Mineral Sites Preferred Options Commentary Report
October 2012
Kent Minerals & Waste Development Framework
Planning for the future of minerals and waste in Kent Front Cover Images
Top Left: Restored sand and gravel quarry.
Bottom Right: Marine sand and gravel being discharged from a dredger on the Thames Estuary. Mineral Sites Preferred Options Commentary Report Kent County Council Contents Abbreviations i 1 Introduction 1 2 Preferred Options Site Map 2
Mineral Sites: Preferred Options
4 Mineral Sites Preferred Options Document 4 5 Mineral Sites Preferred Options Evidence Base 6 6 Sand and Gravel Sites 8 Soft Sand Sites 10 Site 6: Land Adjacent to Platt Industrial Site, Platt 10 Site 24: Land North of Addington Lane, Trottiscliffe 12 Site 75: Boltons Field, Lenham Heath 14 Site 76: Chapel Farm, Lenham 18 Site 77: Burleigh Farm & Tile Lodge, Charing 22 Site 97: Shrine Farm, Postling 26 Site 105: Borough Green Sand Pits Extension, Wrotham 30 Sharp Sand and Gravel Sites 32 Site 2: Beltring Green Farm, East Peckham 32 Site 17: Moat Farm, Capel 34 Site 49: Land Adjacent to Hammer Dyke, Capel 36 Site 71: Stonecastle Farm, Whetsted 38 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 73: Lydd Quarry Extensions (Areas A - D), Lydd 40 7 Crushed Rock (Ragstone) Sites 44 8 Silica Sand Sites 46 Contents Site 24: Land North of Addington Lane, Trottiscliffe 48 9 Chalk Sites for Cement Manufacture 50 10 Chalk Sites for Agriculture and Engineering Use 52 Site 63: Pinden Quarry Extension, Dartford 52 11 Brickearth Sites 56 Site 19: Paradise Farm, Hartlip and Newington 58 Site 98: Jefferies Site, Teynham 62 Site 101: Barbary Farm, Norton Ash 64 Site 102: Barrow Green Farm, Teynham 66 12 Clay Sites 68 Site 60: Norwood Quarry & Landfill Extension, Minster and Eastchurch 68 13 Mineral Importation Sites 70 Site 1: East Peckham Rail Depot, East Peckham 72 14 Secondary and Recycled Aggregate Sites 74 Site 21: F M Conway, Rochester Way, Dartford 76 Site 65: Land North of Stevens & Carlotti, Richborough 78 Site 72: Unit 14, Canterbury Industrial Estate, Hersden 80 Site 91: Animal Products Site, Faversham 84 Site 99: Broomway Ltd, Swanscombe 86 Mineral Sites Preferred Options Commentary Report Kent County Council Contents
Mineral Sites: Not Allocated
Site 3: Arnolds Lodge Farm West, East Peckham 88 Site 4: Woodfalls Farm, Yalding 89 Site 5: Filston Lane, Shoreham 90 Site 7: Hermitage Quarry Westerly Extension, Aylesford 91 Site 8: Chelsfield Ammunition Depot, Shoreham 92 Site 10: Pluckley Road, Charing 93 Site 12: Newington Industrial Estate, Newington 94 Site 16: Beacon Hill Quarry, Charing 95 Site 25: Ham Farm, Faversham 96 Site 26: Hollowshore, Faversham 97 Site 45: Dunbrik Depot, Sundridge 98 Site 50: Ightham Sand Pit Western Extension, Ightham 99 Site 56: Hegdale, Challock 100 Site 62: Newlands Farm, Charing 101 Site 69: Burleigh Farm, Charing 102 Site 74: Charing Quarry Extension, Charing 103 Site 78: Richborough Limestone Mine, Sandwich 104 Site 80: Faversham Quarry, Faversham 105 Site 86: Charing Quarry (Waste 2), Charing 106 Kent County Council Mineral Sites Preferred Options Commentary Report
'No Response' Sites
Contents 'No Response' Sites 107
Appendices
Appendix 1 108 Glossary 112 Mineral Sites Preferred Options Commentary Report Kent County Council i Abbreviations AONB Area of Outstanding Natural Beauty
AQMA Air Quality Management Area
CDE Construction, Demolition and Excavation Waste
EfW Energy from Waste
HGV Heavy Goods Vehicle
HRA Habitats Regulation Assessment
KCC Kent County Council
LWS Local Wildlife Site
MWDF Minerals and Waste Development Framework
NPPF National Planning Policy Framework
NNR National Nature Reserve
PRoW Public Right of Way
RIGS Regionally Important Geological Sites
SA Sustainability Appraisal
SAC Special Area of Conservation
SEA Strategic Environmental Assessment
SNCI Site of Nature Conservation Interest (replaced by LWS)
SPA Special Protection Area
SPZ Source Protection Zone
SSSI Site of Special Scientific Interest ii Kent County Council Mineral Sites Preferred Options Commentary Report
This page has been left blank intentionally. Abbreviations Mineral Sites Preferred Options Commentary Report Kent County Council 1 1 Response Summary Introduction Introduction
What is the Mineral Sites Preferred Options Commentary 1.4 The consultation for the Mineral Sites Plan Preferred Report? Options Document produced a total of 610 responses. Table 1 details how these responses were conveyed and the nature of 1.1 The Mineral Sites Preferred Options Commentary Report their submission. is a summary document of the responses received during the Mineral Sites Plan Preferred Options consultation which ran Table 1. Breakdown of total responses received. from 9am on the 28 May 2012, to 5pm on the 23 July 2012. Consultees and stakeholders were invited to provide their views Total number of responses: 610 on the sites outlined in the Mineral Sites Plan Preferred Options Document(1). Method Nature of response
1.2 This document provides a concise review of the responses Portal website 147 Object 347 (341 for allocated sites) received from members of the public, industry stakeholders and Email 343 Support 105 (28 for allocated sites) statutory consultees(2) in an attempt to highlight the main issues raised in supporting, objecting to or commenting on the various Letter 120 Comment 158 (136 for allocated sites) allocated and non-allocated sites contained within the Mineral Sites Plan Preferred Options Document. Consultees were able 1.5 Petitions accounted for two of the 610 responses which to submit their views via the KCC online consultation website, were sent to KCC by individual consultees. The first petition sent by email and by post. If you would like to view full responses to KCC contained 92 signatures objecting to Site 19 in Hartlip that were made public, please visit our Consultation Portal at and Newington. The second objected to Sites 75 and 76 in http://consult.kent.gov.uk/portal. Lenham and contained 463 signatures (an increase of 386 signatures when compared to a 77 signature petition sent to 1.3 The responses submitted to KCC will be recorded as part KCC during the previous consultation for the Mineral Sites of the ongoing site assessment process. Data collection and Development Plan Document. site visits will then be formulated, taking into consideration the emerging Minerals and Waste Core Strategy policies and 1.6 Please see Appendix 1 for a more detailed comparison of changes to national planning policy. The next document to be response rates for the latest consultation and the Mineral Sites consulted upon will be the Core Strategy Pre-submission Draft. Development Plan Options consultation which ran from the 31 The Pre-submission Mineral Sites Plan will not be published May 2011 to the 9 August 2011. until the Core Strategy is adopted, estimated in September 2014.
1 Available at http://consult.kent.gov.uk/portal/min-dpd/min_pref-options?pointId=2189750 2 As required under the 2004 Local Development (England) Regulations (as amended by the 2008 and 2009 Regulations) and the duty-to-co-operate contained in the Localism Act Mineral Sites - Preferred Options
99 21 ") Medway ") Dartford 60 ") 63 Swale ") Gravesham
Thanet Medway 19 ") 91 98 102 ") 72 ") ") ") 65 10")1 ") 24 Swale ") 105 ")") 6 Canterbury
Sevenoaks Tonbridge and Malling
Maidstone 76 75 ") Dover 1 ") ")77 71 ") 17 ") 2 ") ") ")49
Ashford 97 Tunbridge Wells ")
Shepway
73 ")
0 10 20 Kilometres ¯ © Crown Copyright and database right 2012. Ordnance Survey 100019238 1:390,000 Mineral Sites Preferred Options Commentary Report Kent County Council 3 2 This page has been left blank intentionally. rfre pin ieMap Site Options Preferred 4 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Mineral Sites Preferred Options Document
Object 1
34 responses Support 0 Responses relating to the Mineral Sites Preferred Options Document in its entirety.
