The Branch was again very successfully represented at this year's Michelham, Priory Game & Country Fair. 

The Branch stand, sponsored by Environment Agency, Hardy Greys and Sportfish proved very popular with anglers and potential anglers of all ages, giving our Team of volunteers little respite over the two days.   Casting demonstrations (two per day) were given by Brian Smart of Hardy Greys  Acadamy.  Our team of coaches were hard pressed to satisfy the queues of people wanting to have-a-go at fly casting, together with a number looking for lessons and tips to correct casting faults.  Other visitors were keen to know about S&TA and fishing generally and our band of willing workers were on hand to answer their queries and to give advice on fishing and where to fish.  A number of anglers submitted their names to the waiting list for our very successful Trouting Syndicate - six lakes set in the heart of Sussex - where we also run our Beginners and Improvers courses.

For a slide show of the event click here (courtesy of Paul Cumbers)

The South of England Agricultural Society organised a "Kids Meet the Countryside" event at the Ardingly Showground on 13th July.   Volunteers from the Branch were in attendance to provide casting "Have A Go" on the showground's pond.    With over 2000 school children (mainly Year 6) visiting the event, we estimate that some 700 had a go.   The Environment Agency and the Fly Dressers Guild were also in attendance and collectively we were able to promote the benefits and pleasures of fishing generally.

Our Volunteers were hard pressed to keep up with the demand for "Have a Go" and our Coaches/Helpers had to work flat out.   Well done and thanks to Mark Brown, Mathew Cumber, Bob Hales, Alan Purnell, Brian Raw, Brian Smart & Tom Todd.

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East/West Branch Invitation - Yew Tree Fishery 1 May 2006

Despite the very disappointing attendance, the day was most enjoyable, thanks to the few stalwarts who braved the inclement weather in the morning.

The setting at Yew Tree could not be better and no one failed to catch.    The best fish was caught by Dr  J St Pierre (Sam) - a magnificent 3lb+ Brown trout and the best bag went to Brian Raw (7lb+).    The latter catch could not be more deserved given the effort that Brian had put in to ensure the day was successful.   There were one or two members who understandably had to withdraw because of illness, but others who had promised their attendance and simply did not show, not only missed a great day's fishing but more importantly, let their colleagues down badly.  Consequently, the Branch is somewhat out of pocket and we will have to ensure that for any future events, payment is received up front.

For pictures of the day (kindly taken by Paul Cumbers) click here.

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Sussex Fly Dressers' Guild

                                                               Chairman: John Plowman

                                                      "The Garden House", 246, High Street,

                                                          Uckfield, East Sussex. TN22 1RE

                                                                   Phone: 01825 762975

                                                           Email: beehives@btintemet.com

Dear Tom,

It has fallen to me to organise the Charity Pairs boat fishing competition at Bewl on 8th. October this year.

Below I have added the application form which I would be grateful if you would copy as many as you need.

The price is based on two anglers sharing a boat with a full day ticket each.

Fishing will start at 9.00 am and weigh in is at 5pm. Anglers may continue to fish after weigh in up to the

reservoir closing time. 

In fairness to the Bewl staff I will stick strictly to the closing date for entries. Any late entries will be

welcome provided they book their own boats and make a donation to the charity funds. 

I look forward to meeting you there and hope for good weather.

Yours sincerely,

John Plowman)

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Salmon & Trout Association

Southern Region

presents

‘THE FUTURE OF THE ANGLING ENVIRONMENT’

Open Meeting for all anglers

To be held at

The Felbridge Hotel, London Road, East Grinstead, West Sussex, RH19 2BH

on

Wednesday 29^th March 2006 at 7pm

Speakers:

Charles Jardine

‘Adapting to change in the modern aquatic environment’

Paul Knight

‘Salmon & Trout Association

 – Protecting angling and the environment’

Followed by an

OPEN FORUM

Panellists to include:

Paul Knight, Charles Jardine and Richard Hammond from the Environment Agency

Your chance to question the panellists

ALL WELCOME

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Dear Member,

 It seems hardly possible that another year has passed already.   In many respects, from a fishing angle (pun not intended), it is perhaps a year best forgotten.   Whilst we must not begrudge others the beautifully warm and extended summer,   our sport suffered as a consequence.   Low river flows, depleted reservoirs, rampant weed and algae growth, together with long spells of bright sunshine, made fishing very difficult.   Such conditions are being forecast as the norm by many experts and if their predictions are true, the future of game fishing in our part of the world does start to appear to be unsustainable for future generations.        

 Apart from the weather, the threats mentioned in previous newsletters, remain.    Increasing demands for water continue to threaten our river systems and place pressure on our underground supplies.   Treatment of waste and disposal of rubbish jeopardises water quality, whilst a perceived need to build more and more homes in the South East adds to the overall burden on an already stretched and valuable resource. 

 However, it is not all bad news.   The Branch representations, together with those of other interested bodies, were instrumental in Lloyds Environmental withdrawing their planning application for a hazardous waste landfill and materials recycling plant at South Chailey.   This has been a notable achievement but one which is not yet finalised; Lloyds have declared their intention to re-submit amended plans in the near future.   We have been able to donate funds to The Sussex Ouse Conservation Society for the purchase of equipment to help in their monitoring and analysis of water quality.    We were able to provide some financial assistance to the Bevern Residents Association in their fight against Lloyds’ proposals.   Additionally, we also made a contribution to HQ to help in the publication of the Brown Trout Big Book which will be distributed to all schools, hopefully educating as well as encouraging youngsters into game fishing.

