Correspondence between HCC Planning and Ellenbrook Residents – Brett consultation.

 

----- Forwarded message -----

From:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>

To:​​ johnjackson4@yahoo.co.uk​​ <johnjackson4@yahoo.co.uk>

Cc:​​ Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>; Mike Hartung <mike.hartung@btinternet.com>

Sent:​​ Thursday, 22 August 2019, 11:53:08 BST

Subject:​​ FW: Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

Dear Mr Jackson,

 

Further to your email of 15 August 2019, I attach the response from SLR Consulting to the points raised.

 

I also attach a summary of points raised by Mr. Hartung yesterday, which I hope to have summarised accurately. Brett Aggregates advise me to expect a response to these points in due course. I will of course forward the response to you when I have it, hopefully within the next few days.

 

Kind regards

Chay

 

Chay Dempster

Principal Planning Officer -  Development Management

Spatial Planning & Economy, Environment Department CHN216

Hertfordshire County Council

County Hall Pegs Lane

Hertfordshire SG13 8DN

Direct dial: 01992 556211

 

From:​​ Richard Ford <Richard.Ford@brett.co.uk>​​ 
Sent:​​ 21 August 2019 14:36
To:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>
Cc:​​ Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>; Karen Myers <Karen.Myers@brett.co.uk>; Stuart Wood <Stuart.Wood@brett.co.uk>
Subject:​​ Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

 

Dear Chay

Please find our attached response to the points raised by the Ellenbrook Area Residents Association (EARA) which you forwarded on 15th​​ August 2019.

Each point raised by EARA has been set out in our document and responded to.

Kind regards,

 

Richard Ford

Senior Planning Manager

Brett Group, Robert Brett House, Ashford Road, Canterbury, Kent. CT4 7PP

Tel: 01227 829075

Mob: 07918 608126

www.brett.co.uk

 

From:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>
Date:​​ 15 August 2019 at 16:23:15 BST
To:​​ Richard Ford <Richard.Ford@brett.co.uk>
Cc:​​ Brian Owen <Brian.Owen@hertfordshire.gov.uk>, Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>
Subject:​​ FW: Request to suspend consultation re Hatfield Aerodrome Quarry Application

Dear Richard,

 

We have received the response below from Ellenbrook Residents Association requesting that we suspend consultation on the additional information pending the provision of a complete and clear dataset in relation to the levels of Bromate contamination.

 

We are taking time to consider the points raised and to seek advice from the Environment Agency and Affinity Water.

 

Please can you also consider the points raised and provide us with a view on how you would like us to proceed.

 

Kind regards

Chay

 

Chay Dempster

Principal Planning Officer -  Development Management

Spatial Planning & Economy, Environment Department CHN216

Hertfordshire County Council

County Hall Pegs Lane

Hertfordshire SG13 8DN

Direct dial: 01992 556211

 

From:​​ Ellenbrook Area Residents Association EARA <info@ellenbrookresidents.org>​​ 
Sent:​​ 15 August 2019 14:53
To:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>; Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>
Cc:​​ Margaret Eames-Petersen <Margaret.Eames-Petersen@hertfordshire.gov.uk>; Margaret Eames-Petersen <eamesmargaret@gmail.com>; John Hale <John.Hale@hertfordshire.gov.uk>; Lenny Brandon <lenny.brandon@welhat.gov.uk>; Paul Zukowskyj <Paul.Zukowskyj@hertfordshire.gov.uk>; Grant Shapps <grant@shapps.com>
Subject:​​ Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

Good Afternoon Chay,


We have looked at the new submission in relation to the Hatfield Aerodrome Quarry application that has prompted a new round of consultation.​​ 


Having studied the two documents we request you suspend the consultation until you have dealt with the issues we have raised below.

 

When you look at the actual table of figures (Dataset) it is quite deceptive.




The table​​ shows the levels in a format that does not reflect the relationship with the WHO Guidelines on safe levels i.e.10µg/l.

