Friends of Ringwood Forest objection 2022/2023

Author: Britt Poyntz – Secretary Friends of RingWood Forest

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Proposal: Extraction and processing of building sand together with incidental sand and gravel, ecological mitigation works, new access off the B3081 Verwood Road, processing plant, conveyor system, weighbridge, site office and welfare facilities, staff parking with progressive restoration to a mosaic of lowland heath, gorse scrub, woodland and pond areas

 

1.  Introduction

 

Friends of Ringwood Forest (FoRF) is a local community action group managing the No 2 Purple Haze campaign. Our supporters are drawn from the Dorset town of Verwood (pop. 14,700+), its surrounding communities and regular visitors to Moors Valley Country Park which is adjacent to where the proposed site known as Purple Haze is located.

 

About the FoRF Objection

 

Our strong Objection to granting permission for planning application Ref: NF272 is submitted after our supporters were able to review and comment on the content.

 

We will demonstrate: -

• that the applicant has failed to meet Planning Policy requirements and Development Considerations* for the site known as Purple Haze as set out in Hampshire County Council’s Minerals & Waste Plan adopted in 2013

• that the applicant has failed to meet all Scoping Request requirements

• that the applicant has failed to provide either adequate or accurate data across all documentation submitted with the application

• that the applicant has failed to demonstrate adequate consideration of issues and suggestions following the two Community Involvement Events referred to within the application

*Note: For ease of reference, FoRF has numbered the Development Considerations for the Purple Haze site in the range PH01 > PH14 as shown in Appendix A to this document.

 

Our objection is based on examining the applicant’s submission regarding the following –

 

2.  Transport - Traffic/Highways

 

2.1  Introduction                                

 

Referring to paragraph 4.81 of the applicant’s Planning Statement, we strongly disagree with the HMWP Inspector’s Report that: “the additional traffic generated was unlikely to have significant impact on the B3081 or the wider transport network”.

We note the Highways Authority’s response to the application but suggest it does not consider the experiences of those who live locally and who are only too aware of the problems which occur on this road.

 

We discuss below how local concerns, such as those regarding the proposed site access junction and other highway safety issues, have not been considered adequately by the applicant.

 

2.2  Background

 

Verwood with a population of 14,700+ is the largest town in the North Dorset Parliamentary constituency and slightly less in population size than the nearby Hampshire town of Ringwood.

 

Verwood is a dormitory town with poor public transport links and few of the services, restaurants, shops, and amenities etc. available to Ringwood residents. Verwood trades and businesses trade in Ringwood. The reverse is true for Ringwood businesses. To access Ringwood’s amenities and business/trade links, Verwood residents and trades have to travel along the B3081, past where access to the Purple Haze site would be located.

 

Verwood residents who commute to work daily use the B3081 as the most direct and straightforward means of accessing the A31 and nearby larger towns. The B3081 is the road taken by residents attending hospital appointments, accessing railway stations and nearby airports, and going to college/university and to school.

 

For Verwood residents and businesses alike, the B3081 is a critical arterial road link with the wider area, often via the A31 heading east and west and via the A338 heading north and south.

 

Ringwood businesses and trades use the same arterial road to reach their Verwood clients. Ringwood residents, together with residents from other Hampshire locations, travel to Verwood using the B3081 to access Morrisons supermarket. It is certain that traffic to and through Verwood will increase once the Lidl supermarket, currently under construction, opens for business.

 

The section of the B3081 between the A31 and Verwood is considered by local residents to be poorly maintained. It is not considered a safe route for use by cyclists and pedestrians.

 

Alternative vehicular routes to access the A31 are available via the smaller B3072 road and travelling through the village of Three Legged Cross; however, due to hazards along this road, it is speed limited to 40mph throughout other than for a further reduction to 30mph through the village.

 

Being narrow and winding the B3072 route does not have the same capacity as the B3081. If there are accidents or incidents on the B3081, causing traffic to reroute through Three Legged Cross, this alternative route quickly becomes congested, causing gridlock and leaving Verwood essentially cut off for all except those prepared to take a long diversion, for example towards the Blandford – Salisbury road or a route via Wimborne. These longer diversions involve uncategorised roads, which are more dangerous.

