Cemex UK Operations Ltd - Suffolk

Question 1

To which part of the Modifications would you like to comment on?

View Response

Please complete one questionnaire for every modification you want to

comment on.

Link to Main Mods Document

Link to Tracked Changes Plan

Response Details

From Cemex UK Operations Limited (M…

Date Started: 02 Dec 2019 12:05. Last modified: 02 Dec 2019 12:05

Status Complete

Email Address

Title Mr

First Name Shaun

Last Name Denny

Organisation Cemex UK Operations Limited

Address Line 1 Wolverhampton Road

Address Line 2 Oldbury

Address Town Warley

Address Post Code B69 4RJ

Response ID #767215

Visibility Anyone who can view responses.

https://smwlpconsult.inconsult.uk/consult.ti/planning.consultation/viewUserProfile?uid=25202721&nextURL

Question 4

Do you consider the Local Plan is:

Select the most applicable option in each row.

Yes No

(1) Legally Compliant

You must provide an answer to this question.

Main Modification

Additional Modification

Sustainability Appraisal

Habitats Regulation Assessment

Question 2

Which Main Modification do you wish to comment upon?


MM38

Question 3

What Additional Modification would you like to comment on?


«No response»

(2) Sound

(3) Complies with Duty to co-

operate

Question 5

Please provide your reason for supporting the the legal compliance or soundness of the

Local Plan or it's compliance with the duty to co-operate.


See representation here:

Question 6

Please give details on why you consider the modifications not legally compliant, sound or

does not comply with the Duty to co-operate. Please be as precise as possible.


«No response»

Question 7

Please set out what modification(s) you consider necessary to make the Local Plan legally

compliant or sound, having regarding to the matter you have identified previously. You will

need to say why this modification will make the Local Plan legally compliant or sound. It will

be helpful if you are able to put forward your suggested revised wording of any policy or

text. Please be as precise as possible.


«No response»

Suffolk Minerals & Waste Local Plan Modifications, November 2019 Comments made on behalf of CEMEX UK Materials Ltd.

CEMEX UK Operations Ltd, on behalf of CEMEX UK Materials Ltd. (the Company), is of the view that the proposed deletion of policies MP2g and MS7 from the draft Plan will render it unsound.

This view has been reached on the basis of a number of factors, including guidance contained within paragraph 145 of the 2012 National Planning Policy Framework (NPPF), specifically: -

“making provision for the maintenance of landbanks of at least 7 years for sand and gravel… whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised.”

The Company believes that there is an impending substantial loss of production capacity for producing coarse aggregate within the County due to the closure of Wangford Quarry in 2020 and Flixton Quarry in 2024 due to exhaustion of permitted sand and gravel reserves. This also resonates with paragraph 8.2 of the February 2019 Suffolk Local Aggregates Assessment which states: -

“In Suffolk the sand & gravel deposits are generally sand rich so that there is a shortage of stone.”

Land won aggregate sales in 2018 within Suffolk reached 1.221 million tonnes (Appendix 6 of February 2019 Suffolk LAA). 413 000 tonnes of this was classified as coarse aggregate. On this basis 34% of total aggregate production for 2018 was classified as coarse aggregate. 2018 is the only year for which the sand/coarse spilt data has been available, but the Company is not aware of any developments in the previous ten years that could have led to this split being significantly different over this period.

In the absence of any additional data the 2018 coarse/sand split of 34% has been applied to the overall 10 year average aggregate sales figure of 1.094mt (paragraph 8.4 of 2019 LAA). Over this period, the average sales of coarse aggregate are likely to have reached the order of 371 960 tonnes per annum. On the basis of submissions made to the Council 17% of these coarse sales were sourced from Wangford Quarry, whilst a further 26% were sourced from its sister quarry operated by the Company, Flixton Quarry. For 2018 both sites contributed 20% of overall coarse aggregate sales in the County, the shift from Flixton to Wangford being attributed to the exhaustion of Flixton Park and commencement of quarrying at Homersfield, within which a reduced coarse content has been encountered.

In the absence of the Lime Kiln Farm site (identified by Policy MS7 as a specific site for minerals extraction), and at current rates of sales Wangford Quarry will run out of permitted reserves by the close of 2020. Flixton Quarry has sufficient reserves until 2024, at which point it too will be exhausted of aggregates. A proposed replacement for Flixton Quarry at Mendham (Evidence Base document EB17) was rejected by the Minerals Planning Authority as part of the process of drafting the draft Minerals and

Waste Local Plan. Neither the Company or the Minerals Planning Authority has been able to identify a replacement for Flixton Quarry.

In the Company’s estimation 20% of the County’s productive capacity for coarse aggregate will be lost by the end of 2020 with the closure of Wangford Quarry, rising to 40% by the end of 2024 with the closure of Flixton Quarry. The deletion of Lime Kiln Farm as a specific site for minerals extraction reduces the allocation for coarse aggregate within Suffolk by 25%. These twin outcomes have led the Company to conclude that the deletion of policies MP2g and MS7 from the draft Plan will render it unsound because the Plan will no longer be able to ensure that the capacity of operations to supply a wide range of materials (coarse aggregate) is not compromised, contrary to guidance provided by paragraph 145 of the 2012 NPPF. This reflects, and amplifies, the Council’s own observations contained within paragraph 8.2 of the 2019 LAA.

In its previous submission the Company was of the view that competitor quarries within the County would not be able to increase output of coarse material to compensate for the loss of production at Wangford. It believes this remains the case, and that this is exacerbated by the loss of production capacity at Flixton Quarry in 2024. By examining the example of the proposed quarry extension at Barnham (Evidence Base document EB5 and Chapter 9 of the Draft Plan) the Company believes the difficulties that existing or proposed quarries would encounter in trying to make up the identified shortfall of coarse aggregate within the County are highlighted.

Barnham has been chosen as an example as the current quarry has a high annual sales figure for the County, and the third highest coarse aggregate content of the sites identified by the draft Plan at 30%, after Belstead (31%), which is a green field site and Lime Kiln Farm (60%). The site operator identifies that the extension contains 2.57mt of aggregate, 31% of which is coarse (771 000t), 62% sand (1 593 400t) and the remainder silt. The operator also estimates annual sales of between 100 000 to 200 000tpa, which equates to 30 to 60 000tpa of coarse aggregate, and 62 000 to 124 000tpa of sand. In its submission to the Minerals Planning Authority regards the draft Plan, the Company estimated that Lime Kiln Farm would contribute 80 000tpa to the annual consumption of coarse aggregate. With the closure of Wangford, it has been assumed that 30% of Wangford’s predicted sales might migrate to Barnham (24 000 tonnes), although it is acknowledged that this is an arbitrary figure.

This would have the impact of increasing sales at Barnham from 100 000tpa to 165 600tpa, or from 200 000tpa to 257 600tpa. As a result of one unit of additional coarse aggregate being produced, over 2 units of sand are also produced as a by- product. By seeking to react to the loss of coarse aggregate production capacity due to the closure of Wangford large quantities of sand are produced, significantly increasing sand production compared to demand. Seeking to meet a proportion of the lost coarse aggregates production capacity also shortens the predicted life of the potential reserve, from 25 years to 15, or 13 to 10, due to the increased rates of production required to increase the availability of coarse aggregate. This pattern is likely to be repeated at other quarries in the County as they either are estimated to produce less aggregate per year than Barnham, and/or have a lower coarse content

as a percentage of the overall deposit. The lack of production capacity becomes amplified on the closure of Flixton in 2024.

The adequate provision of coarse aggregate reserves over the Plan period has also been considered. The table accompanying paragraph 1.5 of the 2019 LAA estimates the sand and gravel landbank for Suffolk as being 10.96 million tonnes as of 31st December 2018. No information is available regards the split in the landbank between coarse aggregate and sand, so the sales split for 2018, the only year for which data is available is employed again, where 34% of land won aggregates sales in the County were classed as coarse. This would indicate that as of the 31st

December 2018, 3.63 million tonnes of the overall landbank was coarse aggregate. Excluding Lime Kiln Farm, the draft Plan allocates 3 million tonnes of coarse aggregate as part of sites suitable for mineral extraction, making a combined landbank and allocated sites total of 6.63 million tonnes.

The ten year average sales figure for land won aggregates within the County is 1.94 million tonnes per annum. On the basis of 2018 sales data, it is assumed that 34% of these sales were coarse aggregate, therefore as a ten year average 371 960 tonnes of coarse aggregate are likely to have been sold per year over that period. On this basis the landbank plus allocated sites, without Lime Kiln Farm, are predicted to provide almost 18 years of supply of land won coarse aggregate within the County, or until 2036. This leaves the draft Plan with no safety margin with regard to the provision of coarse aggregate in the County.

The above scenario is considered not to reflect guidance provided by paragraph 145 of the 2012 NPPF relating to the steady and adequate supply of aggregates. This view has been reached on the basis of; -

➢ production capacity for land won aggregates discussed above;

➢ average sales over the last three years indicate that land won aggregate sales are rising significantly compared to the average sales over the last ten years;

➢ paragraphs 3.9 and 10 of the 2019 LAA which identify that a number of future significant infrastructure projects are planned, including Sizewell C and the Lowestoft Third Crossing, to which Wangford Quarry is the closest source of coarse aggregates in both cases, and;

➢ the table accompanying paragraph 1.5 of the 2019 LAA identifies that although the draft Plan identifies 14.77 million tonnes of potential reserves, only 12.18 million tonnes is likely to be worked in the Plan period. Even when removing Lime Kiln Farm from the provision of the draft Plan, this still leaves 1.59 million tonnes of aggregate which the Council considers unlikely to be worked in the Plan period.

In combination it is considered that these factors represent a significant risk that the draft Plan will make insufficient provision for land won coarse aggregate demand in Suffolk over the Plan period and that a safety margin is required to maintain the steady and adequate supply of this material. Reinstating Lime Kiln Farm in the Plan will provide this safety margin, not to do so renders the Plan unsound.

The above serves to illustrate why the Company continues to believe that competitor quarries will not be able to compensate for the loss of coarse aggregate production capacity with the closure of Wangford, a situation that will be amplified with the subsequent closure of Flixton. It also elucidates on the Company’s view that the proposed modifications to the Plan will negate the safety margin with regard to the provision of land won coarse aggregate in the County, and that circumstances point to the likelihood of this safety margin being necessary to maintain the steady and adequate supply of land won coarse aggregate. To conclude: -

➢ To compensate for even a proportion of Wangford’s coarse aggregate production capacity, due to the proportions of coarse to sand at other sites identified in the draft Plan, at least 2 additional units of sand have to be extracted and processed to create 1 unit of coarse. This would lead to an excess of sand production in comparison to past sales volumes, a practice that would have a negative effect on a site’s financial viability;

➢ At the estimated rate of sale of coarse from Wangford of 80 000 tonnes per annum, and given the above, it is estimated that an additional processing capacity of at least 240 000 tonnes per annum would be required. The Plan does not identify nor cater for this;

➢ In the Company’s experience most operators’ do not operate with significant excess operating capacity over long period of time as this is not financially viable;

➢ The increase in production required to compensate for the loss of coarse production capacity, if possible, will significantly reduce the life of these quarries and their contribution to the steady and adequate supply of aggregates in Suffolk, and;

➢ The Plan, as proposed to be modified, has no safety margin for the provision of coarse aggregate, and this in the light of potential future circumstances regards both demand and availability, the Plan does not account for the steady and adequate supply of coarse aggregate.

Due to the coarse aggregate content of the deposit at Lime Kiln Farm (60%) compared to that which is expected to be encountered within the wider region (28%) it is considered a regionally important deposit. A deposit of this nature is not common in Suffolk or East Anglia. Whilst still aggregate, due to the high coarse aggregate content it is not a similar material to that quarried elsewhere in Suffolk, although it is used to produce a range of coarse aggregate products which can be produced at other Suffolk quarries. The loss of the coarse aggregate production capacity that would result from the closure of Wangford Quarry is unlikely to be fully compensated for by other Suffolk quarries as discussed above, and is unlikely to be compensated for from other sources for the reasons outline in the Company’s previous submission. This situation will be exacerbated with the likely closure of Flixton Quarry in 2024. The deletion of Lime Kiln Farm as a specific site for minerals extraction will mean that the Plan will run counter to guidance contained within paragraph 145 of the NPPF 2012 requiring that Minerals Planning Authorities should plan for “…a steady and adequate supply of aggregates…” and to ensure “…that the capacity of operations to supply a wide range of materials is not compromised.” It also runs counter to the Minerals Planning Authority’s own observations in its 2019

LAA. It is the Company’s view that the proposed modifications render the Plan unsound and should be reversed.

As described in its original submission the Company supplies many of its own concrete and concrete block plants with coarse aggregate. An analysis of sales data from 2018 also reveals that the quarry also supplied nineteen customers whom it considers competitors with coarse aggregates. These are businesses who also supply aggregates, concrete and concrete blocks into the same market as does the Company. These customers are a mix of local, regional and national concerns whose businesses draw on the coarse aggregates Wangford Quarry provides, and in 2018 in combination they purchased the majority of the available product from the quarry. Being able to maintain the supply of coarse aggregates from Wangford Quarry is not restricted to being commercially important to the Company, a network of other businesses operating in the same market segment also rely on this supply. This reinforces the Company’s view that the deposit contained within Lime Kiln Farm is of regional importance given the extent of the businesses its supports. The Company has been advised by a number of its customers of their intention to make representations independently on this point.

The Company has also been able to better quantify the potential financial contribution maintaining production at Wangford Quarry could make. This is provided by Appendix A to this submission, but in summary it is estimated that the development of Lime Kiln Farm could result in: -

➢ £160 748 per annum in wages paid to four members of staff

employed directly at the quarry (excluding annual pay rises); ➢ £169 217 in business rates by 2025/6, potentially rising to £338 000

over the life of the site;

➢ £1.68 million in Aggregates Tax (currently levied at £2 per tonne) based on sales of 80 000 over 10.5 years (the assumed life of the development);

➢ Gross value added of £12 million over the life of the development, and;

➢ The retention of a further 4.9 equivalent full time jobs either indirectly or as a result of the wage spending of those direct and indirect jobs.

The above chimes with the guidance contained within paragraph 144 of the 2012 NPPF regards the benefits of the mineral extraction to the economy, and the great weight that should be attached to them.

Paragraph 93 of the 2012 NPPF states the following: -

“Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development.”

The identification of Lime Kiln Farm as a specific site for minerals extraction will not result in a reduction in greenhouse gas emissions compared to the current situation. It is estimated that emissions resulting from the development would remain closely comparable to levels emitted from the current development. In its previous submission the Company identified that all the alternative sources of coarse aggregate to supply the market that Wangford Quarry currently supplies would involve the emission of additional greenhouse gases, notably CO2. Using data gathered across the whole Company as an average 1.93 kilogrammes of CO2 is emitted per tonne of aggregate delivered to customers (in 2017). The only source of coarse aggregate located centrally within Wangford Quarry’s market is Flixton Quarry, and this site neither has the capacity to make a significant contribution to coarse aggregate consumption within the County beyond that which it already makes, and at current rates of sale it is predicted to close by the end of 2024. As a result, any replacement coarse aggregate production capacity is likely to be located at a greater distance from the market than is Wangford, increasing aggregate road miles and CO2 emissions.

The Company also considered sourcing coarse aggregate by rail, but CO2 emissions rise to 4.7 kilogrammes per tonne using delivery by rail. Using data collected by the British Marine Aggregate Producers Association (BMAPA), of which the Company is a member, it is estimated that in 2015 each tonne of aggregate landed resulted in the emission of 7.46 kilogrammes of CO2. Neither scenario factors in the further CO2 emitted as a result of the use of HGVs to deliver product from the railhead or wharf to the customer.

A detailed and independent Landscape and Visual Impact Assessment has been undertaken regarding the extant planning application submitted in May 2019 for the winning and working of gravel at Lime Kiln Farm. The findings of this assessment are summarised as Appendix B to this submission, and the complete assessment is appended as Appendix C. The assessment concludes that the purpose of designating an AONB is to conserve and enhance its the natural beauty, however, landscape character, visual amenity, tranquillity and biodiversity are all intrinsically linked when considering the conservation of ‘scenic beauty’ (as referred to in the NPPF) and ‘natural beauty’ (as referred to in the CRoW Act) within the AONB. This is recognised by the objectives and actions in the AONB Management Plan. These various aspects have been considered in the promotion of Lime Kiln Farm as a Specific Site for Minerals Extraction and, together, the combination of the effects on each of these aspects is not considered to result in overall degradation of the scenic beauty or natural beauty experienced, due to the very limited area of influence that the Extension Site and the Proposed Development has within the wider AONB. Adverse effects on the ‘scenic beauty’ and ‘natural beauty’ within the AONB are therefore considered to be limited and the potential for long-term enhancement, through implementation of the proposed restoration scheme is good, such that compliance with national and local policies would be readily achievable.

Paragraph 116 of the 2012 NPPF states: -

“Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be

demonstrated they are in the public interest. Consideration of such applications should include an assessment of:

➢ the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

➢ the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

➢ any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.”

In its original submission in support of the designation of Lime Kiln Farm the Company provided a detailed assessment of the suitability of the site in the light of the tests paragraph 116 establishes. As a result of the proposed deletion of Lime Kiln Farm from the Plan the Company has reviewed and revaluated this assessment. It has concluded, in addition to or in amplification of its original assessment that: -

➢ Due to the coarse aggregate content of the deposit at Lime Kiln Farm (60%) compared to that which is expected to be encountered within the wider region (28%) it is considered a regionally important deposit. A deposit of this nature is not common in Suffolk or East Anglia. Whilst still aggregate, due to the high coarse aggregate content it is not a similar material to that quarried elsewhere in Suffolk, although it is used to produce a range of coarse aggregate products which can be produced at other Suffolk quarries. The loss of the coarse aggregate production capacity that would result from the closure of Wangford Quarry is unlikely to be fully compensated for by other Suffolk quarries. An additional aggregate production capacity of at least 240 000 tpa would be required to compensate for the loss of capacity at Wangford Quarry due to the low coarse aggregate content of other quarries in the County. The Plan neither identifies or tackles this issue. This situation will be exacerbated with the likely closure of Flixton Quarry in 2024. The above leads the Company to conclude that the deletion of Lime Kiln Farm from the Plan renders it unsound due to guidance provided by paragraph 145 of the 2012 NPPF;

➢ Examination of sales data from 2018 has revealed that Wangford Quarry sold coarse aggregate products to a significant number of its competitors, indeed this made up the majority of sales in that year. The products produced at Wangford Quarry are feedstock not only for the Company’s ‘value added’ processes such as concrete and concrete block manufacture, but also for a significant number of local, regional and national Companies competing with the Company it the same market sector. This reinforces the Company’s belief that the Lime Kiln Farm site is a regionally important deposit;

➢ A more detailed analysis of the economic contribution of the development has been undertaken (see Appendix A). Its findings reflect the guidance provided by paragraph 144 of 2012 NPPF;

➢ Whilst the inclusion of Lime Kiln Farm is unlikely to lead to the reduction in greenhouse gas emissions, all the alternative sources of supply of coarse aggregate into the market that Wangford Quarry supplies is considered likely to increase such emissions, specifically CO2. This consequence is considered to be contrary to advice provided by paragraph 93 of the 2012 NPPF, and;

➢ Adverse effects on the ‘scenic beauty’ and ‘natural beauty’ within the AONB are considered to be limited and the potential for long-term enhancement, through implementation of the proposed restoration scheme is good, such that compliance with national and local policies would be readily achievable. Furthermore, the extent of adverse effect and enhancements are dependent on specific development proposals; the Company believes that there is no reason in principle why the detrimental effect on the environment, the landscape and recreational opportunities cannot be resolved at the application stage.

The deletion of Lime Kiln Farm as a specific site for minerals extraction will mean that the Plan will run counter to guidance contained within NPPF 2012 (paragraph 145) requiring that Minerals Planning Authorities should plan to ensure “…that the capacity of operations to supply a wide range of materials is not compromised.” It also runs counter to the Minerals Planning Authority’s own observations in its 2019 LAA. Furthermore, it is contrary to guidance provided by paragraph 93 with regard to climate change. It is the Company’s view that the proposed modifications render the Plan unsound and should be reversed.

Appendix A: Estimated Economic Contribution of Wangford Quarry

Direct Impact

• Wangford currently employs four members of staff directly. This is

envisaged to remain the case for the life of the proposed Lime Kiln Farm

development;

• This level of direct employment would continue for 10.5 years;

• The Office for National Statistics (ONS) Annual Survey of Hours and

Earnings states that the median gross annual earnings within the mining

and quarrying industry sector was £40 187 per full time job in 2018;

• On the basis of the above, £160 748 would be paid in wages to staff per

annum, all of whom live locally to the quarry;

• Over the life of the proposed development this equates to £1.69 million,

although this figure does not account for annual pay rises, which are

generally in the order of 2%;

• Annual business rates are also paid by CEMEX to the District Council.

