Planning Application Ref No PL/0232/21 Land at Hatfield Aerodrome, Off Hatfield Road
Ellenbrook Area Residents Association objection to the planning application to quarry on Ellenbrook Fields – October 2021
We represent the interests of over 500 houses bordering the Ellenbrook Country Park.
We would like to start with affirming our resident’s association strong objection to the quarry application. We objected to the original application and believe that the risks associated with this application that have been raised in our previous objections still apply to this application.
As a residents group we do not understand how an application to quarry on a site, that is so close to the bromate plume, can even be considered and we would like to see evidence of a proper risk assessment being carried out by independent, qualified experts in this field.
The spillage was not commonly known about by the public or by the Residents Associations until after the local mineral plan was adopted in March 2007. We believe that this site would not have been included in the mineral plan if the bromate pollution was fully understood at the time of adoption.
We believe that there is insufficient borehole information of this pollution available for the whole site and that there should be borehole information extracted from across the whole site and in particular on the actual dig site, not just readings from around the periphery.
We believe that adopting Brett’s water management plan approach as proposed in the quarry application is flawed as it will only come into effect when it is too late. The bromate pollution can take hundreds of years to clear naturally. Once the bromate has contaminated our water it will be too late. In our opinion the council should not allow this high risk strategy, they should just not be relying on a ground water management plan which will alert everyone when the damage has been done. This potential risk is too serious to ignore.
All three specific sites in the mineral plan are in one small part of Hatfield. We believe that this is a disproportionate concentration of mineral works in one small area of the county.
This small area of Hertfordshire has already had quarrying for well over 85 years. This application will extend the quarrying for another 32 years at a minimum, meaning that this area will have been subjected to quarrying for circa 120 years. This is more than a lifetime and it is unacceptable to concentrate so much quarrying in one small part of the county. We do not believe that the cumulative impact of having three quarry sites in one small part of Hatfield has been fairly assessed as part of the planning process and should be reconsidered. In fact this completely flouts MLP Policy 11 which presumes against development that would have an unacceptable cumulative impact on the environment in relation to schemes occurring either concurrently or successively.
The concentration of quarrying in this area will also generate additional HGV traffic movements on the A1057 (St Albans Road West) identified in the A414 consultation as at or exceeding capacity, with limited scope to enhance the road to provide additional capacity. Extracts from the relevant documents are shown below:
“St Albans Road is either approaching or exceeding capacity in either direction and in both AM and PM time periods and in the PM period, Ellenbrook Lane NB (northbound) approach also has a Volume to Capacity ratio over 90% during PM. Delays of over 5 minutes are expected in the roundabout due to the vehicles from the major road (A1057) having to give way to vehicles approaching from Ellenbrook Ln”
“The A1057 Hatfield Road / St Albans Road West links Hatfield and St Albans. It is an intensively used corridor for shorter and longer distance trips by a variety of modes for different journey purposes including commuting, access to the University of Hertfordshire, shopping and logistics. There is limited scope to enhance the road to provide additional capacity and this may not be desirable from a place and movement perspective which should aim to give greater priority to the local functions of the road and to discourage the use of the road for through trips, including those travelling from western parts of St Albans (or beyond) to the A1(M) or areas along the A414 corridor east of Hatfield”.
This additional HGV traffic will also be on top of recent local housing and commercial developments that have generated considerable traffic flow along the A1057. The cumulative impact of all the recent developments does not appear to have been taken into consideration and the road network has already been identified as at or above capacity. The additional 164 vehicle movements a day will only exacerbate these issues. The data shows that this will amount to an extra HGV on this road every four minutes in working times. The impact that this will have on traffic flow, noise and pollution should not be underestimated.
We also believe that the council has not taken into account the economic and delivery risk if for any reason extraction has to stop on this proposed quarry. This quarry will be a hugely complex, difficult and costly operation to extract the gravel which is evident from the time it has taken to get to this stage, yet alone to complete the target of 8+million tonnes within the timescales. There will be ongoing hurdles which potentially will extend the period of extraction, which is already unreasonable, if not cease operations all together. This will lead to derelict land being left, contrary to the conditions in the Local Mineral Plan.
