Object
Initial Consultation document
Representation ID: 92152
Received: 13/08/2018
Respondent: Mr Thomas Pringle
There are a number of areas within the site assessment which are undeveloped and there has been a lack of transparency around the consultation process which will have resulted in many residents being unable to make an informed contribution. The following need to be addressed.
1. advertised consultation deadline stated was incorrect (evidence can be provided on request that the advertised deadline was 4 days later (17/08/18) than the actual deadline of 13/08/18, unfortunately the current web based response system does not allow for evidence to be attached). This should be compensated by an extended consultation deadline. Additionally, the contributors to the site assessment document are unclear. This lack of transparency also raises questions around the fairness and trustworthiness of the process, and therefore the site assessment document, and should be investigated.
2. no evidence was provided in the site assessment document that 'even without mitigation, adverse dust impacts from sand extraction sites are uncommon beyond 250m from the nearest dust generating activities' (see amenity sub-section). The raised public health and river siltation risk should be outlined explicitly within the site assessment document and therefore mitigation addressed in any subsequent application stages.
3. modification to PRoW impacts on daily living and quality of life of all residents in the area as this is a well used outdoor space providing boundless benefits to local people. Even if right of way to the river is maintained the public will have to enter a zone of increased risk to respiratory and auditory health and the mental health benefit of the current tranquil setting will be lost. Therefore, the public health impact should be outlined explicitly within the site assessment document and therefore mitigation addressed in any subsequent application stages.
4. Noise pollution is under-addressed within the site assessment document. It would be unfair to residents (human and fauna) to have another noise pollutant in the area and therefore mitigation must be addressed in any subsequent application stages.
5. The site assessment document does not adequately address the cumulative impact of all proposed extraction on the river Nar. Independent surveys and prediction modelling must be used to ascertain the combined impact of silica sand extraction along with the sand a gravel extraction proposed in 'MIN 19 and MIN 205 - land north of river Nar, Pentney'.
6. High risk of damage to the river Nar's chalk bed is under-addressed in the site assessment document. The river is of great importance and has already been classified as being in only 'moderate condition' (Environment Agency) due to current land uses of the surrounding area. Any mitigating scheme provided within subsequent application processes needs to specifically address how the river's integrity will be maintained and how the target of 'good condition', set by the Environment Agency for 2027, will be achieved.
7. Lack of explicate involvement of statutory bodies in the site assessment document. The Environment Agency and organisations such as the Rivers Trust must be consulted. Any mitigating scheme provided within subsequent application stages can be assumed to be un-evidenced and thus unacceptable unless these agencies are involved.
Summary:
A number of areas within the site assessment document are undeveloped including: a lack of evidence around the impact of dust from extraction, non-reporting of the Environment Agency's targets for River Nar's condition, under-assessment of the impact on public health and a lack of consideration for the cumulative effects of multiple extractions around the River Nar. There has also been a lack of transparency around the consultation process, including inaccurate deadline dates being advertised, which will have resulted in many residents being unable to make an informed contribution. On these grounds I must object to the proposed plans.
There are a number of areas within the site assessment which are undeveloped and there has been a lack of transparency around the consultation process which will have resulted in many residents being unable to make an informed contribution. The following need to be addressed.
1. advertised consultation deadline stated was incorrect (evidence can be provided on request that the advertised deadline was 4 days later (17/08/18) than the actual deadline of 13/08/18, unfortunately the current web based response system does not allow for evidence to be attached). This should be compensated by an extended consultation deadline. Additionally, the contributors to the site assessment document are unclear. This lack of transparency also raises questions around the fairness and trustworthiness of the process, and therefore the site assessment document, and should be investigated.
2. no evidence was provided in the site assessment document that 'even without mitigation, adverse dust impacts from sand extraction sites are uncommon beyond 250m from the nearest dust generating activities' (see amenity sub-section). The raised public health and river siltation risk should be outlined explicitly within the site assessment document and therefore mitigation addressed in any subsequent application stages.
3. modification to PRoW impacts on daily living and quality of life of all residents in the area as this is a well used outdoor space providing boundless benefits to local people. Even if right of way to the river is maintained the public will have to enter a zone of increased risk to respiratory and auditory health and the mental health benefit of the current tranquil setting will be lost. Therefore, the public health impact should be outlined explicitly within the site assessment document and therefore mitigation addressed in any subsequent application stages.
4. Noise pollution is under-addressed within the site assessment document. It would be unfair to residents (human and fauna) to have another noise pollutant in the area and therefore mitigation must be addressed in any subsequent application stages.
5. The site assessment document does not adequately address the cumulative impact of all proposed extraction on the river Nar. Independent surveys and prediction modelling must be used to ascertain the combined impact of silica sand extraction along with the sand a gravel extraction proposed in 'MIN 19 and MIN 205 - land north of river Nar, Pentney'.
6. High risk of damage to the river Nar's chalk bed is under-addressed in the site assessment document. The river is of great importance and has already been classified as being in only 'moderate condition' (Environment Agency) due to current land uses of the surrounding area. Any mitigating scheme provided within subsequent application processes needs to specifically address how the river's integrity will be maintained and how the target of 'good condition', set by the Environment Agency for 2027, will be achieved.
7. Lack of explicate involvement of statutory bodies in the site assessment document. The Environment Agency and organisations such as the Rivers Trust must be consulted. Any mitigating scheme provided within subsequent application stages can be assumed to be un-evidenced and thus unacceptable unless these agencies are involved.