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 leading the No 2 Purple Haze campaign. Our supporters are drawn from the Dorset town of Verwood (pop. 15K+), its surrounding communities as well as from regular visitors to Moors Valley Country Park which is adjacent to the proposed site. 

About the FoRF Objection . . .

Our strong Objection to permitting the planning application for the development of Purple Haze as a mineral extraction site is reiterated following public invitations to review and comment on the content of this response.

The reiteration of our Objection is necessary after examining the applicant’s Regulation 25 Response and the related new and revised documentation where we have focussed on interest areas which have significant Community Impact. Other organisations and consultees have addressed the major environmental & ecological issues arising from the updated proposals for the Purple Haze site and we fully support their conclusions.

Preparation of our response to the Regulation 25 Request Consultation was not assisted by the applicant’s failure to ensure -

• Information about a subject referred to in several locations within the updated application documentation is consistent,

• all data referred to as analysed, and from which conclusions had been drawn, was available for examination,

• referenced externally authored documents had been published in order to prevent future changes impacting any Plan’s construction or forecast outcomes,

• documents/plans are not presented as revised where only the version/date has changed, 

• and, importantly, contributors to document preparation recognised that while Hampshire County Council is the MPA for the Purple Haze site, the vast majority of residents affected most directly by their proposals live and work in Dorset.

The issues outlined above drove an increasing lack of confidence in the documentation presented for this consultation. Given the importance placed on the outcome of the Purple Haze planning application by so many people and organisations, generating the level of concern driven by the applicant’s Regulation 25 Response documentation appears disrespectful and is simply not acceptable.

The following documents were examined: - 

2. Outline Landscape and Ecology Management and Monitoring Plan (LEMMP)

2.1.2 LEMMP Much more detail is needed on the off-setting areas as outlined in this Plan; for example - How will the developer create the right off-set environment to support the off-setting objectives? Who has agreed to this? What public access would be permitted and when? What parking would be available to cope with any increased usage? It is not made clear within this Plan whether the off-set areas are intended purely for wild-life or whether they are intended to also provide the public with additional walking facilities. It appears they are to attempt to provide incompatible functions.

There are, however, enough bits of information amongst other application documentation to construe that the smaller offset is intended mainly for biodiversity (despite the car park and bridleway bisecting it) with the larger, known as Jack’s Garden, intended for biodiversity + displaced visitor access. It is anticipated that other consultation responders will have questioned the appropriateness of Jack’s Garden for the latter purpose. We would support those responders and will welcome any resultant clarification.

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2.5.1 This section is too vague. When does the 60-year period of responsibility start? Where can the definition of appropriately qualified contractors and ecologists be found?

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2.5.2 This section doesn’t go far enough. A Planning Condition is therefore required setting out: -

(i) the precise responsibilities of the appointed ecologist and who they will be accountable to, 

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ii) how they will report back to the public, to both the Hampshire and Dorset Mineral Planning

Authorities plus other interested parties, and 

iii) whether they will have the power to stop operations if they determine there are new or currently unforeseen ecological risks or problems.

2.6.1 & 2.6.2 Further clarification is required. It’s very unclear how the restoration proposals dovetail with the emerging Forest Plan if this latter plan is yet to be published. We understand that a significantly revised Plan is awaiting further consultation: until it is published and finally signed off, there will always remain a possibility it will change.

2.6.4 We challenge the statements made here. We cannot determine the basis of the assumption that the proposed works will not result in the displacement of visitors to other sensitive sites. Local knowledge suggests that recreational users are unlikely to drive distances to access other locations, such as in the New Forest, or will stick to pathways that are on the immediate boundary of the quarry works. People are more likely to instead access pathways close to nearby Ebblake Bog, along the edge of the Moors Valley golf course and onto Rushmoor (part of the Holt and West Moors SSSI) which lies adjacent to the road from Verwood towards Three Legged Cross.

