Noise, environmental damage

**UPDATE** 22/07/22: the application has been refused by Essex County Council. You can read the refusal notice here which also states “[it] is considered expedient to service an enforcement notice requiring the removal of the unauthorised development and the land reinstated.”

Letter to the Head of Planning Services, Essex County Council, 15th July 2022, concerning the yet-to-be authorised aggregates processing operation adjacent to Great Chesterford on the site known as Boro Farm.

To:         Graham Thomas, Head of Planning Service, Essex County Council

Cc:         Tom Sycamore, Planning Officer, Essex County Council

Dear Mr Thomas,

I am writing to bring to your attention the considerable concern of residents and consultees in the vicinity of an aggregates processing operation that has set up immediately north of Great Chesterford, adjacent to the River Cam and just inside the Essex border with Cambridgeshire. The parish councils of Great Chesterford and Ickleton, Uttlesford District Council, the neighbouring Wellcome Genome Campus and the Wildlife Trust for Bedfordshire, Cambridgeshire and Northamptonshire are among the 100+ who have raised concerns.

These concerns fall into four categories : 1. Noise nuisance.  2. Traffic impact and road safety.  3.Environmental and ecology impacts.  4. Inadequate and misleading reports and responses

The response from Great Chesterford parish council (view here) provides a concise overview to which should be added the reaction of the Bedfordshire, Cambridgeshire and Northamptonshire Wildlife Trust, which I have added below as it does not yet appear on your planning portal. It would appear the Environment Agency, in issuing permits for this operation, has ignored its own guidelines and based their consent upon inaccurate data. Therefore those permits should not be taken as read.

I understand that Essex County Council has until 22nd July to issue a decision. If this aggregates operation is consented based on the woefully inadequate information presently before the council there will almost certainly be a judicial review instigated by the parishes either side of the border such is their concern about this application.

Sincerely,

Richard Pavitt

Councillor

Littlebury, Chesterford & Wenden Lofts ward

Uttlesford District Council

Wildlife Trust for Bedfordshire, Cambridgeshire & Northamptonshire

FAO Essex County Council, Planning Department

Dear Sir,

I am responding to this application on behalf The Wildlife Trust for Bedfordshire, Cambridgeshire & Northamptonshire. Although the application site is within Essex it is within 50 metres of the River Cam and associated wetlands. The River Cam is a County Wildlife Site in Cambridgeshire and is a chalk stream priority habitat.

The Biodiversity Checklist appears to be incorrectly filled out in Table 2.2, because while acknowledging the application is within 100 metres of the River Cam, which the Ecological Report (PEA) identifies as a chalk stream and therefore priority habitat, the biodiversity checklist box for proximity to priority habitat has not been ticked. The River Cam at this location is also identified as a County Wildlife Site in Cambridgeshire, but again the relevant box is not ticked. The PEA also fails to acknowledged that the River Cam is a Cambridgeshire County Wildlife Site.

The potential impacts from this development are loss of habitats and various forms of pollution, including light, dust and potentially noise. However, of these, it is likely that light would be the most ecologically damaging. The Ecological Report makes various recommendations relating to lighting, but we are concerned that they do not go far enough and that rather than using E2 standards of light pollution, that E1 standard should be considered as the site is in such close proximity to the River Cam, which is a natural wildlife corridor. The recommendations on light also relate to a different development so may not be relevant to the current application.

The Environment Agency have not objected to the application, but acknowledge that an Environmental Permit will be required. However, we would contend that in this case sufficient details should be provided with this application to demonstrate there will not be any adverse impacts on the ecology of the River Cam and the species using the river and its associated habitat corridor, from various forms of pollution.

The Ecological Report accompanying this application is dated April 2020, with surveys undertaken in April 2020 And confirms to a Preliminary Ecological Assessment (PEA) standard. However the PEA was clearly prepared for another proposal (construction of self-storage units) and not the current application. The PEA is therefore not appropriate for the current application, and at over two years old is also out of date in some respects. Coupled with the failure to undertake a Cambridgeshire biological data search, the Preliminary Ecological Appraisal is not a suitable report for submission with this application (not conforming with CIEEM best practice guidelines).

The PEA identifies additional habitats in the southern portion of the site which will be adversely impacted by the proposed processing facility. No assessment of these impacts has been undertaken, but this must be done before the application is determined, and the Wildlife Trust would also recommend that a Biodiversity Net Gain assessment is undertaken for such a major development in this location, in order to demonstrate whether a Biodiversity Net Gain can be achieved in line with planning policy.

Overall, the applicants have provided insufficient information to rule out potential adverse ecological impacts or to demonstrate a net gain in biodiversity. An updated Ecological Impact Assessment, in accordance with CIEEM best practice, and specifically related to the development now proposed should be prepared and submitted in support of this application, before it is determined. Failure to do so should result in the refusal of this application.

For the above reasons, the Wildlife Trust BCN objects to this application.

I hope these comments are of help to you. If you have any queries regarding this advice, please don’t hesitate to contact me and we would appreciate being kept informed of the progress of this application.

Yours faithfully,

Martin Baker MCIEEM, CEnv.

Conservation Manager

Note: the image used here is not of the actual site but is representative of aggregates processing.

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