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
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.
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.
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
Principal Planning Officer - Planning Policy and Development Management
Communities, Economy and Transport