Fittleworth & District Association Objection letter

FITTLEWORTH AND DISTRICT ASSOCIATION
REGISTERED CHARITY NO. 275440
The Association is affiliated to the Council for the protection of Rural England
C/O MURRAY HOUSE
BEDHAM LANE
FITTLEWORTH
WEST SUSSEX
RH 20 1JH
14th May 2010 07717293710
Email: michael.elliott@tinyworld.co.uk
Mr James Neave
Environmental & Planning Department
West Sussex County Council
County Hall; West Street;
Chichester; West Sussex; PO19 1RG

Dear Mr Neave
Our response to the Barlavington Planning Application for a Sand Quarry at Horncroft –
application ref: WSCC/053/10/BY

Our Association has worked hard for 37 years “to preserve the rural character of Fittleworth and its surroundings”. We represent the views of many residents in Fittleworth and areas closely affected by this application. You will be aware that Fittleworth residents have expressed very strong opposition to this application as have other Villages that will be affected by this quarry at Horncroft.

We have over the past 15 years expressed on a number of occasions our reasons why this area around Horncroft is a very special area and should not be damaged by permitting sand extraction. Most recently in March 2008 we were able at a meeting with the South Downs National Park Inspector to successfully argue the case why Fittleworth and its surroundings including Horncroft are a true area of outstanding natural beauty which must be protected by its inclusion in the National Park. We feel as strongly today that this area with all its facilities must not be destroyed by this sand quarry application.

We are very disappointed that this application has been made and is being considered by West Sussex County Council (WSCC). We set out below our reasons why this Application should be rejected by the County Councillors.

IMPORTANCE OF THIS LANDSCAPE
• Locals View. Residents and Visitors have always given great value to the area of the site for:
- its proximity to Sutton & Coates Commons and Lord’s Piece ;
- the Serpent Trail Public Right of Way;
- the woodland features and habitats it offers;
- the wonderful sounds of birdlife with the absence of man-made noise;
- the many areas for beautiful tranquil walking surrounding it;
- the topography of the area with it ancient wooded elevations and the woodland views it offers from surrounding areas particularly from Hesworth Common and various other elevated areas in the village of Fittleworth, and from the South Downs Way east of Bignor Hill.
Page 1 of 12

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 2 of 12
• Views of Experts
In 1998, after WSCC excluded this site (then only 6.9ha) from its Mineral Plan, an Inspector was required to consider an Objection. In his conclusions he expressed the following words which explain particularly well then and today why this area must be protected from despoiling by a sand quarry. His words are even more valid today as rural areas such as ours are threatened by ever increasing pollution & damage from noise and traffic. And the increasing need for people to ‘escape’ from growing urban centres.


We ask you to give his words full consideration in your assessment of what this area offers and the damage which would occur. Please also ensure County Councillors are aware of the Inspector’s words:

5.330 “On the landscape issue, the Council stated that the site is located in a very tranquil, rural part of the AONB. The objection claimed the extraction would be well hidden, being screened by existing woodland and the natural topography of the area, that the site is not overlooked by higher ground, nor is it close to inhabited properties. However, in my opinion, mineral working on the site would be visible at least from public rights of way in its vicinity and also, in all likelihood, from heathland to which the public will enjoy permissive access. The presence of working would be emphasised by the creation of a new road access from the B2138 and the clearing of trees. An earth bank might screen the internal part of the site from view, but the sides of the bank would themselves be raw and, therefore, prominent.

5.331 “However, not only are the surroundings rural, they are remote, which is part of the attraction of this part of the AONB. Consequently, I consider that the harm to the landscape if mineral workings were to take place at the proposed site would be serious and, in addition, the commercial activity would damage the enjoyment of the area for the people who come to appreciate the remote and tranquil character of the AONB. There may well be a need for the identification of more sand in the Plan, but the need would have to be far greater for me to recommend this site for inclusion under policy 34.”

These words above state very clearly the features of this area and the very damaging affect this quarry would have and why it cannot be justified for approval.

LANDSCAPE AND VISUAL IMPACT ASSESSMENT
Attached is a document giving detailed information on this area and a response to the Landscape and Visual Impact Assessment (LVIA). We ask you to give due consideration to the contents in this document and to ensure those County Councillors involved in the decision on this application are aware of it. This response very clearly explains that:
• There will be “ substantial adverse impact” on views from the South Downs Way (4km away), views between 1 – 3 km from the Quarry, and all points along the PROWs including the Serpent Trail and from the viewpoint at Hesworth Common.
• The view of the Downs as you proceed south from Fittleworth on the B2138 will also be significantly affected by the access road, the new earth bunds , signage and CCTV facilities;
• It is the opinion in the document that the planting will not provide effective screening.
It is our opinion that the “restored“ quarry will not, as claimed by the Applicant, produce a landscape that is of a higher quality than is currently the case.
FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 3 of 12
ROLE OF THE SOUTH DOWNS NATIONAL PARK
1 Reason for Inclusion of this area in the National Park. Many argued successfully why this area had much to offer in its varied landscape and enjoyment activities for people and must therefore be included in the new National Park.
“The twin purposes of the South Downs National Park are:
1. To conserve and enhance the natural beauty, wildlife and cultural heritage of the area
2. To promote opportunities for the understanding and enjoyment of the Park’s special qualities by the public.
This application, should it be granted, would be in direct conflict with both these purposes.
2 Decision making in the National Park and responsibility for activities.
We know that the South Downs National Park Authority will become responsible for all planning decisions in the National Park. As there is less than 11 months to go before the National Park has full responsibility for all decisions of this nature, we find it quite unacceptable for WSCC to take a decision on this application which, if granted, would degrade this area and would be in direct opposition to the aims of the National Park.
As we wait to hear who will be responsible for the enforcement of planning decisions and their conditions in the National Park, we do not believe it is acceptable for WSCC to handle this application when there are such important conditions to be agreed.
3 Government instructions on mineral extraction in National Parks – “ Exceptional cases only”
Government has clearly stated that approval for a new extraction site in the National Park can only be given in exceptional cases. There is no evidence in this application that it is an exceptional case. We consider with less than a year to go before the National Park Authority becomes effective, this application and whether it is exceptional should not be decided by WSCC who has itself encouraged this application.

WSCC MINERAL PLANS
Linkage of WSCC Mineral Plans to this application
• There is confusion over the relationship of this Planning Application to the WSCC Mineral Plans. We have been told by a County Councillor that WSCC Mineral Plans have no bearing on this application. We do not understand how this can be the case as the Mineral Plan is key to the strategy for mineral extraction sites and the application makes regular reference to them. Can you confirm whether WSCC Mineral Plans will be taken into account in any decision on this Application.
• The Application makes regular reference to and uses information from WSCC Mineral Plan documents. However these references are to the “Mineral and Waste Development Framework“ Version 2 December 2009 which was issued for consultation in January 2010. We responded to that consultation. Clearly this document is not yet approved and is only “work in progress”. We do not accept its content can be used, as the applicant is doing.
• In 2005 we participated in the Mineral Development Plan and it our understanding that this 2005 plan was approved and is the one in force. Please advise which is the currently approved Plan.
• Having rejected Horncroft as an “acceptable” site in 1998, you again rejected this site in 2005 stating it was “not acceptable in principle “. As you are currently only in the consulting stage on revising the Mineral Plan (in which you have changed your assessment of this site to “acceptable in principle”) we contend that this consultation document cannot be used as a basis for approving this application. Only the approved Plan should be used and that states this site is not acceptable.
FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 4 of 12
Linkage of WSCC Mineral Plans to this application - continued
• We can find no explanation in your Version 2 documents for you changing the status of Horncroft from being “not acceptable in principle “in 2005 to now “acceptable in principle”. This change is even more inexplicable as the site is now 3 times larger than in 2005 Please advise us of your reasons for this major change.