Comment 33
Consultee Response
In response to the NPPF (in particular para. 153), we advocate that the plans should be brought together and progressed as one Local Plan. This would benefit plan-making because there are several issues such as development management policies for waste sites, environmental criteria-based policies and allocations which are best considered alongside each other. At the very least the MWDF needs Tonbridge & to be rebranded the Minerals and Waste Local Plan and a clear justification needs to be provided for continuing with the production of Malling three separate plans following different plan-making timetables. The documents will also need to demonstrate that they have met the Borough Duty to Cooperate, introduced by the Localism Act, insofar as they have been prepared in liaison and in collaboration with the Districts. Council Whilst it is recognised that there is a need to identify additional sites to meet the plan requirements, concern is expressed about the clustering of sites in and around the Borough Green area and on the border between Tonbridge & Malling and Tunbridge Wells and the cumulative adverse impacts these will have.
Mineral Sites Preferred Options Document Shepherdswell with Coldred PC wishes to ask that every effort be made to route heavy goods vehicles associated with minerals and 4 waste movement away from village roads. Barming PC was very interested in KCC's helpful response (i.e. "that national planning policy Parish requires that applications are assessed against a wider range of planning issues than landbanks alone"). It would be helpful to include Councils a footnote to that effect somewhere in the final document, particularly in view of the forthcoming inquiry into Hermitage Quarry which might well prove to be a landmark decision, whichever way it goes. Teston PC agrees with the views expressed by Barming PC.
We have a number of comments and concerns relating to habitat loss, nitrogen deposition, sulphur emissions, hydrology and water Kent Wildlife quality, noise and disturbance, supporting habitats and the contribution of restoration to the delivery of the Biodiversity Opportunity Areas Trust (BOAs). Detailed comments on the Preferred Options Document and individual mineral sites available here.
Would be helpful to understand what planning conditions are likely to be necessary on each allocated site to give reassurance to those who are concerned about the impact of development and to provide clarity for land owners and developers. Need clarity about the Natural management of the development and operation of allocated sites, to minimise impact on local landscape character, particularly for those England sites in AONBs. HRA narrative requires further clarification through a simple spatial analysis of traffic generation by each of the allocated mineral and waste sites. Mineral Sites Preferred Options Commentary Report Kent County Council 5 4
Consultee Response Document Options Preferred Sites Mineral
The Woodland Trust considers that the potential indirect impacts on ancient woodland from adjacent development must be recognised Woodland in the Mineral Sites Preferred Options Document and that where site allocations affecting ancient woodland are taken forward, sufficient Trust buffering between development and woodland is clearly identified.
There is still no explicit mention of the Water Framework Directive (WFD). This omission and the assessment of the options may mean that the Preferred Options Document overlooks the potentially serious negative impacts and adverse effects that some mineral activities could have on the aquatic environment and on groundwater. Regulation 17 and the associated Regulations need to be considered in this Plan (available here). There is a legal requirement to improve and restore water bodies to reach their ecological potential or status. The requirements of the WFD are as important as the requirements of Habitats Directive. KCC, in their Local Plans and site plans, need Environment to steer site operators/developers so they can do their part to protect and improve our waterbodies in accordance with the requirements Agency of the WFD as part of their overall project. Flood Risk - those sites that have been identified as at risk to flooding in the Strategic Flood Risk Assessment (SFRA) will need to be supported by site specific flood risk assessments (FRA). The FRAs will need to demonstrate that workings will not impede flood flows or reduce flood storage. Biodiversity - there is a legal requirement for no deterioration to waterbodies. Therefore all hydrogeological and hydrological studies will have to demonstrate without any doubt that the proposed extraction sites will not reduce flows and impact on ecology in the watercourses.
We have been pleased to see that many of the most damaging site options do not feature in the document. However, we do have a number of significant outstanding concerns in relation to the sites which have been brought forward. We do not consider sufficient Royal Society safeguards to have been put in place to ensure compliance with the Habitats Regulations. As such, we must object to the Mineral Sites for the Plan Preferred Options Document pending provision of sufficient information to assess impacts. Site restoration - we have identified a Protection of number of issues we wish to raise in relation to the restoration of minerals and waste sites as set out in the Preferred Options Document Birds (Annex 3). We recommend that the restoration of sites that are close together ('cluster' sites) should be considered together at a landscape scale. Biodiversity Opportunity Areas (BOAs) should be used to guide decisions regarding restoration to priority habitats in these 'clusters'. 'Cluster' sites should be shown together on one map. Full response available here.
As noted in our introductory comments, without prejudice to the preferred outcome of a 'preferred area' allocation in the Mineral Sites Plan there are insufficient reserves remaining in the existing Hermitage Quarry to await the outcome of the Mineral Sites Plan process Gallagher in the autumn of 2014. A planning permission for an extension to Hermitage Quarry will be required in advance of that date to ensure Aggregates continuity of production via a transition from the exhaustion of reserves at the existing quarry to commencement of operations in the Ltd westerly extension. These circumstances and important wider considerations of ensuring “steady and adequate supply” should be reflected in amendments to the text of Sections 5.5 and 5.7 in the document. 6 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Mineral Sites Preferred Options Evidence Base
Object 1
13 responses Support 0 Responses relating to the Mineral Sites Preferred Options Evidence Base.
Comment 12
Consultee Response
Draft Local Aggregate Assessment: Our comments relate mostly to your Draft Local Aggregate Assessment. We note the decline in sharp sand and gravel resources with the near exhaustion of the traditional area of gravel working in the Stour Valley. However, your Surrey sales of land-won aggregates have not decreased as steeply as in most other SE counties, so that consequently your share of the County regional total has risen over the past decade. Therefore, we welcome your continued safeguarding of wharf capacity which will be needed Council in the future, not just for maintaining aggregate supplies to Kent, but for neighbouring counties like Surrey where extraction of sharp sand and gravel is likely to peter out towards the end of the 2020s.
Draft Local Aggregate Assessment: Medway is keenly aware of the importance of the safeguarding of imported aggregates as terrestrial Medway deposits become increasingly difficult to exploit, due to environmental and economic constraints. The continued safeguarding of operational Council wharves, associated facilities and the maintenance of separation between other development, that are inherently incompatible with such facilities should continue and be a central theme in the evolution of the Kent Waste and Minerals Core Strategy.
Draft Local Aggregate Assessment: The Kent Downs AONB Unit have already responded on the question of whether soft sand and Mineral Sites Preferred Options Evidence Base sand and gravel should be separated in our consultation response to the Draft Core Strategy. We do not support the amalgamation of 5 the two types of mineral. Mineral Site Assessment: We appreciate that the NPPF is poorly worded to the point of lacking clarity. KCC has chosen to interpret it to mean in effect 'every silica sand site must always have enough reserves for production for at least 10 years'. Kent Downs However, the construction of the policy is couched in terms of supporting investment in plant, and can be interpreted less controversially AONB to mean that 'permissions should be granted for at least 10 years to support actual and proposed investment in plant' (and the next clause of NPPF paragraph 146 refers to providing 15 year permissions "for silica sand sites where significant new capital is required"). In our view the latter interpretation is more sensible and realistic. We doubt that it is the intention of the NPPF to offer all existing silica sand sites an unqualified right to be given unending extensions for the indefinite future on demand to ensure continuation of current output for at least the next 10 years.
Minerals and Waste Sites Interim Sustainability Appraisal Report: Table 8.2 currently states that minerals or waste workings would only have 'some adverse effect' if they are within 100m of these assets. In reality any minerals or waste working is going to have a very KCC Heritage significant adverse effect on heritage assets if they lie as close as 100m and the rating “(-)” should be changed to “(- -)” to reflect this. Furthermore, the text states that “Sites which have archaeological potential could have positive or negative effects, dependent on the Mineral Sites Preferred Options Commentary Report Kent County Council 7 5
Consultee Response Base Evidence Options Preferred Sites Mineral
management of excavations”. We cannot really imagine that introducing minerals or waste working to an archaeological site is likely to have a positive effect as the working would impact negatively on the safety and stability of the remains, public access, the setting and the potential for further study. The “(?)” rating in the table should therefore be changed to “(-)”. The sentence "the effect of individual developments on the countryside and historic environment can be influenced by a number of factors, including lines of sight. As such, in practice there is much potential to avoid and mitigate effects where minerals and waste sites and sensitive features are in close proximity". is somewhat convoluted and might usefully be clarified. It draws attention to the need for minerals and waste workings to take account of the settings of heritage assets, which we would support, but may be taken to suggest that impacts on assets can be discounted if there is no actual line of sight. In many situations this will not be the case and much more substantial mitigation will be needed to avoid negative impacts on heritage assets.
