proposed gravel extraction, broadfield farm

[andyg]

I went to the Parish council meeting this evening where a sizeable number of residents attended to seek information about the proposal to extract gravel from the Broadfield Farm area on the western side of the village. If it is allowed to go ahead it will have a massive long term impact on the village.

We we pointed in the direction of the policy document and I thought a link my be useful for others to make finding it easy:
www.essex.gov.uk/Environment%20Planning/Planning/Minerals-Waste-Planning-Team/Planning-Policy/Policy-Consultations/Current-Consultations/Documents/Vol%202%20(H%20-%20Braintree)%2017-11-10%20Low%20Res.pdf

and also the appendix document (H) which details the assessment and scoring of the Rayne site (pages134-148 / hr-id):

www.essex.gov.uk/Environment%20Planning/Planning/Minerals-Waste-Planning-Team/Planning-Policy/Policy-Consultations/Current-Consultations/Documents/Vol%202%20(H%20-%20Braintree)%2017-11-10%20Low%20Res.pdf

and also a link to the MDD (Minerals Development Documents) home page where there is more information:
www.essex.gov.uk/Environment%20Planning/Planning/Minerals-Waste-Planning-Team/Planning-Policy/Policy-Consultations/Current-Consultations/Pages/MDD-documents-and-supporting-evidence.aspx

For thiose who were not in attendance and who may not be aware there is a'drop in' session at the village hall on Friday 14th Jan from 11.30-18.30.

Objections need to be submitted by 17th February

[andyg]

I wrote to the County council about the timescale for responses but they said they cannot agree to an extension of the consultation time. They did send me the full document plus a copy on CD. They want comments /questions etc on the correct form if possible. - it is on page 92 of the document. I e-mailed ECC and they sent me a more extensive copy.

I'm working on a few questions / objections already!

Dont forget the drop in on Friday.

Has anybody thought about starting an Action Group to co-ordinate efforts on this?
Could call it RAGE - Rayne Against Gravel Extraction!

[andyg]

Food for thought - what the document doesn't tell us.
here's a plan of Rayne with the gravel site overlaid on it as per the MDD Document AND the excavation area superimposed on the village itself - Rayne will fit into the hole about 1 1/2 times!

[stuart]

To add to Andyg's outline above.



The turquoise line fron the centre of the extraction site to the centre of Rayne village is about 1.1 miles.

Pros to the site:

Possible employment locally.
Extra funds for Rayne Parish Council maybe ?
What it gets turned into once extraction is depleted.

Cons to the site apart from noise & dust:

Heavy plant and machinery onsite
Heavy vechicle use locally possibly upto 7 days/week.
No access to the A120 west bound on the B1256 until Great Dunmow.
Closure of west bound A120 past Rayne.
Closure of east bound A120 past Rayne. (Everything goes through Rayne again)
Polution.
Enviroment.
Property values ?
Future expansion of the site.
What happens if once the extraction is completed it's just left ?

[andyg]

one comment that I put on my response form to the MDD team that may be worth pursuing:

An important point I wish to raise that does not come under any other heading is the standard of the document, in particular the accompanying map of site A9. The right hand side of the map conveniently finishes 25m short of the boundary of the primary school and 40m from a quiet cul de sac (Leyside), plus Capel Road and Station Road just a bit further off the map – this did not appear to concern to representatives at today’s drop in session at the village hall

I feel this is a blunt misrepresentation and is deliberately misleading in an attempt to present the proposed site as being remote to housing whereas it actually is not and quite frankly the document should be re-issued to show the true position of the site relative to the village

[andyg]

I've sent in various representations to ECC about the proposal and thought I would share them here in case anybody wishes to submit similar 'questions' . I suggest if you do wish to use them you don't put it word for word as it is unlikely to be counted twice but along a similar theme may add weight to our arguments.

I've also made a representation / question with my map attached about the effect on the community of a hole one and a half times the size of the village housing area

anybody else got items they wish to share?

Ecology and Designations
The ecology around Rayne is varied and includes protected species. Wildlife reports on the parish magazine regularly report barn owl, bat and badger sightings and I believe the increased noise and vibration disturbance will drive these creatures away. The report also gives mention to great crested newts, another protected species.
There is no mention of otters! The south west corner of the site virtually borders the upper end of the River Ter and I have heard of otter sightings on this river in recent years albeit further downstream between Great Leighs and Terling, the groundwater from the workings will need to be disposed of and the topography of the site makes the River Ter the only viable disposal point. I am concerned that vast quantities of muddy water will wreck the river’s ecology and force the otters to relocate just at a time when they are trying to re-establish themselves. The score of Amber1 does not reflect the impact that this development will have on the local wildlife and should be re-considered. I suggest a minimum of Amber3 is appropriate

