Mineral Sites Plan

Published: 25 January 2019

Knowlton Parish Council is a group council which includes Horton parish, within which site AS27 lies. Knowlton Parish Council OBJECTS to the proposal to include site AS27 in the Mineral Sites Plan.

Legal Compliance

Since it is beyond our competence to assess, we do not challenge the legal compliance of the Plan at this point without an independent opinion.


We do not accept that the Plan, as proposed, is sound.

General Issues

The outcomes documentation of the AS08 consultation acknowledges that the publicity for the 2017 consultation referring to AS08 was not well achieved for local people. It went on to list means by which this could be improved, including on-line access, by which local people with an interest could be engaged in the consultation. It was disappointing, therefore, when the only notification of which we were aware was made directly to residents within a 500m radius, and to the parish and town councils.

We were able to make the situation known mainly by word of mouth, since it seems we seem to be constrained from using address data available from the electoral rolls for this purpose under GDPR. Most rural parishes, especially one of our geographical extent, do not run to a ‘parish office’ for public access. The reliance principally on internet-based responses is disingenuous. There is perhaps a lack of understanding of the realities of rural life behind this.

The notification we received came on 17 Dec 18, at the beginning of the Christmas holiday season when it would be at its most difficult to liaise with interested parties and when a significant part of the consultation period would be unavailable. Nevertheless, many members of the public and the town and parish councils have made representations to this consultation and their general concern is strongly expressed throughout.

The initial consideration of AS08 was undertaken shortly after planning permission was granted on 16 Aug 2018 for the site at Redman’s Hill. It not made clear whether the Inspector was aware, when making the suggestion that AS27 should be re-examined, of the possibility of a similar operation nearby with permission to operate until 31 Dec 2021. Reference is made in the current AS27 consultation to Redman’s Hill, but there is no indication that simultaneous operation of AS27 and Redman’s would not be constrained.

Environmental and Social Issues

In the main part, the environmental and social issues affecting this proposal are expressed clearly by other respondents. We support their concerns where there is no clear explanation or clarification from the various agencies associated with these subjects that meets their needs. These are real people, with real needs in their real lives and may not be passed by.

The area which regularly appears as one of concern is that of local infrastructure. The only contribution to date is that of Highways England.

Highways England is an organisation which clearly limits its area of responsibility as: “operates, maintains and improves England’s motorways and major A roads”. This is the organisation which appears in some of the earlier documents under its previous name ‘Highways Agency’. It is not however the Highways Authority for Dorset, which is currently Dorset County Council. This would explain the reference to DfT Circular 02/13 “The Strategic Road Network and the Delivery of Sustainable Development” by Highways England, as their responsibility begins and ends, in this case, at the junctions with the A31. They have no influence or interest in B-classified and Classified Unnumbered roads, such as one affected immediately by the operation of any extraction work on Horton Heath and numbered ‘C2’ by Dorset County Council.

The general function of each road classification is given by DfT in their document ‘DfT - Guidance on Road Classification and the Primary Route Network’ in this extract:

“A B road will still be of significance to traffic (including through traffic), but less so than an A road. A Classified Unnumbered road will be of lower significance and be of primarily local importance, but will perform a more important function than an unclassified road. An Unclassified road will generally have very low significance to traffic, and be of only very local importance”.

C2, as a Classified Unnumbered road, is considered as of primarily local importance. This is not a strategic route. As many respondents have pointed out, C2 is a road which carries traffic of a type and volume from which both the road structure and the adjoining settlements suffer damage and discomfort. It is a road which has outgrown its classification by stealth.

Stretching from the A31 Ashley Heath roundabout to the Wiltshire border, C2 has sections of winding road of narrow width where HGVs find difficulty passing, including one part on the western section which is one-way traffic even for cars and light vans. It is this cart track with a tarmac top which adoption and operation of AS27 could use to and from site and, as it has no direct connection to the A31 (other than by the B3078) to the West, it does not appear in their assessment because it doesn’t connect to their major roads.

It is not yet clear what volume of traffic is expected to serve AS27. The Assessment makes an assumption of 50 vehicles per day if AS08 is discarded - sometimes. There is no indication as to the number of days per week, nor during what hours, that the site would be operated. This is an unknown which must be resolved, surely, before any discussion of adding AS27 to the Plan can be concluded?

Criteria described in the Assessment frequently refer mitigation to be a function of the planning phase. Whilst this is probably an accepted way to proceed, there is a concern that, over the 12+ years of operation of AS27, there would be inadequate resources or methods to monitor or enforce compliance. Mitigation deferred is mitigation lost, and a large number of these ‘mitigated’ concerns should be resolved before there can be any reasonable justification to include AS27 in the Plan.