sandy spoil heaps) will be moved and damaged. To ensure that suitable nesting habitat is always available for the species recorded, it is recommended that at least two sandy spoil heaps remain undisturbed each year and exclusion zones are created around them. The continued use of the site will need to maintain suitable nesting sites and avoid the trampling of the ground by machinery through the creation of sandy spoil heaps during works. These habitats will remain and continue to provide suitable nesting habitats when decommissioned. The RAG scoring of ‘Red’ is deemed to be entirely correct.

Soil quality: The development of Minsted West for mineral working would result in the loss of 10Ha (24.7 Acres) of productive agricultural land currently in full use. Farming is essential to maintaining the landscape as well as supporting a sustainable food supply chain and local employment. Government Policy is to protect the best and most versatile agricultural land and soils in England from significant, inappropriate or unsustainable development proposals (Natural England guide to assessing development proposals on agricultural land January 2019), taking account of the

Minsted Residents Group in association with Stedham with Iping Parish Council Page 13 of 19 economic and other benefits of the best and most versatile agricultural land. To maintain this land it is deemed that land in Grades 1, 2 and 3a of the Agricultural Land Classification should be retained for agricultural use. According to the Minsted West, Severals 2014 Minerals Sites Study for SDNPA, site criteria show soil quality classed as Grade 1 for Minsted West. Grade 1 is excellent quality agricultural land and cannot be dismissed as being of little value when it is in full and productive agricultural use as an integral part of a large dairy farm. Its use for minerals development would conflict with Policy M15 of the WSCC: Minerals Local Plan where proposals for mineral development will be permitted provided only where ‘there are no unacceptable impacts on the intrinsic quality of, and where appropriate, the quality of, air and soil’. The loss of 10ha of valuable natural capital in this way is unacceptable.

Availability of office and processing facilities: The site office, plant and equipment at the adjacent Minsted Sandpit site is mobile in nature. The concrete batching plant has some fixtures to the ground, but these can be easily moved. In any case the use of the batching plant is no longer permitted as imported material is prohibited at the site. The use of the existing site processing area is impractical and unacceptable following the completion of working at Minsted Sandpit because of the ecological impacts referred to under nature conservation above. Therefore, the suggested advantages of a continuing mineral site will be lost.

Hydrology and Hydrogeology: Mineral development will require deep excavation, the movement of substantial quantities of overburden that will cause additional noise and disturbance. Additionally, there will be an impact on surrounding groundwater levels, including the wet heath areas of Stedham Common within Iping Common SSSI as well as the mechanical connection to ‘local running water’ events within the sands that has the potential to affect land away from the site. The location of a nearby group of houses is not called “Quags Corner” without good reason because they are low lying, on boggy ground and at risk of any local flooding. In connection with the ROMP the applicant was unable to produce a satisfactory and complete hydrological study, so that the impacts on the local area from existing mineral working in the short and long term are still unclear. There is potential that the working of the site with the fall in levels towards the River Rother and on to the Arun valley will lead to run off from the site. The existing water environment of Minsted sandpit is tainted by silt because of the absence of care in the working of the site and a failure to use the desilting lagoons. The escape of water from any new workings towards the river Arun could be expected to have a significant effect on water quality, harmful to its biodiversity.

Woodland: There are wooded areas adjacent to the site including Fitzhall Rough and Starveacre Copse, as well as individual trees that are likely to be harmed by changes to the local hydrology.

Dark Skies. Minsted is within a tranquil countryside location being a noted area of dark skies which would be adversely affected by further mineral development and overnight security lighting.

Public Rights of Way. The site is readily visible from multiple public rights of way. The loss of the already diverted Bridleway 907, which has been indicated as necessary by the mineral operator, is

Minsted Residents Group in association with Stedham with Iping Parish Council Page 14 of 19 unacceptable and would not meet the requirements for diversion because of the timeframe and the very long diversion necessary utilising bridleway 3358 and footpath 903 that would affect its recreational enjoyment, convenience, use and value. At the present time it forms part of an attractive circular walk much used by leisure walkers, ramblers, dog walkers, as well as horse riders.

Residential Amenity and Harm: Renewed mineral development would perpetuate the significant harm Minsted has endured, from the mid-eighties onwards until working was suspended by the SDNPA in 2013. During this time the working and processing of sand was very audible, impacting on the amenity of the many visitors to Stedham and Iping’s Local Nature Reserve, the unique countryside and the community. Apart from road noise the Sandpit’s excavators, dumper trucks, dredger and its processing and concrete batching plant created a major neighbourhood nuisance, more so in view of its close proximity to the adjoining SSSI. On taking over operations around 2005 the present operator changed from relatively quiet, environmentally friendly electric power to diesel powered equipment. Eight new homes converted during the last 10 years from farm buildings either side of Minsted Road are within 180-200 metres of the SE boundary of the proposed Minsted West site. There would be a highly detrimental effect on these homes through noise, dust and restriction/loss of outlook across the current tranquil landscape of fields and woodland, including views to the Downs. Residents would also be subject to the hazards of additional HGV traffic at the upper end of Minsted Road, which is single track. In addition, there are another 12 dwellings in Minsted at a similar distance from the site and to properties at Quags Corner, and in the Severals towards Bepton less than 1 mile away All these properties lie downwind of Minsted West in the prevailing SW wind. Mineral development would bring significant environmental harm to the amenity of all these homes. This detriment is in addition to the loss of open outlook and the existing very tranquil setting valued by residents and members of the public alike using Minsted Road for recreational access within the National Park. The RAG score should be ‘red’.

Traffic and Pollution. Properties in or close to Minsted Road, Andrew’s Lane and Quag’s Corner, especially those that are immediately adjacent to the proposed boundary of working, would bear the brunt of the movements of HGV quarry traffic. We also know from when the Sandpit was working that Minsted lorries often travel through Midhurst, which caused many complaints from the town’s residents for noise, pollution, the shaking of buildings and repeated damage to roads.

Air Quality: Recent evidence of traffic pollution measurements for Midhurst shows that it is already suffering from excessive HGV movements because of the infilling work on the West Lavington sandpit. Midhurst already breaches EU Air Quality Standards and Chichester District Council is understood to be working towards declaring Midhurst an Air Quality Management Area. Any new increase in HGV traffic from a new quarry would cause air quality limits to breach acceptable limits and would be refused on that basis. The RAG assessment score should appropriately be ‘red’.

