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News  »  Parish Councils response to Hertfdorshire Minerals Local Plan - 2017



   Parish Councils response to Hertfdorshire Minerals Local Plan - 2017    February 6, 2018

HERTFORSHIRE MINERALS LOCAL PLAN 2016-2031

 

REGULATION 18 CONSULTATION DECEMBER 2017

 

We, Eastwick & Gilston Parish Council are writing on behalf of our community to object to Hertfordshire County Council’s draft Minerals Local Plan: proposed Preferred Area 1 – The Briggens Estate as measured against the policies within the draft plan.

 

Our objection is based on

·         it being inappropriate development in the Green Belt and

·         the adverse impact, over a significant period, on:

·         adjacent villages;

·         potential new housing development;

·         health and well being of surrounding communities;

·         already over congested road network;

·         the environment caused by extraction processes and HGV pollution (both air born particulate and noise).

 

Policy 1 Sustainable Development

East Herts draft District Plan proposes a substantial housing development (10,000 dwellings in the Gilston area in 7 villages, in excess of 3,000 being built by 2033) on land immediately adjacent, to the east of, the proposed Preferred Area 1 – The Briggens Estate.

 

A proposal to extract minerals from the Briggens Estate contravenes Policy 1:

“…. The county council will grant planning permission unless material considerations indicate otherwise, taking into account:

·         Any adverse impacts of granting planning permission that would significantly and demonstrably outweigh the benefits when assessed against the policies in the NPPF; …..“

 

Policy 3 Aggregate Supply & Policy 5 Secondary and Recycled Aggregates

·         The demand for primary sand and gravel is based upon the EERWP assessment which only looks forward to 2020. Herts CC have then projected the base figure of 1.39 m tonnes per annum forward for 22 years from the Plan base year of 2016. Reliance on this figure is concerning as acknowledged by the EEAWP at their meeting in June 2016. It is therefore unsatisfactory to base Policy 3 on this wild projection before a reassessment of demand in the East of England is made.

·         The Plan rightly has a policy to increase secondary and recycled resources, Policy 5, but is woefully short on application and consequently the land bank reserve makes no allowance for increasing such resources and therefore reducing demand for primary sources. The SA underscores the point that plumping for the highest of the alternative supply figures will reduce the demand for secondary and recycled sources. The Plan therefore is flawed in that the supply figures are not justified and there should be a positive approach to recycling. It is not satisfactory to simply encourage recycling but the call for sites should not have been limited to primary resources but also open to aggregate recycling plants. Paragraph 145 of the NPPF requires MPA’s to take into account all supply options. There is no evidence that this has been undertaken in the draft Plan.

Policy 4 Working of Specific Sites or Preferred Area

·         The National Planning Policy Framework paragraphs on the Green Belt precludes mineral extraction at The Briggens Estate:

o    Paragraph 88 requires that “substantial weight is given to any harm to the Green Belt. ‘Very Special Circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”  We do not believe this is the case.

o    Paragraph 90 allows development for mineral extraction in the Green Belt “provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt.”  We do not believe this is the case.

·         The Briggens Estate appears as a preferred area out of the blue in 7.44 of the Sustainability Appraisal as part of Option 4 which is then the core of Policy 4 in the Plan. The reasoning behind this is not explained and there is no analysis of possible alternatives as preferred areas to meet supply (without prejudice to the above).

·         The SA refers to the HCC Cabinet Panel report on site selection dated 7th September 2107 (sieving analysis). We argue that this analysis is fundamentally flawed in two respects: -

Firstly, although highways concerns are raised these overlook the simple fact that there are no west facing sliproads at the A414/B181 interchange thus quarry traffic will have to go through Stanstead Abbotts or Hunsdon which is totally unacceptable on highway safety and environmental grounds. This is completely contrary to the policies in the current and proposed Minerals Plan and in the current and proposed Local Transport Plan 4 for Herts. The NPPF states that ‘severe' traffic impacts are not sustainable. HGV gravel lorries through the centre of Stanstead Abbotts or through the village of Hunsdon are surely ’severe’. If not what is? It is simply not possible to devise mitigation measures for this problem (a new junction onto the A414 is not possible because of the proximity of existing junctions) and it is most unwise to procrastinate and think that it can be solved through some future ‘Transport Assessment’. It is quite simply a showstopper.