 

Any forecast of increased volume of traffic on the B3081 will therefore cause significant concern to Verwood residents. Delivery of road “improvements” which would necessarily mean significant disruption are viewed with considerable misgivings.

In addition, HGV drivers use the B3081 route on diversion through Verwood in either direction when there are delays or incidents causing congestion on the A31/M27.

 

Conclusion. The applicant has failed to consider the proposed road improvements to widen the A31 at its junction with the A338 and related diversions, which will compound the issues unless the A31 works are completed in totality prior to development of the site.

 

Conclusion. The applicant has failed to also consider the seasonal variations of traffic along the A31 during summer months which exacerbate traffic issues on surrounding road networks leading to, amongst congestion problems, increases in pollution from idling HGVs.

 

Conclusion: The applicant has therefore failed to meet the requirements of Planning Policy 12 by not adequately considering the impact of:

• an increase in HGV traffic volume on the B3081, and

• the inevitable disruption from congestion and/or incidents, nearby major roadworks schemes, and

• the need to improve the nearby Baker’s Hanging junction 

on the lives of Verwood residents, and other local communities such as Ringwood, where residents and businesses are entirely dependent on the road link that is provided by the B3081.

 

Recommendation: The applicant should be required to provide, as a minimum –

(i) an outline of the programme of work required for the development roadworks so that potential traffic upheaval may be better gauged than can be achieved with the limited data provided in the Transport Assessment Report, and

(ii) their proposals demonstrating how such disruption will be mitigated.

 

2.3  Road Safety

 

2.3.1  About Baker’s Hanging

 

This section discusses the Traffic Assessment addendum to the Planning Statement which fails to consider the impact of serious incidents which occur at the accident black spot of the junction taking traffic to/from Alderholt from the B3081 known as Baker’s Hanging.

 

The applicant’s original request for police data scoped only the stretch of the B3081 on which the quarry access is proposed to be sited. The applicant was advised additional accidents had occurred just outside of this area. The applicant then fails to mention them, despite having requested the data related to the additional accidents which took place between the proposed site entrance and the A31. The applicant therefore states, inaccurately, that there were 6 accidents in the 5-year period examined when police records show there were 18.

 

The proximity of the Baker’s Hanging junction, to which the applicant makes no reference, to the proposed site entrance adds a serious road safety hazard to the site access proposals. It is extremely difficult for vehicles to exit the junction, particularly when attempting to turn right onto the B3081. The difficulty increases regularly when additional traffic has been diverted to/from the A338 and via Alderholt back to either the A31 or A338 near to Ringwood.

 

With the proposed increase in traffic, and particularly with additional slow-moving HGV traffic with cars bunched up behind, this part of the B3081 will become more difficult to travel through for all road users. It is considered that an increased number of accidents and fatalities will result.

 

Conclusion. The applicant has failed to meet the requirements of Plan Policy 12a by failing to mitigate the effects on highway safety by disregarding the accidents at the Baker’s Hanging junction.

 

2.3.2  About the “Ghost Islands”

 

Site access proposals include two staggered right turn “ghost islands” permitting traffic to enter the quarry site from the north and the Somerley HWRC from the south to avoid queuing traffic behind.

 

We consider this to be the worst junction choice from the options presented during the public engagement event held at The Hub, Verwood. The combination of two staggered right turn ghost islands will create a complicated and dangerous area with potentially four lanes of vehicles either proceeding or waiting to turn right. The section of the B3081 approaching and leaving the area around the entrances to the Purple Haze site and the HWRC would therefore become more perilous for all road users and for cyclists particularly.

 

It is also not clear how easy it will be for traffic, particularly slow-moving HGVs, exiting from the quarry to turn right to return to the south, nor for traffic exiting the household recycling centre to turn right to return north. In fact, despite the Road Safety Audit, it is the considered opinion of those who use this road regularly that the provision of these mid road junctions will make the road more dangerous and not less so.

