SHENINGTON WITH ALKERTON
MINERALS ACTION GROUP
Preliminary Response
To
Environmental Statement Submitted by
Trustees of the Needler D4 Settlement
in Connection with
Review of Mineral Planning Permissions (ROMP)
November 2011
Contents
1 Introduction & Executive Summary 1
2 General 1
2.1 Poorly Formulated Conditions 1
2.2 Base Plan Inaccuracies 1
2.3 Lack of Unworked Buffer Zones 2
2.4 Prevailing Winds 2
2.5 Traffic 2
3 Socio-Economic Impact 3
3.1 Lack of Consultation with Local Stakeholders 3
3.2 Impact on Shenington School 3
3.3 Shenington Doctor’s Surgery: Unrecognised Sensitive Receptor 3
3.4 Impact on Sugarswell Business Park 3
3.5 Impact on Shenington Airfield and Gliding Club 4
3.6 Impact on Middle Hill Farm, Shutford 4
3.7 Net Detrimental Effect on Local Economy 4
3.8 Loss of Housing 5
3.9 Impact on Agriculture 5
4 Air Quality: Dust 5
4.1 Wind Speed and Direction Not Considered 5
4.2 No Baseline Measurement of Dust 5
4.3 Dust Impact on Shenington School and the Surgery 6
4.4 No Mention of Crushing 6
4.5 Lack of Dust Action Plan 6
5 Noise 6
5.1 Wind Speed and Direction Data Not Considered 6
5.2 Base Line/Background Noise Measurements Not Credible 6
5.3 Quarry Operations Noise Estimates Not Credible 7
5.4 Karting: Cumulative Noise Effects Not Considered 7
5.5 Noise Impact on Shenington School and Doctor’s Surgery 8
5.6 Other Sites Subject to “Major Adverse” Noise Impact 8
5.7 Missing Noise Assessment for Site 6 8
5.8 Lack of Provision for Noise Monitoring and Corrective Enforcement 8
6 Extraction Plans 9
6.1 Lack of Constraints on Phasing of Extraction 9
6.2 Nature of On-Site Process Plant 9
6.3 Blasting 9
7 Roads 9
7.1 Shortcomings of Local Road Network Ignored 9
7.2 Questionable Traffic Survey Data 10
7.3 No Swept Paths (Turning Circle Provision at Junctions) 10
7.4 No Speed Surveys Carried Out 10
7.5 No Visibility Splays Specified 10
7.6 Restricted Road Widths Significantly Understated 10
7.7 No Routeing Agreement or Traffic Management Plan 10
7.8 Rural Road Users Not Properly Considered 11
7.9 No Details of Access Roads to Sites 1N and 1S 11
8 Settings and Surroundings 11
8.1 Impact on the AONB 11
8.2 Impact on Conservation Areas 11
9 Ecology 11
9.1 General Points 11
9.2 Impact on Hedgerows 13
9.3 Underestimation of Impact on Protected Species 13
10 Footpaths and Rights of Way 14
10.1 Impacts on Footpaths and Rights of Way 14
11 Other 15
11.1 Light Pollution 15
11.2 Buffers Around Electricity Infrastructure 15
12 Conclusions & Recommendations 15
Shenington with Alkerton Minerals Action Group Preliminary ROMP Response
1 Introduction & Executive Summary
This short report is a preliminary response by the Shenington with Alkerton Minerals Action Group (SWAMAG) to the Shenington ROMP Environmental Statement (ES) report submitted by Barton Wilmore on behalf of the Trustees of the Needler D4 Settlement (the Applicant).
SWAMAG comprises a group of Shenington and Alkerton villagers, formed with backing of the Parish Council and village residents, to formulate an effective response to the ROMP.
The introduction to the ES states (subsection 1.12, page 3):
“The aim of the ES is to assist OCC in providing an up to date set of conditions, in accordance with current environmental standards, to be imposed on the original Shenington permission so that the recommencement of extraction will have a minimal environmental effect on the sites and their surroundings.”
Measured by this objective, the ES fails on numerous counts, by a wide margin. It contains numerous inaccuracies and omissions, some of which appear to be wilful, given that they serve the interests of the Applicant to the detriment of local stakeholders, i.e. local residents, farmers, businesses and those using the countryside for leisure activities.
· As it stands, we consider the ES to be fundamentally flawed and unfit for purpose. The purpose of this report is to highlight inaccuracies and omissions in the ES.
· The Applicant has already been granted considerable time (including a six month extension) to produce this flawed report.
