Copdock and Washbrook Parish Council has submitted an OBJECTION on the following grounds….

The need for this volume of sand & gravel extraction is overstated.

Whilst this site might be earmarked within the Suffolk Minerals and Waste Local Plan (SMWLP), what is proposed by way of volume is far and above what the Plan mandates. The Planning Officers own assessment, earlier this year, was that the latest data available showed a landbank reserve of 8.8 years against a requirement of 7. Furthermore, the working of 1m tonnes at Flixton, nr. Bungay have added a further one year to that landbank.
The scale of the proposed site far exceeds that mandated by the SMWLP.
The proposed 15-20 year life span with at least 243 traffic movements/day, including 173 HGVs does not properly adhere to the intentions of SM&WLP Policy MS3: Belstead, which clearly anticipates a 10 year life for the site (para.10.12) and doubts daily HGV movements will rise above 100 HGVs/day (para.10.16).

SMWLP makes no provision for an inert waste processing plant.

There is no provision within SMWLP Policy MS3: Belstead for an inert waste processing plant the inclusion of which offers no benefit to SCC or the local community and instead serves purely to maximise the commercial returns of the applicant. It must be removed.
The inert waste processing plant magnifies the environmental destruction and adds wholly unnecessary HGV volumes.
The inclusion of on site concrete crushing and inert waste processing dictates that 100% of such waste will need to be brought onto the site by HGV with then about 95% being processed into recycled aggregate before being taken away from the site again by HGV. Inflicting the impact of concrete crushing (over 130 days per year) on the landscape and surrounding local communities and thereby generating many thousands of completely unnecessary HGV movements is unacceptable. There is no evidence to suggest that more sustainable alternatives have been considered, for example, undertaking inert waste processing at the site of their arising, using mobile plant and only sending residual construction wastes to landfill.

Higher level site restoration increases unnecessary volumes of HGV traffic further still.

Analysis of the applicants own drawings imply that approval of this application will result in raising the remediated site by an average of four hundred and thirty millimetres across the whole area which in turn amounts to a minimum additional 135,000 cubic metres of material that will need to be imported. Given that the NPPF seeks “the earliest possible restoration” in such applications, we see no justification for this and there is certainly none in the Belstead MS3 site allocation in the SM&WLP. Moreover, there is no evidence that a lower level restoration approach has been considered. This would have the obvious attraction of minimising reliance on the availability of a highly unpredictable inert waste stream for restoration thereby reducing the very real risk of delays to the restoration timetable. Once again, this aspect seems to serve no interest other than the applicants desire to maximise the commercial return available through the importing of material and the avoidance of landfill duty.

Lorry Route Management Plan remains woefully inadequate.

Data from Suffolk Police “black box” recording equipment in April 2024 revealed that vehicle usage of the Old London Rd (ex A12) was over 52,000 vehicles in a week. This represents a 67% increase over the figure recorded during the same period in 2022 and is directly attributable to increased congestion at the A12/14 Copdock interchange which encourages drivers to attempt short cuts to the A14 through either Swan Hill towards Sproughton or Church Lane towards Belstead and the A137. As this slide illustrates, apps like Google maps show drivers on a daily basis that quicker journeys are to be had by avoiding the A12 and it is a temptation that thousands of drivers every week find it impossible to resist. Why will 170+ HGV drivers emerging from the site and seeing the queuing on the A12 literally above them be any different?
Once the short cut onto the Old London Road is taken, an exit is only possible through either Swan Hill, a narrow lane with blind 90 degree bends (see photos attached - photo 1 and photo 2) or Church Lane which has official Quiet Lane status. Both are country roads totally unsuited to this type and volume of traffic. As far as the latter is concerned, we already have regular occurrences of HGV’s (seeking to cut across to the A137 and on to the A14 eastbound) getting stuck because there is insufficient room to pass other vehicles. Again, why will the behaviour of Brockley Wood HGV drivers be any different?
Additionally, SCC are, in conjunction with Active Travel England, sponsoring a proposed Cycle and Walking Route from Capel St Mary to the Copdock Park and Ride which would run literally alongside the Old London Road which would in turn be converted to single lane traffic. The whole thrust of this proposal is to REDUCE traffic along the Old London Road and create a safer and more pleasant environment for cyclists and pedestrians. How can giving upward of an additional 170+ HGV’s a day unfettered access to this narrowing road possibly be consistent with such an objective?
The Lorry Route Management Plan continues to offers local communities no protection from this volume of HGV traffic and centres its aspiration simply on asking drivers nicely to stick to A12 when they leave the site. which we argue to be woefully inadequate for a quarry and waste processing plant of this scale.
There remain no proposals regarding signage that will make it clear that there is no access to certain roads for BW traffic. There are no proposals for how the site operator will monitor the extent to which drivers are doing as they are instructed. Instead the burden of enforcement is placed entirely on local people: to run down the street tracking offending HGVs and collecting data as to registration numbers, date and times to establish whether they are travelling to or from the Site, and to report them to the Council’s single full time Enforcement Officer (responsible for enforcement at all 72 active minerals and waste site in the large county of Suffolk), with the prospect that a breach of condition notice might be issued if there is enough evidence to support one. In the absence of any proper accountability upon the operator, drivers will in reality be completely free to take whichever route they feel to be the quickest at any given time. Approval of this application can in our view therefore only be considered with the following conditionality at the operator’s expense …...

• a TOR weight restriction northbound on Swan Hill (there is currently one southbound only).
• clear and unequivocal “No Access to Brockley Wood Traffic” signage at either end of Copdock and Bentley communities
• installation of a CCTV camera at the southern entrance of the Old London Rd to monitor vehicle movements as they leave the site at Junction 32b of the A12.

The claim for a judicial review of SCC’s original determination, which led to SCC’s admission of unlawful approval, highlighted that the Council’s Consultant Planner was wrong to advise members that such restrictions cannot be granted through the planning process and we fundamentally disagree with the applicants claim that such a Grampian condition would be contrary to government advice set out in PPG guidance on planning conditions. In our view, they are entirely necessary, relevant, enforceable, precise and reasonable. We further argue that they also conform to other planning tests in that they are entirely necessary to make the development acceptable in planning terms, directly related to the development; and fairly and reasonably related in scale and kind to the development.

It is our view that as nothing has changed from the original application. All four grounds of the judicial review claim, which led to SCC’s admission of unlawful determination, remain valid and “live”. It must be refused.