Royal Society Habitat Regulations Assessment - Screening of Preferred Sites: The RSPB considers that the following further information is required for the to assess impacts on Europeans sites: (1) an assessment of potential impacts from Nitrogen deposition on the SACs within Kent, with Protection of a particular focus on in-combination impacts from the Richborough Waste Corridor; (2) an assessment of potential impacts from sites Birds on nearby SPA and Ramsar sites, with a focus on direct land take and disturbance.
Technical Secretary of Draft Local Aggregate Assessment: A significant point was raised at the July 18 Industry Stakeholder Group Meeting - namely that the South East Kent MWDF is not intending to provide separate allocations for sharp sand and gravel and soft sand. This appears to be contrary to England NPPF. From the documents it is apparent that the only reason for this is in order that the plan can allocate sufficient sites to meet the Regional combined allocation. But this avoids the reality (i.e. clearly stating that Kent is unable to meet the allocation for sand and gravel). That Aggregates is bound to be picked up at an Examination in Public (EiP) and runs a real risk of the plan being found 'unsound'. Working Party
Draft Local Aggregate Assessment: It is noted that the principal purpose of the document is an update of the May 2011 Topic Report to reflect the requirements of the NPPF. In so doing, of key importance, is the recognition that MPA's "should plan for a steady and adequate supply of aggregates" (ref Topic Report paragraph 1.01). However, paragraph 1.01 provides only selected extracts from the full requirements of NPPF, as set out in paragraph 1.45 of NPPF, and should thus be extended. For consistency, changes should also be made to paragraph 7.2.6 of the Topic Report. In the context of the above, and KCC's support for an extension to Hermitage Quarry, Gallagher paragraph 7.2.7 is unnecessary and should be amended. Mineral Site Assessment: Changes should be made to paragraph 6.2.6 to Aggregates similarly reflect the resolution of KCC in relation to the Hermitage Quarry extension (noted in para. 6.2.4), where the first sentence should Ltd be amended to reflect the fact that an extension to Hermitage Quarry may become a commitment by the date of the adoption of the Core Strategy and Mineral Sites Plan, and which thus explains the decisions: (a) to introduce a policy into the Core Strategy which makes a commitment to, and would provide flexibility to ensure that steady and adequate supplies of ragstone are available; and (b) not to identify a specific ragstone preferred area in the Mineral Sites Plan, noting, in any event, that with the exception of the Hermitage Quarry westerly extension, no other ragstone sites have been promoted by the industry or land owners.
General Habitat Regulations Assessment - Screening of Preferred Sites: KCC has not acquired evidence as to whether the organisation proposing Public to use a site for extraction or waste is a fit and proper organisation who will deliver to their proposal. 8 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Sand and Gravel Sites
Object 1
3 responses Support 1 Responses relating to sand and gravel sites.
Comment 1
Sand and Gravel Sites Consultee Response 6 In-combination impacts of Sites 1, 2, 17, 49 and 71
All these sites are adjacent to four interconnected LWSs that contain wetland habitats dependent on the supply and quality of water that emanates from all the above sites. We question whether this sensitive ecosystem is able to maintain the level of disturbance that will result from almost 4.5 million tonnes of gravel and sand being extracted within the locality, especially considering the quarrying already undertaken within the area. We are extremely concerned that the habitats and water supply will be irreparably damaged. We note that phased quarrying has been recommended for Sites 17, 49, and 71 and would recommend that Site 2 be included within the phasing. Kent Wildlife Kent Wildlife Trust requests, as administrators of the LWS network, that hydrological studies are undertaken throughout the area to Trust inform an assessment regarding the viability of the proposed sand extraction within all these sites. It is our view that this study should inform the level of sand that can be extracted without causing irrevocable impact on the surrounding ecological sites.
To ensure the highest ecological gains throughout the area, a connected restoration management and monitoring strategy should be devised within the policy process to ensure that there are no long term impacts on the water supply, supporting wetland habitats and ancient woodland present and that landscape scale enhancement is achieved between all these sites. If hydrological impacts are not fully investigated and extraction levels dictated by the ecological constraints we would strongly object to all the above sites.
Object - the NPPF recommends having separate land banks for materials which have a separate use and market. There should be a separate landbank for soft sand and for sharp sand and gravel. When the majority of the existing reserves are of soft sand and the Hanson greatest demand for materials is for sharp sand and gravel it makes little sense in identifying new resources which are mainly soft sand. Aggregates If the sharp sand and gravel sites were not regarded as being acceptable perhaps the assessment criteria should be relaxed (something that would be relatively easy to do if a scoring system had been used to assess the sites) or developers should be allowed the opportunity to demonstrate how the constraints could be overcome. Mineral Sites Preferred Options Commentary Report Kent County Council 9 6
Consultee Response Sites Gravel and Sand
Brett Aggregates Ltd (BAL) is the wholly owned subsidiary company of Robert Brett and Sons Limited (Brett), the Canterbury based aggregates, building materials and civil engineering independent business. BAL operates a number of mineral extraction and waste management facilities throughout Kent and we have been involved in previous consultations to the emerging Kent Minerals and Waste Core Strategy, and the county's Call for Sites.
We have been actively promoting new sites and extensions to existing sites, both for adoption into the emerging Mineral Sites Plan and the emerging Waste Sites Plan. We have submitted consultation responses to both of these draft plans. The Mineral Sites Preferred Options consultation invites our views on mineral extraction, processing and importation sites (including secondary and recycled Brett aggregates) for the plan period to the end of 2030. We have promoted a number of sites for adoption in the emerging Mineral Sites Plan, Aggregates for mineral extraction and secondary aggregates recycling, of which, the following sites have been identified by KCC as preferred options: Ltd • Site 75: Boltons Field, Lenham Quarry Extension (0.638mt) • Site 76: Chapel Farm (3.5mt) • Site 77: Burleigh Farm and Tile Lodge (2.7mt) • Site 73 A - D: Lydd Quarry Extensions (1.6mt) • Site 91: Animal Products Site, Faversham (Recycled C&D)
We fully support KCC's allocation of these preferred mineral extraction and recycling options. 10 Kent County Council Mineral Sites Preferred Options Commentary Report
Soft Sand Sites
Site 6: Land Adjacent to Platt Industrial Site, Platt
Responses for Site 6: Land Adjacent to Platt Industrial Site, Platt
Object 4 This site is proposed for 1.35mt of sand extraction. The site is currently scrub land and has been partially worked for sand in the past. Adjoining uses include a quarry and an 12 responses Support 1 Sand and Gravel Sites industrial estate. Use would be made of the existing infrastructure and access arrangements 6 Comment 7 from a neighbouring mineral extraction area to the east of the site.
Consultee Response
Sevenoaks Sevenoaks DCis concerned at the increase in traffic that may result from these proposals, especially in relation to the A25. Any District allocation/planning permission should fully consider the impact of additional traffic on access routes through adjoining districts and Council consider conditions to restrict the number of vehicle/lorry movements.