 

A prime​​ example of this is BH108CHK ( Borehole in the Chalk layer).​​ 

It gives a figure of 0.2273mg/l​​ - seems low  until you realise that to relate it to the WHO guidelines µg/l​​ you need to move the decimal point 3 places to the right.

This reading should be read as 227.3µg/l.​​ It is actually 22 times over the recommended limit, we are not all experts and it has taken us time to understand why the figures of bromate contamination were seemingly low.​​ 




When you then go to the map accompanying this table and find this borehole 108 it makes reference to all three levels i.e. BH108U (upper Mineral Horizon), BH101L(Lower Mineral Horizon) and BH108C (Chalk aquifer).​​ 

                  ​​ It shows ND (none Detected) in red between the two markers.​​ 

                  ​​ It shows nothing else relating to these three separate readings.​​ 

                  ​​ So looking at the map you get the false impression that there is no Bromate at this location.​​ 

                  ​​ You can see from looking at the previous paragraph above that BH108CHK - Chalk Aquifer has a reading of 0.227mg/l or when stated in the same measure as the WHO guidelines 227.3µg/l.

                  ​​ The same 'error' can be found with borehole BH105

                  ​​ Is this an oversight or deliberately misleading, we certainly hope that it has not been done deliberately with a view to misleading the public merely an unintentional and misguided decision to use alternative measurements to the WHO.




We have requested full details re current Bromate levels and are once more asking for current figures up to June/July to identify the change in readings due to differing climatic conditions. This is a known probability and we believe this has been seen previously according to analysis of their own historic figures.




Further we are still asking for data from all boreholes, so we are now asking for the data from all the boreholes listed on the table or at least a rationale as to why this is not being released/available such as BH307.




A​​ number of others who are entitled to comment on this application,  may see  these figures on the dataset as 'low and within the 10µg/l​​ limit' and therefore this may well prevent them from making proper and correctly considered comments as is their democratic right. We strongly believe that the information circulated must be accurate, full, transparent and clear.




We are therefore asking that non misleading documents should be requested and the consultation suspended until such time as these corrected documents are submitted and a further 30 day period of consultation be commenced at that time




We look forward to your earliest response.




John Jackson

Submitted on behalf of EARA Committee

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Brett Group is the trading name of Robert Brett & Sons Limited. Reg No 227266 Robert Brett House, Milton Manor Farm, Ashford Road, Canterbury, Kent CT4 7PPV.A.T. Reg. No. 201138818 Registered office: 150 Aldersgate Street, London, EC1A4AB.This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the originator of the message. Any views expressed in this message are those of the individual sender, except where the sender specifies and with authority, states them to be the views of one or any of the Brett Group of Businesses.

Dear Richard,

 

I have been forwarded a link to Ellenbrook Residents Association where they have published an assessment of the further information​​ 

 

https://ellenbrookresidents.org/2019/08/14/brett-quarry-application-the-consultation-runs-until-6th-september-2019/

 

They have asked me two questions and made two other points about the data i.e. -

 

What is the difference between 201S/201D?

In regard to the readings for U/L/C - how is possible to have 3 separate readings from the same borehole?

The readings are from February 2019. The data does not account for seasonal variations where Bromate concentrations may be affected by the relative height of the water table​​ 

The mineral extraction is very close to the boreholes shown to be contaminated by Bromate, for example, Borehole 201 is 66m and BHButm is 150m to the north of the site boundary, both of these boreholes are shown to be contaminated by Bromate

 

They are saying the steady state (Thiem equation) of the lower confined lower aquifer has not been properly assessed. I am told this has the potential to lower the piezometric levels by up to 1m over a 300 to 400m distance away from the borehole well (depending upon the size of the excavation). They assume the effect could be very significant where substantial volumes of sand, gravel and water are removed. They believe the Environment Agency has not properly considered the potential effect on piezometric levels or taken into account how close the contamination is to the proposed mineral working.