For the year 2019/20 these amounted to £49 140.50. Allowing for annual

increases in rates of 2.5% (an assumption drawn from an average of

predicted annual increases over the period 2017/18 to 2021/22), it is

estimated that by 2025/6 business rates will be £57 804.12 per annum;

• By 2025/6 £169 217.27 is predicted to have been paid in business rates;

• Over the life of the development it is reasonable to assume that the total

payments made would exceed £338 000;

• The sale of primary aggregates such as that produced at Wangford

Quarry is subject to a tax of £2 a tonne, payable to HMRC;

• This equates to £180 000 per annum paid to HRMC, or £1.68 million over

the life the development (on the basis of the predicts annual sales of 80

000 tonnes of aggregate per year);

• Gross Value Added (GVA) is defined by Investopedia as “… an economic

productivity metric that measures the contribution of a corporate

subsidiary, company or municipality to an economy, producer, sector or

region. Gross value added provides a dollar value for the amount of

goods and services that have been produced in a country, minus the cost

of all inputs and raw materials that are directly attributable to that

production.”;

• The 2018 edition of Profile of the UK Minerals Products Industry,

published by the Minerals Products Association states that the GVA

associated with sand and gravel quarrying in the UK in 2016 was £896

million on the basis of 62.7 million tonnes extracted. This equates to

£14.29/tonne of sand and gravel;

• Regards Lime Kiln Farm, based on the estimated annum rate of sales of

80 000/tpa, and a development lifespan of 10.5 years, using the 2016

GVA figure the economic contribution of the development would be in the

region of £12 million, excluding inflation, and;

• It is acknowledged that the overarching GVA figure may include the

individual contributions made by those aspects discussed above and that

adding the GVA figure to the above may result in a degree of double

counting.

Indirect Impact

• Using Input-Output Multipliers for the mining and quarrying sector

contained within the Office for National Statistics’ (ONS) Supply and Use

Tables 2010 a multiplier of 1:1.87 has been used to predict levels of

indirect employment resulting from the sector, i.e., for every full time job

in the sector a further 0.87 full time jobs are created in the supply chain;

• Using the same source, a multiplier of 1:1.19 is used to estimate how

many full time employed jobs are supported by the wage spending of full

time direct and indirect full time employees resulting from the sector;

• Given the above and that the proposed development is predicted to

maintain 4 full time posts for its lifetime, it is estimated that the

equivalent of 3.48 indirect full time employees in the supply chain will be

maintained;

• Again, applying the above, 7.48 directly and indirectly employed posts is

predicted through wage spending to generate a further 1.42 full time

equivalent posts, and;

• Overall, therefore, it is predicted that the Lime Kiln Farm development

will result in the retention of 8.9 equivalent full time jobs within and

outside the quarry for the life of the development, 10.5 years.

CEL Ref: CE-LY1271-RP06 - Draft v2i 15 November 2019

Page 1 of 3

Appendix B: Independent Examination of Suffolk Minerals and Waste Local Plan

Landscape-related comments responding to communications from Mr. Nick Palmer BA (Hons) to Mr. John Pricthard of Suffolk County Council, dated 29th July 2019, in relation to proposed allocation of land at Wangford for mineral extraction.

The proposed policies (MP2(g) and MS7) and minerals site allocation at Wangford more specifically relates to land

referred to as ‘Lime Kiln Farm (Wangford Quarry)’, differentiating it from the consented and active adjacent land

at Wangford Quarry.

In his communications Mr. Palmer states: “The site [proposed allocation site at Lime Kiln Farm (Wangford Quarry)]

is within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB). The National Planning Policy

Framework (the Framework) [NPPF 2012] states that great weight should be given to conserving landscape and

scenic beauty in AONB, which have the highest status of protection. The Framework states that permission should

be refused for major developments in these areas except in exceptional circumstances.” My comments relate to

landscape effects only, not in relation to what might be considered to be exceptional circumstances.

In relation to landscape-related matters, Mr. Palmer goes on to say: “…the proposal would be harmful to the

landscape. Following the working, the landform would be altered, and this would not be consistent with national

policy in terms of conservation of the landscape. If the site were to be allocated detailed restoration guidelines

could potentially be included in the Plan. However, the harm to the protected landscape during the period of

working would not be consistent with national policy.”

Whilst Suffolk County Council (SCC) has undertaken its own strategic assessment process, detailed design and

assessment work has been completed by the Operator (in an iterative manner) for the purposes of informing a

planning application in relation to working the Site for minerals (as proposed for allocation). This involved the

undertaking of a detailed landscape and visual impact assessment (LVIA), by experienced chartered landscape

architects, in compliance with best practice guidelines guidance and in consultation with the Council’s landscape

experts, in parallel with the design of a proposed phased operation coupled with progressive restoration scheme

(to minimise landscape effects within the Site), and design of a restoration masterplan (culminating in drawings

‘Figure R1’ and ‘Figure R2’, dated 24th October 2018, see attached). These were submitted as part of the

subsequent planning application for mineral extraction on 4th June 2019.

The design of the Proposed Development was undertaken in an interdisciplinary way to ensure that other

associated environmental aspects (and important considerations in the AONB – see paragraph 115 of the NPPF

2012), notably ecology, soils, cultural heritage and noise, were properly considered. This promoted a detailed,

multi-aspect and cohesive design to be finalised, and for a comprehensive assessment of environmental effects

to be undertaken, responding notably to:

▪ the NPPF 2012 (paragraphs 115 and 116) and emerging local mineral plan policies;

▪ the Suffolk Coast & Heaths Area of Outstanding Natural Beauty Management Plan 2013-18;

▪ the “Landscape Character Guidelines for the Suffolk Coast and Heaths Area of Outstanding Natural Beauty

– Guidance on the maintenance, protection and enhancement of this unique landscape” (publication from

the Suffolk Coast and Heaths Partnership); and

▪ the “Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) - Natural Beauty and Special

Qualities Indicators” publication (dated 21 November 2016) produced by LDA Design in conjunction with

the Suffolk Coast and Heaths AONB Partnership, Suffolk County Council, Suffolk Coastal District Council

and EDF Energy.

CEL Ref: CE-LY1271-RP06 - Draft v2i 15 November 2019

Page 2 of 3

This has allowed a scheme to be devised to facilitate mitigation and enhancement measures to be incorporated,

and assessed, in full consideration of the AONB designation, and its landscape character and special qualities,

giving much more certainty of the landscape (and visual) effects of the Proposed Development, and therefore of

the allocation of the minerals site, than would otherwise normally be available.

It is noted in paragraph 116 of the NPPF 2012 that “…Consideration of such [major development] applications

should include an assessment of: … any detrimental effect on the environment, the landscape and recreational

opportunities, and the extent to which that could be moderated” (my emphasis).

This should additionally be considered in the context of the landscape being dynamic, as is made clear within the

Guidelines for Landscape and Visual Impact Assessment 3rd Edition (‘GLVIA’) (in Para 2.13): “Landscape is not

unchanging. Many different pressures have progressively altered familiar landscapes over time and will continue

to do so in the future, creating new landscapes. Today many of these drivers of change arise from the requirements

for development to meet the needs of a growing and changing population and economy”. This does not mean that

any change is acceptable change, but it also means that change in the landscape is inevitable so this should be

channelled in a managed direction. Change does not necessarily mean harm, and it is the extent of ‘harm’ that is

considered as part of the LVIA process in an objective way, against a policy context.

The LVIA submitted with the planning application “Landscape and Visual Impact Assessment - Proposed Mineral

Extraction at Lime Kiln Farm (Wangford Quarry), nr. Wangford, Suffolk - Report Reference: CE-LY1271-RP03-

FINAL” (dated 26th November 2018) (See Appendix C of this submission) has been cross-referenced to show the

depth of analysis undertaken, the degree to which effects have been moderated, and the long-term benefit that

has been incorporated into the proposals (through restoration and aftercare) preventing permanent harm to the

AONB.

The first key important moderation of harm relates to the geographical extent (particularly within the AONB) that

development of the site would be potentially affected. The zone of primary visibility extends to less than 250m

from the boundary of the Site (extending to circa 400m eastwards into private land). No recreational facilities,

public rights of way (other than local roads) fall within this zone (see Figure L1 of the submitted LVIA). As a result,

the area of influence from where effects of the development could be experienced is very limited in extent.

In the LVIA, none of the adverse visual effects is considered to be Significant (being limited to a maximum level

of Moderate with others generally of a lower level). The adverse effects on the landscape character were assessed

to be limited to a Moderate level during the operational period within the Site, and Minor level in relation to the

wider landscape character, and not Significant.

A new landform would result upon restoration and the change would be appreciable only from close-range

locations. Restored slopes of maximum gradient 1:8 provide the ability to maximise the agricultural capability of

the largest area of land and have the least effect on landscape character. The key characteristics of the Site will

be retained, together with some enhancements, once the restoration elements mature, with the influence of the

reduced levels and landform being extremely localised in nature. The remaining residual characteristics upon

restoration will contribute a number of desirable elements, retaining and enriching the essential aspects of the

landscape character area. The key characteristics of the locality’s landscape character were considered to have

been retained (non-Significant effect).

The purpose of designating an AONB is to conserve and enhance the natural beauty of the AONB, however,

landscape character, visual amenity, tranquillity and biodiversity are all intrinsically linked when considering the

conservation of ‘scenic beauty’ (as referred to in the NPPF) and ‘natural beauty’ (as referred to in the CRoW Act)

within the AONB, as is recognised by the objectives and actions in the AONB Management Plan. These various

aspects have been considered in the development of the proposals and, together, the combination of the effects

on each of these aspects is not considered to result in overall degradation of the scenic beauty or natural beauty

experienced, due to the very limited area of influence that the Extension Site and the Proposed Development has

within the wider AONB.

Adverse effects on the ‘scenic beauty’ and ‘natural beauty’ within the AONB are therefore considered to be limited

and the potential for long-term enhancement, through implementation of the proposed restoration scheme is

good, such that compliance with national and local policies would be readily achievable.

Landscape and Visual Impact Assessment

Proposed Mineral Extraction at

Lime Kiln Farm (Wangford Quarry), nr. Wangford, Suffolk

Report Reference: CE-LY1271-RP03 - FINAL

Produced by Crestwood Environmental Ltd.

26 November 2018

Crestwood Report Reference: CE-LY1271-RP03 - FINAL:

Issued Version Status

Date Produced

Written / Updated by:

Checked & Authorised by:

Draft v1

03/07/18 Karl Jones CMLI CEnv MIAgrM PIEMA

(Director)

-

Draft v2


(Director)

Client

Final


(Director)

Client

This report has been prepared in good faith, with all reasonable skill, care and diligence, based on information provided or known

available at the time of its preparation and within the scope of work agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

The report is provided for the sole use of the named client and is confidential to them and their professional advisors. No responsibility is accepted to others.

Crestwood Environmental Ltd. Units 1 and 2,

Nightingale Place, Pendeford Business Park,

Wolverhampton, WV9 5HF

Web: www.crestwoodenvironmental.co.uk

http://www.crestwoodenvironmental.co.uk/

Landscape and Visual Impact Assessment Proposed Mineral Extraction at Lime Kiln Farm (Wangford Quarry)

CE-LY1271-RP03 - FINAL Page 1 26/11/18

CONTENTS

INTRODUCTION ........................................................................................................................ 3

1.1 BACKGROUND ............................................................................................................................ 3 1.2 METHODOLOGY AND OUTLINE APPROACH ............................................................................... 4

BASELINE SITUATION ................................................................................................................ 7

2.1 LANDSCAPE DESIGNATIONS ....................................................................................................... 7 2.2 REGISTERED PARKS AND GARDENS ............................................................................................ 8 2.3 LISTED BUILDINGS, SCHEDULED MONUMENTS AND CONSERVATION AREAS ........................... 9 2.4 TREES AND WOODLAND ............................................................................................................. 10 2.5 ECOLOGICAL CONSERVATION .................................................................................................... 10 2.6 POLICY ......................................................................................................................................... 13 2.7 AONB MANAGEMENT PLAN ....................................................................................................... 17 2.8 LANDSCAPE CHARACTER ............................................................................................................ 18 2.9 LANDSCAPE VALUE ..................................................................................................................... 36 2.10 VISUAL ANALYSIS ........................................................................................................................ 38 2.11 VISIBILITY .................................................................................................................................... 39 2.12 VIEWPOINTS ............................................................................................................................... 39

LANDSCAPE AND VISUAL ASSESSMENT ................................................................................... 41

3.1 CONSULTATIONS ........................................................................................................................ 41 3.2 ASSUMPTIONS AND LIMITATIONS .............................................................................................. 41 3.3 PREDICTED POTENTIAL IMPACT SOURCES ................................................................................. 41 3.4 IMPACT AVOIDANCE AND MITIGATION MEASURES .................................................................. 41 3.5 EFFECTS ON LANDSCAPE CHARACTERISTICS AND CHARACTER ................................................. 43 3.6 EFFECTS ON VISUAL AMENITY .................................................................................................... 46 3.7 OTHER VIEWPOINTS ................................................................................................................... 53 3.8 SEQUENTIAL CUMULATIVE VISUAL EFFECTS .............................................................................. 54

CONCLUSION .......................................................................................................................... 54

LIST OF TABLES:

Table 1 Relevant AONB Planning Objectives and Actions .......................................................... 18 Table 2 Landscape Quality Indicators ......................................................................................... 23 Table 3 Scenic Quality Indicators ............................................................................................... 24 Table 4 Relative Wildness Indicators .......................................................................................... 25 Table 5 Relative Tranquillity Indicators ...................................................................................... 26 Table 6 Natural Heritage Feature Indicators .............................................................................. 26 Table 7 Cultural Heritage Indicators ........................................................................................... 27 Table 8 Special Qualities ............................................................................................................. 29 Table 9 Landscape Value of the Extension Site .......................................................................... 37 Table 10 Landscape Value of Locality Outside the Extension Site ............................................... 38 Table 11 Viewpoints (VPs) ............................................................................................................ 40 Table 12 Sources of Impact likely to cause Significant Effects prior to mitigation ...................... 41 Table 13 Habitat and Land-use Comparison ................................................................................ 45 Table 14 Summary Visual Sensitivity of Receptors at Viewpoints (VPs) ...................................... 48



LIST OF ANNEXES:

ANNEX 1 METHODOLOGY AND METHOD OF ASSESSMENT ANNEX 2 FIGURES

LIST OF FIGURES IN ANNEX 2:

FIGURE L1: VISUAL ANALYSIS PLAN FIGURE L2: VIEWPOINT 1 (looking northeast) FIGURE L3: VIEWPOINT 1 (looking southwest) FIGURE L4: VIEWPOINT 2 FIGURE L5: VIEWPOINT 3 FIGURE L6: VIEWPOINT 4 FIGURE L7: VIEWPOINT 5 FIGURE L8: VIEWPOINT 6 FIGURE L9: VIEWPOINT 7 FIGURE L10: VIEWPOINT 8



INTRODUCTION

1.1 BACKGROUND

Crestwood Environmental Ltd (‘Crestwood’), a Registered Practice of the Landscape Institute,

was commissioned by Cemex UK Operations Limited (‘the Client’ and ‘the Applicant’) to

undertake a Landscape and Visual Impact Assessment (LVIA) in relation to a proposed mineral

extraction site (extending the working at the existing Wangford Quarry) together with

landscaping, associated works and restoration (‘the Proposed Development’) on land at Lime

Kiln Farm, near Wangford, Suffolk (‘the Extension Site’) – for inclusion in the Environmental

Statement which will accompany an application for planning permission. The planning

application includes land to allow access to the processing area at Wangford Quarry (‘the

Existing Quarry’); where this coincides with existing permitted quarry areas, the restoration to

these areas would be in accordance with associated permitted development.

The Existing Quarry is centred on National Grid Reference (NGR) TM 4699 7750 and the

Extension Site, referred to as Land at Lime Kiln Farm, is located at NGR TM 4770 7763, to the

east. Plate 1 shows the location of the Extension Site, in relation to the Existing Quarry. The

planning application boundary also encompasses (in addition to the boundary shown) land to

facilitate access, processing and accommodation of a portion of overburden within the

Existing Site’s restoration scheme.

Plate 1 Location and boundary of the Extension Site, and 500m distance markers



The approximate extent of new proposed mineral extraction (‘the Mineral Extraction Area’) is

shown within the Extension Site on Figure L1 in Annex 2.

The Extension Site lies within Suffolk County, which is the mineral planning authority (MPA).

The Site is included within the ‘Minerals and Waste Local Plan - Submission Draft Report’ (dated

June 2018) as a site nominated for allocation in the (to be) adopted minerals and waste local

plan.

A detailed description of the Proposed Development is included in the accompanying planning

statement. For the purposes of this LVIA the main features of the Proposed Development are

as follows:

• A mineral extraction area, worked progressively in 6 main phases, using mobile

plant, over a period of 10.5 years, with mineral transported to the existing Quarry

using dumper trucks;

• Soil storage areas, which may also act as soil 2-3m high vegetated screening bunds;

• New site access points and routes to/from the Existing Quarry;

• Retention, improvement and management of boundary vegetation; and

• A low-level restoration scheme, implemented progressively in phases, completed

within 2 years of cessation of mineral extraction operations, and managed to ensure

successful establishment through an aftercare period.

A separate planning application is to be made by the Applicant to vary the restoration scheme

for the Existing Quarry, which has been considered alongside the proposals for the extension

area.

1.2 METHODOLOGY AND OUTLINE APPROACH

The assessment considers the acceptability of the Proposed Development in the location

proposed. Crestwood have has undertaken the following key tasks:

• a desktop study and web search of relevant background documents and maps,

including reviews of aerial photographs, LPA publications and other landscape

character assessments;

• collated information about relevant landscape designations and relevant heritage

assets listed on Heritage England’s national register;

• a field assessment of local site circumstances including a photographic survey of the

character and fabric of the Extension Site and its surroundings, undertaken by

suitably qualified Landscape Architects in suitable weather conditions, in 2017 and

2018;

• provision of feedback into the design of the Proposed Development to avoid or

minimise adverse impacts, including liaison with other design and assessment team

members;

• production of a restoration and aftercare scheme and landscape mitigation

proposals;



• Liaised with the MPA and assisted with public consultations, including efforts to gain

authorised access to neighbouring properties to assist with the assessment process;

and

• an analysis of the likely landscape and visual effects arising from the Proposed

Development, which includes an assessment of the significance of any effects

arising, based on their nature (positive or negative), magnitude and the sensitivity of

the receiving environment.

The full methodology and method of assessment used is provided in Annex 1 and, for the

purposes of accessibility, is summarised below, but it is strongly recommended that the

assessment be read after the detailed method of assessment is fully understood.

This assessment is conducted with regard to the principles set out in:

1. Guidelines for Landscape and Visual Impact Assessment 3rd Edition (The Landscape

Institute, 2013) – referred to as the ‘GLVIA’;

2. An Approach to Landscape Character (Natural England, 2014); and

3. Photography and Photomontage in Landscape and Visual Impact Assessment

(Advice Note 01/11) (Landscape Institute, 2011).

The GLVIA document sets out a range of techniques and approaches which practitioners are

advised to use when conducting Landscape and Visual Impact Assessments (LVIAs) and

Landscape and Visual Appraisals (LVAs), especially when carried out as part of an Environmental

Impact Assessment (EIA) (paragraph 1.4). The intent of the GLVIA is to present a general

overview of a ‘non-prescriptive’ methodology for undertaking assessments of developments:

“It is always the primary responsibility of any landscape professional carrying out an assessment

to ensure that the approach and methodology adopted are appropriate to the particular

circumstances” (GLVIA, paragraph 1.20).

This assessment accords with the general principles of the GLVIA and is considered

appropriately detailed to confidently assess the acceptability of both the principle and details

of development in this location.

The assessment is undertaken in the context of the landscape being dynamic, as is made clear

within the GLVIA (Para 2.13): “Landscape is not unchanging. Many different pressures have

progressively altered familiar landscapes over time and will continue to do so in the future,

creating new landscapes. Today many of these drivers of change arise from the requirements

for development to meet the needs of a growing and changing population and economy”. This

does not mean that any change is acceptable change, but it also means that change in the

landscape is likely and that this should be channelled in a managed direction.

The nature of landscape and visual assessment requires both objective analysis and subjective

professional judgement and is based on clearly defined terms, in line with best practice

guidelines. An explanation of terms and abbreviations used are provided at the end of the

assessment text.

Due to the relatively flat topography of the Extension Site and its context, the initial study area

extended to 1.5km in all directions from the edge of the Extension Site. Although the potential



for Significant Effects was found to be limited to a smaller area than this, the inclusion of a

revised access route between the Extension Site and Existing Quarry during the development

of the designs prompted a precautionary check on potential effects further to the south

(primarily due to the Extension Site being located within, or within near proximity to areas of

environmental designation, including an Area of Outstanding Natural Beauty), to a distance of

2.5km.

The potential visibility was checked ‘in the field’, taking into account potential sensitive

landscape and visual receptors, at which point it was clear that likely significant effects would

be limited to a distance well within 1km of the Extension Site.

A Zone of Primary Visibility (ZPV), indicating the approximate area from where it is predicted

that the Proposed Development at the Extension Site could be clearly noticeable to the casual

observer, taking into account reduced hedgerow and tree cover in winter, is illustrated on

Figure L1, in Annex 2.

Using professional judgement, Landscape Characteristics have been initially assessed for

potential sensitivity to change and a decision made as to whether individual characteristics can

be scoped-out of further assessment. Where not scoped-out, assessment of these

characteristics is undertaken in further detail, on the basis of the level of effects on these

characteristics potentially being a material consideration, and presented as part of the

assessment. Assessment of effects on Landscape Character is undertaken separately, taking

into account all landscape characteristics, including those scoped-out of individual assessment.



BASELINE SITUATION

2.1 LANDSCAPE DESIGNATIONS

The Site lies within the Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB)

– see horizontal green hatched area in Plate 2.

Plate 2 Area covered by AONB designation

The Suffolk Heritage Coast (defined in 1973 and largely contained within the AONB) lies

immediately south of (but not within) the southeastern boundary of the Extension Site – see

Plate 3.



Plate 3 Proximity of the Heritage Coast designation to the Extension Site

2.2 REGISTERED PARKS AND GARDENS

No part of the Extension Site lies within a Registered Park or Garden. Henham Registered

Park and Garden lies circa 1.3km west-northwest of the Extension Site – see Plate 4.