Platt PC's objections and comments for the previous proposals in our area still apply, namely: • The A25 was never constructed to accommodate the weight and volume of traffic that is currently using it. This is still the case and an increase in volume is not acceptable. • We experience dust and debris in summer and mud and debris in winter • Should this proposal be considered, a new route should be stipulated. A new access route is feasible from this proposal, linking up with Borough Green Sandpits and out on to the A227. This will also serve other non-quarry traffic accessing the industrial estate. It will also be possible that Nepicar Quarry could access this route as all three pits will be interlinked. As an alternative, there is already an exit to Nepicar roundabout at the A20/M26 junction, with a metalled road into Nepicar Farm. If access on to the A227 is not available then all three quarries could access this route. It would not be impossible for alterations to be made to this junction to satisfy Kent Highways. Cumulative Effect of Sites 6 and 105 - should these proposals be Parish adopted with the condition to use the Nepicar entrance/exit, vehicles should be encouraged to head eastwards towards the A25/A20 Councils junction at Wrotham Heath and NOT towards Platt. However, we would still maintain that the access/egress of these sites could feed directly on to the A20/M26 junction at Nepicar roundabout, via the existing road, to enable heavy freight to access the main routes directly without further disruption to Wrotham Heath, which is already a busy, built up, junction and could lead to air quality problems. Again, it would not be impossible for alterations to be made to this junction to satisfy Kent Highways. We also refer to two objectives from the proposed Kent Freight Action Plan, namely: Objective 4) to take steps to address problems caused by freight traffic to communities; and Objective 5) to ensure that KCC continues to make effective use of planning and development control powers to reduce the impact of freight traffic. Wrotham PC - this site has the potential to exacerbate the new AQMA at Borough Green unless all traffic exits onto the A25 from the Nepicar Quarry exit and turns left only. It is noted that the Preferred Options Document suggests this exit for both the above quarries and WPC agrees with this approach provided the left turn only is added. Mineral Sites Preferred Options Commentary Report Kent County Council 11 6
Consultee Response Sites Gravel and Sand
The access onto the Maidstone Road needs careful consideration. Lorry routing via Wrotham Heath to avoid the village of Platt and Kent Downs Borough Green suggested. Mitigation suggestions in the event of allocation include: • Lorry routing • Working, restoration and after use AONB management plans to ensure restoration of landscape character over the entire existing and new site.
We note that this site has been scoped out of the HRA for impacts on the European network. This is a confusing assessment as Waste Site 61: SCA Packaging, New Hythe, Aylesford is scoped in for in-combination impacts with Site 105, but Site 105 is scoped out. It is our view that Site 105 should be scoped into the assessment and therefore due to the proximity of Site 6 to Site 105, it will also follow that Site 6 also needs to be assessed for in-combination impacts on the North Downs Woodlands SAC as a result of in-combination nitrogen deposition. We request clarification regarding the criteria used to assess possible impact for all these sites. This site is within the Greensands, Heaths and Commons BOA and in close proximity to TM02 Valley Wood and Wrotham Golf Course LWS, designated for its remnant heathland and ancient woodland habitats. A fragment of ancient woodland is also present at Firemanshaw Wood. There Kent Wildlife are opportunities to extend these habitats within the restoration plans in partnership with the other sites. Within the previous consultation Trust we recommended that the site be restored to woodland and heath. It is important to maintain connectivity between the ancient woodlands within the restoration plan; however, due to the site’s location within the BOA we now feel that restoration should primarily be acidic grassland or heath re-creation. We are concerned that no heathland restoration is detailed within the plan, with the site being restored to previous conditions. We welcome the restoration opportunities identified for woodland and ponds but feel that the plans should reflect the targets of the BOA. In-combination impacts with Site 105 on TM02 LWS will need to be considered and we would recommend that a joint restoration, management and monitoring program be devised incorporating Site 6, 105 and Site 24 and the LWSs that may be impacted. If in-combination impacts on the LWS are not assessed as part of the final Development Plan Document and appropriate mitigation and restoration measures incorporated into the final policy, we would object to the allocation of this site.
We support the proposed allocation of Site 6 in the Mineral Sites Plan Preferred Options Document. We are currently in positive dialogue with the owners of the adjoining Nepicar Quarry regarding the possible joint working of the sites and the potential for sharing their access from the A25. We, however, maintain that this site can be worked and accessed independently. Whilst we welcome the site's allocation, Earth it should be better recognised that Site 6 is the highest performing proposed soft sand extraction site in terms of the SA. In many cases, Enterprises the site substantially outperforms other proposed sites for soft sand extraction. This should be recognised in the text, possibly by the Ltd inclusion of the SA score or a ranking against other sites. Nevertheless, in light of the URS Interim SA Report May 2012, we contend that the site should be reassessed more positively in the following areas: • Natural Environment • Climate Change • Land • Health and Well Being • Highways. Full response available here.
• Pollution from increased traffic and quarry workings • Air quality should be monitored • 'No right turn' introduced for all traffic leaving the site so that school children and residents have some protection from greater volume of HGV traffic passing along A25 • Noise from plant is very disturbing (especially reversing ‘beeps’ which carry over a long distance) • Concern about footpaths - they are used by many people so need to remain • Concern about early hours of operation • Why it is thought necessary to extend the sand quarry at General Nepicar when the total consumption of four materials used in building (i.e. bricks, sand and gravel, crushed rock, and cement) has fallen Public nationally? • If chosen for extraction, what time frame will be given to the archaeological team to investigate the Roman Cemetary within the site and what guarantee we will have as a community that it will be preserved and possibly opened to the local school children/public at least for a period of time? • Who will ensure that “high operational standards are maintained and site restoration proposals are in keeping with the local environment”? • Risk to protected species such as grass snakes and adders. 12 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 24: Land North of Addington Lane, Trottiscliffe
Responses for Site 24: Land North of Addington Lane, Trottiscliffe
Object 2 Proposed extension to the existing Addington (Wrotham) Quarry. The site area currently consists of arable fields. Adjoining uses include agriculture, country lanes and the existing 5 responses Support 1 quarry site. It is located within the Kent Downs AONB. The upper sands are intended for building sand and the lower deposit is suitable for use as industrial sand (silica sand). Site Comment 2 Sand and Gravel Sites 24 can also be found in Chapter 8: Silica Sand Sites. 6
Consultee Response
Wrotham WPC agrees that this nationally important reserve should be worked via the existing pit by utilising an underground conveyor. Restoration Parish needs to be of a high standard that reflects the land's protected AONB status. Council
Object to the allocation for silica sand and/or soft sand and inert fill. Soft sand - there is no justification for the need for this site in the Kent Downs AONB for soft sand as there are other sites outside the AONB that can fulfil the need for soft sand over the plan period. Fill - inert fill to AONB provide for restoration would prolong the life of the site and not necessarily provide for final good restoration. There is no need to provide sites for inert fill.
This site is further to the north of the Greensands Heaths and Commons BOA than the previous site and is adjacent to TW29 Ryarsh Woods LWS. Within Kent Wildlife Trust’s previous consultation response we highlighted the need to ensure that there was no change to the hydrology of Ryarsh Wood LWS and the water supply to the woodland as a result of the proposed quarrying. The LWS is designated as it contains wet ancient woodland which is dependent on the water supply to the streams and ditches that interlace Site 24. We can find no reference to the safeguarding of the water supply within the site specific considerations. We recommend that safeguards to Kent Wildlife ensure the water supply and hydrology of the LWS are not impacted are incorporated within the policy for this site. Trust We welcome the recommendation that heathland or acidic grassland will be created however, due to the sensitivity of the area, we are concerned that there is still a suggestion that this site will be restored to agriculture. Due to the possible impacts on Ryarsh Wood LWS it is our view that it is essential that within the final policy a commitment is secured to restore the site back to acidic grassland or heath to help deliver the BOA target. Mineral Sites Preferred Options Commentary Report Kent County Council 13 6
Consultee Response Sites Gravel and Sand
We recommend that a joint restoration, management and monitoring program be devised incorporating Site 6, 105 and Site 24 and the LWSs that may be impacted. As this site is an extension to the Addington (Wrotham) Quarry there are opportunities to extend the heathland and grassland habitat into the area being worked at the present time. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator, the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.
If hydrological impacts on the LWS are not assessed as part of the final Development Plan Document and appropriate mitigation, restoration and management measures incorporated into the final policy, we would object to the allocation of this site.
The National Trust owns Wrotham Water Farm to the west of this site and Coldrum Long Barrow to the north. This site lies within the Kent Downs AONB and adjacent to the Wealdway which leads to Coldrum and thence up the escarpment of the North Downs. The site National Trust is hitherto open countryside, and is likely to be highly visible from the Downs. As such we do not believe that the site would meet the criteria set out in the NPPF for an exception within the AONB. The National Trust object to the allocation of this site for sand extraction and waste disposal.
