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PRESS RELEASE
Immediate Release: Tuesday, 16 November 2004

Parliamentary Spokesman, Grant Shapps, has set up the http://www.PanshangerSaysNO.com website with the objective of collecting as many petition signatures as possible and the public are encouraged to get friends and neighbours signed up to the campaign by visiting the website.

USEFUL BACKGROUND INFORMATION

Hertfordshire County Council’s Minerals Local Plan Review placed AFS12 in its category 1 list, although it did not finally include it in its list of Specific Sites or Preferred Areas. It concluded that it was “the most marginal between this category and the next” (between category 1 and category 2) of all the eight category 1 sites. (Hertfordshire County Council Aggregates Panel Meeting 5^th July 2002)

Even given the fact that HCC felt AFS12 to be marginal between categories 1 and 2, I feel there are a number of reasons why AFS12 was wrongly placed in category 1 and should be excluded altogether, especially since other agencies involved (Environment Agency, Land Use Consultants) would appear to agree.

These reasons include:

• Hydrology

• Archaeology

• Minerals Requirements in Relation to AFS12

Hertfordshire Minerals Local Plan Review has five Aims.  In Aim 4 the document talks of “ protecting and enhancing the County’s cultural heritage (e.g. archaeology and the historic environment)” and also of “protecting the water environment (e.g. water resources)”  If these Aims had been adhered to, I contend that AFS12 would have been excluded from being a category 1 site and might even have been excluded at the sieving stages.
 

HYDROLOGY

“The Environment Agency has highlighted that four sites identified as part of the planning proposal ( one of these being AFS12) are not considered suitable due to the impact on the local hydrology.” ( Letter from Environment Agency to David Farmer 14^th August 2002 commenting on Hertfordshire County Council’s Key Issues Consultation of the Hertfordshire Mineral Local Plan Review)

One of the most important contemporary considerations on Environmental issues is Climate Change, sometimes referred to as Global Warming and its effect on water resources, drought and also flooding. The Government has recently said that Climate Change is the most serious problem facing us today. 

AFS12 sits on an aquifer, a plateau 75 to 80 metres above sea level between the river valleys of the Lee and the Mimram.  The Holwell Park Spring system comes off this plateau and is referred to in the Landscape Character Assessment as “important”, no doubt because of the importance of the area in terms of water table and aquatic habitats. The County Council’s Review of each individual site considers that there must be “reservations” about extraction in LCA area 12e (which contains the Spring System) referring specifically to the “impact on the local water table, particularly the Holwell Park Spring System)”.  Given the increasing evidence each year of climate change, I feel insufficient weight has been given to hydrological considerations in the placing of site AFS12 in category 1.

The Environment Agency concludes that “dewatering would be necessary at some of the proposed sites.  Long term dewatering could have a deleterious effect upon the chemical and biological quality of nearby watercourses or wetlands by reducing base flows.  Similarly, dewatering could affect other licensed abstractors.” AFS12 would be one of the main sites affected in this way.  There is also the added problem that the Holwell Park Spring System feeds into the River Mimram and that in turn into the River Lea. The River Mimram has long had a problem of low flows and even drying up.  Reference can be made here to a meeting at the House of Commons on April 1 1998, attended by those concerned with the local water situation and the local MP Melanie Johnson, specifically to consider the plight of the River Mimram.

A number of times in the past 20 years, the Mimram has ceased flowing because of lack of winter rainfall.  The water company on these occasions has of course, had to cease extraction.  At times, the River Lee in this area would have ceased flowing if it were not for sewage discharge. If mineral extraction goes ahead this situation can only worsen considerably. The Environment Agency, in a letter to Herts CC on the 4^th January 2002 states, “The hydrological regime is permanently altered following the winning of materials.”  It would be irresponsible to risk this in the current and forecast climatic conditions.

This is especially the case given that the Environment Agency also refer to identification of low flows in certain rivers and identifies seven rivers most at risk.  These include the Mimram (which has a Grade 1 river rating – ‘Salmonid’, the highest in Hertfordshire) and the Middle Lee.  They add that with regard to these rivers in relation to mineral extraction plans,  “The Agency would not wish to see any derogation of river levels or flows as a result of any development.”  They explain in the document that, “The winning of minerals is at the expense of temporary/permanent storage of water within the aquifer system and, therefore, may impact on flows in rivers resulting in them becoming more flashy”  They also express concern about, “the impedance of water flows and groundwater lowering resulting in reduced base-flows and flooding”.  They stress that the reason for this lies in the nature of the area; that is that it, “incorporates wetlands, inundation habitats and habitats associated with a high water table”.

