Consultation short version

Summary of EARA response to the planning application to quarry on Ellenbrook Fields (Hatfield Aerodrome) – January 2023

Planning Application Ref No PL/0232/21 Land at Hatfield Aerodrome, Off Hatfield Road

We would like to start with affirming our resident’s association strong objection to the quarry application. We objected to the original 2016 application and the site’s inclusion in the mineral plan and continue to object to this latest application.

We do not believe that the changes made to this 2021 application, following the previous application (5/0394-16) being dismissed by Hertfordshire County Council, and at the Appeal Inquiry, are sufficient to warrant its approval.  

We also object to the time period that has been allowed for consultation, by effectively running this over the Christmas / New Year period this has substantially reduced the time available to volunteers to provide objections.

As a residents group who were a Rule 6 participant in the recent Planning Inquiry against the previous application to quarry on this site we, along with the vast if not entire local community, continue to believe that this site is not appropriate for mineral extraction and that its inclusion in the Mineral Plan is inappropriate.

We also maintain that the known AND unknown risks associated with the bromate plume should make this application too high a risk for the County and residents of Hatfield. 

We believe that the Ellenbrook Fields fragile Green Belt in between St Albans and Hatfield should be protected and is not appropriate for mineral extraction.

Hertfordshire County Council appear to be making the target of providing gravel the most important factor in their decision making rather than the other factors involved including consideration of viable alternatives.

We believe that all the questions raised as part of the planning inquiry have not been fully answered / resolved in the Brett 2021 application and therefore the decision taken to reject the original 2016 application by HCC and the subsequent appeal dismissal by the Planning Inspector applies to this more recent 2021 application.

We strongly object to the quarry application for the following reasons:

Cumulative impact on the area

  • We believe that there is an unfair concentration of mineral works in one small area of the county.
  • This small area of Hertfordshire has already had quarrying for more than 40 years. This application will extend the quarrying for at least another 36 years meaning that this area will have been subjected to quarrying for over 70 years. This is a lifetime for most of us 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 so many quarry sites in one small part of Hatfield has been fairly assessed as part of the planning process and should be reconsidered.
  • 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.  
  • This additional HGV traffic will also be on top of recent local developments that have generated additional 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 174 vehicle movements a day, associated with this proposal, will only exacerbate these issues.
  • The A1057 is extremely vulnerable to minor changes / incidents occurring on this and surrounding roads. Recent minor roadworks by Wickes have caused major issues at the Smallford Roundabout, with traffic regularly queueing back to the Comet Roundabout and journeys from Ellenbrook to Oakland College entrance taking circa 1 hour. We believe that this is evidence that the road has reached capacity and is therefore vulnerable to major congestion when other changes are introduced.
  • 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 Ellenbrook Fields. This particular 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 if not cease operations all together.
  • The quarry is very close to residential development and the University of Hertfordshire.
  • It encloses Popefield Farm on three sides, comprising three Grade II listed buildings (45 metres away)
    • It is alongside The University of Hertfordshire sports facilities (5-10 metres away)
    • It is opposite residential properties along the A1057 at Poplar Close, St Albans Road West and Bramble Road (400 metres away)
    • It is adjacent to Jove Gardens green space (15 metres away)
    • It is adjacent to Lawrence Close green space (15 metres away)

The University of Hertfordshire sports facilities will be a mere 5 metres away from the active quarry workings. This is not acceptable.

Green Belt & the Country Park

  • Ellenbrook Fields as a country park was promised to residents under a Section 106 agreement, which despite over 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. This is a totally unacceptable position.
  • Ellenbrook Fields is a unique, irreplaceable valuable resource for the community that promotes health and well-being for residents. It is part of Hatfield’s green belt with meadow and grazing land, owls, butterflies, newts, and wildflowers.  It is used extensively by dog walkers, cyclists and recent surveys undertaken by local residents have shown the extent of use of the Park.
  • There is no alternative to this location in the area if the quarry goes ahead and the quarry will effectively destroy the green belt between Hatfield and St Albans for the next 30+ years.
  • The plant area of the quarry operation remains huge even without the concrete batching plant, it will be unsightly, in place for 40 years, and will be right in the north of the park next to proposed walkways.

This does not seem to support the principle of preserving openness of Ellenbrook Fields during any mineral extraction.

