Stop Bengeo Quarry Response to Planning Application for Extracting Sand and Gravel from Land at Ware Park (known as Bengeo Field), Hertford Ref PL\0870\17 Submitted by Stop Bengeo Quarry November 2017 Stop Bengeo Quarry Response, November 2017 Contents INTRODUCTION .............................................................................................................................. 3 1. Landscape and amenity concerns ................................................................................................. 4 2. Ecology concerns ......................................................................................................................... 6 3. Water supply concerns ................................................................................................................. 9 4. Air quality and health concerns ................................................................................................... 10 5. Traffic and road safety ................................................................................................................ 12 6. Noise concerns ........................................................................................................................... 18 7. Archaeological considerations .................................................................................................... 20 8. Planning needs ........................................................................................................................... 22 9. Emerging Minerals Local Plan .................................................................................................... 23 Appendix 1 - Results of landscape survey ................................................................................... 24 Page | 2 Stop Bengeo Quarry Response, November 2017 INTRODUCTION The Stop Bengeo Quarry campaign strongly opposes the proposed quarry north of Hertford. Campaigners believe that all the objections raised in the previous consultation remain. The threat to the landscape and wildlife remains. The health concerns related to gravel extraction remain. The impact of the quarry on the water supply and highways remains a concern. If the quarry were permitted, the character of this part of Hertford will be permanently damaged. This document addresses some of the main issues and concerns in response to the quarry application, covering: traffic and road safety, landscape and amenity, ecology, dust and health, water contamination, archaeology, noise and the strategic need. The strength of local feeling, expressed in response to the original application, has continued to increase since the original application in April 2016. The following provide evidence of the strength of the opposition to the quarry just outside Hertford: • 1,093 members of the Stop Bengeo Quarry Facebook group campaign actively and exchange views, findings and updates. 2,462 followers of Save the Countryside – Stop Bengeo Quarry Facebook page follow up and share the campaign updates. • We have a Facebook presence of well over 3,000 followers. Some of our campaign Facebook updates have been viewed 15,000 times. • In October 2017 we had 2,323 campaign website page views with average session duration of 2.38mins. 61.9% of visitors to the website were new. • The campaign is supported by MP Mark Prisk, as well as the local Green Party and Labour Party, and a number of local Residents Associations including Molewood Residents Association, Lower Bengeo Residents Association, Chapmore End Association, and Watermill Estate Residents’ Association. • The Stop Bengeo Quarry’s HCC e-petition against the quarry proposal has just been approved and the figures of the supportive entries will be shared with HCC within the next few weeks. Page | 3 Stop Bengeo Quarry Response, November 2017 Stop Bengeo Quarry would also like comment on the overall way the new application is presented to the public. We consider the new application unsatisfactory because it is incomplete, which makes the reading of the documents confusing, if not incomprehensible. Some examples of this are: 1. The Transport statement – relies on the Transport statement prepared in the original application of February 2016. 2. The Landscape section - it is unclear whether to refer to the original LVIA of Liz Lake or the LVIA of the revised application and because the new post-quarry relief map shows a significantly different final landform neither documents are actually applicable. 3. The ecology section - relies on the original assessment from February 2016. With a matter of such great interest to the community and of such great public concern this is neither satisfactory nor acceptable. At very least the developer should have resubmitted all the documents with the appropriate addendums attached so that it was clear which documents were being referred to in each section. It is of very great concern to us that the documents are presented in this way and we believe that unless corrected invalidates the application – since the application is clearly incomplete. Finally, the new draft Minerals Local Plan does not recommend the Bengeo Field as a preferred area. We welcome this development and hope that this will be taken account of when judging this new application. 1. Landscape and amenity concerns The land proposed for the quarry is a much loved and visited piece of Green Belt (known locally as Bengeo Field), containing two extensively used public rights of way with beautiful views across the Rib Valley towards Ware Manor. The land is of the Stony Hills landscape character and contains two wave form ridges with distinct central dry valley. The site lies on sloping land with relief sloping to the east towards the river Rib. The Landscape Visual Impact Assessment from Liz Lake (1571 LVA Technical Addendum) takes the form of an addendum to application 3/0770-16. However, there are some significant landscape changes in the new proposal, including: • a new attenuation area, close to the footpath, is planned • the slopes are steeper than originally anticipated • the deepest point of the quarry is below the level of the current path (this point is planned to form the attenuation area). However, within the addendum to the LVIA, views from different locations are not re- considered – as they should be. The central public footpath, recently declared an asset of community value, is heavily used throughout the year. Page | 4 Stop Bengeo Quarry Response, November 2017 It is declared that the central footpath would be undisturbed apart from movements of lorries, yet quarrying working appears to go up to the very edge of the path. It is far from clear how the lorry movements would be safely handled given the current high usage of the path. There is no real explanation as to how bunding would be managed or users of the path protected from the daily workings in the quarry. The addendum totally fails to explain the rationale behind the new proposed (post restoration) landscape. Several of the points made in the rejection of the previous application have not been addressed. For example, the quarry is not an extension of Rickneys quarry, and considerable truck movements across currently open land would be required. The developer has stated (both in the East Herts District Plan - Statement of Common Ground – Gowling WLG Trust Corporation Ltd, and indirectly in the Environmental Statement for the original application) that extraction of minerals is necessary so that the land is not sterilised prior to the development of housing as a part of HERT4 to the south of the field. It is, therefore, clear that the eventual landscape will not be that envisioned in the technical addendum or as shown in the drawings because the southern part of the site will contain new houses. To our knowledge there has never been a landscape assessment which included house building on this precious and valued part of the green belt. This makes the entire landscape assessment flawed as clearly some of the views mentioned would be affected by the new housing. The future of the landscape and the rural amenity value of our countryside is very much the business of HCC, and therefore it is important to consider the complete plan for the land – not just the part covered by the immediate application to extract minerals. D.K. Symes Associates, Environmental Statement says: 1.3 These competing land uses are recognised at both Government and County level (Hertfordshire County Council (HCC) is the mineral planning authority) and policies are in place to avoid the needless sterilisation of known mineral reserves as the deposits are finite. Therefore, there is a real risk that the need for further houses could result in the sterilisation of the identified mineral deposit, both directly by building over the minerals and indirectly by locating new residential development adjacent to an identified mineral area resulting in increased environmental constraints. 1.4 In order to address this conflict discussions have taken place with EHDC who are the authority responsible for delivering the additional homes that are needed. Statement of Common Ground states: 4.1 Plan 1389 A4 01 A is an indicative concept master plan prepared by Liz Lake Associates which demonstrates how the Pre-Submission HERT4 site can be comprehensively developed to provide up to 150 dwellings. Prior to residential development on the Trust land, minerals would be extracted from the land immediately to the north, which is within the Minerals Preferred Area. 6.5 The specific