Proposed gravel extraction/industrial waste processing at Brockley Wood
Following a parish council meeting, Bentley Parish Council proposes to strongly object to this application - see our objection below.
The application for a gravel pit and waste processing industrial plant at the North end of the village threatens to put large volumes of HGV traffic through the village, and to damage our ancient woodlands and wildlife at Brockley Wood and Old Hall Wood.
The application is through Suffolk County Council (SCC/0105/22B).
The closing date for comment is 23rd December 2022.
If you value our rural tranquility and the woodlands, please respond individually or together by email to email@example.com (include your name and address)
The map shows the extent of the planning application in red with the industrial plant in green within 10 metres of Brockley and Old Hall Woods.
These maps show the type of machinery for the industrial plant area with cross sections across the site
Bentley Parish Council: response to SCC Planning Application - SCC/0105/22B
Gravel Pit for the extraction, processing and sale of gravel and positioning of an industrial plant for waste processing, concrete batching sales and access works in an environmentally and ecologically sensitive area.
Bentley Parish Council
OBJECTS to these proposals by reason of:
1. Impact of associated and resulting excessive traffic though Bentley on quiet lanes and the village centre,
2. Siting of an Industrial waste processing and concrete batching plant in an inappropriate rural setting, on the village border, adjacent to ecologically important ancient woodland and close to Bentley Old Hall, a 2* listed building, resulting in.
a) environmental impact of noise, light and dust pollution, visual impact and watercourse pollution.
b) ecological impact on ancient woodlands (County wildlife sites) and nearby countryside.
c) impact on the setting of the listed building, its residents, and those of nearby buildings
d) Impact on the amenity of residents’ enjoyment of footpaths woodlands, quiet countryside and dark skies.
This application has been inadequately and inaccurately presented, contains significant errors, with incorrect and incomplete supporting evidence and a lack of consultation of relevant bodies and affected Bentley landowners and residents. See supporting evidence.
The traffic assessment provided presumes all 358 traffic movements generated by the site will use the A12 to depart and arrive (Ref 1) No account is made of traffic to or from East of the site – North Essex and the Shotley peninsula via the A 137, or any contingencies if there are blockages on the A12, or the A14 which occur frequently.
Any driver to or from the site, using GPS Satnav. or aware of local roadways could be directed via the C456/425 – Bentley Hall Road, which is a single track designated Quiet Lane, or C426 Capel Rd./Station Road through the heart of the village, or conceivably C425 Church Road, a single track designated Quiet Lane, past the Church and village school. All these are accessible from the slip roads connected to the site.
Any such access would cause major impacts and pose potential dangers to village residents and traffic, including pedestrians, cyclists and equestrian users.
The traffic from the neighbouring Tattingstone landfill to the East of the village, site is subject to an agreement not to use routes through the village.
Condition: In the event of approval of the application, an enforceable condition should be undertaken by the site managers that site traffic should not use the C class routes though Bentley village (or, presumably Belstead) but access the A. 137 via the A12/A14.
The siting of the proposed industrial waste processing and concrete batching plant on the location proposed could not be worse from its potential impact on the adjacent ancient woodlands and associated wildlife. The ecological assessment provided has significant omissions and unjustified conclusions.
Brockley Wood and Old Hall Wood are County wildlife sites and, with the connecting hedgerow form most of the southern and western boundaries of the industrial plant site. Old Hall wood, contrary to the assertion in the environmental assessment, has a significant history as being on of the principal study sites of Claude Morley, entomologist founder of the Suffolk Naturalist society.
Badgers. The ecology report is inaccurate. It fails to note a large active sett on the Western border of the plant site (location available) with associated badger activity across the site
The name Brockley Wood implies long association with badgers and badger activity and sett is identified in the survey in the North of the site. From personal knowledge there are or have been several setts in both Brockley and Old Hall Woods, and a walk through of the footpath at East of the site shows further evidence of Badger activity. The survey indicates that disturbance to badgers is likely. Mitigation proposed includes blocking local sett entrances, but takes no account of continual disturbance by noise, light, continued overnight occupation of the site and moving traffic
Bats. The survey notes the frequent presence of at least six bat species present on transect and static recording. Potential roost sites were noted Some were inspected on single occasions only. Assumptions made in the assessment that the impacts of noise on bat roosts and of light and noise on foraging bats would be ‘negligible’ are unfounded. A third-party comment is essential.
