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Curlews calling .....

for the proposed Lime Kiln Farm, Reydon gravel pit to be stopped

View objections to the planning application for a gravel pit at Lime Kiln Farm, Reydon by:-

To have your say follow the link to the Suffolk County Council website


Simon Loftus
Bulcamp House
Halesworth
Suffolk IP19 9LG

Planning Application SCC/0039/19W Lime Kiln Farm Wangford Reydon, Quarry Hill Road Wangford Reydon Suffolk NR34 8AR

I am writing to Object to the above application on the following grounds -

Wrong time, wrong place

1. This application relates to a proposed gravel pit which forms a highly contentious part of a Suffolk County Council's Draft Minerals and Waste Management Plan. That Plan is currently the subject of a formal Review by a Planning Inspector and the proposals for the Lime Kiln Farm quarry have already been the subject of many representations to the Council and to the Inspector. The planning application should not even be considered until the outcome of that review is known.

2. The application may even be invalid, since the location is repeatedly referred to as Wangford, whereas the fields lie in Reydon. This error has sometimes prevented Reydon residents being notified or consulted about the proposed development, or meant that they have learnt about the proposals at the last minute.

No 'exceptional circumstances' to justify contravention of planning policy.

3. Paragraph 172 of the National Planning Policy Framework relates to development within an AONB amongst other designations. The proposed development lies wholly within the Suffolk Coast and Heaths AONB and is a major development. Paragraph 172 states that: -

Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

4. Previous judgements by Planning Inspectors have emphasized that 'exceptional circumstances' cannot be cited as justification for such developments except where immediate and pressing need can be proven. It is not sufficient to envisage a possible future scenario in which 'exceptional circumstances' might be demonstrated. Since the Draft Minerals Plan makes provision for an over-supply of more than 30% against forecast future need, and since there would still be an over-supply of 20% if the Lime Kiln Farm site were excluded from the Plan, 'exceptional circumstances' cannot be cited as justification for this gross violation of the AONB planning guidelines.

5. This is even more relevant when it is acknowledged by the applicants that a significant proportion of the gravel that they hope to extract from this site would be used outside Suffolk and indeed abroad. There is no public interest served by this proposal, which is simply designed to protect the commercial interests of a vast multinational company.

Specious claims for 'restoration' and 'nature conservation'

6. The application is headed 'Proposed extraction of aggregate with restoration to agriculture and nature conservation'. This is a specious attempt to imply environmental benefit where none exists. The proposal would irrevocably damage a protected landscape - felling trees, removing hedgerows, destroying wildlife habitats and undermining public confidence in the planning guidelines that are designed to protect the environment - at a time when there is ever-increasing concern about increasing environmental pollution and the loss of bio-diversity.

7. I can speak with some experience on this subject, as former Chairman of Adnams. In 1995 we acquired a worked-out gravel pit, east of the applicant's site, and developed a conservation plan in conjunction with Suffolk Wildlife Trust. This involved replanting all the perimeter hedgerows, clearing clogged ponds, preserving a sand-martin colony and various other works including planting a small wood in part of the low-lying area. Ten years later, when we built the award-winning Distribution Centre (one of the 'greenest' buildings in Europe at the time of its construction) all the perimeter planting was flourishing but the wood had hardly grown at all, because the fertility had been scooped out of the site during the gravel extraction. Even now, over twenty years after that conservation scheme was undertaken and despite the application of vast amounts of organic material to fertilise the new woodland, there is still very little noticeable growth - and the whole of that low-lying area remains dry, almost barren. This demonstrates the difficulty of regenerating worked-out gravel pits in geologies such as this. The applicant's claim that they will create 'an area of species rich grassland at the base of the restored landform' should be read with considerable scepticism.

8. The applicant states that no new material will be brought onto the site to assist the process of regeneration, but that an area of 'the best and most versatile agricultural land (Grade 3a)' will be created - despite the existing land only being classified Grade 3b. That implies that most of the topsoil from the existing fields will be re-used to enhance the agricultural quality of a smaller acreage (to the commercial benefit of the farmer), leaving the rest of the site less fertile than before, to the detriment of the landscape and its wildlife.

9. The claim that a radically re-shaped and impoverished landscape will somehow compensate for decades of environmental damage by creating a pond or two and some corners where different species may thrive is entirely at odds with the obligation to respect the existing quality and character of the AONB.

10. On the Application Form submitted with this proposal the Applicants were asked whether any 'designated sites, important habitats or other biodiversity features' might be adversely affected, 'on land adjacent to or near the proposed development’. They answered 'No', despite the proximity of the Hen Reedbeds (a nature reserve of national importance) and the Blyth tidal estuary - a haven for vast numbers of waders and other birds, including avocets, marsh harriers, curlews, lapwing, etc. Such habitats are not limited by lines on maps - their surroundings are vital to the eco-system, and even the applicants admit the presence of curlews on their site. Other endangered species are probably found there, despite the conclusions of a very cursory survey on a few hours one winter. To destroy nearby agricultural land, on which many of these estuarine species feed or hunt, or roost at high tide, is environmentally unacceptable.

11. The Habitats Regulation Assessment (HRA/AA) conducted for this site ignored the precautionary approach and imperative of no harm (para 1.4.7), which is a legal requirement. It admitted that Likely Side Effects were determined to occur but suggested completely inadequate measures of mitigation. In any case, the People & Wind judgement makes clear that mitigation cannot be considered in the case of Likely Significant Impacts.

12. Repeated mention is made of the intended use of glyphosate herbicide in the aftercare programme for the site. Numerous studies have demonstrated the harmful effects of glyphosate herbicide on insects and other species and of its reduction of plant bio-diversity, on which these insects depend. No responsible environmental programme would advocate its use.

13. Every previous commitment to limit the timescale of gravel extraction and to restore the landscape has been consistently broken, including commitments made when permission was granted to extend the existing quarry - to restore that site and provide extra habitat in order to make a 'wildlife haven' linking the Hen Reedbeds to Reydon Wood. Nothing has been done to fulfil those undertakings and the company is now trying to amend these conditions. This failure to honour existing agreements casts serious doubts on promises to deliver 'ecological' benefits in the present application.

Conclusion

To permit this proposal to go ahead would be to allow one company's commercial priorities to dictate planning policy, flouting all the guidelines (local and national) that have helped to preserve Suffolk as a place renowned for its natural qualities - its landscape, its wildlife, the cultural creativity that has sprung from this special county - and the tourism that responds to these attributes. No case has been made for 'exceptional circumstances'.

However cunningly disguised in the language of planning consultants the underlying argument for such a substantial breach of these guidelines is the old one of bad precedent - 'Why should you prevent me beating my wife when you have allowed me to do so for all these years?'