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1101379
The current area of the sandpit - phase 4 - is nearing the point of being worked out and the application is for a further extension as phase 5 to allow the continued extraction of sand to meet the needs of the island's building industry from an indigenous source. As explained in previous applications this is the only location where this type of sand is found, a sand which is particularly suitable for plastering.
The area of the proposed extension is 0.168 hectares. The current area approved under application 04/00754/B as phase 4 is 0.231 ha and previous phases were phase 3 of 0.515 ha and phases 1 and 2 of 0.506 ha. The total area including the proposed phase 5 would therefore be 1.42 hectares.
These areas and the volume of extraction fall a long way short of the 15 hectares and 30,000 tonnes of minerals per year for sand extraction stated in the England and Wales guidelines on "when an environmental impact assessment is needed" in their publication "Environmental Impact Assessment: A Guide to Procedures". This is the document referred to in the Isle of Man Strategic Plan at paragraph 7.18.3 on Environmental Impact Assessment.
However the Strategic Plan includes a Chapter 12 relating to Minerals Energy and Waste within which is Minerals Policy 1 listing matters to be addressed in applications for mineral extraction.
A letter was sent to the Planning Section of the Department of Infrastructure, dated 15 March 2011, setting out how we intended to address these matters. This was submitted as a scoping document and a response was received on 24 June 2011, following consultation by the Department of interested parties.
This response indicated that responses had been received from the Highway Division of the Department requiring a transport statement, Manx National Heritage and the Department of Environment Food and Agriculture, wildlife section, requiring method statements for working to minimise disruption to wildlife and habitat, and from the Department of Environment, Food and Agriculture, Environment Protection Unit, advising that they had "no concerns given the small extension proposed, we have had no complaints about noise or air pollution to the best of (their) knowledge and given its proximity would not anticipate any nuisance or annoyance to local residents."
Following receipt of this response further discussions were held with the officer of the Highways Division who expanded on the content expected in the transport statement and with representatives of the wildlife division of DEFA and of Manx National Heritage. Reference to input from Manx Wildlife Trust was made by DEFA and a meeting and site inspection then took place in mid-July with Duncan Bridges of Manx Wildlife Trust.
1101379
Cronk y Scotty Coast Road Jurby Environmental Statement to Accompany Planning Application Ellis Brown - Architects
A letter was received from the Wildlife Trust following this site meeting which outlined their observations and suggestions with regard to site condition and habitat suitability for protected species, the need/suitability for surveys and giving their recommendations.
This letter was circulated to DEFA wildlife section and Manx National Heritage who commented on the letter's contents.
These comments and recommendations have been incorporated in the following sections of this document.
This application is for an extension of an active sandpit, and will be phase 5 of a phased approach to obtaining Planning Approval, a licence and extraction of sand from the sandpit.
The Department of Economic Development has been working with the client/operator to secure the continued and future working of the sandpit, recognising this as an important resource. An extension of the current licence for extraction has now been granted to June of next year to allow continued working whilst this planning application is processed. This licence extension relates to those areas with the benefit of Planning Approval, however this will exhaust phase 4 hence the application to extend to phase 5.
Mineral Policy 1 contains matters in five sub-headings (a) to (c) and these are addressed as follows:
(a) "there would be no unacceptable adverse effect on local residents in terms of visual amenity, dust, noise, or vibration as a result of the on site operation itself (including development, maintenance and restoration) or the traffic generated thereby"
Sand extraction has been taking place in this location since 1966 and this particular sandpit has been operating for 15 years since extraction commenced in phase 1 area. To our client/operator's knowledge no complaints have been received from local residents, the sandpit being located on the coastal dunes and the nearest dwelling being some distance away. This is borne out in the response received to the enquiry to the Environmental Protection Unit of DEFA where the response stated "no concerns given small extension proposed, we have had no complaints about noise or air pollution to the best of my knowledge and given its proximity would not anticipate any nuisance or annoyance to local residents".
This proposal will have no adverse effect on local residents.
Cronk y Scotty Coast Road Jurby Environmental Statement to Accompany Planning Application Ellis Brown - Architects The traffic generation will be addressed in the following section on Transport Statement. (b) "There would be no unacceptable adverse effect on i. landscapes and geology/geomorphology features of special interest or attraction
No such features of special interest or attraction exist. The area is part of the extensive dunes along the coast and the proposal is for a small area extension to the currently active sandpit.
ii. Ancient Monuments or their settings There are no Ancient Monuments on the site or in close proximity to the site. iii. Registered Buildings or their settings There are no Registered Buildings on or in close proximity to the site. iv. the character and appearance of a Conservation Areas The site is not within nor in close proximity to a conservation area. v. sites of archaeological interest The site is not within or in close proximity to an area of archaeological interest. vi. sites containing species or habitats of international, national and local importance.
