From: Development Control (DMW)
Subject: FW: Consultation on
LW/799/CM(EIA) Fisherman's Whart, Newhaven Port
From: Pat Randall
Sent: 08 December 2017 12:04
To: Jeremy Patterson
Cc: Amanda Parks; Sarah Iles
Subject: RE: Consultation on LW/799/CM(EIA) Fisherman's Whart, Newhaven
Port
Jeremy,
Please find below my comments on application reference LW/799/CM
(EIA) from a minerals policy perspective. (Just to clarify, I am not
commenting on the implications of Lewes Local Plan policies).
This is a significant minerals development proposal for
East Sussex, involving various separate and related operations, and as such
raises several policy considerations. It is noted that the development
would occur in stages, beginning with the processing and bagging of marine
dredged aggregates imported to East Quay, and then the products being exported
by road and rail (Stage 1). When Rampion relocates a conveyor system
would be added and the rail siding extended (Stage 2). Once the port
access road is opened a concrete batching plant would be added (Stage 3).
The last stage (4) would involve the addition of a block making plant.
The total aggregate processed during Stage 1 would be in
the region of 200,000 tonnes per annum (tpa) and could rise to 250 000 in Stage
2. If all four stages of the project were to be developed, the throughput
would be about 500,000 tpa.
Policy principle
As minerals planning authority we are required to plan for a steady and adequate supply
of aggregates. As part of this, the NPPF states that Local planning
authorities should safeguard:
These principles are incorporated into the adopted East
Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan
(which comprises the WMP and Sites Plan)*. Whilst the application site is
not specifically identified in the Sites Plan for safeguarding, any proposal
which assists in meeting the supply needs for construction aggregate materials
in the Plan area would be supported in principle, subject to being acceptable
environmentally and in amenity terms, and the various relevant policy caveats
and controls. This particular proposal is notable in terms of the
level of imports and the aggregates and products it would eventually supply.
The current Review of the WMLP is seeking to
establish the level of future demand for aggregates for the Plan area, and will
therefore assess the contribution to be made to this demand from the various
existing and potential sites and facilities in East Sussex, Brighton & Hove
and the SDNP. This work is due to be completed in the first half of
2018. However, whilst likely figures are not yet determined, based on
historical evidence It is fair to say that if implemented this proposal would
make a very significant contribution to the aggregate needs of the Plan
area. It is therefore SUPPORTED in principle.
The application includes various references as to why the
applicant considers that the East Quay site is preferable to North Quay and
other wharves in the Plan area which are safeguarded. It is claimed that
the currently safeguarded wharves are not viable or sufficient to serve the
Plan area. An appendix (15 “The Stanmore Report”) has been included with
the application. Many of the claims in this report and some of the
references in the supporting statement (e.g. 12.6, 12.7) are inaccurate and
misinterpret data from our previous Local Aggregate Assessments. I can provide
more details of this if required. (If you do need these details please let me
know asap). I consider that much of this is based on a
misunderstanding of the role of safeguarding. The purpose of safeguarding
is to protect the wharf from non mineral development which could prejudice its
future use and operations. Safeguarding does not allocate sites as being
more preferable than others.
*NB the
applicant’s supporting statement at 12.4 incorrectly does not include the Sites
Plan as being part of the Development Plan for the area.
Transportation Mode
The proposal is that marine dredged aggregates initially,
and then crushed rock as well, would be imported by sea to the site. Aggregate
processed during Stage 1 would be exported on a 50:50 rail and road
basis. A limited number of other aggregate products (e.g. building sand)
would be imported by road, generally in lorries returning from making
deliveries. Stage 2 would involve crushed rock imports. When Stage 2 is
in operation distribution by road would remain the same but, following the
extension of the rail siding, the amount of aggregates exported by train could
increase. During Stage 3 on occasions some special aggregates would need to be
imported by road.
The WMP (WMP 18)seeks to minimise the environmental and
amenity effects of the transport of minerals by promoting rail and water
transport as an alternative to road transport and
maximising the use of existing railheads and
rail links. WMP 18 states that proposals which enable minerals to be carried on the rail
network or by water will be permitted (subject to other policies of the
Plan). In this respect the proposal is STRONGLY SUPPORTED, particularly
with regard to the extension of the rail link. If approval is recommended
it may be prudent to require that Stage 2 cannot be implemented until the rail
extension is implemented and in use, and that following the opening of the NPAR
the level of rail exports is maintained or increased. This is to ensure
that movements of aggregates and products are not displaced from rail to road.
Traffic impacts of the proposal will need to be assessed
under policies WMP25 and WMP 26 (see below).
NOTE - Again there are number of points in Appendix 15
and the supporting statement which are inaccurate and misleading with regard to
transportation mode and other sites (e.g.9.11). I can provide more details if
required.
DM and overarching policies
A proposal of this scale and size will of course need to
be assessed in terms of a number of development management
considerations. I have listed below the relevant WMP policies that need
to be taken into account. If you need any more details on any policies
please let me know.
WMP 20 Community Involvement and Benefits
WMP 23a Design of built facilities
WMP 23b Operation sites
WMP 24a Climate Change (larger scale proposals expected
to show more detailed mitigation and adaptation measures)
WMP 24b Resource and energy use
WMP 25 General amenity
WMP 26 Traffic impacts
WMP 27 Environment and Environmental Enhancement
WMP 28a Flood risk
WMP 28b Water Resources and Water Quality
Pat Randall
Principal Planning Officer - Planning Policy and
Development Management
Communities, Economy and Transport