This page is for ACTION PLANS
| ENRAGED are committed to ensuring that any future Lafarge's application fails. | ||
30/11/06 |
Action PlansLafarge surrenders options on two of the four sites. Since the last update there have been a number of important developments which, when taken together, give us good cause to believe that for the time being at least the campaign has achieved its objectives.Meeting with The EstateRepresentatives from ENRAGED and Hedenham Parish Meeting met with Viscount Tamworth and the Estate’s managing agent (Savills) and set out the objectors’ case in a very full and frank discussion. We believe that Viscount Tamworth is a conservationist at heart and that he and the Ditchingham Estate are not unsympathetic to the objections that have been raised to the quarry proposals. Nonetheless Viscount Tamworth explained that with the option having been granted to, and exercised by Lafarge, there was little that could now be done to prevent another application being submitted on the site to the east of Fen Lane, although he promised to do whatever was possible to mitigate the effects if the application is ever brought back. Most importantly he confirmed that Lafarge had agreed to surrender the options granted over the other sites on the Estate. Highways MeetingFollowing our request under the Freedom of Information Act to inspect the Highways Department’s files on the quarry application (that identified the absence from such files of important documentation and other evidence to show that the application had been properly considered in accordance with NCC guidelines) representatives from ENRAGED and from Ditchingham Parish Council were invited to attend a meeting at Ditchingham village hall on 18th April 2006 with Tim Edmunds the head of the Highways Department of Norfolk County Council. Following a procedural review of the conduct of the case Mr Edmunds acknowledged that proper procedures had not been followed by the Highways officer dealing with the application and he re-assured the representatives that if the application is ever re-submitted he would deal with it himself and would ensure that a full and proper appraisal of all relevant information was undertaken on a wholly impartial and objective basis. It would take account of all relevant facts including the additional data provided by objectors and the narrow width and particular accident record of the section of the B1332 on either side of the site between Woodton and Bungay. Subsequently Mr Edmunds has written to Lafarge informing it of the review undertaken and making it clear that the views on highways issues given previously by Highway Authority officers should not be used by Lafarge in assessing the merits of any future application since that would be subject to a fresh and comprehensive re-assessment by the Highways Authority with a different officer handling the case. We are confident that any such reassessment would result in a vigorous objection. So what is the present position?Under planning regulations Lafarge has a year from the date on which it withdrew its planning application to submit a new application for the same site without having to pay another fee. The fee is in excess of £25,000 so if there is to be a new application in the near future there is a strong incentive for Lafarge to submit it before 4th February 2007. Back in the spring Lafarge said that it would review the matter 'later in the year' ie in November when it hoped that the landbank would have fallen close to the seven year limit. When asked as to the position last week Stuart Anderson of Lafarge confirmed on the telephone that he was engaged on other projects and that the company had 'no present plans to submit a new application', though he added that it might do so at some (unspecified) future date. Option Rights SurrenderedMore importantly, Lafarge wrote to ENRAGED on 1st November and confirmed that it had completed a Supplemental Agreement with the Estate on 21st September under which the company had surrendered its option rights on two of the other sites on the Estate (the land west of Fen Lane and the Cemetery Site beside Ditchingham Church). The letter goes on to explain: 'We do retain an option on land that was the subject of our withdrawn planning application east of Fen Lane and we may resubmit an application at a future date. There are no plans to submit an application in the immediate future.' It then adds 'Lafarge’s obligations regarding the Irrigation Reservoir remain'. This is a reference to the option site within the ancient medieval deer park situated between the Ditchingham Hall and Hedenham. It is also within larger area of Ditchingham Park which is listed grade II by English Heritage. The retention of Lafarge’s obligation to excavate