The inclusion of the building sand in the Wrotham (Addington) Quarry extension area is supported. Whilst the primary purpose of identifying the extension area is to provide resources of high quality silica sand the silica sand lies beneath the building sand and therefore Hanson the building sand must be removed first. The building sand from Wrotham is an established and accepted source of supply to the local Aggregates construction industry in the area. The inclusion of 500,000 tonnes of building sand in the extension area will contribute to the overall requirements to identify over 23 million tonnes of new sand/sand and gravel resources during the plan period. 14 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 75: Boltons Field, Lenham Heath
Responses for Site 75: Boltons Field, Lenham Heath
Object 28 This site is a proposed extension to the adjoining Lenham Quarry, also known as Shepherd's Farm Quarry. The site area currently consists of rough pasture, wood storage 32 responses Support 2 and a fruit orchard. Adjoining uses include mineral extraction, farmland and residential Comment 2 and commercial properties. Sand and Gravel Sites 6 Consultee Response
Development Management - we are concerned that quarrying at this site would significantly compromise residential amenity in proximity to the site. We also doubt that potential adverse effects on residential amenity can be sufficiently mitigated in the area Maidstone surrounding the proposed site. Transport - this simply involves an extension to the existing quarry. There will be no new accesses Borough Council to the site, instead the existing one will continue to be used for both sites. Although there will be an increase in the number of HGVs accessing the area, we do not think that this would have a significant impact on the road network given there are HGVs already accessing the site.
Lenham PC wishes to maintain its objection to the allocation of Site 75. In summary, our objections are as follows: (1) The site is unacceptably close to a number of residential properties. Occupiers of those properties would suffer from noise, dust (including PM10 particles), vibration, fumes and the impact of lighting in a quiet rural area. The limited bunds and buffer zones proposed to mitigate this would be quite inadequate; (2) The text refers to “suitable sufficient buffer zones” being left. If anything like an adequate buffer zone were to be left (say 100m), the resulting workable area would be too small to be worth extracting. This site has only been made Lenham Parish viable by presupposing an unacceptable impact on neighbouring occupiers; (3) Local people have recorded a range of scarce wildlife Council on the site, including bats, grass snakes, slow worms and lizards; (4) Working the existing Lenham quarry has been very intermittent in recent years, so much so that we question why KCC has not treated it as a dormant site. Firstly, this does not support a strong case of need. Secondly, if Boltons Field were to be worked in this manner there would be an even more prolonged period of disruption for local people; (5) Although the site is stated to be an extension to the adjoining Lenham quarry, the accompanying plan shows it as being worked separately, with a causeway left in between. This would leave a deep hole in the ground with little prospect of it ever being restored to the useful countryside which the site is at present.
Kent Downs We support the Preferred Options consultation assessment. We advocate the mitigation of views from the AONB of both the working AONB face and the final restored north facing slopes. Mineral Sites Preferred Options Commentary Report Kent County Council 15 6
Consultee Response Sites Gravel and Sand
This site is not within a BOA but provides important extension to the Mid Kent Greensands and Gault BOA. There are also likely to be in-combination impacts on the LWS network with Sites 76 and 77 as they are all in close proximity to locally designated sites. Kent Wildlife Trust seeks clarification regarding the restoration for this site. As previously identified, this site is within 127m of Pasture and Ponds Lenham Forstal LWS. Our most recent representation for Shepherds Farm Quarry expressed disappointment with the mitigation strategy proposed. As the original application was historic there was little scope to improve the mitigation however, any new proposal will need to comply with the more rigorous ecological protection now in force within the NPPF. We are concerned that despite mention of the need to mitigate the LWS habitat already lost and provision of neutral grassland and ponds to mitigate any impact the extension may have, it is advised that restoration should complement the existing consented area. It appears that the site would be supported if restoration is to agriculture with acid or neutral grassland and/or other biodiversity improvements. These uses are likely to be in conflict with each other unless the agricultural use was very low level conservation grazing. Any additional fertiliser, herbicide or pesticides used would lead to enrichment of the neutral grassland and damage to the flora and invertebrate communities. Kent Wildlife If intensive grazing were established on site then there would be very little benefit to ecology as the neutral grassland could not Trust establish or thrive. Due to the damage already incurred to the LWS it is imperative that any further quarrying seeks to compensate for past habitat destruction and enhances all available habitat for biodiversity to extend the habitats already present in the area. For the above reasons we would urge KCC to obtain a firm commitment to the restoration of all the extension to neutral grassland and ponds and the provision of a management and monitoring plan to secure the management of the extension in the long term. If appropriate safeguards to conserve the LWS and restoration to extend biodiversity are not incorporated within the final site policy, we would object to allocation of this site. We recommend that a joint restoration, management and monitoring program be devised incorporating Site 75, 76 and Site 77 and the LWSs that may be impacted. As this site is an extension to the Shepherds Farm Quarry there are opportunities to extend the heathland and grassland habitat into the area being worked at the present time. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator, the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.
Charing The site has not been fully explored and it is therefore premature to determine its national importance. Because of the difficult ground Archaeological conditions it would require expert examination using modern forensic skills. We therefore object to Site 75 on the grounds of insufficient Group knowledge until at least further investigations are conducted.
Brett Aggregates We fully support KCC's allocation of this preferred mineral extraction option. Ltd
• Consultation process is flawed - failure to consult properly and disclose important information. KCC did not inform residents of the operator’s intention to remove the bund between the existing quarry and the proposed site, and did not explain the increase in the estimated reserve of sand (i.e. from 500,000 to 635,000 tonnes). The plan map incorrectly shows the bund in place with an indicative access road between the existing and proposed site • Site incorrectly listed as ‘rough pasture’ - it is in fact fertile and productive land General Public used for growing soft fruits. This agricultural land offers far more scope to enhance local employment benefits than a quarry • Noise and air pollution from increased HGV movements and machinery • Increased traffic on the A20 will endanger pedestrians, cyclists, horse riders and also cause more damage to the roads, which are already in poor condition and very narrow (e.g. Rose Lane) • Structural damage to properties from vibration • Dust from sand extraction poses serious risk to residents’ health, particularly small 16 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
(PM10) particles • Residential amenity - adverse effect of dust on residents’ properties, cars, washing, making gardens intolerable during summer • Scepticism over whether operator will restore land to its original state after extraction has finished • Bunds will ruin view of the natural landscape which is part of an AONB • Development of the site will affect the value of residents’ properties • The buffer zone considered is not large enough to protect residents from noise, dust and vibration caused by extraction and are shown in a misleading fashion in the Preferred Options Document. The depth of the buffer zone actually required would very much reduce the land available for extraction to roughly two thirds of the overall area, thus questioning the commercial viability of the site • Development will affect local water courses • Water table could be adversely affected in addition to ecosystem associated with local wetland wildlife reserve • Smell will be an issue if the site is used for landfill after extraction has finished. Filling the hole left by extraction with waste could contaminate local water courses due the type of draining soil in the area • Little or no economic benefit for local people • Existing quarry is worked intermittently, presumably because extraction is not very profitable. We do not need any
Sand and Gravel Sites more sites for land won soft sand and most of our sand is imported from marine deposits. Better to use the land for agricultural
6 purposes • Security floodlights will cause light pollution • Tree planting would not have any great effect on reducing noise, especially as trees would be relatively small by the time extraction took place. Nor would it be prudent to plant trees too close to any buildings bordering the site, without eventually causing overshadowing or even structural damage. A profiled mound presents a much more effective alternative • Site is wholly disruptive and unacceptable to a degree which is totally disproportionate to the small commercial benefit which would be achieved by the operator • Adverse effect on residents’ physical and mental health and on local wildlife. Mineral Sites Preferred Options Commentary Report Kent County Council 17 6 This page has been left blank intentionally. adadGae Sites Gravel and Sand 18 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 76: Chapel Farm, Lenham
Responses for Site 76: Chapel Farm, Lenham
Object 20 The site is located 1km to the west of the existing Lenham Quarry. The site area is currently arable and grazing farmland. It is located to the south of the Kent Downs AONB. Adjoining 28 responses Support 1 uses include residential properties, farmland, sewage works and nearby woodland. There Comment 7 is an area of Ancient Woodland adjacent to the proposed route of the haul road. Sand and Gravel Sites 6 Consultee Response
Development Management - this is an extremely large site and we are concerned that the cumulative impacts of operations in the area would potentially have a negative impact on landscape (setting of AONB), visual amenity, SNCI and ancient woodland, and residential amenity (particularly HGV movements on unsuitable roads). Transport - the existing access arrangements to the site are Maidstone of significant concern given the number of HGV movements the proposal would generate. However, it is proposed to construct a new Borough Council access road from the A20 Ashford Rd to the site. This is the best solution as it will minimise the impact on the existing road network, and on local villages. However, the new road needs to be considered with regard to all planning considerations as it may well have a significant impact on ecology and the landscape area.