Site Pollution: As in the adjacent Minsted Sandpit, airborne pollution including diesel fumes from fixed and mobile plant permeating the footpaths with dust blown around the vicinity will strongly feature. There are also indications that the groundwater has been contaminated with no fish having survived in the Minsted Sandpit lake, which still has an alarming bright yellow colour after standing undisturbed for 7 years during the site’s suspension. It would be unacceptable for this water to be allowed to pollute Minsted West as well.

Minsted Residents Group in association with Stedham with Iping Parish Council Page 15 of 19

Historic environment: Adjacent to the proposed site is the one remaining Bronze Age barrow sitting atop the western cliff of Minsted Sandpit. This is part of a set of 4 barrows that extend into Fitzhall. Four other barrows have already been consumed by Minsted Sandpit excavations.

There are older and newer properties in Minsted itself most of which exhibit inherent heritage attributes through conversion from older properties. There are listed buildings in and around Minsted Road and, in addition cottages, in Andrews Lane have designated heritage value in the Stedham with Iping Neighbourhood Plan. The mineral development will impact on the setting of these heritage assets through changes to their outlook and setting. Furthermore, there is high likelihood of changes to the water table and hydrological effects, drying out foundations giving rise to structural damage, and potentially flooding the area if the resulting lake, elevated above the level of Minsted Road, is ever breached. Mineral development is therefore considered to be potentially harmful to these heritage assets. In consequence, the site scoping assessment referred to in paragraph 2.36 of the SSR should in terms of the effects on cultural heritage be recognised and changed from ‘Depends on scheme details’ to ‘Yes’.

Vehicular Access. The only vehicular access to the site is via the narrow, essentially single track lane. Minsted Road is unsuitable for HGV mineral traffic because of the conflict with walkers, cyclists and equestrian users and existing agricultural and local residential traffic. Its width varies from just 3.00m at the narrower points to an average 3.60m, and at its very widest (extended somewhat by lorry traffic) of 4.15m. The operator’s Volvo FMX460 trucks have a cab width of 3.09m (including mirrors) and therefore take up most or all of the road. Minsted Road includes the steep brow of a hill about 100M from the A272 which hides any advance view of oncoming traffic. The only passing places consist of the verges by two entrances to Stedham Common, which are frequently obstructed by vehicles of visitors to the common walking their dogs. In any case, all the ad-hoc passing places and verge-parking areas along Minsted Road to the sandpit are illegal as they have been created by destroying registered common land on both sides of the road. Minsted Road contains no pavement, no speed limit sign, no warning sign for the reduced hill-brow visibility, and no signs for any of the five side turnings into housing areas; and yet this inadequate road serves twenty dwellings, all of which will be affected by the sandpit’s noise and traffic, as well as the very active dairy farm. Furthermore, any further urbanisation of this road through signage is strongly opposed as it will be a permanent reminder of the continuing attempted destruction of this rural setting. In fact, a less suitable service road for heavy sandpit traffic is difficult to think of. Minsted Road is crossed by two Public Footpaths; a Bridleway; a designated cycleway to Midhurst; part of the Serpent Trail; and adjoins Stedham Common SNCI. It is entirely unsuitable for HGV traffic and conflicts with other users with constant risks to farm animals, wildlife as well as the farm’s own traffic. The RAG score should be ‘red’.

Minsted Residents Group in association with Stedham with Iping Parish Council Page 16 of 19

Extracts from: INSPECTOR’S REPORT, WEST SUSSEX MINERALS LOCAL PLAN PUBLIC LOCAL INQUIRY 1998 0403/050 ARC Southern and 0562/001 All Souls College, Oxford Site 25: MINSTED

Mineral working at Minsted has already been the subject of assessment by the Planning Inspectorate, as recently as 1998. It is considered that significant weight must be given to the independent assessment particularly as the decision taken by the Planning Inspector to exclude Minsted (now named Minsted East) following the June 1998 Public Inquiry which sets a clear precedent, not just for Minsted East but for all decisions in respect of the “Vista” which includes Minsted West whose boundaries are just a few hundred metres apart with similar characteristics to Minsted East. The Inspector’s reasoning is repeated because it is the only authoritative, legal and relevant decision that can be drawn on for comparison. The arguments then for Minsted East are the same today and are equally applicable to Minsted West that the site is inappropriate for mineral development, particularly with the subsequent designation of the National Park.

“…the Council considered that the impact of mineral working on the landscape, on residential amenities and the loss of agricultural land were fundamental reasons why the omission site should not be included as a proposal site under Policy 34. So far as the effect on the landscape is concerned, the site is within the Sussex Downs AONB and is generally flat, with a gentle slope in the eastern part down to the Woolmer Brook. Beyond the northern boundary lies the small enclave of residential development which comprises Quags Comer. Open farmland extends beyond the southern boundary which contains the small hamlet of Minsted. The area is well endowed with woodland, either as coniferous plantations, small copses or strongly defined hedgerows. A mineral operation on the site as described in the objection would result in a lake with clearly defined cliffs or lake margins. A dredger would float on the lake surface. Landscaped earth bunds would almost certainly be built around the site to screen local views into the sand pit and to act as noise attenuation barriers. The objection stated that views of the site would be contained, but I do not agree. Not only would the site be seen from the footpath alongside the southern boundary, the Minsted Road and residential properties -at Quags Comer and Minsted, it would also be seen from the South Downs Way about 4km distant and footpaths or bridleways which lead to and from the South Downs ridge. The view from the Downs is part of a vista which, as one would expect, includes a wide variety of landforms, land cover and land uses. Nevertheless, I consider that mineral working on the omission site would be prominent when seen from the Downs and would have a significantly adverse impact in the AONB. In addition, the local landscape would be harmed by the introduction of artificial screen mounding around the site in an area where the currently active operation cannot be seen. The impact on residential amenities would be felt mostly of all by those who live in the several houses at Quags Comer and Nos 6 & 7 Slygates. Two aspects would be most noticeable, the effect on the outlook and noise. Mineral working on the site would be directly overlooked from the houses on the northern boundary. The impact would be even more noticeable as the properties have a southerly outlook onto the site. Without any form of bunding, the view would be directly into the operation. However, the construction of artificial earth mounds, sufficiently effective to act as a screen, would create just as much as an intrusion as the operation. As explained in para 64 of PPG l, it is not the purpose of the planning system to protect the private interests of one person against the activities of another. Nevertheless, where several properties would be affected to the degree which I can foresee, I consider that the outlook would be severely harmed. _Tree and shrub planting might offer a very Jong term solution, but one which would take years beyond the period