Pollution & the Bromate Plume – risk to health

  • 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.
  • Bromate is a known carcinogen, but very little research is available to understand the health implications for the local population. Potential exposure to this deadly product is an unacceptable risk for residents.
  • This bromate plume is cited as the largest known bromate contamination in Europe.
  • The proposed quarry site is right next to the bromate plume. We strongly object to such a high-risk operation taking place so close to the plume and cannot understand why, seemingly by default, this application continues to be pursued by the planning authorities despite the evidence of risk to our water supplies by contamination from the plume.
  • The Environment Agency have been fully involved in the remediation plan to deal with the bromate plume, yet despite this, after over 10 years of remediation work the plume shows little sign of abatement and continues to travel across Hertfordshire. This is of major concern to local residents. We have asked the Environment Agency for up to date information regarding the plume but have not yet received any and are therefore unable to analyse the current position in time for this submission.  
  • The Inspectors Inquiry report clearly outlined the ongoing issues with the bromate plume remediation.

There are some very important points to extract from the Inspectors comments.

  • Firstly that prior to the Inquiry Brett had proposed to pump the LMH, without any objection from the EA. It became clear during the Inquiry, and agreed by all the hydrogeology experts that this was not an appropriate way to quarry this area and it was agreed that the original method of pumping water from the LMH to remove sand and gravel finds shall cease. This fundamental change to quarrying this area does not give us confidence that the whole plan is a safe one given that prior to the inquiry Brett and the Environment Agency had both approved the previous method of extraction.
  • Secondly it was agreed by the Inspector that the current borehole monitoring, again as proposed by Brett and agreed by the EA, was inadequate in terms of defining the extent of the bromate pollution. Although Brett have now agreed to install new monitoring boreholes prior to commencement of quarrying, this again does not give us confidence in the system. As a minimum this application should if not rejected be shelved until such additional monitoring has occurred and analysed by independent experts.
  • Thirdly although the Inspector is of the view that planning conditions can reduce the risk caused by the bromate plume, he also said the actions plans must include explicit provision for the cessation of excavation in the LMH if there was evidence that it was interfering with the remediation of the bromate pollution. In these circumstances it would be necessary for this cessation to endure for the lifetime of the development unless the Mineral Planning Authority determined that compelling evidence demonstrated that excavation in the LMH could resume without any adverse effect on the remediation of the bromate pollution.

This demonstrates just how serious a risk the bromate presents and reinforces our view that a zero risk approach should be taken with the bromate and that no quarrying should be allowed in the site until the bromate has been eradicated. The plume is an unknown phenomenon that no one can predict and therefore no risks should be taken.

  • We do not believe that the water management plan (as agreed between the applicant and Hertfordshire County Council to manage any issues with the bromate plume) provides sufficient safeguards to deal with the risks of either cross contaminating the upper and lower mineral aquifers or the possible impact on the lateral movement of the plume. We believe that the approach 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 be relying on a ground water management plan which will alert everyone when the damage has been done. If things do go wrong, they cannot be put right. This potential risk is too serious to ignore. 
  • Our community are very concerned about the potential grave health issues that the local population may have been exposed to prior to the plumes discovery in early 2000. We are disturbed that the possible impact on our health was kept quiet at the time of discovery, following the realisation that bromate in excess of the WHO guidelines had for an unknown period been released into the water actually supplied to the public, possibly since the chemical works opened in the 1950s and until the factory ceased operations. 
  • We remain concerned that no known official investigation into the harm this may have caused to the general public has been instigated, or made public, and that no health monitoring surveys appear to be in place or again been made public.

Public Water Sources

  • We are really concerned that the quarry may have potentially catastrophic effects on the 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.
  • Our contention is not necessarily that the bromate pollution plume has already contaminated the dig site, but 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.
  • 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.
  • We also accept that the applicant will monitor the area for bromate but once detected it is too late; the bromate can take centuries to naturally dissipate.
  • The hot summer of 2022 has resulted in a number of water companies having to introduce hosepipe bans and the issue of water scarcity in the future has been highlighted time and again during 2022. We find it difficult to believe that the Environment Agency and Affinity Water are willing to take a risk by not objecting to the quarry when it could contaminate huge quantities of source water, the slightest risk to this valuable commodity should not be taken.
  • To reiterate our concerns, to put our water supply at any risk seems to be a highly dangerous strategy.