there to create a reservoir has (if ever implemented) direct implications for the residents of Hedenham and Hedenham Hall in particular. This means that for both villages of Hedenham and Ditchingham the quarry threat remains (to both the site to the east of Fen Lane and the Reservoir Site); albeit as a future possibility rather than an immediate danger. Finally this week we have at last received documentary evidence from Lafarge’s solicitors that the Class (IV) Land Charges registered by Lafarge over the two option sites (to ensure that anyone dealing with the land has notice of Lafarge’s interest) have been cancelled. On the basis of these latest developments in this battle over the proposed quarry ENRAGED invited those most directly affected by the proposals to a meeting at the Mermaid last Sunday to report on the present position and agree the appropriate community response. At that meeting it was acknowledged that whilst the battle to remove the quarry threat altogether is not yet won we have reason to believe that the immediate threat has been seen off. Furthermore we have secured the support of the Environment Agency, CPRE, DEFRA, NCC Landscape Department, South Norfolk District Council, The Garden History Society, The Georgian Group, all the relevant Parish councils and over 200 residents and other interested individuals who have written personal letters of objection. The campaign has been a huge success in alerting interested parties to the issues and persuading those consulted on the application that it should be rejected. With the Highways Department having also now made it clear its determination to consider any new application properly and extended permissions being granted to Flixton and Henham quarries, Lafarge has a daunting (and very expensive) task before it to submit a new application with any realistic prospect of success. Next StepsThe meeting concluded unanimously that on the basis that there was no immediate threat of a new application the protest signs should be taken down and the campaign put on a 'watch' footing to ensure that at the first signs of any renewed activity by Lafarge the campaign could quickly resume its former momentum. The Future?The Reservoir Site in Ditchingham Park and the land to the east of Fen Lane remain at risk of a future application. Please advise us at any time of any relevant information you may acquire. ENRAGED will maintain a constructive dialogue with the Estate and other interested parties. We of course will try to keep you informed. You can always contact us 01986 895700
|
|
12/04/06 |
Action PlansLafarge has withdrawn its current application for the quarry. This is not all good news as the reasons are technical planning issues only (need). Lafarge cite the reason for withdrawing as being the successful appeal of the Tarmac application for the quarry by the Trafford Estate (Horstead with Stanninghall). But the Horstead quarry's reserves (c3m tonnes) are equivalent to just one year of demand in Norfolk. So. with the land bank now at 8 years, Lafarge could potentially submit another application at Ditchingham, in less than a years time... but most likely later THIS year as this would avoid Lafarge incurring a further application fee (£27,930).ENRAGED are convinced however that there are other more fundamental grounds on which any application for the quarry at Ditchingham would fail, so our fight goes on. We must not be complacent. While Lafarge has withdrawn its current planning application for the site at Ditchingham it has continued to pursue the application by engaging with its experts and Norfolk County Council the Minerals Planning Authority (MPA) responsible for planning in Norfolk. ENRAGED has been actively engaging with Lafarge and NCC since the application was withdrawn. Click here to checkout latest history. ENRAGED remain true to their conviction that this application should never have been allowed to proceed beyond the scoping opinion stage, and that as it has, there has not been proper application of procedure by the MPA. Because the application is withdrawn the files are part of the record and are available for public inspection, although in any event the public has a right of access to public information under the provisions of the Freedom of Information Act 2000. ENRAGED has made use of the provisions contained therein and discovered that it appears that there are potentially serious procedural irregularities of conduct and governance with regard the application. ENRAGED has instructed their solicitors Leathes Prior to help determine the extent of the potential irregularity and has written to Adrian Gunson, Cabinet Member for Planning and Transportation to help clarify the position. Click here for copy of letter sent to Adrian Gunson.