Minsted Residents Group in association with Stedham with Iping Parish Council Page 17 of 19 of the Plan to be as effective as they need to be. Therefore, I do not see short term planting as a means of overcoming the harm to the appearance of the area as seen from Quags Comer. The noise from the operation would not be as great as one where there would be processing. Nevertheless, the initial ground clearance would be extremely disturbing and the subsequent pumping would be continuous. The operation may well be able to work within the noise levels advised in MPGll. However, the site is so remote and the background noise likely to be so low, that any additional noise of machinery, especially running on a day in day out basis, would be troublesome. Therefore, in my opinion, the intrusion which would be caused by a mineral operation on the omission site would be sufficient to cause significant harm to the residential amenities of those who live nearby. The objection states that the noise issue could be dealt with satisfactorily at the planning application stage, but in the face of a lack of evidence to support that view, I am not convinced. There is frequently an advantage in developing an extension to an existing operation, rather than opening up a new site. However, in this case, despite the close proximity of the Minsted sandpit, the character and appearance of the site and immediate surroundings is of a tranquil, relatively remote rural area and so the impact of operations at the site would have all the intrusive effects of a green field site being developed. Nearly two thirds of the site is underlain by best and most versatile agricultural land. Restoration of the site to its former state as agricultural land would be unlikely given the depth of the deposit. The Council and objector differed on the amount of reserves which remain to be worked in the existing pit at Minsted The Council commented that, if the site were to be worked, a nature conservation restoration scheme could have some attributes. However, because of the harm that would be caused to the landscape and the character and appearance of the countryside by working the omission site and the effect on residential amenities of the people who live at Quags Comer and also at Slygates, I do not support. the objection and shall not recommend the site for inclusion in Policy 34 of the Plan”.

Conclusion: The above reaffirms the unsuitability of Minsted West for any further sand working, which would conflict with National and Local planning policies. It is considered that the SSR site assessment is only considered to be sound if it takes full account of this information. In doing so and applying sound planning judgements it is considered that Minsted West is unsuitable, in principle, for mineral development and should be excluded from any consideration of mineral working for the foreseeable future in the SSR.

SECTION 4

The Sustainability Appraisal

The Sustainability Appraisal, including Strategic Environmental Assessment at para 5.23 did not take into account the potential for marine won soft sands and wrongly concludes that the one policy option would have significant negative effects for SA objectives 10 (air quality) and 13 (transport), due to the increased dependence on imports to meet requirements which cannot be met from indigenous supplies, which is likely to result in increases in lorry traffic transporting soft sand into West Sussex by road. On the contrary, the option of marine won reserves would reduce traffic and air quality impacts through the delivery of soft sand closer to the coastal population centres, avoiding trips through the National Park and disturbance through mineral working in areas of high landscape importance.

Minsted Residents Group in association with Stedham with Iping Parish Council Page 18 of 19

The SA recognised the importance of a hierarchical approach to soft sand provision, by clearly prioritising supply from existing permitted reserves first and not allocating extensions or additional sites in the SDNP. In this context if there is a need for soft sand within the plan area, additional allocations/areas of search should be beyond the SDNP. The SA has not had full regard to the amenity and harm from the development of the Minsted West site and needs to take account of all the points in section 3 to ensure the accuracy and justification of the appraisal and its conclusions.

END

Minsted Residents Group in association with Stedham with Iping Parish Council Page 19 of 19

From:

Subject: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19) Date: 03 March 2020 10:31:09 Attachments: image003.png

Good Morning,

The Reg 19 publication of the Soft Sand Review of the West Sussex Joint Minerals Local Plan has been considered at previous planning meetings of Horley Town Council and most recently at the meeting on 14 January 2020 when it was noted and resolved that no action was required. I am therefore writing to let you know that Horley Town Council is grateful for the opportunity to make representations but on this occasion has no comment.

Kind Regards Judy Morgan RFO and Planning Officer - Please note I do not work Fridays

Horley Town Council, 92 Albert Road, Horley, Surrey RH6 7HZ Tel: 01293 784765 www.horleysurrey-tc.gov.uk; http://twitter.com/horleyTC For regular updates and information, please sign up to the newsletter on our homepage This e-mail and any files transmitted with it may be confidential and are intended for the sole use of the intended recipient(s). If you are not the intended recipient, any use of, reliance upon, disclosure of or copying of this e-mail is unauthorised. If received in error, please notify us and delete all copies. You should note that we cannot guarantee that this message or any attachment is virus free or has not been intercepted and amended. Please note that the Council does not accept responsibility for viruses. You are advised, before opening or using attachments, to check them for viruses. The views of the author of this e-mail may not necessarily reflect those of the Town Council. Please think of the environment before printing this e-mail.

From: Local Plan To: PL MWDF Subject: Arun SSR representation Date: 03 March 2020 14:03:16 Attachments: image003.png

Hello

Please take this as being the officer level response to the consultation on the Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19).

It is acknowledged that there are no allocations made within Arun District Council. However, it is also noted that there is potential from sites on the wider road network. As some of the sites are in the vicinity of the authority boundary, we wish to ensure that this is addressed at the application stage. On this basis please keep us informed as the document progresses.

Kind Regards

The Planning Policy Team

Charlotte Hardy | Senior Environmental Assessment Officer, Planning, Arun District Council | Location: First Floor, Arun Civic Centre, Maltravers Road, Littlehampton, BN17 5LF Internal: 37794| External: +44 (0) 1903 737794| E-mail: [email protected]

Visit Arun's web site at www.arun.gov.uk P Save the environment - think before you print.

http://www.arun.gov.uk DX 57406 Littlehampton You can view Arun District Council’s Privacy Policy from https://www.arun.gov.uk/privacy-policy

Important Notice This e-mail is intended exclusively for the addressee and may contain information that is confidential and/or privileged. If you are not the intended recipient (or authorised to receive it for the addressee), please notify the sender and delete the e-mail immediately; using, copying, or disclosing it to anyone else, is strictly prohibited and may be unlawful. Any views, opinions or options presented are solely those of the author and do not necessarily represent those of Arun District Council. The information in this e-mail may be subject to public disclosure under the Freedom of Information Act 2000, therefore we cannot guarantee that we will not provide the whole or part of this e-mail to a third party. The Council reserves the right to monitor e- mails in accordance with relevant legislation. Whilst outgoing e-mails are checked for viruses, we cannot guarantee this e-mail is virus-free or has not been intercepted or changed and we do not accept liability for any damage caused. Any reference to "e- mail" in this disclaimer includes any attachments. ********************************************************************** Dear Mr Elkington and Mr Slaney,

Soft Sand Review of the West Sussex Joint Minerals Local Plan – Regulation 19 Consultation

Thank you for consulting East Sussex County Council (ESCC) and Brighton & Hove City Council (B&HCC) on the Soft Sand Review of the West Sussex Joint Minerals Local Plan. This response represents Officer views on behalf of ESCC and B&HCC as minerals planning authorities.

