Post by andyg on Feb 13, 2011 10:01:32 GMT
I've written a set of bullet points below which might give you ideas for topics for your objections, please feel free to use them . I attended a meeting with the Parish Council and ECC on Thursday and once again it was stressed to us that the number of submissions received will have great bearing on our vhances of success. It is also worth noting that we should not rely on just one family member to write in , if (say) 3 family members write in objecting on the same grounds (but not using exactly the same text) then that will count in our favour. The Parish council objection itself only counts as one for each point raised so it is important that we spend these last few days sending in as many objections as possible on the topics that we feel strongly against.
I've also written a 'rough guide' to writing objections which is on the Rayne Mineral Matters site:
www.handy4u.co.uk/layouts/layout0001.asp?url=raynemineralmatters.handy4u.co.uk&pid=1000&edt=1
Bullet points:
Minerals resource and timetable
• ECC have details of the gravel resources available in each area but have not done a study of the market areas – Rayne is not close to any large towns so are they confident there is a nearby market
• Are there still unused reserves from current sites due to recession that can be used instead
Planning history
• Previously refused – so why re-visit
Landscape
• Views across fields from Pods Lane, evening sunsets (best point in Rayne for viewing)
• Destruction of woodland (Moors Spinney) – not even mentioned in the report and bunding around Rumney Wood
• Views will be spoilt by massive heaps of waste sand and soil
• Report says ‘Advanced Planting’ carried out – does this imply that there is a quiet agreement in place for the site to go ahead
• Eastern side (nearest Rayne) not identified for digging- will all the storage heaps be here , close to the village?
Challenge score of AMBER 2 – maybe propose RED
Ecology and Designations
• Damage to habitats- Moors Spinney will be ripped up, noise & dust will disturb animals
• Protected species – Bats, Great Crested Newts & Badgers
• Dirty water being pumped away into local rivers (Ter and Pods Brook), damage to environment
Challenge score of AMBER 1 – maybe propose AMBER 3
Historic Environment
• Destruction of Roman remains along old Roman Road – irreversible
• Destruction of important Roman villa – irreversible
Challenge score of AMBER 3 –propose RED
Agriculture
• Question if the scoring system is correct –the guideline scores are inverted so Rayne should have a lower score e.g. amber 3
• Why dig up prime agricultural land when there are other sites already being worked with more reserves – challenge score, should it be RED
Proximity to sensitive uses
• 14 metre deep hole can not leave large expanse of water due to Stansted. Will need filling to above water table level so imports will generate carbon
Challenge score of AMBER 3 – maybe propose RED
Water/ Hydrology
• Will pumping away the ground water cause ground settlement which could rupture the large high pressure gas main on east side of site sending a gas cloud over the school and village
• Conflict of details – gravel will be ‘Wet Dug’ but there must not be standing water due to Stansted – how?
• Water table will drop significantly causing damage to ecology
• Lowering of water table will cause clay to shrink – damage to house foundations – will ECC be liable?
• Effect of pumping away water into River Ter – what damage will it do to river – silt, flooding
• Accuracy of water table – local businessman has borehole record showing water table much higher than ECC data
challenge GREEN score and suggest AMBER2 or thereabouts
Traffic and transportation
• Lorries will come through village and then through Braintree to avoid delays at Galleys Corner which gridlocks at peak times when it tails back to Panners Farm
• Lack of knowledge of market areas – without this how can it be proved that Rayne is a viable site when it is far from the major Essex towns
• Lorries will go past other sites on their way to deliver – unnecessary long journeys and unnecessary carbon emissions
challenge AMBER 1 score and suggest AMBER2 or AMBER 3
Recreation
• Public safety – large deep hole full of water, standard of fencing on other sites in area is very poor, what controls will be in place – tempting dangerous playground close to village
challenge AMBER 1 score and suggest AMBER3 or thereabouts
Amenity and Pollution
• Question scoring – is it assessed as at present, should be assessing the difference i.e. impact
• Roundabout at entrance is close to A120 but road is further from village ad in a cutting which stops the noise. Pods Lane is quiet. GREEN is not a true assessment – suggest AMBER 3?
• No identification of markets so may be creating unnecessary traffic over long distances, there are other existing pits to provide local supplies anyway
• Carbon footprint – gravel from Rayne will pass other sites on way to deliveries, unnecessary journey lengths – challenge score of AMBER1 , suggest AMBER 2 or 3 in question
• Dust – Rayne school and housing is only 800m from site and downwind
challenge GREEN score and suggest AMBER2 or thereabouts
Restoration and After-use
• The need to fill the hole above water table level (due to stansted) will require vast amounts of imported fill causing disturbance, pollution and increased carbon footprint
• Why not use sites that do not have such restraints on the restoration
challenge AMBER 2 score and suggest AMBER 3
Other
• Disproportionate size of development – hole will be 1 ½ times the size of the village housing footprint
• Site plan is misleading – conveniently stops on right hand side just 25 metres short of school and housing so gives a false impression of being away from village
• Creeping development – most sites one started tend to extend on and on – will it happen here?