Plate 4 Registered Park and Gardens near the Extension Site



The associated citation states “…Henham enjoys a predominantly rural and agricultural

setting, with Wangford village to the north-east and Blythburgh and the Blyth estuary to the

south and south-east. It is completely surrounded by parkland tree belts apart from the

western end of the north boundary so there are no views into park. From the house platform

there are views south into park and the carriage drives provide views back towards the

platform. Wangford church provides a focus for views from the east drive”.

2.3 LISTED BUILDINGS, SCHEDULED MONUMENTS AND CONSERVATION AREAS

A formal assessment of the historical setting of heritage assets falls outside the scope of this

report and the professional experience of the report author. Irrespective of this, to help

ascertain the landscape value of the locality and whether there were potential landscape-

related effects of the Proposed Development on heritage features the following was

determined.

There are no Conservation Areas within the Extension Site; Wangford Conservation Area lies

circa 1.25km to the northwest of the Extension Site. There are no Scheduled Monuments

within 1.5km of the Extension Site.

As shown in Plate 5, there are no listed buildings within the Extension Site. One lies circa 300m

to the north-northwest of the Extension Site (Reydon Grange) and one circa 525m to the

north-northeast. Six others fall between 1 and 1.5km of the Extension Site and there are a

cluster present at Wangford village circa 1.6km to the northwest.

Plate 5 Listed Buildings near the Extension Site



2.4 TREES AND WOODLAND

There are no areas of ancient woodland within the Extension Site; the nearest (Reydon Wood)

being circa 750m to the north of the Extension Site – see Plate 6.

Plate 6 Ancient Woodland near the Extension Site

No veteran or ancient trees are shown on the Woodland Trust’s inventory map

(http://www.ancient-tree-hunt.org.uk/discoveries/interactivemap).

No Tree Preservation Orders (TPOs) are thought to relate to the Extension Site – see Tree

Constraints Plan Re. 18_C015_WANG_004 submitted with the planning application.

2.5 ECOLOGICAL CONSERVATION

The Site does not contain or overlap any national or international designations for ecological

conservation.

The Site lies in relative proximity to a number of ecological-related designations, all circa 400m

south-southwest of the Extension Site, as follows:

• Site of Special Scientific Interest (SSSI), see Plate 7;

• Special Protection Area (SPA), see Plate 8;

• Ramsar site, see Plate 9; and

• National Nature Reserve (NNR), see Plate 10.

http://www.ancient-tree-hunt.org.uk/discoveries/interactivemap



No Special Areas of Conservation (SACs) or Local Nature Reserves (LNRs) lie within the Study

Area.



Plate 9 Ramsar sites near the Extension Site

Plate 10 National Nature Reserves near the Extension Site



Hen Reedbeds is a Suffolk Wildlife Trust wildlife site that forms part of the NNR and has some

public access to provide viewpoints over the reedbeds and areas of water, with the nearest

point being located circa 450m south-southwest of the Extension Site. Reydon Wood (ancient

woodland), shown on Plate 6 is also a Suffolk Wildlife Trust wildlife site and lies circa 750m to

the north.

2.6 POLICY

An appreciation of the ‘weight’ to be attributed to any visual and landscape effects arising

from development requires an understanding of the planning context within which any such

development is to be tested for its acceptability.

Strictly, in legal terms, there is no automatic right to a view. However, the enjoyment of a

view could be an important part of the residential amenity of location (e.g. a neighbouring

property), and its loss might therefore have an adverse impact on the residential amenity of

that property (i.e. an environmental effect on humans).

Minerals can only be worked they are found and although development may generally be

preferentially be steered away from intrinsically valued environmentally designated areas,

temporary mineral development can be considered acceptable, once proportionate impact

assessments have been undertaken and a suitable scheme, responding to the findings of the

impact assessments, has been designed.

The current policy framework for planning control relating specifically to the Extension Site is

provided by the Development Plan comprised of the relevant policies described below.

European Landscape Convention

The UK is a signatory to the Council of Europe’s European Landscape Convention which

promotes landscape protection, management and planning. The UK Government has stated

that it considers the UK to be compliant with the ELC’s requirements and that the principal

requirements of the ELC are already enshrined in the existing suite of national policies and

guidance on the assessment of landscape and visual effects.

It is important to recognise that the ELC does not require the preservation of all landscapes

although landscape protection is one of the core themes of the convention. Equally important

though is the requirement to manage and plan future landscape change.

National Planning Policy - Landscape

An appreciation of the ‘weight’ to be attributed to any landscape effects arising from

development starts with an understanding of the planning context within which any such

development is to be tested for its acceptability.

It is stated in paragraph 7 of the National Planning Policy Framework (NPPF) (Ministry of

Housing, Communities and Local Government, 2018) that “The purpose of the planning system

is to contribute to the achievement of sustainable development”. It goes on to state in

paragraph 11 that:

“Plans and decisions should apply a presumption in favour of sustainable development… For

decision-taking this means:

http://www.naturalengland.org.uk/ourwork/landscape/protection/europeanconvention/default.aspx



c) approving development proposals that accord with an up-to-date development plan without

delay; or

d) where there are no relevant development plan policies, or the policies which are most

important for determining the application are out-of-date, granting permission unless:

i. the application of policies in this Framework that protect areas or assets of particular

importance provides a clear reason for refusing the development proposed; or

ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits,

when assessed against the policies in this Framework taken as a whole.”

Paragraph 170 of the NPPF states:

“[Planning] decisions should contribute to and enhance the natural and local environment by:

a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils

(in a manner commensurate with their statutory status or identified quality in the development

plan);

b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from

natural capital and ecosystem services – including the economic and other benefits of the best

and most versatile agricultural land, and of trees and woodland;

c) maintaining the character of the undeveloped coast, while improving public access to it where

appropriate;

d) minimising impacts on and providing net gains for biodiversity, including by establishing

coherent ecological networks that are more resilient to current and future pressures;

e) preventing new and existing development from contributing to, being put at unacceptable

risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution

or land instability. Development should, wherever possible, help to improve local environmental

conditions such as air and water quality, taking into account relevant information such as river

basin management plans; and

f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land,

where appropriate.”.

Paragraph 172 of the NPPF states:

“Great weight should be given to conserving and enhancing landscape and scenic beauty in

National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest

status of protection in relation to these issues. The conservation and enhancement of wildlife

and cultural heritage are also important considerations in these areas, and should be given

great weight in National Parks and the Broads. The scale and extent of development within

these designated areas should be limited. Planning permission should be refused for major

development other than in exceptional circumstances, and where it can be demonstrated that

the development is in the public interest. Consideration of such applications should include an

assessment of:

a) the need for the development, including in terms of any national considerations, and the



impact of permitting it, or refusing it, upon the local economy;

b) the cost of, and scope for, developing outside the designated area, or meeting the need for it

in some other way; and

c) any detrimental effect on the environment, the landscape and recreational opportunities, and

the extent to which that could be moderated.”

As a footnote to paragraph 172, it states “For the purposes of paragraphs 172 and 173, whether

a proposal is ‘major development’ is a matter for the decision maker, taking into account its

nature, scale and setting, and whether it could have a significant adverse impact on the

purposes for which the area has been designated or defined.”

Specifically in relation to minerals developments, paragraph 205 of the NPPF states:

“When determining planning applications, great weight should be given to the benefits of

mineral extraction, including to the economy. In considering proposals for mineral extraction,

minerals planning authorities should:

a) as far as is practical, provide for the maintenance of landbanks of non-energy minerals from

outside National Parks, the Broads, Areas of Outstanding Natural Beauty and World Heritage

Sites, scheduled monuments and conservation areas;

b) ensure that there are no unacceptable adverse impacts on the natural and historic

environment, human health or aviation safety, and take into account the cumulative effect of

multiple impacts from individual sites and/or from a number of sites in a locality…”.

The legal framework for AONB’s in England and Wales is provided by the Countryside and

Rights of Way Act 2000 (‘CRoW Act’) which reaffirms the primary purpose of AONB’s: “to

conserve and enhance natural beauty”. Natural England broadly defines ‘natural beauty’ as:

“not just the look of the landscape but also the landform and geology, plants and animals,

landscape features and the rich history of human settlement over the centuries”.

Local Policy

The Site lies in Waveney District, in the county of Suffolk, and circa 450m northeast of the

boundary with Suffolk Coastal District – see Plate 11.



Plate 11 Local Planning Authority boundaries

The Proposed Development would be classed as a ‘county matter’ and dealt with in terms of

land-use planning by Suffolk County Council. The relevant minerals development plan polices

are contained in the following (with the Suffolk Minerals Local Plan 1999 used in their

‘evidence base’ only):

• Minerals and Waste Development Framework – Minerals Core Strategy Adopted

Version – September 2008; and

• Suffolk Minerals & Waste Local Plan - Preferred Options Draft - dated October 2017.

Waveney District Council has local development plan policies in:

• Waveney Local Plan – Final Draft Plan, March 2018;

• The Approach to Future Development in Waveney to 2021 Core Strategy Development

Plan Document - Adopted January 2009; and

• Policies to Help Make Decisions on Planning Applications Development Management

Policies Development Plan Document - Adopted January 2011.



2.7 AONB MANAGEMENT PLAN

The AONB is currently guided by the ‘Suffolk Coast & Heaths Area of Outstanding Natural

Beauty Management Plan 2013-18’, which “sets a framework for any organisation or

individual whose activities will have an impact on the objectives for the area”. The

Management Plan is set in the context of national and local policy and strategy, and has a role

in supporting the Local Development Frameworks of the local authorities. As such, the

content of the Management Plan would be a material consideration when considering the

Proposed Development. The Management Plan also includes objectives, policies and action

that additionally applies to the Heritage Coast.

The Site lies within an area characterised within the Management Plan as ‘Estate Sandlands’

– which forms circa 38% of the AONB (by far the most commonly-found characterised area

within the AONB). Few of the listed important characteristics relate to the Extension Site (see

reproduced from the Management Plan in Box 1.

Box 1 Listed Important Characteristics of ‘Estate Sandlands’



A vision between 2013-2033 is included within the Management Plan, which can be

summarised as:

• Special wildlife, landscape, seascape and heritage qualities are conserved and meet the

needs of people who live, work in and visit the AONB;

• Local communities are fully engaged in the care of the area; and

• A high-quality landscape and infrastructure exists to support sustainable access,

tourism and business.

A selection of relevant priority objectives and actions within the Management Plan, related

to planning (noting that the Proposed Development would not be considered to be a ‘major

infrastructure development’) are given in Table 1.

Table 1 Relevant AONB Planning Objectives and Actions

AONB Objectives AONB Actions

2.7 There is a consistently high standard of development control decision-making. This will

prevent significant adverse impact on the landscape and scenic beauty of the AONB, as set

out in the National Policy Planning Framework (the NPPF states that landscape and scenic beauty of

AONBs should be given ‘great weight’).

Three including:

2.7.3 Assess visual impacts of developments on landscape and seascape character and scenic beauty,

either through LVIA as part of EIA or through less formal visualisations (photographs etc.) of minor

developments where visual impacts are unclear, both within and adjacent to the AONB.

2.8 The special qualities of the AONB are consistently taken into account and enhanced by

the planning process.

Various – relating to ecological networks, geodiversity, tranquillity and the conservation of historic parks and

gardens.

Additional potentially relevant Objectives and Actions are included in the Management Plan,

relating to Wildlife (conservation, management and restoration of characteristic habitats and

development and promotion of ecological networks within the AONB) and to Farming and

Forestry (promoting sustainable farming techniques appropriate to the location).

Research into what ‘Natural Beauty’ aspects and ‘Special Qualities’ relate to the Suffolk Coast

& Heaths AONB has also been undertaken (see paragraphs 2.8.11 to 2.8.13, below).

2.8 LANDSCAPE CHARACTER

Introduction

Landscape character is the physical make up, condition and experience of a landscape.

Landscape character arises from a distinct, recognisable and consistent pattern of physical and

social elements, aesthetic factors and perceptual aspects.

Information from published character assessments is provided first, followed by additional

information collated during other desk studies and the field work, all contributing to a better

understanding of the Extension Site’s landscape character.

National Landscape Character Assessment

The Site lies within the Suffolk Coast and Heaths National Character Area (NCA) (Natural

England, 2013). The key characteristics for this character area are listed as:



• A predominantly low-lying landscape with some areas along the coastal plain below or

at sea level. Changes in relief are slight, but enough to distinguish the Sandlings, sandy

rolling ‘upland’ between estuaries.

• Crag deposits covered by deep, free-draining sands, gravels and till, forming light,

sandy, easily worked soils on the Sandlings, giving rise to characteristic variation in land

cover.

• A dynamic coast, shaped by long, sweeping bays, cut by the series of more sheltered

estuaries. The shoreline is defined by shingle beaches and structures, sea defence

features and in places low, soft crumbling cliffs.

• Rivers flow west - east forming intimate, twisting alluvial valleys. Estuaries support

internationally important salt marshes and intertidal flats with large numbers of waders

and wildfowl, while their open waters are busy with pleasure and commercial craft.

• Expansive coastal level grazing marshes divided by drainage dykes contain

internationally important reedbeds and fens. Many are managed as nature reserves

owing to their rich biodiversity, which includes a nationally important concentration of

breeding bittern.

• Fragments of internationally important lowland heathland support nightjar, woodlark,

adder and silver-studded blue butterfly. Views across the dry farmland and heathlands

are open and extensive, except where enclosed by woodland.

• Farm woodlands, plantations and field boundary trees provide a treed character with

substantial coniferous forests (Rendlesham, Tunstall and Dunwich) in the core of the

NCA. Ancient broadleaved woodland and parkland wood pasture cloak the southern

river valley and estuary slopes. The coastal levels are largely devoid of trees.

• High-quality vegetable production and outdoor pig units are distinctive agricultural land

uses. Beef cattle graze the coastal levels although drainage has led to the conversion of

many of the grazing marshes to arable production.

• Inland valleys contain small-scale historic patterns of irregular drained meadow

enclosure, bounded by elm hedgerows. The Sandlings and the coastal plain show 18th-

to mid-19th-century large-scale regular enclosure. Pine lines and shelterbelts are

characteristic of the Sandlings.

• A rich archaeology includes Saxon burial mounds, medieval rabbit warrens and

numerous country house estates. The coast supports Napoleonic Martello towers,

Second World War pillboxes and the Orford Ness Cold War testing area with its

distinctive ‘pagodas‘.

• Settlement is sparse, with small, isolated villages and farmsteads. Larger urban

settlements are confined to the north and south (Lowestoft, Ipswich and Harwich).

Distinctive coastal towns (Aldeburgh, Southwold and Felixstowe) enjoy a relatively

unspoilt atmosphere.

• Traditional buildings utilise soft-hued red bricks with straw thatch, pantiles or peg tiles.

Some are rendered and painted (often in ‘Suffolk Pink’) while others (including churches)

use locally occurring split or knapped flint. Brightly painted beach huts line the coastal



resort seafronts.

• Large commercial ports (Harwich and Felixstowe), Sizewell nuclear power station, the

Cobra Mist transmitting station and the Orwell Bridge all contribute landmark diversity.

Major transport infrastructure includes the A14 and A12 and the main East Coast rail

line.

• Public access is extensive both on the land and on the rivers. The sense of tranquillity

and wildness is integral to the distinctiveness of the NCA, inspiring many writers, artists

and naturalists, and supports the area’s popularity as a recreation and tourist

destination.

County Landscape Character Assessment

The Suffolk County Landscape Character Assessment (http://www.suffolklandscape.org.uk)

places the majority of the Extension Site within the Rolling Estate Sandlands Landscape Type,

with a small proportion of the northwestern most sector of the Extension Site lying within the

Ancient Estate Claylands Landscape Type.

The key characteristics of the Rolling Estate Sandlands are:

• Rolling river terraces and coastal slopes;

• Sandy and free draining soils with areas of heathland;

• Late enclosure with a pattern of tree belts and straight hedges;

• Landscape parklands;

• A focus of settlement in the Estate Sandlands landscape;

• 19thC red brick buildings with black glazed pantiles in the east;

• Lark valley buildings are frequently of brick or flint with tiled or slate roofs;

• Tree belts and plantations throughout;

• Occasional and significant semi-natural woodlands and ribbons of wet woodland;

and

• Complex and intimate landscape on valley sides.

The Guidelines for this landscape type (where it is noted that the effect of vertical elements

have the most potential to have a negative effect on the landscape here) are summarised as:

• Reinforce the historic pattern of regular boundaries;

• Restore, maintain and enhance the pattern of locally distinctive “pine lines”;

• Restore, maintain and enhance the network of tree belts and pattern of small

plantations found across much of this landscape type; and

• Restore and maintain landscape parklands and their features.

The key characteristics of the Ancient Estate Claylands are:

http://www.suffolklandscape.org.uk/



• Dissected Boulder Clay plateau;

• Organic pattern of field enclosures;

• Straight boundaries where influence of privately owned estates is strongest;

• Enclosed former greens and commons;

• Parklands;

• WWII airfields;

• Villages with dispersed hamlets and farmsteads;

• Timber framed buildings;

• Distinctive estate cottages; and

• Ancient semi-natural woodland.

The Guidelines for this landscape type are summarised as:

• Reinforce the historic pattern of sinuous field boundaries;

• Recognise localised areas of late enclosure hedges when restoring and planting

hedgerows;

• Maintain and restore greens and commons;

• Maintain and increase the stock of hedgerow trees;

• Restore, maintain and enhance the historic parklands and the elements within

them;

• Maintain the extent, and improve the condition, of woodland cover with effective

management; and

• Maintain and restore the stock of moats and ponds in this landscape.

District Landscape Character Assessment

The Waveney District Landscape Character Assessment (April 2008) shows the Extension Site

sitting within the ‘H7 - Blyth and Wang Tributary Valley Farmland’ Landscape Character Area.

The key characteristics of this Landscape Character Area are listed as:

• A bedrock geology of Norwich Crag is overlain with deep glaciofluvial drift deposits of

sand and gravels and cut by minor tributaries, giving rise to an undulating landform.

• Topography ranges from 5m AOD to the boundary with the adjacent Wang and Blyth

Valleys, to 15m -20m AOD to the adjacent plateau.

• The area forms a backdrop to the adjacent river landscapes providing scale and

contrast.

• Well drained, sandy soils associated with glaciofluvial drift material create a fertile

landscape predominantly in arable cultivation.



• Some areas of rough grazing and permanent pasture are associated with the minor

tributaries that cross the landscape.

• Enclosure pattern is primarily pre 18th century enclosure – some intact hedgerow

networks remain, while in other areas hedgerows are sparse. Large mature oaks within

hedgerows are key features.

• Considerable wooded cover notably associated with the tributary valleys as well as well

as areas of parkland, as at Henham Park, with its plantations, copses and avenues.

• Principal elements of the cultural landscape are the hall and associated parkland at

Henham, with estate buildings such as lodges.

• Settlement includes the extended villages at Reydon and Wangford on the border of the

area, with modern development fronting or backing onto farmland.

• Outside the villages there are numerous dispersed farms, manors and halls.

• A quiet, rural landscape forming a transition area between the river valleys and higher

plateau areas. Tranquillity is reduced by a number of A roads that cross the landscape.

• A network of narrow rural lanes, some sunken and enclosed by steep vegetated banks,

create a more enclosed character.

• Occasional views across adjacent low lying Blyth Valley marshes to the south.

The Strategic Objectives for this character area are stated as:

“The primary strategic objective for this character area is to conserve and enhance the subtle

tributary valleys that thread through the farmland and link to the river valleys and coastal

marshes. In the light of climate change and rising sea levels these minor tributaries are key areas

for creation of freshwater habitats to compensate to some extent for those likely to be lost to

inundation at the coast. The landscape pattern of pre-18th century enclosure hedgerows and

pattern of trees, woodland and parkland which create interest and diversity in the landscape

should also be conserved”.

AONB ‘Special Qualities’ and ‘Natural Beauty’

A document titled “Suffolk Coast and Heaths Area of Outstanding Natural Beauty (AONB) -

Natural Beauty and Special Qualities Indicators” has been produced by LDA Design in

conjunction with Suffolk Coast and Heaths AONB Partnership, Suffolk County Council, Suffolk

Coastal District Council and EDF Energy (dated 21 November 2016). This sought to set out what

‘Natural Beauty’ and ‘Special Qualities’ indicators relate to the Suffolk Coast & Heaths AONB.

Natural Beauty Indicators were considered to be as set out in Table 2 to Table 7.

Special Qualities Indicators were considered to be as set out in Table 8.



Table 2 Landscape Quality Indicators

Factor Example Sub- Factor Example Indicator Suffolk Coast and Heaths AONB Indicator

Landscape quality

Intactness of the landscape in visual, functional and ecological perspectives

Characteristic natural and man- made elements are well represented throughout

Close-knit interrelationship of semi-natural and cultural landscapes (notably sea, coast, estuaries, reedbeds, Sandlings heath, forest, farmland and market towns) and built heritage features (such as Martello towers, pill boxes, river walls), creating a juxtaposition of elements in a relatively small area.

The AONB contains important areas of heath and acid grassland, and it supports a high number of protected species populations. As such it has importance in a national context for biodiversity.

The condition of the landscape’s features and elements

Landscape elements are in good condition

Strong overall character, albeit that the evolving nature of intensively farmed arable land with agricultural fleece/polythene and outdoor pig rearing can divide opinion on landscape condition in visually sensitive locations such as on valley sides.

The influence of incongruous features or elements (whether man-made or natural) on the perceived natural beauty of the area

Incongruous elements are not present to a significant degree, are not visually intrusive, have only localised influence or are temporary in nature

A small number of large scale and long established elements on the coast of the AONB divide opinion, being regarded by some as incongruous features and by others as enigmatic; for example the complex military site at Orford Ness. The power stations at Sizewell also divide opinion in this way, however in many views, particularly of the B station, the apparent uncluttered simple appearance and outline as well as the lack of visible human activity, partially mitigate the adverse visual impacts.

