Smallford Residents Association (SRA) Opposition to Brett Aggregates Ltd Planning Application for a new Quarry at Smallford/Hatfield Aerodrome Site – off Hatfield Road, St Albans, Hertfordshire.

Application PL\0755\16 & 5/0394-16

Grid Ref: 519837, 208389

Background

Brett Aggregates has submitted a planning application to Hertfordshire County Council in February 2016 to build a quarry on up to 87 hectares of green belt land owned by the Goodman Group at Smallford/Hatfied Aerodrome in St Albans for operations for 32 years. Placing this size into context (Figures 1, 8), this large area of 870,000 square meters represents a size 2.5 greater than the proposed site for a Rail Freight terminal in nearby Radlett (330,000 square meters) which was recently refused after a Secretary of State appeal in 2015.

This whole site is land contained by Ellenbrook Nature Park. The area is surrounded by local village communities of Smallford, Ellenbrook and is within a Green Belt area in the East of St Albans and crosses the district boundary to Hatfield. It consists of land with Ancient Woods, rich wildlife habitats at pools of water and grassland, Ellenbrook Tree Reserve area and recreational land and an area in which a National Grid gas pipeline runs. The area is used daily for recreation by walkers, ramblers and those that enjoy wildlife e.g. bird and deer watchers, including members of the Hertfordshire and Middlesex Wildlife Trusts and RSPB.

There is no doubt that the application for construction of an 87 hectare quarry that will be operating for a considerable 32 year timeframe will greatly adversely affect the local environment, Green belt, wildlife, habitats, available recreational land, road traffic and infrastructure, noise and air pollution and the community. Local residents are very concerned about the impact of this plan. The plans are an industrial works on a huge scale not seen previously in St Albans.

The area is also of historical importance because St Albans is a Roman settlement and has evidence of Paleolithic (Stone Age) settlements and likely archaeological remains from the Bronze Age 10,000 years ago. More recently the site has historic importance in the 20th Century due to the runway that lay in the site from the De Havilland airfield that was important during World War 2 and in the development of important aircraft, including the Comet, the first commercial jet aeroplane in the world.

Concerns of Brett Aggregates Limited Planning Application for Quarry on Ellenbrook Fields PL/0755/16

• Loss of Green belt
• Loss of buffer against urban sprawl between St Albans and Hatfield
• Loss of Wildlife habitat leading to loss of wildlife both endangered and non- endangered
• Loss of local leisure facilities
• Loss of footpaths and rights of way
• Increased noise and air pollution resulting from the operation of the site and traffic created.
• Health concerns
• Traffic congestion on the basis of the 194 lorry movements a day proposed
• Traffic concerns in respect of A1057 Hatfield Road as the main east west route hosting bus routes, ambulances, fire engines etc. A crucial transport link.
• Property values will be affected
• Need to investigate Herts CC and look at the option of a class action for non- disclosure in the past for those having purchased property in the area since 2001.
• No impact recognition of existing activities in the area including, Cemex site, Glinwells, Existing traffic issues, Industrial estate, Oaklands College , Hertfordshire University, Hatfield Business Park.
• No impact recognition of proposed activities in the area: Cemex application for landfill up to 250 lorry movements a day, Oaklands development, Chester Nurseries development, Radio Nurseries development, Hat 2 development, Symondshyde proposal, Hatfield Green Proposal.
• The fact that the general road infrastructure is inadequate and there is no proposal to change or improve this.
• No consideration of road fragility and in particular Station Road and the bridge and constant damage to Smallford roundabout.
• No fully thought out site access plan
• No consideration of alternative access plans such as from the Hatfield Business Park
• No consideration of or consultation with the National Grid in respect of the Gas Pipeline running through the site.
• No consideration of the historical and archaeological history and value of the site
• No consideration for Unexploaded Bomb Ordinance deep in ground adjacent to gas pipeline.
• Blatant boundary infraction has occurred in the plan in that the mineral extraction area as defined by HCC has been extended in the planning application.
• No consideration of current water courses and in particular effluent output from Popefield farm
• Lack of resident consultation
• Impact post quarrying and reclamation stage not considered, thus not 32 years but longer.
• No consultation with the Ellenbrook Park Preservation Trust
• The site was provided by Goodman as part of the permission for the development of house and industrial units on the airfield site there appears to be no recognition of this and as such the previous permission must be revisited for non-compliance.
• The failure of Goodman and the relevant local councils to establish the Ellenbrook Park Preservation Trust needs to be explained and considered.
• There is no consideration in the proposal as to the sustainability impact and indeed in some areas the exact opposite to sustainability seems to be being proposed.

Conclusions

The proposal by Brett Aggregates for this quarry and change in land use should be rejected.

Detail

1. The application has shown inadequate consultation in regards to change in land use, contradiction to 106 Agreements, National Framework Policy, Green Belt Assessment land use, St Albans Strategic Local Plan Draft 2016, Hertfordshire Strategic green Infrastructure Plan and Ellenbrook Park Preservation Trust.

2. The effect on local and distant road networks and danger closer to the site access in terms of vehicles, pedestrians and congestion are also detrimental. The site and its access is fundamentally unsustainable and still would need to be proven. The current load and high demand on the local roads and access site has not been evaluated adequately. Recent local housing developments that have been agreed are going to increase capacity before the extra demand by a quarry. This is compounded by the recent planning acceptance for Cemex to infill their adjacent quarry with 300 HGV movements per day. 32 years of operations with considerable times of work on 6 days of the week with 194 extra vehicles from this application are unmanageable and have not been shown to be acceptable.