Ellenbrook Fields as a country park was promised to residents under a Section 106 agreement, which despite nearly 20 years passing since it was agreed has still not been set up. The Country Park Trust must be set up before any planning application is considered to protect this valuable resource and ensure that activities on this site are agreed in accordance with the Section 106.
As a residents association we have little faith that the Council will not renege on this agreement as despite our constant pressure the agreement is still not in place. If this application goes ahead we believe that it is unlikely that the Country Park Trust will ever materialise, contrary to what was promised to the residents. The council should be protecting the Country Park on behalf of the residents, looking after the needs of locals and not allowing the developers to call the shots.
The last time this Applicant brought a near identical application to Committee, the landowners sent correspondence on the morning of the meeting promising to sign the elusive s106 if the application was approved. This attempt to strong arm the Council into approving this application should be looked at sceptically. It is concerning that this is how the LANDOWNERS AND APPLICANTS think the Planning Committee works.
Ellenbrook Fields is a unique, irreplaceable valuable resource for the community that promotes health and wellbeing for residents. It is part of Hatfield’s green belt with meadow and grazing land, owls, butterflies, crested newts, and wildflowers.
It is used extensively by dog walkers, cyclists and ramblers.
The Covid 19 Pandemic showed how valuable this piece of land is for local residents. It became a safe haven of open, green space, where locals could get fresh air, go for walks, and not encounter crowds of people. These areas should be fiercely protected by the Council and not handed over to developers.
There is no alternative for local residents or wildlife to this location in the area if the quarry goes ahead.
The Development of Evidence for Welwyn Hatfield Local Plan: Green Gap Assessment clearly states that it is inappropriate to build on the green belt land between Hatfield and St Albans along the A1057 area and has identified this area as a gap policy area to prevent the future merging of Hatfield with St Albans. The following are recommendations / comments from the document
The case for keeping this land open is strengthened by the role the area plays in providing a rural parkland setting to the edge of Hatfield, as well as its ecological value represented by the presence of local wildlife sites.
Maintain a physical and visual separation between the two settlements, avoiding scattered and ribbon development along the connection roads that could erode the gap. This is particularly pertinent between the edge of Smallford (St Albans) and Ellenbrook (Hatfield);
Improve habitat provision throughout the area, particularly acid grassland and broadleaved woodland;
Preserve the character of Ellenbrook Fields country park and its role as a recreational resource;
Ensure the area within the gap continues to provide a rural setting to Hatfield; and maintain public access to and across the area, seeking opportunities for further public rights of way.
All the above bullet points are in conflict with the recommendations being made, and this will lead to the loss of Ellenbrook Country Park and the green belt gap between Hatfield and St Albans.
Ellenbrook Fields lays over an area which is contaminated by bromate, a known carcinogen, which occurred as a result of a major pollution disaster discovered in the year 2000. The pollution originated because of a major chemical spill at Steetly Chemical Factory, Sandridge, some 20 years previously, resulting in a bromate plume which has travelled underground all the way from Sandridge to Broxbourne, part of which is underneath Ellenbrook Fields. The plume has travelled approximately 20 km, this contamination is considered by the experts to be the worst ground water contamination event in Europe.
We believe that the quarry site is already contaminated with bromate and bromide and that no risks should be taken that may affect the movement of the bromate plume and cross contamination of our water supplies. .
We therefore believe that the quarry application will breach the Environment Agency first planning condition that “1. No mineral is extracted from within the existing plume of bromate and bromide groundwater pollution. “
“The site lies over an area contaminated with a plume of Bromate which is found in the lower horizon of the sand and gravel resource. Proposals will require an extensive plan of groundwater level and quality monitoring before, during and after the working to protect the water supply. The Bromate plume will need to be assessed and shown that it will not be spread either vertically or laterally as a result of proposed works. This is of particular importance for proposals which extend below the water table or into the lower mineral horizon.”
We do not believe that the actions as detailed in the Hertfordshire Minerals Local Plan have been carried out satisfactorily, that is, the groundwater level and quality monitoring has not been carried out on the actual dig site, only on the periphery; the bromate plume has not been shown that it will not be spread either vertically or laterally as a result of quarrying. The fact that the plan specifically states that this is of particular importance for quarrying that extends into the lower mineral horizon seems to be being completely ignored.