 

2.3.2.1  Drainage

 

Paragraph 7.1.5 of the Traffic Assessment references a requirement for improved drainage works for the new road junction.

 

Conclusion. The applicant has failed to indicate where the contaminated water run-off will drain to and how it will be prevented from ultimately entering as diffuse pollution the mire system including Ebblake Bog SSSi (SAC, SPA, Ramsar).

 

2.4  Cyclists

 

There are local cyclists who like, or who need to as their only means of transport, to cycle regularly along the B3081 towards Ringwood. They have no suitable alternative route except one that is longer via Moors Valley and the Castleman Trailway and which is considered suitable for mainly daylight use. Local cyclists report that using the B3081 is very unpleasant and that it feels dangerous being overtaken by HGVs at their current levels.

 

Given current road conditions, some residents have made the decision that the B3081 is currently too dangerous to cycle. They have stopped doing so and now drive a vehicle instead. This outcome is at variance with Government efforts in response to the Climate Emergency to reduce the volume of motorised vehicles using UK road networks.

 

Other residents have raised concerns that it would be too dangerous for cycling sporting events frequently held at Somerley Estate if these plans were to go ahead. We consider that increasing the number of HGVs on the B3081 will make it even more hazardous.

 

When there are roadworks to create the quarry site access, or there is an incident or seasonal congestion on the B3081, more road users, including cyclists, will be tempted to use the surrounding minor roads which are dangerous.

 

Conclusion. The applicant has failed to contribute to the vision offered by the HCC Cycling Strategy, see Page 6 at https://documents.hants.gov.uk/transport-strategy-documents/HampshireCyclingStrategy.pdf, as their plans will result in cyclists being driven away from using the B3081.

 

Conclusion. The applicant has failed to evidence adequate mitigation of the effects on road safety as required by Policy 12.

 

Conclusion. The applicant has failed to meet the requirements of Development Consideration PH13 which states there should be “safe and satisfactory access including alternatives to access off the B3081 to ensure provision for vulnerable highway users”.  

 

2.5  Traffic Management

 

The applicant has included in the Planning Statement an underestimation of 90 HGV movements per weekday. Our concern with the applicant’s estimate is based on a recent planning application extending operations of the Blue Haze landfill site to handle a further 770,000 tonnes of waste with a predicted increase from 34,000 two-way movements to 35,000 two-way movements per annum and equating to 126 HGV movements per day.

 

Verwood residents who have lived close to quarries elsewhere advise that despite the applicant stating they expect HGV visits to be flat profile, HGVs queue or park up in readiness for site access, often in the mornings and at other times during the day causing congestion and disruption.

 

Conclusion. The applicant has failed to provide adequate data supporting their estimate of 90 HGV movements per weekday and should therefore be required to: -

• provide detailed evidence to substantiate their estimate, and

• identify the variables, and

• identify proposed mitigation for the variables, individually and in combination.

 

 

 

2.6  Traffic Through Verwood

 

The applicant has not provided sufficient evidence to:

(i) support the claim that 90% of the expected traffic will arrive from the A31 and 10% through Verwood, and

(ii) to evidence their consideration of other local factors affecting traffic travelling through Verwood as follows below.

 

The B3081 within Verwood is called Ringwood Road: it is residential and extremely busy for pedestrians to cross. The figure of 9 HGV movements per day is a significant additional amount of HGV traffic through Verwood.

 

Conclusion. The applicant has failed to state and consider the tolerance level in terms of capacity, road, and pedestrian safety, and has failed to consider the overall impact if the estimate of 9 HGV movements per day proves to be inaccurate.

 

We consider, however, that the estimate of 9 HGV movements per day may be inaccurate because there is a housebuilding plan and expansion of local amenities currently underway in Verwood, leading to more residents using the B3081 and a current increase in HGVs, and other trade vehicles, travelling into Verwood to serve the building sites etc.

 

Conclusion. The applicant has failed to evidence consideration of all the factors set out above.

 

Conclusion. The applicant has also failed to consider the cumulative effects of HGV traffic already using the B3081 to access the Veolia landfill site, especially in the future when Blue Haze closes in 2031 until which time waste laden HGV movements are likely to increase, and then moves into a significant restoration phase with, potentially, an as yet unknown volume of associated HGV movements or to also access the Somerley HWRC.