In its response to Herts CC’s Key Issues Consultation on its Minerals Plan, the Environment Agency in that letter of January 2002 identified AFS12 as one of four sites out of the 21 under discussion which “posed a moderate to significant threat to water dependant nature conservation sites and watercourses”. It continued that these four sites “could cause a deterioration of baseline conditions at proximal water courses and water dependant nature conservation sites”.

The HCC Minerals Local Plan states,” Mineral workings, because of their depth and their exposure of the underlying strata, inevitably affect the drainage of an area and it is important that both surface water and groundwater resources are protected”; therefore such an important hydrological area as AFS12 should not have been designated as a category 1 site especially given the increasing threat of climate change and I ask for it to be removed from the list of potential mineral extraction sites.

ARCHAEOLOGY

“the remains of a buried prehistoric landscape are evident within the fields north of Birchall Farm”. (Museum of London Archaeology Service 2002)

 The Government’s guidance on Planning Policy is PPG16 , Archaeology and Planning. Separate controls exist for scheduled monuments. PPG16 states that “the CBI’s revised Code of practice for Mineral Operators on archaeological investigations provides advice on how mineral operators should consult archaeological interests in formulating planning applications, to ensure that archaeological factors are fully taken into account in the planning process.”

 Under Government guidance, HCC commissioned a Strategic Environmental Appraisal (SEA) from Land Use Consultants in 2002 to consider the Local Plan Review to “ensure that a clear set of environmental and sustainability objectives are established which inform each part of the plan”.(Chapter 2 Hertfordshire Minerals Local Plan Review September 2002)

 This SEA concluded that the actions, identified in the scoping report, to be taken in response to PPG16  ‘Archaeology and Planning’, “have not been translated fully into the plan”  They continue, “no indication is given in the policy or supporting text as to how (archaeological) assets should be protected/managed. The scoping exercise indicates that the Plan should state a presumption in favour of physical preservation if appropriate, that the sites and monuments record should be referred to and that the CBI’s Code of Practice for Mineral Operators on archaeological investigations should be referred to. These actions should be followed up, as they will strengthen protection for archaeological assets. It would appear that the review of the Minerals Local Plan has led to a weakening of protection for archaeological assets.”  (my emphasis) 

 Interestingly, a recent Economic and Social Research Council report entitled “The Effect of Environmental Appraisal in Achieving Changes to Development Plans” concludes, “ It was found, however, that many appraisals were not fully integrated within the plan preparation process.  Furthermore, it was found that a lack of consultation and public participation during the appraisal process often led to limited benefits to the actual plan preparation process.”  There has been insufficient  integration of LUC’s  environmental appraisal into the Plan given the importance of the archaeology of the area of AFS12 which I shall now detail.

AFS12 is an area rich in archaeological potential, probably far more than any of the other sites.  Herts County Council’s own map of crop marks (App. 1) indicate an area rich in barrows, a supposed hengiform monument identified by the Royal Commission on Historical Monuments in 1912 and one of only five in the whole of Hertfordshire ( see letter from County Archaeology Unit (App.2), evidence of field systems, trackways and early settlements, and, adjacent, a supposed Roman villa. These are all recorded in the Sites and Monuments Records at County Hall which Land Use Consultants say should be consulted. ( See list of SMRs supplied )

Recently, Thames Water installed a large sewer deep underground, for which an area of land around the perimeter of the farm was investigated by the Museum of London Archaeology Service (MoLAS)

In their report just published and available through HCC, MoLAS  emphasize in their introduction that the “La Tene Chieftain Burial” was discovered in Welwyn Garden City in 1965 and is now one of the central exhibits in the Celtic room in the British Museum. They point out that “significantly the site is located within the Panshanger estate” (adjacent to Birchall Farm).  There have also been a number of other Iron Age discoveries in Panshanger in the later years of the 20^th century

While investigating the site (on what is AFS12) they identified many archaeological features “likely to be of prehistoric date” and of “buried archaeological features representative of land use during the prehistoric period…The features identified included a number of ditches representing areas of land division and enclosure; these were recorded in close association with areas of possible settlement activity.  A possible hengiform monument and four potential roundbarrows were also identified near the western boundary of Birchall Wood, further supporting the possibility of localised settlement.  Areas of pitting were also identified within the eastern sections of the site.  No secure dating has been obtained for these features. However, their morphology suggests that they are prehistoric in origin….”