 

They argue contaminated groundwater could be drawn in to the LMH lagoon from the surrounding confined lower aquifer. This will result in the LMH lagoon becoming contaminated by Bromate. They say during conditions where groundwater levels are particularly high the design infiltration rates will not occur, therefore the storage volume in the LMH lagoon will be exceeded and contaminated groundwater will be discharged in to the Ellenbrook either directly from the back-drain or as a result of groundwater flooding.

 

These points are bound to come up at committee and it would be very helpful to be able to address them in the committee report so that members have a clear picture in their minds before the day.

 

I would be grateful to be advised by SLR on the points and assumptions raised by EARA.​​ 

 

Yours sincerely​​ 

 

Chay Dempster

Principal Planning Officer -  Development Management

Spatial Planning & Economy, Environment Department CHN216

Hertfordshire County Council

County Hall Pegs Lane

Hertfordshire SG13 8DN

Direct dial: 01992 556211

 

From:​​ Ellenbrook Area Residents Association EARA <info@ellenbrookresidents.org>​​ 
Sent:​​ 21 August 2019 13:07
To:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>
Cc:​​ Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>
Subject:​​ RE: Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

Hi Chay.

 

I am surprised that you ask what grounds you should suspend the consultation, surely it is obvious that in our view, and you I believe must agree that the documents are inaccurate, the map alone gives false information. Therefor you are knowingly running a flawed consultation, it is only if the person looking at the consultation discovers for themselves the errors we have identified to you that they could possibly comment accurately on the position.​​ 

You may be 'following' procedure to the letter but surely accuracy and morality should be a consideration.

We will do our best to ensure as many people as possible are informed of the situation.

Regards

 

John

On 21 August 2019 at 10:36 Chay Dempster <Chay.Dempster@hertfordshire.gov.uk> wrote:​​ 

Dear John,

 

I contacted Brett Aggregates with EARA’s concerns and asked them to consider the points and provide us with a response.

 

The response today from Brett Aggregates says their consultant (SLR) is considering the points and will provide us with a response, but advise​​ ‘we [the LPA] currently have in your possession all of the data and information that we have’​​ 

 

We are required to publish any environmental information provided to us. We have requested the information from the applicant and they have been provided us with it.

 

I am unclear on what grounds we should suspend the consultation.

 

Kind regards

 

 

Chay Dempster​​ 

Principal Planning Officer -  Development Management​​ 

Spatial Planning & Economy, Environment Department CHN216​​ 

Hertfordshire County Council​​ 

County Hall Pegs Lane​​ 

Hertfordshire SG13 8DN​​ 

Direct dial: 01992 556211​​ 

 

From:​​ Ellenbrook Area Residents Association EARA <info@ellenbrookresidents.org>​​ 
Sent:​​ 19 August 2019 14:55
To:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>
Cc:​​ Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>
Subject:​​ RE: Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

Hi Chay.

Have you made a decision yet as to the consultation.

We would urge you to press the applicants to provide the full and accurate documentation and restart the consultation,​​ rather than waiting on EA and AW for their opinions.

As you have not contacted the general public direct for their views, merely an article in the newspaper, those of the public who do see the consultation and then are actually able to find the incomplete and somewhat misleading documentation may decide not to comment, whereas if the information was transparent and accurate they would.

Our concerns are that time is running out to get the publics view, it should not be EARA's job to let everyone know the correct position.

Please can you update us re your position as soon as possible.

 

Regards

John

 

John Jackson

07941 302 513

On behalf of EARA Committee

On 15 August 2019 at 16:29 Chay Dempster <Chay.Dempster@hertfordshire.gov.uk> wrote:

Dear Mr Jackson,

 

Thank you for your email. We are considering the points raised and will provide a response as soon as possible. I propose to forward your email to the Environment Agency and Affinity Water to consider the points alongside the additional information. I will ask them to address the points raised in your email in their response.

 

I will advise how we propose to proceed as soon as possible.