Object for the following reasons: (1) Site 76 would have a severe impact on views from the Kent Downs AONB; (2) Long open views across the site from Lenham Heath Road and from the footpaths/bridleways that cross it (including the Stour Valley Walk) would be ruined not only by the proposed working but by the protracted and uncertain process of restoration at a lower level. An attempt to screen the workings by bunds would destroy the open character of the area and the bunds would look alien; (3) The Plan admits that some of the site is grade 2 agricultural land. The importance of such a scarce and irreplaceable resource is being increasingly recognised (NPPF para. 112). Restoration to “low level acid grassland and heathland” as stated makes a mockery of this resource. Lenham Parish At any rate the grade 2 land should be excluded; (4) This site is known to be rich in archaeological remains from prehistory onwards. Council The Plan comments that preservation in situ of particular features may be necessary. As the location of any such features is unknown, it is obvious that this could render the site unworkable; (5) The proposed access would destory hedgerows and add to the overall visual impact. It would then emerge onto a particularly fast-moving and dangerous stretch of the A20, only about 200m from the existing junction with the road leading to Lenham Heath, where new accesses have in the past been rightly resisted; (6) There are several residential properties bordering or close to the site whose occupiers would suffer adverse effects, as detailed for Site 75; (7) The site is home to numerous wildlife (slow worms, common lizard, possible sand lizards). The headwaters of the River Stour run through this site and would be vulnerable to pollution or silt discharge. Working this site would also threaten the work put into the Mineral Sites Preferred Options Commentary Report Kent County Council 19 6
Consultee Response Sites Gravel and Sand
area by the Heaths Countryside Corridor, partly funded by KCC, which crosses the site; (8) The Plan is ambiguous about when the site would be worked. If allocated, working should commence only after the exhaustion of permitted reserves at Lenham quarry and Boltons Field; (9) If it were still felt appropriate to include the site, only part should be allocated, either the eastern or the western half.
Reserve judgement on the allocation of the western half of the site north west of Chapel Farm depending on the method of working Kent Downs and phased restoration/pre-landscaping. Mitigation - careful method of working and phased restoration to ameliorate impact of views AONB from the Downs scarp. Pre-landscaping of site and haul route to ameliorate impact of views from the AONB scarp.
Site 76 is not within a BOA but runs along the boundary of the Mid Kent Greensands and Gault BOA. The proposed operations are likely to have an impact on the adjacent LWS if not mitigated. Kent Wildlife Trust therefore welcomes the conditions that have been put in place to safeguard the hydrology and water courses within the proposed quarry. We are also pleased to note that the restoration is to be acidic grassland and heathland. The safeguarding of the water resources and restoration plan will limit the impact on the adjacent Lenham Heath and Chilston Park LWS and extend this habitat into the surrounding countryside. As this site is just outside Kent Wildlife the Mid Kent Greensands and Gault BOA the proposed heathland and acidic grassland will form a valuable addition to this landscape Trust scale corridor. To ensure management of the re-created habitat we would recommend that the final policy specifies that a management and monitoring strategy and appropriate funding for management in the long term be secured as part of any permission granted. As this site is situated within the proximity of Site 75 and 77 we recommend that the operators work together to achieve landscape scale enhancement connecting existing LWSs with the new habitats wherever possible. If a management and monitoring Strategy is not secured as part of the final site policy, we would object to the allocation of this site.
KCC Heritage - need to establish the extent of areas that warrant preservation through detailed archaeological evaluation as early as possible, as sizeable areas may be required to preserve the assets meaningfully. Site should only be supported subject to the Archaeology protection of the setting of the nearby listed buildings, particularly those at Chapel Farm and Royton Manor. Lenham Archaeological Society object to Site 76 as it is a major archaeological site. Sand extraction warrants a complete major professional dig of the whole field. Charing Archaeological Group object on the grounds of insufficient knowledge until at least further investigations are conducted.
The site must include mitigation for the loss of ponds and other wetland features. The current proposal suggests that the loss of Environment wetland features will form part of the restoration of the site, however this would lead to a significant loss of ponds and ditches for a Agency significant period of time. These features should be created before they are lost.
Object - site contains an unnamed block of ancient woodland (Grid Ref. TR909511) located within the site boundaries in the northern Woodland Trust section. Ancient woodland (Grid Ref. TR146377 and TR138375) is located adjacent to Site 76. This will be susceptible to indirect impacts from the operation of the quarry. Development will result in the loss of and damage to ancient woodland.
Brett Aggregates We fully support KCC's allocation of this preferred mineral extraction option. Ltd 20 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
Wastewater infrastructure crosses the site and needs to be protected so that it can continue to fulfil its function. Future maintenance Southern Water and upsizing of the infrastructure must be secured through easements of between 6 and 13 metres. Diversion of the infrastructure may be possible at the developer's expense, provided a feasible alternative route is available.
• Noise, dust, pollution (air and light), congestion • Bunding will be insufficient to protect views from the AONB due to the contours of the land • Alterations to the water table in the vicinity of the River Stour could have serious consequences for the watercourse and its drainage • Archaeological remains • Roads are very narrow (i.e. Rose Lane) and in poor condition and are therefore unsuitable for HGVs • New access route will increase visual impact of development and worsen road safety (unlikely to meet Highways Agency General Public selection criteria) • Removal of ancient woodland and footpaths • Proposal will affect a number of protected and declining wildlife species (nesting skylarks, common lizard, white clawed crayfish) • Yield of 68,000 tonnes per hectare does not constitute efficient use of land under Sustainability Objective 8 when compared to other proposed sites • Adverse effect on property values • Smell and Sand and Gravel Sites contamination if landfill chosen as restoration method • Effect on local tourism • Rigorous tree and hedge planting scheme required 6 to mitigate impact of the proposed access road. Road should be reinstated after completion, leaving an avenue of trees behind. Mineral Sites Preferred Options Commentary Report Kent County Council 21 6 This page has been left blank intentionally. adadGae Sites Gravel and Sand 22 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 77: Burleigh Farm & Tile Lodge, Charing
Responses for Site 77: Burleigh Farm & Tile Lodge, Charing
Object 47 Proposed extension to the existing Charing Quarry. The mineral from this area would be moved by conveyor to the existing quarry plant site. The site is currently arable farmland. 56 responses Support 3 Adjoining uses include residential properties, woodland to north of the railway and further Comment 6 farmland. The site is crossed by two Public Rights of Way (AW11 & AW12A). Sand and Gravel Sites 6 Consultee Response
Ashford BC - if allocated, the following points should be contained in the policy: (1) Highway Improvements - any proposals for the scheme would need to ensure that any increased impacts on the highway network are mitigated against. This should include preventing any vehicles associated with mineral extraction using Tile Lodge Road; (2) Residential Amenity - we have concerns that the proposed extension site is not well connected to the existing quarry site on Hook Lane. The proposal for a conveyor belt under Tile Lodge Road Borough would need to be constructed in a way which does not affect the residential amenity of the properties on Tile Lodge Road; (3) Rural Councils Character - the site is contained within the Charing Heath Farmlands character area (see Appendix 1). Any development proposals would need to have regard for the character area assessment and specifically protect views from the footpaths adjoining and to the north of the site. Hedgerows, specifically the ones of merit, should be retained and where this is not possible, relocated. Maidstone BC does not consider the extension will have any greater impact on amenity or character of the area than the current site. Transport - the impact on the local road network would be acceptable in transport terms.