2.6.9 The reptile mitigation strategy seems to be based on the retention of an area of habitat that is far too small and cannot provide all the requirements for all 6 species and the translocation of reptiles to both this and the newly created habitat between the fire break and B3081. Yet the strategy is “Outline” only: given the national and regional importance of sand lizard and smooth snake far more precise detail is needed at this stage.

2.6.10 Detail is needed on how Nightjars will be provided with a suitable alternative habitat. How will the extraction plan deal with nesting Nightjars in terms of ensuring that their nests are identified and they are not disturbed during the nesting/breeding season? Clarification is required.

4.4.3 This section appears to be an attempt to impose more controls in the area, i.e., dogs on leads, walkers on guided paths only. This appears to be being done in the name of conservation. It is, however, a significant change to the way that people use the whole area today and how they would normally conduct themselves elsewhere within the adjacent Moors Valley Country Park. It’s unclear how this could possibly be policed/controlled – for example, any number of people visit this area out of normal hours solely because of the seclusion and tranquillity it offers at those times. 

Further clarification is also required here as it is unclear whether there will be permanent public exclusion from areas other than those determined by the proposed Final Footpath Plan.

4.7.2 We are concerned by the implied threat that if people consistently stray away from the prescribed paths, then fences/barriers are likely to be erected to stop them. We would suggest that, instead, the applicant invests in appropriate solid track making such as those successfully established in nearby locations such as Stephens Castle and Dewlands Common or, indeed, elsewhere in the adjacent Moors Valley Country Park.

5.1.1 This section is hypothetical and not based on scientific analysis. The implications that the extraction plan will not have any impact on the SSSI are not based on objective analysis. When considering the information provided elsewhere in this application’s latest set of documentation, it is simply not possible for the applicant to guarantee that run off will not happen from the extraction sites. Relying on the depth of a void to prevent overflow seems a risky strategy. A deep void with even a small amount of water sitting in it for any amount of time would instead create a potential and considerable public safety issue.

5.2.1 This section acknowledges there is a risk of run-off pollution but does not specify how this will be monitored in real time and dealt with if pollution does occur. A Planning Condition is required to establish an effective 24hr real-time monitoring system with an agreed action plan in the event of a pollution incident.

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7.4.1 The proposal to enhance the two off-set areas to compensate for the loss of SINC quality habitats lacks detail. A full survey is required not just for vegetation and should include information on current visitor use. A minimum net gain of 10% must be demonstrated.

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9.1.17 It is recognised that public access to the Purple Haze location is permitted by the Somerley Estate. The applicant has failed to set out, as referred to elsewhere in this response, how the replacement of existing access managed through facilities operated/managed by the adjacent Moors Valley Country Park such as 2 cycle routes and the Bridleway, is going to be managed and the ongoing maintenance funded.

It follows that the existing car parks at Bakers Hanging and the Coach Road, used for recreational purposes by visitors to enjoy Moors Valley Country Park locations as well as to access the current Purple Haze tracks, will close. To help maintain visitor numbers to Moors Valley Country park, and so offset risk from potential future financial impact, it’s clear that facilities at both the Ebblake and Watchmoor Wood permitted car parks must therefore be substantially extended. This will also impact on biodiversity. This is not covered in the Plan.

9.1.18 The tragic accident near to Bakers Hanging in the last two years shows the dangers that can arise if trees are felled and the remaining trees are exposed to strong winds and risk of wind throw, especially where soils are wet. Inspection of the health of the trees every 3 years or after an extreme weather event will simply not remove the danger to the public using the B3081. Because of the nature of the soil here and exposure to wind, the Plan should be updated to require the trees referred to in this section to be inspected every year and after all extreme weather events.

9.1.20 This section doesn’t go far enough. The final sentence should be amended to change “should” to “will”.

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13.1.3 This section should be extended to cover the likely impact on public access during tree felling. We have set out during previous consultations the adverse impact on tracks which can be caused by the vehicles involved, often making some impassable or waterlogged. Where tracks so affected are not within the boundary of the proposed site, the action which will be taken by the applicant to resolve any such issues should be set out in this Plan and covered by a Planning Condition.