SITE SIZE & SITE ASSESSMENT
Unexplained Increase in the size of the Site to be Quarried
• In all Mineral Plan documents up to the 2009 consultation paper, the size of the site has been 6.9ha from which 1.5 million tons was to be extracted. This application now intends to extract 1.5m tons over 20 years at the same level of 75,000 tons per year from an area of 19.80ha + 2.86ha for access, No explanation is given in the Application for this 2.9 times larger site.
• With a County Councillor mentioning 150,000 tons pa and not 75,000 and saying “Barlavington was shrewd to offer 150,000 tons p.a” we are understandably suspicious of how much is going to be extracted. An adviser has considered the site size and depth and indicated that more than 2.0m tons could be extracted.
• There is no mention of whether any legally binding guarantee will operate limiting extraction to no more than the stated 75,000p.a over the life of the site. Allowing a higher extraction rate would have even more major adverse implication on transport and noise.
• We consider that the Applicant should have justified the increase in the size of the site.
• The site was deemed unacceptable at a size 1/3rd of what is now proposed. Clearly it is quite unacceptable now. Please explain why you accept the site being so much larger for the same 75,000 tons pa and confirm that you have not been discussing 150,000 tons pa.
Risks to the 20 years of operation and the level of annual extraction.
• As sites like Heath End have been extended by 6+ years over their stated closure date, we feel it is very likely that this very large quarry at Horncroft will operate for more than 20 years and/or have its annual extraction rate increased above 75,000 pa. How will WSCC ensure that this cannot happen and what form of guarantees would there be.
• How would legally binding guarantees be given to ensure that the site would be properly restored and no other activity undertaken on the site. Statements that the Applicant guarantees it are not adequate.
Assessment of this site.
• The Mineral Plan documents list the key criteria to be considered in the assessment of a site. The latest assessment of Horncroft by WSCC fails to provide clear reasons why WSCC has made the change in the assessment of the site “ to acceptable in principle” particularly as Consultation paper 5 does state you still have to assess many of the criteria. In this letter we have commented on areas where the site fails to meet some of the key criteria
• We do not accept your exclusion of the Transport criteria in your comments on the assessment. This is a very major issue. We explain our concerns in our Roads & Traffic section.
• The assessment of the buffers to SNCI & SSSI should not be ignored by WSCC.
• We note you have asked the Applicants to provide you with an assessment of each of the sites on the “Long List”. We are surprised that WSCC should request this as there is clearly a conflict of interest. We expect WSCC to have an independent body do this assessment. Please confirm that WSCC will not use the Applicant’s Assessment of all the sites and their classification of Horncroft as a Preferred Site.


FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 5 of 12
THE ISSUE OF “NEED” TO JUSTIFY THIS APPLICATION
• Commenting on Need. We were very surprised to be told by a County Councillor that any comments we make on the “Need“issue would not be considered by the WSCC decision makers. We have been advised that we are entitled to raise our concerns on this issue and that you are obligated to consider our comments. We feel our right to be heard is further confirmed by the lengthy reference to this issue in the Application documents.
• Queries & Issues on ‘need' to be resolved before new site approved. We consider that there are so many questions and reservations about the amount of soft sand required and the reserves held that the decision on this application should not be rushed through at this time. Some of the reasons for questioning the validity of the need figures are:
- uncertainty of the split between sand pits & gravel pit apportionment;
- no split between soft sand & sharp sand in Annual Production numbers (Table 1);
- uncertainty of actual output numbers as, surprisingly, there is no obligation on operators to provide output numbers. So last 5 years all include estimates;
- accuracy of the reserves figures - either supplied by operators who probably understate or estimated made by WSCC. These need to be reviewed before such a big decision is taken over this new quarry;
- change in government is likely to result in reduction in local new homes numbers so reducing need of soft sand for local building sites;
- many permitted sites have experienced such low levels of output that the reserves and output requirement must be reviewed;
- the apportionment figure needs to be reduced to recognise the major reduction in actual gravel extraction;
- growth in recycling of sand & gravel with 629,000 tons in year 2008/2009 needs to be encouraged and should impact extraction levels and be recognised in the apportionment figure
- Eco homes expected to reduce amount of soft sand needed.
• “Government requirement on the Landbank”. The MWDF document of December 2009 states that there is a “large & growing demand for building and construction products manufactured from these minerals and so the apportionment rate for sand & gravel is set by the Government at 0.91million tons per annum”. With the annual average actual production levels over the past 8 years at only 80% of the 0.91 million tons target and only 65% over the past 5 years average ; demand has clearly been below the target level and it calls into question the validity of that target figure.
With these lower actual levels of production, it also confirms that there are much more resources left than the potential in the actual 6 .7 years calculation versus the 7.0 years stated to be required.
• Gov’t targets in a National Park. When the government set this 7 year landbank target the South Downs National Park had not been approved. Now the National Park exists there are clear rules that need to be applied. Horncroft does not meet the “exceptional circumstances“ requirement.
Precedent in other National Parks indicates a clear reluctance to open new sites. Also that Gov’t will accept shortfalls in NP landbank figures. WSCC’s current shortfall of just 3.9% would be readily accepted so WSCC is unable to demonstrate that this extra soft sand from a National Park area is essential and must be approved; it is not an exceptional case.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 6 of 12
THE ISSUE OF “NEED” TO JUSTIFY THIS APPLICATION - continued
• “Sand & Gravel Provisions” (Table 3). This shows that the permitted reserves at end 2008/9 were 6,123,000 tons which represents 6.729 years against the 7.0 “government target”. This means that, using the 0.91m tons target, only another 35.1m tons p.a. are required for the next 7 years. This increase could easily be met by an increase of just 3.9% in the annual allowances at existing sites; we feel sites would be happy to be permitted to increase supply since demand has been so low over the past couple of years. With Heath End only achieving 20% of their annual permitted level in the past year, their reserves will have increased again and so there must be a need to increase/extend their permitted levels.
• Issue of the Apportionment figure and the splits within. We note all you comments on this apportionment issue in Background paper 3 and support all attempts to resolve it to give a relevant and meaningful figure. We consider this must be properly resolved before any new sites are approved such as Horncroft
As the apportionment requirement of 910,000 tons pa has always been based on a combined supply of sand and gravel, it is clearly a meaningless requirement now that the level of actual production from “Gravel pits” has fallen to so low a level at just 4% for 2008 and an average of just 7.5% over the past 3 years. This level of 2% of the apportionment figures from gravel pits means WSCC, by focussing on this apportionment figure, is trying to claim that all the sand reserves need to cover 891,000 tons pa which is quite unacceptable. It highlights the dangers of using figures which are so removed from reality to justify such a decision as opening Horncroft. Please explain if we are incorrect in this analysis of your justification for Horncroft.
• Changes in the Permitted Reserves. It is noted that the level of “Permitted Reserves” (sites with permissions) at end 2008/9 year are 6.1m tons which was an increase of 2.223 m tons from the 2007/2008 level. This major increase is not explained but it suggests that existing sites are reporting higher reserves and so the 3.9% shortfall should be met from existing sites.
We believe you should wait until the permitted reserves are reported for 2009/10 and assessed, before a decision on Horncroft is considered. Based on what happened in 2008/09 it is almost certain the reserves will increase again. It reinforces why a decision on Horncroft should not be made at this time.
• Existing sites and the “long list” review. Proper consideration of extending existing sites is required before any decision on Horncroft is taken. Also no consideration of Horncroft should be made without a full independent assessment of the entire list of “long sites”. WSCC states that full consultation is not proposed until Winter 2010
• Soft Sand figures. These need to properly identified and separated from sharp sand figures. If soft sand represented 25% of the reserves then adding Horncroft would double the existing supply. Can you advise what is the actual split between soft sand & sharp sand both for the production and for the permitted reserves. Table 5 in Background paper 3 does not support using a split of 80% soft sand in the justification.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 7 of 12
THE ISSUE OF “NEED” TO JUSTIFY THIS APPLICATION - continued
• Applicant’s statement (2.5) “a substantial shortfall in soft sand in the Plan period to 2026”
They have referred to the WSCC Background Paper 3 but there is no clear evidence in it supporting that statement of a substantial shortfall. In fact the Background Paper 3 clause 3.14 makes a very misleading statement - “the decline that has taken place in sand and gravel production since 2001 makes the delivery of the apportionment figure for primary aggregates more challenging“. This appears an incorrect statement as a lack of demand means there is more left in the reserves for meeting the apportionment; it also calls into question the credibility of the apportionment figure. Could WSCC please explain their comment in 3.14 and the actual details to support such a statement by the Applicant and clarify the comment “ substantial shortfall.
• Use of the Regional Spacial Strategy. The RSS figures need to be clarified as to soft sand requirements.
• Requirement to demonstrate the ”proposal to be in the public interest” and ”an overriding need” With all the above uncertainties about the need for the Horncroft soft sand , the criteria listed in your MDWF Paper 5 Background is not met . The criteria state that the “proposal should be demonstrated to be in the public interest before being allowed to proceed” and “there may be an overriding need”. Clearly these criteria cannot be met in this application. If you believe the Application meets these criteria please explain how it meets them.
• Existing Site extensions and the influence of Industry. It is our impression that the latest draft MWDF has been overly influenced by ‘the industry’ who have advised WSCC that; there should not be a preference for extending existing sites; AONB’s and the National Park should not be considered as special areas when agreeing mineral sites; and that the ease of sand extraction in the National Park area compared with the more easterly part of the Folkestone sand belt means that sites within the National Park should be considered more favourably.
Industry needs to recognise that the National Park and AONB’s are recognised as valuable to the Nation as a place of beauty, tranquillity and tourism. While a monetary value cannot always be properly placed on this quality, we are in no doubt that it has present and future economic value to local people, which will be in jeopardy should opening new sites in the National Park such sites as Horncroft be permitted when the clear need cannot be proven.