Hazel dormice. Historically the records of dormice from Bentley and Belstead were the only records in the East of the County (Bullion – The Mammals of Suffolk p.54). The finding of a Dormouse at Old Hall in 2002 prompted an extensive survey which identified a cluster of sites locally in Bentley (ibid. p 57), since when some replanting of hedges as wildlife corridors e.g. along the side of the A.12 along the access route has been undertaken to encourage them further. Although the report indicates no Dormice were found in their surveys it is notable that in 3 of their nest tubes left in situ (2,3 and 4) there was externally visible evidence of occupation or use (November 21st. 2022). No record is mentioned of other usage or occupancy of the survey tubes in the report.
It is highly unlikely that the operations at this site will not impact on Hazel Dormice populations, and a further third-party assessment is essential.
See also comment Colin Hawes FRSB appendix 1
It is also noteworthy that deer are not mentioned. The site hosts Roe, Fallow and Muntjac deer.
Birds. The survey offered significantly under records known local breeding birds including Eurasian Hobby (Brockley wood a known breeding site), Common Buzzard and Tawny and Little owls and wintering birds such as Siskin and Lesser redpoll and Skylark. The impact of the industrial site on Owl behaviour is not assessed. The current fields are a significant nesting site for Skylarks, and adjacent hedgerows for Yellowhammer, Whitethroat and other priority species. The impact on these, apart from loss of breeding territory is assessed as minor without supportive evidence.
A third-party comment is essential.
Invertebrates It is interesting that the surveyor makes no mention of butterflies. Old Hall Wood is a site of important populations of White Admiral and Silver-washed fritillary butterflies – rare but re-merging species locally. Impact such as dust could well affect the breeding and spread of these. The adjacent farmland and path edges are host to other species including Little and Essex skipper, Large Skipper, Brown Argus, Common and Holly blue, Small Heath and other species potentially susceptible to the environmental damage incurred.
The environmental statement fails to mention that the access route, and parts of Brockley Wood and Old Hall Wood lie within Bentley and the Southern border of the site is on the Bentley boundary, The environmental impact will be predominately on Bentley residents, on Brockley Wood, Old Hall Wood and those residents who enjoy the amenity of footpaths from Bentley in and near the site.
The proposed location of the plant site currently benefits from dark skies which is acknowledged in the lighting impact assessment. This assessment is a desktop exercise, and though it mentions attempts to minimize impact on flora and fauna, it does not specifically assess the impact on residents of Old Hall, and does not specifically address the impact on Bats, Badgers, Hazel dormice, Owls and other nocturnal protected species.
It makes no mention of HGV and car headlights, which will be in use during evening working hours between mid-October and mid-March.
The presence of 8m, street lighting pylons on the boundary of the site will inevitably impact on the skyline, and the presence of residential staff and security lighting will cause continued lighting impact after working hours.
The noise report acknowledges that there will be an adverse impact of noise on residents and wildlife but does not quantify these. In particular, the impact of peak noise levels due to waste lorry tipping and earth moving over the18 years+ operation at the site seems not to be a consideration. Government guidance is available (appendix 1)The residents most sensitive to the noise impact are at Bentley Old Hall and Bentley Barn at 300 m. from the site. The location of the waste processing and concrete batching operation on the site, if necessary, at a more remote part of the site could attenuate some of the noise nuisance.
The washing of waste and discharge of the washings to ground, risks contamination of the water table. Although waste processed at the site is proposed to be ‘inert’ there seems to be no sorting or testing proposed on site, and no programme of testing the settling water. All water discharges from the site are into the ground water. The Ph of ground water would be altered by concrete washing.
Additionally, according to the surface water drainage report provided ‘Sites with heavy pollution (e.g. haulage yards, highly frequented lorry approaches to industrial estates and waste sites) are classified as having a high pollution hazard level.
Dust and air quality
Concrete processing on site will cause release of concrete dust with an impact on air quality on site and the adjacent sensitive woodland. This would be less ecologically damaging with a more remote location of the plant if such is needed.
Setting of Grade 2* listed Building – Bentley Old Hall
Bentley Old Hall lies 300m. from the boundary of the Industrial plant site. It is a 13/14th Century Hall House (the oldest in Bentley, and noteworthy for its isolated rural setting).
This industrial development would materially impact the setting of the building by reason of visual intrusion, noise and light and have a grave impact on the residents of Old Hall and the adjacent Old Hall Barn.