During the investigation, a small assemblage of Late Bronze Age (3000 to 3500 years old) pottery was discovered around the areas of ditches and pits. The MoLAS report concludes, “The prehistoric pottery is of local significance as it indicates Later Bronze Age activity in the area.”

This supports findings during the construction of the A414 in this very area, a report on which has also just been published.and which refers to “extensive evidence of … a Late Bronze Age and Early Iron Age settlement of circular buildings” and “ a large size of pottery assemblage” from “a Neolithic or Bronze Age occupation layer.”

PPG16 stresses the need to preserve archaeological evidence “in situ” and states,” If physical preservation in situ is not feasible, an archaeological excavation for the purposes of ‘preservation by record’, may be an acceptable alternative…From the archaeological point of view this should be regarded as a second best option.” (my emphasis)

Given that the whole site ( see enclosed maps) is a designated Area of Archaeological Significance (AAS) with important archaeological remains across its whole area, it would be impossible to proceed without irreparable damage to this “critical capital”. The Museum of London Archaeology Service conclude in their report that  “The remains of a buried prehistoric landscape are evident within the fields north of Birchall Farm” and that even the limited, perimeter planned infrastructure of the Thames Water underground sewer “will have a high impact on any surviving archaeological deposits in the area”.

Herts County Council have failed to take sufficient consideration of the important archaeology in the area and of PPG16 and the Strategic Environmental Appraisal conducted by Land Use Consultants. As PPG16 states:  “Archaeological remains are irreplaceable… (They) should be seen as a finite and non-renewable resource, in many cases highly fragile and vulnerable to damage and destruction. In particular, care must be taken to ensure that archaeological remains are not needlessly or thoughtlessly destroyed. They can contain irreplaceable information about our past and the potential for an increase in future knowledge.” The site should be excluded on these grounds from category 1 status.

MINERALS REQUIREMENTS IN RELATION TO AFS12  

The independent consultant’s report on “ Defining need and encouraging recycling and re-use of aggregates” (LUC) begins, “ In order to encourage recycling and re-use of aggregates (recommended to DEFRA by a Wuppertal Institute report t2002), it is important that the level of need against which proposals are considered is set at such a rate that supply of new material is sufficiently restricted to stimulate demand for recycled material.”  It continues, “…the Plan recognises that it is increasingly apparent that this figure (produced by County) will be reduced as the Government progresses its policies to reduce dependence on land-won sources of supply and encourage the use of sources of alternatives for primary aggregates in the construction industry”.  It concludes that the Plan in this respect “allows for flexibility”.

Even if it were to transpire that further supplies of minerals were required then the Plan already provides the flexibility to provide what Land Use Consultants call “substitutes to enable sequential working during the landbank period”.

Land Use Consultants conclude with respect to site selection that, “ it is evident that the four sites identified, in combination with the reserve sites, provide the necessary flexibility to enable the delivery of policies concerning need, supply and the maintenance of the landbank”.

AFS12 was not one of the sites chosen nor was it a reserve site.  Given the previously documented points concerning the site and its hydrology and archaeological potential, I contend that HCC should not include AFS12 as a category 1 site.

 

David Farmer ( F.A.M.E. committee member) 2004

Sources

• Environment Agency Letter (4 January 2002 ) to Herts CC re Herts Minerals Local Plan Review - Key
  Issues Consultation

• Herts Waste Local Plan 1995 - 2005 (12 January 1999)

• East Herts District : Contaminated Land Strategy

• Environment Agency - Thames Region.  The General Quality Assessment Scheme ( GQA ) for UK Rivers and Canals.

• HM Government White Paper : “ Making Waste Work.  A Strategy for Sustainable Waste Management in England and Wales.”

• Minutes of a Westminster meeting at the House of Commons ( April 1 1998 ) on the “State of the River Mimram”.

• Herts Panel Survey on Mineral Extraction : “ Research Study Conducted for Herts CC”.

• East Herts District Council - Report by Executive Member for Planning and Property ( 18 December 2001 )

• Herts County Council Report by Sue Davidson on HM Government’s Green Paper,. “ Planning: Delivering a Fundamental Change”.  ( 29 January 2002 )

• Strategic Environmental Appraisal of the Hertfordshire Minerals Local Plan Review   Land Use Consultants 2002

• Thames Water Southern Outfall Sewer  WGC    Museum of London Archaeology Service 2004