· We ask OCC to consider whether the Applicant has failed to submit an ES meeting the requirements of the relevant legislation and the Scoping Opinion issued by the MPA in May 2010. If that is judged to be the case, we respectfully request that Planning Permission 1899/9/6 be considered null and void and that OCC invokes its powers of prohibition in accordance with statutory requirements.
2 General
2.1 Poorly Formulated Conditions
The ES includes a proposed list of conditions, which are in many respects too loose and fail completely to address some key issues. In comparison with the conditions under which other quarries in the area such as Wroxton and Woodeaton operate, numerous key conditions are entirely missing. These include conditions with respect to buffer distances between the quarrying operations and dwellings, phasing of sites, and a viable transport plan. Each of these shortcomings will be addressed in more detail below.
2.2 Base Plan Inaccuracies
The base plans used are inaccurate, and evidently not based upon diligent on-the-ground surveys; the Applicant admits as much within the ES (Chapter 9, page 10, paragraph 9.35 is one example).
Most worryingly, numerous buildings are missing from these plans, including (but not restricted to) Balscote village hall and several buildings at Sugarswell Business Park. In addition we have identified several dwellings which are seemingly removed to make way for quarrying.
2.3 Lack of Unworked Buffer Zones
The ES includes no allowance for explicit unworked buffers between the workings and existing dwellings and structures. This is particularly egregious with regard to Shenington Church of England Primary School (the “School”) and Shenington doctors’ surgery (the “Surgery”) (both site 7 North), Sugarswell Business Park (site 6) and Shutford (site 3).
The MPA’s May 2010 Scoping Opinion states that in relation to Shutford and Shenington “there must be a detailed consideration of unworked buffer zones”; this requirement has clearly been ignored by the Applicant.
This constitutes a serious, fundamental flaw in the ES, evincing the Applicant’s unwillingness to voluntarily minimise the impact of quarrying on local stakeholders.
At a smaller scale, no allowance has been made for a buffer between any quarry workings and roads/site boundaries; we understand that a minimum 10m buffer is specified at Wroxton quarry.
2.4 Prevailing Winds
Wind speed and direction data have not been considered in the ES. MPS2 (Annex 1 paragraph 1A.10) recognises that these are important in considering the likely behaviour of dust and noise at mineral sites; therefore the ES lacks the information necessary to set appropriate conditions.
Data provided by the Met Office from its Banbury observation point shows that the prevailing wind direction locally is west-south-westerly, with a modal (most frequently occurring) wind direction of 238 degrees, with a median speed of 11km/h; in effect the wind blows from a southerly through to westerly direction for more than 50% of the time.
2.5 Traffic
It is evident that the construction of the local road network has not been assessed properly in the ES. It is self-evident, even on cursory inspection of the proposed routes that there are very significant construction deficiencies, which render the roads completely unsuitable for the proposed volume of HGV traffic.
The local unclassified road network is unlit, without footways and is of inadequate width and construction. Visibility splays at site access points are not identified within the ES.
In terms of highway widths the ES makes sweeping and erroneous statements as to road dimensions. Aside from the element of Sugarswell Lane north of Sugarswell Business Park highway widths are significantly less than the required 5.5m for HGVs to pass (source: Manual For Streets) and in the majority of cases below 5.0m. In places Rattlecombe Road, Shenington Road and Alkerton Road narrow to 4.2, 3.95 and 3.8m respectively.
The ES does not address the needs and concerns of rural road users such as school-run traffic, horses, the local hunt, cyclists and walkers. The unclassified roads earmarked for mineral haulage are narrow, and frequently travelled by these potentially vulnerable users.
3 Socio-Economic Impact
3.1 Lack of Consultation with Local Stakeholders
The Applicant has not carried out any pre-application consultation with local stakeholders. This reinforces the impression that the ES has been constructed solely with the Applicant’s interests in mind.
3.2 Impact on Shenington School
Section 5.2 of the ES states: “As the recommencement of extraction in these sites will not generate any additional population no significant effects on social infrastructure, such as health and education, are anticipated.” This fails to account for the direct impact of quarrying on the School and the Surgery.
The School is situated around 75m east of site 7 North. The School is well-regarded, with an Ofsted rating of “good” for overall effectiveness, and pupil intakes being oversubscribed in recent years. There are currently 105 pupils and 9 full-time equivalent staff.
