Downton Farm Gravel Works
Public Inquiry: 17th April

The Public Inquiry into the proposal to turn this local farm into a major gravel pit will open on 17 April at 10am at Lyndhurst Park Hotel.
There have been over 1200 letters of objection to this proposal. The proposal is also opposed by our MP, our District and County Councillors, and by NFDC, and has been rejected twice by Hampshire County Council.
The Parish Council remains firmly opposed to this proposal and we shall be explaining our reasons at the Inquiry.Our submission is set out below.
Proof of Evidence: Downton Manor Farm
1. My name is Bob Bishop. I am speaking on behalf of Milford-on-Sea Parish Council.
2. I wish to address:-
1. The proposal
2. The presentation and Assessment
3. The question of fairness
4. The consultation process on needs and sites, and Prematurity
The Proposal
3. When the Council and residents first learned of this application we were stunned that such a radical and far-reaching proposal could be made on green belt land beside the village without forewarning. Those who had bought properties in recent years certainly had no notification that such proposals were in the offing. The council unanimously opposes the application.
4. The site is an attractive green-belt farm close to the village and holiday park. The adjoining area is walked and enjoyed by many residents and visitors. It provides a very peaceful green environment. Nearby there are extensive public areas of stream and woodland including a SINC and ancient woodland managed in co-operation with the Forestry Commission. The area also sustains a wide variety of wildlife.
5. The proposal would involve:
The extraction and removal of 810,000 tons of sand and gravel;
The creation of a road, soil dumps and a 3 to 4 metre bund on the edge of the farm;
The movement of a 20 ton lorry every 10 minutes with a loading time of 5 minutes;
The use of dump trucks, bulldozers, generators and possibly floodlighting;
The importation of very large quantities of waste.
6. This would inevitably cause unacceptable disturbance to residents and visitors.
7. The proposal fails to meet the criteria in Policy 7 of the current plan because :
It would not have due regard to residential and other properties;
It would generate an unacceptable traffic impact;
It would not safeguard the character and amenities of neighbouring settlements;
It would damage a decent quality farm;
It would not protect the very sensitive and important habitat;
It may well have an adverse impact on sensitive local watercourses.
The Presentation and Assessment
8. The Inquiry is being asked by the Applicant to believe that the disturbance will end in 7 years; that the site will be restored and the bund will be removed.
9. But we all know that this is not the intention. The applicant is currently pressing extremely hard to have the entire farm ( and indeed an adjacent farm) identified as a preferred site. If the applicant succeeded, the works and thus the adverse impact on the greenbelt and on the village would last for very many years.
10. It therefore seems reasonable to ask that the Application is not viewed in isolation. For example, the bunding is proposed at the edge of the farm; this would maximise the noise impact (Page 17 of Noise Assessment) and minimise the noise attenuation (see NFDC letter of 4 October 2004 and Applicant's expert's letter of 10 December 2004). The siting of the bund has no merit in this application; it is simply seeking to anticipate a further application.
11. As presented the scope of the current Application is clearly contrived and disingenuous.
12. There are also critical elements of the Application that are contradictory and misleading. The Applicant's noise assessment (conclusions) makes it clear that there will be noise from the site, particularly relating to bund building and the large soil dumps. It acknowledges that there will be noise from the gravel workings, but suggests that will not be significant. It is therefore misleading for the Applicant to assert (non-technical summary - paragraph 4) that the gravel workings will not be heard in any way.
13. Furthermore, even the statement asserting there will not be significant noise relies on ignoring the current low noise levels "typically 34 to 44 DBL". The assessment dismisses these actual low levels of background noise and suggests instead pretending the background noise levels are higher so that the increase in noise can somehow be discounted.
14. The plain fact is that , in this very quiet area, noise from lorries and their loading and unloading, and extensive earthmoving by bulldozers will be considerably greater than the occasional noise from the farm tractor which is currently heard.
15. We also find the Applicant's assertions concerning the likely impact on Shorefields unconvincing. Given the nature of the Park, its setting, and the visitors it attracts, we consider the threat to Shorefield is real. Many of our shops and other businesses rely heavily on spend generated by Shorefield owners and visitors; any downturn would be very serious.
