Cemex Planning Application

Hound Parish Council members have objected to the Cemex planning application HCC/2021/0787 which refers to the proposed gravel extraction site on Hamble Airfield.

​The objection has been raised regarding traffic, air quality and ecology.

Transport

• Transport assessment Volume 2 Chapter 13 Table 13.2 states Hamble Lane north of Hound Road is a 30mph limit - it is actually 40mph with shared pedestrian and cycle path next to the road without any physical barrier - the only barrier are plastic uprights which have become flattened over time indicating that vehicles have mounted the pavement over time. This pathway becomes very congested at the start and end of school hours, and there is little available space for both pedestrians and cyclists; thus cyclists will often use the road. As CEMEX has mis-represented the speed limit, they will have mis-represented the impact that additional HGVs will have on pedestrians and cyclists within this area and sensitivity of the receptors - they state the Link Sensitivity is “low” due to this error - this needs to be reassessed in view of the incorrect speed limit used. The speed of HGVs travelling alongside large groups of schoolchildren walking to school during the period of highest volume of HGV movements is highly likely to be at the 40mph speed limit along this stretch of road. 
• From the transport report - there is predicted to be an HGV movement every 2.3 minutes between 07.00 until 08.00 for 5 years between years 3-7. There will be a slightly smaller peak of HGV movements between 14.00 and 15.00. This is when large numbers of people will be travelling along Hamble Lane by car to get to work, and the majority of pedestrians and cyclists travel along Hamble Lane to get to school (morning peak found to be between 07.30 and 08.30 particularly north of Portsmouth Road). CEMEX have noted that the impact of HGV movements will fall into the “major” magnitude category during the morning peak - they state this will have a maximum impact on 2-way HGV flows on the local highway network of 127.3% in the morning peak during phase 2, and 87.8% (moderate) during the morning peak in phases 1 and 3. I do not accept that putting forward contributions to improvements to Hamble Lane to make walking and cycling more attractive will have an effect as I believe the majority of users travelling along Hamble Lane during the morning peak are commuting to and from work, and that cycling is not necessarily a viable option for them to travel. 
• “Fear and Intimidation” threshold from the IEMA - “Extreme” is noted to be average speeds over 18 hr day - “Extreme” degree of hazard is noted to be 20+ mph - the part of Hamble Lane north of the proposed development between the Hound Road roundabout and Mallards Road, where lots of children walk along the shared cycle path/footpath to and from school at the time when there will be the maximum number of HGV movements is 40mph limit. The poorly maintained pavement which is commonly overgrown with brambles resulting in narrowing the pavement is next to the southbound traffic, which will have the highest speeds at this time of the day. I therefore do not accept that the proposed development will not have a material impact in terms of fear and safety. There’s a high likelihood that parents will decide to drive their children into Hamble School rather than allowing them to walk along Hamble Lane from Bursledon next to high volumes of HGV traffic, travelling at speed and thus increasing the load of traffic on the road and congestion. High likelihood of people reverting back to travelling by cars along Hamble Lane rather than attempting to travel by foot or bike, again increasing the load of cars on the road. 
• “Dirt and Dust” - the transport assessment suggests that problems with dirt and dust can occur up to 50m for the road. Children and pedestrians using the road to travel to and from school during the peak time when the maximum HGVs are proposed to be using the road will be affected by this. 
• Cycling and walking - I do not agree that the infrastructure for cyclists is adequate along the entirety of Hamble Lane to Windhover Roundabout despite being identified as a key walking and cycling route. 
• The proposed development has been shown to drive Providence Hill junction onto the Windhover Roundabout over capacity during the morning peak of traffic, which will result in unacceptable delays. 
• The walking, cycling and horse-riding survey data suggests the majority of pedestrian and cycle movements on Hamble Lane are northbound during the morning peak and southbound during the evening peak. This does not fit with my lived experience where large numbers of young people travel along Hamble Lane from Netley and Bursledon to Hamble School in the morning and back along Hamble Lane to Netley and Bursledon in the evening. They will be in close proximity to the peak of the HGV movements.  

Air pollution
I do not feel that Cemex’s reply has adequately addressed my previous concerns regarding air pollution and dust created by the proposed development, so my previous concerns below still stand.