It is noteworthy that Heritage England was not consulted in the compilation of the application.
Loss of Amenity to residents
The footpaths through the site, particularly Old Hall Wood are accessible to residents, particularly from Bentley and Belstead, and particularly enjoyed for their paths through the woods with spectacular Bluebell and Wood anemone displays, and the rural views and tranquility of the setting. Some footpaths will be closed and there are safety concerns for pedestrians using the footpath that will run alongside the access road being used by HGV traffic to connect to the site.
Appendix 1 – Comment: Colin Hawes FRSB
Brockley Wood Gravel Extraction
All of Bentley’s woods including Brockley Wood are County Wildlife Sites. Hazel Dormice are present in all these woods. Hazel Dormice breeding sites and resting places are protected by law under the Wildlife and Countryside Act 1981 (as amended) and the Conservation of Habitats and Species Regulations 2017.
Regulations state that you must not do any of the following:
- Deliberately capture, injure or kill Hazel Dormice
- Damage or destroy a dormouse resting place or breeding site
- Deliberately or recklessly disturb a Hazel Dormouse while it is in a structure or place of shelter or protection
- Block access to structures or places of shelter or protection
- Possess, sell, control or transport live or dead dormice, or parts of Hazel Dormice.
Activities that can harm Hazel Dormice
- Disturbance, e.g. noise and light, woodland and hedgerow management
- Habitat removal, clearing woodland and removing hedgerows Habitat fragmentation and isolation
Note: Hazel Dormice travel between suitable habitats that are close to their breeding and resting sites in order to feed or to start a new colony. Disturbance caused by noise and light can prevent this (see 2. above).
Should planning application SCC/0105/22B be granted then it is highly likely that disturbance of breeding and resting dormice in Brockley Wood,Old Hall Wood and Long Wood by noise and light will occur.
The Hazel Dormouse is an endangered species and its conservation in the UK is the responsibility of the People’s Trust for Endangered Species.
Colin Hawes BSc (Hons), Dip. Env. St., C. Biol., FRSB.
Independent Consultant Ecologist
Appendix 2 - What are the appropriate noise standards for mineral operators for normal operations?
Mineral planning authorities should aim to establish a noise limit, through a planning condition, at the noise-sensitive property that does not exceed the background noise level (LA90,1h) by more than 10dB(A) during normal working hours (0700-1900). Where it will be difficult not to exceed the background level by more than 10dB(A) without imposing unreasonable burdens on the mineral operator, the limit set should be as near that level as practicable. In any event, the total noise from the operations should not exceed 55dB(A) LAeq, 1h (free field). For operations during the evening (1900-2200) the noise limits should not exceed the background noise level (LA90,1h) by more than 10dB(A) and should not exceed 55dB(A) LAeq, 1h (free field ). For any operations during the period 22.00 – 07.00 noise limits should be set to reduce to a minimum any adverse impacts, without imposing unreasonable burdens on the mineral operator. In any event the noise limit should not exceed 42dB(A) LAeq,1h (free field) at a noise sensitive property.
Where the site noise has a significant tonal element, it may be appropriate to set specific limits to control this aspect. Peak or impulsive noise, which may include some reversing bleepers, may also require separate limits that are independent of background noise (eg Lmax in specific octave or third-octave frequency bands – and that should not be allowed to occur regularly at night.)
Care should be taken, however, to avoid any of these suggested values being implemented as fixed thresholds as specific circumstances may justify some small variation being allowed.
What type of operations may give rise to particularly noisy short-term activities and what noise limits may be appropriate?
Activities such as soil-stripping, the construction and removal of baffle mounds, soil storage mounds and spoil heaps, construction of new permanent landforms and aspects of site road construction and maintenance.
Increased temporary daytime noise limits of up to 70dB(A) LAeq 1h (free field) for periods of up to 8 weeks in a year at specified noise-sensitive properties should be considered to facilitate essential site preparation and restoration work and construction of baffle mounds where it is clear that this will bring longer-term environmental benefits to the site or its environs.
Where work is likely to take longer than 8 weeks, a lower limit over a longer period should be considered. In some wholly exceptional cases, where there is no viable alternative, a higher limit for a very limited period may be appropriate in order to attain the environmental benefits. Within this framework, the 70 dB(A) LAeq 1h (free field) limit referred to above should be regarded as the norm.