Offshore wind turbines at Greater Gabbard, Galloper and the more distant London Array are visible from some stretches of the coastline. These create a cluttered horizon and, like the large scale elements onshore, also divide opinion.



Table 3 Scenic Quality Indicators

Factor Example Sub- Factor

Example Indicator Suffolk Coast and Heaths AONB Indicator

Scenic quality

A distinctive sense of place

Landscape character lends a clear and recognisable sense of place

Unique character defined by semi-natural and cultural landscapes (notably sea, coast, estuaries, reedbeds, Sandlings heath, forest, farmland and villages) and built heritage features (such as Martello towers, pill boxes, river walls), creating a juxtaposition elements in a relatively small area.

Striking landform

Landform shows a strong sense of scale or contrast

Sea cliffs and shingle beaches contrasting to flat and gently rolling Sandlings heaths and farmland.

Extensive shingle beaches and shallow bays provide opportunities for long distance and panoramic views including out to sea and along the Heritage Coast.

Views to coastal landform also possible from locations offshore.

Landscape displays a ‘rhythm’ dictated by a series of east-west rivers and estuaries, and the interfluves that lie between them.

There are striking landform types or coastal configurations

Coastal cliffs, shingle spits, estuaries and beaches are striking landform features.

Visual interest in patterns of land cover

Land cover and vegetation types form an appealing pattern or composition in relation to each other and/or to landform which may be appreciated from either a vantage point or as one travels through a landscape

Varied habitats and land cover in intricate mosaic corresponding to natural geography (landform, geology, soils & climate) and displaying seasonal differences, either as a result of natural processes or past and current farming and land management regimes.

Elevated vantage points provide impressive views over low lying coastal marshes, estuaries, beaches and expansive long distance views out to sea. Views to the coastline from out at sea are also noted.

Appeal to the senses

Strong aesthetic qualities, reflecting factors such as scale and form, degree of openness or enclosure, colours and textures, simplicity or diversity, and ephemeral or seasonal interest

Close-knit interrelationship of constituent features creates a juxtaposition of colours and textures (such as coniferous forests, reedbeds, intertidal mud flats and heathland, sand dunes and shingle beaches) that is further enhanced by seasonal changes.

Strong aesthetic, spatial and emotional experiences - for example in the contrast between open and exposed areas on the coast, seaward or within estuaries with more traditional enclosed farmland areas.

Memorable or unusual views and eye- catching features or landmarks

Large open vistas across heaths and along the coast, out to sea and from sea to the coastline. Landmarks include historic structures such as medieval churches, Martello towers and lighthouses, the House in the Clouds (Thorpeness) and Snape Maltings, the riverside at Woodbridge with iconic Tide Mill, along with more modern structures including Sizewell A and B and former military site at Orford Ness.

Characteristic cognitive and sensory stimuli (e.g. sounds, quality of light, characteristic smells, characteristics of the weather)

Sensory stimuli enhanced by quality of light/space (the big ‘Suffolk skies’), areas with dark skies and sound (e.g. bird calls, curlews on heath and geese on estuaries, the wind through reeds in estuaries, waves on shingle).



Table 4 Relative Wildness Indicators


Relative wildness

A sense of remoteness Relatively few roads or other transport routes.

Absence of major coastal road or rail route, due to estuaries, and intermittent ‘soft edged’, often lightly trafficked access routes across the AONB to the coastline from main routes inland, has contributed to the relatively undeveloped character of the Suffolk coast.

Distant from or perceived as distant from significant habitation.

Pockets of relative wildness associated with coast, estuary and forests in this largely farmed and settled landscape.

A relative lack of human influence

Extensive areas of semi-natural vegetation.

Semi-natural habitats evident, notably on the Sandlings heaths, marshes, reedbeds, estuaries and along the coastline.

Uninterrupted tracts of land with few built features and no overt industrial or urban influences.

Largely undeveloped coastline and offshore areas and areas of semi-natural habitat including Sandlings heath, forests, reedbeds, estuaries and marshland.

Landscape interspersed with isolated villages, and built heritage assets such as Martello towers, pill boxes, river walls that contribute to character.

A small number of large scale and industrial elements on the coast of the AONB are long established, notably Sizewell A and B and the former military site at Orford Ness, whilst offshore wind turbines at Greater Gabbard, Galloper and the more distant London Array are visible from stretches of the

A sense of openness and exposure

Open, exposed to the elements and expansive in character.

Big ‘Suffolk skies’ and expansive views offshore emphasise sense of openness and exposure on open and exposed coastline and on the Sandlings heaths.

A sense of enclosure and isolation

Sense of enclosure provided by (e.g.) woodland, landform that offers a feeling of isolation.

Forestry plantations create sense of enclosure and isolation contrasting to open and more exposed areas along the coast and on the Sandlings heaths.

A sense of the passing of time and a return to nature

Absence or apparent absence of active human intervention.

Significant areas of semi natural landscape and seascape notably along the coastline, offshore and within undeveloped estuaries where there is little evidence of apparent human activity despite the sea walls and coastal marshes.



Table 5 Relative Tranquillity Indicators



Relative tranquillity

Contributors to tranquillity

Presence and / or perceptions of natural landscape, birdsong, peace and quiet, natural

–looking woodland, stars at night, stream, sea,

Areas of semi natural habitat, where there is a general absence of development and apparent human activity, contribute to a sense of relative tranquillity. Further enhanced by sounds (bird calls, the wind through reeds in estuaries, waves on shingle) and relatively dark skies.

Detractors from tranquillity

Presence and/or perceptions of traffic noise, large numbers of people, urban development, overhead light pollution, low flying aircraft, power lines and similar influences

Some local detractors from tranquillity include the seasonal influx of visitors to coastal towns, low flying aircraft noise and urban development on fringes of the AONB.

Table 6 Natural Heritage Feature Indicators



Natural heritage features

Geological and geomorphological features

Visible expression of geology in distinctive sense of place and other aspects of scenic quality

Boundary of the AONB is broadly geological marking the border between the inland boulder clay and the coastal fringe.

Visible and striking expressions of geology and sedimentation on faces of crumbling coastal cliffs.

Use of flint, local crag and Aldeburgh brick for building are indicators of local geology.

Presence of striking or memorable geomorphological features

Low crumbling cliffs and steep banks of pebbles on shingle beaches contribute to a landscape of constant change.

Striking and memorable geomorphological features include the vast cuspate foreland shingle spit of Orford Ness and river estuaries such as the estuary of the River Alde.

Wildlife and habitats

Presence of wildlife and / or habitats that make a particular contribution to distinctive sense of place and other aspects of scenic quality

Varied, nationally and internationally protected sites such as SSSI, SPA and SAC, semi natural habitats designated for their nature conservation interest and range of species supported (including shingle beaches, intertidal and offshore areas, reedbeds, grazing marshes and Sandlings heaths).

Intricate mosaic, highly dynamic and sensitive regimes (due to periodic flooding) along with rapid transitions add to biodiversity interest, distinctive landscape character and scenic quality.

Presence of individual species that contribute to sense of place, relative wildness or tranquillity

Varied protected species across major habitat types, for example breeding and wading birds in estuaries and reedbeds; rare communities of salt tolerant plants on the coast; and birds and invertebrates on the Sandlings heaths.



Table 7 Cultural Heritage Indicators



Cultural heritage

Built environment, archaeology and designed landscapes

Presence of settlements, buildings or other structures that make a particular contribution to distinctive sense of place and other aspects of scenic quality

Villages and small towns, particularly at ‘end of the road’ coastal and estuary locations, such as Pin Mill, Ramsolt and Walberswick and built heritage assets such as military structures (e.g. Martello towers, castle at Orford and pillboxes); Low Countries influence on architecture (as at Aldeburgh); and use of soft hued red brick and pink render with thatch or pantiles contribute to sense of place.

Presence of visible archaeological remains, parkland or designed landscapes that provide striking features in the landscape

Archaeological and historic sites and features include prehistoric and later burial monuments (including the Anglo-Saxon burial ground at Sutton Hoo); early medieval churches (many of which pre-date the Domesday survey); historic field and settlement patterns; and evidence of land reclamation dating back to the 12th century.

Distinctive vernacular use of flint, clunch and brick.

Designed landscapes are important notably along southern estuaries and in the northern part of the AONB, including Thorpeness Model Village.

Historic influence on the landscape

Visible presence of historic landscape types or specific landscape elements or features that provide evidence of time depth or historic influence on the landscape

Field patterns reflect process of land management and enclosure stretching back many centuries.

Evidence of reclamation of former intertidal areas to form freshwater grazing marsh dating back to the 12th century.

Prehistoric and later burial monuments (such as at Sutton Hoo), early medieval churches/religious houses and castles.

There is also more recent military and infrastructure elements particularly on the coast (e.g. Martello towers, former military installations at Orford Ness), WW11 airfields, radar installations and pillboxes that form part of the long history of “Suffolk’s Defended Shore”.

More latterly the Sizewell nuclear complex highlights evidence of time depth across the landscape. Both the nuclear complex and the nearby infrastructure associated with offshore energy generation are part of a developing story of the Suffolk’s Energy Coast.

There are often strong associations between these features and areas of more remote coastal landscape character.

Some of the military structures by reason of their scale, design, and cultural importance have now become an accepted part of the landscape, such as the Martello towers or the pagodas. Whereas other infrastructure, such as electricity pylons and the power stations are still cited by some as visual detractors in the landscape, despite the test of time.



Cultural heritage (cont’d)

Historic influence on the landscape (cont’d)

Perceptions of a harmonious balance between natural and cultural elements in the landscape that stretch back over time

Rural landscape and smaller settlements (notably using vernacular building materials) display a harmonious balance between natural and cultural elements in the landscape, some of which date back several hundreds of years.

Association between reedbeds and thatched roofs and local crag and flint where used as building materials.

History of river use with Thames barges indicating links to past maritime heritage, and contemporary recreational use of the estuaries and coast, with many boatyards and in-river moorings.

Characteristic land management practices

Existence of characteristic land management practices, industries or crafts which contribute to natural beauty

Landscape character and diversity of habitat types dependent on wide range of land management practices, several of which date back many centuries. Examples include pasturing; grazing on coastal marshes; forestry; extensive grazing to maintain heathland; reed cutting; and ditch/marshland and hydrological management.

Small scale fishing industry results in boats, nets, pots and storage buildings on some stretches of coastline.

Associations with written descriptions

Availability of descriptions of the landscape in notable literature, topographical writings or guide books, or significant literature inspired by the landscape.

Associations with numerous writers including George Crabbe, (e.g. the poem ‘The Borough’, 1810), P.D. James and Arthur Ransome.

Associations with artistic representations

Depiction of the landscape in art, other art forms such as photography or film, through language or folklore, or in inspiring related music

Landscape, towns, coastal areas and the sea captured in, or formed the inspiration for, the works of various artists and composers including J.M.W. Turner (e.g. ‘Aldborough, Suffolk’ c.1826) and Benjamin Britten (e.g. the opera ‘Peter Grimes’ c.1945).

Annual arts and music festival established in 1948, by Benjamin Britten along with singer Peter Pears and writer Eric Crozier.

Associations of the landscape with people, places or events

Evidence that the landscape has associations with notable people or events, cultural traditions or beliefs

Wide range of ‘stories’ describing historical events or activities relate to the landscape and features within the landscape, including stories related to smuggling; the creation of Minsmere; and the loss of Dunwich to the sea.

More recent stories include the discovery of the Sutton Hoo ship burial in 1939, the 1953 flood, and experimental projects; Cobra Mist at Orford Ness and Radar at Bawdsey Manor.



Table 8 Special Qualities


Health and Well-being

Access along defined routes for walking and cycling

Presence of network of local and strategic access routes

Extensive rights of way network (including promoted and long distance routes), offering access to key landscape types (such as coast, Sandlings heath, forest, wetlands and estuaries) and between centres of population and key tourist destinations.

Open access to areas of semi natural landscape

Presence of designated areas for open access

Areas designated as open access land, including extensive nature reserves, notably on heathland, along the coast and within woodland/forest provide opportunities for health improvement.

Opportunities for active and passive recreation

Presence of range of facilities and opportunities for diverse recreational pursuits

Opportunities for a range of active and passive recreational pursuits on the coast and offshore and inland including rambling, boating, bird-watching and fishing at sea and in the estuaries and rivers. In addition, many sporting events held in the landscape, such as the Heritage Coast Run and Suffolk Coast Cycle route.

Community

Relationship between people and place

Evidence that communities have a long established connection to the places in which they live and work

Strong sense of local and family heritage (including dialect), and evidence of long established connections to the landscape – such as fishermen and larger estates.

Evidence that communities have a close relationship to their surroundings

Active commoners, farmers and artistic community demonstrate strong links between communities and their landscape. Increasing number of community-led initiatives, particularly on the coast and estuaries.

Evidence of a local food culture

Opportunities to ‘taste’ the landscape with great significance placed on local food and drink (e.g. Adnams Brewery, local smokeries and oysterages and annual food and drink festival held in Aldeburgh).

Cont’d…





Economy

Landscape, community and economy closely intertwined

Evidence that the landscape and community forms an important part of the local economy

The landscape is an important contributor to the local economy. The coast in particular is a major tourist destination. Other notable contributors to the local economy are recreational sailing (with associated boatyards and moorings), farming, energy generation at Sizewell and attractions/events in and close to the AONB such as Minsmere RSPB Reserve, Snape Maltings,

Evidence of Community conservation schemes through which funding for grass-roots community and conservation projects within the AONB is secured.

Local visitor payback scheme, currently called ‘AONB Community and Conservation Fund’, into which tourism businesses contribute ‘visitor payback funds’ which are then used to support grass roots conservation, access and education projects.

Evidence of clearly defined ‘brand’ that is underpinned by the local landscape

Active promotion of the Suffolk Coast as a tourist destination founded on the special qualities of the area and more specifically as part of branding associated with local products (e.g. Adnams) and the ‘energy coast’.

Ecosystem Goods and Services

Landscape delivers broad range of ecosystem goods and services

Evidence that the landscape performs a diverse range ecosystem services

One of the most significant ecosystems in lowland UK containing several broad habitat types which perform a wide range of ecosystem goods and services under the three broad categories of ‘provisioning’, ‘cultural’ and ‘regulating’ (e.g. regulating climate, carbon storage, water storage, flood defence, flood prevention and climate change adaptation through linked habitats).



AONB Landscape Character Guidelines

A document titled “Landscape Character Guidelines for the Suffolk Coast and Heaths Area of Outstanding

Natural Beauty – Guidance on the maintenance, protection and enhancement of this unique landscape ”

has been produced on behalf of the Suffolk Coast and Heaths Partnership. This provides general guidance

for application across the AONB and also specific guidelines for different landscape types within. The Site

falls most congruently within the Estuary Valley Sides landscape type.

The general guidance potentially relevant to the Proposed Development and the Extension Site are:

• Retain and enhance the distinctive character of the Coast and Heaths.

• Ensure that new development is in keeping with the landscape, and proliferation of urban

clutter is prevented.

• Retain traditional landscape features.

• Maintain and support traditional farming practices.

• Promote the implementation of conservation measures on intensively farmed land.

• Retain and manage semi-natural habitats, and increase their area where possible.

• Promote the use of agri-environment grant aid and other support to achieve conservation

aims.

• In the open countryside, choose native species which occur locally in hedgerows, woods etc.

Avoid ornamental trees such as Norway maple or red oak and conspicuous non-natives such as

Leylandii.

• Before planting always consider whether natural regeneration would be a possibility.

• Use stock grown from British seed or, even better, from Suffolk seed, if available.

• Keep species mixes simple to avoid a fussy, artificial effect.

The landscape type-specific guidance (for Estuary Valley Sides) potentially relevant to the Proposed

Development and the Extension Site are:

• Retain mosaic of grassland, arable and woodland land use.

• Retain strong field boundaries marked by hedgerows and hedgerow trees.

• Restore hedgerows by filling in gaps and managing sympathetically.

• Plant new hedgerows across large fields, ideally on old boundary lines.

• Introduce field margins alongside hedgerows, ditches, woods etc.

• Permanent set-aside land can be used to good effect on agriculturally poor land.

• Retain and manage woodlands and copses. Woodlands are typically mixed, but broadleaved

species should predominate over conifers.

• New woodland can be established through planting or natural regeneration, providing it is not



• sited on land with existing habitat value.

• Create areas of grassland, heathland or scrub from marginal farmland, especially near the

shore.

• Where arable land reaches the shore, establish an uncropped 'buffer strip’.

Landscape Description and Characteristics

The Site is circa 23ha in plan area (although the area subject to the winning and working of minerals is

13.4 hectares in extent) and is generally flat (lying at circa 14m AOD, with a slight fall to the

south/southeast). The land was in arable agricultural use at the time of the fieldwork with large fields

largely bounded by hedgerows, with numerous hedgerow trees present (mostly English oak (Quercus

robur) with a small number of ash (Fraxinus excelsior) and field maple (Acer campestre)).

Referencing Plate 13 the northern boundary of the western sector of the Extension Site (Boundary A, to

Field 1) is delineated by a line of mature individual English Oak trees, possibly along the line of a previous

hedgerow. The western boundary (Boundary H) comprises of a hedgerow with trees, as does the

western section of the southern boundary (Boundary G). A number of gaps are present throughout (see

Figures L2 to L6, in Annex 2, and Plate 12, below (refer to photolocation ‘A’ on Figure L1, in Annex 2, for

location). A gappy hedgerow (aligned north-south), along Boundary I, splits the western sector of the

Extension Site from the eastern sector, and also forms the western boundary (Boundary B) of the

northern part of the eastern sector of the Extension Site (Field 2); this length containing a higher density

of trees along its length.

Plate 12 Illustrative view of hedges along (western) southern boundary of the Extension Site

A hedgerow (aligned north-south, along Boundary J) also splits the eastern sector of the Extension Site

into two (between Fields 2 and 3; an old sandpit marking (on old maps) the point where it meets the

northern boundary (Boundary C). A very gappy hedgerow / line of trees also form the eastern boundary

(Boundary D) of this part of the Extension Site. The southern boundary of the eastern sector of the



Extension Site (Boundary E) coincides with an established planted shelterbelt of deciduous trees (circa

20 years old and circa 20m wide). Two large 20th Century agricultural barns are present immediately

south of the Extension Site’s southern boundary (at the southern end of Boundary I), together with

adjacent hardstanding (see Figure L6, in Annex 2). Hedgerows are absent along this section of boundary.

Plate 13 Boundary and Field References

Public Rights of Way and Access Land

See Figure L1, in Annex 2. There are no Public Right of Way, other than public highways, within 500m of

the Extension Site. There is one Public Right of Way (public footpath) leading southeastwards from

Wolsey Bridge, circa 700m south of the southwest corner of the Extension Site. A permissive path

provided by Suffolk Wildlife Trust, from their Hen Reedbeds car park (circa 400m southwest of the

Extension Site), leads to this footpath.

A Byway Open to All Traffic (‘BOAT’) is present circa 650m north of the Extension Site.

The nearest ‘Access Land’ to the Extension Site is circa 2km to the south (see Figure L1, in Annex 2).

As shown in Plate 14 there are no National Cycle Routes within or immediately adjacent to the Extension

Site. One National Cycle Network route lies circa 0.9km northeast of the Extension Site at its closest

point (see Plate 14).



Plate 14 National Cycleway Routes

The A12 road passes circa 1.3km to the west-northwest of the Extension Site and the A1095 passes

alongside the southeastern boundary of the Extension Site. The B1126 passes within circa 600m of the

Extension Site, to the north.

A narrow local road (Mardle Road) passes immediately adjacent to the western-most boundary of the

Extension Site, joining the B1126 (from the north) to the A1095, to the southeast. A narrow track leads

northwestwards (joining with Hill Road circa 700m to the northwest) from the southwestern corner of

the Extension Site (where it forms a crossroads with Mardle Road – see Viewpoint 1). This highway forms

a slightly wider road from where it leads eastwards from the crossroads, and joins the A1095 after a

distance of 400m.

Water Courses and Water Bodies

There are no large waterbodies or water courses close to or adjacent to the Extension Site, the nearest

being the reedbeds and associated water at the confluence of the River Wang and River Blyth circa 400m

to the south. The River Wang runs from the northwest at a distance of between 500 and 1.2km from the

Extension Site (to the west and southwest), and further afield to the northwest of the Extension Site.

Settlement and Nearby Properties

Refer to Figure L1, in Annex 2, to assist in locating properties and land described below. Wangford village



lies circa 1.2km to the northwest and Reydon village circa 1.4km to the east.

To the immediate north are additional fields and small areas of woodland, with a residence at Reydon

Grange present circa 300m north of the boundary. A residence with holiday lettings facilities is also

present circa 200m to the west of the Extension Site’s northwestern boundary (at Wangford Farm, on

Mardle Road), with a woodland dell lying between these points, and circa 30m to the south of the

southern boundary of the Extension Site (at Lime Kiln Farm).

Agricultural land is generally present to the south and east, with a large ‘distribution centre’ for Adnams

Beers present circa 450m to the east, within an area of lower-lying land, within an old quarry and Reydon

Solar Farm present circa 600m to the east, on slightly elevated land, just off Quay Lane (all within the

AONB). To the west, there is a closed landfill site (Wangford Landfill Site) which was being capped and

restored at the time of the fieldwork, with an associated woodland plantation lying between the

Extension Site and the landfill. To the southwest is the remaining field within the Existing Quarry area

(due to be extracted) with the operational extraction area of the Existing Quarry just beyond. Small soil

bunds are also present. See Figure L3 in in Annex 2.