ESCC and BHCC work jointly with the South Downs National Park Authority (SDNPA) on waste and minerals planning policy documents. Our adopted joint plans are the Waste and Minerals Plan 2013 and the Waste and Minerals Sites Plan 2017, which together make up the East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan (WMLP).

As you will be aware, we are currently carrying out a Review of the WMLP. The context for our WMLP Review and details of the soft sand situation in this Plan Area are set out in our letter (dated 13 March 2019) sent to you in response to the Issues and Options stage of your Soft Sand Review. Since that time our Authorities have worked with the other South East Mineral Planning Authorities to agree a Position Statement on Soft Sand. This sets out the context for soft sand provision at a regional level.

In addition, following on from the regional position statement, in 2019 our Authorities all signed a Statement of Common Ground (SOCG) with Kent County Council regarding soft sand. This SOCG summarises the position of each planning Authority with regard to soft sand and acknowledges the current reliance on imported materials (including from Kent and West Sussex) to meet the needs of the East Sussex, South Downs and Brighton & Hove Plan Area.

Our WMLP Regulation 18 document is currently going through the Member approval stage and hopefully will be published for consultation in April 2020. In preparing the Review, the Authorities have undertaken surveys to understand where the soft sand material is imported from and how the need for soft sand is currently being met. Evidence gathered suggests that a proportion of soft sand produced or received in West Sussex is imported to serve the East Sussex/Brighton & Hove market.

Our comments on the Soft Sand Review are therefore made in the context of how future provision of soft sand in West Sussex/SDNP impacts on import requirements which assist the constructional needs of the East Sussex/Brighton & Hove Plan area. From a mineral planning perspective we would therefore aim to secure an adequate and steady continued supply from import sources as far as we are able. It should be noted that whilst East Sussex may rely on imports of aggregates, it does contribute considerably to exports of gypsum and clay products to a much wider market. Hence the cross-border imports/exports of minerals that are found in other areas should be recognised and acknowledged in other mineral planning authorities Plans.

Having examined the Soft Sand Review documents, it is noted that three allocations are identified for soft sand extraction: one new site outside of the National Park and two extension sites within the National Park. These allocations together equal 2.72 million tonnes (mt) of soft sand provision. Three demand forecast scenarios are put forward which take account of assumptions in varying extents relating to residential growth rates and percentage of aggregates used in residential dwellings. The shortfall of sand required to meet these scenarios ranges from 1.65 – 2.83 mt. I understand from recent email clarification that the Review does not aim to meet a specific demand scenario, but if the highest scenario is realised, the shortfall would only be 110,000 tonnes (about a third of a years supply), and therefore if the demand is lower there should be sufficient sand available to meet requirements.

Data used to calculate the demand scenarios accounts for sales from existing sites regardless of final consumption (i.e. this would include East Sussex and/or Brighton & Hove), and other data also considers demand for housing in neighbouring areas including East Sussex and/or Brighton & Hove. It would appear therefore that scenarios used to plan provision have incorporated growth assumptions for constructional materials in East Sussex and Brighton & Hove. Provided that this continues to be the case and that the proposed allocations remain in the Soft Sand Review, we are satisfied that the Review has considered the implications of provision to our Plan Area. On this basis we have no objections to the Regulation 19 draft Soft Sand Review. Yours sincerely,

Liz Hobden

Edward Sheath Liz Hobden

Thakeham Parish Council Clerk to the Council: Mr Owen Richards

Thakeham Parish Office Thakeham Village Hall 1 Abingworth Crescent, Thakeham, Pulborough West Sussex RH20 3GW

Phone 01798 815305 E-mail: [email protected] Website: www.thakehamparish.co.uk Planning Services (Ref: Soft Sand Review) West Sussex County Council County Hall Chichester PO19 1RH

5 March 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

With apologies for this submission being made after the 2 March deadline, Thakeham Parish Council wishes to register that its members do not believe the review has properly addressed the many previous issues raised and therefore fully supports the objections raised by neighbouring Storrington & Sullington Parish Council in STRONGLY OBJECTING to the above site being included on the following grounds:-

1. The new traffic junction arrangements near the existing Water Lane/A283 junction, which would be required by this proposal are likely to create further congestion on the A283, which will incentivise cars, commercial vehicles and HGCs to detour north through Thakeham on the B2139 and Rock Road, creating unacceptable additional traffic impact throughout Thakeham; 2. The same traffic junction arrangements are likely to create a new zone of air pollution, which has the potential to spread impact eastwards and northwards, affecting southern Thakeham residents. 3. The proposed development has the potential for severe negative impact on existing wildlife, particularly if access road has to be dug down to the level of the bottom of the sand pit. 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 appears not to have been assessed. An ecological report survey must be undertaken to establish whether there are any protected species in this area. 4. The extraction site itself, and the related highways works, would together have an unacceptable landscape impact, including severe negative impact on views to and from the South Downs.

Yours sincerely

Caroline Instance Roger Taylor Chair of Thakeham Parish Council Chair, Thakeham PC Neighbourhood Planning Committee

Official use only PROPOSED SUBMISSION DRAFT SOFT SAND REVIEW Respondent No: OF THE WEST SUSSEX JOINT MINERALS LOCAL PLAN - REPRESENTATION FORM

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This form comprises of 3 main parts:

PART A: PERSONAL INFORMATION A1. Personal Details

Title MrsFirst Name Helen Last Name Hudson

Job Title (where relevant) Planning Consultant

Organisation or affiliation (where relevant) Hudson Planning Limited

A2. Client Details (if applicable) If you are completing this form on behalf of someone else then please provide details of the person(s) or organisation you represent.

Title First Name Last Name

Job Title (where relevant)

Organisation or affiliation (where relevant) CEMEX UK Operations Limited

A3. Contact Address Details Please provide details of the person who should be contacted regarding this representation.

Name Helen Hudson

Address 188 High Street, Egham, Surrey, TW20 9ED

Telephone Mobile: 07702314652 Telephone 01932 583639

Email [email protected]

Preferred Method of Contact Post Email

Please tick all categories below that most adequately describe you.

SSR Reference No See separate sheet for SSR comments

CEMEX support and welcome the inclusion of Land East of West Heath Common - as an extension soft sand site to West Heath Quarry.