Charing PC object for the following reasons: (1) There is a requirement to restore the quarry to a greenfield site on completion, in accordance with the design specified in the application document. Considering this was one of the reasons for not allocating Waste Site 85: Charing Quarry (Waste), Charing the same should apply for Site 77; (2) If access through the restored greenfield site of the former Charing quarry is precluded, there is no other acceptable access for Site 77. The statement in the SA is incorrect. Site 77 does not have good access to the A20. Charing Quarry has adequate access, but it will be restored to a greenfield site; (3) Any development would destroy water courses and potentially disrupt natural drainage downstream. There is no mention of the fact that Parish Councils a watercourse crosses the site, and therefore impacts on its ecological value should be taken into account. Cumulative Effect of Sites 76 and 77 - should Site 76 also go ahead, the potential loss of several tributaries to the Stour must be considered. The more sand that is extracted from Charing Heath and neighbouring Lenham Heath, the greater the extra risk to both the Great Stour and our water supply; (4) Adverse effect on listed buildings and footpaths; (5) Adverse effect on slope stability for northern boundary railway line and stability of accommodation bridge underneath; (6) Adverse effect on wildlife (Great Crested Newts are known to be in the area); (7) The Chapel at Burleigh Farm and its associated unexcavated historic buildings must be carefully preserved; (8) KCC have allocated more soft sand sites that necessary in order to compensate for a shortfall in sharp sand and gravel. Charing Heath should Mineral Sites Preferred Options Commentary Report Kent County Council 23 6
Consultee Response Sites Gravel and Sand
not suffer further depredation in order to tick a box; (9) Charing Heath has endured decades of quarrying, the M20 and HS1. Further loss of landscape quality and amenity to long suffering residents is unjustifiable. The area has paid its debt to the nation, no further degradation of the character of the area should be allowed. Charing Heath Parish object to Site 77 for one overwhelming reason: the sand is not required. According to TRM1, the need for additional soft sand supplies for the period to 2030 is estimated at just 3.2 tonnes while the preferred sites in total would supply 17.1 tonnes. Additional sand from Site 77 is therefore not required.
Support allocation. Mitigation - haul route across existing site should not hold up or impact on restoration, afteruse and land Kent Downs management of existing quarry and should therefore be carefully located and screened with bunding and landscaping from restored AONB existing quarry and area to the north. Restoration and aftercare land management of existing quarry and new site should be of the highest quality. Careful treatment of angles and planting of final batters is needed to ensure no lasting impact on views from the north.
Site 77 is not within a BOA but will provide a valuable extension to the Mid Greensands and Gault BOA if restored for biodiversity. We note that this site is 540m from Pastures and Ponds Lenham Forstal LWS. Although the proposed plans will not affect the LWS directly, due to the interconnected water system between the proposed quarry and the LWS; we have concerns that any impact on the water system within the site could lead to changes in the water quality and supply that feed the LWS, especially when viewed in-combination with Site 75. Within the final policy it will be important to clearly specify investigation of hydrology especially in relation to the LWS and protection of the water courses wherever possible. We are pleased that this issue has been included within the specifications for the site. We welcome the proposed restoration of heathland and acidic grassland creation. However, the site Kent Wildlife specifications also state that low level agriculture will be restored. The ecological and agricultural uses are likely to be in conflict with Trust each other unless the agricultural use was very low level conservation grazing. Any additional fertiliser, herbicide or pesticides used would lead to enrichment of the acidic grassland and heath and damage to the flora and invertebrate communities respectively. If intensive grazing were established on site then there would be very little benefit to ecology as the ecological habitats could not establish or thrive. We would therefore urge KCC to obtain a firm commitment to the restoration of the site to acidic grassland and heath habitat. As this site is situated within the proximity of Sites 75 and 76 we recommend that the operators work together to achieve landscape scale enhancement connecting existing LWSs with the new habitats wherever possible. If a management and monitoring strategy is not secured as part of the final site policy, we would object to the allocation of this site.
KCC Heritage - the buffer around Burleigh Farm should be increased to ensure that the remains of the old chapel are not lost. Further Archaeology archaeological assessment including field evaluation required in advance of development. Charing Archaeological Group object to Site 77 on the grounds of insufficient knowledge until at least further investigations are conducted.
Object - proposal disregards the agreement to restore the site to a high specification of agricultural use and biodiversity. Bretts are Charing Heath now seeking to renege on their promise and seek economic benefits at expense of the community. Bretts should honour their Action Group commitment to the residents who have endured their presence for 20 years and leave Charing/Charing Heath alone.
Brett Aggregates We fully support KCC's allocation of this preferred mineral extraction option. Ltd 24 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
• There is a legal binding agreement for the current sand site to be restored to a greenfield site. Operator must honour this before any new work can commence • Loss of agricultural land • Consultation process is weighted in favour of the developer and little new information has emerged in the latest documents • Site was refused planning permission 10 years ago and nothing has materially changed to alter or contradict that decision • Conveyor belt under road would be noisy and dangerous. Existing conveyor belt is poorly maintained as noise covers are often left off • Restrict country walks/footpaths and adversely affect local watercourses which are susceptible to drying out and contamination • Increased noise, dust, pollution (air and light), vibration and congestion. Additional traffic will worsen condition and safety of roads • Residents have tolerated sand extraction for long enough and endured the negative General Public impacts of previous developments such as the M20 and HS1 • Adverse effect on Kent Downs AONB landscape and on wildlife (e.g. nesting corn bunting and skylarks, buzzards, sand lizards, Great Crested Newts and orchids). Destruction of ancient hedgerows • Bunding will reduce the amount of natural light properties receive • Adverse effect on property values • Conveyor will not increase
Sand and Gravel Sites road involvements, which is a great advantage to this local community. However, noise levels must be stipulated • Due to a decline
6 in the construction industry/the fact that the preferred sites will contribute far more soft sand than is required, Site 77 is not needed • We have no objections to the extension of the sandpit and the lengthening of the conveyor belt. Bretts have been good and helpful neighbours • Archaeological remains • Similar disused pits nearby have been poorly maintained and are now unproductive and hazardous scars on our landscape • Proximity of site to railway line which will further affect slope stability. Mineral Sites Preferred Options Commentary Report Kent County Council 25 6 This page has been left blank intentionally. adadGae Sites Gravel and Sand 26 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 97: Shrine Farm, Postling
Responses for Site 97: Shrine Farm, Postling
Object 27 This site area is proposed for the extraction of 8 million tonnes of soft sand. The site is currently used for agriculture. Adjoining uses include farmland, areas of Ancient Woodland 32 responses Support 1 and a well used footpath along the site boundary. The Kent Downs AONB and Postling Comment 4 Wents Woods LWS are near the site. Sand and Gravel Sites 6 Consultee Response
We object for the following reasons: (1) Local/residential amenity; (2) Traffic/transport implications; (3) Biodiversity; (4) Landscape Shepway District - scale of site has major implications for AONB; (5) Heritage/archaeology (6) Aquifers (site lies within a groundwater SPZ); (7) Utilities; Council (8) No economic benefit for the local community; (9) Restoration programme. Despite being the largest soft sand site, the specified criteria in the consultation document seem even less developed than the much smaller sites which have specific details to satisfy.
Postling PC is opposed to-sand extraction at Site 97 for the following reasons: (1) Impact on views of Kent Downs AONB; (2) Impingement on the quality of life for Postling residents; (3) Adverse effect on natural drainage of area and local watercourses (including wildlife such as water voles); (4) Dangerous proposed access point. Mitigation if allocated - a buffer zone of at least 50m in width must be established around any of the woodland. Alongside the Byway on the northern boundary, a bund must be created at least 30m wide and 5m high and planted up with native trees. Lyminge PC opposes the development of this site for the following reasons: (1) Substantial additional HGVs, both empty and full, using the nearby motorway junction used by parish residents; (2) The site is adjacent to the Kent Downs AONB and development of the proposed site will detract from the visual amenity; (3) The proposed development will create a precedent for major development north of the M20/CTRL corridor; (4) Nearness of a large development Parish Councils site to the hamlet of Stanford North. Stanford PC object to Site 97. Working is likely to affect the course of the East Stour River, and the very high water table along the northern boundary will cause the site to flood. The proposed access to the site, some 300m north of the J11 roundabout on the B2068, will interfere with all traffic to and from Stanford North and Canterbury throughout every working day for the next 60 years. Bartholomew Wood at Postling Wents is a protected site, and both Butchers Wood and Perry Wood are very significant parts of the local scenery, where the stability of the trees and their water absorption will be damaged by removal of material from close to their margins. The whole site is overlooked by the AONB which was designated to protect views and prevent such intrusions as the sand quarry. The right to quiet enjoyment of their homes for many of our residents is being put at risk. The movement of around 100 HGVs every day, even if restricted to J11, will affect our daily lives as it is difficult to get anywhere from here without taking the B2068 to the roundabout. This lorry traffic will add significantly to the problems that Operation Stack causes. Mineral Sites Preferred Options Commentary Report Kent County Council 27 6
Consultee Response Sites Gravel and Sand
Stelling Minnis PC object to Site 97 for the following reasons: (1) Impact of a huge increase in HGV movements on the local road network (including the cumulative effect of Waste Site 27: Otterpool Quarry in nearby Sellindge); (2) The loss of even more of the rural environment; and (3) The gradual but creeping industrial development of the M20 corridor between Ashford and Folkestone.
