Independent Examination of the Hampshire Portsmouth, Southampton, New Forest National Park & South Downs National Park Minerals and Waste Plan: Partial Update – Submission Plan (July 2024)

Statement by Fordingbridge Town Council

Introduction

The Town Council has previously objected to the inclusion of Midgham Farm as an allocated site within the Draft Plan both at Regulation 18 and 19 stages.

These objections are a matter of record and therefore the detailed comments are not repeated in this statement. The Town Council would however like to draw specific points to the attention of the Inspector as part of the current Examination.

Submissions

Due Process

The Inspector will be aware that at both Regulation 18 and 19 Consultation stages a substantial number of representations and objections were made to the County Council regarding the proposed allocation of the Midgham Farm site as part of the Draft Plan. A majority of these representations raised concerns / objections regarding the principle of allocating the site for development.

In the view of the Town Council the County Council has failed to follow due process in the consideration and assessment of these “in principle” objections and has had a closed mind. Contrary to the principles of the County Council’s Statement of Community Involvement there has been no objective consideration of the objections to the proposed allocation of the site for development. It is as if the principle of development is not to be considered and that all matters raised can be dealt with through the development management process.

This situation is reflected in the County Council’s published Reg 18 / Reg 19 Consultation Statements and the Town Council has been unable to identify any document that objectively considers or reviews the proposed allocation of the site in the light of the in principle objections raised.

It is a matter of record that the Town Council has previously made representation / complaint to the County Council that it considers that the decision to proceed to Regulation 19 Consultation was predetermined and that the published Executive Decision Record confirms that no other options were considered other than to agree the proposal to proceed to Reg 19 Consultation.

Detailed Comments

Nearby Bournemouth Airport

Midgham Farm lies within Bournemouth Airport’s Aerodrome Safeguarding Zone.

• Wildlife management: Prevents developments or activities that attract wildlife, such as landscaping schemes, cranes, and firework displays.

There will be a series of silt lagoons and freshwater lagoons constructed on the site. Wading birds will use silt lagoons and have been known to breed on them.

Ecology

Plants are affected by quarry dust both physically and chemically. Covering leaves limits light for photosynthesis, blocks stomata, and increases transpiration and water stress. Clay layers may contaminate local springs and the nearby ancient woodland. Natural England Technical Note TIN208 indicates that the entire site is in the Nutrient neutrality SSSI Catchment for the River Avon. There are sands and clays beneath the river terrace gravels, which connect to the floodplain. Leachates from the site must be avoided to prevent contamination. The effect on springs in the woodland needs more

study. Excavation may release soil nutrients and affect groundwater. Overall an unacceptable impact on the local environment that cannot be justified by the need for gravel extraction

Residents

Housing so close to this site contradicts the goals of the Hampshire Local Transport Plan (LTP4) and the Hampshire Vision 2050.

In addition to the 49 HGV movements a day from Bleak Hill, which is only 0.01 km away, 110 HGV movements from Midgham Farm will significantly reduce the air quality.

Hillbury Park is home to a large number of older residents. Some have existing lung conditions. Long-term exposure to NO2 and particulate matter (PM10 and PM2.5 affects a wide range of health conditions (lungs and Heart) This site is just metres away from their homes.

The bunds around the site will need to be assessed, as the height of 3 to 4 metres was found not to adequately control noise levels at Bleak Hill.

This is an unacceptable impact on residents that cannot be justified by the need for gravel extraction.

Several properties are near the proposed site. Can extraction occur near these properties without harming their foundations? We are surprised HCC suggests Midgham as an extraction site, as it is unsuitable. We worry about potential damage to third-party properties and believe no work should occur within 10 meters of these properties’ boundaries.

The nearest BGS borehole log is located south of the site at Northend Farm (BGS ref: SU11SW5), drilled in June 1976. Groundwater was found at 3. 4m, and bailing operations indicated potential instability in excavations below the water table, especially near property boundaries.

Using imported inert materials

There would need to be monitoring of the type of infill. The document provides no information about where the infill will come from. Infill material must be similar to gravel, or the site will flood more. We are concerned that there is much more gravel on the site than this study states. There may be more trucks visiting the site or an application for an extension of time.

We seriously doubt that the Sustainability (Incorporating Strategic Environmental Assessment) Environmental Report’s Objectives will be achievable.

There should be an Environmental Impact Assessment that includes the Greenhouse gases produced by all these extra diesel HGV movements. Not just at the site. Consideration should be given to impacts from carbon that is released from transporting waste around the country. Where is the infill coming from?