The Friends of the South Downs believe that there is not a rising demand for ‘soft sand’ and that we see no reason why further sites should be allocated in West Sussex; especially those in the National Park.
What’s at stake? The review shortlisted 9 sites. 7 inside the National Park and 2 just outside (starred *) the Park:
- Buncton Manor Farm (new site), Washington
- Chantry Lane (Extension), Storrington and Sullington*
- Coopers Moor (Extension) Duncton
- Duncton Common (Extension) Duncton and Petworth
- East of West Heath Common (Extension) Harting and Rogate
- Ham Farm (new site) Steyning and Wiston*
- Minsted West (Extension) Stedham with Iping
- Severals East (new site) Woolbeding with Redford
- Severals West (new site) Woolbeding with Redford
These, as well as those soft sand sites previously considered during the preparation of the Joint Minerals Local Plan, will be assessed for their suitability for potential allocation. The ‘soft sand review’ sets out three main issues for consideration which are:
- the need for soft sand;
- the strategy for soft sand supply; and
- potential sites and site selection.
The review relies solely upon the ‘Local Aggregates Assessments’ (LAA) to predict ‘needs’ from 2019 to 2033 (14 years). This LAA also relied up historical sales of the material to assess annual demand alongside the usage and to extrapolate future demand.
The views and comments of the Friends of the South Downs (South Downs Society) are:
Local Aggregates Assessments (LAA)
We understand that the Mineral Products Association not only writes the guidance on preparation of Local Area Assessments but they also sit in the Aggregates working parties. If this is the case their influence should be counterbalanced by the inclusion of environmental bodies.
The West Sussex LAA surveys between 2013 and 2018 shows there is a less than level demand for this type of mineral. If this trend continues, and there seems to be no evidence it won’t, the need for this aggregate will reduce to an extent where the predicted 2033 shortfall estimated is more than compensated for by the lack of demand.
The LAA of 2017 states that existing reserves are provided by several sites and currently amount to 2,754,000 tonnes. The reader might assume that the existing supplies available from the 6 sandpits already in use would suffice until 2033. However, by following government advice in how to calculate future demand the requirement suddenly reaches 4,426,720 tonnes (3-year average x 15), 1,593,833 tonnes more than the highest demand scenario in the LAA! This simplistic and unscientific method of estimating future demand produces artificially high requirements and therefore would drive the planning authority to allocate far more land than is actually required to meet the demand.
The Society also question the validity of the ‘Sustainability Assessment’(SA) referred to in the consultation. This document has 693 pages. We have grave concerns about the findings of this document. There are many worrying statements – too many to reiterate here. We recommend that this SA document (And therefore the SSR document) should be withdrawn and undergo a complete review. Also, it ought to be examined in public before being used again as a basis for planning any mineral extraction.
We disagree with the WSCC assumptions where they say “The SA inevitably relies on an element of subjective judgement.” This seems very odd – is WSCC saying therefore that National Parks, ANOB and SSSIs are created by a subjective judgement? The creation of these areas have been the result of considerable professional input whereas the LAA calculations have never be tested to see if they have any accuracy in forecasting future demand. We also have grave concern about the ‘Proposed Vision and Strategic Objectives’. How can the minerals plan provide a positive vision when the effect of extracting the material will despoil the National Park and cause a major increase in diesel pollution from 40 Ton HGVs along narrow roads and through villages in the National Park? Also can the plan have a positive effects on the social wellbeing of the community – health, wellbeing and amenity of residents?
‘Demand’ figures are flawed
We believe that basing future soft sand requirements on future housing demand figures is flawed since the method of construction has changed considerably over the past few years whereby the requirement for wholly brick built houses is reducing. We believe that housing construction uses far less bricks than even a few years ago and that forecasting should take account of changes in the design of housing and therefore the use of soft sand for mortar.
Government Guidelines (National and regional guidelines for aggregates provision in England 2005-2020) support our view that alternatives to the use of basic minerals should be used when collecting evidence: Section 9 says ‘matters for particular attention in monitoring will include evidence of trends in: construction activity within the economy AND the use of alternatives to primary aggregates. Alternatives to primary aggregates have not been considered in this report.
Today modern housing construction does not continue the tradition of an 11 inch double brick wall with a cavity. Yes, the cavity is there but the inner skin is very rarely made of brick. The outer skin could be made of brick but even if it was in every case this would halve the need for mortar associated with brick walls. We believe this trend will increase in the future. Many new homes are timber framed with an outer brick skin. In any event there is a need to reduce the reliance on conventional brick design for houses because of the shortage of brick clay. House design is changing, often being built as a shell and a framework with only brickwork being the outer layer. Very few industrial buildings use bricks and mortar. One only has to look at the various trading estates on the outskirts of towns to see this is the case. Likewise, supermarkets and other retail businesses are often not constructed of bricks and mortar. Public realm buildings are often built without extensive brickwork. Design features may include some brickwork but not to the extent of the traditionally brick-built Town hall, medical centres, hospitals and other public round buildings.
We have already reached the stage where many industrial and commercial buildings contain very few brick components and therefore very little mortar. Supermarkets shopping centres and trading estate buildings have virtually no bricks in their construction. They may use concrete but don’t have large requirements for ‘building sand’ as they don’t use bricks or block construction. There are many other systems and designs used todaywhich don’t use ‘builders sand’ including: Timber frame homes, Modular Units, Structural Insulated Panels (SIPs), Precast Concrete, Insulated Concrete Forms (ICFs)
Value of the Environment
No ‘monetary value’ placed on the environmental cost of mining in a National Park and the resultant despoliation. There should be a comparison made between the loss of natural landscape and the value of the the mineral won from excavation and mining.