Access to the site and traffic movements

  • The new application proposes moving the entrance to the site in an easterly direction 5m along A1057. We do not believe that this makes any difference to the safety of the entrance.
  • We believe that this concentration of works in one area will have a major impact on the traffic movements in the area, particularly on the A1057 St Albans Road West as both the Cemex and Brett quarries will be using the same road network.  Cemex currently have permission to utilise 300 vehicle movements a day for the existing quarry operation and the Furze Field site. Once you add the proposed Brett 174 lorry movements per day, that makes a total of 464 per day, equivalent to one lorry every 85 seconds. Given that it is unlikely that lorry movements will be evenly spaced out during the day one can see that during some time periods there will be lorry movements every few seconds. 
  • 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 174 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.
  • Recent road works in the last few weeks have proved this theory, causing traffic in the morning at the Smallford roundabout to be queued back to the Comet 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 do not accept the Highways view that it should be safe if all the ancient trees and hedgerow are removed and clear vision granted. This unacceptable destruction of the foliage will forever change the rural appearance of this street and area into a commercial zone. The recent destruction of trees and foliage at the entrance to the Smallford Works on Station Road highlights how a pleasant tree lined view has been decimated.

Heritage Assets

  • Popefield Farm has three Grade II listed buildings which have all been fully restored over recent years.
  • The Inspectors report identified that due to the proximity of the excavation / infill operation to Popefield that there could be enduring, adverse effect of the residents of Popefeld Farm, in particular the noise from vehicles working on the site, and that this effect will occur over an extended period of time due to the fact that the phased work will surround Popefield Farm for nearly all of the 40 years.
  • The farm will be bordered on three sides by four phases of quarrying activity, so are going to be affected by the quarrying and restoration activity for most of the duration of the quarry. The report produced on behalf of Brett implies that Popefield Farm is effectively screened from the effects of quarrying by bunds, the existing trees and proposed new planting but having a quarrying operation around Popefield Farm for almost the entire duration of the extraction will no doubt have a detrimental effect on the daily life of the residents. 

Character and Appearance

  • We believe that that area will not be able to function as an attractive country park during the decades of quarrying.
  • We do not believe that the new scheme, even without the Concrete Batching Plant (excluded from the 2021 application), would not include intrusive features that would have a serious detrimental effect on the enjoyment of the country park.
  • The new entrance on A1057, large enough to accommodate lorries, will have a serious adverse effect on the visual landscape. One only has to look at the entrance to the nearby Smallford Works to get some idea of how an entrance area can be ruined. 
  • The Inspector is very clear that in his view the 2016 scheme would have an adverse effect on the character and appearance of the area of moderate/substantial significance. We do not believe that the 2021 proposal provides significant differences to alter this view.

Public access to the park during its lifetime and engagement with the community

  • The Inspectors report is clear that it is important that there are attractive, safe walking routes to be available throughout the lifetime of the quarry.

HCC have made it clear that engagement with the local community is important.

There has been no contact made with residents groups since the Inquiry to discuss their concerns. A leaflet drop years ago (pre Inquiry) and a website do not constitute engagement.

Colney Heath Parish Council and the Residents Associations have undertaken surveys of usage of the park during Dec 22 / Jan 23 which clearly show the high level of usage and main routes followed around the park, even during inclement weather conditions.

The map below taken from Brett’s response to the HCC Reg 25 letter gives an example of just how unattractive the proposed routes around the site will be.

For Ellenbrook residents their main walking route during Phase B will predominately border the A1057, alongside the access road, with a circular route around the plant site. This is not exactly in keeping with a peaceful walk around a country park.

Our view on the proposed routes is:

  • They have been designed with zero input from local residents, Rule 6 parties and the existing user base.
  • There has been no consideration of the “attractiveness” of the proposed routes, contrary to the Inspectors report and the HCC Reg25 letter
  • They run along the A1057, a busy main road and therefore noisy, subject to car / lorry fumes, definitely unattractive
  • They are close to the plant area and therefore will be noisy and dusty, and definitely unattractive
  • They run alongside the access road into the site, close to lorry noise and fumes,  and definitely be unattractive
  • There is no mention of any access for disabled users

This is not an acceptable public access strategy.