Submission 1 - Scaling Images

PolishCampScaling (above) was taken looking North West, from Footpath 8, near the Polish Camp, at the junction with the track to the Wayfarers Site.

The scaling pole is 4m in height and is being held at the edge of the woodland (W3).

The existing hanger can be clearly seen through the trees.

The highest trees in the image, on the right are about 16m. The typical heights are around 11m, but some trees are lower still.

The developer has inaccurately shown this block of woodland as being 18m throughout (plan 3-8). He also makes no allowance for the fact that almost all the trees are deciduous, allowing views through the trees for many months of the year.

Allowing for scaling, the south eastern flank of the proposed buildings near the incinerator stack would be very similar in height to the top ridge of the existing hanger as seen in the image and therefore clearly not fully screened as claimed by the developer in the application documents at 5.14.2.3.1 ("The only element of the proposed development which would project about this tree screen would be the CHP chimney").

Given the inaccuracy in the developer's visualisations and drawings relating to the tree heights and screening effectiveness, the incinerator chimney and gas flare stack would also be more prominent in the landscape than he has stated.

The visibility of the proposed plant through the trees from this viewing point would also be increased further, over and above what can be derived from this image, due to the fact that the proposed buildings have a very much larger footprint and because due to the loss of most of the trees in this woodland block, the depth of free-standing trees along the line of sight would be reduced to just 15m.

WoodhouseFarmScaling (above) was taken looking South West from the garden of the listed building Woodhouse Farm, from a location fairly close to the building. The view is looking towards where the incinerator stack would be situated.

The scaling pole is, as before, 4m in height.

The image shows that the heights of the trees in woodland block W1 along this line of sight are generally lower than shown by the developer. The highest of the deciduous trees are less than 13m. The highest of the coniferous trees are about 16.5m, but do not form a continuous screen.

In the revised drawing 3-18 submitted as part of the Regulation 19 response, the applicant shows this woodland as an almost uniform solid block of trees up to about 16.5m high. (But in drawing 3-8 this is further increased to 19-22m). Furthermore, he makes no allowance for the fact that many of the trees are deciduous.

The viewpoint is slightly forward of the front door of Woodhouse Farm and not taken at 2m above ground level, as is the positioning of drawing 3-8), and so this image slightly underestimates the real impact from the viewpoint the applicant has used (which is currently blocked by brambles).

This image therefore shows that the incinerator stack would be more visible above and through the trees from Woodhouse Farm than the revised drawing 3-18 shows (which replaced an earlier drawing claiming there was no visibility at all).

From this viewpoint, and generally from the garden immediately around the Listed Farm (the "setting"), the chimney stack would be a dominant feature, almost reaching the top of the frame of the image. For a 45m chimney, the visual dominance would be even greater and it would extend well beyond the top of the image.

SUBMISSION 2 - Woodhouse Farm

WoodhouseFarmGarden(1)R (see below) was taken looking South Westwards from the garden of the farm building near Footpath 8 which passes the building.

The existing hanger can be clearly seen through the trees.
 
The proposed waste plant main building would be about 2m lower than the profile of the hanger as seen in this image, but would clearly still be seen through the trees due to the fact that the trees do not form a continuous screen, are generally of a lower height than stated by the applicant and are largely deciduous.  Furthermore, the proposed development would extend completely across the view of this image.
 
It can therefore be concluded that the existing trees would not afford the complete screening of the proposed development, as claimed by the applicant, especially as seen from the listed building Woodhouse Farm, and its setting in the countryside.

WoodhouseFarm(13) is an image looking North Westward taken from the garden of the Farm. It shows the listed building and its setting in the countryside. Some of the farm buildings can be seen to the rear.

This image shows that the listed Farm is in a rural location. The application site and its surrounds is not a largely developed, industrial setting as implied by the applicant. The setting of Woodhouse Farm would be harmed by the proposed development, including the development of a large area of car and coach parking, which the applicant states in the Reg 19 information would also be used for the "Site R" minerals workings. This would intensify the commercial use of the site.

