Brockley Wood Planning Application - additional response from Bentley Parish Council
After the initial round of consultation, Suffolk County Council requested that further information be submitted by the applicant under Regulation 25 of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (the EIA Regulations) - see http://suffolk.planning-register.co.uk/Planning/Display?applicationNumber=SCC%2F0105%2F22B for the responses.
Following another period of consultation, Bentley Parish Council have drafted the response below to the further information supplied by the applicant. If agreed at our next Parish Council meeting in September, this response will be sent to SCC on behalf of the village.
Bentley Parish Council
Extraction, processing and sale of sand and gravel, processing of inert waste materials and concrete batching with associated plant and related sales, associated access works, phased restoration using inert recovered materials and aftercare plan.
Response to further information requested under regulation 25.
The Parish Council has considered the applicant’s responses in respect of regulation 25.
It maintains its objections in respect of
- Impact of site-related traffic on the safety of pedestrian, equestrian and cyclist road users on the C class quiet lanes and the village centre, school, playgrounds, and churches.
- Ecological impact on ancient woodlands (County wildlife sites) and nearby countryside.
- Environmental impact of noise, light and dust pollution, visual impact, and watercourse pollution.
- Impact on the setting of a grade 11* listed building – Bentley Old Hall, its residents and those in nearby buildings.
- Impact on the amenity of resident’s enjoyment of footpaths, woodlands, quiet countryside and dark skies.
Regulation 25 responses
Traffic and road safety, Bentley
The response and attached road safety audit makes no reference to the impact on Bentley village and residents in respect to ancillary access to and from the site via C class, single track designated quiet lanes and the village centre.
The traffic plan envisages all access to and from the site via the A12, but the siting of the access on a slip road with junctions with C class roads through Bentley will inevitably result in G.P.S. directed traffic from the East, North Essex via the A137, and the Shotley peninsula. There is likely to be particularly heavy traffic through these lanes when the A14 or A12 are blocked – which are frequent occurrences.
These lanes are much used by pedestrians, horse riders, cyclists and pass the village school, playgrounds, and churches. There will be major concerns for the safety of road users in the village through increased heavy lorry traffic and other vehicles accessing the site.
If planning permission is granted there should be an enforceable and monitored condition, avoiding site-related traffic through Bentley village.
The revised response from Hopkins Ecology relies on the data from their original surveys in 2021. This was inaccurate and incomplete, for example, missing the presence of a large and active Badger sett adjacent to the proposed plant, in Old Hall Wood, the presence of breeding Kestrels and Buzzards in Brockley Wood and the records of Breeding Hobbies (Falco subbuteo} in Brockley wood.
It ignores (and did not look for) breeding Little and Tawny owls (Athene noctua – population declining, and Strix aluco – amber listed), both of which have been present in adjacent woodland and would be affected by noise, light and disturbance of feeding habitat. It dismisses, on no evidence, that the impact on the many identified bat species by light and noise, as minimal.
It also overlooks the presence of a rare (for Suffolk) butterfly species, Silver-washed fritillary, Arginnis paphia, which has recently re-colonised Old Hall wood.
The Hopkins Woodland management plan acknowledges the need for a re-survey of the impact on woodlands under the control of the applicants, but it is notable that there has been no engagement with or negotiation with the owners of Old Hall Wood (Bentley residents).
The responses rely on incomplete and inaccurate information and concentrate on mitigation for the damage caused to the ecology and landscape caused by the siting of such an industrial plant and its related processes, in a wholly inappropriate site. This would be unnecessary if the plant was sited elsewhere.
Impact on the setting and occupants of grade 11* listed building - Bentley Old Hall
The responses dismiss any visual impact on the setting of Old Hall, which is notable for its isolated rural setting. The attached revised Sharps Redmore noise impact assessment accepts that there will be adverse noise impact on the residents of Old Hall (and neighbours) and accepts that effective mitigation is not feasible.
While it acknowledges the permission, already granted, for gravel extraction at the site, the Parish Council remains wholly opposed to the siting of an industrial waste processing and concrete batching plant in a totally unsuitable situation, by reason of the impact on residents’ road safety, due to increased heavy traffic through Bentley, and its impact on protected wildlife sites, sensitive rural landscapes, dark skies, listed buildings, and residents’ amenity.