•
• No mention of the effect on PEOPLE , section dedicated to ecology with rare animal surveys etc, but nothing about the residents,
• Report is biased in favour of promoter
• Scoring overall is inaccurate – some sections seem to just look at how it is now rather than considering the impact on the community
• Spatial development – concentration of pits in the Braintree area (50% of total tonnage) while main towns are out of area so long haulage journeys
Finally my step daughter has written some objections mainly on the same themes as myself (but a bit briefer) and using some of the bullet points above, these are her objections which you may wish to use as a basis for your own:
From
Address:
MDD policy, Site A9, Broadfield Farm, Rayne
Previous submission reference number:
I wish to submit the following questions:
Agriculture
Question 1:
Will you confirm that your scoring system for agriculture is correct please, the scores appear to be reversed as a grade 3 is rated more important and thus a lower score than grade 1 & 2 soil. Site A9 is mainly grade 1 or 2 soil so the score has been increased as a result. Do you agree that the score guidelines for this topic are incorrect and that site A9 should be scored Amber 3 and not Amber 2?
Question 2:
Why are you allowing the digging up of 90 hectares of prime agricultural land when there is a shortage of food in the world and because of imports our food bills have to keep going up. This land could help to feed Rayne at far less cost and would be better for the environment as it wouldn’t be brought in from abroad, we should be growing as much food in this country as we can rather than destroying the land– it just doesn’t make any sense at all, the shortfall will have to come from somewhere. If you think making Rayne less self sufficient is acceptable then think of the consequence - the score should be RED
Amenity & Pollution
Question 1:
I am believe that your scoring for site A9 re noise pollution (tranquil) is inaccurate, The area around the proposed site near the roundabout and would be entrance is a bit noisy due to the A120 being very close just there but the village itself is very quiet as the A120 is in a cutting as it passes the village and there is also solid fencing to deflect traffic noise. Also the road goes further away from the village as it passes Rayne so that it is around ½ mile south. To the east of the site Pods Lane is very quiet as it is rural and I question your score of Green – I think Amber 3 would reflect the situation more accurately.
Question 2:
I have another question under the same heading – your scoring seems to be more about the current situation instead of the likely difference caused by the development should it go ahead – is that correct?
Question 3:
Your document says where the sources of gravel are, but not where you expect the markets to be or more precisely the breakdown of where the gravel markets are. Without knowing that how can you accurately establish the best locations based on the distances to transport gravel and the carbon footprint it generates. The Rayne site is some way from all the major towns apart from Braintree which already has pits at Bradwell and Rivenhall so on that basis may I propose that you re-score Amenity & Pollution for site A9 as either Amber 2 or 3. The scoring appears to be at odds with the likely future situation if the pit is developed, are these scores based on the current situation
Question 4
Because most of the market for the gravel is not close to Rayne, lots of the traffic going to or from it will pass other existing preferred sites on its way to delivering its loads. This will increase journey lengths unnecessarily as the other pits have the resources available to meet the demand were approval to be granted. All this traffic will generate large amounts of carbon dioxide massively increasing the county’s carbon footprint – how will you justify this? It will also cause lots of other needless pollution due to the longer journeys involved and the other toxic gases generated by HGV traffic, the score of Amber1 is not accurate and it should be Amber2 or Amber3
Question 5 (Dust)
Your document states dust from surface mineral operations can have a noticeable environmental impact and affect the quality of life of local communities and 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 boundary of the proposed pit and downwind of the prevailing westerly wind and with the village housing is also about the same distance away will you please tell me how the location of this site meets the above criteria re local communities as stated in your own document please? You have scored this site green which suggests this is quite alright but that does not concur with your own stated criteria. I believe Amber 2 would be an accurate reflection of the actual situation bearing in mind that it is downwind of the proposed pit
Ecology and Designations
We have an excellent variety of wildlife in and around Rayne including protected species noted in your report and the wildlife reports in the monthly parish magazine confirm these and are of great interest demonstrating our community’s interest in the environment. I am very concerned that if this development goes ahead it will destroy the habitat for many of these animals but those that do not actually lose their homes will be forced away by the 6 day a week noise and dust – how will you prevent this?
