Hertfordshire Draft Minerals and Waste Local Plan 2040 – How To Respond

The quarry at Olives Farm is back on the agenda. According to Hertfordshire County Council’s new draft plan, the so-called Briggens Estate site will be the number one site for minerals extraction in Hertfordshire.

Known as the Hertfordshire County Council Draft Minerals and Waste Local Plan 2040, the proposal is out for consultation now, and the consultation period ends on October 31, 2022.

There will be another stage in the process next year when the Plan is examined in public but if it is approved and adopted following this, the quarry effectively will have planning consent, with just the operational details to settle. At this point it will be too late to stop it.

So we must act now to stop this madness.

The Parish Council have produced these notes to help you to make a response to the consultation objecting to the Draft Minerals Plan proposals.

We have picked out the Policies in the Plan which affect us the most. You can download our crib sheet on how to respond, or keep reading below.

POLICY 2 – MEETING SAND AND GRAVEL NEEDS- The Briggens Estate – Appendix 1

Under this policy The Briggens Estate) is designated as a Minerals Allocation Site (MAS01) It will stretch from Stanstead Abbotts to Olives Farm in Hunsdon. Planning permission will be granted in principle for sand and gravel extraction under the draft Plan if it is allowed to proceed. This leaves only matters of detail to be resolved when the Site comes forward for planning approval.

TEN GOOD REASONS WHY THE BRIGGENS ESTATE SHOULD BE OMITTED FROM THE PLAN

1. The access arrangement restricts the transport of sand and gravel from Briggens Estate to the east into Essex. This may well suit the potential operators, Tarmac, but it means that Hertfordshire’s needs will have to be met from elsewhere. So why destroy our countryside to provide sand and gravel for use outside Hertfordshire? Briggens Estate Site should be omitted from the Plan.
   
2. There will be pressure to find alternative means of access via roundabout routes. There is a high danger they will allow lorries to use the B180 and drive through Hunsdon. This will have a very severe impact on the village and conservation area. This threat cannot be ignored. Briggens Estate Site should be omitted from the Plan to eliminate this risk.
   
3. The Plan takes no account of recycled construction materials contributing to meeting the demand for sand and gravel aggregates. It therefore fails to comply with the National Planning Policy Framework and fails to support its own aspirations on – Climate Change in Policy 1 and Secondary and Recycled Materials in Policy 10.
   
4. The impact of the quarry will be widespread and damaging to the local wildlife sites particularly Lords Wood Ancient Woodland, an irreplaceable habitat on the eastern boundary. The harm inflicted on our countryside clearly outweighs any benefits to Hertfordshire and is contrary to its own Policy 15 – Biodiversity and Geodiversity.
   
5. Heritage assets in the parish nearby include listed buildings at Olives Farm settlement, St Dunstan’s Church and Hunsdon House. The close proximity and sensitivity of the settings of these listed buildings will be severely impacted by the quarry operations and consequently the Plan fails to protect and conserve our heritage contrary to its own Policy 18 – Historic Environmennt.
   
6. The site is located adjacent to Village 7 of the Gilston Area development for 1500 dwellings These new residents (over 3000) as well as our existing Hunsdon residents, will be significantly impacted by noise, dust, fumes, light pollution, odour, visual impact and vehicle movements which will result in a prolonged period of harm for over a generation. This is totally contrary to its own Policy 19 – Protection and Enhancement of Amenity and Policy 20 – Health and Wellbeing.
   
7. The landscape will be unavoidably permanently altered and visually destroyed by the extraction operations. No amount of recovery in 25 years time will make up for this. This is unacceptable and contrary to its own Policy 16 – Landscape and Green Infrastructure and also contrary to Policy HE3 of the Hunsdon Area Neighbourhood Plan – Landscape Character and Cherished Views.
   
8. The Site is traversed by Harcamlow Way an important regional RoW which would have to be diverted around the perimeter drastically. This is contrary to Policy 25 – Public Rights of Way.
   
9. The openness of the Green Belt countryside between Stanstead Abbotts and Harlow, already compromised by the Gilston Area Development, will be destroyed by quarrying activities leading to an urban sprawl between Harlow and the A10. Green Belt policy does allow minerals development but only if the openness of the Green Belt is preserved. It won’t be and the cumulative effect of the Gilston Development and this Plan for Briggens Estate causes too much harm which is not outweighed by the benefits, contrary to the NPPF and its own Policy 14 – Green Belt and Policy 26 – Cumulative Impacts.
   
10. The Site Selection Methodology used to support the Plan is flawed in that 9 potential sand and gravel sites were omitted from the process because of ‘lack of information’. Also, the assessment of Briggens Estate overlooked 4 key elements of the environmental impacts which would have lowered its ranking (impacts on local wildlife site, Village 7, landscape cherished views (Green Belt openness) and transport impacts). These errors must be rectified and all the Sites reassessed.

In summary, the brief for the Briggens Estate Site and a proper assessment of its impacts leads to the conclusions that its inclusion in Policy 2 of the Plan fails to meet the Draft Plan’s Objectives No’s 1, 3, 5, 6, 7, 8 and 10.

Briggens Estate Site should be rejected and omitted from this Plan

POLICY – 4 – SITE SAFEGUARDING AND CONSULTATION AREAS

The Draft Policies Map shows two Waste Management Sites within the Parish of Hunsdon.

WMS 93 – Hunsdon Skip Hire

This site has a certificate of permitted development and has been operating in excess of the licenced tonnages. The lorries associated with these operations are unsuitable on the narrow lanes around the village and represent a real danger to road users particularly pedestrians, equestrians and cyclists.

HCC have been reluctant to take any action to get the operators to conform to the permitted use. The Environment Agency has had to take enforcement action against the operators in recent times. It is not in the community’s overall interest to have the site safeguarded as alternative use of the land could be considered. The operations may serve a useful purpose regarding waste management but should be relocated to more suitable facilities.

WMS 93 should not be safeguarded and removed from the Policy Map.

WMS 110 – Hunsdon Airfield

This WMS is located at Hunsdon Lodge on the disused airfield within the land designated under Policy GA1 of the Local Plan for community open space. The HGV’s associated with operations represent a very real danger to highway users on Church Lane and Acorn Street. The continued use for waste processing is therefore totally unacceptable and WMS 110 should not be safeguarded and removed from the Policy Maps.

HOW TO RESPOND

The Waste and Minerals Plan website offers three alternative routes to submitting your response. You may wish to select all or some of the issues we have identified or of course add you own points in your own words.

You can use the on-line form which requires personal details and then your written response related to specific polices and/or text in the draft Plan.

Alternatively, there is a form available to download and email with the same format here: https://www.hertfordshire.gov.uk/media-library/documents/waste/mwlp/mwlp-2022-reg-18-response-form.docx

There is always the option to write and send your response direct to:

Minerals and Waste Planning Policy Team
Spatial Planning Unit (CHN216)
Hertfordshire County Council
County Hall
Pegs Lane
Hertford
SG13 8DN

Or to send it via email to mineralsandwaste@hertfordshire.gov.uk

Whichever route you choose please copy your response to our County Councillor, Eric Buckmaster at Eric.Buckmaster@hertfordshire.gov.uk