Landform

Contours showing the landform near the Extension Site are shown on Figure L1, in Annex 2. Generally, the

elevation varies little to the north and east of the Extension Site, for a distance of over 1.5km, being largely

flat, with only gentle changes in gradient. To the immediate east (at the Adnams site) there is a lower

landform present due to previous mineral extraction, with localised landscaped bunds present around the

distribution centre itself. To the west, Wangford Landfill has higher level associated with it (reaching circa

23m AOD, compared to circa 14m AOD within the Extension Site) with gradients largely between 1:6 and

1:10 present. The levels within Wangford Quarry itself are lower than at the Extension Site, with the

quarry base being circa 2mAOD. Side slopes are of steeper gradient, but range from circa 1:1 (extraction

slopes) through to 1:8, where restored.

Generally, to the south, southwest and southeast of the Extension Site, the land falls away towards the

convergence areas between the River Wang, River Blythe, Reydon Marshes and Bulcamp Marshes at Sea

Level. The land rises only very steadily to the south beyond there, reaching circa 5m AOD circa 2km to the

south.

The nearest private residences to the Extension Site are:

• Lime Kiln Farm, immediately south of the Extension Site – occupied by the owner of the Extension

Site;

• Wangford Farm (residence and B&B), circa 200m west of the northwestern-most corner of the

Extension Site;

• Cave Cottages, circa 260m south of the Extension Site;

• Reydon Grange, circa 300m north of the Extension Site;

• Toad Hall, circa 340m northwest of the Extension Site

• Wexford House, circa 500m north of the Extension Site; and

• Reydon Hall, circa 525m north-northwest of the Extension Site.



2.9 LANDSCAPE VALUE

Landscape Value is one aspect used to help determine the sensitivity of the landscape. Determination of

Landscape Value requires a degree of professional judgement, based on the findings in the desk studies

and field work. Overall Landscape Value is derived, in this assessment, using criteria on a number of

contributing factors (e.g. Scenic Quality), see Tables Ap1 – Ap10 in Methodology and Method of

Assessment in Annex 1.

Value of Landscape Character and Characteristics at the Extension Site

A number of aspects are relevant to determination of the Landscape value of the Extension Site and area

as described below:

Landscape Protection - The Site lies within the AONB.

Landscape Condition - The hedges within the Extension Site vary in their condition, some being

continuous and others gappy, with some parts appearing to have previously been hedges, but with only

trees now left standing. A number of hedgerows contain mature hedgerow trees.

Scenic Quality - The Site comprises of a relatively flat landform, with arable farmland characteristics with

mature trees and variable hedgerows. Visually prominent, detracting, modern agricultural outbuildings

are present on the Extension Site’s boundary.

Rarity - Small number of individual locally distinctive elements within the Extension Site and at its

periphery (e.g. continuous hedgerows and mature hedgerow trees).

Representativeness - The fields and elements such as hedgerows and hedgerow trees are typical of those

in the landscape character area and frequently found and representative of the landscape type.

Conservation Interest - There are no ecological designations within the Extension Site and there are no

cultural heritage features of note present within the Extension Site, but with the potential for local or

regionally important buried heritage elements to be present.

Tranquillity – There is a presence of local roads on two sides of the Extension Site with one A-class road

(the A1095 Halesworth Road) abutting the southern boundary of the Extension Site producing the most

noise.

Associations – No known associations with the Extension Site.

Recreational Value – No public rights of way pass through or adjacent to the Extension Site and the

Extension Site is not used for any recreational purposes.

Agricultural Value - According to the Agricultural Land Classification and Soil Survey report the agricultural

land quality relating to the Extension Site as being predominantly Grade 3b with a small area of Grade 3a

also being present.

The factors contributing to the landscape value of the Extension Site have been summarised in Table 9.



Table 9 Landscape Value of the Extension Site

Val

ue

Le

vel

Pro

tect

ion

Lan

dsc

ape

Co

nd

itio

n

Sc

en

ic Q

ual

ity

R

arit

y

Re

pre

sen

tati

ve-

ne

ss

Con

serv

atio

n

Inte

rest

s

Tran

qu

illit

y /

Wild

ne

ss

A

sso

ciat

ion

s

Re

cre

atio

nal

Val

ue

Agr

icu

ltu

ral

Val

ue

Very High

High

Medium

Low

Very Low

Overall, the characteristics and landscape character of the Extension Site have been assessed as having a

Medium landscape value, although there is significant variability between the individual aspects.

Value of Landscape Character and Characteristics of the Locality

The various aspects relating to the Value of Landscape Character and Characteristics of local area adjacent

to the Extension Site are described below.

Landscape Protection – The area surrounding the Extension Site is designated as AONB and the Extension

Site lies adjacent to an area designated as Heritage Coast.

Landscape Condition – The landscape condition of the immediate area is generally in variable with the

majority of fields being bounded by continuous hedgerows and mature hedgerow trees; although some

hedgerows are gappy in places. There has been a number of changes to the landscape nearby including

landfills, existing and restored operational quarry areas, and a solar farm. Other areas, to the north, and

further distance from the Extension Site appear to be in good condition.

Scenic Quality – The immediate area has some aspects that are likely to be considered to be aesthetically

pleasing, which include views across arable and pastoral fields, surrounded by hedgerows, mature trees

and woodland forming skylines. Detracting elements are busy roads, modern agricultural buildings,

landfill, solar farms and quarry elements – all in close proximity to the Extension Site. Areas more remote

from the Extension Site are likely to be considered to be more aesthetically pleasing.

Rarity – To the south, a highly distinctive landscape is present. In all other directions, the landscapes are

not as distinctive, and variable.

Representativeness – Landscape characteristics and character are a good example of its kind, e.g.

hedgerow, hedgerow trees, woodland and man-made (naturalised) meres.

Conservation Interest – To the south in particular, are wildlife designations of international importance.

Cultural Heritage features of note relating to the locality include dispersed Listed Buildings, and the



Registered Park and Garden at Henham to the west.

Tranquillity – This is primarily affected by well-used local roads and A-class roads. Human influences are

evident with scattered properties and villages present including other business developments, but away

from the roads, the landscape could be considered tranquil.

Associations – A number of associations, with individuals in history, without the links being specifically

landscape-related. Latitude (music and arts) festival is a more recent association with the locality.

Recreational Value – Relatively few opportunities to access the local landscape, given the presence of the

AONB, but with a network of general public rights of way are present in the wider area. Access to Hen

Reedbeds to the southwest and to land alongside the marshes is of greater note.

Agricultural Value – Natural England's Strategic maps of agricultural land quality relating to the locality is

generally a combination of Grade 3 and Grade 4 quality (www.magic.gov.uk).

The factors contributing have been summarised in Table 10.

Table 10 Landscape Value of Locality Outside the Extension Site

Val

ue

Le

vel

Pro

tect

ion

Lan

dsc

ape

Co

nd

itio

n

Sc

en

ic Q

ual

ity

R

arit

y

Re

pre

sen

tati

ve-

ne

ss

Con

serv

atio

n

Inte

rest

s

Tran

qu

illit

y /

Wild

ne

ss

A

sso

ciat

ion

s

Re

cre

atio

nal

Val

ue

Agr

icu

ltu

ral

Val

ue

Very High

High

Medium

Low

Very Low

Overall, the characteristics and landscape character of the local area near to the Extension Site have been

assessed as having a High landscape value.

2.10 VISUAL ANALYSIS

Introduction

This section describes the views available to and from the Extension Site, their distribution, character and

sensitivity to change. Crestwood has conducted an assessment of the views available to and from the

Extension Site through a combination of desk studies and fieldwork. Predicted visibility of the Proposed

Development is normally greater in winter (when trees and hedgerows have no leaves) and the

assessment has taken this into account.

http://www.magic.gov.uk/



Access to nearby properties with potential to have views of the Extension Site was sought. Where this

was not possible, photos from the residents were requested. A number responded positively to the

request and a number declined.

2.11 VISIBILITY

The area from where the Proposed Development would be visible was found to be extremely limited in

extent. A zone of ‘primary visibility’ (ZPV), indicating the approximate area from where it is predicted that

the Proposed Development would be most clearly noticeable to the casual observer, taking into account

hedgerow and tree cover in winter, is illustrated on Figure L1, in Annex 2. Visibility of the Proposed

Development beyond this zone is extremely limited due to the low-lying nature of the proposals within

the Mineral Extraction Area and the combination of a largely flat landscape to the north and east, the

woodland and landfill to the west and the lower land levels to the south, southwest and southeast. The

landform allows hedgerows and wooded areas to have a strong visual screening effect.

Generally, the primary visibility of the Proposed Development is likely to be restricted to an area very

close to the perimeter of the Extension Site, represented by Viewpoint locations 1 to 5 - see Figure L1, in

Annex 2. These are primarily from roadside locations, but are also representative of views from Wangford

Farm and Lime Kiln Farm (residence).

Additional secondary views (from outside of the ZPV) are illustrated from 3 locations (Viewpoints 6 to 8).

See Figure L1, in Annex 2.

Specific effort was made to request authorised access to nearby private properties to maximise

understanding and consideration of aspects such as residential visual amenity, upper storey views,

detailed use of the landholding etc. as follows (refer to Figure L1, in Annex 2):

• Lime Kiln Farm – upper window photographs provided by the occupant.

• Wangford Farm – request for access declined, no photographs provided by occupant.

• Cave Cottages – general fieldwork confirmed that no view would be possible from this property.

• Reydon Grange – request for access declined, no photographs provided by occupant.

• Toad Hall – general fieldwork confirmed that no view would be possible from this property.

• Wexford House – access provided, and illustrative photograph included in Figure L9.

• Reydon Hall – request for access declined, no photographs provided by occupant.

In addition to the above residents, access was also provided by Adnams allowing a photographic record

to made from their private property and an illustrative photograph is included in Figure L10.

2.12 VIEWPOINTS

The desk study, and examination and verification in the field enabled 8 viewpoints to be identified for

representative assessment (see Figure L1). ‘Viewpoints’ have been selected (upon consultation with the

MPA) to best represent the variety of views available from vantage points towards the Extension Site.

The selected views are contained at Viewpoints 1 to 8 and described in Table 11.



Table 11 Viewpoints (VPs)

VP

No.

Location

Distance to the

Extension Site

Reason for selection

1 From Mardle Road immediately southwest of the southwestern corner of the Extension Site.

0m Close range views representative of views from the highway of the Extension Site and new access – 2 views provided.

2 From Mardle Road immediately west of the western corner of the Extension Site.

0m

Close range view representative of views from the highway.

3

From Mardle Road west and northwest of the Extension Site.

180m

Close range view representative of views from the highway and Wangford Farm.

4

From highway immediately adjacent to Lime Kiln Farm

10m

Close range view representative of views from the highway and residential property of Lime Kiln Farm.

5

From A1095 near southern boundary of the Extension Site

5m

Close range view representative of views from the highway.

6 From purpose-built viewing platform on the Adnams Distribution Centre building

465m

Medium range view representative of views from Adnams Distribution Centre (illustrative).

7

From curtilage of property relating to Wexford House

390m

Medium range view representative of views from private land at Wexford House (residential).

8

From Public Footpath and access land at Walberswick Common

2km

Long range view representative of views from southern part of valley, within the AONB.

The predicted change in views in relation to the existing situation is described in the assessment section.



LANDSCAPE AND VISUAL ASSESSMENT

3.1 CONSULTATIONS

A number of consultations were made during the development of the proposals, which included

discussions on scope of the LVIA with the MPA, informal pre-application comments on draft restoration

proposals, public consultation events held by the Applicant and requests to gain access to private

properties near to the Extension Site (as described above).

3.2 ASSUMPTIONS AND LIMITATIONS

For the assessment, it is assumed that the Extension Site would otherwise continue to be used as

existing, should permission not be granted, as the ‘do nothing’ scenario.

Limitations to the visual impact assessment relate to access to private residential locations (e.g. first

floor views from windows), where this has largely not been possible. Cross-sectional and sightline

analyses and professional judgement have been applied in these situations with a high level of

confidence in the likely assessment outcome.

3.3 PREDICTED POTENTIAL IMPACT SOURCES

The predicted potential visual and landscape impacts are expected to relate primarily to the operational

period. The potential sources of impact (without mitigation measures applied) are identified in Table 12,

i.e. these sources have the potential to significantly and adversely affect views, visual amenity and

landscape character, both from within and from outside and have been used as the start point for the

assessment and design of mitigation.

Table 12 Sources of Impact likely to cause Significant Effects prior to mitigation

Source of Potential Impact

Change of land cover and landscape elements (during operational periods) potentially changing the landscape character and creating visual impacts – including:

- Addition of new elements, such as exposed sand, fencing, soil screens, tracks and processing plant.

- Removal (temporary and permanent) of existing elements, such as mature trees, hedgerows and fields.

Mineral extraction operations including movement associated with excavators, dump trucks, dozers (potentially causing noise impacts, affecting tranquillity) potentially creating visual and landscape impacts.

Temporary landform changes during mineral extraction and from soil screens and permanent landform changes upon restoration.

New access points between the Existing Quarry and the Mineral Extraction Area.

3.4 IMPACT AVOIDANCE AND MITIGATION MEASURES

Options Explored

Alternative directions and methods of working and restoration scheme configurations were all

considered when seeking the most effective scheme for the Proposed Development.

Additionally, a number of alternative locations to transfer the mineral to the Existing Quarry were

examined and relative landscape and visual effects (as well as noise, safety and practical considerations)

analysed to determine the best option. Importing of infill material to reinstate land levels to those pre-



development was not considered practical at the time of writing and was discounted early on in the

development of the proposals.

Embedded Mitigation

The Proposed Development has had the following impact avoidance and reduction measures

incorporated to mitigate adverse landscape and visual effects:

The proposed limit of mineral extraction has been designed through a combination of considerations.

The aim has been to strike a balance between the recovery of the mineral resource without incurring

significant adverse environmental effects. Retention of peripheral hedgerows and trees has been a key

aim and an arboricultural survey was undertaken (by the Applicant) to determine the tree retention

categories and appropriate root protection areas / stand-off distances. No works have been proposed

inside these stand-offs, where trees are retained, save for management of hedges and additional

planting.

Land at the periphery of the Extension Site is also required for the temporary storage of soil, for re-use

in restoration. The dimensions of the soil storage screens are governed by the volume required to be

stored, the additional requirements of the screens themselves (e.g. visual screening, noise attenuation)

and the acceptability of the storage (in terms of size and location) such that 1:4 maximum gradient

outward-facing slopes would be used with a maximum height of circa 2 metres for visual screens. These

screens would be limited to the maximum height required (with detailed design occurring on site, during

construction – but no higher than 3 metres) such that the required volume of soil is accommodated and

that the mineral extraction area is screened, from eye-level locations, whilst keeping skyline features

(e.g. distant woodlands) in the view, wherever possible. The bunds also provide acoustic attenuation,

helping to contain noise within the Extension Site, minimising potential adverse effects on tranquillity.

The mineral will be worked progressively in 6 phases, utilising the screening effects of the existing

landform, trees and hedgerows within the Extension Site. The progressive extraction will be coupled

with progressive restoration, to limit ‘land-take’ to the minimum possible.

Planting woodland, new hedgerows and hedgerow trees (including infilling gaps at key locations within

the existing perimeter hedgerow) at the earliest practical stage upon receipt of any consent and

managing thereafter to promote good growth will be undertaken to provide:

• Screening of the operations, the plant and soil screens;

• Enhanced landscape structure and habitat corridors; and

• An early contribution to the restoration scheme.

A suitable, restoration scheme, characteristic of the locality, and following the landscape guidelines for

the AONB and character areas has been designed to provide a characteristic farmland-based landscape,

with smaller mosaic of habitats within the confines of site-specific constraints.

Peripheral hedgerows are of variable quality/condition around the Extension Site. Gapping-up and

additional hedgerow tree planting will be undertaken in the first available year to improve visual

screening and to enhance the landscape condition of these elements. Management will be undertaken

of existing hedgerows to ensure that they are between 2 and 2.5 metres height and have a dense

shrubby form to maintain their screening potential and to provide a landscape function (as a stock-proof

barrier and as an ecological corridor and habitat).



3.5 EFFECTS ON LANDSCAPE CHARACTERISTICS AND CHARACTER

Landscape Value (see Section 2.9) is Medium, within the Extension Site, and High, near the Extension

Site. Based on Table Ax 12 the Landscape Susceptibility to the Proposed Development is considered to

be Medium, i.e. Landscape characteristics have a degree of susceptibility to change and there is some

scope to replace these elements without adversely affecting the character. Distinguishable landscape

structure, few or no features worthy of conservation; may contain occasional detracting features.

The determination of Landscape Sensitivity is guided by Table Ap13, reproduced below:

The Landscape Sensitivity to the Proposed Development is considered to be Medium.

The determination of magnitude of landscape effect is guided by Table Ax 13, as reproduced below.

Magnitude of Landscape Effect

Landscape Criteria

Very Large

Typically, large scale changes and/or numerous changes to important landscape characteristics

Large

Typically, large scale changes to some landscape characteristics, or a high number of medium scale changes to the landscape characteristics

Medium

Typically, some medium scale changes to some landscape characteristics

Small

Typically, a low number of medium scale changes to landscape characteristics, or a number of small scale changes to landscape characteristics

Very Small

Typically, occasional, small scale changes to unimportant landscape characteristics

Operational Period

During the operational period of the Potential Development, there will be progressive reduction in land

levels and uncharacteristic (of the natural landscape) temporary steep extraction slopes near the

periphery of the Mineral Extraction Area, with circa 2-3m high vegetated screening bunds also present.

As the Extension Site is not overlooked, except from Lime Kiln Farm itself, the adverse effects of this

aspect will be largely limited to within the Extension Site itself. Although not a positive characteristic of

the landscape, this (and mineral extraction, generally) is not a new landscape characteristic (having

historically been present in close proximity to the north and east of the Extension Site, and being

currently present at the Existing Quarry). Progressive restoration will assist in limiting adverse landscape

effects of the active Mineral Extraction Area, by limiting the area of ‘land-take’ at any moment in time.



The operational period of the Proposed Development would take place after extraction at the Existing

Quarry has been largely completed, minimising the potential for combined landscape effects. Removal

of the existing congruous land cover elements (farmland, existing landform, hedgerows and 4 hedgerow

trees and woodland) will take place during the operational period over a number of phases coupled with

progressive restoration to minimise operational ‘land-take’.

The addition of new temporary grassed soil screens (incongruous elements) and congruous new

hedgerow, hedgerow trees and woodland elements will also take place during the operational period.

The level of tranquillity afforded at the Extension Site and immediate areas will reduce during the short

(up to 8 weeks) annual periods of soil removal and earthworks. Also, tranquillity will be affected by

increased road traffic accessing the Existing Quarry along the new short access road. The Proposed

Development (operations) are not a wholly uncharacteristic element of the landscape but will create an

adverse effect for a Long-term duration overall (with specific areas of mineral extraction affected on a

phase-by-phase basis for a Short-term duration). Enhancement and mitigation planting improvements

will be incorporated in Year 1 (hedgerow gapping-up and new tree planting).

Restoration, Aftercare and Residual Periods

The landform will be permanently altered, creating a new landform in the landscape that would be

appreciable only from close-range locations. Restored slopes of maximum gradient 1:8 provide the

ability to maximise the agricultural capability of the largest area of land and have the least effect on

landscape character. Restored slopes of up to 1:4 maximum gradient are considered acceptable in

smaller areas, through provision of naturalistic variation in slope profile and appropriate non-

agricultural land cover.

The general changes in landform will have a marginal adverse effect on landscape character, but will

allow:

• The retention of productive agricultural uses (at least in the basal area of the ‘depression’);

• The planting of trees and hedgerows (with the visual ‘experience’ of the landscape character

(from outwith the Extension Site) being replicated most effectively by locating this on higher

areas); and

• The opportunity to provide ecological enhancements (in terms of semi-natural habitats).

New positive elements will be added upon restoration, including agricultural grassland restoration,

with in-built enhancements for ecology and with the addition of new areas of broadleaved native

woodland, new and gapped-up hedgerows and hedgerow trees. Strengthening of ecological value and

landscape elements (and thereby landscape character) is provided via:

• Strengthening existing hedgerows (via gapping-up planting and management) and bridging gaps

between retained and new hedgerows;

• Providing continuity of presence of individual hedgerow trees into the future, via new planting;

• Incorporation of characteristic semi-natural habitats (e.g. neutral grassland scrub, linking the

restoration scheme into that of the Existing Quarry to provide a wider network of

complementary habitats, or generally linking similar habitats within the locality to improve

habitat connectivity);



• Providing conservation headlands at the periphery of restored arable fields;

• Providing preferential receptor infiltration areas, for surface water run-off, providing new

ephemeral wetland habitats; and

• Improving of agricultural land quality by reducing droughtiness providing an increase in area of

Best and Most Versatile agricultural land over the baseline

The restored Site will reflect the wider landscape character, and respond positively to the landscape

guidelines for the AONB and landscape character areas. The key characteristics of the Extension Site will

be retained, together with some enhancements, once the restoration elements mature, with the

influence of the reduced levels and landform being extremely localised in nature. The remaining residual

characteristics upon restoration will contribute a number of desirable elements, retaining and enriching

the essential aspects of the landscape character area. See Table 13 for a comparison of habitats/land-

use between the pre-development situation and post-restoration.

Table 13 Habitat and Land-use Comparison

The landscape sensitivity of the landscape character to this type of development is considered to be

Medium.

The main changes are unavoidable for this type of development (i.e. loss of 3 trees within the centre of

the Extension Site and to accommodate safe visual splays for access, and changes to the land levels

(without importing fill material)). The magnitude and nature of effect on the landscape character area

during the phased operational period (phased effects occurring for a Short-term duration with full term

effects lasting for a Long-term duration) is considered to be Medium and Adverse.