IMPACT ON FITTLEWORTH VILLAGE & THE LOCAL ECONOMY
• Impact on enjoyment. This beautiful area with its many walks provides a lot of enjoyment to the residents of Fittleworth and surrounding villages and also importantly to many visitors to this area. This proposal will have a major impact on that enjoyment.
• Error in Application. The application incorrectly states that the location of the site is either 2km (clause 5.4) or 2.5km in (clause13E.1/9.E.1). It is in fact less than 1 km.
It also wrong in its description of the types of properties affected as there are many reasonably sized houses with families starting within ½ km from the site.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 8 of 12
IMPACT ON FITTLEWORTH VILLAGE & THE LOCAL ECONOMY - continued
• Misleading/erroneous statements. The application also misleads when it states (5.14) “the proposed sandpit is in an out-of the way and well screened location” There are 2 important commons and an important PROW (the Serpent Trail) directly adjoining the sandpit which many walk on. It is not out of the way and the views of the site are very clear. The enjoyments of the views and walks will be greatly reduced by this proposal - to which must added the substantial noise of the equipment/vehicles on the site.
• Impact on National Park. One key purpose of the new National Park is “To promote the opportunities for the understanding and enjoyment of the park’s special qualities by the public” This sandpit will destroy that objective for this area around Fittleworth.
• Impact on local businesses. With the reduction in walking enjoyment, the change in the B2138 and its views, the added signage & CCTV, increased HGVs and the noise of a quarry, Fittleworth is likely to be viewed as a Village-with-a-Sand-Quarry. So instead of local businesses benefiting from the National Park, they will be hurt by this proposal – with reduced visitors. The National Park Inspector agreed that Fittleworth Village provided a worthy entry point to the National Park. That is being destroyed by this proposal
• Tourism – Fittleworth loss v Barlavington gain. It is unacceptable for the Applicant to state “the Estate is looking carefully at its assets with the Local planning Authorities to see how it could accommodate the anticipated demand for leisure and recreation within the National Park” (4.9) when his sandpit will have the exactly opposite effect on Fittleworth residents & their businesses. It shows the applicant has no appreciation of, or sensitivity to the impact this sandpit will have on Fittleworth, its residents and visitors. We would dispute the claim in Table 13.1 b) that “local businesses would not be significantly affected”. We ask WSCC Tourism personnel to review this impact.
• Mitigation – funds from ASLF/COMMA Can WSCC confirm that it is correct that the funds stated as being available in Clause 13.G.1 will be available to Fittleworth and surrounding areas.
• Impact on weekend visitors. Operating a quarry on a Saturday will discourage weekend visitors to stay in the area. There are B & B facilities very near the site which will be affected.
• Request for clarification. Could WSCC help clarify what the Application means in Clause 13 F.6 “the impact on local tourism and leisure related businesses…. is considered to be diffuse.” We also consider the impact on recreational and amenity value is not, as stated, “a complex and subjective matter”. It is very clear that the impact on walks will be very significant – walking is a major recreation which this area offers. There are many uses of the PROWs which will be affected by the site operations
• “Clear benefits after 20 years” –disputed. Restoring an area clearly left as a “hole in the ground“ with attempts to grow vegetation and provide an extra walk is not an added benefit which more than compensates for the reduction in the views and enjoyment of walks and other activities both during the 25 years and after. This does not come near to compensating for the removal of a magnificent elevated ancient woodland landscape which will be gone for ever. Elevations of landscape are to be valued not removed.


FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 9 of 12
ROADS AND TRAFFIC ISSUES
• The increase in vehicles through and around Fittleworth is the aspect of this application which will have the most direct impact on the lives of people in this area - on road safety, road damage , noise , pollution, tourism and interference to their lives.
Traffic is the issue which currently most affects people’s lives in this area and we do not feel that either the Applicant or WSCC have demonstrated that they understand the serious impact which will arise. Sending vehicles by another route is not a realistic solution and so does not mitigate the problem. No more HGVs should be added to the existing problems. This issue is a key reason why the Quarry should not be approved.
• WSCC Assessment on Traffic. We are very surprised that WSCC Table 2 in the Background Paper 5 fails to recognise, by omitting it from its comments, that traffic is a very significant issue for Fittleworth and other surrounding Villages.
WSCC Highways are very well aware of how traffic through Fittleworth has been and still is the major issue for the Village so we would expect WSCC to recognise that it is a very big issue in this application. Please ensure it gets proper examination from WSCC.
• Traffic Count data – clarification . There is an error in the 3312 vehicle figure in Clause 9.F.4. It is also not clear whether the figures being used reflect the actual average per day during a normal 5.5days per week; we would have thought that all the measurements should be based on 5.5 days as these are the days the site is to be worked.
As the HGV figures of 80 southbound v 23 northbound is so skewed, can you confirm it is reliable data. It is also surprising that 40% more vehicles in a day travel South than North. This also raises questions on the validity of the data.
• Meeting EIA guidelines. The application states the HGV increase is +1.0% increase in traffic and so meets EIA. This is not correct as the EIA rule says “or if HGV will increase by more than 30%”. With a potential of 60 more HGV on a day this represents an overall HGV increase of 58% and the HGV vehicles travelling North will represent an increase of 130%. So in failing to meet the rule can you confirm that they have adequately assessed the impact and met the rule requirements.
• Direction of HGV Traffic The application states 70% will go South and 30% go North. The Applicant advised that these figures are only based on the projected new homes as shown in the Chart “Figure 13.1” in Chapter 13B. This chart is very suspect as it shows no new homes in the NW quadrant – yet we know new homes are expected in Petworth & Midhurst. Surely better quality figures should have been used - such as the direction of lorries from the Heath End sandpit. If more than the 30% of vehicles go North many more villages will be affected and there will be more safety issues on the roads.
• Types of Traffic – smaller lorries All the comments discuss the HGV impact. However there is clearly an intention to sell in quantities of less than 15 tons per load as the Applicant intends to operate its own 1 ton tipper and there are sure to be customers using their own vehicles to buy quantities of less than 7 tons. Should this impact not be assessed.
• Number of HGV per day The application makes all its comments on the impact assessment on the basis of 36 HGV per day. It is our view that the impact should be assessed again the potential of 60 per day. The limit of 40 per day averaged over a quarter could still result in 60 per day over a “more normal operating” week of 4.5days (none on Saturday or Friday pm) over 10.7 weeks in a 13 week quarter. Clearly 60 is the number to be assessed.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 10 of 12
ROADS AND TRAFFIC ISSUES - continued
• Mitigation of Traffic – all to the South. While directing all HGVs to the south could reduce the HGVs through Lower Street in Fittleworth, it is the view of many that the drivers who need to come from or go to the NW quadrant will still take the shorter routes rather than go on the proposed Pulborough route. There are many ways to appear to arrive/leave in the South direction but in fact travel North by turning round - it save 3+ miles off their trip and a lot of time & cost - examples are:
o Go to the A29 spur junction; turn right onto A29 and then immediately right back up the B2138 and head North
o Go to the A29, turn left up to Coldwaltham and then left up along Waltham park Road to Fittleworth.
o 100 yards after leaving the site turn right into Bignor Park Road and go round the loop back to the B2138 just up from the A29 junction
o Go onto Bignor Park Road and then go NW onto Burton Park Road and the A285
There are clearly many easy ways to turn round and go along Lower Street in Fittleworth or use the country roads in the area. Sat Nav will also encourage these shorter routes.
Currently WSCC have advisory signs up that Lower Street is not suitable for HGV but this has not stopped such vehicles. Clearly many roads in & around Fittleworth will suffer.
• Impact of HGVs through Fittleworth on A283 The plan to route HGV vehicles onto the A283 through Fittleworth seems to have ignored the significant adverse impact it will have on this area of the Village. Just pushing the HGVs from Lower Street to the A283 is not a solution. Please arrange for traffic data on HGVs on this stretch of road to be provided & assessed.
Fully laden sand HGV travelling at 40+ mph down the Fleet will be more dangerous than allowing HGVs on Lower Street. Then they will have the very dangerous stretch of the A283 round Hallelujah bend and up through the trees past Hesworth House. Parts of this stretch of road are not wide enough for 2 HGVs and damage to the sides of the road will occur and accidents are much more likely. Has WSCC Highways department done an assessment of the safety and road damage issues associated with this route.
• Road surface problems. The B2138 has major road surface problems which WSCC to date have been unable to resolve. The Applicant has stated that they are not contributing to the necessary repairs to the current surface. Clearly WSCC need to determine how they can ensure that the road surface is made safe and maintained safe – something they have found very difficult to do to date
• Safety at the Junction of the new access road. Has WSCC Highways undertaken an investigation of the safety of the new access junction - to ensure that the intended 160metre from the point of visibility is adequate for reacting and stopping from 60mph when a car encounters a loaded HGV pulling out of the site. We have concerns that this distance is not sufficiently safe. There will also be a lot of noise for local houses
• Safety at the Junction of the A29 The attempts to mitigate the dangers of the existing A29/B2138 junction by routing all laden vehicles up the spur seem to overlook the dangers arising from these vehicle trying to handle the incline at the top onto the A29 as they join it in both directions. Getting a laden HGV up to speed over the incline will be very slow and noisy Has a thorough safety assessment be undertaken by WSCC Highways.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 11 of 12
ROADS AND TRAFFIC ISSUES - continued
• Access road and height of mounds Clause 3.8 states the landscaped mounds behind the hedge on the B2138 will be no more than 1.5m higher than ground level. But in Clause 8.F.7 it states the earth bunds will be 2.5m to3.0m high running parallel to Tripp Hill. This higher level will more adversely affect the view of the South Downs. Bunds are never an attractive site. It is disappointing that these contradictions in information are appearing in this application and leaves one wondering what other contractions exist. Can we be advised of what the actual planned height is and whether acceptable to WSCC.

NOISE
• Reversing Signal on Vehicles. This is a very distinct loud noise. The Applicant proposes a condition that this noise will not be emitted. However the Applicant states that this can only be applied to vehicles under its control; presumably because the vehicles which travel on the roads have to maintain their reversing signal. With up to 30 HGV and other smaller vehicles operating around the site each day this will have a substantial adverse effect on those trying to enjoy walks and other activities on the adjoining land and in nearby homes.
• Blasting on the site. Clause 8.F.3 states that “Blasting will not be undertaken”. It is not however listed as a condition. We consider it must be an unqualified condition under 3.35. Can you also clarify how long the conditions listed in 3.35 will remain in force as the Applicant suggested many would only apply for 5 years.
• Conclusion of an Independent Noise Survey. You will be aware of the independent Noise Survey conducted by Acoustics Associates May 2010. We ask that WSCC read this report. It expresses the opinion that the Applicant’s conclusion of “ no significant effect “ is to be queried as the evidence does not appear sufficient to reach that conclusion.

HABITAT
• Concerns & Goshawks. We support the concerns which you have received from residents on the matter of habitat and trust you will consider their concerns.
You have been told that goshawks have been seen in the area near the site. This has not been mentioned in the Ecology assessment. We request WSCC to arrange for the necessary assessment.

FINANCIAL ASPECTS IN THIS APPLICATION
• Financial Information from the Applicant in place of Bonds. The applicant has stated that no financial bonds are required. However when this change in policy 25 was made under government guidance in MPG7 there was a requirement that the Applicant demonstrate in their application what the likely financial and material budgets for restoration and aftercare will be and how they propose to make provision for such work during the operational life of the site. This is regarded as important in order to secure proper restoration. This financial and material information does not appear to have been provided. Please can WSCC arrange for this information to be made available and assessed.
• Missing document. Clause 3.34 mentions “ See Part I “ which is said to include Heads of Terms and may include the required financial information but this Part is not in the documentation which we have been given access to. We therefore believe that the Application is not complete Can WSCC arrange to make these missing documents available.

FDA Response to the Planning Application for a Sand Quarry at Horncroft – continued – Page 12 of 12
FINANCIAL ASPECTS IN THIS APPLICATION - continued
• No payments by the Applicant during the operation of the site. The Applicant has stated that they will not be making any payments to any party affected by this new quarry. A County Councillor also advised that absolutely no money is due to be received by WSCC in connection with this application other than the fee already received with the submission of the application. If it is correct that there are no annual licence fees due to WSCC or other payments including help with road repairs needed now then we ask how WSCC is expected to fund the cost of monitoring this operation and the cost of making repairs and alterations required by the project.

DECISION MAKING PROCESS BEING FOLLOWED BY WSCC
• Visits to site by County Councillors. As the impact of this site on the landscape and people’s enjoyment is so significant , can you confirm that all County Councillors who are involved in the decision taking on this application will be required to visit the area around the site before any decision is taken. We would hope this visit along the PROW and Commons, made without the Applicant, would be between 8.00 -11.00 in the morning to fully appreciate what walkers enjoy on the Serpent Trail and Lord’s Piece/Sutton Common.
• Conflict of interest. Could you advise how WSCC will handle the conflict of interest of a Councillor considering this Application which arises when they are representing a constituency which has one of the other sites on the long list.