Historic Environment
the report states that ‘there is a high possibility for disturbance of below ground remains within close proximity to the roman road including possible remains of a high status roman villa and prehistoric and paleolithic archaeology’ Armed with this information how can you possibly consider / condone the destruction of such an important site? Furthermore if (or more likely when) these remains are unearthed – I wont say discovered as you have virtually acknowledged the existence of these sites, with the cutbacks in your archaeology department how can we be assured that an important part of our heritage will not be lost forever? You have scored this Amber3 but with the pre-information quoted how can it’s disturbance even be considered – this should be Red without a shadow of a doubt as the permanent damage and loss cannot be mitigated in any way if the ground is excavated beyond recognition

Proximity to sensitive uses
please see my comments about the restoration further on as these are directly related
Water/ Hydrology
water table- observation of ponds and lakes in this area show that the water table is about 2 metres below ground level. By dividing the volume of gravel to be extracted (taking the loose weight of a cubic metre of gravel at approx 1.6 tonnes , the average depth over the worked site will be 4.75m plus the overburden depth so at least 5m. This will require the removal of vast quantities of water to allow excavation to take place and all this I assume will need to run into the river Ter. The effects on the river will be dramatic to say the least and conversely the drop in water table that this will bring about will devastate wildlife in local ponds and cause drying out of hedgerows etc. I therefore challenge the Green score for water / hydrology as being accurate. Amber 2 would be a better reflection of the site

Traffic and transportation
– because of the location of site A9 at Broadfield Farm any vehicles to or from the site will be passing other existing or preferred sites on their journey, only local traffic to Braintree or Dunmow will not pass other sites and both towns have other existing/preferred sites serving them thus this proposal will create unnecessary traffic in the local area. The A120 at Galleys corner becomes gridlocked at peak times and vehicles look for alternative routes to avoid the A120 – I dread the thought of them coming through the quiet village of Rayne to save a bit of journey time. Although there is existing access/egress for Eastbound vehicles on the A120, westbound vehicles will have to use the ‘old’ former Roman road (Stane Street) which has become rural in nature, this trend should not be allowed to reverse – I believe the Amber1 score for traffic & transport is incorrect and should be at least Amber2

Amenity and Pollution
carbon footprint – site A9 is located at a point where to reach any large town in Essex lorries will need to pass existing gravel sites. The nearest town (Braintree) has 3 indicate existing sites surrounding it, 2 of which have applied for 8 further workings between them. To the south Chelmsford has existing sites surrounding it and a new proposal to the west and to the west the nearest town (Dunmow) has an existing site close by which has 2 applications included in the plan. The area to the north is almost exclusively rural therefore most traffic leaving this site will pass other sites on it’s way and as such will un-necessarily increase road traffic and thereby the county’s carbon footprint, on this basis I believe the criteria of traffic& transport (Amber1) and pollution (Green !) have been incorrectly scored particularly when my points about the restoration of the site below are also considered properly in conjunction with this topic

Restoration and After-use
The report states that due to the proximity of Stansted large areas of water cannot be left on the site and that reinstatement will be by replacement of the overburden. By dividing the volume of gravel to be extracted (taking the loose weight of a cubic metre of gravel at approx 1.6 tonnes, I have calculated that the average depth over the worked site will be 4.75m plus the overburden depth so assuming the overburden goes back again it will leave a 4.75 m deep hole which will be partially filled with water as the ground water table re-establishes itself, probably to within 2 or 3 metres of the final ground level. This will provide the large area of water which the report says is to be avoided and raises more questions than answers- Either the large area of water will have to remain , much to the dissatisfaction of Stansted Airport otherwise vast quantities of ‘material’ will need to be imported to bring the ground levels up above the ground water table –which alternative will be adopted because common sense says it will have to be one or the other and if it the latter then it will involve vast numbers of lorries bringing in the landfill so we will have carbon emissions arriving on our doorsteps by road and dropping from the air! I suggest that the restoration score of Amber2 does not take this long term blight into account and should be at least Amber3 or even Red as there is no apparent suitable mitigation as one will immediately counterbalance the other

Other
1: The thin end of the wedge – 16 of the 20 preferred sites are existing establishments (some of which have already extended their original application areas under previous applications) thus demonstrating that once an initial site is permitted then the likelihood is that future extensions will be allowed. With the eastern limit of the present application being within 1000m of the village housing (and more precisely the primary school) a future extension is likely to virtually border the individual property boundaries – I find the prospect of houses and a primary school possibly being so close to such workings with the accompanying dust and noise to be totally appalling and that a ‘thin end of the wedge’ development should not be allowed when there are so many existing viable sites operating

andy

[andyg]

Has anybody else filled in the objection / question forms yet - It is most important that we as a village submit as many questions as possible rather than just relying on the parish council, volume of well constructed questions and objections will have much greater effect.

I raised questions about the submission system as I felt it is not entirely user friendly and received this reply:

It is recommended that you complete a response form for each consultation question you respond to. However, this is not essential and we are happy to receive comments typed out in a normal email or letter. Responding directly online is also another method.The only email address you should submit MDD consultation comments to is the address I am writing to you from – [e-mail]

All comments we receive in regards to this consultation are logged, acknowledged via posted letter, and then processed on to our online system so they can be viewed by the public. No comments received by the Minerals and Waste Planning team are ever discarded and if we require clarification from a respondent to ensure we process the comments under the correct question then we make contact directly

so if the sight of the form alarms you simply write an e-mail to the above address and it will still get recorded.