The idea that the plume is moving and yet static can be easily understood by analogy of a sponge that is impregnated with salt and drip fed with clean water. The sponge would leach salty water and taste of salt for a long time. The rate of the flow is set by the drip frequency.
The plume flows from West to East saturated with bromate, the gravel in the lower mineral horizon (LMH) aquifer acts as storage or sponge – in this case static – and not moving.
“The lower aquifer to the north of the application site is contaminated by bromate. The application proposes the extraction of sand and gravels from within the lower aquifer in close proximity to groundwater contaminated by bromate.
Bromate and bromide (which is a precursor to bromate) has been detected around the proposed dig site in levels greater than expected. Bromate levels have been detected over 1000 µg/l on Ellenbrook Fields quite close to the proposed quarry, and in 2019 quarterly reading were detected in the site area over the “fringe” level of 0.5µg/l. Bromide levels greater than the norm have been detected at internal boreholes within the site of 2280µg/l of bromide. We believe that this remains a valid reason for rejection.
We believe that bromate and bromide are below the dig site or so close to it that quarrying poses a major risk by disturbing it.
“The proposed site lies over an area contaminated with a plume of Bromate. A more robust risk assessment may be required at this site in order to determine the risk of impact on the Three Valleys Water source at the public water source at Bishops Rise.”
Clearly the magnitude of the bromate contamination was not considered when the Local Minerals Plan was drawn up.
Quarrying on land contaminated by bromate & bromide is covered by the National Planning Policy Framework 2021. We believe that the application for the quarry does not comply with the framework as described below:
Ground conditions and pollution
“Planning policies and decisions should ensure that: a) a site is suitable for its proposed use taking account of ground conditions and any risks arising from land instability and contamination”.
“planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment”
The quarry is sited within these water protection zones and is a threat to them because the capture of groundwater in the chalk aquifer is used directly to supply PWS Roestock & Tyttenhanger. But, in the case of Bishops Rise the aquifer is already polluted with bromate and shows up as 340micrograms/litre at BR station – it’s not used as a public water supply now.
Extract from Affinity Water statement:
“Since May 2000, we have not used the groundwater abstraction source at HATF for public supply due to the concentration of bromate in the Chalk groundwater. We operate several other abstraction points in the vicinity which are of relevance. These are ESSE, ROES, TYTT and NORM. The bromate pollution and the actions dealing with it, all have an impact on our operations at these sites. You should be aware that the proposed mineral extraction site is located within an Environment Agency defined groundwater Source Protection Zone 3 (SPZ) corresponding to a number of these sources, whilst being in or bordering one or more SPZ 2 zones”.
Clearly, as described by Affinity Water in bold above, the bromate pollution and the actions dealing with it are of concern to them.
To quarry so close to the plume is an unacceptable risk to our health and environment. The World Health Organisation (WHO) states that bromate levels should be below 10 µg/l in our drinking water. Whilst we acknowledge that the water companies would not allow this carcinogen to infect the water actually supplied to the public but having a quarry on top of the source of the groundwater supply is a very high risk to the ongoing use of this scarce resource.
This bromate plume next to the quarry contravenes the WHO guidelines by a huge amount
Known readings within 100 m of the quarry perimeter show levels 9 times greater than the WHO levels
Known readings within 500 m of the quarry perimeter show readings 56 times greater than the WHO levels
We believe that information titled “Bromate & bromide groundwater quality (Aug 2013 - Nov 2019)” supplied by SLR clearly shows that bromate does exist on the site. This is despite the information being supplied in milligrams instead of micrograms and an unreadable scanned copy.
Dr Rivett, a Contaminant hydrogeologist with 35 years of research-oriented groundwater experience has provided an independent analysis of the situation based on information provided and his expertise. He is currently Director of GroundH2O Plus Ltd based in Birmingham in the UK, an environmental consultancy specialising in research-informed hydrogeological assessment and technical review of groundwater contamination issues of concern to contaminated land, nuclear, energy-development, water-industry, and groundwater regulation and developing world sectors. This analysis should be taken very seriously when the Council are making their decision. He has no financial interest in the quarry and therefore his findings are completely unbiased.