 

2.7  Damage to Vehicles/Highway

 

Conclusion. The applicant has failed to show how the risk of any spillages on the highway, occurring after loaded vehicles have exited the site, will be mitigated.

 

Recommendation. The applicant should be required to provide a legally binding undertaking regarding the measures which will be taken, by themselves or others, to contribute to reducing the vehicle damage currently caused by the poor maintenance of the B3081 road surface between the A31 and Verwood and/or how the applicant will operate to mitigate the frequent damage caused to windscreens and vehicle bodywork by stones flying off quarry/gravel lorries already using the B3081 and/or the Baker’s Hanging junction.

 

2.8  Traffic Conclusion Summary

 

(i) The applicant has failed to meet the requirements of Policy 12 to ensure that the development mitigates adverse effects on highway and pedestrian safety, highway capacity and the environment.

(ii) The applicant has failed to meet the requirements of Policy 10 that the development should not cause an unacceptable cumulative impact arising from other mineral and waste sites.

(iii) The applicant has failed to meet the requirements of Development Consideration PH14 which mandates the consideration of traffic issues including cumulative impact with other mineral workings and the protection of Verwood from mineral traffic.

 

3.    Noise

 

3.1  Equipment Operating at Site

 

The Noise report states, “in summary, for normal daytime site operations the noise limit at residential properties should be no greater than 10 dB above the existing background level with an upper limit of 55 dB LAeq,1h. For Temporary operations, the noise limit at residential properties should be no greater than 70dB LAeq,1h.”

 

The Noise report states that noise sources within the extraction areas will include an excavator, dump truck and conveyor.

 

The noise sources within the plant area include processing plant for the excavated material, a loading shovel and HGVs. There are two processing plants running in parallel at the site: one for dry screened sand and the other for washed sand. The loading shovel will move the material and load the HGVs at the plant site. There are to be up to 90 HGV movements per day (around 8 vehicles per hour).

 

However, the Dust report mentions additional equipment as follows: "sand screeners, a hydrocyclone and dewatering screen*, plus fixed and mobile dust extraction and suppression equipment.”

* which may be the two processing plants mentioned in the previous paragraph.

 

Conclusion. The applicant has failed to demonstrate that noise sources likely to operate within the site, and their related noise level estimates, have been identified in totality for the purposes of the Noise report.

 

Recommendation. The Noise report as presented for examination should be withdrawn.

 

3.2  Total Noise Levels

                                                                                     

The report states that temporary operations, which can take place for a period of 8 weeks a year are permitted to generate higher noise levels (70 dB). Temporary operations include works to restore earlier worked phases.

 

Whilst it is not clear from the Noise report whether these temporary operations and normal operations will occur at the same time, it is clear from the Planning Statement, Section 3.18 that restoration works, and normal excavation operations will occur at the same time. It states "While sand is extracted from phase 2, phase 1 will undergo levelling to the restoration profile and restoring using soils and overburden stripped from phase 3. Following restoration, the area will be planted and seeded as required to meet the restoration after use”.

 

This clearly indicates that as works move from phase to phase, restoration and excavation will occur concurrently.

 

Further reading seems to indicate that this concurrence of activity has not been considered as the Noise report states "These noise levels have been calculated for extraction activity at the nearest phase to each noise sensitive receptor and at the maximum working height. The calculated noise levels also include simultaneous processing of material at the plant site. As such, these calculated levels are considered to be a reasonable worst case. The activity assumptions for normal daytime operations are presented in Appendix F."

 

This seems to suggest that the noise generated by extraction and processing occurring concurrently has been considered but the noise generated by temporary operations (levelling and restoring) occurring simultaneously has not been considered when calculating the maximum noise levels. This level of ambiguity is unacceptable.

 

Conclusion. The applicant has failed to demonstrate that the overall level of noise to be generated during periods when normal activity and temporary operations are occurring concurrently has been accurately assessed.

 

Recommendation. The Noise report as presented for examination should be withdrawn.

