Team Lopez - Julia Lopez MP has written to residents who have sought contact about Brett Aggregate's proposals for sand and gravel extraction at Rainham Lodge Farm.
Julia's comments
I am writing following our recent correspondence about Brett Aggregate’s proposals for sand and gravel extraction at Rainham Lodge Farm. I apologise for the time it has taken for this update to reach you, but we have only just received a detailed response to our questions from Brett.
The Planning Director of their proposals, Mr Treacy, has suggested that if a particular home or property owner has specific concerns relating to their property, they should contact Brett directly at [email protected] or via the contact section of their website - www.rainhamquarry.co.uk/contact-us
I had highlighted a number of concerns that residents had raised with me directly to Brett, focussing on air quality, residential areas, green amenities and the local road network.
In terms of air quality, I asked Brett about the particulate Respirable Crystalline Silica (RCS), including whether their proposals would impact the NHS St George’s Health and Wellbeing Hub that is currently under construction, and sought further information on the monitoring equipment Brett would use to measure changes in air quality. The response I received to these questions is pasted below:
AIR QUALITY
Assessing impacts on air quality
A detailed air quality assessment in line with Air Quality Standards Regulations (among other legislation and policy) has been carried out as part of the development of our planning application to date and the findings of the assessment were shared at our recent public consultation.
The assessment considered current air quality and potential impacts from the proposal at a number of locations (‘receptors’) around the site and along proposed vehicle routes, taking into account local meteorological conditions such as wind speed and direction. The area that covers Hacton Park Corner Farm was included within this air quality assessment along with Bushells Way and Suttons Lane that would incorporate the area around the planned St George’s Health and Wellbeing Hub.
The study, which looked at the potential for finer particles of material to become airborne, as well as emissions from the proposed activities, in accordance with technical guidance, found that there would be negligible impact on air quality. With regards to ‘particulate’ matter (PM10), levels are expected to remain well within PM10 limit values and the assessment concludes that there would be little chance of the site causing any exceedance of PM10 limits.
In terms of Respirable Crystalline Silica (RCS) it is widely accepted that any risk in relation to quarries is generally confined to the use of machinery inside buildings where silica dust is contained and could be a risk for employees if not correctly managed. As we are not proposing processes at Rainham Lodge Farm that could give rise to such conditions, the risk of generating RCS at Rainham Lodge Farm is low.
Monitoring air quality
As part of any planning application Brett would submit a detailed Dust Management Plan which would detail the site mitigation measures to be put in place as identified within the air quality assessment carried out and in line with industry standards/best practice. If planning permission is granted, we would expect this Dust Management Plan and the monitoring of it, to be a requirement of a planning condition.
In terms of residential areas, I asked Brett to set out whether reassurance can be provided to nearby homes about the environmental impact, whether compensation would be considered to nearby houses, and whether Brett would invite further feedback from the community if it delayed its application. The response to these queries is pasted below:
RESIDENTIAL AREAS
As previously shared at the public consultation and on our dedicated website (see details below) we have conducted a number of detailed assessments covering all potential impacts on air quality, noise and transport as part of the planning application and accompanying environmental statement. Accompanying these reports are measures to be taken to protect the amenities of local residents, which combined with the temporary and progressive nature of the proposal, means we do not anticipate any significant detrimental impacts on our neighbours.
We are very grateful for the additional local feedback we have received during the pre-application public consultation and are carrying out further studies to explore how we can improve some aspects of our proposals to take into account the issues raised. We encourage members of the community to continue to give us feedback and comments directly via the website which we will continue to consider.
Additionally, Brett is currently undertaking further pre-application consultation with stakeholders including Thames Chase Trust, Essex Wildlife Trust and Havering Borough. Any amendments to the proposal which come from these consultations will be uploaded to the planning application website https://www.rainhamquarry.co.uk.
All the feedback from consultation, together with the various assessments and reports will form part of our planning application so that the planning authority has the information necessary to make an informed decision on the proposal, The development would only be allowed to progress on the basis of Brett demonstrating that any impacts will be at acceptable levels.
Given that I have not received a response about compensation, I will be following this up with Brett for further comment.
In terms of green amenities, I sought Brett’s comments on whether compensation will be made for any loss of access to green spaces, further information on whether the proposals will impact Hornchurch Country Park, Berwick Glades and Ingrebourne Valley, and what measures will be introduced to prevent any negative impact on local wildlife populations and habitats. The response is pasted below:
GREEN AMENITIES, POTENTIAL IMPACTS AND PUBLIC ACCESS TO LOCAL GREEN SPACES
The proposed development, as part of the Ingrebourne Valley, has been carefully designed so that there would not be a negative impact on local areas such as Hornchurch Country Park and Berwick Glades, but that there would be a positive contribution towards public access, nature conservation and increased biodiversity.
The planning application will be accompanied by a comprehensive Ecological Assessment which will describe how the protection of and improvement to, habitat used by Protected Species, will form part of a scheme that provides an overall benefit, i.e. a net gain, to local biodiversity.
The proposed development will not result in the loss of public access to green spaces. As work progresses temporary changes to current public access will be made by providing alternative access arrangements, however, there will be an overall improvement in access as the land is restored. Details of this are currently being discussed, with the Thames Chase Trust and Essex Wildlife Trust for example, including how the restored site will integrate with nearby green amenities.
I will be following up with Brett on how they expect their proposals to ensure biodiversity net gain and that access to green space will be maintained.
Finally, I had asked Brett if they would consider improvements to local highways in order to support additional vehicles, how will any significant increase in traffic be managed, how safety will be ensured, and what measures will be implemented to ensure material runoff is prevented. Brett’s response is as follows:
LOCAL ROAD NETWORK
We received a great deal of feedback on traffic movements, both in terms of Brett vehicles and other road users, and detailed consideration is currently being given to vehicle numbers, spread of vehicles throughout operational hours, routing and road improvements. Once a draft scheme has been prepared this will be shared initially with the Highways Authority before the updated scheme is placed on our website when the planning application is made.
We will keep local roads clear of material runoff by having surfaced access roads and wheel cleaning facilities at both the extraction and plant site ends of the vehicle route, to prevent mud or debris being tracked on to the highway. All HGV’s will also be sheeted to prevent spillage. As and when necessary, this measure will be supplemented by the use of a road sweeper.
I apologise for the length of this update, but I wanted to ensure that the response I received from Brett to residents’ questions is properly shared with you. I am waiting for a further response from Havering Council, which I will share with you as soon as it becomes available.
Finally, I wish to reiterate that this matter will ultimately be determined by way of a planning decision - a process over which I have no jurisdiction as the final decision will be taken by those elected councillors who sit on the relevant Havering Council planning committee. However, I have and will continue to make the community's concerns known to both Brett and Havering Council, and I would strongly encourage you to write to your local ward councillors and the Leader of the Council to raise your concerns directly so that they can be reflected upon when the Council is determining any planning application by Brett. You may also wish to sign the local petition organised by the Hornchurch & Upminster Conservative Association, which I imagine will also be shared with the relevant planning committee councillors should an application eventually be put forward for their determination.
I wish you and your loved ones a very happy Christmas and New Year.
With kind regards,
Julia