Also there will be large volumes of dirty water which will have to go somewhere, I am concerned about damage to the local rivers, both are small and such a large amount of water will change them completely – how will you ensure control both in the quantity and the quality of the water going into the rivers
I think your Amber 1 score for this is wrong; the impact will be far greater that you are suggesting –I think it should be Amber 3
Historic Environment
The report says that there are probably roman remains on the site as it is close to the old Roman road and you believe that there may be an important Roman villa there. This is part of our ancient heritage and no matter what you say or do, if you let this development go ahead then these ancient sites will be lost forever because it doesn’t take a expert to realise that once the developer starts work he will be in a very strong position to continue without proper controls in place no matter what is found. To consider the wrecking such important history is scandalous and I want to know how you can justify this, you’ve scored it Amber3 but it can only be Red if you want the report to hold any credibility
Landscape
Question 1:
The views across these fields from Pods Lane and the nearby footpath just east of it are some of the best in Rayne especially in the evening when we can see beautiful sunsets – this is the best spot n Rayne for seeing them. You are content to condone the complete destruction of an area of woodland (Moors Spinney) and also the site will be very close (60m) to Rumley Wood so if that is protected by bunding which will totally spoil the views across this land – why has such little consideration been given to this and Moors Spinney not even afforded a line in the report. I cannot see how this can be scored anything other than Red (currently Amber 2) as the site will just become an eyesore of heaps of gravel and waste soil covered in weeds blocking the views to the west . You say advance planting is well established on the southern boundary – the words ‘Advanced Planting’ imply that your mind is already made up and that this is just a paper exercise to satisfy those who have the ultimate say? – surely if the planting is part of the scheme it requires planning permission and until that is granted it should not have commenced- is that a reasonable assumption? Please justify your proposed actions and revisit your scores as suggested above
Question 2
The eastern side of the site is not part of the excavation area so logic says area will be used for soil and waste material storage in large heaps which will literally cast a shadow over Rayne in the evening sun ( the hole will be 14 metres deep and 9 metres of that is overburden which will be stored before going back and as this area is about 1/3 of the excavated area it will be much more than 9 metres high (3 times i.e. 27 metres?) and blight our landscape for many, many years. How can you justify this? There are wonderful views across these fields at present and the wanton destruction of this landscape deserves nothing other than a score of RED
Mineral resources
As we are still in a recession and have been for some time, I expect that the gravel assigned to the current programme has not all been dug. Has this been taken into account for the next programme in that the reserves identified for this plan may not all be needed if there is still some of the last ones left I cannot comment on the score without your answer but assume that if my point is correct then the relevant one will be adjusted
Proximity to sensitive uses
The proximity of Stansted as a sensitive use brings about massive restrictions on how this site can be developed and just as importantly how it is left afterwards. There will be an enormous hole which cannot be left with water in it so unlike other sites not within the Stansted zone this will have to be filled up again afterwards to meet their requirements, all this will cost money unless it is paid for by the charges to dump nasty materials on the site in which case the proposal can only be profit motivated – why is this considered acceptable? It is scored Amber 3 which is the minimum I feel is reasonable but to me this should be RED as the constraints make it totally unreasonable to develop it
Restoration and After-use
Your report says that because of Stansted you cannot have large areas of water on the site either during the works or when work finishes due to waterfowl and that reinstatement will be by replacement of the overburden. This will be a very large deep hole (About 14 METRES DEEP) and the overburden will be like a drop in the ocean. It doesn’t take much realise that to meet the Stansted conditions the hole will need a vast quantity of extra fill to bring the level up above the natural water table. So as well as putting up with 14 years of gravel extraction and the associated pollution and disturbance (a very negative amenity) we are going to have vast amounts of carbon emissions pushing up the county carbon footprint because this site’s location (unlike others) means it can be left as a water amenity. – Please tell me how you can disagree with this state of affairs. It is scored Amber 2 at present but I believe it should be Amber3 under your scoring system
Traffic and transportation
Question 1
I’m worried that despite your assurances some of this extra traffic will use the road through our tranquil village as a short cut to avoid the delays that build up from Galley’s corner back to Panners and beyond. You say this will be the official route but previous experience from reading the press shows that lorry contraventions are generally ignored – e.g. the recent so called golf development at Black Notley that was no more that a falsely named tip. At the first sign of delays and it happens most mid afternoon especially in the summer because it’s the first bottleneck after leaving London, the lorries will go through Rayne and then through Braintree to make their deliveries quicker – to them time is money and that will be all that matters. Going west you have recently de-classified the old A120 to a B road and now you want to put extra lorries back on to it – that totally defies logic!
Your score of Amber 1 suggests that you have not considered this properly so please explain how you expect our roads to stand up to this heavy traffic being imposed upon it and also give it a more reasonable score of Amber 2 or Amber 3
Question 2 (the market for gravel from site A9)
This is the same question to one in the Amenity & Pollution heading but I’m asking it for different reasons i.e. to do with transport as it is also relevant. Your document says where the sources of gravel are, but not where you expect the markets to be or more precisely the breakdown of where the gravel markets are. Without knowing that how can you accurately establish the best locations based on the distances to transport gravel and the carbon footprint it generates. The Rayne site is some way from all the major towns apart from Braintree which already has pits at Bradwell and Rivenhall so on that basis may I propose that you re-score Amenity & Pollution for site A9 as Amber 3. The scoring appears to be at odds with the likely future situation if the pit is developed, are these scores based on the current situation
Water & Hydrology
Question 1
There is a big high pressure gas main running along the eastern side of the site by Pods Lane (along it’s closest side to the village) and I am concerned that as the ground water is pumped away the ground will settle and break the main so that we get a gas cloud drifting across the school and village, have you risk assessed this and how will you prove to the residents that there is absolutely no chance of it breaking? I think your score of GREEN is wrong and it should be AMBER 3
Question 2
Because of Stansted there will be a large hole full of water that will cannot have water standing in it yet the gravel is to be ‘wet dug’ – how do these two facts compliment one another? Surely it will have to be constantly drained. This will drop the water levels all around Rayne and ensure that plants dry out depriving wildlife of its habitat. It will also mean that all this water will have to go into the River Ter - how can all this water go into a tiny river without having any effect, in the summer it will account for most of the water in the river and the silt will clog it up (that’s what has happened at Great Leighs at the nature reserve downstream of the pit there) and in the winter when the river runs full it wont be able to cope with the extra water and because of the silt build up and everywhere will get flooded. – The green score implies no effect – how can you prove that, it must be Amber 2 or 3 because that river will get ruined?