CEMEX consider that the overall strategy promoted by the MPA in the soft sand review fails to make proper provision for soft sand within the Plan area for the period of the plan. CEMEX consider that this approach is not consistent with national policy. The plan is reliant on unknown resources from beyond the plan area which the MPA cannot control. CEMEX consider that further consideration should be given to finding sites within the Plan area - perhaps working additional resource within the SDNPA if the tests of very special circumstance can be met and restoration to secure wider NP objectives can be met. CEMEX consider the strategy proposed does not fully assess the impact of working and importing soft sand reserves from beyond the plan area. The environmental and social impact may be greater than acknowledged - particularly in terms of road movements. CEMEX consider that the environmental impacts of extracting soft sand from other sites in the south east may be as equally constrained and this has not been fully assessed through the Strategic Environmental Assessment of the Plans preferred strategy. West Sussex Soft Sand Review: Proposed Submission Draft

The Strategy should place less weight on finding soft sand reserves beyond the Plan area and greater effort in reassessing reserves and finding opportunities to work sites within the NP which may provide restoration opportunities through access and net biodiversity gain.

West Sussex Soft Sand Review: Proposed Submission Draft

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

No - I wish to communicate through written representations Yes - I wish to speak to the inspector at the hearing sessions. Please answer B7.

Please note: The inspector will determine the most appropriate procedure to hear those who have indicated that they wish to participate at the hearing part of the examination.

B7. If you wish to participate at the hearing part of the examination, please outline why you consider this to be necessary. CEMEX wish to ensure that Mineral Site - East of West Heath Common is retained as an extension site within the review plan - as there may be opposition to it. CEMEX also wish to comment on the strategy and CEMEX consider that the MPA is too reliant on reserves from beyond the plan area which it cannot control and has not fully assessed the impact of being worked and transported to the plan area. THIS PAGE HAS INTENTIONALLY BEEN LEFT BLANK. Single Issue Soft Sand Review (Regulation 19) – West Sussex and South downs National Park Authority (SDNPA)

CEMEX UK Operations Limited

2/03/2020

Thank you for consulting CEMEX UK Operations (CEMEX) on the proposed draft submission soft sand single issue review. CEMEX very much welcome the allocation of and inclusion of “East of West Heath Common” for inclusion under SSR1 Chapter 7.

I set out CEMEX’s comments below on the relevant SSRs – but have the general comments to make on the proposed strategy set out in Chapter 2 of the paper.

Proposed Strategy

The review should make clear the soft sand period being provided for. The existing plan was adopted in July 2018 and so it is assumed that the soft sand provision being made is for the 15-year period 2018-2033. This should be clear in the calculations.

CEMEX consider that the plan should make provision for the worst-case scenario and so support the implementation of demand forecast 3 – although it is unclear why this scenario doesn’t apply both assumption 1 and 2. This Scenario 3 forecast based on 15 years gives a requirement of 5,586,885. Taking into current reserves this means the plan needs to make provision, once current permitted reserves are taken into account of 2,841,887. This figure makes no allowance for a minimum landbank of 7 years at the end of the plan period which could see an additional requirement of some 2,607,213 tonnes. The plan has allocated three soft sand sites – totalling 2.675mt. This means even without meeting the provision of a minimum 7-year landbank at the end of the plan period, the site allocation falls short of plan provision.

As such CEMEX considers that whilst soft sand allocations in the SDNP area does not want to be opened up to an open season, the MPAs need to be positive and identify where sustainable sites could be allocated which would not present significant impacts on the National Park, but where there could be future opportunities too for future gain through restoration schemes. CEMEX consider that the sustainability assessment/strategy is skewed towards assessing adverse impacts in the national park and not placing sufficient weight on the adverse impacts of working soft sand elsewhere and the impacts that may have in terms of transportation - air quality, energy consumption, additional infrastructure and noise on communities which have to make provision for West Sussex’s shortfall.

1 CEMEX Soft Sand Review Reg 19 Whilst currently some minerals may be transported by road, this is not a sustainable practice for the future and should be avoided where materials can be supplied/sourced locally. CEMEX note that when discussing soft sand supply from outside of West Sussex reference is made to the Statement of Common Ground between Kent County Council, Brighton and Hove City Council and East Sussex County Council. Whilst the statement states that any surplus material – 1m tonnes maximum could travel the wider region. This statement is unrealistic. CEMEX has challenged this statement. CEMEX consider that it is not possible for MPAs to control, where mineral extracted in their county, will be sold to. Ultimately the markets will decide, but factors such as distance travelled will play a key part. Additional soft sand generated in Kent may well go into the London areas. On this basis CEMEX consider it unlikely that soft sands in Kent can be guaranteed to make up any shortfall in the West Sussex/SDNP market.

The additional provision Kent has made is Chapel Farm (West Site) which is in Lenham and CEMEX consider that it is not sustainable for MPAs to encourage long distance travel of aggregates/soft sands when local materials may be won which can be worked and where the overall impact on the environment as a whole is less. A Strategic Environmental Assessment of this approach to soft sand provision between these counties would identify this.

CEMEX consider that a strategy approach - of providing a shortfall from outside of West Sussex without full consultation and proper sustainability assessment will not work. Working soft sands in Kent to substitute soft sands in the South Downs National Park may not be the most sustainable option.

East of West Heath Common

CEMEX has promoted this extension site for inclusion as a soft sand site for a number of years. Whilst this site is within the SDNP area CEMEX believe that this site can be worked as an extension site to the existing West Heath Quarry with minimal adverse impact once mitigation measures are in place. The extension site can be worked as a temporary area using the existing quarry infrastructure and access. The inclusion of the extension site will allow CEMEX to develop a masterplan restoration scheme for the extension site and the whole quarry area – with the potential to provide significant biodiversity and access benefits to the local community. Any restoration scheme can be designed in conjunction with the SDNPA to ensure that it delivers wider aims of the authority.

(SSR1 – support)

CEMEX question the wording of SSR2 and would prefer to see the paragraph changed to read “The soft sand resource is constrained due to its location within or adjacent to the South Downs National Park. However, there may be very special circumstance where these constraints can be overcome”. This approach seems more consistent with wording elsewhere in the review.

(SSR2 – suggest rephrasing)

2 CEMEX Soft Sand Review Reg 19 SSR3 - CEMEX do not support the forecast of soft sand supplies. New paragraph number 6.2.14 SSR3 predicts that based on a 3-year average of soft sand sales that this is 295,115 (2015-2017) per annum. Existing permitted reserves of land won soft sand are 2,754,000 tonnes. Based on these figures the landbank is predicted as being 9.3 years.

Within NPPG (National planning practice guidance) para 64 when predicting future provision MPAs are asked to consider a variety of factors and this. A three-year average of sales is only one factor – WSCC/SDNPA should also consider “Local Aggregate Assessments must also consider other relevant local information in addition to the 10-year rolling supply, which seeks to look ahead at possible future demand, rather than rely solely on past sales. Such information may include, for example, levels of planned construction and housebuilding in their area and throughout the country.”