The key landscape characteristics will be permanently restored with an increase in woodland,

hedgerows, trees and other habitats, with a marginal decrease in agricultural land. The overall ratio of

habitats would be improved to reflect the landscape character types better whilst targeting quality

improvements in habitats, connectivity and landscape elements (e.g. increased woodland, hedgerows,

agricultural land quality), within the constraints of the residual landform and restoration material

availability. Upon restoration, the magnitude of effect on a ‘site only’ basis, is Small (and essentially

limited to the Extension Site’s landscape character); the magnitude of effect on the landscape character

area is also Small, and Neutral in nature for the residual period (Very Long-term duration).



The derivation of Significance generally follows a pattern by which the relationship between sensitivity

and magnitude contributes to the level of significance as shown diagrammatically below:

Using the principles set out in the diagram above and Table Ax 15(see Annex 1) the adverse effects on

landscape characteristics during the operational period are considered to be of Moderate Significance,

having some effect on the landscape characteristics and landscape character without exceeding the

landscape capacity threshold. Key characteristics would be retained and not be affected to a Significant

degree.

Generally, upon establishment of the restoration, there will be an enhancement with regards to the

condition and ‘quality’ of the landscape characteristics within the Extension Site overall but with a largely

neutral effect on landscape character. Whilst there would be a reduction in the area of farmland and a

change to the original landform, the replacement habitats are characteristic elements in the natural area

and so will be considered to have an equally positive effect. The positive effects will strengthen with

time as the landscape elements mature.

The (overall) residual effect on the landscape characteristics at the Extension Site and locality is

considered to be neutral (not significant). There would be some effect on the landscape characteristics

and landscape character with those changes keeping within the threshold of change. Key characteristics

would be retained and enhanced but not affected to a Significant or notable degree.

3.6 EFFECTS ON VISUAL AMENITY

The presentation of the assessment of visual effects has focused on representative viewpoints that

represent a range of sensitive locations with the potential to be affected to a significant level.

Eight viewpoints have been selected (after consultations with the MPA) to best represent the range of

sensitive viewpoint locations and main effects within the Study Area, and elsewhere, and are primarily

illustrated using photographs in Figures L2 to L10. Additional illustrative photographs have been

included in the main text to further assist the reader, where appropriate.

Close range views are taken to be from viewpoints within 0.25km. Medium-range views from between

0.25 and 1.0km and Long-range views from over 1.0km from the Extension Site. The criteria for

Sensitivity of visual receptors is provided in Table Ax 16, as reproduced below:



Visual Sensitivity

Value and Susceptibility to Change Criteria

Typical Receptor Types/Locations

Very High

Nationally well recognised and advertised location for high visual amenity value

Prominent location or vista with high visual amenity value that is recognised in published sources.

Very high susceptibility to change as a very high level of attention focussed on the landscape and particular views.

Nationally promoted Long Distance Footpath users. Protected View recognised in planning policy designation.

Visitors to nationally advertised attractions where visual amenity is very important to their enjoyment.

Private views from primary living space regularly used in daylight hours where the focus is on a landscape of recognised very high value.

High

Well-known area recognised regionally for high landscape value.

Open areas of recognised public access where primary enjoyment is of the views of the landscape.

High susceptibility to change as a high level of attention focused on the landscape and particular views.

Users of local advertised circular, recreational or well-used footpath routes and open access land where primary enjoyment is from the landscape and visual amenity.

Road and rail users on routes through landscapes recognised for their high scenic value.

Private views from areas of a property curtilage occasionally used in daylight hours, e.g. access drives, where the focus is on the landscape beyond private curtilage.

Medium

Locations afford views of some value, but visual amenity not well recognised beyond locality.

Moderate susceptibility to change as a moderate level of attention focussed on the landscape and particular views.

General recognised public access routes (road and rail routes) with some landscape interest.

Public houses, restaurants etc. where views would include some focus on the wider landscape.

Views from recreational sport areas which may involve some incidental appreciation of views of the wider landscape, e.g. golf or fishing.

Private views from residential properties from rooms not normally occupied in waking or daylight hours, e.g. bedrooms.

Low

Viewpoint context and location is of lesser value than similar views from nearby visual receptors that may be more accessible.

Low susceptibility to change as low level of attention focussed on the landscape and particular views.

Views from recreational sport areas which does not involve or depend upon appreciation of views of the landscape, e.g. football, rugby, speedway.

Minor road routes where passengers would have limited focus on a landscape of no recognised value.

People at their places of work where the main focus is not on the surrounding landscape context.

Very Low

Viewpoint context is such that views have a very low value.

Expectations of visual amenity are very low.

Activity at viewpoint is incidental to the view.

People at their place of work where there the type of activity has no relationship to the surrounding landscape context.

The representative viewpoint locations are shown on Figure L1. Table 14 shows the viewpoint locations

with an indication of the receptor groups represented and the visual sensitivity of these receptors.



Table 14 Summary Visual Sensitivity of Receptors at Viewpoints (VPs)

Viewpoint No.

Location Description Receptors Represented

Sensitivity

1 From Mardle Road immediately southwest of the southwestern corner of the Extension Site.

Road users

Low

2 From Mardle Road immediately west of the western corner of the Extension Site.

Road users

Low

3

From Mardle Road west and northwest of the Extension Site.

Residents High

Road users Low

4

From highway immediately adjacent to Lime Kiln Farm.

Residents High

Road users Low

5 From A1095 near southern boundary of the Extension Site. Road users Low

6 From purpose-built viewing platform on the Adnams Distribution Centre building.

Workers / Visitors

Low

7 From curtilage of property relating to Wexford House. Residents Medium

8 From Public Footpath and access land at Walberswick Common. Walkers High

The assessment of visual effects uses professional judgement to ascertain levels of Significance through

levels of contribution of sensitivity (as described above), magnitude and nature of effect. The Magnitude

of effect is provided in Table Ax 17, as reproduced below. This is not necessarily the same as magnitude

of change in the view, as the nature of the change in the residual view may be no different overall,

despite large changes having occurred.

Magnitude of Visual Effect

Typical Visual Criteria

Very Large

Where the proposals become the only dominant feature in the view and to which all other elements become subordinate. Typically involves direct views at close range over a wide horizontal and vertical extent.

Large

Where the proposals would form a significant and immediately apparent element of the scene and would affect the overall impression of the view. Typically involves direct or oblique views at close range with notable changes over the horizontal and vertical extent.

Medium

Where proposals would form a visible and recognisable new development but where it is not intrusive within the overall view. Typically involves direct or oblique views at medium range with a moderate horizontal and/or vertical extent of the view affected.

Small

Where proposals constitute only a minor component of the wider view, which the casual observer could miss or where awareness does not affect the overall quality of the scene. Typically involves an oblique view at medium or long range or a direct view at long range with a small horizontal/vertical extent of the view affected.

Very Small Where only a very small part of the development is discernible or that it is at such a distance that the effects are scarcely appreciated.

The derivation of Significance generally follows a pattern by which the relationship between sensitivity

and magnitude contributes to the level of significance as shown diagrammatically below:



Assessment from Viewpoint 1

Individual Visual Effects on Viewpoint 1

Viewpoint 1 is from Mardle Road immediately southwest of the southwestern corner of the Extension

Site; see Figures L2 and L3. The view represents those obtained by local highway users and have been

assessed as having a Low visual sensitivity.

The view takes in the field where mineral extraction will start and the access route from the Extension

Site to the Existing Quarry. The main changes will occur in year 1 when the soil bunds and the access

points will be created and the planting up of gaps in the existing hedgerow. Due to the linear nature of

the roads/field boundaries, the visual effect of loss of hedgerow and 1 tree will be minimal. Once bund

are in place, the screening provided by these will limit views to glimpse passing views into the immediate

area of the Extension Site and of vehicles using the access track. The new hedgerow planting and

enhanced management of existing hedgerows will gradually increase the visual screening of the bunds

and traffic. The majority of the existing trees on the skyline will be retained.

Upon restoration and removal of soil bunds, there will be minimal views into the Extension Site from tis

location due to the visual screening effects of the hedgerow.

The magnitude of adverse effect is considered to be Large initially, reducing to Medium as the hedgerow

screening increases. There would be a neutral effect upon restoration. The level of visual effect is

assessed as being Moderate, reducing to Moderate-Minor as screening increases. The visual effects are

not considered to be Significant.

Cumulative Visual Effects

The visual effects in combination with those potentially arising from the Existing Quarry are not

considered to be different to the individual effects assessed above, due to the lack of visibility of the

Existing Quarry except from the new access points (assessed above) from hedgerow screening and

timing of restoration.



Viewpoint 2 is from Mardle Road immediately west of the western corner of the Extension Site; see

Figure L4. The view represents those obtained by local highway users and have been assessed as having

a Low visual sensitivity.



The view takes in the field where mineral extraction will start and is currently comprised of open views

of the field (through large gaps in the hedgerow) and modern farm buildings associated with Lime Kiln

Farm, with trees forming the skyline. The main changes will occur in year 1 when the soil bund is created

and the planting up of gaps in the existing hedgerow takes place. Once the bund is in place, views of the

Mineral Extraction Area will not be afforded. The new hedgerow planting and enhanced management

of existing hedgerows will gradually increase the visual screening of the bunds. Themselves. The majority

of the existing trees on the skyline will be retained.

Upon restoration and removal of soil bunds, there will be minimal views into the Extension Site from tis

location due to the visual screening effects of the hedgerow A farmland scene with tree-lined skylines

would be present beyond.

The magnitude of adverse effect is considered to be Medium initially, reducing to Small as the hedgerow


assessed as being Minor-Moderate, reducing to Minor as screening increases. The visual effects are not

considered to be Significant.


No combined cumulative visual effects are anticipated.



Viewpoint 3 is from Mardle Road 180m west and northwest of the Extension Site; see Figure L5. The

view represents those obtained by local highway users (Low visual sensitivity) and residents/visitors to

Wangford Farm Bed and Breakfast (High visual sensitivity).

The view takes in a field which is not part of the Proposed Development, with horizon trees and

hedgeline marking the location of the boundary of the Extension Site in the view. Buildings associated

with Lime Kiln Farm are also visible in the distance. The western boundary in the view is hedge-lined and

the northern boundary in the view is not. This boundary would be planted to hedgerow in year one and

a 2m high bund installed prior to mineral extraction. This would also result in the lowering of levels

within the Mineral Extraction Area, with levels quickly reducing as mineral extraction progresses. Activity

within the Extension Site, from the road and Wangford Farm, is expected to be minimal.

Upon restoration and removal of soil bunds, there will be no discernible change in the view.

The magnitude of adverse effect is considered to be Small initially, reducing to Very Small as the

hedgerow screening increases and as levels in the mineral extraction area reduce. There would be a

neutral effect upon restoration. The level of visual effect is assessed as being Moderate, reducing to

Minor-Moderate as visibility decreases further, for residents and visitors to Wangford Farm, and Minor

to Negligible for road users. The visual effects are not considered to be Significant.


No combined visual effects are anticipated.





Viewpoint 4 is from the highway immediately adjacent to Lime Kiln Farm, south of the Extension Site

(near to but not wholly representative of view from Lime Kiln Farm itself); see Figure L6. Buildings lie

between the residence and the Extension Site, restricting views to upper storey locations from the

residence itself. The residents provided their own photographs from upper storey locations to help

inform the assessment (see Plate 15). A similar (but oblique) view is also available from an attic location.

No other views of the Proposed Development from Lime Kiln Farm were available.

The view (in Figure L6) represents those obtained by local highway users (Low visual sensitivity) and

residents of Lime Kiln Farm (Medium visual sensitivity) - Plate 15.

Plate 15 View from first floor of Lime Kiln Farm towards the Extension Site

The view from the roadside takes in the field where initial extraction would take place. Acoustic and

visual screening bunds would be created before mineral extraction begins and advance planting

undertaken at the periphery between the viewpoint and the bunds. This would screen views into the

Extension Site whilst retaining the skyline of trees. As the interlying vegetation develops and matures,

the view of the bunds would decrease. Upon restoration and removal of soil bunds, there will be no view

into the Extension Site due to the screening effects of the interlying vegetation.

The magnitude of adverse effect is considered to be Medium initially, reducing to Small as the planting


assessed as being Minor-Moderate, reducing to Minor as visibility decreases further, for road users. The

visual effects are not considered to be Significant.



For the residents of Lime Kiln Farm the bund would screen part of the Extension Site, but some views

into the Mineral Extraction Area would be possible. Allowing the hedgerow to grow taller (circa 3m) and

additional hedgerow trees located along this specific length of hedgerow would assist in further

screening the specific views, if desired by the landowner. Upon restoration there would be a woodland

farmland aspect to the view. The magnitude of adverse effect is considered to be Medium-Large. The

level of visual effect is assessed as being Moderate, There would be a neutral effect upon restoration.

The visual effects are not considered to be Significant.





Viewpoint 5 is from the A1095 Halesworth Road immediately south of the Extension Site (within the

Heritage Coast designated area); see Figure L7. The view is a specific view where otherwise woodland

screens views of the Extension Site, and so would form a glimpsed view for passing road users. The visual

sensitivity is Low.

The view is of the fields in the eastern part of the Extension Site, with a vista formed into the agricultural

area by the woodland in the foreground. The view would only be affected from Phase 3 onwards, when

a 2m high screen bund would be installed. No views within the Extension Site would then be possible,

except from elevated positions (e.g. trucks). Upon restoration, a similar view would prevail to existing,

until the new woodland establishes beyond, which would then form the view.

The magnitude of adverse effect is considered to be Small. There would be a neutral effect upon

restoration. The level of visual effect is assessed as being Minor, for road users. The visual effects are

not considered to be Significant.





Viewpoint 6 is from an elevated viewing platform on Adnams’ Distribution Centre building, circa 465m

to the east; see Figure L8. No other views into the Extension Site are generally afforded from the area

around the building. The visual sensitivity is Low.

The view takes in the restored quarry area within Adnams’ landholding, with the partially Site visible in

the background. The Site would be worked towards the viewpoint, limiting views through retention of

intervening higher landform. As the working nears the abutting Site boundary more of the Extension

Site will be visible beyond, where restoration will take place first. Upon restoration, a similar view would

prevail to existing.

The magnitude of adverse effect is considered to be Medium. There would be a neutral effect upon

restoration. The level of visual effect is assessed as being Minor-Moderate, for workers and visitors to

the platform area. The visual effects are not considered to be Significant.







Viewpoint 7 is from the curtilage of property relating to Wexford House; see Figure L9. No other views

into the Extension Site are generally afforded from the property (including first floor views). The visual

sensitivity is Medium.

The viewpoint represents the worst case location for the potential for views to be afforded from the

property at Wexford House. The view takes in agricultural land with two lines of hedgerow lying between

the viewpoint and the Extension Site. Although the roof of Lime Kiln Farm can just be seen in the

background, no views of the Proposed Development would be possible, even in winter.

There will be no effect on this viewpoint.





Viewpoint 8 is from a Public Footpath adjacent to access land at Walberswick Common; see Figure L10.

This viewpoint was included to demonstrate the effect on views from within the AONB to the south of

the valley, across from the Extension Site – where there was potential to gain views of dumper trucks

accessing between the Extension Site and the Existing Quarry. The visual sensitivity is High.

The viewpoint represents the worst case location for the potential for views towards the Extension Site

from the south side of the valley. No views of the Existing Quarry or Mineral Extraction Area would be

possible. The access road and vehicles using it would form a very small component of the view and would

be easily missed during casual observations. The access road and planting bund would screen views of

the dumpers and integrate the access point into the view. The magnitude of effect would be Very Small.

The level of visual effect is assessed as being Minor-Moderate, for these High sensitivity visual receptors.

The visual effects are not considered to be Significant.



3.7 OTHER VIEWPOINTS

Residents at Reydon Grange and Reydon Hall are unlikely to experience views of the Proposed

Development due to interlying vegetation and distance from the Mineral Extraction Area.

No views from Toad Hall or Cave Cottages are anticipated.

There is potential for glimpse views of the access road from the A1095, from more elevated positions,

as it passes close by (e.g. from coaches). Due to the fleeting nature of the view, the screening proposed



and the non-continuous use of the track by traffic, no significant visual effects are anticipated.

3.8 SEQUENTIAL CUMULATIVE VISUAL EFFECTS

No significant sequential cumulative visual effects are anticipated, as no continuous routes (e.g. National

Trails or other PRoW) pass through the ZPV.

CONCLUSION

Minerals can only be worked they are found and although development may generally be

preferentially be steered away from intrinsically valued environmentally designated areas, temporary

mineral development can be considered acceptable, once proportionate impact assessments have

been undertaken and a suitable design, responding to the findings of the impact assessments, has been

devised. Adverse effects on landscape and visual receptors have been acknowledged during the

assessment process.

None of the adverse visual effects is considered to be Significant. The adverse effects on visual amenity

are limited to a maximum level of Moderate with others generally of a lower level.

The adverse effects on the landscape character are limited to a Moderate level during the operational

period within the Extension Site, and Minor level in relation to the wider landscape character, and not

Significant.

Whilst there would be a modest reduction in the area of farmland, and a small change to the original

landform, the replacement land-uses and habitats are characteristic elements in the natural and

landscape character area. The key characteristics of the locality’s landscape character will be considered

to have been retained (non-Significant effect).

The purpose of designating an AONB is to conserve and enhance the natural beauty of the AONB,

however, landscape character, visual amenity, tranquillity and biodiversity are all intrinsically linked

when considering the conservation of ‘scenic beauty’ (as referred to in the NPPF) and ‘natural beauty’

(as referred to in the CRoW Act) within the AONB, as is recognised by the objectives and actions in the

AONB Management Plan. These various aspects have been considered in the development of the

proposals and, together, the combination of the effects on each of these aspects is not considered to

result in overall degradation of the scenic beauty or natural beauty experienced, in particular as nearby

areas (the adjacent landfill and the Existing Quarry) are restored, and due to the very limited area of

influence that the Extension Site and the Proposed Development has within the wider AONB.

Adverse effects on the ‘scenic beauty’ and ‘natural beauty’ within the AONB are therefore considered

to be limited and the potential for long-term enhancement, through implementation of the proposed

restoration scheme is good, such that compliance with national and local policies would be readily

achievable.

The Site lies outside of the Heritage Coast designation, but the Extension Site is close to its boundary,

between which a 20m wide established woodland belt is present. Effects on views of the Proposed

Development will be limited to a Minor level, from a specific viewpoint, so no ‘experiential’ effects on

the landscape within will be created by the Proposed Development, such that the Heritage Coast would

retain its ‘undeveloped’ character.

This LVIA has assessed that the Extension Site and Proposed Development does not provide landscape



or visual constraints or effects that would be considered to be Significant, or overriding, either during

the operational period or upon restoration.



REFERENCES:

▪ Landscape Institute, 2011. Photography and Photomontage in Landscape and Visual Impact Assessment (Advice Note 01/11). s.l.:s.n.

▪ MAFF, 1988. Agricultural Land Classification of England and Wales - Revised Guidelines and Criteria for Grading the Quality of Agricultural Land. s.l.:s.n.

▪ Ministry of Housing, Communities and Local Government, 2018. National Planning Policy Framework. s.l.:s.n.

▪ Natural England, 2013. National Character Area Profile. In: s.l.:s.n.

▪ Natural England, 2014. An Approach to Landscape Character. In: s.l.:s.n.

▪ The Landscape Institute, 2013. Guidelines for Landscape and Visual Impact Assessment (Third Edition). In: s.l.:s.n.



ABBREVIATIONS / ACRONYMS:

For the avoidance of confusion, abbreviations used have the meanings given below:

AGL Above Ground Level SINC Site of Importance for Nature Conservation

AGLV Area of Great Landscape Value SLINC Site of Local Importance for Nature Conservation

AOD Above Ordnance Datum SSSI Site of Special Scientific Interest

AONB Area of Outstanding Natural Beauty TPO Tree Preservation Order

AVR Accurate Visual Representation VEM Visual Envelope Map

c. Circa ZVI Zone of Visual Influence

CoP Code of Practice ZTV Zone of Theoretical Visibility

CWS County Wildlife Site ZPV Zone of Primary Visibility

DEM Digital Elevation Model ZSV Zone of Secondary Visibility

DSM Digital Surface Model

DTM Digital Terrain Model

EA Environment Agency

FOV Field of View

GIS Geographical Information System

LCA Landscape Character Area

LCT Landscape Character Type

LNR Local Nature Reserve

LPA Local Planning Authority

LVA Landscape and Visual Appraisal

LVIA Landscape and Visual Impact Assessment

LWS Local Wildlife Site

MPA Mineral Planning Authority

NCA National Character Area

NGR National Grid Reference

NNR National Nature Reserve

NPPF National Planning Policy Framework

NPPG National Planning Policy Guidance

OS Ordnance Survey

POS Public Open Space

PDL Previously Developed Land

RCA Regional Character Area

RIGS Regionally Important Geological Site

SAC Special Conservation Area

SAM Scheduled Ancient Monument



GLOSSARY:

For the avoidance of confusion, the terms used in this report follow the definitions given below:

Landscape

An area, as perceived by people (in relation to past experiences, education etc.), whose character is the result of the action and interaction of natural and/or human factors. Landscape may comprise areas of rural land, urban fringe, urban land (townscape), coastal land, the sea (seascape) etc.

Townscape

The character and composition of the built environment including the buildings and the relationships between them, the different types of urban open space, including green spaces, and the relationship between buildings and open spaces.

Seascape Landscapes with views of the coast or seas, and coasts and adjacent marine environments with cultural, historical and archaeological links with each other.

Landscape Element

A component part of the landscape (e.g. landform, roads, hedges, woods).

Landscape Feature

A prominent eye-catching element (e.g. wooded hilltop or church spire).

Landscape Characteristics

Combinations of elements and experiential characteristics (e.g. noise, smell) that make a particular contribution to a Landscape Character Type.

Landscape Receptor

Defined aspects of the landscape that have the potential to be affected by a Proposed Development.