We are concerned about the risk to negative effects to the hydrology of our heathland sites, many of which are SSSIs and lie on building sand. Quarrying can seriously change the hydrological regime on any given site and through that bring about vegetation changes to the SSSI, that consideration does not appear to be covered in the “Water Environment” considerations. Coopers Moor (SDNP) Duncton Common is a classic example, as it runs very close to Lavington Common SSSI which has some excellent wet heath. That that wet heath could be seriously affected by lowering of the water table bought about by nearby extraction and or dewatering.
Severals East and West
The two sites, Severals East and West, total 75 ha and are in single ownership of the Cowdray estate. They comprise large areas of plantation forest including areas of ancient woodland in Severals West. They are located within an extensive tract of greensand west of Midhurst and between Midhurst Common immediately to the east and a series of commons (Stedham, Iping and Trotton) to the west.
They are criss-crossed by a network of public footpaths, bridleways and permissive paths and the Serpent Trail links them all. They provide valuable opportunities for quiet informal recreation for local residents and visitors to this deeply tranquil area of the National Park which is easily accessible by the A272 and with a bus service between Petersfield and Midhurst.
Even well before the designation of the South Downs National Park, the two Severals sites were not allocated in the West Sussex Minerals Local Plan of 2003 and were not considered acceptable in the Minerals Issues and Options paper of 2005 due to the landscape and conservation impact of mineral working. They were also rejected in the 2018 joint Minerals Local Plan for the same reasons and having regard to the NPPF which affords the highest protection of land within a National Park. The Severals East and West are identified in the current consultation as having a medium/ high sensitivity to landscape and nature conservation;. Various Sites of Nature Conservation Importance (SNCI) lie close to the Severals on the east, north and west.
Although the Severals lie adjacent to the A272, even if HGVs were required to access the sites only from the west (i.e. from the A3) and so avoiding Midhurst, they would have an environmental impact on the two close-knit villages of Trotton and Rogate which already suffer from noise and pollution of HGVs.
Large amounts of money have been spent to restore and improve the Severals heathland (estimated to be £300,000 to Cowdray Estate and £2.47 million to Heathlands Reunited). Revisiting this issue every few years is very costly for residents and parishes. It causes great distress, onus should be on those offering sites why the ‘exceptional reasons’ for exclusion no longer exist.
With the development of quarries comes HGV traffic. We are concerned that no estimates of lorry movements have been included in the SSR. This should be added before the plans are progressed. The public should then be allowed to comments on any traffic modelling. Many section of A roads east to west are unsuitable for an increase in HGV traffic, such as:
Duncton Common W of Heath End and Coopers Moor S of Heath End:
Access via A285 north across the narrow medieval Coultershaw bridge and through Petworth or south to the A27 via Duncton and Halnaker. The A285 is known as the most dangerous single carriageway A class road in England.
Access along the A 272 east through Petworth or west across the narrow medieval light-controlled Trotton bridge and the villages of Trotton,, Rogate and Sheet to the A3.
East of West Heath Common
Via a narrow lane across medieval bridge to the A272 and though Sheet to the A3.
WSCC Advisory Lorry Route shows that the access road for all ‘shortlisted’ site are via, what they define as single carriageway ‘local’ routes.
In any assessment the following planning policies should be taken into account:
SDNP policies including:
- Core Policy SD1: Sustainable Development
- Core Policy SD2: Ecosystem Services
- Strategic Policy SD4: Landscape Character
- Strategic Policy SD9: Biodiversity and Geodiversity
- Development Management Policy SD11: Trees, Woodland and Hedgerows
- Strategic Policy SD17: Protection of the Water Environment
- Strategic Policy SD19: Transport and Accessibility
- Strategic Policy SD45: Green Infrastructure
NPPF Para 204.
Planning policies should:
b) so far as practicable, take account of the contribution that substitute or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials, …
The SSR report does not state that any investigation is taking place into any alternatives
NPPF para 205:
When determining planning applications, great weight should be given to the benefits of mineral extraction, including to the economy. In considering proposals for mineral extraction, minerals planning authorities should:
a) as far as is practical, provide for the maintenance of landbanks of non-energy minerals from outside National Parks, the Broads, Areas of Outstanding Natural Beauty and World Heritage Sites, scheduled monuments and conservation areas;
Para 207 of the NPPF states “maintaining landbanks of at least 7 years for sand”. The planning period for the Joint Minerals Local Plan (JMLP) is 14 years – to 2033.
Para 207 of the NPPF states
Minerals planning authorities should plan for a steady and adequate supply of aggregates by:
f) maintaining landbanks of at least 7 years for sand and gravel and at least 10 years for crushed rock, whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised;
Here are some background notes:
The Joint Minerals Local Plan (adopted in July 2018) required West Sussex County Council and the South Downs National Park authority, to undertake a review of the approach to planning for ‘soft sand’ (Or builders sand in layman’s terms).
The public consultation at this stage finished has now finished. The authorities now have to consider the comments and the need or otherwise of the supply and demand for soft sand up to 2033. Last year businesses and landowners were asked to put forward sites. In January 2019 the two authorities issued their report which was subject of the public consultation which closed last month (March 2019). The officials are now considering the comments received. In the next few months a schedule of modifications to the existing Joint Minerals Local Plan will be published. Then there will be a final period of public consultation (Called regulation 19) to allow representations to be made but only on the ‘soundness’ and ‘legal and procedural compliance’ before submission to the Secretary of State for independent examination by a Government-appointed Planning Inspector.