SUBMISSION 3 - Woodhouse Farm

WoodhouseFarm(12) (below) was taken looking Southwards from the garden of the Farm building near Footpath 8, which passes the building. This illustrates the peaceful, rural nature of the location, with its many trees and how unsuitable it would be for a major industrial development near this location operating 24/7 with lighting, noise, emissions and odours. The Farm, several nearby buildings and some of the trees are either known or suspected bat roosts. The site is also the habitat for many birds including owls. 

 

WoodhouseFarmDoorL (below) is taken looking South Westwards from the highest part of the front door step of the Farm - the same visualisation point used by the applicant in drawing 3-18.

 

The image shows the peaceful, rural nature of the location as seen from the doorway. The applicant claims that 2m of the incinerator chimney would be visible above the trees (prior to the Reg 19 request he denied it would be visible at all). In this image the 35m incinerator chimney would be about 1/3 in from the right hand edge, rising above the trees and clearly visible from the listed Farm and its garden. A 45m stack would obviously be even more visible.

SUBMISSION 4 - Landscapes - From Herons Farm

HeronsFarmBund(2) was taken from near the public footpath at the southern edge of the land associated with the farm, where the bund to the "Site R" minerals extraction works is situated. The view is looking towards the South East.

The existing hanger can be clearly seen above and through the current tree cover, emphasising that the woodland that is there now does not screen the existing building and hence would not screen the proposed building, which would be on a much larger footprint, projecting to the right and beyond the edge of this image. The development would result in the destruction of the current stands of TPO trees to the North West of the hanger which can be partly seen on the right hand edge of this view.
 
Planting is proposed to act as a screen as seen from this view, but would take many years to become effective, and would not in any case fully screen the stack.
 
The incinerator stack would be particularly intrusive from this location, being to the left of the current hanger in this view and about 2.5 times higher.

SUBMISSION 5 - Landscapes - From near The Polish Camp

These 3 images were all taken from Footpath 8, just to the North West of The Polish Camp, at the start of the track to the Wayfarers Site.

PolishCamp(2)LEFT4COMP shows a panorama of four images, stitched together. This view shows the entire frontage of TPO woodland block W3, most of which would be destroyed by the proposed development.

The existing hanger building can be clearly seen through the trees. The proposed buildings would be on a much larger footprint, and extend across most of this view. The proposed buildings would also be much closer to the edge of the woodland than the hanger that can be seen, with (about) just 20 metres of trees remaining as a screening belt along the line of sight of this view, of which 5 metres would be coppiced.
 
The developer has wrongly stated (in several places in his documents) that Footpath 8 is 300 metres from the development. Footpath 8 runs along the track that can be seen on the right hand side of this view, to the edge of the woodland. The nearest point to the waste site buildings would be a few tens of metres from the public footpath, not 300 metres.
 
The developer has tried to give the impression that the airfield site and surrounds is an industrial area. Whilst there are a few scattered commercial activities, much of the site and the area in general is woodland and arable land, as can be clearly seen in this view. It has the physical appearance of being predominantly the countryside, which in planning policy terms, as adopted at all levels of the planning system "must be protected for its own sake".
 
The 7 metres wide, 35 metres high incinerator stack, and the gas flare stack, would be particularly intrusive in the landscape as seen from along this length of Footpath 8, located in line, and in front of, where the existing hanger can be seen and visible both through, and rising high above, the woodland, which is much lower than described by the developer in his various drawings and descriptions.

PolishCamp(2)RIGHT2 is a stitched composite of 2 images and shows the listed Woodhouse Farm and its surrounds as seen from Footpath 8. Again, this image illustrates the fact that this is a site in the countryside, with arable land and trees being the dominant landscape features in which the buildings are situated.

PolishCampFINALCOMP (below) is a wider angle view across the whole of the frontage of TPO woodland W3 and the setting of the listed Woodhouse Farm. It is a stitched composite of a different set of images than the two described above.