 We were well represented at the Michelham Game & Country Fair in July.   The venue proved to be excellent and our stand attracted a constant stream of visitors, many of whom queued to “Have A Go” at fly casting.    We made a large number of new friends and had a marvellous couple of days.  Branch Membership is still at the 400 mark in round terms.  Over the year we recruited 19 new members but during the same period, lost 45.   Of those, 24 are “lapsed”.    If you have inadvertently forgotten to renew your membership, please do so now.    Remember, the healthier our membership, the better able we are as an Association, to continue to lobby on those issues which matter to Game angling.

 For regular news updates throughout the year visit the Branch website at www.east-sussex-sta.org.uk.

 Branch Organiser

 We welcome Peter Langton as our new Branch Organiser.    Peter is still finding his feet, but is already making a difference.   Peter’s contact details are on this year’s programme

 2006 Programme

 The 2006 programme is enclosed with this letter.   Our first event is the AGM on 3 February 2006, again at the excellent Wellshurst Golf & Country Club near Hellingly. It would be great to see a good attendance. 

 Sussex Ouse Conservation Society

 S.O.C.S. has continued to realise its aims and objectives for the protection and enhancement of the Ouse Catchment over the past year.   The Society has remained financially secure and membership is slightly up on last year.

 The Task Force has continued with a regular programme of debris clearing and stream management and is expanding its areas of operation to other streams in the system.

 The Water Testing Team has continued with its endeavours and sampling on the main river has been extended to Sheffield Mill and Scaynes Hill. Unfortunately our analytical chemist, Peter Symonds, has recently ceased analysing our samples, due to pressure from other commitments. We are extremely grateful for the work that Peter has done for us in the past and wish him well with his new venture. Sample analysis has now been taken on by the S.O.C.S. Director, relying on an antique qualification in A level chemistry and thus on a steep learning curve. So far, he seems to be coping.   Biological monitoring continues with two sampling teams. The results (as for chemical analyses) are published on our website.

 S.O.C.S has also continued with its Schools Education Programme and this year we had a combined exercise with Hamsey and St. Peter’s (Chailey) primary schools which featured Dr. Richard Osmond’s HI-TECH WILD TREK trailer for live video of collected specimens. We are grateful to South East Water who generously sponsored this event.

 Our involvement with Dr. Elizabeth Hill’s study into the effects of hormonal contamination of the Ouse on living organisms is well established. We have been collecting samples of bivalve molluscs for evaluation in the University of Sussex unit.

Our support for Hannah Rei with her degree dissertation on the Bevern Stream paid handsome dividends. Hannah has produced an impressive report detailing the effects of effluents on the ecology of this stream. A copy has been sent to the Environment Agency and we hope it will encourage some action on the problems faced. We are delighted to hear that Hannah won the prize for the best dissertation in her year, an accolade well deserved.

 We exhibited again at the South of England Show together with Dr. Osmond and his trailer, by kind permission of the South of England Agricultural Society, and we have continued to give presentations on our work at the Uckfield Environment Exhibition, Sussex Biodiversity Records Centre Annual Seminar, Plumpton College Open Day Parish Council annual meetings and local village events.  We also provided teas again at the Mount Harry Garden Open day on 15^th May. This is always a most pleasurable exercise and we are extremely grateful to Lord and Lady Renton for regularly inviting us. The next Open Garden Day at Mount Harry is on Sunday 21^st May 2006; well worth a visit.

 The Stakeholder Committee of the Adur and Ouse Catchment Abstraction Management Strategy (CAMS), on which I represented S.O.C.S. and the Branch, published its strategy report in March 2005. It illustrates the problems we face due to scarce water resources in our area and we hope that the strategy will aid the husbanding of this precious commodity.

 The work undertaken by S.O.C.S. has a direct beneficial effect on the quality of your fishing. We value your support and are always pleased to welcome new members. Membership is only £10 per annum and you will receive our quarterly newsletter. It’s not just your money we are after, the more members we have, the more influence we gain. For details of what we do and information about joining us, please visit our website at www.sussex-ouse.org.uk or alternatively give me a call on 01273 400093.

 “Sam” St.Pierre – Director

 Trouting Syndicate

 After a number of false starts, work to improve the access path from the gate to the fishing hut was completed in November.   Subscriptions, however, have been increased to £190 for the season, in order to help fund future improvements.   As a trial we have decided to start our season on 1 March this year, finishing as usual on 31 October.

 Water Resources

 We are facing the same problems upon which I reported in 2004, only worse. As I write this in mid November, we are still subject to a hosepipe ban, which really says it all. A combination of low rainfall and increasing demand has precipitated this situation. Those of you who fish at Cinder Hill will have noticed how the feeder dried up this summer and this has happened in many of the tributaries of the River Ouse. Lack of flow leads to a rise in water temperature, depletion of oxygen and concentration of pollutants, which all take their toll. These factors no doubt contributed to the Argulus (fish louse) infestation experienced at Cinder Hill towards the end of the season.