You will see from our comments above why we strongly oppose this application.
In summary the key reasons are:
• Landscape with its tranquillity ,habitat and woodland is too valuable to damage;
• In the South Downs National Park so the WSCC should not determine this application;
• Opposes the key purposes of the new National Park and sets unacceptable precedent;
• Fails the National Parks requirement for “ exceptional cases” only;
• Adverse impact on tourism and visitors, and Fittleworth villagers & their businesses;
• Major adverse impact on road safety and traffic; and the mitigations cause greater problems. No more HGV should be added to the roads through these villages;
• Timing of this decision quite inappropriate. No need for this haste;
• Need for this soft sand is not validated and many figures require investigation;
• Noise will be greater than indicated
• Quality & benefit of Restoration is doubled and risk of higher output and extensions
• Errors, omissions and misleading comments in the Application documents - to be resolved
• A number of issues for WSCC to explain and resolve

We will be forwarding our letter to the Secretary of State and asking advice about the process for ‘calling in’ this application. In the meantime, we request 5 minutes to present our case to the Planning Committee when this Application is considered.


Yours faithfully Michael Elliott – Chairman

Attached – document on Response to the Landscape and Visual Impact Assessment LVIA



Attachment to FDA letter dated 14th May 2010 - Response to the Barlavington Planning Application for a Sand Quarry at Horncroft – application ref: WSCC/053/10/BY

Response to the Landscape and Visual Impact Assessment LVIA

Susanne Dipper BSc Hons. MSc. MPhil. Chartered Landscape Architect.
May 2010


Background to the LVIA

In response to Barlavington Estate’s request for a Screening Opinion for a sandpit or quarry at Horncroft, West Sussex County Council stated (November 1999) that: ‘By virtue of the scale and nature of potential impacts it was considered that the proposals have the potential for significant environmental impacts’, and ‘The assessment should have particular regard to the potential impacts of the development on public rights of way, public areas (Sutton Common), and the AONB (now national park) and the South Downs, and how this would be mitigated’. WSCC also noted ‘the potential to impact on the South Downs National Park and conserving and enhancing the natural beauty, opportunities for enjoyment by the public, wildlife and cultural heritage of the national park...’


Existing Baseline Conditions: Landscape Setting

Situated in the middle of the new South Downs National Park, between the River Rother to the north and the Chalk Downs to the south, Horncroft sits in a rich landscape derived from a complex geology, landform and land use history. Bands of chalk, clay, sand, gravel heads and riverine deposits all occur within a 4km east west belt giving rise to a landscape of low undulating hills and ridges dominated by deciduous woodland, with deep cut lanes, small villages, fields and open heath, all overlooked by the high scarp of the Chalk Downs to the south, and Commons of Fittleworth to the north.

The proposed quarry site is located in an attractive, small valley defined to the east by the slopes of Horncroft Warren, the top of which forms the eastern boundary of the Site, and to the west by the ridge of Sutton Common. At the base of this ridge runs a bridleway lined with mature oaks that define the western boundary of the Site. The Site itself has ancient field boundaries and is likely to include buried features of archaeological interest. Of particular interest in terms of landscape on and adjacent to the site are:
• The two PROWs immediately adjacent to the Site, including the Serpent Trail. Also the common usage of the path through the Site by the local community
• The Open Access Area of Sutton Common / Lord’s Piece
• The views of the Chalk Downs from the ridge of Sutton Common above the site
• The mature oaks along the PROW at the edge of the Site and the mature oaks occurring on the Site
• The attractive stream and enclosure of the valley
• The setting of the SAM

Public Access in Relation to Horncroft Sand Quarry


Principle features of the development

The likely principle features of the proposed Horncroft Sandpit that are of landscape significance during the 25 year working and restoration period will be:
• a 7m wide access road, high kerbs, traffic islands, signs, site compound, earth mounds, road cutting, new planting, possibly fencing.
• phased quarrying of Horncroft Warren, formation of 20m sand cliffs, 2m high perimeter fencing and signage, new planting along bridleway, progressive new planting of sections of the quarry, quarry vehicles, customer HGVs in quarry and on roads
• quarrying of Mansby Field, wide metal bridge over stream, formation of 8m steep slopes, quarry vehicles, customer HGVs in quarry and on roads

Following restoration, the likely principle features will be:
• new establishing woodland adjacent to the Fittleworth Bury road
• 20m sand cliffs, fencing, new planting, raised stream and margin, bridleway for public use
• a large pit with up to 8m slopes, fencing, individual tree planting


Re: LVIA 10.F Landscape Impacts: Mitigation of impacts by tree and shrub planting

Unusually for a landscape and visual impact assessment, the LVIA outlines mitigation and restoration proposals before describing the landscape and visual impacts of the development. While this may be a valid approach, it makes it harder to appreciate fully the real extent of landscape change caused by the development. Most importantly, the basis for this approach relies on an assumption that early planting would provide very effective screening for all but the first phases of construction; the LVIA then incorporates this potential screening onto the ‘baseline’ before assessing the likely impacts.

We believe this assumption to be fundamentally incorrect for the following reasons:
• With the exception of the proposed planting on the arable field at Horncroft Common, establishment rates and effective growth rates for the proposed trees and shrubs are likely to be very low indeed given that these will occur on arid, acidic, infertile and unstable pure sand on the quarry floor, or under the canopy and between existing mature oaks on very sandy soil at the western boundary.
• Although rabbit protection is proposed, this area has a significant number of browsing deer, and without deer fencing newly planted trees and shrubs are unlikely to grow well; fencing creates its own visual impact.
• It is probable that although the retention of mature trees alongside the stream and the bridleway boundary will provide partial screening of the works, these trees with their large root-zones, will come under stress once the ground around them is excavated, leading to a decline in health and screening potential during the lifetime of the quarry.
• Native trees and shrubs, while entirely in context, provide very little winter screening
• Trees and shrubs are generally suppressed when planted between mature trees as proposed along the bridleway and will only provide a partial screen, mostly during the growing season. Indeed, this planting activity may even have a detrimental effect on existing trees; ref: 4.3.1 ‘All landscaping activity within RPAs has the potential to cause severe damage’ .
• No planting or restoration is proposed for the quarry cliff faces.
• Heathland Restoration for the western half of the site will include spreading with cuttings of heather and grasses for one half of the site, leaving the other half for natural colonisation. This has problems as it is notoriously difficult to get heathland vegetation to establish; the long term heathland restoration at both Lords Piece and Hesworth Common illustrates this difficulty (Fittleworth Parish Council with the help of the South Downs Joint Committee manage Hesworth Common). Thus, the area of Mansby will remain an area of almost pure sand in a deep pit (8m banks) for a very long time, and while it is proposed to plant individual oaks in this pit, even if they do establish, they will not contribute positively to the scene for many decades.

We have therefore based our landscape and visual assessment on the basis that the screening effect of new planting in and around the quarrying will not provide very effective screening during the lifetime of the excavation and restoration works.

Response to the Impact Assessment
As explained in the LVIA, the assessment methodology adopted recognises that certain landscape elements or viewpoints can be rated ‘low’ to ‘high’ according to their importance; this is their ‘sensitivity’. The magnitude of impact can rate the scale and nature of likely landscape change from ‘none’ to ‘high’ during and after the development’s lifetime. By cross referencing ‘sensitivity’ with ‘magnitude’, the assessment derives the ‘impact significance’. We have looked in detail at the LVIA analysis; where we disagree, we have shown this below (boxes) supported by explanations.

Re LVIA: 10.F.20 -23 Landscape Character

Using criteria set out in the LVIA we judge the impact on the landscape character not moderate adverse but to have substantial adverse impact during quarrying and not significantly beneficial but to have substantial adverse impact after restoration.