13.2.4 This section confirms that the public will only be allowed on the permitted paths. Further clarification is required as it’s unclear whether this solely applies to the quarry area or also to the whole broader area covered by the marked paths.

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14.2.3 Seems completely unrealistic. How will quarry workers be trained and incentivised to identify reliably individual bird species and then stop work to allow an ecologist to assess the situation? The applicant should provide examples of where this practice has been successful during the operation of other mineral extraction sites they manage.

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15.1.2 It would be hoped that other interested parties could be allowed to participate in the inspection of aftercare operations, or as a bare minimum, the resultant reports made available to the public and that this requirement is supported by a Planning Condition.

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16.1.1 As the site is on their doorstep, we’d like to see this section expanded to include the involvement of local residents in the process, perhaps through liaison via Verwood Town Council. Residents who visit this area could then become effective eyes & ears, especially outside of the site’s normal operating times.

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3. Proposed Diversion Plan (Drawing 2785-4-3-2 DR0002-S4-P1)

The Plan is incomplete. No mention is made of the intended fates of either the Watchmoor or the Somerley cycle routes. Nor has Bridleway BR E60/50 been included. The bridleway is of importance as part of a recognised Safe Route used to navigate the B3081. Please note that submitted comments to date have addressed only the Hampshire Rights of Way. An alternative route must be found which is established prior to site start-up, supported by a Planning Condition.

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4. Transport (Revised Environmental Statement III: Figures and Appendices 1-12, dated January 2023, Appendix 10)

The applicant has stated that a Regulation 25 Response update of this document was not required as

Hampshire Highways raised no objections to previous Highway design proposals for site access (B3081). It is, however, a consequence of the changed content of updated documentation presented in response to the Regulation 25 Request, that these issues now need to be addressed –

1. Dorset Council felt that a three week survey of the overall traffic figures should be carried out. The Junction Assessment of 2022, however, only appears to relate to site/staff/public vehicles entering or leaving the site. The purpose of the survey is unclear. It’s also unclear whether it complies with transport related impact requirements.

2. Proposed mitigation for likely unacceptable congestion around the B3081 and Bakers Hanging junction is not mentioned.

3. There is no assessment of the impact of the construction of the proposed road layout - How long would this take? Will traffic be rerouted whilst the work is carried out? Have the numbers in potential queues been assessed and, if so, where’s the data? 

4. There is no assessment of the dual danger of traffic entering/leaving the Somerley Recycling Site and the entrance to Purple Haze at the same time during construction of the new road layout and site operation access and possibly after their completion. A recent road traffic accident involving several vehicles in this area highlights situations which are a frequent risk when queues form nearby. For example, an assessment for this current period of vehicles entering Somerley Recycling Site suggest that if all slots are booked this could result in 187 vehicles per day.

5. The opening of the Hamer Warren Solar Farm site on the road from Bakers Hanging junction to

Alderholt would also result in an increase in traffic. The junction has been described by Dorset Council as a site of long standing concern. The cumulative effect of traffic involved in other sites in the area – e.g., Blue Haze Landfill Site - other quarries and those servicing the continued housebuilding in Verwood do not appear to have been considered.

6. There is likely to be additional risk around the site entrance during the hours of darkness which may need mitigation. Streetlighting is not advocated as a solution and would be resisted as provision will have a damaging ecological impact.

7. No assessment is evident of the impact which the combination of hard landscaping near the site together with the proposed clear felling of some of the trees along the B3081 will have on surface flooding of the road, increased run-off and therefore possible ground pollution which must be considered and mitigated. 

8. Additionally, no indication can be found of how the proposed clear felling of the roadside border beside the site and the B3081 will be managed – particularly how avoidance of verge damage will be achieved when using of heavy machinery and vehicles. How long will clear felling in this area  take to complete? Will road drainage gullies be kept clear during the felling? More detail is required.