 Your Branch continues to keep a watchful eye on discharge consents and we robustly lobby for higher standards to protect our fisheries. We are also active in pressing for more sustainable policies regarding the abstraction of water for potable use, irrigation etc. I just hope that we get more rain in 2006.

As there was no one else foolish enough to volunteer, I applied for a seat on the Environment Agency’s Regional Fisheries Ecology & Recreation Advisory Committee (RFERAC), to which I have been duly appointed. So far, it has proved a useful forum for me to voice our concerns. I am told that the Agency does take the views of the committee seriously. I hope this is so, as it will make the effort worthwhile.

 “Sam” St.Pierre – Water Resources Officer

 Acknowledgements

 Thanks go as always to everyone who has continued to give of their time in helping the Branch at various events and functions.  Particular thanks go to Paul Cumbers, Robert Nathan and Graham Mortimore for organising our stand at the Michelham Priory Game & Country Fare.   Together with our sponsors, Caffyns and Sportfish, they made our presence one of the most successful I can remember.  A big thank you to the Branch Committee for their invaluable input and sterling efforts.  Also thanks to all the volunteers who help keep Cinder Hill neat and tidy throughout the season, especially to Brian Raw and to Ron Staplehurst, who has single-handed tidied and improved the fishing hut.

 If you would like to have an input to the running of the Branch, then why not volunteer as a Committee Member?   We are always on the look out for new blood and fresh ideas.  Let’s hear from you at the AGM.

 Best wishes to you and your families for 2006 and tight lines.

 Yours sincerely,

Tom Todd

Chairman

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CINDER HILL 2005 NEWSLETTER

 Dear Fellow Members,

Those of you with the “cormorant’s eye” will note that I live quite close to Cinder Hill, about 10 minutes drive on a bad day.  I am sure this is what John Masters spotted when he asked me to take over his “stocking role”.

We are at the end of my first year of office, which seems to have gone in a flash of silver, turning rapidly red towards the middle of the year.

The weather and fish quality have given me a steep learning curve and I am grateful to all of you for comments, help and guidance.  I stress I am only a humble fisherman and no scientist.

The weather has given us low water, no oxygen, weed and freshwater lice.  Add to this a problem of gravid fish in several deliveries and you can imagine my uncertainties at such an inauspicious start in the job.  However, we have a new fish supplier and there were much better catches and quality towards the end of the season.

The release programme is already set out for next season although this may be brought forward if our season begins early.  I have planned much lower stocking levels for July and August to try and avoid a repetition of previous years’ drought conditions.  This is probably a recipe for full flood all year!  There will also be a slight shift in weights, which I hope will avoid some of the more disappointing catches.  It is worth remembering that the residue of this year’s poor quality fish may still show in some of next year’s catches.  That’s fishing!

I am sure we will all thank John for his sterling efforts over the past eight years, and I continue with thanks to Bill Impey for his regular catch records.  I have not repeated the help rota for release days because our new supplier is more than happy to aid me in the job, thus making the whole thing a very easy and interesting exercise.

My ‘phone number is at the top of this note and please do feel free to call me with ANY comments you may wish to make.  I wish you all a Merry Christmas and a good season for 2006 and I look forward to meeting more of you on the waterside.

Peter Neave

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THE BROWN TROUT BIG BOOK

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Lloyds

ENVIRONMENTAL WASTE MANAGE.MENT LTD

llead Office: Old Flamso, Brickworks South Cliailev Nr Lewes East Sussex BN8 4Q1)

Tel: (0 1273) 401888 Fax: (0 1273) 401999 w\vks,.llo\,dsenvironiiicntal.co.uk info,a 11(~ydsenx,ir(~nmental.co.uk

1 August 2005

Dear Sir/Madam

I am writing to inform you that, following consideration of the officer's report to East Sussex County Planning and Highways Sub Committee on August 3, we have decided to withdraw our planning application for a Materials Recycling Facility and specialist landfill site. 

While we are obviously disappointed with the recommendation made in the report to refuse the application, we continue to believe that the integrated approach we proposed offered a sensible, local solution to the serious problems of waste disposal faced by both local authorities and waste producers in East Sussex.

 Certainly, tougher environmental legislation means the problem of waste disposal still needs to be addressed ‑ we all create waste and we all share a responsibility for dealing with it.

 We will now look closely at the conclusions drawn in the report to the committee. It is our intention to re‑submit a revised planning application in the coming months.

 Having consulted very widely on this project I would like to thank everyone who has taken part in the process. The Lloyds Environmental team will keep these lines of communication open while we review how best to move our proposals forward.

Yours faithfully

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Stewart Glassar

Case Officer

Department of Transport and Environment

County Hall

St. Anne’s Crescent

Lewes BN7 1UE.

 4^th July 2005

 Dear Mr Glassar

 Re Application LW/424/CM(EIM) – Non hazardous and stable non-reactive

Hazardous waste landfill site and materials recovery facility

Old Hamsey Brickworks, South Chailey.