 

 
The small commercial site used by a road sweeping business can just be seen on the far left, although there is a question as to whether this site has planning consent, a matter that has been reported to both the district and county councils.
 
Apart from this small commercial site, the view is of the countryside, with Footpath 8 track leading off towards the TPO woodland W3. Footpath 8 then turns to the right as seen in this view, passing close to the listed farm buildings.

The sheer scale of the proposed development can be judged by comparing its width to the panoramic view in the image. The waste plant would take up over half the width of this image, dominating the scene and damaging the setting of the listed buildings at Woodhouse Farm. Whilst there would be some screening effect from the woodland surviving the development, as previously stated, the applicant has overstated the height of the trees and has been selective in the choice of where he visualises the incinerator stack from. In the case of the gas flare stack, he has produced no visualisations at all. In this view, parts of the main waste site buildings would be seen above and through the trees, but in particular, the two stacks would be very prominent above the tree line.

SUBMISSION 6 - Landscapes - Woodhouse Farm

WoodhouseFarmDoorFINALCOMP (below) is a stitched composite image taken from near the front door of Woodhouse Farm, looking South West. This is almost the same visualisation point as used by the applicant in his drawing 3-18 to illustrate the visibility of the incinerator stack from the farm.

WoodhouseFarmGarden(1)FINALCOMP (below) is a stitched composite panorama taken from the front garden of the listed farm, looking South West. This shows the existing hanger visible through the trees and the skyline across the eastern part of the proposed plant, including the location of the incinerator stack.

These two images show that the trees in woodland block W1 along this line of sight do not form a screen of continuous height or opacity, as implied by the applicant. As identified previously by our visualisations and scaling measurements, the trees are also generally lower than claimed by the developer. The highest of the deciduous trees are less than 13m. The highest of the coniferous trees are about 16.5m.
 
In the applicant's revised drawing 3-18 submitted as part of the Regulation 19 response, he shows this woodland as an almost uniform solid block of trees up to about 16.5m high. (But in drawing 3-8 this is further increased to 19-22m). Furthermore, he makes no allowance for the fact that many of the trees are deciduous.
 
In WoodhouseFarmDoorFINALCOMP, the incinerator stack would be just to the right of centre, rising above the tree line and clearly visible from the listed farmhouse and its setting.

In WoodhouseFarmGarden(1)FINALCOMP, the proposed waste plant would be visible through, and in places, above, the trees. The incinerator stack would be located about 1/3 in from the left hand edge of this view, rising above the tree line and starkly visible from the garden of the listed Woodhouse Farm and the adjacent public footpath 8. Whilst the applicant makes reference to industrial structures on and around the airfield, and in particular the radar tower, it can be seen from this image that none of these are currently visible from this sensitive location and so the 35m high, 7 m wide incinerator stack would be a new and intrusive industrial feature in the rural landscape. 

SUBMISSION 7 - Landscapes - Parkgate

These images were taken from the track/footpath that can be accessed from Parkgate Road (which starts immediately opposite the Parkgate Farm agricultural buildings). 

ParkGateFINALCOMP (below) is a wide view stitched panorama looking broadly North East. The woodland across the view is mostly the designated County Wildlife site Storey's Wood, including the "detached portion" (designation W139 Storey's Wood 3.7ha TL 825199). The woodland to the left of the view, beyond the telegraph pole, includes some of the trees in TPO woodland blocks W2 and W3. The small road sweeping business site, with conifer screening, can barely be seen on the right.

 
This view again illustrates the fact that the area is open countryside comprised largely of arable fields and woodlands, typical of the mid-Essex rural landscape. There is little evidence of commercial activity, which the applicant states is widespread in the area.

ParkgateLEFTCOMP (below) is part of the above composite but gives a more detailed view looking almost Northwards towards the location of the proposed waste site. The incinerator stack would be about centred in this view, its visibility dependant on its height as seen from this more distant location, almost 1km from the incinerator.