In 2000, Hatfield lost its main water supply called Bishops Rise, which was turned into a remedial “scavenging” station where some bromate was removed from the ground. It was not deemed a great success, also Essendon station was contaminated to a lesser extent. Wells all the way to the New North River and Ware, Hoddesdon have been compromised and as far as we know they are “out of action”. Licenses for private wells have been rejected.
A remediation plan to deal with the bromate pollution was established 10 years ago and managed by the Environment Agency (EA), but unfortunately the remediation plan has failed to significantly reduce the levels of bromate within the area. A voluntary new remediation statement was signed in September 2020 and the actions in the statement are waiting to be addressed.
We cannot understand why there is not a joint review of the potential impact of two quarries operating side by side in such a vulnerable area of land polluted with a carcinogen. The review should be looking into both the impact of quarrying on the bromate plume and the potential effect on the groundwater flood risk.
The fact that the 10 year mitigation plan (as approved by the EA in 2008) to stop the spread of the plume from Sandridge (the original source of the plume) has completely failed, should be sufficient evidence that the plume is not understood by the “experts”. The fact that a second remediation plan is necessary with additional options (other than scavenging) to manage the plume should set off alarm bells that the spread of this plume is proving very difficult to eradicate, yet alone predict.
We are also concerned that despite a huge amount of effort being made to stop the plume, it continues to spread and shows no sign of abating. Again, by potentially disrupting the plume, this seems like a high risk strategy to take. We are extremely disappointed about the approach that the Environment Agency is taking towards this application when they have seen first-hand the devastating impact bromate has on the environment and the extreme difficulty it poses to remove once contamination has occurred.
The local Environment Agency has previously stated that the quarry working is ‘unlikely’ to cause the bromate plume to impact upon the remaining water pumping stations. “Unlikely” in our view is not a good enough guarantee that it will not, particularly when it is clear that the bromate is extremely difficult to remove, and efforts to remove it have been unsuccessful to date.
We believe that the risk to public water supplies contravenes MLP policies 17 and 18. Policy 17(iv) provides that development would not be permitted if it would have a negative quantitative and/or qualitative impact on groundwater resources, unless appropriate measures can be imposed to mitigate any harmful effects.
We are really concerned that the quarry may have catastrophic effects on this scarce water resource in the aquifer under the proposed dig site, used as the source for our public water supplies and do not believe that any risk to the water source should be taken, particularly in a time when both the EA and Affinity Water are warning of water shortages. In May 2019, ‘Affinity Water has warned that within the next 25 years and beyond, there may not be enough water due to climate change, population growth and increases in demand.’ (https://www.affinitywater.co.uk/news/affinity-water-warns-of-water-shortages-unless-government-acts-now). It is completely inappropriate and reckless to put any water sources under any risk whatsoever when Affinity Water themselves are launching campaigns and informing the public of catastrophic impacts of water shortages. The same article states ‘Water efficiency is critical in the South East – a severely water stressed area. Environment Agency CEO, Sir James Bevan recently warned that the water crisis was like ‘looking into the jaws of death’ and the forces of climate change and population growth could mean severe water shortages within the next 25 years.’. We reiterate that no risk whatsoever should be taken with our precious water source.
We are really concerned that the quarrying process may draw the bromate pollution onto the area and contaminate the source water used by Affinity Water to provide public supplies. The water management plan that the applicants are relying upon will not in our opinion eliminate this risk of drawing the bromate pollution onto the site, the plan is not a strong enough safeguard and leaves too high a risk to take with the source water. Our concerns are reinforced by the fact that Affinity Water originally objected to the previous application before a legal agreement was reached between them and Brett Aggregates.
We are aware that Affinity Water will not put contaminated water into the public network, but we will risk losing this valuable resource for decades at the least if any bromate leaks into the source water area. The private agreement between the applicant and Affinity Water should this happen is also concerning. This should be subject to public scrutiny, and there is no reason why this agreement is not open and transparent.
The bromate plume has already affected the land and water supply in and around our area of Hatfield. Two local pumping stations have already been affected by the plume; one in Hatfield had to be closed when it was realised this was putting contaminated water into the public water systems, and one in Essendon is closely monitored to ensure that the drinking water remains below WHO guidelines, this means that Affinity Water have to keep turning it off and mixing the water with uncontaminated water to lower the bromate concentration in order to keep the community supplied with clean, safe drinking water. If the plume continues to move in a southerly direction it will start to affect the remaining uncontaminated water pumping stations. We do not believe that any risks to the remaining supplies in the area should be taken.