The Sussex Ouse Conservation Society, (S.O.C.S.) has previously written to you in respect of the above facility, we continue to oppose the granting of planning consent for it on the grounds set out below. We have reviewed the further information provided by the developer's consultants (Robert Long Consultancy) in their response to your letter of 21^st March 2005 and remain of the opinion that there still has been no proper evaluation of potential impacts upon the Bevern Stream, a tributary of the Sussex Ouse. Our objections continue to relate primarily to the landfill component of the proposed development. Because of the Society's remit our comments are restricted primarily to how the Bevern Stream may be affected by the development. We would, however, again note our continuing concern about the Environmental Statement in its entirety as, while the response to your letter of 21^st March does clarify certain issues, we still consider it to be a seriously flawed document.  

We wish to draw you attention to the following outstanding issues, which are not, or are inadequately addressed in the Response to Consultations provided by the Robert Long Consultancy, or in the initial Environmental Statement (ES): 

1)  In spite of the additional information provided there remains ambiguity as to exactly what is proposed for the site, and this still includes there being no clear account of what is proposed with respect to the management and treatment of leachate. The Response to Consultations states (pg 22, 5.17) that “the ES is clear that there will be no effluent discharges or run-off from the site into controlled watercourses during the operational period” and again (pg 23, 5.17) “The ES is clear that there will be no effluent discharge from the site into surface watercourses during the operational period”. These assertions are inaccurate because it is stated in the initial ES (Non Technical Summary, pg 5) that leachate will either “be taken off site in tankers to a suitable sewage treatment works, or treated in the on-site liquid waste treatment plant” (which ultimately discharges into the Bevern stream). This anomaly indicates that the Robert Long Consultancy, in drafting their response, appear unaware of what they themselves drafted in the initial ES, or of what is actually proposed with respect to leachate management at the site. Given that leachate generation and management is one of the most significant aspects of landfill operation, a lack of consideration of the impact of its disposal/discharge is a very serious omission. Additionally, we remain concerned that the statement in the initial ES that the leachate could be “treated in the on-site liquid waste treatment plant” does not represent a valid treatment option, as the liquid waste treatment plant could not be constructed in the form for which planning permission has been given, if planning consent was also granted for the landfill. While Robert Long Consultants have (partially) clarified the situation in their Response to Consultations with respect to the exact location of the liquid waste plant relative to the landfill facility, it still appears to us that it cannot, as stated in the existing planning consent, discharge into the old brick pit as this will be the site of the landfill operation.  

2) The primary concern for S.O.C.S. remains that the proposed landfill is in close proximity to the Bevern Stream (and an un-named tributary of it) and may adversely affect it, either by a   direct or indirect discharge of leachate generated by the site, by a failure of on-site leachate management or an accidental spillage, or by a failure of the integrity of the landfill lining. The initial  Environmental Statement briefly acknowledged both the proximity to the Bevern Stream (stated to be 180m at its closest) and the option of discharging treated leachate to it (via the liquid waste treatment plant), but failed to make any assessment of potential impacts upon it. In the Environmental Statement (which runs to several hundred pages) only a few lines were devoted specifically to the Bevern Stream, contrasting with other issues, some of which, e.g. landscape impacts were covered in depth. This rendered the Environmental Statement overall unbalanced as a document. No qualitative or quantitative data relating to water quality in the Bevern Stream, or to its ecological characteristics, were presented. This must be regarded as a highly significant omission given the proximity of the development to the stream, and the stream’s ecological importance. The further information provided by the Robert Long Consultancy in the Response to Consultations provides absolutely no information whatsoever in respect of these issues and this fundamental deficiency in the scope of the ES remains uncorrected. 

The Environmental Statement actually quotes (Appendix 2, 4.20) the advice of the Environment Agency that “The EIA should therefore include an investigation into flood risk issues and potential chemical and biological impacts on the nearby watercourses”. No such investigation of chemical or biological impacts was included in the Environmental Statement. The Robert Long Consultancy’s  Response to Consultations does address, (section 12), at least some of the Agency’s concerns in respect of flood risk and there is some limited information provided with respect to the ponds on site. However, there is again absolutely no consideration of any discharge to, or potential impact on, the Bevern Stream.  This consistent failure to address potential impacts upon it is particularly incongruous given that the Bevern is probably the most important spawning stream for sea trout in the Sussex Ouse catchment; Environment Agency reports (e.g.OUSE01/OU27) state that “The Bevern Stream is a well known sea trout water……The importance of the Bevern Stream lies in its suitability as a salmonids spawning ground, accounting for a large proportion of the Sussex area salmonid population”. There is no indication that those responsible for preparing the Environmental Statement or Response to Consultations were aware of this fact, and there remains no consideration whatsoever of how the sea trout stock (and other fish species) could be affected. 

There is, in fact, no reference to fish of any species (or indeed any fauna or flora) being present in the Bevern Stream. The fish population of the river is actually relatively well documented, including in the Environment Agency reports referred to above, and such data should have been, but was not, drawn upon by those who prepared the Environmental Statement. 

The Bevern Stream must be regarded as one of the most important sea trout spawning grounds, not just in Sussex, but in the whole of lowland South and East England. With  fish passes scheduled for construction on Redbridge and Clappers weirs on the lower Bevern in 2005, to facilitate access to the stream for adult sea trout migrating upstream, there is the prospect of even greater runs of sea trout entering the stream from autumn 2005 onwards, and its importance increasing still further. The sea trout of the Sussex Ouse catchment are exceptionally large fish, and individuals of 5kg or more are regularly observed spawning in the Bevern Stream.   