3. No evidence has been provided that this site is better than another for such a mineral quarry. Rickneys Quarry site does not have as significant concerns with archaeological and historic issues, district boundary/green belt functions, amalgamation of two towns, change of land use from Green Belt and breaking Ellenbrook Nature Park Trust & 106 Agreements, loss of recreational land and wildlife & habitats, significant impact on traffic congestion, noise and dust pollution on nearby and distant communities and the dangers with a gas pipeline on the site Other sites may also be more preferential considering the Hertfordshire Mineral Local Plan Review 2002-2006, Adopted March 2007 document is out of date and does not now represent the current site use and its sensitivities. That document only set out potential sites and does not determine which is most appropriate.

4. There has not been any adequate data and research indicating safety in terms of air pollution from dust exposure to the local area. 32 years of exposure to local residents and businesses carries high risk in regards to respiratory disease and exacerbation of pre-existing conditions. This may result in successful legal challenges against authorities/mineral firms by those affected. This needs to be considered with the adjacent Cemex quarry work and the combined increased HGV vehicle loads in the area that these two works bring.

5. The application has significant errors and omissions in regards to the site, wildlife, green belt use, buildings and traffic impact that cannot be ignored and hence make the application untrustworthy and untenable.

6. Ellenbrook Fields was established by way of a section 106 agreement between St Albans City and District Council, Welwyn/Hatfield Borough Council. The Ellenbrook Park Preservation Trust was agreed to be set up with these Councils, Colney Heath Parish Council and Goodman Group. A full inquiry needs to be undertaken why the Ellenbrook Park Preservation Trust has not been set up prior to considering any planning submission. In particular, reasons why this has not come about, those at fault and an analysis why the public should lose the benefits of the site for the financial gain of a landowner, mineral company or third party need to be undertaken.The investigation should determine those who may gain from loss of the green belt site and the delay in forming the The Ellenbrook Park Preservation Trust. This includes investigation into the above Councils and Goodman Group. The public should be content that delay or obstruction, intentionally or not by lack of action, will not prejudice this application with the associated loss of Green Belt, recreational amenities, wildlife and their habitats. The Trust should be established over others’ gain, including financial. Investigation should also make clear the influences and intentions associated stakeholders have on future developments including housing and district amalgamation.

7. The site has importance in regards to ancient archaeology and modern WW2 history and has the listed Popefield Farm building. Full appreciation needs to be duly given to these issues which has not been performed. Full consultations need to be undertaken by affected stakeholders and time given for them to voice their concerns.

8. The site/adjacent land has been shown to have bromate contamination that could affect a water source. No indication of how this will be affected the plans has been made clear or how it will be managed if issues arise. The adjacent running stream to Popefield Farm currently discharges residential effluent into a running stream by agreement with the Environment agency. There are no provisions to ensure that this stream continues to flow or how it will be managed.

9. The National Grid gas pipeline crosses the West of the site from South to North. There is no evidence that guide lines to ensure its protection are being followed for safety to the area and local houses and businesses. These do not seem to have been taken into proper account especially as there are potential unexploded ordinance bombs from WW2 on the site.

10. Various organisations have made it clear previously that the site has importance for recreation use, access footpath use, historic interest, important wild life and habitats including protected species with potential permanent destruction. Adjacent ancient woods and their wildlife and habitats will also be affected or destroyed.

11. The plans of works are from 07:00 am and 18:00 pm Monday to Friday and 07:00 to 13:00 on Saturday for 32 years. There is no evidence provided that the plans are sustainable for this extent in this locality, nor that it needs this operation.

12. The Brett Quarry application does not fulfil Aim 3 of the Hertfordshire Mineral Local Plan Review 2002-2006, Adopted March 2007 document or the methodology outlined in the Hertfordshire Mineral Local Plan Site Selection Methodology Report. It will have a 32 year adverse impact on the environment, highways and local businesses and people.

The proposal by Brett Aggregates for this quarry and change in land use should be rejected.

Images

Figure 1 – Map of the proposed site in red.

Smallford with Oaklands Lane (Pink) and houses to West (Orange) and proposed access road (Yellow). Current Cemex quarry to North West (Grey). Ancient woods to the North and old De Havilland runway extending into centre.

Figure 2 – Ellenbrook Fields/Ellenbrook Nature Park site showing extent to Hatfield on the East with Hatfield Business Park.

The boundary on the left extends towards Oaklands Lane in St Albans. Popefield Farm is at the bottom square midway at the district boundary between St Albans and Hatfield. Ellenbrook Tree reserve is to the North-East of this.

Figure 3 – Article from the Herts Advertiser newspaper in 2011.

Detailing the whole site to be secured by St Albans City & District Council & Welwyn/Hatfield Borough Council as green space parkland as 106 Agreement.

Figure 4 – Map indicating district boundary

Running vertically (hashed line) approximately centrally through site.

Figure 5 – Hatfield Road looking at proposed access site.

Past the footpath sign at current entrance for walkers. This is a busy road liking St Albans and Hatfield.

Figure 6 – National Grid pipeline 1

Marked on the site at West close to Oaklands Lane, Notcutts Garden Centre and Chester Nursery housing development.

Figure 7 – National Grid pipeline 2

Marked on the site at West and one of the new tree plantations.

Figure 8 – Extent of site size.

Hatfield Business Park visible in distance.