 

3.3  Impact on users of Moors Valley

 

The noise impact on users of Moors Valley is dismissed as being negligible because the paths and routes within the country park are transient areas and people do not stay in the area for extended periods of time.

 

If people have come to the park for a quiet walk and find their tranquillity disturbed by the works, this might prevent repeat visits and ultimately damage the business of the country park; alternatively, they may choose to visit the nearby sensitive Heathlands instead.

 

Conclusion. The applicant fails to mention the impact on horse riders who use this area as a safe route to travel between Verwood and Ringwood. It appears that the British Horse Society has not been consulted and so we have provided them with information about the planning application.

 

3.4  Plant Site

 

The plant site will be built 3 metres below ground and will be the first area to be built, there will be no bunds to dampen sound whilst this building is going on.

 

Conclusion. The applicant has failed to include mitigation for noise levels from this initial phase of development, nor for the noise created by the road alterations, although they could be significant.

3.5  Afforestation

 

Mention is made that the forest will provide a degree of screening. The forest is managed.

 

The proposed restoration of the site will lead to replanting of young trees and some different species, it is not clear what impact this will have on noise levels. Most of those proposed are deciduous so will only offer any degree of screening when mature and when in full leaf, i.e., for about 6 months a year.

 

Conclusion. The applicant has failed to identify what additional sound mitigation will be provided if trees which had been providing screening are removed and noise levels rise to unacceptable levels.

 

3.6 Mitigation, Monitoring and Management

 

The Noise report contains an extract from the Planning Practice Guidance Minerals (PPMG) which states that those making mineral development proposals should, amongst other things:

identify proposals to minimise, mitigate or remove noise emissions at source;

monitor the resulting noise to check compliance with any proposed or imposed conditions.

 

The only mitigation apparent in the report is embedded mitigation, which consists of the soil bunds as follows:

 

Embedded Mitigation

The proposed phasing plans show that bunding is to be incorporated in the scheme formed from topsoil and overburden excavated from the site. The bunds are between 1.5m and 3m in height.

 

Topsoil and overburden from the plant site area, phase 1 and phase 2 will be used for a 2m high bund along the NE and SE sides of the plant site area and a 3m high bund along the SE side of the plant area.

 

As phases are worked, the topsoil and overburden from each will be used for form 1.5m tall bunds around the outside edges of the active phases.

 

The acoustic screening attenuation provided by the bunds is included in the site noise calculations and assessment. No additional mitigation is offered in the Noise report and nothing additional appears in the conclusions. There is no apparent commitment in the Noise report to ongoing monitoring of noise levels.

 

The Environmental Statement section 8 Table 8.2 makes a series of recommended best practices regarding noise but does not commit to regular monitoring or advise any additional mitigation.

 

We note the response from Environmental Protection at New Forest District Council but suggest the lack of any apparent commitment to ongoing noise monitoring will make it impossible for the applicant to demonstrate compliance with the target levels as described in government guidance.

As there is no operational plan we do not know if the applicant will provide ongoing noise monitoring at the receptors used to create the calculations set out in this report. If there is no ongoing monitoring, how will we know that the limits are not being exceeded? 

 

Conclusion. The applicant has failed to demonstrate proposals to monitor noise to ensure that the noise limits set out in this report are not breached.

 

Conclusion. The applicant has failed to demonstrate proposals to monitor noise to provide evidence that it is compliant with any planning conditions imposed by the local authority.

 

Recommendation. The applicant should be required by a planning condition to provide adequate and regular noise monitoring.

 

4.    Dust

 

4.1  Silica

 

Sand quarries generate silica dust (Respirable Crystalline Silica - RCS) yet silica is not mentioned specifically in the Dust report nor in the Environmental Statement. This is concerning because silica is identified by the UK government as a hazardous material. Its particles are so small it is invisible but if inhaled can lodge in the lungs and cause serious lung disease.

 

The report concludes that monitoring of dust using passive or real-time units is not recommended at this stage but goes on to say that dust emissions should be routinely monitored by visual means. Silica is invisible, the lack of passive monitoring means that dangerous dust may well be missed.