 

Kind regards

Chay

 

Chay Dempster​​ 

Principal Planning Officer -  Development Management​​ 

Spatial Planning & Economy, Environment Department CHN216​​ 

Hertfordshire County Council​​ 

County Hall Pegs Lane​​ 

Hertfordshire SG13 8DN​​ 

Direct dial: 01992 556211​​ 

 

From:​​ Ellenbrook Area Residents Association EARA <info@ellenbrookresidents.org>​​ 
Sent:​​ 15 August 2019 14:53
To:​​ Chay Dempster <Chay.Dempster@hertfordshire.gov.uk>; Brian Owen <Brian.Owen@hertfordshire.gov.uk>; Jonathan Tiley <Jonathan.Tiley@hertfordshire.gov.uk>
Cc:​​ Margaret Eames-Petersen <Margaret.Eames-Petersen@hertfordshire.gov.uk>; Margaret Eames-Petersen <eamesmargaret@gmail.com>; John Hale <John.Hale@hertfordshire.gov.uk>; Lenny Brandon <lenny.brandon@welhat.gov.uk>; Paul Zukowskyj <Paul.Zukowskyj@hertfordshire.gov.uk>; Grant Shapps <grant@shapps.com>
Subject:​​ Request to suspend consultation re Hatfield Aerodrome Quarry Application

 

Good Afternoon Chay,

 

We have looked at the new submission in relation to the Hatfield Aerodrome Quarry application that has prompted a new round of consultation.​​ 

 

Having studied the two documents we request you suspend the consultation until you have dealt with the issues we have raised below.

 ​​ 

When you look at the actual table of figures (Dataset) it is quite deceptive.

 

The table​​ shows the levels in a format that does not reflect the relationship with the WHO Guidelines on safe levels i.e.10µg/l.

 ​​ 

A prime​​ example of this is BH108CHK ( Borehole in the Chalk layer).​​ 

It gives a figure of 0.2273mg/l​​ - seems low  until you realise that to relate it to the WHO guidelines µg/l​​ you need to move the decimal point 3 places to the right.

This reading should be read as 227.3µg/l.​​ It is actually 22 times over the recommended limit, we are not all experts and it has taken us time to understand why the figures of bromate contamination were seemingly low.​​ 

 

When you then go to the map accompanying this table and find this borehole 108 it makes reference to all three levels i.e. BH108U (upper Mineral Horizon), BH101L(Lower Mineral Horizon) and BH108C (Chalk aquifer).​​ 

                    ​​ It shows ND (none Detected) in red between the two markers.​​ 

                    ​​ It shows nothing else relating to these three separate readings.​​ 

                    ​​ So looking at the map you get the false impression that there is no Bromate at this location.​​ 

                    ​​ You can see from looking at the previous paragraph above that BH108CHK - Chalk Aquifer has a reading of 0.227mg/l or when stated in the same measure as the WHO guidelines 227.3µg/l.

                    ​​ The same 'error' can be found with borehole BH105

                    ​​ Is this an oversight or deliberately misleading, we certainly hope that it has not been done deliberately with a view to misleading the public merely an unintentional and misguided decision to use alternative measurements to the WHO.

 

We have requested full details re current Bromate levels and are once more asking for current figures up to June/July to identify the change in readings due to differing climatic conditions. This is a known probability and we believe this has been seen previously according to analysis of their own historic figures.

 

Further we are still asking for data from all boreholes, so we are now asking for the data from all the boreholes listed on the table or at least a rationale as to why this is not being released/available such as BH307.

 

A​​ number of others who are entitled to comment on this application,  may see  these figures on the dataset as 'low and within the 10µg/l​​ limit' and therefore this may well prevent them from making proper and correctly considered comments as is their democratic right. We strongly believe that the information circulated must be accurate, full, transparent and clear.

 

We are therefore asking that non misleading documents should be requested and the consultation suspended until such time as these corrected documents are submitted and a further 30 day period of consultation be commenced at that time

 

We look forward to your earliest response.

 

John Jackson

Submitted on behalf of EARA Committee

****Disclaimer****


 

 

Brett-responce-to-HCC-Planning-Queries-raised-by-EARA-21-8-19