We again note that the Bevern Stream receives most of its base flow from the Chalk aquifer. While around Bevern Bridge it flows over Weald clay, it does retain partial chalkstream characteristics at this point and its upstream tributaries, particularly the Plumpton Mill Stream are in their upper reaches essentially pure chalkstream habitats. The Roman’s winterbourne, which enters the Bevern just upstream of the proposed development site, is a classic chalk winterbourne. These chalkstream habitats are in their own right important sea trout spawning grounds and any pollution of the main Bevern Stream could affect the upstream migration of adults to, or downstream migration of smolts from them, thus affecting their ecology. Chalkstreams are priority habitats and potential impacts upon them should be identified and evaluated when they could be affected by a proposed development. No such evaluation was made within the Environmental Statement, nor has this omission subsequently been remedied. 

3)  The ecological assessment was presented as Appendix 9 of the Environmental Statement. It was stated (Appendix. 9, 3.1) that the study area included all the land within the application site boundary together with an area of woodland to the east. Restricting the boundary for ecological assessment to the site boundary was entirely inappropriate as this excludes any consideration of ecological impacts on the Bevern Stream, which may receive a direct discharge of treated leachate, or could be polluted following a failure of the landfill liner or accidental release of leachate. Given that the initial Environmental Statement acknowledged (contrary to Robert Longs assertations in their Response to Consultations; see point 1) above) that treated leachate may be discharged, via the liquid waste treatment plant into the Bevern, it is quite extraordinary that there is no consideration given to the ecology of the Bevern Stream, or how this may be impacted by the development. This omission is simply incompatible with proper Environmental Impact Assessment practice. The stretch of the stream around Bevern Bridge is of particular importance for sea trout spawning. Juvenile salmonids are very sensitive to pollution and any potential impact upon them should have been rigorously assessed. It should also have been recognised that any effect on sea trout spawning in the Bevern could, given the stream’s particular importance, have a significant impact on the sea trout stock of the Ouse catchment overall, and on the significant recreational fishery for sea trout dependent on it. The Sussex Ouse consistently has the highest annual rod catch of sea trout for any river entering the several hundred km long stretch of coast between the Itchen in Southampton and Yorkshire Esk at Whitby.

In addition to the sea trout stock, other fish species of particular conservation significance are present in the Bevern Stream, including a large population of bullhead. Twaite shad are being recorded in increasing numbers in the main Sussex Ouse around Barcombe, and there are also well documented spawning populations of sea and river lampreys at Barcombe Mills. Any serious pollution incident arising from the proposed development could potentially impact upon these ecologically valuable populations in the Ouse itself. The extent to which pollution of a tributary of the Ouse can impact upon the fish stocks of the main river is graphically illustrated by an incident in 2001, when small quantities of a pesticide pollutant entered the Ouse at Sheffield Park Bridge via the Pellingford Brook, resulting in an estimated (by the Environment Agency) 80% mortality of the river’s fish stock as far downstream as the tidal reaches. There is a clear indication in the Robert Longs Consultancy’s Response to Consultations that the methodology employed in undertaking the Environmental Assessment is flawed with respect to determining to what distance from the development site potential impacts should be evaluated. It is stated (pg 22; 5.16) that consideration of any impact on the Barcombe Mills Water Treatment Works was omitted as at c.4km from the proposed site it fell outside the “normal” radius of enquiry for receptors. In conducting an environmental assessment proper consideration should be given to how far impacts may extend, rather than relying on arbitrary cut off points.  

4) The Surface and Groundwater Impact assessment (Appendix. 12 of the initial Environmental Statement) provided absolutely no data whatsoever on prevailing chemical water quality in the Bevern stream and made no proper assessment of what impact on chemical water quality a discharge of treated leachate would have. The Response to Consultations similarly provides no information on this. There is also no proper assessment of what the impact of a failure of the liner, or other plant or management failure allowing leachate to escape, would be on the Bevern Stream. There could be potentially serious releases of leachate during both the operational and post-operational phases of the development. There is reference in the Response to Consultations (pg 22, 5.13) that the PPC application will address the impact of long-term migration of leachate, however it would be good practice for this to be addressed in the ES itself, rather than deferring its consideration.  

There remains inadequate information in the Environmental Assessment and Response to Consultations to determine the full range of scenarios during individual development phases which could lead to such a release (in particular because there is still no proper account of leachate management), but given the close proximity to the Bevern stream it is entirely plausible that, should a spillage or other release of leachate occur, it will enter the stream. Depending on the severity of such a pollution incident, its impact could extend downstream to the main Sussex Ouse.  The possibility of a pollution incident is tacitly acknowledged in the Response to Consultations (pg 22, 5.18), in the context of an impact upon the Barcombe Mills Water Treatment Works.  However, there is no attempt to consider what impact any such pollution may have on the ecology of the Bevern Stream itself. 