 

Conclusion. The applicant has not provided data regarding what percentage of the possible dust emissions will be silica. It is therefore not possible to determine whether adequate processes and procedures, including dust monitoring by other than visual means, should be in place to protect nearby community members, including recreational users of the area, from this material.

 

4.2  Dust Management Plan

 

The Dust report contains a dust management plan which identifies potential strategies to minimise hazards from dust. However, as there is no Operational plan there is no guarantee that any of these mitigations will be implemented.

 

The environmental statement includes attenuation measures, however whilst it is implied these will be implemented and will be controlled through planning conditions, there is no guarantee that these measures will indeed be implemented. This leaves a considerable degree of uncertainty that protection measures will be adequate.

 

Conclusion. On examination of the relevant application report content alone, because HCC has yet to state what planning condition(s) will be applied to Dust Management, it is not possible to determine whether adequate measures will be in place to protect nearby community members.

4.3  Water Use

 

Much of the mitigation proposed in the dust management plan is linked to use of water, to dampen down etc. It is not clear how much water will be used, how the proposed water well will be operated and what impact this may have on local supplies, drought orders, etc.

 

Conclusion. The applicant should be required to provide the missing information concerning water use on site.

 

4.4  Weather

 

The report states that “As an overriding requirement, during dry windy weather, i.e. ‘red’ conditions as defined in Table 4.1, if any operations are identified as causing or likely to cause visible emissions across the site boundaries and towards sensitive receptors, or if abnormal emissions are observed within the site, the Site Manager should immediately modify, reduce or suspend those operations until either effective remedial actions can be taken or the weather conditions giving rise to the emissions have moderated.”

 

The above is a recommendation only and relies on visible emissions. It not clear, because there is no operational plan, that this type of action will be taken when the site is operating. It is also not clear what warnings will be given to local residents and users of Moors Valley Country Park in the event that emergency actions are required and how these will be transmitted.

 

Conclusion. The applicant should be required to state how red condition warnings will be notified and to whom.

 

5.    Socio-Economic & Health

 

This report, by referring to Hampshire Socio-Economic & Health data alone, is considered irrelevant to the application, demonstrating a lack of care concerning identification of impact on the local community in Dorset near to Purple Haze and which the applicant has failed to recognise for the purposes of this report and elsewhere in their application.

 

The landowner and operator are not Dorset based, therefore no financial or tangible benefit, and long-term profit investment, is likely to accrue within Dorset where the greater and expanding population of people will reside who are affected directly by developing the Purple Haze site - except for access, if proposed restoration plans are accepted, to water bodies surrounded by gorse thicket proposed to the south of the site plus information boards to be located around the site. This is an omission which should be rectified.

 

Conclusion. The applicant should be required, via a planning condition, that when considering their employment and local supplier needs, they commit to giving priority to nearby Dorset residents and businesses.

 

 

Conclusion. The applicant has failed to indicate to Dorset communities and businesses a willingness to provide adequate Community Benefits or improvements to Community Amenity in compensation for the upheaval and disruption likely to be experienced over the 25+ years the site will operate and an unknown period beyond during ongoing restoration.

 

Recommendation. This report should be withdrawn as it does not reflect that while the site is physically located in Hampshire, the consequent impact of its development will affect, primarily, nearby Dorset community members.

 

6.    Hydrology

 

It will be recalled that we submitted considerable detailed evidence about Hydrology concerns in relation to the Purple Haze site during previous proceedings to adopt the HCC Minerals & Waste Plan in 2013 and the related Examinations in Public including, in particular, our comprehensive response to the Main Modifications & DCLG Guidance Consultation. We were opposed to HCC adopting the site due to the significant and unresolved concerns as touched on in the Planning Inspector’s final report and which were discussed with HCC Officers at the time.

 

After a detailed examination of the planning application for Purple Haze together with the supporting reports which reference Hydrology, no reasons to proceed have emerged which negate our previous significant concerns and so our position is unchanged. We remain convinced the site should not be developed.