Question 3
You sent my step father some information on boreholes and water table information and I am concerned about the accuracy of the information in those reports and the effect it will have on the environment and also houses in Rayne. The information is at odds with a trial borehole made by a local landowner for his water supply for his business which found that the water table is far closer to the surface than your results suggest. This massive hole is going to drain the surrounding land for the duration of the works as the water will be constantly pumped away making room for more water to run into the hole (water travels very easily through gravel so it will drain from well into the housing areas of the village and the dropping of water levels will have a great impact on clay shrinkage with risk to property foundations and also on the local environment 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? Instead of GREEN the score should be AMBER 2
Other – creeping development
I’m worried that this application is just the thin end of the wedge and once started it will just be allowed to grow and grow – the plan shows a large area (about 20 hectares?) on the eastern side of the site (nearest the village) which is not being dug up at this stage. But when you look at the 20 sites being proposed, 16 of them are already being dug and are looking to expand so history says that this one is likely to as well and that ECC will support that expansion as part of their plans as it a preferred policy, so the residents and school pupils of Rayne will have a giant hole creeping ever closer every time you update you minerals policy – how do you justify so much damage to our village life?
Other – disproportionate size of proposed development
This is totally out of proportion to our very adjacent village of just 1100 houses. – the giant hole will actually be about 1 ½ times the size of the village – yes 1 ½ times as big, and 14 metres deep as well – how can you suggest that something so disproportional will have no effect on the character of the village, it will drain the whole area and leave us with dried gardens and lawns, the trees will die through lack of water and Rayne will be changed for the worse for ever. It doesn’t fall into a category precisely but may I propose that it will affect the amenity of the village and that score should be changed from Green to Amber3 or even Red in view of the overwhelming size relative to the village itself
Other –site plan is misleading
Your plan for this site is misleading. The right hand side of the plan stops almost exactly where the housing and the school starts so that they do not show on the plan (about 20 metres from the school!) – This is a very misleading representation to make the site appear to be more rural and far from the village community and if I wonder if this is done deliberately just for that reason. Will you tell me why the map so conveniently finishes there and in fact why can’t you re-issue the document with the housing and school shown to give a proper indication of the proximity of the site to the village please? It doesn’t really fall into one of the categories but maybe under amenity which is scored GREEN, its actual closeness to the housing should make that score an AMBER 2
Other - Public Safety
You make no mention re the safety of the public during the proposed development – why?
An enormous hole containing deep water, slurry pits and machinery moving around the site and static plant for gravel washing and yet is there no mention of the protection of the public by way of fencing. With it so close to the village (although your map conveniently hides that fact) you are creating an irresistible attraction for children and I wonder why such a dangerous playground is being proposed so close to the village. My step father looked at the site at Great Leighs recently and showed me some photos which how easy it is to get onto the site, there is even a well trodden path clearly visible on one photo that he took! The fencing is little more than a token gesture and is not maintained so that it is very easy for even a mildly adventurous child to get onto the site and either fall into the water or slurry or climb on the machinery – With the Rayne site being that much closer to the village a serious accident it will only be a matter of time before a serious accident happens – why does the document not mention this? It doesn’t fall into a category (although it should be considered) but I suppose it could be regarded as unofficial recreation and dangerous one at that so may I propose that you change the Recreation score from Amber 1 to Amber 3 please
Question 15
Do you agree that these planning policy areas cover the correct topics and themes? Please
explain your answer. Sub-heading ‘Protecting the Environment and Mitigation of Adverse Impacts on Local Residential Amenity’
There appears to be little or no consideration for the residents of Rayne in the assessment of site A9 and there isn’t even a topic included to cover ‘people’. The document seems to be written totally in favour of the site promoter and yourselves with the local community placed a very distance last. You have a section dedicated to ecology so I assume animals etc are rated as more important than people. I support conservation and even though I am pleased to see various species having proper surveys and reports I’m disappointed that there’s no thought or assessment about the close proximity of the pit to our village (the plan conveniently finishes 25 metres short of the housing thus implying a far more rural location to the site) It seems that the residents of Rayne come a very distant second,. Please explain this policy to me as I believe we are being overlooked.
Question 17
Do you agree with the Site Selection Methodology? Please explain your answer. (Provide
details of how you think the methodology might be improved OR suggest an alternative
methodology that would achieve a more robust outcome).
The scoring in some of the sections seems to be wrong. It appears to relate to the environment and community as it stands at present without taking into account the impact if the site is allowed to be developed, I have highlighted in my other questions in specific but wish to raise it as an overall observation and to question the reason for doing it this way unless it is an error in the production of the report
Question 18 states:
‘Do you agree that the distribution of preferred sites shown on Map 5 above reflects the preferred spatial strategy - that is, provides a dispersed spread of sites with an emphasis on extensions?
NO! There are already many sites in the Braintree district and your plan calls for around 50% of the county gravel to be supplied from these pits whereas the actual demand in the Braintree area is probably no more that 10 or 15% so 35% of the county’s gravel will be transported over unnecessarily long journeys generating pollution in the form of noise, dust and toxic emissions and causing a massive increase in the carbon footprint of Mid Essex? Why are the sites closer to their markets not being considered more seriously rather than concentrate the Essex gravel production mainly in the Braintree district where demand is not as high? This makes a mockery of the Amber1 score for traffic & transportation re the site A9 which will see some of the longest journeys and I suggest that Amber 3 is more appropriate for site A9
Don't leave it until Friday - you will be too late, objections must be in by 17.00 Thursday 17th.