We recognise the importance of the remediation work (circa 2008) to remove the bromate, which has been undertaken by Affinity Water, who operates the Water Pumping Stations in our area. However over the past 10 years this remediation work has sadly, despite the huge financial cost and more importantly the ongoing loss of millions of litres of precious and scarce water, made no noticeable difference to the level of contamination in the source water arriving at Bishops Rise Water Pumping Station and formally used for our drinking water. Thus, this and possibly other water pumping stations will close or remain closed for the supply of water and will do so for many decades to come.
As stated above, Affinity Water and the Environment Agency have both made media statements in 2019 regarding the scarcity of water in the future. We find it difficult to believe that the Environment Agency and Affinity Water can make such statements whilst still looking to give their permission to this quarry which could contaminate huge quantities of source water, the slightest risk to this valuable commodity should not be taken. Not only have both organisations told the public how they expect the Government to take steps to protect water sources, but the Environment Agency has also released a report ‘Adapt or Die’ in the last month about the huge risk that climate change is bringing to flooding. In light of all these statements how can they then agree to risks being taken with this source water? It raises the question, do the departments in the EA and AW that are raising these warnings know of the application, or are the EA and AW representatives at these hearings working separately.
Cemex have permission to utilise 250 vehicle movements a day, they are not and have not to date used anywhere near this, however with the permissions granted already and the commencement of a new quarry at Furze Field starting next and the infilling commencing on other parts of the Cemex quarrying operation they had anticipated they will be at full capacity by spring of 2020. The global Pandemic has had an impact on this timescale, however as the UK shifts back into normal working patterns it is likely Cemex will hit these figures in the near future. This will add more vehicles to the A1057 that do not currently use the road and has not been accounted for in calculations by the applicant.
MLP policy 16 states that mineral development will only be permitted when the provisions for vehicle movement are such that traffic generated would not have an unacceptable impact on highway safety, the effective operation of the road network, residential amenity or the local environment. The transport information / analysis provided by the applicant is severely out of date. We understand that the reasoning given by the applicant is that the Covid 19 pandemic has impacted on traffic flow. We agree with this, however a decision should not be made on information that is almost 6 years out of date. Significant changes have happened in traffic flow in the last 6 years and should be investigated before making a decision on this application and as people are just now starting to return to some working normality the vehicle usage will only go up.
It is not good enough that the applicant states that “While the data would normally be considered as time-expired, the effects of the Covid 19 Pandemic cannot be underestimated in terms of disruption to ‘normal’ traffic volumes, and as such it is considered that growthing the previously acquired data would serve better in context of any assessment work.” There were plenty of opportunities for the applicants to undertake more up to date assessments between 2016 and 2020, however, this was not done.
With the recent push to encourage the public to use bicycles, adding more HGVs to an already heavily congested road, this seems out of kilter with the government’s other priorities.
We believe that the risk posed to highway safety at the entrance to the quarry site (by Notcutts) flouts MLP policy 16. This site will have 164 HGV movements a day onto a single carriage road. To access the site HGVs will need to have a turning lane on the A1057 into the access road as all traffic must enter coming from the East. This is a busy road and slow HGVs queuing in this lane will cause the traffic to back up, it will only take two or three lorries waiting to completely block the road. This will raise the potential for accidents from vehicles coming across stationary traffic on a fast stretch of road or very slowly moving vehicles entering onto the roadway from the site, again into the path of fast moving vehicles. The placement of the entrance (5m from where it was in the original application) is in a more dangerous position than where it previously had been identified as it is now closer to the blind bend
Weekday rush hours often has traffic queuing from the Albatross Way/Ellenbrook Lane Roundabout to A1057/Oaklands Lane/Station Road Roundabout. This is without the addition of multiple HGVs which will be attempting to cross across a flow of traffic, on a bend in the road. The applicant states that this piece of road is ‘relatively straight’, however they are omitting the fact that the entrance to the site is on a bend in the road, where by crossing across traffic, there are likely to be further delays to traffic between Hatfield and St Albans, as well as a potential risk to those cars travelling from St Albans to Hatfield, unexpectedly coming across an HGV crossing across their path. As local residents, the A1057 is not only a road that we use daily, often at peak times, but it is the only access and egress route for all vehicular traffic from the entire Ellenbrook area. The real life, anecdotal evidence should not be ignored. We have photographic and video footage showing a typical queue of traffic between these two roundabouts. From this footage, you can also see the number of HGV type vehicles already on the road.