Indeed para 65 also asks MPAs to consider

x “the Annual Minerals Raised Inquiry Survey, which sets out sales of each type of mineral in Great Britain; x the 4-yearly Aggregate Minerals Surveys on the sales, movement, consumption and permitted reserves of aggregate minerals; x local data on the arisings of and recovery/disposal routes of Construction and Demolition waste, including inert waste used to restore mineral sites. This includes data available from the Environment Agency; x the Annual Report of the Aggregate Working Party, which sets out sales of aggregates, aggregate mineral reserves, local information on Construction and Demolition waste, secondary aggregates, and planning permissions; x any Annual Monitoring Reports prepared by mineral planning authorities setting out the effectiveness of mineral policy and providing information to be used in reviewing and preparing new policies; x published National and Sub National Guidelines on future aggregates provision; and x data and information on mineral resources held by the British Geological Survey and the Crown Estate.”

CEMEX would wish to see this paragraph reworded to reflect that annual provision is not only based on 10/3-year average sales – but a variety of factors and reflect all the parameters in NPPG para 65.

(SSR3- suggest rewording)

SSR4- CEMEX consider that the wording of paragraph 6.2.14 is not consistent with National Policy and SSR4 is not accepted and should be changed such that strategic objective 1 should read “To promote the prudent and efficient production and use of minerals to ensure a steady and adequate supply. This phrase is used elsewhere in the review and to be consistent this should be included.

(SSR4- suggest referencing – steady and adequate as per the NPPF)

SSR8 - CEMEX welcome the allocation of soft sand sites within West Sussex and the South Downs National Park but question the approach to relying on soft sand resources from elsewhere to make up reserves. CEMEX believe this is not necessarily sustainable and is not a holistic approach to assessing the environmental impacts on mineral working. The MPA appears to be relying in part on

3 CEMEX Soft Sand Review Reg 19 soft sand resources from beyond its boundaries which may not be proven to be sustainable when the environmental impacts on transporting these materials is assessed. West Sussex and the SDNP cannot manage soft sand markets and therefore cannot ensure sand from elsewhere makes up any shortfall in provision in the Plan area. A shortfall in provision may put pressure on other reserves in the south east which may also be constrained and have adverse environmental/social impacts if extracted which may be greater than working local soft sands within the National Park.

(SSR8 – the strategy is not fully justified, consistent with national policy or effective – CEMEX would welcome a more detailed strategic environmental assessment of the proposed strategy.)

SSR9 - CEMEX considers that this approach is not sound or positively planned. This soft sand review is to address supplies up until 2033. The wording of paragraph 6.2.20 suggests that the MPA is hoping that future, unknown innovations will mean that soft sand can be provided from beyond the SDNPA/WSCC area. This does not appear to give any certainty to supply or to plan positively. CEMEX would like to see this paragraph re-worded to something along the lines of “This strategy accords with national policy as it seeks to make provision for non-energy minerals from outside of protected areas in the first instance NPPF para 205a. In future provision of soft sand from inside the SDNPA area may be considered dependent on the scale and extent of the mineral development any proposals within these areas would only be considered in exceptional circumstances, and where it can be demonstrated that the development is in the public interest. Consideration of such applications should include an assessment of: a) the need for the development, including in terms of any national considerations, and the impact of permitting it or refusing it, upon the local economy; b) the cost of, and scope for, developing outside the designated area, or meeting the need for it in some other way; and c)any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.” (SSR9 – suggest rewording – see above)

SSR10 – CEMEX support the addition of this new paragraph.

SSR13 – CEMEX support the wording of Policy M2 – but the definition of “Lorry Route Network” is unclear and so reserve comment on this – as to how it may influence future sites.

SSR18 – CEMEX support and welcome the wording to this paragraph.

SSR36 – East of West Heath Common – West Heath Quarry Extension – New Paragraph number 7.2.8 – CEMEX note the wish that the development of this site should contribute to the Petersfield to Pulborough via Midhurst non-motorised route. This can be explored with the MPA as part of pre- application submission – but delivery or contribution to this may be dependent on a number of external factors beyond the control of CEMEX.

4 CEMEX Soft Sand Review Reg 19 CEMEX would like criterion vii amended to read “At pre-application stage, a lidar survey should be undertaken and a desk-based assessment of the impacts on buried archaeological remains should be carried out. A detailed written scheme of archaeological investigation will need to be approved and agreed setting out how archaeological features and remains will be assessed should the MPA be minded to grant planning permission for any extension” CEMEX request this change as they consider it is not necessary to undertake pre-determination archaeological field investigation for mineral working when the site is going to be entirely stripped to the top of the mineral and the archaeological layer/interest exposed for the site. Provided there is an agreed WSI in place – any archaeological finds can be assessed and mitigated against at this time. If necessary, left in-situ. This approach is at the operator’s risk in terms of cost and delay. Pre-application trail trenching will still often miss key archaeological features and not predict archaeological impacts. A detailed WSI when the site is being worked yields better archaeological results and mitigation measures built into the scheme can ensure significant adverse impacts on archaeological finds are avoided - including preservation in-situ if assessment if significance indicates this.

CEMEX supports the other criteria and assessment measures identified and seeks to work with WSCC and the SDNP to design a restoration scheme which meet the wider objectives of the NP.

(SSR36 – suggested rewording to archaeological criterion).

5 CEMEX Soft Sand Review Reg 19 From: To: PL MWDF Subject: RE: Soft Sand review consultation. Date: 05 March 2020 13:35:07

Thank you very much Alex for taking the trouble to point this out to me. I should have included it.

No, I do not wish to participate in the examination.

From: Alexander Dean [mailto:[email protected]] On Behalf Of PL MWDF Sent: 05 March 2020 11:59 To: Robin Harrild Subject: RE: Soft Sand review consultation.

Thank you for your email

In order for your email to be considered a formal representation, please could you provide the information requested in Question B7 of the representations form. This regards participation in the examination hearings:

“B7. If you wish to participate at the hearing part of the examination, please outline why you consider this to be necessary.”

This information can be provided by email reply. The representations form is also attached to this email for convenience.

When the Review is submitted for examination, all representations will be submitted for review by the Planning Inspector, and you would be provided with the following unique ID's relevant to your representation;

• Your representation number • Your unique ID

Kind regards

Alex

Sent: 28 February 2020 20:31 To: PL MWDF Subject: Soft Sand review consultation.