|
|
06/02/06 |
ContextLafarge has withdrawn its current planning application for the site at Ditchingham. At this early stage, this should NOT be seen as a victory, but simply a stay of execution. Click here for copy of letter sent to local residents. Lafarge has stated the reason for withdrawing its application is the issue of ‘need’. Not surprisingly. It is almost certain, that had the application been considered by the Planning Committee, it would have been refused on technical grounds. This is because in justifying any proposal, the applicant has to demonstrate that the current County landbank is under the strategic reserve level for maintaining a 7-year supply for sand and gravel. The policies in the Norfolk Local Minerals Plan, state: Policy MIN14, that ‘The County Council will maintain a landbank of permitted reserves of sand and gravel separate from that for carstone, both of which will be in accordance with minerals planning guidance note 6….’ And policy MIN15, that ‘Proposals for extraction of sand and gravel … on new sites will not normally be permitted when the landbank exceeds the seven year level’ and is clearly designed to limit new sites commencing when the land bank exceeds 7 years, and to prevent the spread and proliferation of new mineral workings when there is no justifiable need. When policies MIN14 and MIN15 are read in conjunction, the combined function of the two policies is to maintain only a 7-year land bank. No more. So what does this mean?At this early stage it’s difficult to say. But all other things being equal, it could well mean that Lafarge will resubmit their application when the landbank again approaches the 7-year level. In theory, this could be as early as October this year, or conversely much, much later, in many years time. This would mean that the threat of the quarry and the resultant blight will hang over Ditchingham until a more certain position is established. Of course, it could mean that Lafarge is seeking a quiet exit, that is, not wanting to withdraw under successful residents’ objections. This is a possibility, but we just do not know. But even if this were the situation, then ENRAGED must work hard to ensure that the threat of a quarry at Ditchingham is removed for all time. How? This will not be easy to achieve, but it will involve: Lafarge surrendering their option, and similarly the Ditchingham Estate assuring the local community that they will not promote or otherwise allow any subsequent mineral developments [on this] landscape. It will also involve lobbying Norfolk County Council and South Norfolk District Council to ensure that policy will preclude development in the future. This will take time. If the application is resubmittedWe must assume that it will be. ENRAGED must remain prepared. We will not disband, or allow the passage of time to dilute our resolve. We will challenge every aspect of any future application, and on every account. And until such time that any future application is resubmitted, we will progress policy and other planning issues with both SNDC and NCC. We will test the integrity of the planning process itself. The Lafarge application runs contrary to policyAs can be demonstrated below, Lafarge’s application runs contrary to much of local and national policy. We must ensure that the greed of a multinational corporate who has no interest in the local community, and a wealthy landowner who will likely secure many £millions from land sales for future housing development as identified in the South Norfolk Local Development Framework are not allowed to despoil our landscape and livelihood. UK planning regulations. Developers wishing to apply for planning application [to develop a quarry such as that proposed at Ditchingham] must provide information that identifies how the proposed development (if allowed to proceed) will impact the environment by providing an environmental impact assessment (EIA). It is therefore vitally important that the applicant addresses all relevant factors including issues of landscape, visual amenity, highways, traffic, soils, ecology, archaeology, noise, hydrology and hydrogeology as honestly and comprehensively as possible. The requirement for an EIA originates from European Directive. We contend that the application that Lafarge has now withdrawn was deficient in a number of important respects. The Environmental and Supporting Statement (ESS) contains errors, inconsistencies, omissions and misinterpretation that require correction if a fair appraisal of the relevant issues is to be undertaken by those deciding the application and Lafarge will have to correct these errors before they submit any future application. This may be to our detriment as when (or if) the application is resubmitted, we can be sure that this time they will submit an application that is not only more comprehensive in its argument and provision of supporting data, but that it is of a higher standard of quality. Unfortunately, they now have time to do this and they will have learnt from their latest experience, unless of course by doing so portrays this application so unfavourably, it would never pass any planning