16. The Appeal statement contains the Applicant's views on some of the many letters of objection from residents, businesses, visitors and employees of Shorefield. The Applicant seeks to diminish these letters. In our view it would be quite wrong to do so; the letters express genuine and strongly held concerns that have also been voiced at Parish meetings and in continuing widespread public support for DAMAGE.
17. And there is a significant difference between these detailed objections and those letters of support generated by the Applicant, predominantly from contractors and hauliers. The objections directly address the many contentious issues relating to this site. In contrast the supporters' concerns can be met by sourcing supplies from other far less damaging sites.
The question of fairness
18. There is, of course, an expectation that any radical planning proposal will be subject to due process; an expectation of fairness. That expectation has been sorely tested in the last three years as we have faced varying assessments, a re-application, an invitation to comment on the emerging Plan, and now this Appeal.
19. Given the fundamental nature of an Application to transform a greenbelt farm into a gravel pit it seemed reasonable to expect a process that was open and rigorous and would consider both future needs and, crucially, compare all possible future sites.
Without that comparative assessment there can be no sense of fairness.
20. Many local people were therefore stunned not just by the making of this Application, but by its terms. We were invited by the Applicant to believe that it was "imperative" to agree a new site quickly and that there was no alternative to Downton. We were relieved therefore to learn that there were rules against which the Application would be judged; that there was an alternative site at, Plumley Wood; and that Plumley Wood could not be dismissed, as the Applicant had sought to do, by stating, " This deposit, if granted, will replace Nea Farm but only in the long term."
21. We also noted that the Application did not meet the criteria in Policy 20 of the current Plan. It has certainly never been demonstrated that extraction at Downton would be equally acceptable to working the preferred area at Plumley Wood as required by Policy 20(I)(b).
The consultation process on needs and sites, and Prematurity
22. Over the last 2 years or so the Parish has received various documents dealing with future needs and sites including:
Statement of Community Involvement
The Strategy Issues and Preferred Options
Scoping Report
Consultation Statement
Strategy
23. We have been assured that this is an open and objective process in which all respondents will be treated fairly; and all potential future sites will be assessed on their merits against common criteria.
24. HCC have also arranged a series of County-wide workshops. . Their invitation letter for the New Forest South workshop explained that while the Strategy "does not identify an additional need for new quarries or landfill beyond the existing or preferred areas "an evaluation of potential sites was necessary. The workshop was well attended and the Parish council has responded in detail. We understand that a list of "preferred options" will be published in October and further comments invited.
25. The Parish Council are glad to contribute to this process; it is the only way to deal with these controversial matters fairly.
26. It is essential to allow this process to continue without it being pre-empted for two reasons:-
i. first the Inspector who is about to decide the new Plan may well agree there is no need to identify new quarries beyond existing preferred areas;
ii. even if the Plan required further sites these should be chosen in line with the Strategy's methodology (Appendix 2) and not on the basis of isolated applications.
27. It is therefore difficult to imagine a case that we would more fully meet the grounds for prematurely as set out in the Department's General Principles.
Conclusion
28. The Application falls at the first hurdle; there is no need further sites at this time. The proposal fails to meet any of the conditions in Policy 20.
29. The new Plan is about to be determined. That will decide the question of need. The Application is plainly "Premature", as defined in the Department's General Principles.
30. A process is also already underway to ensure that all potential future sites that may be needed are properly assessed on their relative merits and in a comprehensive manner. There is no case for side-stepping that process. Indeed, given the clear precedent that would be set in this area, this proposal would drive a coach and horses through that process.
31. The Application is also flawed on its merits when judged against Policy 7.
The proposed activity would be clearly incompatible alongside residential properties, holiday homes and a greenbelt area of high amenity. In addition, there are strong concerns at the likely adverse effects on our major local employer and the spend generated by our visitors which is so essential for the economic health of our village businesses.
32. We therefore urge the Inspector to recommend against this Application.
R T Bishop
Vice-Chairman Milford on Sea Parish Council
15 March 2007