5)  Rather than establishing existing water quality in the Bevern Stream, as a baseline for impact prediction, and then properly assessing impacts upon its water quality, which would be normal practice in conducting an environmental impact assessment, the Environmental Statement places an over-reliance on the monitoring of water quality once the development is in place.  The Environmental Statement noted (Appendix 12, 2.99&2.1000) that there will be monitoring of the Bevern Stream and its un-named tributary stream to the east of the development, but to simply state that water quality will be “monitored” (with no proper details provided as to what parameters will be monitored) is inadequate and there is no contingency presented for mitigating any impact on the stream should monitoring detect a problem. This inadequacy is not addressed by the Response to Consultations.   

6) The groundwater impact assessment in the initial ES identified, but did not follow through, a potential pathway via which leachate could migrate from the landfill to the Bevern Stream.  The Environmental Statement recognised (Appendix 12, 2.95) that “the confined sand unit to the south and east of the site remains a plausible receptor that could be affected by the landfill development…….The un-named surface stream east of the site may intersect the sand unit and it is considered that any further risk assessment work should concentrate on the sand unit and its relation to the proposed landfill in terms of potential leachate migration into the groundwater within the sand, and then any relationship between the sand unit (e.g. spring discharges) and water flow in the stream”. The Response to Consultations does not provide a detailed risk assessment. The purpose of an Environmental Statement is to provide an evaluation of potential environmental effects and it would have been appropriate for the Environmental Statement to have directly addressed this potential effect, not to defer its consideration to “any further risk assessment work”. The lack of a detailed risk assessment in the Responses to Consultations comprises a further missed opportunity for the developers to assess this issue. It is obvious that any leachate which does reach the small un-named stream may then flow into the Bevern Stream, with potentially serious consequences.                                                                                      

7)  The consideration of alternatives is an important aspect of Environmental Impact Assessment. The Non Technical Summary of the Environmental Statement stated (pg 2) that “The applicant did not consider alternative sites for the proposed development because the site at Old Hamsey is highly suitable for the purpose”. The Response to Consultations does provide a consideration of alternative sites; however, in again concluding that the site is suitable, no consideration as a constraining factor is given to the proximity to, and ecological significance of, the Bevern Stream.  It remains highly questionable whether a location where the receiving watercourse for the discharge of treated leachate  is a very important sea trout spawning stream, of limited flow and capacity to dilute pollutants, can be regarded as “highly suitable” for a landfill development.

8)  The primary role of an Environmental Statement is to provide a planning authority with information on the environmental implications of a project to assist it to make an informed decision. The continuing lack of any consideration of the ecological significance of the Bevern Stream and of potential impacts upon it means that the initial Environmental Statement and the Response to Consultations remain an inadequate basis for making such a decision. 

We trust that the observations set out in our objection will be of assistance to the Council in further evaluating and determining the planning application. If you require any further clarification in respect of any of the issues detailed above please contact me. It remains our opinion that by virtue of failing to determine the baseline environmental characteristics of, and potential impacts upon, the Bevern Stream the ES (and Responses to Consultations, if deemed to be part of the ES) is fundamentally deficient with respect to the requirements of the Environmental Assessment Regulations, and should be treated as such by the Council.  

Yours sincerely, 

J.E.St.Pierre – Director – Sussex Ouse Conservation Society.

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The additional information submitted by LLoyds has not changed their application significantly.   Nor has it alleviated the threat to the Bevern stream in particular and the environment in general, if their application was successful.

Our previous letter of objection (click here) has therefore been re-submitted to the new Councillors.

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20 June 2005

Stewart Glassar                          LW/424/CM

Tel. 01273 481595                      AR/SG

Fax 0 1273 479040

stewart.glassar@eastsussex.gov.uk

 Dear Sir/Madam

 Hamsey Brickworks ‑ Planning Application LW/424/CM

I have received further information from the applicants regarding their proposed development of a non‑hazardous and sable non‑reactive hazardous waste landfill site and materials recovery facility at the above site.

Copies of this additional information will be available for your inspection at this office and at the Directorate of Planning & Environmental Services, Lewes District Council, Southover House, Southover Road, Lewes during normal office hours.

If you wish to comment on the additional information, please do so in writing by 11 July 2005. The views that you express, together with any previous views, will be brought to the attention of the Planning & Highways Sub Committee, which will determine whether or not planning permission should be granted.

For reasons of economy, no acknowledgement will be sent to you on receipt of your representations but anyone making representations will be informed of the final decision in due course.

Yours sincerely

Stewart Glassar

Principal Planner (Development Control)

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Lee Jamieson

Regulatory Specialist

The Environment Agency

Saxon House

Little High Street

Worthing BN11 1DH                                                           Saturday, 21 May 2005

Dear Mr Jamieson,

CONSENT APPLICATION P.12337/S/05 – E. SUSSEX NATIONAL GOLF CLUB 

Thank you for your letter dated 19^th May 2005. We are pleased that the summertime effluent will be used for irrigation purposes, which should indeed have a significant effect in reducing the nutrient burden to the stream at the most critical time.

We would like to express our appreciation for the effort the Agency has undoubtedly made to achieve this result.

Yours sincerely,

 J.E.St.Pierre – Director – Sussex Ouse Conservation Society.