committee! In particular, they will wish to address the flaws in their current submission that include: Norfolk Minerals Local Plan Lafarge asserts that their proposals are in accordance with the detailed policies contained in the Norfolk Minerals Local Plan. However, the facts are that proposals actually run contrary to the Minerals Plan and the site itself was not one earmarked within the Plan as one suitable for investigation. Lafarge provided no argument to support the case for their [withdrawn] application being considered outside of the Plan framework, and no analysis of the need for minerals from this site was put forward, or of the market, which it is suggested by the application, the proposed quarry will serve. That Lafarge submitted the application in the light of the existing Horstead application and the inevitable outcome of process raises questions. It is incomprehensible that Lafarge, self acknowledged as a world leader in minerals exploitation, was not aware of the likely outcome. More likely, that a game of a strategic nature is being played. Local residents, be aware! Nonetheless, the Minerals Plan is comprehensive in its policy provisions and the application for a quarry at Ditchingham is contrary to most, if not all of its policies. But importantly, it is perhaps policy MIN33 that demonstrates the contempt of Lafarge in the submission of their application. MIN33 states that ‘The County Council requires planning applications for mineral working and associated activities to be accompanied by a comprehensive statement covering the following, as appropriate: 1. Where necessary an assessment of the need for the mineral and the market to be served; Lafarge has produced no such an assessment, and although it assumes that reserves may fall below the 7-year threshold, provides no calculation or evidence to support such an argument. 2. Evidence (supported by borehole testing and/or trial pits) of the type, size and depth of the deposit; Lafarge has not produced such evidence. 3. Output and life of the operation; Lafarge blandly states that proven reserves are in the region of 1.25m tonnes but that more realistically only some 1.0 m tonnes may be recoverable. Lafarge also variously state that extraction will last some 8 – 11 years. It appears that these statements are loosely founded, and provide such significant variability that they have no worthwhile use. 4. Hours of operation; Lafarge, on the one hand, state that core hours will be 5½ days week 07:00 – 17:00, but also state that they reserve the right to apply for extended working, providing effectively 24/7 operations if demand necessitates. This statement is ambiguous and the intended hours of working and requires clarification. 5. Appraisal of the effect on the surrounding landscape both during working and after restoration; with a land surface level survey showing existing and proposed landform including its relationship with adjacent land; Lafarge has produced drawings and cross section illustrations to this effect but has not produced any satisfactory argument that the resulting landform is acceptable. 6. Appraisal of the potential impact on local residential and visual amenities and measures to deal effectively with these impacts; Lafarge has produced an impact assessment to this effect, but uses its own value judgements to assess the impact, and has not produced any satisfactory argument that the measures to deal with these [self assessed] impacts are effective. 7. Appraisal of the impact on listed buildings and their setting; Lafarge has produced an impact assessment with regard Ditchingham Park and Hall, but has made no reference to the important Rider Haggard Estate, and little refection on the broader setting adjacent to the site. 8. Appraisal of archaeological features including, where necessary, the results of a field evaluation, and proposals for protecting and recording them; Lafarge has undertaken a field evaluation, but has provided no indication as to methodology for protecting or recording archaeological features. 9. Appraisal of wildlife, scientific and geological value and measures to protect such interests; Lafarge has produced an appraisal of the wildlife, scientific and geological features of the site, but has been selective in the use of information and in the summarisation of their own experts’ reports. It is simply unacceptable to promote any argument for protection, when there is no justification for the original destruction of these features. 10. Extent and quality of agricultural land to be affected and the impact on the viability and structure of agricultural holding; Government policy is opposed to the use of best and most versatile land for mineral extraction (which much of the Ditchingham site comprises). Not all of the land will be returned to agricultural use; the balance will be used to provide alternative habitats. 11. Effect on water resources, drainage, flood prevention and water courses; Lafarge has provided an analysis of hydrology and hydrogeological conditions on the site and in the locality. Based on evidence provided by a local resident, Lafarge’s experts’ reports are incomplete and should not be used without further testing and analysis and are further evidenced by the Environment Agency requesting information. 