Secondly, quarrying at Briggens completely ignores the proposals to develop the Gilston Area for housing, part of which is in the Briggens Estate. The Gilston Area is subject to determination by the Secretary of State following the EIP of the Regulation 19 East Herts District Plan. If confirmed the gravel quarry during its operational period will adjoin residential properties.

We argue that both of these issues should be considered as constraints in the sieving analysis (Sieve1) thus eliminating the Briggens Estate from further consideration.

·         The SA recognises that housing development in Herts will increase demand for gravel and consequently adopts the highest supply demand figures of 1.39m tonnes/annum. The inclusion of the Briggens Estate as the preferred Area is clearly convenient for the supply of concrete aggregate for the Gilston Area housing allocation should this be confirmed in the District Plan. However, Village 7 of the proposed development adjoins the quarry area and thus seriously jeopardises the viability of Village 7. The draft Minerals Plan is therefore in direct conflict with the emerging District Plan.

Policy 8 Mineral Safeguarding

Policy 8 determines that the close proximity of both Stanstead Abbots, to the west, and potential development of the Gilston area, to the east, of the Briggens Estate disqualifies the Briggens Estate as being suitable for mineral extraction.

 

“…….

Any proposals for non-mineral development which fall within the Mineral Safeguarding Areas and Mineral Consultation Areas, other than applications for the ‘excluded development’ will be subject to consultation with the Minerals Planning Authority.

…….

The Mineral Planning Authority will object to proposals for non-mineral development within the Mineral Safeguarding Areas and Mineral Consultation Areas, as shown on the Policies Map, unless it is clearly demonstrated to the Mineral Planning Authority that: 

·         mineral extraction is not environmentally acceptable; or 

·         the need for the non-mineral development clearly outweighs the need for the mineral resource and therefore sterilisation of the mineral resources; or

………”

 

Policy 14 Cumulative Impact

“….

Proposals will need to take into account the cumulative impact on the following potential matters:

·         Natural environment;

·         Historic environment;

·         Human health and general amenity;

·         Transport Networks;

…….”

The Briggens Estate being within close proximity of housing is likely to impact on “human health”.

 

As stated above although highways concerns are raised these overlook the simple fact that there are no west facing sliproads at the A414/B181 interchange thus quarry traffic will have to go through Stanstead Abbotts or Hunsdon which is totally unacceptable on highway safety and environmental grounds. This is completely contrary to the policies in the current and proposed Minerals Plan and in the current and proposed Local Transport Plan 4 for Herts. The NPPF states that ‘severe' traffic impacts are not sustainable. HGV gravel lorries through the centre of Stanstead Abbotts or through the village of Hunsdon are surely ’severe’. If not what is? It is simply not possible to devise mitigation measures for this problem (a new junction onto the A414 is not possible because of the proximity of existing junctions) and it is most unwise to procrastinate and think that it can be solved through some future ‘Transport Assessment’. It is quite simply a showstopper.

 

Policy 20 Strategic Transport

“….

Proposals for mineral extraction and associated development should seek to use sustainable transport and where possible minimise transport movements and distance travelled by road, through the use of sustainable methods such as rail or water or use on site. 

……”

Policy 21 Operational Transport

“Mineral extraction and associated development will be permitted where it is clearly demonstrated that the provision for vehicle movement within the site, access to and from the site and the conditions of the local highway network are such that the traffic impacts likely to be generated would not have a significant adverse impact on:

·         highway safety;

·         the effective operation of the highway network;

·         amenity;

·         human health; and

·         the natural, built and historic environment.

…..”

 

There being no alternative means of transport other than by roads through existing villages, as discussed under Policy 14 above, the movement of minerals from the Briggens Estate will have considerable adverse impact on already over congested highways and potential health damage as a result of transport exhaust fumes, noise and stress to local residents.

 

We trust you find the above comments valid, demonstrating the proposal for The Briggens Estate is unsuitable and unsustainable and, therefore, rejected.  But in any event, we would ask you to confirm if these points will be addressed and if not, why.

 

On behalf of

Eastwick & Gilston Parish Council

 

 

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