There is an Action Group meeting at the primary school tomorrow evening at 19.00 please make every effort to attend
thank you
I've also written a 'rough guide' to writing objections which is on the Rayne Mineral Matters site:
www.handy4u.co.uk/layouts/layout0001.asp?url=raynemineralmatters.handy4u.co.uk&pid=1000&edt=1
Bullet points:
Minerals resource and timetable
• ECC have details of the gravel resources available in each area but have not done a study of the market areas – Rayne is not close to any large towns so are they confident there is a nearby market
• Are there still unused reserves from current sites due to recession that can be used instead
Planning history
• Previously refused – so why re-visit
Landscape
• Views across fields from Pods Lane, evening sunsets (best point in Rayne for viewing)
• Destruction of woodland (Moors Spinney) – not even mentioned in the report and bunding around Rumney Wood
• Views will be spoilt by massive heaps of waste sand and soil
• Report says ‘Advanced Planting’ carried out – does this imply that there is a quiet agreement in place for the site to go ahead
• Eastern side (nearest Rayne) not identified for digging- will all the storage heaps be here , close to the village?
Challenge score of AMBER 2 – maybe propose RED
Ecology and Designations
• Damage to habitats- Moors Spinney will be ripped up, noise & dust will disturb animals
• Protected species – Bats, Great Crested Newts & Badgers
• Dirty water being pumped away into local rivers (Ter and Pods Brook), damage to environment
Challenge score of AMBER 1 – maybe propose AMBER 3
Historic Environment
• Destruction of Roman remains along old Roman Road – irreversible
• Destruction of important Roman villa – irreversible
Challenge score of AMBER 3 –propose RED
Agriculture
• Question if the scoring system is correct –the guideline scores are inverted so Rayne should have a lower score e.g. amber 3
• Why dig up prime agricultural land when there are other sites already being worked with more reserves – challenge score, should it be RED
Proximity to sensitive uses
• 14 metre deep hole can not leave large expanse of water due to Stansted. Will need filling to above water table level so imports will generate carbon
Challenge score of AMBER 3 – maybe propose RED
Water/ Hydrology
• Will pumping away the ground water cause ground settlement which could rupture the large high pressure gas main on east side of site sending a gas cloud over the school and village
• Conflict of details – gravel will be ‘Wet Dug’ but there must not be standing water due to Stansted – how?
• Water table will drop significantly causing damage to ecology
• Lowering of water table will cause clay to shrink – damage to house foundations – will ECC be liable?
• Effect of pumping away water into River Ter – what damage will it do to river – silt, flooding
• Accuracy of water table – local businessman has borehole record showing water table much higher than ECC data
challenge GREEN score and suggest AMBER2 or thereabouts
Traffic and transportation
• Lorries will come through village and then through Braintree to avoid delays at Galleys Corner which gridlocks at peak times when it tails back to Panners Farm
• Lack of knowledge of market areas – without this how can it be proved that Rayne is a viable site when it is far from the major Essex towns
• Lorries will go past other sites on their way to deliver – unnecessary long journeys and unnecessary carbon emissions
challenge AMBER 1 score and suggest AMBER2 or AMBER 3
Recreation
• Public safety – large deep hole full of water, standard of fencing on other sites in area is very poor, what controls will be in place – tempting dangerous playground close to village
challenge AMBER 1 score and suggest AMBER3 or thereabouts
Amenity and Pollution
• Question scoring – is it assessed as at present, should be assessing the difference i.e. impact
• Roundabout at entrance is close to A120 but road is further from village ad in a cutting which stops the noise. Pods Lane is quiet. GREEN is not a true assessment – suggest AMBER 3?
• No identification of markets so may be creating unnecessary traffic over long distances, there are other existing pits to provide local supplies anyway
• Carbon footprint – gravel from Rayne will pass other sites on way to deliveries, unnecessary journey lengths – challenge score of AMBER1 , suggest AMBER 2 or 3 in question
• Dust – Rayne school and housing is only 800m from site and downwind
challenge GREEN score and suggest AMBER2 or thereabouts
Restoration and After-use
• The need to fill the hole above water table level (due to stansted) will require vast amounts of imported fill causing disturbance, pollution and increased carbon footprint
• Why not use sites that do not have such restraints on the restoration
challenge AMBER 2 score and suggest AMBER 3
Other
• Disproportionate size of development – hole will be 1 ½ times the size of the village housing footprint
• Site plan is misleading – conveniently stops on right hand side just 25 metres short of school and housing so gives a false impression of being away from village
• Creeping development – most sites one started tend to extend on and on – will it happen here?