I've been busy on a few more submissions and will post them here later

[andyg]

here's some more that I've sent in:

Landscape
The views across these fields offer unparallelled westward views from Pods Lane ( a protected lane) and the footpath/bridleway between the Dunmow road and Duckend Green. To many it is particularly important as it offers the best views from Rayne of beautiful sunsets such as this one that I was fortunate to see and photograph recently:



Loss of such a valuable visual amenity to the village folk would be a travesty of justice and although you have scored ‘landscape’ Amber 2 this hardly reflects the potential loss of this unique view, Will you please reassess this subjective score and I propose that it should be either Amber 3 or Red in view of it’s importance to our village as it is the only point where uncluttered sunsets can be observed in Rayne


Water/ Hydrology
The massive hole proposed just west of Rayne (about 1.5 times the area of the housing in Rayne village) which assuming the London clay overburden is approx 3m deep will when fully excavated be around 4.65million cubic metres in volume and 7.75m deep. The water table locally during the summer months from observing local ponds is approx 2m below existing surface level and assuming that to enable gravel extraction the water in the hole will mainly be pumped away to keep it dry the surrounding water table is likely to be lowered by some 5 metres. Gravel is generally very porous allowing quite rapid lateral water movement from quite long distances away and will thus easily drain the surrounding land including that under the housing of Rayne village into this monstrous hole.
In turn this will lead to drying out and shrinkage of the London clay overburden / subsoils under the houses in Rayne and many of these houses were constructed in the 19th or mid 20th century before the more recent rigorous building regulations to protect against foundation settlement in clay soils were introduced and consequently there is likely to be many instances of foundation settlement and even failure within the village.
Some London clays will shrink up to 25% when dried from their natural water content and without the natural water table below to maintain a reasonable water content within the clay this will have devastating effects on foundations not constructed to counter this shrinkage.
Has this likelihood been taken into account and will residents have recourse to claim against both the gravel prospector for the damage incurred and the County Council for negligence in not protecting the people of Rayne against this hazard which due diligence by the County council must surely have flagged up?

Amenity / Pollution
In an earlier submission (no 10) I touched on the subject of unnecessary and excessive generation of Carbon Dioxide (CO2) due to the location of site A9 whereby a high proportion of the traffic generated will pass other gravel sites on their journeys to and from site A9 (their routes were explained to me during the drop in session at Rayne on 14th January). I have now investigated this further and assembled data as shown on the spreadsheet below:



This demonstrates that by promoting a site in this location where extra travelling is required compared to the use of other sites more local to markets that over the lifetime of the pit an incredible extra unneccessary 5011.7 tonnes (yes TONNES) of CO2 will be generated during the lifetime of the pit and that assumes that incoming lorries transport waste fill rather than dedicated journeys just to dump on completion of the gravel excavation.

In the document the MDD Vision states the following :
10. Climate Change Mitigation and Adaptation
Minerals Transportation, sites and facilities for mineral development will be planned, located
and operated having regard to the need to mitigate and adapt to the impacts of climate
change. – please explain how the excessive CO2 generation calculated above compliments this statement – to my semi-trained eye it does just the opposite.

And then of course this is just the CO2 element, there are other currently EEC regulated emissions such as Nitrogen oxides (NOx), Total hydrocarbon (THC), Non-methane hydrocarbons (NMHC), Carbon monoxide (CO) and particulate matter (PM) for most vehicle types including HGVs. - all of these emissions will drift on the predominate wind over our tranquil village.

Based on this information, please justify you score of Green for pollution for site A9 , it must surely be at least an amber of some degree or other (Amber 3?) due to the unnecessary nature of the pollution

Pollution
More precisely dust

In the document the MDD Vision states the following :

2.3.8 Air Quality
The transportation of minerals to various sites throughout the County is an important issue with regard to associated air quality through vehicle emissions. In addition to transport related air quality, aggregate recycling dust from surface mineral operations can have a noticeable environmental impact and affect the quality of life of local communities. Amenities can potentially be
affected by dust up to 1km from the source, although concerns about dust are most likely to be experienced near to dust sources, at distances up to approximately 100m.Rayne primary school is only 800m from the eastern edge of the proposed pit and on the leeward side of the prevailing wing and there is an area of housing surrounding the school at a similar distance from the proposed workings therefore please explain how the proposed siting of the gravel workings at site A9 meet the stated intention of ECC to deal with this impact on the local community particularly the primary school


Based on this information, please justify you score of Green for pollution for site A9 , it must surely be at least an amber of some degree due to the location of the site relative to the village


please feel free to use these ideas as a basis for your own submissions to ECC - the more that are submitted the better. One site has already got numerous on line objections in place and we need to be at least as active as them as their score was the same as Rayne.