There remains uncertainty over whether the stack would be 35m high, or would be required by the Environment Agency to be higher, for example at least 45m (more typical for a plant of the proposed size).
 
The road sweeping business site can just be seen. To the left of that, part of the "Site R" minerals workings can be seen, although this will be restored to agricultural use under agreed planning conditions.

There are several footpaths crossing, and adjacent to, these views and these are well used by local people.

SUBMISSION 8 - Landscapes - Western Road

These images were taken from one of the permissive paths that can be accessed from Western Road, opposite the entrance to the gravel pits (the location is about 500 metres north of the entrance to the pits).

 
WesternRoadR (above) is a single image and shows how the landscape is much more open from this side of the airfield than is the case from other viewpoints. There is less tree cover and the existing hanger can be clearly seen, despite being nearly 1 km away. The view is looking broadly North East.
 
The proposed waste site buildings would project well forward of where the hanger is now - to the left of it as seen in this view. The proposed mitigating planting would take many years to grow sufficiently to screen the plant, and structures would still be visible throughout the lifetime of the plant despite the planting, particularly the incinerator stack, which would be slightly to the right of the hanger as seen in this view.
 
Silver End is the nearest settlement to the proposed waste site and is an historically important model garden factory village partly covered by a Conservation Area. Many properties in the village on its eastern and northern sides, including listed buildings, would have direct views in to the waste site owing to the very open nature of the landscape from this side.
 
Essex County Council and Braintree District Council have for many years strictly controlled development in Silver End to protect its architectural importance. Yet if planning consent is granted by the County Council for the waste site, many of those same residents will have direct views of one of the largest waste sites in Europe and will be exposed to emissions from the plant. Many villagers who enjoy the open landscape of the airfield for its amenity and wildlife value will see that enjoyment harmed by the development of a large industrial complex in open countryside, both during construction and operation for the decades that follow. 
 
On the far right of the image, the small road sweeping business site can be seen, although there are questions as to whether this site has planning permission.
 
To the left, some of the minerals workings can be seen, associated with "Site R".

WesternRoadFINALCOMP (above) is a wide view stitched composite panorama from the same location, looking between North North West and North East. The existing radar tower can be seen to the left, together with one of the airfield hangers and a few small scattered airfield buildings. The waste site hanger can be seen to the right, as per the image above.
 
Despite the majority of the larger airfield structures being visible in this image, it is still a view of an open, largely rural landscape, dominated by arable land and scattered trees and copses. It is not the industrial landscape implied by the applicant.
 
The applicant has included (ie drawing 3-8) what appears to be a wide road described as "To hanger No. 1 industrial zone". We do not know what is meant by this as there is currently no "industrial zone" at hanger no.1, just light commercial useage. Does this reveal an intention to further develop the airfield in the future for industrial purposes ? 

SUBMISSION 9 - Landscapes - The Hanger

These images were taken from near the TPO Tree Group G1 and the nearby small airfield buildings. The view is looking towards the main hanger, generally towards the South East.

HangerFINALCOMP (below) is a stitched wide view of the whole north western side of the hanger and the protected woodland around it.

The view illustrates the rural nature of the site. The surviving WWII hanger is used for various purposes, but at a very low intensity.
 
To the right of the hanger can be seen TPO Woodland Block W2. Most of this would be destroyed by the development.
 
To the left of the hanger, parts of TPO Woodland Block W1 can be seen, which would remain.
 
Although the hanger is largely forward of the trees, and therefore cannot be directly scaled, the general view clearly shows that the trees are not dominant over the hanger, as would be the case if the applicants claimed heights for the trees were accurate. The applicant claims various heights for the trees, up to and above 20 metres. Given the height of the hanger, which is about 14m to the highest ridge, and the fact that there are some trees in TPO Woodland Block W3 close to the hanger behind it, it would be expected that some of these trees should visible above the hanger, yet there are none.
 