Any road works in the last few years have proved the theory that any disruption to the flow of traffic has a monumental impact, causing traffic in the morning at the Smallford roundabout to be queued back to beyond the Ellenbrook roundabout, along Station Road down to the bridge and Oaklands Lane up to the roundabouts at Jersey Farm. The vehicles waiting to turn across traffic onto the site via the proposed access will be prevented from doing so by traffic coming from St Albans towards the Galleria and the A1. This will be aggravated by HGVs slowly pulling out of and away from the site onto the A1057 slowing the eastbound traffic.
We believe that the authorities have not taken the following into account in regard to the potential for flooding-
Climate change poses a real threat to flooding in our area, with extreme events occurring much more regularly than predicted
The Ellenbrook area is regularly the subject of a flood risk warning highlighting this real risk to the area from flooding
the ‘Adapt or die’ report recently published by the Environment Agency (EA)
previous warnings from the Head of EA and Affinity Water regarding shortage of drinking water
The cumulative impact from all the current, historic and proposed quarrying in the immediate vicinity of this site turning permeable land into non-permeable land, altering the areas hydrology including increasing run off of large quantities of surface water along with the loss of open areas of land.
The use of the rivers to carry away excess water in extreme weather conditions including overflows from the lagoons which will end up leaving the site and travelling through the residential area of Ellenbrook via the Ellen Brook, an open but confined stream which runs along Ellenbrook Lane and is already at full capacity during normal wet weather conditions.
The risks to urban properties from the closeness of the Brett lagoons has been undervalued. Only 350m separate the University, roads, and local housing, the quarry is too close and poses a significant risk to them.
These lagoons are man - made and subject to accidents, overflow, and blocking due to silt & algae.
They are extremely deep, and carry vast amounts of water.
Lagoons overloading. The consequence of the lagoon overflowing the 1 metre headroom will be that no more excess water can be removed from the site by the Sustainable Drainage System (SuDS) method. The result is that surface water run-off, over impervious surface, will now travel towards the river systems; exceedance to Nast or Ellen Brook will cause extensive flooding to housing, university, A1057 and the flood zones reach to both the A414 and A1M.
Complexities of the site. When you consider the complexity of any water management plan and attempts to control water along with the risk of any errors in judgement, working practice, human error and climate change we believe to dig here is a very high risk especially when you consider the potential implications and outcomes for the community and environment if it goes wrong.
Due to the high risk associated with the bromate plume which may cause gravel extraction to pause or stop, this site cannot guarantee the supply of the expected amount of sand and gravel. If certain conditions such as water levels alter or the bromate plume contaminates the aquifer all digging must stop. This is a credible reality not just scare mongering.
As an active residents association, who have invested a significant amount of time and energy into investigating the bromate plume and into fighting previous applications of this source, we are strongly of the view that when the quarry application was originally considered in 2016, the true impact of the dangers posed by the bromate plume were not understood nor taken into account when the resolve to grant planning permission was agreed.
We do not believe that the potential serious consequences of disturbing the bromate plume have been weighted sufficiently in the decisions taken by the appropriate governing / regulatory bodies namely the Environment Agency, Hertfordshire County Council and Affinity Water. For these reasons then the proposed Brett quarry should be rejected.
The Council now has an opportunity to reconsider the cumulative impact on the area, potential for flooding, impact on the green belt and the risks associated with the plume and refuse this further application and therefore not put the public water source, health and well-being of Hatfield residents at risk and continue to subject Hatfield residents to another 30+ years of quarrying in this one, small area.
We ask are you, the council, prepared to let the fate of further contamination of our area with a known carcinogen be left in the hands of two private companies monitoring a water management plan, when if that fails it will be too late.
We ask you to reject the application.
Mike Hartung and Sue Meehan on behalf of
Ellenbrook Area Residents Association