Species and habitats have been identified in consultation with DEFA wildlife section, Manx Wildlife Trust and Manx National Heritage. Recommendations have been made and accepted and these are incorporated in a management approach outlined in a later section of this document.
vii. land drainage and water resources
There have been no adverse effects on land drainage or water resources from the previous immediately adjacent working phases of this active sandpit.
viii. designated National Heritage Areas
The site is neither within nor in close proximity to a designated National Heritage Area.
Cronk y Scotty Coast Road Jurb Environmental Statement to Accompany Planning Application Ellis Brown - Architects
Consultation has taken place with Manx National Heritage and their Curator - Field Archaeology/Inspector of Ancient Monuments has confirmed in an e-mail that there are no monuments (as designated under the terms of the Manx Museum and National Trust Acts) and no known sites of archaeological importance or significance on the land affected by the proposed development.
He further commented that whilst this does not completely preclude the potential for archaeological remains or artefacts to be found he would not see this as a hurdle to development taking place.
(c) "the proposal is acceptable in terms of access arrangements and highway safety" This is addressed in the following section on Transport Statement. (d) "working will be in accordance with a phased scheme of restoration and landscaping"
This proposal is for phase 5 of a phased working of the sandpit where restoration and landscaping of worked out areas followed in a phased manner with opening new phases for working. This will be expanded upon in the management of the site section later in this document.
(e) "the proposal does not sterilize other significant mineral deposits"
The proposal is a planned extension of an existing working to extract a mineral deposit, namely sand, the only mineral present in the location. The method of working in a phased approach working into the sand face will not sterilize the mineral deposits.
The sandpit at Cronk y Scotty has been in operation for 15 years during which time to the best of our client/operator's knowledge there have been no accidents connected with its operation and use.
The proposal is to continue to use the same access and haul road currently in use.
The wagons used to transport the sand are tipper wagons, 6.3 metres long, 2.4 metres wide and 3.0 metres high as shown on the attached illustration as appendix 1.
At its peak, pre 2005, there were up to 8 wagon loads a day being extracted, 16 vehicle movements, 8 in 8 out. Over the last twelve to eighteen months the maximum number of loads extracted was 3 a day, 6 vehicle movements, and currently there is 1 load a day, 2 vehicle movements.
With the current financial climate and slow down in the building industry this latest level is anticipated to continue for the foreseeable future.
In addition whereas previously there were 2 operators, 2 brothers, there is now 1 surviving brother operating the business. This will impact on the potential numbers of future movements which it is anticipated will not reach the previous maximum numbers.
The intention is to work out the current, phase 4, area before commencing extraction from the proposed phase 5 area.
There will therefore be no overlap of working or vehicular movements, movements will be as detailed above with no increase in vehicle movements from those previously generated by the operation of the sandpit.
The site forms a small part of the grey dune complex on the coastal strip to the north-west of Jurby. The proposal is for a further phased extension to the existing sandpit, quarrying of sand having been ongoing in a phased manner in this pit for 15 years. The previous phases have been worked out (phases 1-3) or are nearing worked out situation (current phase 4). These were carried out in a phased approach of working and restoration of previously worked phases. Manx National Heritage in their response to the scoping enquiry commented that previous turf restoration had only been partially successful and asked that a plan to improve its prospects should be provided. This will be addressed in the method statement for working within this document.
Consultation has taken place with Manx National Heritage, the Wildlife Section of Department of Environment, Food and Agriculture and Manx Wildlife Trust. A site visit with a representative of Manx Wildlife Trust has also taken place.
The habitat is a typical mature dune complex and consultations and site visit have identified the potential for the presence of a number of significant and protected species namely lizards, plants (orchids and Isle of Man Cabbage), invertebrates (Scarce Crimson and Gold Moth and Lesser Beefly) and birds (nesting sand martins).
Records referred to by the Wildlife Section of DEFA noted that lizards had been recorded close to the site and suggested a lizard survey, by the Manx Wildlife Trust, to determine their presence or otherwise on the site or to assume their presence and consider mitigation measures.
Discussions and a site visit with the Director of Manx Wildlife Trust were undertaken and the whilst it was noted that there was limited refugia the suitability of the site for foraging and basking was noted. Given the suitability of the habitat condition and the recording of the species close to the site it was suggested that no survey be carried out but to presume a presence and to adopt a suitable management approach in the development for mitigation/precautionary measures. This suggestion was accepted and the method statement/management procedures which follow address this matter.