I have the following comments and issues with the Proposed Submission Draft Soft Sand Review of the West Sussex Joint Mineral Local Plan. The issues relate primarily to what I believe to be unsound elements in SSR40 (Inclusion of a Chantry Lane extension)

1. There is a clear presumption that the current Chantry Lane access will not be used for the proposed Chantry Lane Extension and a new access route will be created. The only possible access route is across the field adjoining Sullington Lane and the A283. The statement in 2.36 that the potential impact on cultural heritage is “dependent on the scheme details”, is disingenuous and seems to flout the first four of the guiding principles in 2.41. The access however it is designed, will inevitably cause major damage to a particularly sensitive environment. This environment includes the best view in the area of the South Downs and views to and from a Grade 1 listed building and a number of other grade 2 listed buildings.

2. The traffic congestion implications do not appear to have been fully considered. In particular the impact of the decision (WSCC/044/18/SR) to allow Cemex to refill the large sand pit on the opposite side of the A283 which will bring an estimated 134 large vehicle movements per working day, does not seem to have been factored in. Even before this activity starts there are frequent tail backs from the centre of Storrington well past the Sullington and Water Lane junction.

3. The Air Quality implications do not seem to have been fully considered. Per the Sunday Times, Storrington has the unenviable distinction of being the most air polluted village in England.

4. The notion in 7.2.10 that the site could eventually be restored to agriculture is most implausible. 1,000,000 tons from a 2.5ha site implies an incredibly deep pit. And indeed if such restoration were attempted it would necessitate another massive influx of large vehicle movements.

Finally I would observe that the very considerable amount of modification to the document implies continuing instability.

LEGAL DISCLAIMER 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. 0080 - 4271 west ;sussex Working in Partnership countY. ,,.��South Downs council National Park Authority

Official use only PROPOSED SUBMISSION DRAFT SOFT SAND REVIEW Respondent No: OF THE WEST SUSSEX JOINT MINERALS LOCAL PLAN - REPRESENTATION FORM

If you would like more information about the Soft Sand Review or this process, please contact the Planning Policy and Infrastructure Team at: • Planning Services (ref Soft Sand Review), West Sussex County Council, County Hall, Chichester, POl 9 1 RH • [email protected] • 01243 642118

This formshould be returned by 11.59pm on 2 March 2020 to the above address. Additional copies of the formcan be obtained from the County Council's website: www.westsussex.qov.uk/mwdf. Photocopies of blank forms can also be made. There is also an online form available at www.westsussex.qov.uk/haveyoursay.

Advice on how to make representations is provided in the accompanying guidance notes. You are advised to read these before completing the form.

This formcomprises of 3 main parts:

• PartA - Personal Details • PartB - Your representation(s) - please fill in a separate sheet for each representation you wish to make. Only fill in Part A once and send all representations in together. • PartC - An equalities form- this is voluntary and will be dealt with separately from Parts A and B

Data protection: Respondent details and representations will be forwarded to the Secretary of State for consideration when the Soft Sand Review is submitted for examination. All documents will be held at West Sussex County Council offices,County Hall in Chichester, and representations can be viewed by appointment and will be published online. They will be handled in accordance with the Data Protection Act 2018. West Sussex County Council is registered as Data Controller (Reg. No. Z6413427). For further details and informationabout our Data Controller, please see www.westsussex.gov.uk/privacy-policy. Personal contact details will be removed from copies of representations published electronically.

STEYNING AND DISTRICT BUSINESS CHAMBER

Response to Soft Sand Review of the West Sussex Joint Minerals Local Plan Consultation January 2020

Background The Steyning and District Business Chamber supports local businesses and helps promote the area as a tourist destination. It is important to us that our town is able to attract people to the area and retain visitor numbers. 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. Currently our High Street and surrounding area is bucking the national trend, businesses are choosing to come to Steyning and open. The site just outside Steyning’s inclusion could stop or alter this trend. The proposed inclusion of the Ham Farm site as one of the identified areas for soft sand ignores the extent to which its inclusion would impact on visitor numbers and amenities for residents. It will also have an unacceptable effect on the surrounding landscape and should be withdrawn as a potential site. Our representations We object to the inclusion of the Ham Farm as one of the three selected sites. This is referred to in policies: SSR 1 (Chapter 7); SSR 30; SSR SSR34 and SSR35.

SSR27 (New Para 7.1.7) There are five six key 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. Ham Farm is recognised as Grade 3 agricultural land i.e. the best and the assessment notes that this seems likely to be lost in restoration. It fails this principle, no net-gain in biodiversity will be possible. SSR 27 (7.7.2.7) states the detailed technical assessment of the site has been undertaken that has not identified any overriding or fundamental constraints to the proposed forms of development on the allocated sites. We do not agree with several of these assessments, which also reflect the guiding principles

Page | 1 26.02.2020 The technical assessment on Soil quality is amber. We rate this using the Framework as Red

• 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

The Site Selection Report records that the site is visually sensitive in views from the top of the scarp and accepts that there will be negative impacts for users of Wiston Park. The fact that the SDNP boundary is to the south of the road indicates the value of the landscape in this area. It will be highly visible to all users of the South Downs Way and Chanctonbury Hill and its surrounding downland. These are well- known and accessible tourist destinations in the SDNP. Views at these locations are of the highest sensitivity owing to the location being within a National Park, on a National Trail and at a viewpoint destination. There are an estimated 39 million daily visits to the National Park. Extraction would include structures, movement, noise, lighting etc and cumulatively these will have a serious impact on those seeking tranquillity, peace and stunning views; the very reasons why visitors come to this area. In our opinion you have undervalued the impact at Amber. Within the immediate area of the site are Alderwood Pond, Wiston House with Wiston Park and the Cow Shed Studio, all are visitor attractions. Alderwood Pond has 45 fishing points including 4 for disabled use. This is the only fishing pond in the area with disabled access and provides facilities for several major charities. The Cow Shed Studio, immediately adjacent at Hammes Farm offer courses, exhibitions which attract visitors from a wide area. Wiston House has an international reputation as a Conference Centre. The current tranquil setting is used for Weddings, Dining, Social Events and the park hosts events such as the Steam Rally, Big Church, Concerts and other gatherings. The setting of all these popular attractions will be adversely affected. Steyning often features in articles as an attractive place to live, work and retire to and all of the local features, in particular the immediate landscape of the SDNP area are all extremely well used. The economic wellbeing of Steyning relies on attracting people to visit and initial impressions driving-by matter. The approach by road to the Steyning area from the south is already adversely impacted by the disused cement works. The proposed development of the quarry will adversely impact the approach from the west.