The application site lies in the Rother Farmland and Heath Mosaic character area (L2) , regarded to be high sensitivity. Given the characteristic of quarrying, which is not a beneficial characteristic of this landscape area, we disagree that the magnitude of impact during the working stages of the development is low adverse (ie that it will cause only minor loss to the existing characteristics). We judge the magnitude of impact to be high adverse. We also disagree that once the site has been restored the magnitude of impact on this character area will be medium beneficial (ie that it will cause considerable beneficial alteration to existing characteristics), but judge that the magnitude of impact will be high adverse.

Re LVIA: 10.F.24 - 33
As there is no physical relationship between the site and other landscape character areas, ie they are not ‘landscape elements’ that are relevant to this quarry site, we judge that they need not be included in this assessment. Any visual impacts from viewpoints in these areas are assessed separately.

Re LVIA: 10.F.34 - 37 Land Use

Using criteria set out in the LVIA we judge the impact on land use not moderate adverse but to have substantial adverse impact during quarrying and not moderate beneficial but to have significant adverse impact after restoration.

The LVIA notes that ‘A bridleway runs adjacent to the western site boundary and around the northern end of the site’. It does not acknowledge the significance of the Serpent Trail as a county walking route and the Lord’s Piece Open Access area that overlooks the development site. The site and adjacent areas are well used by locals and tourists for walking, riding and running (including Fittleworth Flyers running club and South Downs Orienteers). Therefore we consider that land-use is high sensitivity and not medium sensitivity as the applicant states. We disagree that the magnitude of impact during the working stages of the development is medium adverse (ie would cause only partial loss to features or introduce elements that though prominent are not uncharacteristic). We judge the magnitude of impact to be high adverse. We disagree that after restoration the magnitude of impact will be moderate beneficial due to the very long timespan that will be required for trees and heathland to establish. We judge it to be medium adverse after restoration

Re LVIA: 10.F.38 - 41 Topography

Using criteria set out in the LVIA we judge the impact on topography not significant adverse but substantial adverse during quarrying and after restoration.

We agree that topography is high sensitivity. We disagree that the magnitude of impact on topography during the working stages of the development is judged to be medium adverse (ie would cause only partial loss to a key element). We judge it to be high adverse since ‘the proposals would cause total loss or major alteration to key elements’ of the landscape even after restoration.

Re LVIA: 10.F.42 Vegetation

Using criteria set out in the LVIA we judge the impact on vegetation not minor adverse but substantial adverse impact during quarrying and not significant beneficial but moderate beneficial impact after restoration.

The importance of the mature, possibly 200 year old oaks on the wooded slope is understated in the LVIA. ‘A number of (category B) trees visible as skyline features from outside the site’ and ‘Large individual trees and significant features created by tree groupings are a dominant element of local character’ . Therefore we consider that vegetation is high sensitivity.

‘This proposal will result in the loss of several high category trees and groups of trees’ . Some 40 category B mature oaks or groups of oaks, and 5 category A mature oaks or groups will be removed by the excavation. In addition, while there are significant areas of coniferous planting, the majority of this is mature scots pine, an appropriate species for this sandy area (the applicant has retained some of these trees on the adjacent Lords Piece for landscape reasons and indeed this species is specified within some of the proposed woodland planting). The LVIA states that ‘the woodland areas are not ecologically diverse’ but then neither is heathland (and indeed this is to be expected on very sandy soil as found here). It is, however, of ‘County Importance’ and mature native oaks support the richest of invertebrate fauna in the UK. Moreover, this wooded slope, while undoubtedly deserving of good woodland management to improve its status, provides visitors using the Serpent Trail with a magical experience of enclosure which contrasts dramatically with the openness of the views to the South Downs when they reach the ridge of Sutton Common and Lord’s Piece. While it is likely that in this case the bluebells are not indicative of ancient woodland, they do indicate that the banks found throughout the site are ancient and have remained relatively undisturbed since medieval times. The fact that the mature oaks are multi-stemmed may suggest that they were at one time cut or coppiced. A strip of mixed oak woodland would be retained along the stream, but the LVIA recognises the likelihood of stress on these trees through its suggestion that the cut ‘slopes would be spread with topsoil to increase water retention within the soil, in order to minimise the potential impact on the retained trees which would be at a higher elevation than the floor level of the excavation’.

Mitigation includes soft landscape works being carried out around mature oaks which may pose a risk to the oaks themselves. ‘All landscaping activity within the RPAs (root protection areas) has the potential to cause severe damage’ . New hedgerow and native woodland planting and management towards the creation of heathland may eventually balance the impact on the vegetation although it is questionable that the proposed woodland management to existing areas of woodland is dependent on quarrying.

Bearing the above in mind, the magnitude of impact on vegetation during the working stages of the development is judged not to be low adverse, but high adverse. Once the site has been restored the magnitude of impact is judged not to be of high beneficial impact, but of low beneficial impact given the difficulty of establishment and the long time likely to be taken for rich habitats to form.

Re LVIA 10.F.44 - 45 Public Rights Of Way

Using criteria set out in the LVIA we judge the impact on public rights of way not neutral but to be significant adverse during quarrying and not significant beneficial but neutral after restoration.

We agree that PROW is high sensitivity.
However the LVIA does not at this point consider the two public rights of way (bridleway 762 and a restricted byway) that are located immediately adjacent to the northern and western edges of the site. This includes the Serpent Trail which ‘snakes for 64 miles (108km) through the beautiful heathland landscapes of West Sussex. Waymarked by Serpent Trail discs, the route showcases the work of the Sussex Wealden Greensand Heaths Project and highlights the outstanding landscape of the greensand hills.’
In addition, the track through the proposed quarry, through the lower parts of the woodland, has been enjoyed by walkers and riders since before 1914 which is well before the Barlavington Estate purchased the land. There is also statutory open access land with its ridge just above the quarry site. The LVIA fails to mention these as a factor for assessing the landscape impact on PROWs at this point in its assessment. We disagree that the magnitude of impact on public rights of way during the working phases is none but judge it to be substantial adverse. We disagree that once the site has been restored the magnitude of impact on public rights of way is judged to be medium but, given that the proposed new path through the site would in effect replace an existing one (although not a PROW) judge the magnitude of impact to be none.

Re LVIA 10.F.46 -48 Water Courses

Using criteria set out in the LVIA we agree that the impact on water courses during quarrying and restoration may be moderate adverse.

The proposals include protection for the pretty little stream through the site. However, we note that water courses are a high sensitivity landscape element and there is potential for a significant level of disturbance and pollution, particularly where the metal bridge crosses at the upper end of the stream, and the sides of the stream will be liable to collapse here. Also the report identifies that the catchment where water currently drains from the slopes of Horncroft Warren will be removed. Provided that protection measures are stringently followed, we agree that during and after excavation the magnitude of impact may be low adverse.

Re: National Statutory and Local Designations

Using criteria set out in the LVIA we judge the impact on national statutory and local designation during quarrying to be substantial adverse and moderate adverse after restoration.

The site and its surroundings are within a National Park. Both national and county policy applies which gives a strong emphasis on landscape, amenity and nature conservation. As such, national statutory designation is high sensitivity. Given the priorities of UK national parks, the magnitude of impact during excavation is high adverse, and after restoration will be low adverse.

We judge these to be medium sensitivity. Although no Sites of Nature Conservation Interest (SNCI) occur on site, two have been identified by West Sussex County Council very close to the site at Horncroft Farm Pasture and Lord’s Piece. With regard to Horncroft Farm Pasture, it is thought possible by the South Downs Joint Committee field staff that the site will be adversely affected by the adjacent excavation. Therefore we consider that the magnitude of impact for SNCI’s is medium adverse both during and after excavation.