9. Where and how would walkers, of which organised groups as well as individuals can be seen using the B3081 verges between Verwood and Bakers Hanging, be diverted to? Ideally, the long needed, and often requested, multi-user pathway/track with a compact surface alongside the Verwood to Bakers Hanging stretch of the B3031 - often referred to locally as a cycle path - would be installed prior to the site commencing operations. It would be a major community benefit to local people and visitors alike. It would also take some pressure off tracks on the Moors Valley Country Park side of the site from walkers, cyclists and others who currently use them solely to safely avoid the main road.

10. Finally, it’s unclear how the clear-felled area, with perhaps some trees remaining, between the B3081 and the site boundary would be maintained long-term and whether this area extends beyond the immediate site entrance. Assuming a longer area might be clear-felled, it’s worth noting that the B3081 verges are frequently strewn with litter. Litter-picking by both Hampshire & Dorset Councils can be sporadic and often relies on public reporting to get it cleared. Verge cutting usually takes places seasonally and often without litter picking immediately beforehand. Given the more open aspect resulting from clear felling, what measures will be taken specifically to prevent micro-plastics and larger items of litter entering the site both during and after both operations and restoration? It’s also not clear who will take maintenance responsibility for the clear-felled areas between the B3081 and the site boundary. Clarification is required.

5. Visitor Survey (Environmental Statement Appendix 2: Ecological Chapter - Appendix 12)

Opinion Summary

The Visitor Survey Appendix is considered to be totally inadequate, biased and with some conclusions drawn which are more opinion than data analysis based. It is also considered to be fundamentally flawed for these key reasons: -

• The Visitor Survey Report has been constructed in such a way as to draw positive conclusions, regardless of the data.

• The survey sample size (368 surveys completed) is too small to draw any meaningful conclusions and the decision to conduct it outside a main holiday period paints a false picture of the true number of visitors to the impacted area.

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• The survey exercise was shambolic and is discredited by the admission that the CCTV detection systems were placed in such a way that they were likely to miss people passing them, again minimising the numbers. The admission that they were unable to man all of their chosen survey locations again reduces the effectiveness of the survey. 

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• The survey was conducted in the middle of the Covid pandemic and whilst there were no restrictions on accessing Ringwood Forest, it is clear that many people were still reluctant to leave home and to risk any social contact. This paints a low and false picture of the normal use of the surveyed area.

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Conclusion: Now there is greater social mobility following the Covid pandemic, a further Visitor Survey is required which embraces at least a representative part of a holiday period, offers correct choices for other sites to visit and includes all data analysed to support the conclusions subsequently drawn.

Detailed evidence supporting the above Conclusion follows -

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About the Key Findings . . . 

The Key Findings section in the report is considered to be superficial and biased as set out in our following comments -

368 visitor survey forms were completed, with 36.7% of users not choosing to conduct a questionnaire when invited to do so. 4,164 site users were observed during the seven days of monitoring at six locations with CCTV cameras. 

Comment: Average of 99 users per location per day.

There were a wide variety of reasons for visiting the site, with proximity to home being the key Reason. 

Comment: This is not a reason for visiting the site, it is a simple data point which refers to where people travel to the site from.

Activities conducted whilst on site included walking/jogging, dog walking, cycling, socialising, looking at wildlife, horse riding, golf, and Segway. Cyclists tended to use the ‘Through the Forest’ cycle route rather than other tracks. 75% of site users make use of other sites within the local area to conduct their chosen activities.

Comment: This is a meaningless statement in terms of trying to understand why people visit the impacted area. It implies that 75% of people can simply go elsewhere if they don’t like the impact of the quarry, which is an unsafe conclusion to draw.

23-33% of activity (depending on the survey method) is outside the typical operation hours of the proposed quarry, with weekends typically being busier than weekdays.  

Comment: This implies that there will be no impact to visitor experience outside of the hours of operation, which is plainly false.

The majority (average of 60.5%) of site users who have a dog or dogs do not keep them on the lead for the duration of their activity. 