 

In order to avoid repetition of the content of other responses to the current consultation, we wish instead to attach our strong affirmation to the arguments for refusing planning permission when considering the site’s hydrology/hydrogeology as presented by other respondents and those of the Environment Agency and EDEP in particular.

 

Conclusion. In summary, we object to planning permission being granted on the grounds that the applicant has not provided sufficient detail of the location and movement of water into, within, under and away from the site as it is now and how that would change, nor have they demonstrated that development of Purple Haze would avoid harm to the nearby areas of important biodiversity interest and particularly Ebblake Bog SSSI (SAC, SPA, Ramsar) and its catchment.

 

7.    Archaeology

 

The Cultural Heritage Assessment Report recommends that it should be a requirement of the planning consent that a thorough mitigation strategy should be instigated to ensure the preservation by record of the probable barrow and other archaeological sites within the development area. This mitigation strategy covers the full excavation of the probable barrow and establishes a plan to ensure that there is an ongoing programme of observation and investigation throughout the life of the project. This entails a review of each area before soil stripping commences, throughout the life of the project. This mitigation is endorsed by Hampshire County Councils Senior Archaeologist.

 

The Planning Statement acknowledges the requirement for mitigation prior to the excavation of the probable barrow and states that a detailed Written Scheme of Investigation would be submitted to Hampshire County Council before development commenced and would be subject to a planning condition requiring its implementation. It only makes a passing reference to the need for ongoing monitoring, stating that a "watching brief" will be held over the remainder of the site. Both the Planning Statement and the Environmental Statement contain a comment as follows: It is concluded that this balanced approach should be a consideration in the decision-making process.

 

Recommendation. The wording in both the Planning Statement and the Environmental Statement seems weak compared to the detail set out in the Cultural Heritage Assessment and as endorsed by the Senior Archaeologist. We would like to see a firm commitment from the applicant that they will follow the mitigation as set out in the Cultural Heritage Assessment, throughout the life of the project and would like confirmation from Hampshire County Council that this will be enforced through planning conditions.

 

8.    Community Benefit & Amenity

 

8.1  Post Restoration Access

 

The applicant has proposed a three stage “clear, extract, restore” approach to extract minerals on a strip-by-strip basis. Should the restoration plan for any worked strip be accepted to include the provision of replacement habitat, public access is likely to be denied to that strip for at least 30 years to prevent replacement habitat disturbance.

 

It is therefore considered unlikely that public access to the majority of the Purple Haze site will be regained for many years and plans to, for example, divert cycle tracks and marked trails could fail where restoration plans involve habitats for sensitive species such as the sand lizard population present on site.

 

Recommendation. The applicant should be required to demonstrate how and when public access will be restored for each strip as extraction progresses, to show how any replacement habitats for sensitive species will be protected from disturbance and to demonstrate how this will affect the diversion of current amenities such as cycle tracks and marked trails.

 

8.2  Information Boards

 

It is proposed that information boards will be provided at suitable locations around the site. While their provision would be welcomed, the applicant should be aware there is a history of local anti-social behaviour involving the defacement and unauthorised removal of such boards.

 

Recommendation. The applicant should be required to work with Moors Valley Country Park to design, install and maintain the information boards accordingly.

 

8.3  Permitted Parking on B3081 to access Moors Valley Country Park

 

Parking and access tracks from the B3081 are provided by Forestry England to facilitate local informal recreation. These parking areas, along with those on other roads bordering Moors Valley Country Park and the park’s main car park, are often full during weekends, over Bank and school holidays. If the parking capacity along the B3081 is reduced for any reason, the recreational users affected may migrate to nearby Heathlands.

 

Conclusion. The applicant has failed to state the mitigation measures which will replace permitted parking when tracks from the B3081 into Moors Valley are closed to the general public for any length of time due to site operations.

 

8.4  Tracks, Informal Paths & HGVs: Making Good

 

When planned harvesting of trees takes place within Ringwood Forest, HGVs use existing gravel tracks and also cross informal pathways which become unsuitable for recreational access until they have been made good.

 

It is considered that when preparations for site operations get under way beyond the site’s boundary, recreational users are likely to experience similar unsuitable track and pathway conditions so preventing permitted access.