•
• No mention of the effect on PEOPLE , section dedicated to ecology with rare animal surveys etc, but nothing about the residents,
• Report is biased in favour of promoter
• Scoring overall is inaccurate – some sections seem to just look at how it is now rather than considering the impact on the community
• Spatial development – concentration of pits in the Braintree area (50% of total tonnage) while main towns are out of area so long haulage journeys
Finally my step daughter has written some objections mainly on the same themes as myself (but a bit briefer) and using some of the bullet points above, these are her objections which you may wish to use as a basis for your own:
From
Address:
MDD policy, Site A9, Broadfield Farm, Rayne
Previous submission reference number:
I wish to submit the following questions:
Agriculture
Question 1:
Will you confirm that your scoring system for agriculture is correct please, the scores appear to be reversed as a grade 3 is rated more important and thus a lower score than grade 1 & 2 soil. Site A9 is mainly grade 1 or 2 soil so the score has been increased as a result. Do you agree that the score guidelines for this topic are incorrect and that site A9 should be scored Amber 3 and not Amber 2?
Question 2:
Why are you allowing the digging up of 90 hectares of prime agricultural land when there is a shortage of food in the world and because of imports our food bills have to keep going up. This land could help to feed Rayne at far less cost and would be better for the environment as it wouldn’t be brought in from abroad, we should be growing as much food in this country as we can rather than destroying the land– it just doesn’t make any sense at all, the shortfall will have to come from somewhere. If you think making Rayne less self sufficient is acceptable then think of the consequence - the score should be RED
Amenity & Pollution
Question 1:
I am believe that your scoring for site A9 re noise pollution (tranquil) is inaccurate, The area around the proposed site near the roundabout and would be entrance is a bit noisy due to the A120 being very close just there but the village itself is very quiet as the A120 is in a cutting as it passes the village and there is also solid fencing to deflect traffic noise. Also the road goes further away from the village as it passes Rayne so that it is around ½ mile south. To the east of the site Pods Lane is very quiet as it is rural and I question your score of Green – I think Amber 3 would reflect the situation more accurately.
Question 2:
I have another question under the same heading – your scoring seems to be more about the current situation instead of the likely difference caused by the development should it go ahead – is that correct?
Question 3:
Your document says where the sources of gravel are, but not where you expect the markets to be or more precisely the breakdown of where the gravel markets are. Without knowing that how can you accurately establish the best locations based on the distances to transport gravel and the carbon footprint it generates. The Rayne site is some way from all the major towns apart from Braintree which already has pits at Bradwell and Rivenhall so on that basis may I propose that you re-score Amenity & Pollution for site A9 as either Amber 2 or 3. The scoring appears to be at odds with the likely future situation if the pit is developed, are these scores based on the current situation
Question 4
Because most of the market for the gravel is not close to Rayne, lots of the traffic going to or from it will pass other existing preferred sites on its way to delivering its loads. This will increase journey lengths unnecessarily as the other pits have the resources available to meet the demand were approval to be granted. All this traffic will generate large amounts of carbon dioxide massively increasing the county’s carbon footprint – how will you justify this? It will also cause lots of other needless pollution due to the longer journeys involved and the other toxic gases generated by HGV traffic, the score of Amber1 is not accurate and it should be Amber2 or Amber3
Question 5 (Dust)
Your document states dust from surface mineral operations can have a noticeable environmental impact and affect the quality of life of local communities and 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 boundary of the proposed pit and downwind of the prevailing westerly wind and with the village housing is also about the same distance away will you please tell me how the location of this site meets the above criteria re local communities as stated in your own document please? You have scored this site green which suggests this is quite alright but that does not concur with your own stated criteria. I believe Amber 2 would be an accurate reflection of the actual situation bearing in mind that it is downwind of the proposed pit
Ecology and Designations
We have an excellent variety of wildlife in and around Rayne including protected species noted in your report and the wildlife reports in the monthly parish magazine confirm these and are of great interest demonstrating our community’s interest in the environment. I am very concerned that if this development goes ahead it will destroy the habitat for many of these animals but those that do not actually lose their homes will be forced away by the 6 day a week noise and dust – how will you prevent this?
Also there will be large volumes of dirty water which will have to go somewhere, I am concerned about damage to the local rivers, both are small and such a large amount of water will change them completely – how will you ensure control both in the quantity and the quality of the water going into the rivers
I think your Amber 1 score for this is wrong; the impact will be far greater that you are suggesting –I think it should be Amber 3
Historic Environment
The report says that there are probably roman remains on the site as it is close to the old Roman road and you believe that there may be an important Roman villa there. This is part of our ancient heritage and no matter what you say or do, if you let this development go ahead then these ancient sites will be lost forever because it doesn’t take a expert to realise that once the developer starts work he will be in a very strong position to continue without proper controls in place no matter what is found. To consider the wrecking such important history is scandalous and I want to know how you can justify this, you’ve scored it Amber3 but it can only be Red if you want the report to hold any credibility
Landscape
Question 1:
The views across these fields from Pods Lane and the nearby footpath just east of it are some of the best in Rayne especially in the evening when we can see beautiful sunsets – this is the best spot n Rayne for seeing them. You are content to condone the complete destruction of an area of woodland (Moors Spinney) and also the site will be very close (60m) to Rumley Wood so if that is protected by bunding which will totally spoil the views across this land – why has such little consideration been given to this and Moors Spinney not even afforded a line in the report. I cannot see how this can be scored anything other than Red (currently Amber 2) as the site will just become an eyesore of heaps of gravel and waste soil covered in weeds blocking the views to the west . You say advance planting is well established on the southern boundary – the words ‘Advanced Planting’ imply that your mind is already made up and that this is just a paper exercise to satisfy those who have the ultimate say? – surely if the planting is part of the scheme it requires planning permission and until that is granted it should not have commenced- is that a reasonable assumption? Please justify your proposed actions and revisit your scores as suggested above
Question 2
The eastern side of the site is not part of the excavation area so logic says area will be used for soil and waste material storage in large heaps which will literally cast a shadow over Rayne in the evening sun ( the hole will be 14 metres deep and 9 metres of that is overburden which will be stored before going back and as this area is about 1/3 of the excavated area it will be much more than 9 metres high (3 times i.e. 27 metres?) and blight our landscape for many, many years. How can you justify this? There are wonderful views across these fields at present and the wanton destruction of this landscape deserves nothing other than a score of RED
Mineral resources
As we are still in a recession and have been for some time, I expect that the gravel assigned to the current programme has not all been dug. Has this been taken into account for the next programme in that the reserves identified for this plan may not all be needed if there is still some of the last ones left I cannot comment on the score without your answer but assume that if my point is correct then the relevant one will be adjusted
Proximity to sensitive uses
The proximity of Stansted as a sensitive use brings about massive restrictions on how this site can be developed and just as importantly how it is left afterwards. There will be an enormous hole which cannot be left with water in it so unlike other sites not within the Stansted zone this will have to be filled up again afterwards to meet their requirements, all this will cost money unless it is paid for by the charges to dump nasty materials on the site in which case the proposal can only be profit motivated – why is this considered acceptable? It is scored Amber 3 which is the minimum I feel is reasonable but to me this should be RED as the constraints make it totally unreasonable to develop it
Restoration and After-use
Your report says that because of Stansted you cannot have large areas of water on the site either during the works or when work finishes due to waterfowl and that reinstatement will be by replacement of the overburden. This will be a very large deep hole (About 14 METRES DEEP) and the overburden will be like a drop in the ocean. It doesn’t take much realise that to meet the Stansted conditions the hole will need a vast quantity of extra fill to bring the level up above the natural water table. So as well as putting up with 14 years of gravel extraction and the associated pollution and disturbance (a very negative amenity) we are going to have vast amounts of carbon emissions pushing up the county carbon footprint because this site’s location (unlike others) means it can be left as a water amenity. – Please tell me how you can disagree with this state of affairs. It is scored Amber 2 at present but I believe it should be Amber3 under your scoring system
Traffic and transportation
Question 1
I’m worried that despite your assurances some of this extra traffic will use the road through our tranquil village as a short cut to avoid the delays that build up from Galley’s corner back to Panners and beyond. You say this will be the official route but previous experience from reading the press shows that lorry contraventions are generally ignored – e.g. the recent so called golf development at Black Notley that was no more that a falsely named tip. At the first sign of delays and it happens most mid afternoon especially in the summer because it’s the first bottleneck after leaving London, the lorries will go through Rayne and then through Braintree to make their deliveries quicker – to them time is money and that will be all that matters. Going west you have recently de-classified the old A120 to a B road and now you want to put extra lorries back on to it – that totally defies logic!
Your score of Amber 1 suggests that you have not considered this properly so please explain how you expect our roads to stand up to this heavy traffic being imposed upon it and also give it a more reasonable score of Amber 2 or Amber 3
Question 2 (the market for gravel from site A9)
This is the same question to one in the Amenity & Pollution heading but I’m asking it for different reasons i.e. to do with transport as it is also relevant. Your document says where the sources of gravel are, but not where you expect the markets to be or more precisely the breakdown of where the gravel markets are. Without knowing that how can you accurately establish the best locations based on the distances to transport gravel and the carbon footprint it generates. The Rayne site is some way from all the major towns apart from Braintree which already has pits at Bradwell and Rivenhall so on that basis may I propose that you re-score Amenity & Pollution for site A9 as Amber 3. The scoring appears to be at odds with the likely future situation if the pit is developed, are these scores based on the current situation
Water & Hydrology
Question 1
There is a big high pressure gas main running along the eastern side of the site by Pods Lane (along it’s closest side to the village) and I am concerned that as the ground water is pumped away the ground will settle and break the main so that we get a gas cloud drifting across the school and village, have you risk assessed this and how will you prove to the residents that there is absolutely no chance of it breaking? I think your score of GREEN is wrong and it should be AMBER 3
Question 2
Because of Stansted there will be a large hole full of water that will cannot have water standing in it yet the gravel is to be ‘wet dug’ – how do these two facts compliment one another? Surely it will have to be constantly drained. This will drop the water levels all around Rayne and ensure that plants dry out depriving wildlife of its habitat. It will also mean that all this water will have to go into the River Ter - how can all this water go into a tiny river without having any effect, in the summer it will account for most of the water in the river and the silt will clog it up (that’s what has happened at Great Leighs at the nature reserve downstream of the pit there) and in the winter when the river runs full it wont be able to cope with the extra water and because of the silt build up and everywhere will get flooded. – The green score implies no effect – how can you prove that, it must be Amber 2 or 3 because that river will get ruined?