Comment: A pointless statement. That said, it is recognised that if these dog walkers were to go to nearby designated heaths that would have huge impact, especially to nesting birds.

Respondents indicated that there are a wide range of reasons which might reduce the likelihood of them visiting the area, many of which will not be influenced by the proposals. 

Comment: Here they are simply glossing over the real reasons why people would be less likely to visit the area and so have not provided any hard evidence or data to support their conclusion.

Mitigation measures will be included to reduce the likelihood of noise or dust reducing the attractiveness of the site to users. A detailed assessment on the potential for displacement has concluded that whilst localised displacement may occur, the off-site habitats north-west of the site within the SAC, SPA and RAMSAR are currently subject to a low level of use. 

Comment: Why has this detailed assessment not been published? It is impossible to judge the accuracy of the conclusion without the data. This Finding is therefore simply an opinion.

The potential for displacement of site users to this area is considered less likely than displacement to other forest tracks within Moors Valley Country Park or Ringwood Forest SINC due to their condition, choice of routes and ease of access being more attractive to users. 

Comment: This Finding is once again not supported by data. It is therefore a subjective opinion.

With regards to alternative sites, 27% of respondents indicated that they currently make use of Nature Reserves or SSSIs, 20% of which make use of the New Forest (i.e., 73 of 368 respondents). 

Comment: The intention here appears to be to suggest that there are plenty of alternative sites for people to go to. However, they chose not to point out the personal financial cost and impact on the environment of people travelling further to access similar amenities such as in the New Forest. It is understood that the applicant was guided towards also using the Dorset designated heathlands for the impact assessment but chose instead to look solely at the impact on suggested more distant New Forest sites plus other unfamiliar sites included in Appendix 3 which seems a strange choice.

During operation of the proposed quarry, users will have open access to the majority of current tracks within the site, enabling continued choice which is considered of value to users. The restoration scheme will reinstate and/or increase the provision of tracks for mixed use and cycling, with improved measures to ensure the long-term protection of habitats and wildlife interests of the site. 

Comment: This trivialises the impact by basically implying that everything will be OK again when the quarrying has ended, and the area restored. They failed to say how long a time period this will stretch over – it could be 60 years in some cases.

About the Survey Form . . .

3.2.1 The primary aim of the survey was to understand how local people use the local area recreationally, therefore the survey was timed to avoid the summer holidays when visitor  numbers are at their highest.

Comment: Why would it be considered that only local people are impacted when we have first-hand knowledge that visitors to the adjacent Moors Valley Country Park (numbering hundreds of thousands per annum) also access the site location for cycling, exercise etc.? The implication that this is an area that is only ever used by a relatively small number of local people misrepresents the situation.

3.4.3 A local Facebook group ‘No 2 Purple Haze’ was encouraging local people to visit the site as much as possible throughout the duration of the CCTV surveys which may have influenced the frequency of visits to the area above the typical baseline.  

Comment: This is a mischievous suggestion as any impact the Facebook group may have had is dwarfed by the impact of the Covid pandemic which is not referenced at all in the survey. 

3.4.4 & 3.4.5 Comment: These sections, when taken together, are an admission that the CCTV exercise was mis-managed and is most likely to have led to incorrect numbers and time periods being captured.

4.2.4 Comment: Acknowledges that 70% of the people surveyed accessed the area via a vehicle, but there is no mention made about the problems that might arise for this group when car parking capacity along the Verwood to Ringwood road (B3081) is reduced. 

 5.1.2 & 5.1.3 Comment: These sections, when taken together, try to create the impression that the continued usage of the north-eastern and south-eastern car parks (which are not directly impacted by the development) will alleviate any parking issues. We have suggested under our analysis of the LEMMP that both of the alternative car parks mentioned must therefore be enlarged to compensate. 

  Comment: The section on behaviour of visitors appears to be irrelevant.

5.2.2 From Year 3, the proposals will require the temporary redirection of the ‘Through the Forest’ cycle route along Track F on the western boundary of the site. This will reduce the length of the 7.15km route by 430m (6%). This is not considered likely to reduce the attractiveness of the route to users. The route will be reinstated within the site with a more varied topography and an equal or greater length than currently present on site. 