 

Conclusion. The applicant has failed to state how long each of the tracks and pathways used by HGVs during site set up would be inaccessible, when the impact of such HGV disturbance on each will be made good and to what standard to meet the requirements of both users and biodiversity.

 

9.    Community Involvement & Engagement

 

Timing of the Application Consultation

 

We appreciate that the timing of any planning application consultation is dictated by rules and regulations rather than by simple custom and practice. This consultation is no different, except that it is taking place during the Covid-19 pandemic. It is a time of national social unsettlement when local community members have other priority concerns.

 

Recommendation. When the time comes for a decision to be made on whether planning permission will be granted or refused, we would ask that it be noted that any lack of direct public response to the consultation is considered to be due more to current social circumstances than to any decline in public concern about the effect of the site’s development on an environment that is highly valued, locally cherished and considered worth protecting from harm.

 

10. Accessibility of Application Content

 

10.1 Empowering Inclusion

 

We accept that while the applicant is responsible for submitting the plans, text and data required to support their application, authorship of individual report content has often been the responsibility of more than one organisation as evidenced by both style and content.

 

The perception of accessibility by the general public to the wealth of information provided to support this application has therefore varied between “way too technical for me to read” (creating exclusion) to “that was easy to understand” (empowering inclusion). Specific examples of the variance in accessibility can be provided if requested.

 

Recommendation. We doubt that the overall approach to the authoring of individual application reports is going to change. However, it would be helpful if the applicant were reminded to consider, before signing off their content for submission, that the intended audience includes lay people who may or may not have the same degree of technical understanding enjoyed by those consultees routinely working or volunteering in roles related directly to the application.

 

10.2 Cross Sections & 3D Modelling

 

The application includes a number of 2D graphics using contour lines to demonstrate how the site landscape changes over time. Feedback to FoRF indicates that these have caused frustration for a number of people who have had difficulty in visualising how contour lines “work”.

 

During both public engagement events, we advised the applicant that 3D modelling would be a helpful aid to understanding the proposed landscape changes given that Purple Haze cannot be described as either a regularly or flatly contoured site.

 

We also note that, in response to the Scoping Opinion consultation, Dorset Council advised that cross-sections should be provided and, in their application response, EDEP has reiterated the need for before and after cross-sections of worked strips demonstrating the landscape changes.

 

Conclusion. The applicant has failed to meet Scoping requirements with regard to providing cross sections and should be required to provide them before the application can be further considered.

 

END

Appendix A Purple Haze: Development Considerations

 

PH01 Protection of the Dorset Heathland Special Area of Conservation (SAC), Special Protection Area (SPA) and Ramsar site, the Avon Valley SPA and Ramsar site and the River Avon SAC*.

PH02 The impact on the offsite foraging and breeding areas of the qualifying bird species of nearby SPA/Ramsar*.

PH03 The impact on Ringwood Forest and Home Wood Site of Importance for Nature Conservation.

PH04 Protection and enhancement of the amenity and users of the Moors Valley Country Park and other local residents.

PH05 Maintenance and management of levels of permissive access and recreational use of the Moors Valley Country Park via the B3081*.

PH06 Protection of the nearby cycle paths and footpaths.

PH07 Management arrangements to secure short and long term objectives for amenity and biodiversity.

PH08 Phasing programme and working to protect the amenity of local residents and permissive access to the site.

PH09 The impact on the Bronze Age burial mound and its preservation.

PH10 Protection of the amenity of Verwood residents, other residents in the vicinity and local businesses.

PH11 Exclusion from extraction and buffer of the northern end of the site to protect the amenity of local residents*.

PH12 Protection of the water quality and recharge of the underlying aquifer, groundwater and surface water and safeguard the hydrological regime of Ebblake Bog Site of Special Scientific Interest*.

PH13 Safe and satisfactory access including alternatives to access off the B3801 to ensure provision for vulnerable highway users and the impact on peak flows is managed.

PH14 Traffic issues including cumulative impact with other mineral workings and the protection of Verwood from minerals traffic.