• Eastleigh ranked 250 out of 317 local authorities for background concentrations of PM2.5 in 2018 and 2019 with background levels of 10.6µg/m3. These existing background levels are already deemed to be dangerous and in breach of WHO limits of average annual limit of 5 µg/m3 (Taskforce for Lung Health). The current application by CEMEX has an objective of an annual mean PM2.5 of 25µg/m3, which is significantly higher than the WHO recommended limits.
• There is likely to be a very high risk to local residents’ health from airborne dust containing crystalline silica, which is known to lead to an increased risk of silicosis and lung cancer. Silicosis is deemed to usually develop after being exposed to silica for 10-20 years, although it can sometimes develop after 5-10 years of exposure. Occasionally, it can occur after only a few months of very heavy exposure. The main symptoms of silicosis are: a persistent cough, shortness of breath, weakness and tiredness, and can ultimately be fatal. Silicosis can increase the risk of developing other health conditions such as chest infections, heart failure, arthritis, kidney disease, Chronic Obstructive Pulmonary Disease (COPD) and lung cancer. 
• There are regulations and limits set for workplace exposure to dust containing crystalline silica. These limits are taken over an 8hr period. The “All Party Parliamentary Group for Respiratory Health - Silica - The next asbestos” noted that the “regulation is currently ineffective” regarding exposure limits and recommended halving the limits to exposure. But the majority of quarries which exist in the UK are not directly next to schools where the school children will potentially be exposed to these harmful contaminants on a daily basis with no Personal Protective Equipment over a 6 hour period, and residential properties where the residents will be exposed over the entire 24 hour period with no Personal Protective Equipment. She is extremely concerned about the long-term effect of having a gravel extraction plant immediately next door to the school and residential properties, which will put these people in particular but also the whole population on the entire peninsula at an unacceptably high risk to their health as small particulates are known to be blown and travel long distances. 
• The current plan from CEMEX proposes that they use water suppression only on prolonged dry weather and/or high winds, or if visible dust is generated. However, silica dust particles are invisible to the naked eye in normal light, so high concentrations can be inhaled without the worker being aware of it. Thus, if the proposed mitigations against air pollution from silica dust rely on workers being able to see the dust generated before using water suppression, they will be entirely ineffective in preventing and transmission of silica dust particles. 
• Relying on rainy weather will not help - It is known that there is an average of between 8 and 12 rainy days per month in Hamble, leaving between 221 and 269 dry days in the year when the local population will be at risk of inhaling crystalline silica dust, and so at long term risk of silicosis and lung cancer. 
• The “All Party Parliamentary Group for Respiratory Health - Silica - The next asbestos” noted that the “regulation is currently ineffective” regarding exposure limits. Respirable Crystalline Silica is noted in this document to be most toxic when it is freshly fractured, ie: when it has been freshly mined. It was noted that exposure to Respirable Crystalline Silica occurs beyond the task of drilling or cutting, and can remain airborne after the task, to be released later when disturbed from clothes or in leaks or spillages. The “All Party Parliamentary Group for Respiratory Health - Silica - The next asbestos” has recommended methods of designing out exposure to Respirable Crystalline Silica should be used to reduce risk - the best and most appropriate way of designing out exposure in this situation is to not have the gravel extraction plant directly next to schools and residential properties. 

Ecology
CURRENT ECOLOGY
Ecology currently onsite -
Currently lowland acid grassland with widespread shrubbery across the entire site, with scattered trees (semi-mature oak, english elm, silver birch, ash, whitebeam) mostly in the southern half of the site. 

Reptiles
Grassland and scrub mosaic, hedgerows and woodland noted in Ecology survey to be suitable habitat for protected species including slow worm and common lizard. Most recent survey reports a good population of slow-worm and low population of common lizards, but assumes populations of both could potentially be exceptional. Noted to provide a very substantial area of grassland and scrub mosaic highly suitable for these species. 
Grassland management following restoration is intended to enhance foraging opportunities and basking sites for reptiles. Site considered to be of Regional Value for slow worm and common lizard.

Mammals
Hazel Dormouse - ecology survey noted no dormouse records within 2km of site - However, recent dormouse nests have been found in Westwood last year. 

Hedgehogs - known to be classified as Vulnerable to extinction and subject of significant conservation efforts, reports that desk study shows 19 records of hedgehog within 2km of site - anecdotally, we all know there are many sightings of hedgehogs within Hamble and Netley, so it is extremely likely to be many hedgehogs on site.

Invertebrates
3 x S41 Priority Species, 1 Nationally Rare species, 9 Nationally Scarce species, 1 Vulnerable species, 1 Rare species, and 7 Nationally Scarce - Notable species. Ecology survey noted favourable site habitat for these species was Scrub edge, Scrub heath and moorland, and Open short sward. 

Birds 
17 species confirmed as breeding onsite, including bird species of national conservation concern - skylark, linnet, song thrush (all Red listed), dunnock, common whitethroat (both Amber listed). Further species breeding on-site include Amber-listed Willow Warbler and Stock Dove. Protected species Dartford Warbler recorded on site 2017, and seen and photographed nearby in 2021. Site identified as being of value for species of conservation concern including kestrel, green woodpecker, mistle thrush, dunnock, bullfinch, house sparrow, starling, song thrush, redwing and marsh tit. Site identified as being of ornithological interest and value. Site identified to be of substantial value for overwintering flocks of nationally declining farmland bird species - skylark, linnet and meadow pipit.
Red listed Spotted Flycatcher and amber listed Green Woodpecker, House Martin, Swallow and Long-eared Owl were recorded during 2020 surveys.
Flocks of starling, meadow pipit, as well as linnet and skylarks were recorded within the more open grassland sections of the site, indicating the importance of maintaining and protecting these areas of open grassland for these Red listed birds which are known to be declining in Hampshire and nationally. 