Landscape Scene

The landscape characteristics discernible from a given viewpoint/location. The visual aspects of this can be illustrated in a static two-dimensional manner in photographs to represent a sample view of the landscape scene.

Landscape Character

The distinct recognisable pattern of elements that occurs consistently in a particular landscape and how people perceive this, creating a particular sense of place.

Landscape Character Types

LCTs refer to multiple areas of the same character.

Landscape Character Areas

LCAs refer to specific geographical locations of a particular character type. These can be described and categorised at different scales depending on criteria used.

Landscape Condition

The strength of expression of landscape character and intactness of constituent characteristic elements from visual, functional, ecological and cultural perspectives. This is not the same as Scenic Beauty.

Landscape Capacity

The threshold at which change to the landscape resource results in significant change to its landscape character. This is directly related to landscape sensitivity.

Landscape Susceptibility

The ability of a defined landscape receptor (e.g. landscape characteristics) to accommodate the specific Proposed Development without undue negative consequences.

Landscape Value

The desirability of landscape characteristics (including scenic beauty, tranquillity, wildness, cultural associations, conservation interests etc.) and the acceptability of their loss to different stakeholders (i.e. valued for different reasons by different people and on different scales, e.g. local, national).

Landscape Sensitivity

The level of stability, robustness and resilience of landscape receptors and their ability to be replicated based on their quality, condition and value. Landscape sensitivity is based on a combination of judgements on landscape susceptibility and landscape value.

Landscape Receptor

Landscape element, characteristic or character that would potentially receive/experience an effect.



Visual Receptor

Individuals, special interest groups, a community or population that would potentially experience an effect on their view.

Scenic Beauty / Scenic Quality

Subjective value attributed to the emotional response of an individual to a landscape scene, which, although heavily influenced by intrinsic condition, is also conditioned by an individual's perception (memories, associations, cultural influences and preference).

Visual Amenity The subjective value attributed to the degree of pleasure gained from what is seen in a given view (quality of view).

Visual Sensitivity

The estimated level of susceptibility or likely viewer’s response to a change in view from a given viewpoint in relation to its context, the existing visual amenity, the activity and expectations of the viewer and the number of viewers affected.

Tranquillity

Subjective experience from being at a location that provides individuals with the space and conditions to relax, achieve mental balance and a sense of distance from stress. Tranquil areas are often associated with quiet, remote (or appearing remote), natural, non-developed (non- built) and non-busy areas.

Impacts and Effects

‘Impact’ refers to an action being taken and an ‘effect’ is the change resulting from that action. The process of assessing effects arising from development is commonly referred to as ‘impact assessment’. ‘Impacts’ and ‘effects’ are often used interchangeably.

Significant Effect

Directive 2011/92/EU (The assessment of the effects of certain public and private projects on the environment) requires member states to assess the likely significant effects of a project (e.g. development) on the environment before determining whether consent should be given. This requirement has been transposed via Environmental Impact Assessment (EIA) Regulations. This LVIA refers to significance (or level) of effects in the wider sense, to mean positive (beneficial) or negative (adverse) environmental effects that are important (material) considerations in the decision-making process, whether assessed as part of an EIA or otherwise. This is directly related to set criteria and terminology as set out within the assessment process. Significant effects, on balance, may with other considerations, be acceptable or unacceptable in overall planning terms.

Site Visibility The areas within which the subject site can be seen, the amount of site visible and the numbers able to see the subject site.

Zone of Theoretical Visibility (ZTV)

Also known as a Zone of Visual Influence (ZVI), Visual Envelope Map (VEM) and Viewshed. This represents the area over which a development can theoretically be seen, based on a DTM. The ZTV usually presents a ‘bare ground’ scenario - that is, a landscape without screening structures or vegetation. This information is usually presented upon a map base.

Zone of Primary Visibility (ZPV)

The Zone of Primary Visibility (ZPV) represents the geographical area from which the Proposed Development would represent a notable new element in the view and therefore where significant landscape and/or visual effects are likely to occur without further consideration (e.g. secondary mitigation).

Zone of Secondary Visibility (ZSV)

A Zone of Secondary Visibility (ZSV) can be used to represent the geographical area from which the Proposed Development may be visible without being a notable new element in the view or where views are partly restricted or are from greater distances, and therefore where significant landscape and/or visual effects are unlikely to occur after Primary Mitigation measures have been taken into account.

Digital Terrain Model (DTM)

Also known as a digital elevation model (DEM). This is a digital representation of the ground surface (landform or terrain) created by linking co-ordinate points of surveyed elevation values to create a 3D ‘model’ which computers can use to undertake calculations relating to slope angles, point visibility, flood risk etc.

Digital Surface Model (DSM)

As per a DTM except that it relates to the levels of surfaces above the ground where present (e.g. vegetation or roof levels).

http://en.wikipedia.org/wiki/Digital

http://en.wikipedia.org/wiki/Surface

http://en.wikipedia.org/wiki/Terrain



Field of View (FOV)

Term used to describe the height and width of a view as represented by an image. These constitute the horizontal field of view and vertical field of view and are expressed as angles in degrees. Humans have an extreme horizontal field of view of about 200°, but only 6-10° will be in focus at any one time. Thus a viewer moves their eyes and head around to see a view over a wide area.

Enhancement A measure resulting in a beneficial effect which is not related to any adverse effect.

Mitigation

A measure to avoid, reduce or remedy adverse effects (principally significant effects) caused by the proposed development. These may be defined at Primary and Secondary Mitigation measures.

Primary (1o) Mitigation

Mitigation measures which have either been developed through the iterative design process and which have become integrated or embedded into the project design, or are commitments to utilise best practice techniques to avoid or minimise adverse effects (e.g. industry best practice guidance on construction).

Secondary (2o) Mitigation

Mitigation measures that have been designed to address any adverse effects remaining after Primary Mitigation measures have been incorporated into the project design (i.e. residual adverse effects).


CE-LY1271-RP03 - FINAL 26/11/18

ANNEXES:

ANNEX 1 METHODOLOGY AND METHOD OF ASSESSMENT ANNEX 2 FIGURES

LIST OF ANNEX TABLES:

TABLE AX 1 VALUE IN RELATION TO LANDSCAPE PROTECTION TABLE AX 2 VALUE IN RELATION TO LANDSCAPE CONDITION TABLE AX 3 VALUE IN RELATION TO SCENIC QUALITY TABLE AX 4 VALUE IN RELATION TO RARITY TABLE AX 5 VALUE IN RELATION TO REPRESENTATIVENESS TABLE AX 6 VALUE IN RELATION TO CONSERVATION INTEREST TABLE AX 7 VALUE IN RELATION TO TRANQUILLITY/WILDNESS TABLE AX 8 VALUE IN RELATION TO ASSOCIATIONS TABLE AX 9 RECREATION VALUE TABLE AX 10 AGRICULTURAL VALUE TABLE AX 11 OVERALL LANDSCAPE VALUE (EXAMPLE ONLY) TABLE AX 12 SUSCEPTIBILITY TO CHANGE OF LANDSCAPE RECEPTORS TABLE AX 13 LANDSCAPE SENSITIVITY TABLE AX 14 MAGNITUDE OF LANDSCAPE EFFECTS TABLE AX 15 SIGNIFICANCE OF LANDSCAPE EFFECTS TABLE AX 16 SENSITIVITY OF VISUAL RECEPTORS TABLE AX 17 MAGNITUDE OF VISUAL EFFECTS TABLE AX 18 SIGNIFICANCE OF VISUAL EFFECTS TABLE AX 19 CATEGORISATION OF CUMULATIVE EFFECTS


Annex 1: 62 CE-LY1271-RP03 - FINAL 26/11/18

Annex 1 METHODOLOGY AND METHOD OF ASSESSMENT

Ax 1.1 GENERAL

Ax 1.1.1 This assessment has been undertaken in accordance with:

• The Guidelines for Landscape and Visual Impact Assessment (third edition), published

April 2013 by the Landscape Institute and Institute of Environmental Management and

Assessment;

• An Approach to Landscape Character (Natural England, 2014); and

• Photography and Photomontage in Landscape and Visual Impact Assessment (Advice

Note 01/11), published February 2011 by the Landscape Institute.

Ax 1.1.2 The assessment considers two separate (but inter-related) components:

• effects on the Landscape; and

• effects on Views.

Ax 1.1.3 As the two components are inter-related, the assessment of one has been undertaken alongside

the other and this resultant document referred to as the Landscape and Visual Appraisal (LVA)

or Landscape and Visual Impact Assessment (LVIA).

Ax 1.1.4 The assessment process aims to:

• establish the baseline situation;

• identify potential sources of direct and indirect impact;

• identify impact receptors and estimate their sensitivity;

• Estimate the magnitude and nature of effects;

• appraise alternatives and indicate additional/alternative measures of impact avoidance,

mitigation or offset, where possible;

• re-estimate the magnitude and nature of effects; and

• provide an assessment of the significance of the mitigated effects and relate this back to

the relevant Landscape Planning Policies.

Ax 1.1.5 The assessment of alternativeness is not presented in detail within this report.

Ax 1.1.6 The assessment includes a combination of objective and subjective judgements. Subjective

judgements are avoided where possible, focussing on what would be experienced rather than

making assumptions regarding people’s expected responses.

Ax 1.1.7 The assessment allows for worst-case scenarios, although indications are given as to the effects

under ‘normal conditions’ also, e.g. seasonal effects of vegetation.

Ax 1.1.8 No specific assessment has been made, in this report, of impacts on the historic landscape

character of the area or any cultural heritage receptors such as Scheduled Monuments and

Listed Buildings.

Ax 1.1.9 The detailed assessment process and terminology used is specific to this assessment. This is



further described below with the intended meaning of some specific terms explained in the

glossary provided.

Ax 1.2 BASELINE SITUATION – GENERAL

Ax 1.2.1 Both the landscape and visual assessment components have been undertaken against a set of

Baseline Conditions (the Baseline Situation), which has been established during the first stage

of the assessment process, using a combination of desk study and field survey work. This

provides a transparent basis from which assessment results have been determined and against

which professional judgements have been made.

Ax 1.2.2 The baseline used may be different for the landscape and visual impact assessment of specific

development proposals assessed:

• in isolation (i.e. where development is assessed on its own merits); and

• in combination with other developments creating a similar effect (i.e. the cumulative

landscape and visual effects of a number of similar developments).

Ax 1.2.3 The baseline used has been detailed in the assessment assumptions, in the relevant section.

Ax 1.2.4 The study of the Baseline Situation includes a review of available document sources (e.g.

published Landscape Character Assessments, landscape policy guidance), Ordnance Survey map

data, historical maps, aerial photographs and the undertaking of a field survey.

Ax 1.2.5 During the field survey, the principal landscape elements and features were recorded which,

depending on their prominence and importance, contribute to the overall character of the area.

Typical elements may include landform, land use, watercourses, vegetation, built

development/infrastructure and areas of public access.

Ax 1.2.6 A check of the likely visibility of the development proposals is also made during the field survey,

with a photographic record made and visual receptor information noted.

Ax 1.3 BASELINE SITUATION – LANDSCAPE ASPECTS

Ax 1.3.1 A description of the landscape characteristics is provided in relation to the Extension Site itself

and the surrounding landscape. Further analysis of the existing landscape is also made to

determine aspects such as Landscape Condition, Landscape Value (non-monetary) and site

visibility (see glossary) to assist in the determination of landscape sensitivity.

Historic Landscape Aspects

Ax 1.3.2 Research of historic aspects of the landscape in this document is limited to sites designated for

historic-related reasons and changes observed between older maps and aerial photographs

where relevant.

Baseline Situation – Visual Aspects

Zones of Primary Visibility (ZPV)

Ax 1.3.3 A zone of primary visibility (ZPV) has been produced, based on field analysis, to indicate where

the Proposed Development is predicted to form a noticeable element of the view to the casual

observer.



Viewpoints

Ax 1.3.4 During the field study, a photographic record was made to represent the range of potential

views towards the Extension Site, from available viewpoints within the study area. These

locations are mapped, the visual receptor types recorded and viewpoint landscape context

described. No access to private properties has been obtained during the field study. Estimates

of visibility have been made using computer software modelling where required.

Ax 1.3.5 The photographs have been taken using a digital SLR camera using a 50m m focal length (35 mm

format equivalent) lens.

Ax 1.3.6 Viewpoints may be categorised as follows:

• Representative Viewpoints – selected to represent the experience of different types of

visual receptor, where larger numbers of viewpoints cannot all be included individually and

where the effects are unlikely to differ;

• Specific Viewpoints – selected because they are key and sometimes promoted viewpoints

within the landscape; and

• Illustrative Viewpoints – Selected specifically to demonstrate a particular effect or specific

aspect (e.g. screening).

Ax 1.3.7 From the record of identified visual receptors and general visibility viewpoints have been

determined and used in the assessment process. These have been included to reflect the

locations which represent a range of available views and which are typically representative of

views of visual receptors most likely to incur significant visual effects within the ZPV.

Ax 1.3.8 The photographs used to illustrate the assessment have been ‘stitched’ together using digital

imaging software to provide a ‘panorama image’, thus providing a visual context to the focus of

the centre photograph. The photographs have been corrected for lens distortion and to correct

changes of scale across the photograph and a cylindrical projection used to ensure consistency

of scale across the panorama, vertically and horizontally when viewed on printed paper.

Ax 1.4 ASSESSMENT OF LANDSCAPE EFFECTS

General

Ax 1.4.1 Landscape receptors can be described in a number of ways. Landscape effects derive from

changes to landscape receptors which include the physical landscape (landscape elements),

which may give rise to change in how the landscape is experienced. These individual

contributors to landscape character are termed ‘landscape characteristics’. Areas with similar

landscape characteristics can be described as having a certain landscape character or of being

a particular Landscape Character Type (LCT). Where these are specific to a geographical area

they are referred to as Landscape Character Areas (LCAs). These can be described and

categorised at different scales depending on criteria used.

Ax 1.4.2 The context of a location, in its wider setting, can influence the experience of the landscape and

therefore its landscape character. Therefore, changes in the landscape character at one location

can potentially affect the context of another landscape character type. In certain situations this

can have an effect on the setting of valued or important landscape elements (e.g. registered

parks and gardens).



Ax 1.4.3 The landscape impact assessment describes the likely nature and scale of changes to individual

landscape elements and characteristics and the consequential effect on the landscape character

in relation to the development site itself and on the wider landscape. Due to the inherently

dynamic nature of the landscape, it can be accepted that change arising from a development

may not necessarily be significant.

Landscape Sensitivity

Ax 1.4.4 Landscape sensitivity can vary for landscape characteristics and landscape character. The

specific sensitivity of landscape character to change is referred to as landscape character

sensitivity.

Ax 1.4.5 Landscape (character) sensitivity relates to the combination of:

• the (non-monetary) value of the landscape receptors, which is established at the baseline

stage; and

• the susceptibility of the landscape receptors to change in relation to the Proposed

Development.

Landscape Value

Ax 1.4.6 Value of landscape receptors is affected by a number of factors:

• Landscape Protection - through designation or strength of landscape policies/strategy aims

associated with a landscape or its constituent parts;

• Landscape Condition - Subjective value attributed to the emotional response of an

individual to a landscape scene, which, although heavily influenced by intrinsic condition, is

also conditioned by an individual's perception (memories, associations, cultural influences

and preference);

• Scenic Quality - Subjective value attributed to the emotional response of an individual to a

landscape scene, which, although heavily influenced by intrinsic condition, is also

conditioned by an individual's perception (memories, associations, cultural influences and

preference);

• Rarity - The presence of rare elements or features in the landscape or the presence of a

rare Landscape Character Type;

• Representativeness - Whether the landscape contains a particular character and/or

features or elements which are considered particularly important values;

• Conservation Interests - The presence of features of wildlife, earth science or

archaeological or historical and cultural interest where this adds value to the landscape;

• Wildness/tranquillity - The presence of wild (or relatively wild) character in the landscape

(e.g. rivers, sea) which makes a particular contribution to sense of place; closely associated

with tranquillity (i.e. the subjective experience from being at a location that provides

individuals with the space and conditions to relax, achieve mental balance and a sense of

distance from stress;

• Associations - With particular people, (e.g. artists, writers) or events in history that

contribute to perceptions of the natural beauty of the area;

• Recreation Value - Evidence that the landscape is valued for recreational activity where



experience of the landscape is important; and

• Agricultural Value – Evidence that the landscape is valued for its agricultural use,

referencing known site surveys, farmer knowledge and resources such as the ALC of

England and Wales (MAFF, 1988).

Landscape Value: Geographical level of landscape protection

Ax 1.4.7 International designations (e.g. World Heritage Sites) would be classed as the highest level

under this category, whereas the lowest would be where there are no designations, where there

never have been any designations and where the landscape policy or strategy advocates the

need for substantial change to improve the landscape. Relative ratings for this aspect are

indicated in Table Ax 1:

Table Ax 1 Value in relation to Landscape Protection

Value Level

Relevant Criteria

Very High

Statutory, international or national landscape designation and/or policies/strategies which reflect this level of protection to change.

High

Current, non-statutory, local landscape designation based on up-to-date assessment methods and criteria and/or policies/strategies which reflect this level of protection to change.

Medium

Previous local landscape designations which are no longer in place but which reflect some previous value to society and/or reflected in some restrictions to change in local policies/strategies.

Low

Landscape never been designated although some relevant general local policies in place to prevent harmful development from detracting from the landscape.

Very Low

Landscape never been designated and active policies/strategies in place to promote improvements to a poorly-valued landscape.

Landscape Value: Landscape Condition

Ax 1.4.8 Relative ratings for this aspect are indicated in Table Ax 2:

Table Ax 2 Value in relation to Landscape Condition

Value Level

Relevant Criteria

Very High

Consistently, characteristics are in very good condition and present in a unified manner.

Landscape and cultural elements are all intact and in a strong functional and visual condition.

In rural landscapes, diverse range of large and continuous habitats of very high importance.

High

Characteristics in good condition but not in unified manner: interrupted character.

Landscape and cultural elements are mostly in a strong functional and visual condition.

In rural landscapes, the semi-natural habitats are fairly large, closely clustered and frequent allowing relatively easy cross-interaction.

Medium

Generally, characteristics in good condition but sometimes masked or disrupted by incongruous elements: small level of deterioration evident.

Visual and functional condition of characteristic landscape and cultural elements generally (but not necessarily entirely) reasonable; some evidence of decline.

In rural landscapes, the semi-natural habitats are in relatively discrete but medium-sized units with some opportunity for cross-interaction.



Low

Weak or degraded landscape character with a small number of characteristics present and at least as many incongruous elements present.

Visual and functional condition of landscape and cultural elements generally poor.

In rural landscapes, the semi-natural habitats are of limited area and patchy, providing limited opportunity for cross-interaction.

Very Low

Heavily degraded landscape character dominated by incongruous elements in poor condition.

Land has been subject to extensive alteration of distinctive landscape components removing its historical and cultural significance.

In rural areas, fragmented semi-natural vegetation present, too isolated to allow natural repopulation.

Landscape Value: Scenic Quality


Table Ax 3 Value in relation to Scenic Quality

Value Level

Relevant Criteria

Very High

No detracting characteristics. Presence of diversity and balance of form, colour, texture and contrast with interesting or captivating scenery in an aesthetically pleasing and uncommon way.

High

Occasional detracting characteristics. Presence of some diversity and balance of form, colour, texture and contrast with interesting scenery, in an aesthetically pleasing way.

Medium

Some detracting characteristics balancing a number of aesthetically pleasing aspects, but fairly common over the locality.

Low

A number of detracting characteristics, with little variation or colour, texture, form or contrast generally outweighing aesthetically pleasing positive contributing characteristics to the scene.

Very Low

Few, if any, positive characteristics present within the scene with no balance or diversity, little interest and very low aesthetic appeal.

Landscape Value: Rarity


Table Ax 4 Value in relation to Rarity

Value Level

Relevant Criteria

Very High Internationally or nationally distinctive, rare landscape characteristics contributing to individual character.

High

Regionally distinctive, rare landscape characteristics contributing to individual character.

Medium

Locally distinctive landscape characteristics contributing to local character.

Low

Occasional individual locally distinctive landscape characteristics.

Very Low

Very commonly found, indistinctive landscape characteristics present.



Landscape Value: Representativeness


Table Ax 5 Value in relation to Representativeness

Value Level

Relevant Criteria

Very High

Landscape characteristics / character of an exceptional example of its kind.

High

Landscape characteristics / character of an good example of its kind.

Medium

Occasionally found examples of similar landscape characteristics / character.

Low

Fairly frequently found examples of similar landscape characteristics / character.

Very Low

Commonly encountered examples of similar unremarkable landscape characteristics / character.

Landscape Value: Conservation Interests


Table Ax 6 Value in relation to Conservation Interest

Value Level

Relevant Criteria

Very High Numerous and/or extensive international or nationally important features or elements of wildlife, earth science, archaeological, historical or cultural interest.

High Frequent (some of international or national importance) features or elements of wildlife, earth science, archaeological, historical or cultural interest.

Medium Some regionally or locally important features or elements of wildlife, earth science, archaeological, historical or cultural interest.

Low Occasional locally important features or elements of wildlife, earth science, archaeological, historical or cultural interest.

Very Low

Few, if any, elements of wildlife, earth science, archaeological, historical or cultural interest.



Landscape Value: Tranquillity/Wildness


Table Ax 7 Value in relation to Tranquillity/Wildness

Value Level

Relevant Criteria

Very High

Strong sense of remoteness or isolation with virtually no obvious human influences present – Relative abundance of landscape characteristics contributing to an experience of tranquillity.

A Tranquil Area.

High

Secluded parts of the landscape are wild in character, where there is a sense of remoteness or isolation. Human influences are not dominant, with settlement being sparsely distributed. Occasional minor detractors to an experience of tranquillity.