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Salmon & Trout Association

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

The County Planning Officer

West Sussex County Council

County Hall

Tower Street

CHICHESTER

PO19 1RH

West Sussex

                                                                                                                           29 March 2005

Dear Sir,

CORY/FRESHFIELD LANE BRICKWORKS – APPLICATION FOR LANDFILL

I am writing on behalf of my 450 members to lodge our strongest possible objection to the application by Cory/FLB for the creation of a landfill site at Freshfield Lane, Horsted Keynes.

Apart from the inadequate and dangerous access, the threat to health and quality of life, the damage to leisure tourism and the rural economy, our main concern, as one of the main national conservationist organisations, is the threat to our water resources.

The Freshfield Lane Brickworks stands on porous rock on an aquifer, and any landfill operation will inevitably produce leachate into both the aquifer and the near-by Cockhaise and Danehill Streams.    These two streams, as feeders to the Sussex Ouse will threaten the ecology and wildlife of a river system which has now gained Salmonid designation under the terms of the European Union Freshwater Fisheries Directive, demanding much higher standards of water quality.   The Ouse is recognised as an important salmonid fishery, unique in respect of the rapid maturation to unusually heavy weights of its sea trout population.   In addition it is home to indigenous brown trout and bullheads, the latter being a species already recognised internationally as being under threat.    

Already heavy effluent loads within the Ouse catchment make this latest application even more worrying, especially since ultimately, the Ouse provides one of the largest sources of fresh drinking water in Sussex.   Since the recent Environment Agency’s Catchment Area Management System (Cams) review confirms that there are no other sustainable sources available for further abstraction, the need to protect the Ouse from the possibility of further pollution is absolutely critical.

This application appears to be purely opportunistic, particularly since the site is not required for WSCC Waste Local Plan and the need for such a site not proven.    Current EU policy is that landfill should be a last resort and given the pressure to reduce landfill,  increase recycling and protect our environment, I trust that WSCC will refuse this application.

Yours sincerely,

T J Todd

Chairman

cc Peter Jessop, S&TA Regional Representative

Lee Jamieson                                                                               18^th March 2005

Regulatory Specialist

Environment Agency (Southern Region)

Dear Mr Jamieson,

WATER RESOURCES ACT 1991, SHEDULE 10

(AS AMENDED BY THE ENVIRONMENT ACT 1995)

NOTICE OF APPLICATION FOR CONSENT TO DISCHARGE

ZANLIA LTD. – EAST SUSSEX NATIONAL GOLF CLUB  Ref P12337/S/05

On behalf of the East Sussex Branch of the Salmon & Trout Association, I hereby make representations regarding this application. 

• We note that again the Agency refers to highly treated effluent in its Notice statement. Does “highly treated” mean that the effluent will be treated to the highest possible standard of purity, including UV disinfection and nutrient stripping? If not, please will you clarify the bio-chemical parameters that the Agency has in mind.
• We note that the proposed volume is up to 95 cubic metres per day. This is an extremely heavy effluent load for the size of the receiving water (Little Horsted Stream). This stream supports a population of wild brown trout and is a spawning ground for migratory trout. Lack of dilution, particularly in low summer flows demands a high quality of outfall.

• The costs of treating this effluent would be doubtless borne by Zanlia Ltd., a private enterprise. We assume therefore that no quality constraints for financial reasons would be applied either by OFWAT or DEFRA. In our opinion, the Agency should therefore insist on treatment of this effluent to the highest possible standard.
• It should be borne in mind that the ultimate receiving waters (Rivers Uck and Ouse) are now designated as Salmonid under the terms of the EU Freshwater Fisheries Directive, demanding the higher standards of water quality as laid out in this Directive.

The River Ouse is an important salmonid fishery, unique in respect of the rapid maturation to unusually heavy weights of its sea trout population. This species is already endangered from the heavy effluent loads within the catchment. We see this as a golden opportunity for the Agency to demonstrate its commitment to improve the standard of water quality rather than accepting the status quo.

Yours sincerely, 

Dr.J.E.St.Pierre – Water Resources Officer – Salmon & Trout Association – East Sussex.

Our ref:           P.12337/S/05

Your ref: ‑       ‑‑‑‑‑‑‑‑‑‑‑                                                                              ENVIRONMENT

Date:                18th March 2005                                                                   AGENCY

Dr. J.E. St. Pierre

Oakwood House

Barcombe

East Sussex

BN8 5BW

Dear Dr. St. Pierre,

CONSENT APPLICATION P.12337/S/05 ‑ EAST SUSSEX NATIONAL GOLF CLUB

Thank you for your representation on the above discharge consent application. The Environment Agency will take account of your comments in deciding whether or not consent should be granted and, if granted, what conditions should be imposed.

The Agency is required by law to determine the application(s) within four months, unless an extension to that period is agreed with the applicant. When we have determined the application and issued or refused the consent we will write to you again to inform you of the decision.

Please note that Section 10, 5(1) of the Water Resources Act gives the Secretary of State for the Environment powers to call in consent applications for his determination as a result of requests. If you wish to request him to call in the application you should write to the Secretary of State for the Environment, Food and Rural Affairs, Water Quality Division, Floor 3, Ashdown House, 123 Victoria Street, London, SWIE 6DE. The Agency is required to determine the application unless the Secretary of State calls in the application before the determination process is completed.