For all the above reasons we disagree with the report’s technical assessment of Amenity as Red/ Amber and have rated this as Red

For the above considerations we are of the opinion that the assessment of Ham Farm for Landscape is should be scored Red/Amber and not Green as indicated

• 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

Page | 2 26.02.2020 principle’, that is, there should not be any technical issues, with regard to highway capacity and road safety, that cannot be overcome.

The Technical study for Transport and access is rated Green, indicating no highway concerns. This judgement appears to rely on the transport study arising from a planning application With approximately 96 vehicle movements – rated at 8, two way movements per hour, this seems a very crude assessment, when the rating has a strong effect as to a decision on the chosen site. In addition, the vehicle numbers are provided by the promoter. Assuming there is an even spread (which seems likely to be unrealistic) there will be a minimum of 4 vehicles turning across the traffic. This may appear minimal but with fast moving traffic it is bound to cause serious delays at busy times. This seems to ignore that removal of spoil and reinstatement in particular is likely to be in particular directions, also that this section of road has been identified as a dangerous stretch of road. The camber, flooding in the area and curves, which show straighter in any documents have not been taken into consideration. Taking these considerations into account implies that highway will need major improvements and lighting at the site entrance. (There seems some confusion in the technical assessment which refers to an addendum in October 2016 as opposed to the paper on Transport in 2019). These will impact on the visibility of the site from the SDNP and lead to a detraction in air quality which would be particularly disruptive when major events take place at Wiston Park. It will also be a departure from the current rural outlook at a point immediately before visitors enter Steyning.

The technical assessment for Transport and access is Green. We refute this and for the above reasons the correct marking should be Red/Amber.

The earlier comments highlight the impact on the highly sensitive views from the SDNP and national trail which are very popular as a tourist destination and residents alike. In addition, the site, as recognised in the report is only 125m from the ancient Great Alder Wood. The site is also adjacent to several listed buildings and historically important buildings: Horsebrook Cottage; the Old Rectory, buildings at Wappingthorne and importantly to the south of the Grade 1 Wiston House and a the 16th Century Barn at Hammes Farm. The development of this site, estimated to take 10 years, will have strong negative impact on all these buildings and amenities.

The technical assessment of Historic environment designations is Red/Amber, which we agree.

Page | 3 26.02.2020 Fifth principle: A preference for extensions to existing sites rather than new sites, subject to cumulative impact assessments. Development of this site conflicts with this principle. • Sixth principle: The need to avoid the needless sterilisation of minerals by other forms of development

There is no reason why this land would stay otherwise than Grade 3 agricultural land Conclusions Changes to the boundary of the Ham Farm site have not resulted in any amelioration of the adverse impacts on tourism. It will now have a greater frontage to the A283 and wider impact to the SDNP.

We remain of the view that the impacts on tourism have been undervalued and misunderstood. Steyning is one of the gateway towns to the SDNP and its main attractions include easy access to the SDNP. In this crowded part of the UK many visitors relish easy access to the South Downs which offer openness, naturalness, lack of noise and distant views.

The proposal will result in adverse visible disturbance to the natural landscape, noise and light pollution, all detractors to peace and tranquillity. Visitors are also attracted by the views of the Downs and the surrounding countryside as they approach from the A283. This highly visible and busy site with structures will have a serious impact on the setting of this picturesque market town. For these reasons we continue to take the view that there will be an adverse impact on tourism which is an essential element of the local economy. These principles are underpinned by the Soft Sand Selection Report which assesses the individual sites in line with an Assessment Framework. Our review of the Ham Farm site using the Site Assessment Framework using the Framework is attached. Our differing Scores having regard to the above comments are set out in the table. We ask that this site is removed from the Local Minerals Plan.

Page | 4 26.02.2020 From: Champion, Sophie Sent: 06 March 2020 15:04 To: PL MWDF Subject: Re: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Follow Up Flag: Follow up Flag Status: Flagged

Alex,

Thanks for confirming. I'll send through the forms next week.

B.7 No ‐ Hampshire County Council do not wish to participate at the examination hearings, it is not necessary and any further correspondence on the matter can be done by written representation if necessary.

I'll be in touch again next week.

Kind regards,

Sophie

Project Manager 01962 846766 [email protected]

Economy, Transport & Environment Department EII Court West, The Castle, Winchester Hampshire, SO23 8UD

From: Champion, Sophie [mailto:[email protected]] Sent: 06 March 2020 14:40 To: PL MWDF Subject: Re: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Alex,

Apologies for the difficulties you've had with the representation forms submitted. I did just try to call you to confirm whether an email as you suggested is acceptable, as from my workplace today I'm unable to download the representation form - just view it.

The representation from Hampshire County Council stated that Hampshire County Council agrees with the strategy for the provision of land won soft sand as outlined in SSR8. The policy also highlights the importance that site provision is made for soft sand outside of protected landscapes in the first instance. Policy SSR5 informed the strategy and considered the following opportunities for extraction:

• within West Sussex but outside of the SDNP • outside of West Sussex • from other sources • from within the SDNP, within West Sussex • a combination of the options

The policy does not differentiate between areas outside of West Sussex that are both within the South Downs National Park or other protected landscapes; this consideration is only made within West Sussex itself. For example, Hampshire is outside of West Sussex but also contains soft sand constrained by national parks.

On this basis, the representation made was that the proposed submission plan was not sound because it was not justified or in compliance with the National Policy. It was suggested that in continuing the policy aspiration to avoid protected landscapes, it would be helpful to make this distinction clear in the policy wording by including an additional criteria ‘within the SDNP (or other protected landscape), outside of West Sussex’ when considering soft sand supply. Not just 'outside of West Sussex'.

3 Alexander Dean

From: Champion, Sophie Sent: 06 March 2020 15:04 To: PL MWDF Subject: Re: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

Follow Up Flag: Follow up Flag Status: Flagged

Alex,

Thanks for confirming. I'll send through the forms next week.

B.7

No‐ Central and Eastern Berkshire do no wish to participate at the examination hearings.

I'll be in touch again next week.

Kind regards,

Sophie

Project Manager 01962 846766 [email protected]

Economy, Transport & Environment Department EII Court West, The Castle, Winchester Hampshire, SO23 8UD

From: Champion, Sophie [mailto:[email protected]] Sent: 06 March 2020 14:40 To: PL MWDF Subject: Re: Publication of Soft Sand Review of the West Sussex Joint Minerals Local Plan (Regulation 19)

With regard to the representation made on behalf of the Central and Eastern Berkshire authorities, the proposed submission was considered as part of the joint working with Hampshire Services to prepare the Central and Eastern Berkshire Minerals Plan. There were no comments to make on the proposed submission.