Similarly whilst none of the invertebrates mentioned above have been observed on the site, the comments having been made due to their known presence on the Ayres nearby and the habitat being similar to that location, the management proposal for the lizards will also address these species.
Again whilst the habitat is suitable for the plants noted none were observed on site during the site visit. In his letter following the site visit the Director of Manx Wildlife Trust noted that no seed spikes or basal rosettes of orchids had been observed and considering the small area of the extension proposed he was reasonably confident that there are none in the area in question.
Sand Martins were observed on site and nests were noted. In its unworked state the faces of the dunes/quarry collapse and degrade rendering them unsuitable for the birds. However the vertical faces of sand created by the quarrying operation are ideal for nesting and attract the sand martins. This is a positive contribution to the habitat by the quarrying operation. It is recognised that this will require management of the quarrying operation and this is addressed in the method statement/management procedures which follow in this document.
In light of these observations following the site visit recommendations for operational procedures, timing of procedures and restoration were given by Manx Wildlife Trust, and these are incorporated in the method statement/management procedures which follow.
Manx National Heritage in their response to the scoping enquiry also suggested protection measures be included, in light of recent applications for off-road motorbike facilities along this stretch of coast. Such measures to include barriers and notices which would not only protect against illicit or inadvertent entry by walkers or motorbikers but would also guard against unnecessary additional disruption to the dune flora. The method statement/management procedures will include for this.
Cronk y Scotty Coast Road Jurby Environmental Statement to Accompany Planning Application Ellis Brown - Architects
During discussions on previous phases of the extraction a meeting was held on site (in 2004) with representatives of the Wildlife Section of DAFF (now DEFA) and Manx National Heritage to consider reinstatement works. At that time it was accepted that the transplanting of marram grass was generally successful but that relocation of turfs was only partially successful. This may have been attributable to depth of turf being taken and disturbance to roots. It is therefore proposed that turfs be taken carefully with greater depths than previously ensuring that all roots are taken with the turf. The turfs are to be taken as large, mainly intact turfs. These turfs will be immediately relocated and transplanted on previously worked areas of the sandpit.
Marram grass will be transplanted as before, however Manx Wildlife Trust have indicated that they have a harvester for seed and have offered assistance in harvesting marram grass seed should this be required. The applicant will accept this offer should there be a need for seed to augment the transplanting process.
In the 2004 discussions it was agreed that no import of fill material should take place for the reinstatement process. This was to protect the integrity of the dune habitat and this will be followed for current and future phases.
Following reclamation and transplanting of turfs and transplanting of marram grass on previously worked areas of the dune sandpit these areas will be left undisturbed to vegetate, habitat will be relocated within the area with no net loss.
Timing of the stripping of overburden will be planned to minimise disturbance to lizards and allow for the potential, however remote, of the named invertebrates and plants. Autumn or winter would be appropriate for the latter but autumn would be better for the lizards, autumn will be the planned target time.
To avoid disturbance of the nesting sand martins extraction in advance and stockpiling will be adopted.
Fencing of the site, with warning signs attached, will be carried out and the extraction vehicle, when not in use, will be housed in a secure compound made from herras fencing on the base of the working sandpit. The wagon used for transport of sand has not nor will be kept on the site of the site. This follows the recommendation of Manx National Heritage.
The proposed method of working is,
Erect a post and wire fence, 1 metre high and 3 strands of wire to avoid disturbance to wildlife but give a barrier to humans, with appropriate warning notices - "Danger - Working Sandpit" attached to the fence along the north-west, seaward, edge of the proposed and previous phases of the sandpit, giving protection from the coastline. A similar fence to be erected along the south-west boundary of the proposed phase 5 extension to the workings.
In Autumn strip a sufficient area of overburden from the area to be worked to allow one year's working of the new area. The overburden turfs are to be taken as large intact turfs, taking care to remove sufficient depth to avoid damage to roots. These turfs are to be immediately placed in final locations on a previously worked out area of the sandpit and then left undisturbed. Transplanting of marram grass in worked out slopes to be carried out in conjunction with the turf transplanting. By this approach the previously worked out area will be reinstated in a phased and planned manner as work progresses into the new quarrying area, thus re-habilitating the dune and balancing the removal and restoration of the dune for the benefit of the various species.
This timing will minimise disturbance to the lizards as they will still be active at this time and avoid the area, post the nesting season of the sand martins and will allow for any invertebrate flight activity to have passed. The timing will also be suitable for the plant species within the overburden turfs to be transplanted.
Over winter remove and stockpile sufficient area/volume of sand to avoid working the face during the time period of sand martin activity and nesting. This will prepare the new sand faces to encourage the nesting of the sand martins.
Repeat the process for future years.
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