In the meantime may I take this opportunity to address some of the points raised in your letter.

I and my colleagues continue to consider it appropriate to describe effluent as "highly treated" when it has been treated to a quality substantially better than the old "Royal Commission" standard of 20 ing/1 BOD and 30 ing/1 suspended solid (20/30). In this particular case due to the lack of significant dilution afforded by the receiving watercourse, the existence of nearby downstream on‑line fish ponds and the EU Fishery Designations of the main downstream watercourse, the quality of the treated sewage will need to be of a standard significantly tighter than the Royal Commission 20/30. In fact the proposed consent conditions are as follows ‑ BOD not greater than 10 mg/1, suspended solids not greater than 15 mg/1 and ammoniacal nitrogen not greater than 3 mg/1 during the summer months and not greater than 5 mg/1 during the winter months.

Please note that if a proposed discharge was to undergo UV and/or nutrient stripping the Agency would include the words "UV" and "nutrient stripping (or perhaps the term "tertiary treated") in the description of the effluent.

 As this will be a "private" discharge I can confirm that the considerable capital and running costs of the "top of the range" sewage treatment plant required to meet these stringent conditions will be met solely by the applicant with no contribution from the "public purse".

I trust the above clarifies some of the matters regarding this application.

Yours sincerely,

LEE JAMIESON

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HOUSE OF COMMONS

LONDON SW1A OAA

Thomas J Todd                                                        4 February 2005

Coverside                                                               Our ref: TT0402‑Environment

Hazeldene Lane

North Chailey

LEWES

BN84HH

  Dear Mr Todd,

 You contacted me recently to let me know of your quite proper concern about the proposal submitted by Lloyds Environmental for both a hazardous waste site and materials recycling facility to be created at the Old Hamsey Brickworks in South Chailey.

 You will know from my previous reply that I strongly oppose this application, and I thought I would drop you a line to let you know that Ihave now been able to raise this matter in the House of Commons, and enclose a copy of the media release I issued following that debate. I hope that this will add to the pressure on the County Council to refuse this unwanted application, I have also written to them separately to recommend they do so.

 I hope this is helpful in bringing you up to date with developments.

 Yours sincerely,

 Norman Baker

 Enc.

NORMAN BAKER MP (Liberal Democrat ‑Lewes)

Contact: Tom Fewins ‑ 0207 219 2864

Embargo: Immediate, 3d February 2005

LOCAL MP TAKES CHAILEY DUMP SITE

CONTROVERSY TO THE COMMONS

Chailey's MP Norman Baker has called in the House of Commons for the proposal for a hazardous waste dump at the Old Hamsey Brickworks in South Chailey to be firmly rejected.

 Speaking in a debate on hazardous waste, Mr Baker condemned the proposal from Lloyds Environmental and called upon the Conservative County Council to reject the application. He also criticised the authority for encouraging the applicant to roll together two separate proposals into one application ‑ for the hazardous waste landfill, and for a MRF (materials recycling facility).

 He told the Minister, Ben Bradshaw:

"There are no sites for the disposal of hazardous waste anywhere remotely near to my constituency. No such site to deal with hazardous waste has been identified in the East Sussex, Brighton and Hove waste plan, but a speculative application has arrived for a site in Chailey in my constituency, which is wholly unsuitable. The proposed site is the old Hamsey brickworks, and it is unsuitable because it will lead to the generation of a huge number of lorry movements. Because there are so few sites, and there are none for miles around, a large number of lorry movements from Kent, Surrey and West and East Sussex will all bear down on that site.

The proposal would also place the site on top of a geological fault, of all things. It is close to a stream and it is very close to a residential area, and it would be a nightmare if that were allowed to proceed. However, I am afraid to say that the Conservative county council, which is in charge in my area, has seen fit to ask the applicant, Lloyds Environmental, to combine the application for a landfill site for hazardous waste with a materials recycling facility. They are quite clearly different decisions, but it is being asked that they be considered together. On behalf of my constituents, who have written to me in large numbers, I call on the county council to reject that application. I hope that those comments will be picked up and relayed to the county council.” 

After the debate, Norman added: 

 “I intend to leave no stone unturned in opposing this worrying proposal. The County Council must be left in no doubt just how strongly my constituents understandably feel about this matter."

 ENDS

Inquisitor of the Year 2001

Opposition MP of the Year 2002

Westminster Office: Tel: 0207 219 28641 Fax: 0207 219 0445

Constituency Office: Tel: 01273 480 268 1 Fax: 01273 280 287

Email. bakem@partiamentuk http:/~.normanbaker.o[g.uk

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NEW BRANCH ORGANISER & COMMITTEE MEMBERS ELECTED

We are pleased to announce that at the AGM held on Friday 4 February 2005, Peter Langton was elected as the new Branch Organiser.   The Branch extends its warmest thanks to Peter for taking on this important role and wishes him every success for the future.

Also at the AGM, the following members were elected to the Branch Committee; our thanks to them for volunteering their services:

                                          Frank Reader

                                          Ken Field

                                          Dr Rod Yuill

                                          George Martin

For a full list of the Branch Officers and Committee