Re: Archaeology and Cultural Heritage

Using criteria set out in the LVIA we judge the impact on archaeology and cultural heritage to be significant adverse during quarrying and neutral after restoration.

Scheduled ancient monuments (SAM), archaeologically sensitive areas, listed buildings, conservation areas, historic parks and ancient woodland all occur within a kilometre of the site. These are judged to be high sensitivity.

No designated ancient or historic feature occurs on site. ‘However, the broader historic landscape in which the Site is located, will be significantly affected by the proposals: The land-use and settlement pattern of the Study Area has survived relatively unchanged since at least the medieval period, and a section of this landscape will be completely removed by the proposed extraction, along with the surviving remains of historic boundary features and evidence for the development of different land-use systems, such as the management of coppice woodland regimes and remnants of common arable fields’.

Four SAMs are recorded locally including a group of Bronze Age bowl barrows on Sutton Common, located close to the western perimeter of the Site. In terms of the impact of the proposed extraction on the setting of the SAMs 20066 and 20063, these are located on the eastern edge of Sutton Common, which directly overlooks the extraction site from the west. ‘Although the current proposals will not physically affect these monuments, it likely that the barrows were specifically sited to overlook the valley to their east, and it is therefore clear that the proposed extraction will have a significant impact on their setting’.
Two Archaeologically Sensitive Areas exist nearby: a Mesolithic site at Broadhalfpenny and also at St Agatha’s church 500 and 600m away from the quarry respectively.

The Conservation Area of Coates hamlet is located about 500m north of the site, and the Conservation Area of lower Fittleworth at just over 1km from the quarry. The following 20 or so Listed Buildings lie close to the boundary:
• The Grade 1 listed Parish church of St Agatha, Coates, 13th century or earlier, also an Archaeologically Sensitive Area, lies approximately 600m from the quarry
• C17th Horncroft Farmhouse and Satchers lie approximately 200m from the quarry and access road
• C17th Keepers Cottage, Bignor Park Cottage and Coates Castle & park lie approximately 500m from the quarry
• Tripphill Farmhouse, Coates Manor, Coates Farmhouse, all C17th , other buildings in Coates Conservation Area, and Flint Cottage all lie approximately 600m from the quarry
• The Historic Park & Garden of Bignor Park, listed on the English Heritage Register lies approximately 600m from the quarry
• 4 more listed buildings within 1,000m of the quarry.
While none of the listed buildings or Conservation Areas will be affected by the extraction area itself, the settings of two listed buildings will be affected by the access road, and it is clear that there will be a general impact on buildings located next to a road with additional quarry HGVs passing along, including the Conservation Area at Fittleworth.

Some ten areas of Ancient & Semi-Natural Woodland and Ancient Replanted Woodland occur within 1km of the site. Although not occurring on the Site itself, ancient woodland is located close to the southern boundary and ancient woodland indicator species are present in the woodland of the quarry site.

The magnitude of impact for archaeology and cultural heritage is judged to be medium adverse during excavation, and none following restoration.
Re LVIA 3.14 Agricultural Land Classification

Using criteria set out in the LVIA we judge the impact on agricultural land to be moderate adverse during quarrying and after restoration.

Agree that this is low sensitivity, however during quarrying and after restoration, with the removal of agricultural potential, the magnitude of impact is high adverse.
Response to the Visual Impact Assessment
A review of the Visual Impact Assessment finds generally that the applicant judges the visual impact to be generally low. We have found, however, that this is often not the case, and have also identified additional significant viewpoints.
Summary of Potential Visual Impacts

LVIA Ref Locations Sensitivity Magnitude starting: ‘Where the development site would be individually appreciated in the overall view and .......... Significance

From Long Distance Views approximately 4km from quarry

The South Downs Way is a national trail that in this section runs along the crest of the Chalk escarpment. Panoramic views across the Low Weald landscapes of the national park can be enjoyed by walkers and horse riders. The view includes a foreground of large open fields at the foot of the scarp, a mid ground of predominantly deciduous woodland with small fields and heath, a background of larger scale field and woodland on the slopes rising north of the Rother Valley, and distant views to the Surrey Hills. Horncroft quarry lies in the mid ground in a significant swathe of mixed woodland. In addition, the loss of tree cover from the Site will be just perceptible from some views, and the top of the cliffs will start to become discernable from year 10 into the latter phases and beyond, particularly from Farm Hill access land. We do not agree that where the quarry site can be seen it will ‘disappear’ into the overall landscape; in fact, the exposed yellow of the quarry cliffs may be quite obvious when the low angle of the sun catches cliff tops in the late afternoon and evening.
• When walking between Bignor Hill Toby Stone to the lower slopes of West Burton Hill, Horncroft is highly visible; the northern part of Mansby, much of Horncroft Warren and the whole of Horncroft Common can be clearly seen. Thus the quarry and access road and HGVs will be highly visible for the whole of the operational life of the quarry. Following restoration, quarry cliffs and a significant part of the quarry floor will remain visible.
• *From the Bignor Hill viewpoint near the car park views are currently screened by the tops of the trees on the upper slopes of the scarp; however, it is noted that trees and scrub may be periodically cleared around the viewpoint to open up the panorama to visitors, in which case, the quarry would be highly visible.
• From the PROW east of Glatting Beacon there will only be limited diffuse winter views of the quarry site due to screening by the crowns of deciduous trees on the upper slopes of the scarp.
• From Bignor Hill access land the quarry site will not be visible.
• From the north, on the slopes above the Rother, it is likely that the top of the quarry cliff will be visible from some points along Haslingbourne Lane, the PROWs and from some residences in Lower Byworth.

2, 5, 6 South Downs Way between
Toby’s Stone & West Burton Hill & tumuli, Farm Hill access land, PROW at Barlavington Down,
Points along Haslingbourne Lane including PROW & Lower Byworth High ‘....causes a significant deterioration forming an immediately apparent part of the scene affecting the overall character of the scene’
Substantial adverse impact
1, 3, 4 South Downs Way at
Bignor Hill: viewpoint
Bignor Hill access land, PROW at Glatting Beacon High ‘Where the development site would on balance have little effect on the scene’. * But note comment above Neutral*

From Medium Distance Views 1 – 3km from quarry

With one exception, these viewpoints are mainly from lower ground. It is likely that there are other views of the site from the many PROWs in this area where during quarrying and after restoration, the sandy cliff tops may be visible particularly during winter.
• Hesworth Common viewpoint and bench is very popular with the Fittleworth community and visitors from further afield. This open access area is managed for heathland and woodland mosaic but with amenity in mind. This lovely view encompasses the Rother valley and the wooded ridges and vales to the wooded scarp of the South Downs. The quarry cliff will be clearly seen from this viewpoint both during quarrying and after restoration.
• Barlavington Lane to the south west of the Site is an attractive narrow road popular with both locals travelling to and from Chichester and Portsmouth, and tourists as it traverses the bottom of the chalk scarp taking in the picturesque villages here. Where this popular PROW descending the Chalk Downs to the Weald crosses the lane, the view opens in the direction of the quarry site. The sloping ground of Horncroft Warren and the higher ground of Horncroft Common are clearly visible from the stile and footpath. The quarry cliffs will become and remain highly visible especially during late afternoon and evening.
• From Bignor Park and Coates Lane, the trees from the highest elevation will be lost from the view but it is unlikely that the quarry itself will be visible.