Medium

Wildness is not a strong contributing characteristic and human influences are evident, with scattered villages and other development present, detracting from an experience of tranquillity, which would be confined to localised places.

Low

Human presence is more dominant with a corresponding lack of wildness evident, despite some rural influences. Experience of tranquillity would be rare in this landscape.

Very Low

Human presence in terms of people, noise, movement and development dominant such that there is an absence of tranquillity or wildness.

Landscape Value: Associations


Table Ax 8 Value in relation to Associations

Value Level

Relevant Criteria

Very High Landscape strongly associated with internationally prominent people, artists or writers or internationally important well-known events in history.

High Landscape associated with nationally prominent people, artists or writers or nationally important well-known events in history.

Medium Landscape widely associated with locally prominent people, artists or writers or locally important events in history.

Low Landscape associated, to some, with locally prominent people, artists or writers or locally recorded but minor events in history.

Very Low Landscape associations limited to local knowledge of locally well-known people or local minor events only.



Landscape Value: Recreation Value


Table Ax 9 Recreation Value

Value Level

Relevant Criteria

Very High

Internationally recognised or promoted area or routes for tourism and recreational use (e.g. National Park, European Long Distance Footpath) and very well used generally recreationally by more distant visitors and local population.

High

Nationally or regionally promoted areas of open recreation or routes for such use (e.g. country park, National Trail, Scenic Routes). Other commercial uses (e.g. golf course, fishing, boating). Generally well-used for recreation from visitors and local population.

Medium Open general access available or general public rights of way where appreciation of the landscape is linked to its use. Fairly well-used for recreation locally.

Low Permissive, informal or general access routes or land where appreciation of the landscape not a strong link to its use. Used by some of local population.

Very Low

Access and recreational value limited or absent due to incompatible land-uses.

Landscape Value: Agricultural Value


Table Ax 10 Agricultural Value

Value Level

Relevant Criteria

Very High Agricultural capability is typically excellent or very high (generally equivalent to ALC Grade 1 or 2) – ‘Best and Most Versatile’ (BMV) agricultural land.

High Agricultural capability is typically good (generally equivalent to ALC Grade 3a) – ‘Best and Most Versatile’ (BMV) agricultural land.

Medium

Agricultural land typically of moderate quality (generally equivalent to ALC Grade 3b).

Low

Agricultural land typically of poor quality (generally equivalent to ALC Grade 4).

Very Low

Agricultural land is typically absent or of very poor quality (generally equivalent to ALC Grade 5).

Landscape Value: Summary

Ax 1.4.17 The assessment of Landscape Value is undertaken as appropriate for the receiving landscape

receptors (e.g. the Extension Site, or a location within an adjacent character area) and

summarised in a table (example as per Table Ax 11) and subsequently given an overall

assessment of landscape value provided for the landscape receptor, with further explanation

provided where required. The Overall Landscape Value in the example below would be Medium.



Table Ax 11 Overall Landscape Value (example only)

V

alu

e L

eve

l

Pro

tect

ion

Lan

dsc

ape

Co

nd

itio

n

Sce

nic

Qu

alit

y

Rar

ity

Rep

rese

nta

tiv

e-n

ess

Con

serv

atio

n

Inte

rest

s

Tran

qu

illit

y /

Wild

ne

ss

Ass

oci

atio

ns

Re

cre

atio

nal

Val

ue

Agr

icu

ltu

ral

Val

ue

Very High

High

Medium

Low

Very Low

Landscape Susceptibility

Ax 1.4.18 Susceptibility refers to the ability of landscape receptors to accommodate changes brought

about by the Proposed Development. Relevant criteria are provided in Table Ax 12.

Table Ax 12 Susceptibility to Change of Landscape Receptors

Susceptibility

Relevant Criteria

Very High

Key landscape characteristics highly susceptible to change and very difficult to replace without affecting the existing character. Strong landscape structure with many distinct characteristics worthy of conservation.

High

Landscape characteristics susceptible to change and fairly difficult to mitigate without affecting the existing character. Typically of recognisable landscape structure and some features worthy of conservation.

Medium

Landscape characteristics with a degree of susceptibility to change; some scope to replace these elements without adversely affecting the character. Distinguishable landscape structure, few or no features worthy of conservation; may contain occasional detracting features.

Low

Landscape characteristics of low susceptibility to change or easily replaced and potentially enhanced. Weak landscape structure or transitional in nature; some evidence of degradation and a number of detracting features.

Very Low

Landscape characteristics are not susceptible to change. High probability to mitigate or replace the lost elements and to enhance the existing landscape. Damaged landscape structure, evidence of severe disturbance or dereliction; detracting features dominate.

Assessment of Landscape Sensitivity

Ax 1.4.19 Landscape Susceptibility and Landscape Value are then assessed in combination to provide an

overall rating in terms of Landscape Sensitivity, with professional judgement applied and

described. Generally this follows the relationship as shown in



Table Ax 13 Landscape Sensitivity

Magnitude of Landscape Effects

Ax 1.4.20 The Magnitude of change is concerned with the scale of change to the landscape characteristics,

the geographical extent of this change and the duration/reversibility of the changes. The

magnitude of landscape effects have been categorised as follows in Table Ax 14.

Table Ax 14 Magnitude of Landscape Effects

Magnitude of Landscape Effect

Landscape Criteria

Very Large

Typically, large scale changes and/or numerous changes to important landscape characteristics

Large

Typically, large scale changes to some landscape characteristics, or a high number of medium scale changes to the landscape characteristics

Medium

Typically, some medium scale changes to some landscape characteristics

Small

Typically, a low number of medium scale changes to landscape characteristics, or a number of small scale changes to landscape characteristics

Very Small

Typically, occasional, small scale changes to unimportant landscape characteristics

Ax 1.4.21 In general, the duration weighting applied to magnitude is as follows:

• Very Long term effect: 15+ years

• Long term effect: 8 to 15 years

• Medium term effect: 3 to 8 years

• Short term effects: 1 to 3 years

• Temporary effect: Less than 12 months

Ax 1.4.22 Where variations between relevant criteria, duration etc. occur, reasoned professional

judgement is applied and described in the assessment to determine the magnitude of effect.



Nature of Landscape Effect

Ax 1.4.23 Changes to landscape characteristics can be of a positive, negative or neutral nature. The

determination of the nature of effect on landscape receptors is related to the Baseline Situation

and what is recognised to be either a desirable or an undesirable change (e.g. from assessments

of landscape quality, landscape policy guidance). A neutral effect may occur, for example, if a

characteristic element is replaced with a different but equally characteristic element. Therefore,

it is possible for there to be a large magnitude of change but with a neutral effect overall.

Significance of Landscape Effects

Ax 1.4.24 The significance of a landscape effect (from an impact) is a function of the sensitivity of the

affected landscape receptor, the magnitude of change and the nature of effect. While the

methodology is designed to be robust and transparent, professional judgement is ultimately

applied to determine the significance of each effect.

Ax 1.4.25 The degree of landscape significance is defined in Table Ax 15. These are different for beneficial

and adverse effects. Generally, an effect, which is greater than a ‘Moderate’ significance, is likely

to be a pertinent ‘material consideration’ in the decision-making process.



Table Ax 15 Significance of Landscape Effects

Significance

Adverse Landscape Effects

Beneficial Landscape Effects

Negligible

Overall, typically, there may be some Small scale, Short-term impacts but virtually no lasting adverse effect on existing landscape character.

Overall, typically, there may be some Small scale Short-term positive impacts but virtually no lasting beneficial effect on existing landscape character

Minor

Typically:

Some Small-Medium scale effects on existing landscape character in poor condition.

Very Small or Temporary changes to Medium sensitivity landscape.

Minimal effect on landscape character.

Overall, typically, landscape character and condition is slightly improved via strengthening of some valued characteristic landscape elements for a Long-term duration, in high and Very High sensitivity landscapes where limited scope to provide improvement exists, or

Some shorter duration improvements to landscapes of lower sensitivity

Moderate

Typically:

Large scale and Long term changes to landscapes and/or landscape receptor of low sensitivity.

Some Medium scale changes to Medium sensitivity landscape and/or landscape receptor.

Very Small or Temporary changes to highly sensitive landscape and/or landscape receptor.

Noticeable effect on the landscape and/or landscape receptor without exceeding the landscape capacity threshold.

Overall, typically, landscape character and condition is improved via the introduction of characteristic landscape elements and the removal of incongruous landscape elements:

Permanently and greatly in highly sensitive areas;

For a number of characteristics for a Medium-Long- term duration in areas of Medium landscape sensitivity;

For a small number of characteristics for a Short- Medium-term duration in lower sensitivity landscapes

Major

Typically:

Numerous Long-term effects on Medium sensitivity landscape and/or landscape receptor.

Small permanent effects on highly sensitivity landscape and/or landscape receptor.

Landscape receptor and/or character is affected to a significant degree.

Overall, typically, landscape character and condition is significantly improved via removal of some existing incongruous landscape elements and introduction/restoration of some valued characteristic landscape elements in lower and Medium sensitivity landscapes where much scope to provide improvement exists

Substantial

Proposals are at complete variance with many key characteristics of a very highly valued landscape.

Proposals would remove substantial numbers of existing incongruous landscape elements and introduce a number of highly desirable landscape elements to substantially restore an area of landscape character of high potential landscape value for a Very Long-term period

The derivation of the level of significance (of effect) uses professional judgement taking into

consideration the contributing factors of sensitivity, magnitude and nature of effect and generally

follows a pattern by which the relationship between sensitivity and magnitude contributes to the level

of significance as shown diagrammatically in Diagram 1. It should be noted that, strictly, notable or

Significant effects only need to be determined, not the assessed level of all effects, but it is



acknowledged that levels of effects can be a useful aid when reading and understanding the

assessment.

Diagram 1 General Relationship Between Magnitude, Sensitivity and Significance

Ax 1.5 ASSESSMENT OF VISUAL EFFECTS

General

Ax 1.5.1 Visual effects relate to the experienced changes that arise in the composition of available views

due to changes in a landscape scene, and to the overall effects with respect to visual amenity.

Effects are defined as the relationship between the visual sensitivity, the magnitude of change

and the nature of the effect.

Visual Sensitivity

Ax 1.5.2 The sensitivity of the visual receptor will be influenced by the value attached to views (which is

established at the baseline stage) and the susceptibility to change, in relation to the

development proposed.

Ax 1.5.3 Judgements on value take into account any recognised importance of the view (e.g. in relation

to valued landscapes or features, or through planning designations) and any indicators of value

attached to views by visitors e.g. guidebooks and tourist maps.

Ax 1.5.4 Susceptibility to change, in relation to the development proposed, is influenced by the

following factors:

• location and context of the viewpoint;

• characteristics of the view, e.g. whether it is continuous or intermittent and static or

transient; and

• the activity or expectations of the receptor at the viewpoint.

Ax 1.5.5 In terms of private residential receptors, whilst it is an accepted planning principle that there is

‘no right to a view’ residents are recognised as having the potential to be particularly susceptible

to changes in their visual amenity. Locations (rooms) normally used in waking or daylight hours

are usually considered more sensitive than other locations.

Ax 1.5.6 The indicative terminology in Table Ax 16 was used as a guide to describe sensitivity with regard

to visual receptors.



Table Ax 16 Sensitivity of Visual Receptors

Visual Sensitivity

Value and Susceptibility to Change Criteria

Typical Receptor Types/Locations

Very High

Nationally well recognised and advertised location for high visual amenity value

Prominent location or vista with high visual amenity value that is recognised in published sources.

Very high susceptibility to change as a very high level of attention focussed on the landscape and particular views.

Nationally promoted Long Distance Footpath users. Protected View recognised in planning policy designation.

Visitors to nationally advertised attractions where visual amenity is very important to their enjoyment.

Private views from primary living space regularly used in daylight hours where the focus is on a landscape of recognised very high value.

High

Well-known area recognised regionally for high landscape value.

Open areas of recognised public access where primary enjoyment is of the views of the landscape.

High susceptibility to change as a high level of attention focused on the landscape and particular views.

Users of local advertised circular, recreational or well-used footpath routes and open access land where primary enjoyment is from the landscape and visual amenity.

Road and rail users on routes through landscapes recognised for their high scenic value.

Private views from areas of a property curtilage occasionally used in daylight hours, e.g. access drives, where the focus is on the landscape beyond private curtilage.

Medium

Locations afford views of some value, but visual amenity not well recognised beyond locality.

Moderate susceptibility to change as a moderate level of attention focussed on the landscape and particular views.

General recognised public access routes (road and rail routes) with some landscape interest.

Public houses, restaurants etc. where views would include some focus on the wider landscape.

Views from recreational sport areas which may involve some incidental appreciation of views of the wider landscape, e.g. golf or fishing.

Private views from residential properties from rooms not normally occupied in waking or daylight hours, e.g. bedrooms.

Low

Viewpoint context and location is of lesser value than similar views from nearby visual receptors that may be more accessible.

Low susceptibility to change as low level of attention focussed on the landscape and particular views.

Views from recreational sport areas which does not involve or depend upon appreciation of views of the landscape, e.g. football, rugby, speedway.

Minor road routes where passengers would have limited focus on a landscape of no recognised value.

People at their places of work where the main focus is not on the surrounding landscape context.

Very Low

Viewpoint context is such that views have a very low value.

Expectations of visual amenity are very low.

Activity at viewpoint is incidental to the view.

People at their place of work where there the type of activity has no relationship to the surrounding landscape context.

Magnitude of Visual Effects

Ax 1.5.7 The magnitude or scale of visual change is described by reference to:

• Scale of Change;

• Geographical Extent; and

• The Duration and Reversibility of the effect.



Ax 1.5.8 The Scale of Change takes into account the loss or addition of features in the view and changes

in the composition of the view including the proportion of the view occupied by the Proposed

Development. The extent of contrast or integration of any new features or changes in the

landscape scene with the existing or remaining landscape elements and characteristics in terms

of form, scale and mass, line, height, colour and texture is also considered.

Ax 1.5.9 The Geographical Extent will vary with different viewpoints and is likely to reflect the:

• angle of view in relation to the main activity of the receptor;

• proximity of the viewpoint to the Proposed Development; and

• the extent of the area over which the changes would be visible.

Ax 1.5.10 Viewpoint proximity to the Extension Site was classed as follows:

• Close-range: Within 250m

• Medium-range: Between 250m and 1km

• Long-range: Over 1km

Ax 1.5.11 In general, the Duration and reversibility considerations applied to magnitude are as follows:

• Very Long term effect: 15+ years

• Long term effect: 8 to 15 years

• Medium term effect: 3 to 8 years

• Short term effects: 1 to 3 years

• Temporary effect: Less than 12 months

Ax 1.5.12 The terminology in Table Ax 17 was adopted for the definition of magnitude of visual effects:

Table Ax 17 Magnitude of Visual Effects

Magnitude of Visual Effect

Visual Criteria

Very Large

Where the proposals become the only dominant feature in the view and to which all other elements become subordinate. Typically involves direct views at close range over a wide horizontal and vertical extent.

Large Where the proposals would form a significant and immediately apparent element of the scene and would affect the overall impression of the view. Typically involves direct or oblique views at close range with notable changes over the horizontal and vertical extent.

Medium

Where proposals would form a visible and recognisable new development but where it is not intrusive within the overall view. Typically involves direct or oblique views at medium range with a moderate horizontal and/or vertical extent of the view affected.

Small

Where proposals constitute only a minor component of the wider view, which the casual observer could miss or where awareness does not affect the overall quality of the scene. Typically involves an oblique view at medium or long range or a direct view at long range with a small horizontal/vertical extent of the view affected.

Very Small Where only a very small part of the development is discernible or that it is at such a distance that the effects are scarcely appreciated.



Ax 1.5.13 Where variations between relevant criteria occur, reasoned professional judgement is applied

and described in the assessment to determine the magnitude of effect.

Nature of Visual Effect

Ax 1.5.14 Changes to view can be of a positive, negative or neutral nature. The determination of the

nature of effect on view is related to the Baseline Situation and what is considered to be either

a desirable or an undesirable change. The assessment of the nature of visual effect focuses on

what is experienced, although some professional judgement has (by necessity) been applied to

consider the subjective matter of whether the change could generally be received by the visual

receptors as positive, negative or neutral. The assumptions and judgements made are reasoned

in the text.

Significance of Visual Effects

Ax 1.5.15 The significance of visual effects (from an impact) is a function of the sensitivity of the affected

visual receptor, the magnitude of change and the nature of effect. While the methodology is

designed to be robust and transparent, professional judgement is ultimately applied to

determine the significance of each effect.

Ax 1.5.16 The results of the assessment have been presented by providing a brief description of the

existing view from each principal representative viewpoint/receptor, followed by a description

of changes to the view and the landscape scene and an analysis of the magnitude and nature of

the effects.

Ax 1.5.17 The significance of visual effects is defined in Table Ax 18. These are different for beneficial and

adverse effects. Generally, an effect which is of ‘Major’ significance, or above, is likely to be a

pertinent ‘material consideration’ in the decision-making process.



Table Ax 18 Significance of Visual Effects

Significance

Adverse Visual Effects

Beneficial Visual Effects

Negligible

Adverse effect has minimal significance due to low visual amenity even from otherwise sensitive viewpoints.

Produces only very slight deterioration to views.

Beneficial effect has minimal significance due to limited scope to improve existing view even from sensitive viewpoints.

Provides only very slight improvement to views.

Minor

Typically:

Large-very large scale deterioration to low sensitivity views of low quality.

Small scale deterioration to lower and Medium sensitivity views of high quality.

Very Small-Medium scale deterioration to higher sensitivity receptors with low existing visual amenity.

Typically:

Medium scale improvements to existing views with high visual amenity and Medium sensitivity.

Small scale improvements to views of low visual amenity from low sensitivity viewpoints.

Very Small scale improvements to low quality high sensitivity views.

Moderate

Typically:

Noticeable Long-term or Large scale deterioration in low sensitivity but high quality views.

Medium scale deterioration to Medium sensitivity high quality views and Very Large changes to low quality views.

Small scale and Temporary deterioration in Highly sensitive and high amenity value views and larger scale deterioration in low quality views.

Typically:

Noticeable large-scale improvement in unimportant views with low existing visual amenity and visual sensitivity.

Small to Medium scale improvements to views from Medium and High sensitivity viewpoints with low existing visual amenity.

Very Small scale improvements in existing low visual amenity from Very High sensitivity viewpoints.

Major

Typically:

Medium scale deterioration in High sensitivity, high quality views, or larger scale deterioration in High sensitivity but lower quality views.

Small scale deterioration to higher sensitivity views of high quality.

Considerable Long-term deterioration in Medium sensitivity views of high amenity value.

Typically:

Large to Very Large scale improvements at Medium to High sensitivity locations.

Medium to Large scale improvements to High sensitivity viewpoints with low existing visual amenity.

Substantial

Clear and obvious Very Large-scale adverse changes resulting in considerable and Long- term deterioration in Highly sensitive and important views.

Clear and obvious very large scale changes resulting in considerable and Long-term improvement in existing poor view for High sensitivity receptors.

The derivation of the level of significance (of effect) uses professional judgement taking into

consideration the contributing factors of sensitivity, magnitude and nature of effect and generally

follows a pattern by which the relationship between sensitivity and magnitude contributes to the level

of significance as shown diagrammatically in Diagram 2. It should be noted that, strictly, notable or

Significant effects only need to be determined, not the assessed level of all effects, but it is

acknowledged that levels of effects can be a useful aid when reading and understanding the

assessment.



Diagram 2 General Relationship Between Magnitude, Sensitivity and Significance

Ax 1.6 ASSESSMENT OF CUMULATIVE EFFECTS

General

Ax 1.6.1 The cumulative landscape and visual effects of two or more developments may be more or less

than the sum of the individual effects and therefore may need to be assessed in addition to the

assessment of effects of the Proposed Development undertaken in isolation of other similar

developments.

Ax 1.6.2 The assessment of cumulative effects may require different baseline assumptions to be made,

to allow the assessment to differentiate between isolated and cumulative effects.

Ax 1.6.3 Cumulative effects may take into account:

• Other existing (recently built or partially built) developments;

• Other approved developments that have not yet been built;

• Other proposals awaiting determination of approval or are reasonably foreseeable.

Ax 1.6.4 The assessment of cumulative effects process remains the same as for the individual assessment

and the same terminology (supplemented below) can be applied.


Ax 1.6.5 Cumulative visual effects can be gained in combination (i.e. where two or more similar

developments are visible from one viewpoint) and sequentially (i.e. when two or more similar

developments are visible from different viewpoints along a route (e.g. a railway line, recognised

tourist route or recreational footpath). Cumulative visual effects can be further categorised as

described in Table Ax 19.



Table Ax 19 Categorisation of Cumulative Effects

Cumulative Visual Effect

Sub-type of Effect

Description

Combined Effect

Simultaneous Two or more developments visible from one viewpoint in field of view gained from looking in one direction

Successive Two or more developments visible from one viewpoint only by changing orientation of viewing direction (i.e. by turning round)

Sequential Effect

Frequently sequential

Where similar visual effects are experienced along a route, from different viewpoints separated by short distances or short time gaps (e.g. along a motorway)

Occasionally sequential

Where similar visual effects are experienced along a route, from different viewpoints separated by large distances or long time gaps (e.g. along a long distance footpath)

Ax 1.6.6 A cumulative perceived effect may occur due to a receptors’ knowledge of developments’

proximity to one another, even though they may not be visible.

Cumulative Landscape Effects

Ax 1.6.7 Cumulative landscape effects can occur in relation to landscape elements individually and also

in combination (landscape character). The cumulative effects on landscape character take into

account the wider area and the potential effects of other listed developments.



Annex 2 FIGURES







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