DURING RESTORATION

From Outline Landscape restoration - planning on using Glycosulphate to spray areas to reduce weeds prior to replanting. Glycosulphate is a non-selective herbicide noted by the International Agency for Research on Cancer to be “probably carcinogenic” in 2015. Some research suggests it may persist in the soil for up to a year, with some residues up to 3 years. . It has been found to potentially destroy beneficial soil microorganisms and affect earthworms. It is only approved for use for another 2 years in the UK. 

AFTER RESTORATION

Following restoration, planned to have community area in very north of site with 20 year management plan, area of woodland and grassed area with 10 year management plan in north of site (coincidentally the area highlighted as a “Countryside Gap”), with grassed area only in south half of site with 5 year management plan which will be managed with grazing or mowing. 39.019Ha rough acid grassland to be recreated (previously ?64Ha) - “re-establishing existing rough grassland with new field edge woodlands and scrub blocks habitat for reptiles and ground nesting birds, managed by regular grazing” - this appears to take up the larger part of the total area of the plot, and the claim is that this area will be 
contributing to a large part of improving the biodiversity following extraction - “to provide a valuable habitat resource for the important fauna, including badger, foraging and commuting bats, ground-nesting birds, wintering birds, hedgehog, invertebrates and reptiles”. Therefore, this contribution to the improvement in biodiversity needs to be guaranteed and protected for longer than the proposed 5 years. 

Biodiversity net gain calculated as being at 10.56%. Environment Act 2021 - all planning permissions need to deliver at least 10% net gain. This net gain across the entire site needs to be protected - Natural England states that this net gain should be secured for at least 30 years via obligations/conservation covenants (as stated in Cemex’s no 10 Ecology survey).
There are species on site that are covered by Biodiversity Action Plans (BAPs) - policy for protecting and restoring priority species and habitats - important for Skylark (open habitat, currently 19 territories mostly recorded in the north of the site - planned to become more woodland habitat), Linnet (less dense scrub, currently 4 territories mostly in north of site, designed to become more woodland habitat), House Sparrow, Dunnock (scrub), Bullfinch, Starling, Song Thrush. As most of the territories of the Skylark and Linnet are in the north park of the site, by changing this north part of the site into a more wooded area, this is likely to adversely affect these Red listed bird species of national conservation concern. The current restoration plan does not appear to adequately protect these species under BAPs as the replacement habitats does not match the habitats and territories currently established by these species - ie territories in open grassland are being replaced by broadleaved woodland, and there will be a permanent loss of approx 15.3Ha of existing scrub habitat on site, with the ecology survey suggesting that the magnitude of effect of losing this scrub will be “Moderate”.

Trees
Planned to be a loss of approx 0.026 Ha of broadleaved woodland.
Loss of 14 existing trees (0.51Ha of scattered tree habitat). Loss of 3 trees off-site. 21 new trees are proposed (0.7692Ha), but small young trees will not replace the habitat of large mature trees. Ecology report suggests these trees will take a number of decades to mature into more established woodland habitat. 
Currently, the site is mainly lowland acid grassland. Proposal for redevelopment is that part of the existing acid grassland will be replaced by broadleaved woodland habitat, all in the Northeastern area rather than spread throughout the site which is the current state.

Trees to be felled
Includes Cat B2 Oaks, 1x Cat C Oak amongst others - important in biodiversity of local area.
Another Cat B Oak will be at risk of having its RPA damaged by the access.

In summary
There are many species living, breeding and feeding on-site, which are Red-Listed, classed as vulnerable to extinction, are species of national conservation concern, and species which are covered by policies to protect and restore the species and their habitats, with the current plan being to destroy their habitat over many years.
There have been found to be potentially exceptional populations of protected species.
The site is currently considered to be of regional value for some species found there.
The current plan for restoration will be permanently altering and destroying the type of habitat available for the most vulnerable of these species by significantly reducing the lowland acid grassland available to these species, and changing a large percentage of the site into broad-leafed woodland, possibly in order to be able to increase the total biodiversity of the site. What lowland acid grassland is proposed to be left, is only proposed to be protected for 5 years, leaving the remaining most vulnerable, nationally declining and highly protected of species (which includes the skylarks, linnets, meadow pipits) that require the open grassland to potentially losing their remaining habitat once this protection finishes. The Environmental Act 2021 asks for protection of the increase in biodiversity to be protected for at least 30 years.
I recommend we object on impact to Traffic, Air Quality, and Ecology, and ask that any restoration of the site respects the habitat and territory of the protected and vulnerable species, with retention of open acid grassland across the site, maintaining the scattered trees and scrubland which currently exist on the site, and that the entire site is protected following restoration for at least the 30 years as per the Environmental Act 2021.