12. Effect on public rights of way and access to the countryside; Lafarge makes no reference to the effects that the proposed scheme will have on local ramblers, the proximity of the site to the Bigod Way, and the network of local lanes and footpaths that are enjoyed by many leisure users. 13. Traffic generation and routeing as far as the County’s primary route hierarchy; Lafarge has provided no reliable information on traffic volumes and routeing. Lafarge remain entrenched with their estimate of 42 HGV movements a day, and has only lately acknowledged that this estimate will be significantly increased with the introduction of a readymix batching plant that they admit remains likelihood within the longer term context of the site. While it is evident that traffic will utilise the B1332, albeit entirely unsuitable, Lafarge do not indicate the extent to which traffic may be routed south towards the A143, or north towards the A47. 14. Detailed layout and elevations of plant, machinery and buildings; Lafarge has not provided detailed layout or elevations of plant, machinery and buildings. Instead, they have loosely indicated the location and height of some plant, but have not produced details of all structures, including buildings, car parks, ancillary structures, etc as is required by this policy. 15. Effect on employment; Lafarge remarks that the site will employ some 4 staff, likely redeployed from other sites, but do not mention the likely adverse impact that the scheme may have on other businesses within the immediate locality, aligned to leisure pursuits, or that of the nearby convent, that are highly dependent on quality of landscape and amenity that would be impaired by the Lafarge proposals. 16. Method and programme of working; Lafarge loosely refer to phased workings and campaign digging, but are not clear with regard the full programme of workings that support this concept. 17. Landscaping, screening and planting proposals; Lafarge provides comprehensive proposals for landscaping, screening and planting. However, these are clearly inadequate for the intended purpose. The proposed screening bunds will not restrict views into or across the site, and the proposed planting will take many years to mature, and being of a deciduous base, will be entirely ineffective when not in leaf. 18. Means of progressive restoration, including machinery and criteria for handling soils; The Ditchingham site is comparatively small to adopt this method of operation and progressive restoration will generate disproportionate transport movement for the hauling of soils and overburden. This will create unacceptable levels of noise, dust and other nuisance. 19. Co-ordination or planned after use with working, creation of final contours and restoration: Part of Lafarge’s original scheme was to import inert landfill required to achieve ‘acceptable landform’. Now they indicate that this is no longer part of the scheme, as ‘acceptable landform’ will now be achieved through the reprofiling of a broader area outside the extraction area. Restoration by reprofiling, besides having ecological consequences, will increase noise and be visually detrimental. 20. After-care scheme for a five-year period to manage the site; Lafarge has said that they will provide an extra five years ‘after-care’. It is doubtful as to how this could be enforced. The Minerals Plan goes on to say that NCC seeks to achieve high standards of working and restoration with a co-ordinated and planned approach to the establishment of beneficial after-uses and that in order to minimise the environmental impact of mineral operations, planning applications need to be carefully prepared and supported by all of the information and assessments required for the determination of the application. As is clearly indicated by the above assessment of the depth, breadth and quality of the information provided by Lafarge, this is clearly not the case. Lafarge has simply not provided the adequately robust information demanded by this policy. Indeed ENRAGED, supported by their experts’ reports, demonstrate that, while Lafarge may have provided in many instances a nominal or otherwise superficial response for the information requested, they have not provided the adequately robust information demanded by this policy. Central Government and Other Guidance Lafarge’s attitude towards central government policy and guidance is no less contemptuous. While Lafarge correctly sets out and considers a whole range of policy guidance notes, and although quoting extensively from the source material in some 112 paragraphs, they fail to relate it to the application and its inevitable impact. They assert that the application should be considered favourably, yet fail to demonstrate how this assertion is justified in the context of the policies discussed. It is therefore of some significance that their conclusions in this regard are dealt with by bland statements in just two paragraphs. In particular, there is no evidence that the proposed