Both this photographic survey and the applicants own most recent tree survey prove that the trees are much lower than previously claimed by the applicant and do not provide a solid block of screening.
 
The proposed development is so vast that the position from where this view was taken would actually be well inside the buildings. All of the arable land, the planted hedgerow, trees and old airfield buildings in front of the hanger would be destroyed, as would the hanger itself, despite the strong local interest in the airfield as an historic site.
 
The Adopted Essex Waste Plan does identify part of the airfield as a potential waste management site. However, the allocated footprint (site WM1) is different to that proposed in the application, and is restricted to the western edge of the existing taxiway, over 100 metres less in extent westward than the buildings proposed. In addition, the allocation for the site in the Plan states
(2) Waste management development could use the existing buildings on site or, if replacement buildings or structures are proposed, they should be sensitively designed having regard to their surroundings and be comparable to the scale of current buildings.

The more open areas of the site are likely to be more appropriate for uses such as outdoor composting. Screening and landscaping should have regard to visibility from public viewpoints and from Silver End, and to preserving the setting of listed buildings at Woodhouse Farm.

Clearly the proposed buildings are not comparable to the scale of the current hanger, the design is an alien industrial one, the buildings will be clearly be seen from many vantage points, including Silver End, and the setting of the listed buildings at Woodhouse Farm are clearly harmed by virtue of the visibility of parts of the proposed waste site buildings and the incinerator stack. This is a fundemental breach of the Adopted Waste Local Plan.

In the view of this image, the incinerator stack would be about where the centre of the hanger building can be seen, but much taller.

The airfield taxiways and footpaths are used by people to fly model aircraft, to fly kites, for children to learn to ride bikes, for walking and many more peaceful outdoor activities. The development of the waste site and the inevitable security surrounding it would completely remove this amenity. 
 

Hanger(1)L (below) shows the left hand side of the hanger and parts of TPO Tree Group G3 and TPO Woodland Block W1. This again illustrates the quiet, rural nature of the location. This area is one of the most active bat sites on the airfield. Bats are a protected species. 4 species of bat have been identified so far on the site and their disturbance or the destruction of their habitat is illegal.

 

Hanger(2)IR (below) shows the right hand end of the hanger. the woodland shown is part of TPO Woodland Block W2 which would be almost completely destroyed by the proposed development.

As well as being a bat habitat, the airfield is also an important habitat for birds. 66 species of birds have been identified on the site of which 52 species breed there. Improtant species include barn owl, kingfisher, hobby, little ringed plover, skylark and woodpecker. The most recent surveys have identified more bird species, and more bat species, than previously thought to use the site. Many of the birds are listed at various degrees of being under threat, including some Red List species. Some are Biodiversity Action Plan Species (BAP). Essex County Council has pledged to protect the environment, boost tree cover in the county, support the protection of threatened and BAP species, yet the proposed development would cause direct and quantifiable damage to the existing woodland, habitats and species using them.   

An aspect of the site which the images can only suggest at is how peaceful it currently is. This is a site where the "big skies" of Essex can be fully appreciated, owing to its location on a local plateau. There is very little noise and very little light pollution at night. All that would change with a 24/7 industrial development.

SUBMISSION 10 - Landscapes - Views from Listed Buildings

These five images were taken from the grounds of three listed buildings located at various points around the airfield. These are quite distant views, yet the existing hanger building, and hence the proposed development, can clearly be seen from two of the locations.
 
Two of the locations also have public footpaths nearby.
 
As previously stated, the applicant has provided photographs and visualisations that do not adequately cover the range of viewpoints available and do not accurately show the likely appearance of the incinerator stack. Nor has he provided views from a representative range of sensitive public viewpoints, such as from footpaths and listed buildings.
This set of images and the visualisations to follow do attempt to fill that gap in the available information so that the landscape impacts can be better assessed. 