Comment: The survey does not set out for how long (from year 3) the cycle route will be impacted and when it will be restored. Clarification is required together with inclusion in any future survey.

5.2.4 The proposals will not change the accessibility of the site but will have a minor impact on the choice of routes available. Tracks A, B, E & F and the unnamed track on the north-western boundary of the site will remain open for access by site users throughout operation of the quarry. Tracks C and D which bisect the site will be closed during extraction of some areas and reinstated as part of the restoration process. 

Comment: This, again, is very subjective and an expression of opinion rather than fact supported by data.

5.2.6 The woodland habitat will be reduced in extent, however, in the long-term, woodland will be reinstated along many of the tracks, keeping the feel of a wooded landscape, with woodland edge habitat increasing from 8.9km to 11.46km. 

Comment: No time period is given, and this could therefore be misleading. What is ‘long term’ in years? The type of woodland will also change to species that are unsuitable for this location.

5.3.3 This demonstrates that around a quarter of activity at the time of the survey (when sunrise was at c. 06:45 and sunset was at 19:20) took place outside of the proposed operational hours of the quarry. Timing of activity is likely to vary seasonally. 

Comment: This is misleading. It should state that 75% of activity takes place during the proposed hours of operation of the quarry. Making a positive point out of minority data is mischievous.

5.4.2 These behaviours are considered likely to be causing potential disturbance impacts to wildlife such as basking reptiles and ground nesting birds within the SINC and off-site SAC, SPA and RAMSAR. The proposals to include measures to limit public access to habitat enhancement areas and areas of the restored quarry is likely to be of benefit to wildlife within the site. 

Comment: This is complete conjecture and again focuses on a small issue to try to justify incorrectly the claim that the development of a quarry will enhance the environment for wildlife. It’s simply wrong to state things this way.

5.5.1 25% of respondents to Q8 of the QS indicated that they did not visit other sites, reflecting the importance of the site to local people. However, around 160 alternative sites (some of which may be alternative names for the same site) are used by the remainder of respondents, with

choice of site influenced by a range of factors, such as alternative sites including woodland or forest (45%), heathland (29%), and beach or coastal sites (10%). 

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Comment: This is highly misleading. Most of the alternate sites are a long distance from Ringwood Forest. No mention is made of the negative impact on the environment if people have to travel further (by vehicle) to alternate sites. We have commented above on the misleading and wrongly selected choice of alternative sites offered by the survey.

Section 5.5.2 Comment: is written in such a way as to completely dismiss the concerns about the factors that would make visiting the area less attractive. It is considered biased in the extreme.

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6.  Socio Economic & Health (Revised Environmental Statement Section)

Socio Economic

6.2 of the revised Environmental Statement states: The main socio-economic impacts that would be associated with the development proposals would be in respect of:

• Tax contribution;

• Employment (direct and indirect); and

• Supply of Sand and Gravel to the construction industry

Comment: As previously noted the tax receipts (estimated in section 6.4 of the revised Environmental statement to be in the region of 600K pa) will accrue to Hampshire not Dorset; however, the communities most impacted by this development lie within Dorset Council’s boundary.  

As the financial benefits from the location of Purple Haze do not accrue to Dorset Council area residents, the applicant, together with Hampshire CC, should consider how best to deliver tangible community benefits for the nearby Dorset communities. Local residents have endured too many years of living near to Hampshire’s various mineral extraction and waste management operations. In doing so they have experienced all the cumulative effects of the inconvenience and daily problems arising which in any year can include any/all of the following -

• highly unpleasant odours lingering for days when the wind blows, or doesn’t, in the wrong direction,

• vermin in nearby gardens,

• the worry caused by landfill fires, especially when the weather is dry,

• seeing the abundant rubbish strewn along the B3081, some of which has been observed to fall from waste lorries,

• car damage to windscreens & bodywork caused by hard objects falling from quarry lorries, especially near to the Bakers Hanging turning,

• a poor quality road surface (B3081) causing pothole reporting to be considered almost a local sport with the winner being the resident who can first report the latest one,

• etc, etc, etc . . . 