mineral workings have been considered in a way that demonstrates unequivocally that ‘no conflict is found… [with] Central Government Guidance Notes’ and we would contend that Lafarge wrongly concludes that ‘the Government advice provides positive support for the development, in particular, contributions to local bio-diversity and sustainable development initiative’. Objectors resolveOur resolve to fight any future application by Lafarge is strengthened by the support we have received from the community more broadly. At the point that the application was withdrawn, NCC had received some 200 letters of objection to the proposals and have been further encouraged by the strong objections raised to the application by the statutory bodies consulted by the County Council. The sisters of All Hallows Convent remain implacably opposed to the scheme and have highlighted in their letter of objection the threat posed to the 46 jobs that support their conference and religious retreat centre which hosts over 10,000 visitors a year. Statutory consultees commented:
The objectors are further encouraged by the conclusions reached by their experts’:
All encouraging stuff. But we can not afford to be complacent. Next Steps?It’s difficult to say. First perhaps, a period of reflection, and then communication. Be very clear, Lafarge may have received a set back, or it may just be part of their strategic game plan. We just do not know. But Lafarge need to be very clear as well. Whereas Lafarge may assume that local residents can be ‘bullied’ into submission by using the significant resources that are available to it, and may also assume that their 'expert' knowledge, compared to ours, will advantage them to win, they assume incorrectly. Objector resistance is committed to ensuring that there will never be a quarry in Ditchingham. If then Lafarge are exploiting psychology or attrition tactics, Lafarge must be prepared for a long haul ahead. Perhaps many years. Lafarge must reflect whether to proceed or withdraw completely, and not leave the community with a death threat over its head by withdrawing the 'current' application. They have already unnecessarily wasted the not inconsiderable resources of local residents and statutory consultees who have contributed to the application this far, including that of the tax payer. And much of this effort and cost this will be reincurred if they resubmit their application, for example, our letters of objection refer to the application now withdrawn, not to a future application! Learning of the Quarry for many of us, was very much like learning about a terminal illness. If it were to happen, there is no doubt that it will certainly kill the heart and soul of Ditchingham, and no doubt certainly blight the future of many who have built for their future here. An analogy of this situation is to the work of Elizabeth Kubler-Ross who developed a model of personal change after spending time analysing the emotional responses to grief by terminally ill patients. The model suggests that when you learn of a terminal illness, the natural responses are: You receive the ‘bad news’. You then enter a number of stages of ‘grief’: resulting in Denial; Anger; Bargaining; Depression, and finally Acceptance. The model suggests that these stages can be managed:
While Kubler-Ross’s work is not accepted by all, it is frequently used as a tool to address change management, techniques that the corporate PR engine of Lafarge will understand and deploy. So what has Lafarge done? Arguably, to manage Denial, they launched their exhibition early; they relied on the PR approach knowing that the application process would happen many months hence, or perhaps as in this instance, many years hence. To manage Anger, they attempt to justify their profiteering because of need: there is no need. To manage Bargaining, they promoted the ecological value of the restored site: the site that they will have destroyed. To manage Depression, they promote such stunts as a liaison group: but with limited representation, and to gain Acceptance it appears that they are attempting to build on their own efforts of screening and tree planting: all to hide the destruction that they themselves will have initiated. Time may be a healer, Lafarge may assume that time will 'allow' Ditchingham residents to become accustomed to the concept of a quarry on their back door step. But not this time. Ditchingham residents can see straight through these tactics. This time local residents have called the bluff. This quarry will not happen. Supporting ENRAGEDLast, but not least. Fund raising. We need your support. Keeping this campaign up and running is hard work, but moreover it costs money (protest signs, printing, postage, copying and most significantly, for the advice of our technical experts). If you are able to offer us financial support it will help. It could be the difference between success and failure. Lafarge know this. That is why it is in Lafarge's interest to draw out the timeline. Call us on 01986 895700 or email us at enquiries@nraged.org.uk We will tell you how you can help. But what ever. Watch this space. And be prepared! |
|