Hesworth Common viewpoint, PROW & open access land High ‘... causes a significant deterioration forming an immediately apparent part of the scene and affecting the overall character of the scene’ Substantial adverse impact
Barlavington Lane PROW High ‘...causes a moderate deterioration forming a visible element in the scene, having an effect on the scene’ Moderate adverse impact
7 Bignor Park historic park, Coates Lane
High ‘... causes slight deterioration forming a minor element in the scene’ Slight adverse impact

From Close Views from the area immediately surrounding the site

The quarry site is judged by the Applicant to have little adverse visual impact on close views. While we recognise that the quarry itself is enclosed by the higher ground of Horncroft and Sutton Commons, and that phasing the excavation works and advance planting would go some way to reducing the scale of impact, nevertheless, the views from the Serpent Trail, bridleway and Lord’s Piece would be significant and the impact heightened by inevitable movements and alien noises during quarrying and restoration. The access road must also be considered.
• It is from the Serpent Trail, bridleway and the open access land that the quarry will be most visible. Walkers, joggers and riders currently enjoy the tranquillity, and wooded enclosure of this site which complement the lovely wide open views from Sutton Common, across Lords Piece to the Chalk Downs. With Pulborough Station nearby, this area has the potential to become even more popular with visitors choosing to start their walks in the National Park to and from Hesworth Common or the Swan Inn at Fittleworth. There is a feeling of wild nature here that is so unusual in the South East of England. For locals and visitors walking the Serpent Trail or the ridge on Lord’s Piece, no amount of new planting will screen the quarry fences, digger, dumper, vibrator, HGVs and emerging cliff faces from walkers and riders; and the noise on site will be at odds with the birds and background hum of rural life.
• The private house of Mansby looks on to the quarry site and will be directly affected for the whole life of the quarry.
• The level, open fields of Horncroft Common afford clear distant views of the South Downs escarpment. During the construction and quarrying phases, residents living nearby and motorists travelling along the Fittleworth Bury road will have good views of the access road and its high concrete kerbs, traffic islands, signs, fences, mounds, cuttings, new planting and HGV’s. In ¼ century’s time, the access road will be removed and new woodland will have matured, giving more enclosure to the area, and restricting the long views south.

16, 17, 18
8 -15 All points along the PROWs bordering the site, including the Serpent Trail and open access land above the site.
2 listed buildings & the Fittleworth to Bury B road
Mansby dwelling High ‘... causes a substantial deterioration being a dominant feature to which other elements become subordinate and markedly affecting the overall character of the scene Severe adverse impact




Re: LVIA 10.F.60 Significance of Predicted effects

We agree with the Applicant that this landscape within the South Downs National Park is ‘sensitive’, and that in the first 10 years of quarrying there would be an ‘adverse primary impact with the loss of woodland cover and other vegetation, significant changes to topography and the creation of a temporary sandpit land use’. We judge, however, that this scale of impact will continue throughout the life of the quarry, and that 20 years will not seem temporary to the people who use this area. We do not agree with the Applicant that ‘the distance and panoramic nature of the views (from the Chalk Downs) result in the site being a minor element of the scene’. We would point out that it is not correct that ‘no residential dwellings would have direct views of the sandpit’ as the house called ‘Mansby’ is situated on Coates Common just above the quarry site.

The Applicant highlights that mineral workings are a feature of this landscape as sand has, of course, been won locally for centuries. We note, however, these old workings are small, hidden, and generally out of bounds to the public. This quarry at Horncroft is located next to paths and areas that are well used by local people and visitors to the area; it will not be a hidden and overgrown secret, but will remain clearly identifiable as a recently disused quarry which on account of the unstable cliffs, will need to be securely fenced.

We feel it is admirable that the proposal includes measures to enhance the quarry for wildlife and biodiversity; it is clear that much thought has been put into this and the choice of planting has been carefully chosen. Clearly, of course, it would be far easier and more effective, if there is a true commitment to improve the site for wildlife, to do this without any quarrying; indeed, the Applicant has demonstrated this well at Lord’s Piece and elsewhere.

We do not agree with the Applicant that ‘overall, the long term impact on the landscape elements is, on balance, beneficial’, or that ‘the residual impact over the long term with the restored landscape would improve the experiential qualities by replacing intense agricultural management with land managed for wildlife and conservation’. The ‘restored’ quarry will not produce a landscape that is of a higher quality than is currently the case. If an improvement should be made to this landscape, it might simply be a case of removing the coniferous trees on Horncroft Warren and replanting with native species and by establishing heathland areas on Mansby; afterall, the Applicant has done this on Lord’s Piece and elsewhere. It should also be borne in mind that while the Applicant has the the admirable intention to restore the development for nature conservation, it is common for disused quarries to eventually have other uses (eg Coates Sandpit for pigfarm storage, Heath End builders merchant).

Even though the proposal includes phased workings to reduce the impact, the impact on the landscape is unquestionable and the view of the top of the large sand quarry north of Fittleworth, now visible from the South Downs Way, should send alarm bells out given that Horncroft is much closer to these viewpoints. What can be envisaged from the public areas adjacent to the workings is that in a ¼ of a century Horncroft will comprise a large pit surrounded by 8m high eroding, unstable slopes near the bridleway to 20m high eroding cliffs facing the bridleway. We can agree with the LVIA that ‘the steep banks will be at odds with the surrounding landscape’. The odd raised bank of land supporting declining mature trees will enhance the divide between the two areas.
• The area that is currently Mansby field and closest to the bridleway will be almost bare sand with some planted trees struggling to survive, although self sown birch saplings will be establishing. The eroding banks will be starting to undercut the mature oaks between the pit and the bridleway and there will be fencing and notices warning the public to keep out because of the 8m high unstable slopes. The Field Crickets will be moving in, but not much else.
• To the west of the raised stream where Horncroft Warren used to be, a private bridleway will again allow walkers and riders through the site. They will see the 20 metre high cliffs at the back of this area which will be spectacular but out of bounds and fenced off for safety. The cliffs themselves will be unstable and, as at Coates Sandpit, will start to recede at the top. The sand martins will already be established in the cliff face and there may be some tiny red tipped cudweed but not much else. The quarry floor here is likely to be of more landscape and amenity interest, although much of the planting will be struggling to establish in this dry acid sandy soil and fencing will be required to protect from browsing deer. It is likely that acid grassland and birch scrub will be colonising on the more stable areas where the original surface soil has been spread.
• The access road with all its signage etc will have been removed and planted. The woodland planting will be well established and, while losing its long views to the Chalk Downs, this area is likely, eventually, to result in an improvement to the wider landscape.


Conclusion

We have seen that the planting proposals which are aimed at screening the impact of the development will simply not rise to the challenge, and that the ‘restored landscape will retain the character of a disused quarry with fencing, scrubby areas and unstable slopes. We have identified that the loss of mature oaks and the creation of new habitats is not likely to provide a higher quality of landscape or amenity. We believe that the presence of the quarry and its traffic will have an impact on nearby houses and historic features. We have shown that the disruption to the enjoyment of this landscape by locals and visitors using the rights of way adjacent to the site and those enjoying the panoramas from popular viewpoints may be significant.

We do not, therefore, agree with the Applicant that the landscape and visual impacts of the development will be minor or moderately adverse during quarrying and neutral or beneficial following restoration.

It is our judgement that the landscape impacts will in many cases will be significantly adverse during quarrying and generally moderately adverse after restoration, and the visual impacts will be substantially or severely adverse from key views on and off site

What does designation mean?
Designation as a National Park is a formal recognition of the South Down’s special qualities in terms of natural beauty and opportunities for open-air recreation. It means that:
• the area has the highest level of landscape protection under the planning system
• there is a fixed boundary for the area to be protected
• public bodies and others are required to have regard to National Park purposes when operating in the area
• it permits a National Park authority to be established (under the Environment Act 1995) to carry out functions associated with the Park
• National Parks, along with Areas of Outstanding Natural Beauty, are considered to be the nation’s finest landscapes. They form part of a worldwide network of protected landscapes established by the IUCN (International Union for the Conservation of Nature)