Question 3
You sent my step father some information on boreholes and water table information and I am concerned about the accuracy of the information in those reports and the effect it will have on the environment and also houses in Rayne. The information is at odds with a trial borehole made by a local landowner for his water supply for his business which found that the water table is far closer to the surface than your results suggest. This massive hole is going to drain the surrounding land for the duration of the works as the water will be constantly pumped away making room for more water to run into the hole (water travels very easily through gravel so it will drain from well into the housing areas of the village and the dropping of water levels will have a great impact on clay shrinkage with risk to property foundations and also on the local environment 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? Instead of GREEN the score should be AMBER 2
Other – creeping development
I’m worried that this application is just the thin end of the wedge and once started it will just be allowed to grow and grow – the plan shows a large area (about 20 hectares?) on the eastern side of the site (nearest the village) which is not being dug up at this stage. But when you look at the 20 sites being proposed, 16 of them are already being dug and are looking to expand so history says that this one is likely to as well and that ECC will support that expansion as part of their plans as it a preferred policy, so the residents and school pupils of Rayne will have a giant hole creeping ever closer every time you update you minerals policy – how do you justify so much damage to our village life?
Other – disproportionate size of proposed development
This is totally out of proportion to our very adjacent village of just 1100 houses. – the giant hole will actually be about 1 ½ times the size of the village – yes 1 ½ times as big, and 14 metres deep as well – how can you suggest that something so disproportional will have no effect on the character of the village, it will drain the whole area and leave us with dried gardens and lawns, the trees will die through lack of water and Rayne will be changed for the worse for ever. It doesn’t fall into a category precisely but may I propose that it will affect the amenity of the village and that score should be changed from Green to Amber3 or even Red in view of the overwhelming size relative to the village itself
Other –site plan is misleading
Your plan for this site is misleading. The right hand side of the plan stops almost exactly where the housing and the school starts so that they do not show on the plan (about 20 metres from the school!) – This is a very misleading representation to make the site appear to be more rural and far from the village community and if I wonder if this is done deliberately just for that reason. Will you tell me why the map so conveniently finishes there and in fact why can’t you re-issue the document with the housing and school shown to give a proper indication of the proximity of the site to the village please? It doesn’t really fall into one of the categories but maybe under amenity which is scored GREEN, its actual closeness to the housing should make that score an AMBER 2
Other - Public Safety
You make no mention re the safety of the public during the proposed development – why?
An enormous hole containing deep water, slurry pits and machinery moving around the site and static plant for gravel washing and yet is there no mention of the protection of the public by way of fencing. With it so close to the village (although your map conveniently hides that fact) you are creating an irresistible attraction for children and I wonder why such a dangerous playground is being proposed so close to the village. My step father looked at the site at Great Leighs recently and showed me some photos which how easy it is to get onto the site, there is even a well trodden path clearly visible on one photo that he took! The fencing is little more than a token gesture and is not maintained so that it is very easy for even a mildly adventurous child to get onto the site and either fall into the water or slurry or climb on the machinery – With the Rayne site being that much closer to the village a serious accident it will only be a matter of time before a serious accident happens – why does the document not mention this? It doesn’t fall into a category (although it should be considered) but I suppose it could be regarded as unofficial recreation and dangerous one at that so may I propose that you change the Recreation score from Amber 1 to Amber 3 please
Question 15
Do you agree that these planning policy areas cover the correct topics and themes? Please
explain your answer. Sub-heading ‘Protecting the Environment and Mitigation of Adverse Impacts on Local Residential Amenity’
There appears to be little or no consideration for the residents of Rayne in the assessment of site A9 and there isn’t even a topic included to cover ‘people’. The document seems to be written totally in favour of the site promoter and yourselves with the local community placed a very distance last. You have a section dedicated to ecology so I assume animals etc are rated as more important than people. I support conservation and even though I am pleased to see various species having proper surveys and reports I’m disappointed that there’s no thought or assessment about the close proximity of the pit to our village (the plan conveniently finishes 25 metres short of the housing thus implying a far more rural location to the site) It seems that the residents of Rayne come a very distant second,. Please explain this policy to me as I believe we are being overlooked.
Question 17
Do you agree with the Site Selection Methodology? Please explain your answer. (Provide
details of how you think the methodology might be improved OR suggest an alternative
methodology that would achieve a more robust outcome).
The scoring in some of the sections seems to be wrong. It appears to relate to the environment and community as it stands at present without taking into account the impact if the site is allowed to be developed, I have highlighted in my other questions in specific but wish to raise it as an overall observation and to question the reason for doing it this way unless it is an error in the production of the report
Question 18 states:
‘Do you agree that the distribution of preferred sites shown on Map 5 above reflects the preferred spatial strategy - that is, provides a dispersed spread of sites with an emphasis on extensions?
NO! There are already many sites in the Braintree district and your plan calls for around 50% of the county gravel to be supplied from these pits whereas the actual demand in the Braintree area is probably no more that 10 or 15% so 35% of the county’s gravel will be transported over unnecessarily long journeys generating pollution in the form of noise, dust and toxic emissions and causing a massive increase in the carbon footprint of Mid Essex? Why are the sites closer to their markets not being considered more seriously rather than concentrate the Essex gravel production mainly in the Braintree district where demand is not as high? This makes a mockery of the Amber1 score for traffic & transportation re the site A9 which will see some of the longest journeys and I suggest that Amber 3 is more appropriate for site A9
Don't leave it until Friday - you will be too late, objections must be in by 17.00 Thursday 17th.
There is an Action Group meeting at the primary school tomorrow evening at 19.00 please make every effort to attend
thank you