6.5. states: At a local level, mineral extraction provides benefits to the local economy through employment (both direct and indirect), generation and support of economic activity and provision of building products.

Comment: The materials extracted from this quarry are most likely to be used by HCC & BCP and all the planned & proposed building construction in the nearby Ringwood/Fordingbridge area, with little

direct benefit to Dorset. It is stated there will be just 7 full time roles at the site. This is not anticipated to generate much additional economic activity for local Verwood based businesses.

6.6. states:  The proposed development will provide new employment with the creation of 7 full time jobs at the site. The revenue generated at the quarry will be returned directly into the local economy in staff wages and expenditure on the goods and services it requires. In addition, a substantial element of financial return to the community will arise through the payment of business rates to the local council.

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Comment: As above, 7 jobs will provide little stimulus to the local economy. We would expect the applicant to already have contracts in place for the support services it needs, so it is highly doubtful that much supplementary business will be generated for local (Verwood/Dorset based) businesses.  As above, the business rates will be paid to Hampshire and not to Dorset – a fact the applicant should be aware of already.

6.7 states: Indirect employment will be provided through the use of local suppliers where possible for goods and services such as plant and vehicle maintenance and spares, fencing and ecologists at the proposed development. It is anticipated that this will create up to 12 jobs.

Comment: As above, we would expect the applicant to have some suppliers already on contract for vehicle maintenance etc. The speculative impact of a total of 19 jobs is unlikely to have much impact on the local community based in Verwood, especially when compared to the inconvenience, disruption, and long term damage to the local property market they could face.

Section 6.8 states: The proposed development will provide a local supply of high quality sand and gravel which is required to sustain the planned local economic development. The nearest local supply of sand and gravel has very limited remaining reserves. By not planning for the replenishment of these reserves there will be an increase in cost to local developers/builders, as the needed construction materials will have to be imported from farther afield. 

Comment: Such vehicle movements are considered to be unsustainable and have the potential to increase road congestion and CO2 and NOx emissions. It is expected the majority of the material extracted is to be for use by HCC, BCP & NFDC and all the planned building in the Ringwood/Fordingbridge area, and for HCC planned local economic development. This will offer little, if anything, to Dorset.

Section 6.11 states: No significant adverse effects on local businesses are anticipated. A number of positive socio-economic effects would occur as a result of the proposed development. These positive effects will include the associated expenditure in wages and in payments to local suppliers, as well as the long term benefits associated with the improvements for tourism/recreation associated with restoration.

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Comment: The disruption to traffic flows whilst road improvements are made and after the site opens for trade may well impact Verwood based businesses negatively. As already stated, the amount of money related to wages (due to the limited number of jobs created) has not been quantified but is likely to be insignificant. Similarly, the spend with local suppliers is speculative but is not expected to be meaningful. As to long term benefits, these will take many years to be delivered and are unlikely to deliver benefit for many current Verwood based businesses.

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Health

Health Assessment Screening Document appended to the ES at Appendix 11

This states: As regards the impact on the health from Air quality, noise, light and water management

A range of technical assessments have been prepared and submitted as part of an Environmental

Statement. It is demonstrated that through the use of appropriate mitigation, the proposed development will not result in any significant adverse impacts in relation to air quality, noise, light and water management.

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Comment: This remains to be seen, and why robust monitoring will be essential, as it is possible that irreparable harm will be done which is not immediately obvious. Any issues arising in the early stages of this development may persist or develop over a considerable period of time as the proposed site is anticipated to operate for 20 + years.

This document contradicts Section 6.6 of the Environmental statement which states that the project will deliver 7 full time roles. Inconsistencies in documentation are unacceptable and lead the reader to consider whether other errors have been made. This assessment has not been updated and is dated 2020. Despite being included within revised documents, it has not been revised. 