RookHall(1) (below) is a single image that was taken from the listed Rook Hall, looking North West. Despite the application site being almost 2 km away, the existing hanger building is clearly visible, about 1/3 in from the right hand edge of this view, the roof areas being a dark red/brown in colour.  

The incinerator and gas flare stacks would be clearly visible from this location, in front of where the hanger is currently sited.
 
On the left of the image, the existing, and more distant airfield radar tower can be seen, which is useful as an additional confirmation of scaling for the height of the incinerator stack (allowing for the distance ratio).
 
The County Wildlife site Storey's Wood is visible across the left hand third of the image and a public footpath runs across the image.
 
As with all our other photographic submissions of the landscape, this image shows the very rural nature of the site, a typical mix of gently rolling arable land and woodland. The application site is in the open countryside, which under planning law at all levels should be "protected for its own sake".
 
The next two images were taken from the grounds of Porters Farm, which is also a listed building. The view is looking broadly North West. Because it is in a slight dip, Parkgate Road cannot quite be seen, but is located just in front of the white sign that can be seen on the wooden fencing.
 
PortersFarmSign(1) (below) is a single image taken from the western end of a recently planted Trafalgar woodland (see the Woodland Trust for further details of this nationwide programme). This wood commemorates the ship Bellerophon and is to be known as “Ruffian Wood”. It extends across 30 acres and is planted with various native broadleaved species including oak which was used extensively for ship building in Nelson’s day.

The mature woodland running across the whole of the view is the County Wildlife site Storey's Wood. The incinerator stack would be visible about in the middle of this image, to an extent depending on its height.

 

PortersFarm(1)FINAL(2)COMP (below) is a stitched composite panorama taken from a similar location in Ruffian Wood.

Both the main part, and the "detached portion" of Storey's Wood can be seen with the existing airfield radar tower just to the left of the "detached portion". The radar tower is 2 km distant, the proposed incinerator stack 1.3km distant, which gives a useful scaling confirmation. According to the applicants, the radar tower is 48 metres high. We estimate that the ground level at the radar tower is about 2 metres higher than at the proposed incinerator location. In this view the incinerator stack would be about 1/6 of the way in from the right hand edge of the view, visible to an extent dependant on its height.
 
Whilst the proposed access to the waste site is off the A120 at Bradwell, occasionally HGVs currently access the few commercial activities on the airfield via Parkgate Road. The applicant has shown an access on to the proposed waste site via Woodhouse Farm Lane, which joins Parkgate Road close to Porters Farm.The lane is also currently used to access Allshots Farm and the Polish Camp. The A120 and A12, both of which are the designated approach roads to the development site, are well known locally, and documented, as being prone to peak time congestion and when blocked by accidents, displacement of heavy traffic through the villages around the airfield is commonplace. If the waste site is built, then when these conditions arise, we would question where the 400 plus HGVs per day would go. The only realistic alternative access would appear to be Parkgate Road, resulting in waste HGVs coming through Rivenhall and Silver End and through the middle of the view in these images. 

Wolverton(1)a (below) is taken from the grounds of the listed house Wolverton, situated in Boars Tye Road, Silver End. Wolverton is one of the finest of the listed modern movement houses in Silver End.

The view is towards the East North East. There is a horse field in the foreground. Between the two small stables, the hanger located on the proposed development site can clearly be seen. As previously stated, the views of the development site are much more open from this side of the airfield and the residents of many houses in Silver End would be able to see both the main waste site buildings and the stacks.
 
Just beyond the stables is the single track Sheepcotes Lane, which is a quiet lane extensively used by local people for walking and cycling. A public footpath leads off to the left in this view, from the lane.
 
At the far left of the image, the hanger near Sheepcotes Farm can just be seen.
 
The overall view is one of a quiet rural aspect, where a large industrial development would be utterly alien.

Wolverton(3)a (below) is taken from about the same location, but is a wider view, taking in all of the hanger and nearby Sheepcotes Farm (the red building behind the horse). The radar tower can be seen, as can the hanger at the proposed development site.