The outside areas at the School include dedicated outdoor teaching spaces for the Reception class (4 and 5 year olds) on the north-west (quarrying) side of the school building, an outdoor classroom to the south of the building and playing fields used for play and sports abutting site 7 North.
We wish to strongly assert our view that the ES significantly understates the potential impact of dust and noise from quarrying on the School and, in particular, takes no account of the direction of the prevailing wind. We therefore request that the MPA takes a diligent and precautionary approach and insists on a minimum 400m buffer from the School’s western boundary to compensate for the prevailing westerly wind.
3.3 Shenington Doctor’s Surgery: Unrecognised Sensitive Receptor
The Surgery is located adjacent to the School, 120m to the east of site 7 North. The practice consists of four doctors and two practice nurses and offers a wide range of GP services on behalf of Warwickshire PCT, serving around 2,500 patients. The catchment area encompasses Fenny Compton, Northend, Avon Dassett, Warmington, Shotteswell, Hornton, Horley, Wroxton, Balscote, Arlescote, Shenington, Epwell, Edgehill, Tysoe, Gaydon, Knightcote, Boddington Mollington and Farnborough.
The ES fails to acknowledge the existence of the Surgery, and completely fails to recognise that it is a high sensitivity receptor as defined in MPS2 Annex 1 Table 1A2, given that it provides injections and other medical procedures which require equipment to be sterile.
3.4 Impact on Sugarswell Business Park
No account is taken of the impact on Sugarswell Business Park, which will effectively be surrounded by the site 6 operations, with no buffer zone proposed; indeed several existing buildings, including two dwellings and six commercial/business units housing 8 businesses, plus the main car parking area, are removed to make way for quarrying, according to the extraction plans. The ES also proposes that the existing access road for the business park is shared by quarry traffic, which would be hazardous.
The park currently hosts around 25 diverse service sector businesses, which provide employment for around 120 people. Even setting aside the proposed removal of eight buildings, it seems highly likely that many tenants of the park would choose not to renew their leases if quarrying were to proceed, creating a substantial loss for the local economy.
3.5 Impact on Shenington Airfield and Gliding Club
The ES does not acknowledge that Shenington Airfield, which is impinged upon by the quarry workings of site 7 North, is an active airfield, operated by Shenington Gliding Club. The club flies throughout the year, having 121 active members with 3 or more professional staff employed full time between April and October. It is a registered charity, a registered centre for junior gliding and caters for disabled pilots with specially adapted aircraft. Approximately 600 visitors attend per year for organised training or other activities.
As proposed, site 7 North would bisect the airfield’s most useful SW/NE runway, taking the hard-surface prevailing-wind runway out of use. Furthermore, the club’s chairman is of the opinion that the proximity of quarrying operations, especially the creation of bunds, would leave low-flying aircraft potentially out of sight on approach, which would render flying activities unsafe. As a result the airfield and gliding club would close.
3.6 Impact on Middle Hill Farm, Shutford
The ES does not acknowledge that the main dwelling, ancillary residential unit, and attendant farm buildings at Middle Hill Farm, Epwell Road, Shutford will be lost through the quarrying of site 3. This equates to the loss of two family homes and business. In addition to the two dwellings proposed demolished at Sugarswell Farm this is a significant negative impact on which the ES is, incredibly, silent.
3.7 Net Detrimental Effect on Local Economy
The ES states that quarrying operations will have a “minor beneficial effect” through the creation of up to 40 jobs. This assertion is not credible.
Only if all sites were operated simultaneously would 40 jobs be created, and these would be short-lived. This scenario seems very unlikely, given the lack of demand for the product (crushed ironstone aggregate) and the inability of the local road infrastructure to support this scale of extraction. Assuming, more realistically, that one site were operated at a time, while another was restored or prepared, we estimate that medium term job creation from quarrying would amount to no more than 10 full time jobs.
Against this, must be offset the loss of employment from Sugarswell Business Park and Shenington Gliding Club, which would probably amount to significantly more than 10 jobs.
In addition, the ES fails to appreciate the concentration of high value economic activity within the affected villages of Shenington, Alkerton, Balscote, Shutford and Epwell. There are numerous very successful small- to medium-sized businesses operating from the villages, generating significant revenues for the local economy. Quarrying activity would doubtless encourage many of these businesses to leave.
3.8 Loss of Housing
We have established that at minimum four dwellings are proposed demolished to make way for quarrying. The ES is astonishingly silent on this fact. This is a very significant impact and consequently a very serious omission in the ES.
3.9 Impact on Agriculture