Section 8.8 states: that in order to complete a Health Impact Assessment a baseline needs to be established. 

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Comment: It goes on to say that the HIA has consulted the latest available version of the Hampshire Health and Wellbeing Board – Joint Strategic Needs Assessment (JSNA). The JSNA looks at the current and future health and wellbeing needs and inequalities within the Hampshire population. This is a significant oversight requiring correction. Whilst the development may be within the borders of Hampshire the effect of the quarry will be felt, in the main, by residents in Dorset. We therefore strongly contest the use of Hampshire data as the baseline. All statistics provided as a baseline are therefore inappropriate. 

Section 8.8 states: Should planning permission be granted, it is anticipated that both Mineral Planning Authorities would wish to impose Planning Conditions which will require the monitoring, mitigation, and environmental commitments to be implemented as proposed.

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Comment: We have assumed the applicant is referring to both Hampshire County Council & Dorset Council.

Site Management Measures

(I) Daily visual assessment of emissions to include the quarry processing plant; water sprays; conveyor; stockpiles; loading areas; haul road; wheel wash and entrance road/exit.

ii) General site inspection checklist to include inspections of conveyor; edge protection; site security and vehicle sheeting requirements.

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Comment: The outcome and results of these inspections will be provided to HCC. Clarification is required to demonstrate how the general public and Dorset Council will be advised whether the requirements are being met.

iii) Complaints Register: any complaints will be logged, investigated, actioned as appropriate and the complainant notified of the outcome, with a full written record retained

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Comment: There are no details of the processes by which complaints will be handled, the time limits required for responses, escalation, etc.  For the public to have confidence it should be entirely clear how complaints will be handled from start to finish, including what appeal process is available. Additionally, it’s unclear how out of hours concerns will be addressed – if via the widely recognised Environment Agency reporting route or another route, the applicant should say so.

Table 8.2 Noise

Section 8.2 (iii) states: Operations will occur as far away from potential receptors as practicable.

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Comment: Clarity is needed on what the receptors are – people, homes, roads, ecology? In reality, the work will take place in the phase being developed at the time, some of these are nearer to potential receptors, some further away. Moving the work as far away as possible will not be possible if a phase being worked on is closer to potential receptors.

Additionally, much of the language used around the mitigation of site issues is loose – “should”, “where practicable” etc.  This does not give any level of assurance that all necessary measures will be taken to stop noise and dust issues. One interpretation, therefore, is that the applicant’s mitigation strategies will be implemented only where they deem it possible and when convenient to them. Clarification is required.

Section 8.19 states: 8.19 The table above outlines a wide range of attenuation measures and controls that will reduce emissions that might otherwise impact upon the health and well-being of nearby sensitive receptors. Subject to the grant of planning permission, it is anticipated that many of these measures will be controlled through the use of planning conditions, of which there will be routine compliance monitoring undertaken by each Mineral Planning Authority.

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Comment: As the MPAs have not been named above, we have assumed they are intended to be Hampshire County Council and Dorset Council.

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7. Noise & Dust

For all issues we had raised previously concerning site Noise and Dust management, there are numerous references within the applicant’s Regulation 25 Response to proposed operational practice, control measures and planning conditions which are offered as mitigation of the majority of those concerns. 

Some of the mitigation measures proposed are, however, based on technical assessments which we are not, as an organisation, qualified with the necessary skills to challenge at a detailed level. For Noise, however, please see our detailed concerns set out in Section 6 above. For Dust, we remain of the opinion that automated monitoring is a necessity despite the suggested mitigation.

In both cases, however, it is essential that any resultant agreed processes for reporting Noise & Dust issues, whether covered by Planning Conditions or not, are clearly sign-posted to the general public from before commencement of ground works for creation of the Site Office through to confirmation that quarrying works have ended and the related site office has closed for day-to-day activities. It is also essential that the outcomes of the required monitoring of both Dust & Noise Management are also made readily accessible to the public.

END