Object on the basis of: (1) The AONB surrounds the site on the north western, northern, north eastern, eastern and southern sides and is overlooked from the scarp of the North Downs. The visual impact of the allocation would be significant, damaging and major Kent Downs on the immediate views out from the AONB; (2) No reference is made to the policies of the Kent Downs AONB Management Plan AONB 2009-2014, which are a material consideration and have been adopted by KCC; (3) There is no justifiable need for the release of Shrine Farm. Allocating additional soft sand sites cannot alleviate the shortage of sharp sand and gravel.
Site 97 is within the Mid Kent Greensands and Gault BOA, is surrounded by ancient woodland part of which is designated as Postling Wents LWS, and has been identified within the HRA as possibly having impacts on Folkestone to Etchinghill Escarpment SAC. Although we welcome the mitigation recommended of the stand-off areas to ensure the ancient woodlands are buffered and protection of the water habitats, we continue to have very high concerns regarding the viability of such a large extraction in such a sensitive area. We note that the proposed restoration is to low level farmland which will provide little mitigation for ecology other than the connections between the woodlands. We would urge KCC to consider the targets within the BOA statement and design any mitigation to help to deliver these targets. The most relevant targets will be dependent on the underlying geology but it would seem most appropriate, due to the ancient woodland surrounding the site, that woodland or wood pasture is re-created. We note that an impact to Folkestone to Etchinghill Escarpment SAC has been identified within the HRA due to increased emissions on the M20. However, we are concerned by the assessment which implies that proposed vehicle movements of 50 vehicles per day will not result in an exceedance of the critical loads for this site and denigrates assessment. Kent Wildlife Trust has been concerned for a number of years regarding the in-combination impact on Folkestone to Etchinghill Escarpment SAC, Dover to Kingsdown Cliffs SAC and Lydden and Temple Ewell Downlands SAC, as a result of the rises in traffic from a number of developments that will increase traffic along Kent Wildlife the M20/A20 corridor. However, despite this pressure, yet again the assessment is denigrated. We note that the criterion of 200 extra Trust vehicle movements per day has been used to justify the position in regards to this site. Although the site alone may not generate 200 vehicle movements, an assessment is required regarding in-combination impacts with other developments. The in-combination impact is likely to far exceed 200 vehicle movements. We are concerned that if a strategic approach is not taken then the in-combination impacts are likely to be underestimated. We would advise that any in-combination impacts be assessed as part of the HRA for the Minerals Sites Development Plan Document with appropriate mitigation measures to alleviate impacts in respect of Site 97. As Dover to Kingsdown Cliffs SAC and Lydden and Temple Ewell Downlands SAC are also situated within 200m of the road network, we question why these sites have not been included within the assessment of impact. We recommend that the impact on these SACs is considered within the HRA unless it can be proved that the vehicle movements will not transport minerals on the part of the transport network adjacent to these sites. Unless an in-combination assessment is undertaken on impacts and a resilient mitigation package with significant ecological benefits is incorporated within the policy to mitigate impact on the SAC, LWS and adjacent ancient woodland, we would strongly object to this site being allocated, as the current plans do not conform to national policy contained within the Conservation of Habitats and Species Regulations and the NPPF (paragraphs 109 and 113). Appropriate assessment and mitigation of impacts on the SACs within the M20 corridor and the provision of a management and monitoring plan to secure the long term management of any habitat created are essential, if ecological impacts are to be mitigated. 28 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
Environment Potential for enhancement to waterbodies that cross site if they have been negatively impacted by agriculture. Potential for enhancement Agency as part of this scheme should be considered. Could be a positive contribution to biodiversity and the Water Framework Directive.
Potential impacts on European sites from nitrogen deposition. Concerned about potential impacts from transport of materials by road Royal Society for and associated nitrogen deposition. May be that the route passes within 200m of Folkestone to Etchinghill Escarpment SAC, Dover the Protection of to Kingsdown Cliffs SAC, and other SACs. Route should be set out and an assessment made to analyse potential impacts (including Birds an assessment of current state of SACs).
Object - the boundaries of Site 97 surround Butcher Wood, Perry Wood (on three sides) and Bartholomew Wood. Without significant Woodland Trust buffering (in excess of 100m) there will be a severe negative indirect impact on these three woods.
Sand and Gravel Sites We act on behalf of the landowner. We support the site for the following reasons: (1) Extraction will provide diversification to the 6 farming enterprise income and help support continuing agricultural operations on the Estate; (2) The site comprises a deposit which will serve the needs not only in this Mineral Plan, but for future plans as well; (3) The Site is better able to serve parts of Kent than Bidwells other sites identified within the consultation document. This will result in a saving of road miles and haulage costs; (4) The Site has Consultancy good highway access to the main transport corridor, and lorry movements will not impact upon settlements or villages; (5) Mitigation measures during the extraction programme will reduce visual impact; (6) Greater biodiversity will be provided during and after the extraction process; (7) There should be no planning concerns with regard to the deliverability of this site. Full response, which includes a reply to the most common objections can be found here.
• Loss of view • Noise and air pollution, damage to flora and fauna. Dust poses health risks (i.e. silicosis) and will make life worse for those with existing respiratory conditions • Dangerous site entrance which will worsen condition and safety of roads • No economic benefit for local community • Will affect residents’ right to a quiet life • Scant attention has been given to the aspects of access and General Public the impact on traffic flows in the vicinity • Adverse effect on property values • Extraction may affect underground power lines • No need for soft sand from this site. Only allocated to make up for a shortage in sharp sand and gravel • Destruction of ancient woodland and adverse effect on water table/aquifers • Volume of HGVs and plant accessing, leaving, or simply being parked on the site. Mineral Sites Preferred Options Commentary Report Kent County Council 29 6 This page has been left blank intentionally. adadGae Sites Gravel and Sand 30 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 105: Borough Green Sand Pits Extension, Wrotham
Responses for Site 105: Borough Green Sand Pits Extension, Wrotham
Object 2 A proposed northerly extension to the existing sand extraction pit area. The site is currently 8 responses Support 1 used for agriculture. Adjoining uses include farmland, the M26 motorway to north, woodland and the existing quarry area to the south. Comment 5 Sand and Gravel Sites 6 Consultee Response
The District Council is concerned at the increase in traffic that may result from these proposals, especially in relation to the A25. Any Sevenoaks allocation/planning permission should fully consider the impact of additional traffic on access routes through adjoining districts and District Council consider conditions to restrict the number of vehicle/lorry movements.
Platt PC strongly object to the extension of these pits for the same reason as for Site 6, which are increased traffic movements on the A25, especially through the existing Industrial Estate. We would reinforce Highways Comment: “Several concerns about the industrial estate road access onto the A25, including the limited width of the roads and footways. The junction to the neighbouring Nepicar Quarry is to a much higher standard; utilising their access onto the A25 is recommended”. We trust KCC stand by their comment that this Site will only be supported if the access is via Nepicar Quarry entrance and NOT via Industrial Estate. Cumulative Effect of Sites 6 and 105 - should these proposals be adopted with the condition to use the Nepicar entrance/exit, vehicles should be encouraged to head eastwards towards the A25/A20 junction at Wrotham Heath and NOT towards Platt. However, we would still maintain that the access/egress of these sites could feed directly on to the A20/M26 junction at Nepicar roundabout, via the existing road, to enable heavy freight to access the main routes directly without further disruption to Wrotham Heath, which is already a busy, Parish Councils built up, junction and could lead to air quality problems. It would not be impossible for alterations to be made to this junction to satisfy Kent Highways. We also refer to two objectives from the proposed Kent Freight Action Plan, namely: Objective 4) to take steps to address problems caused by freight traffic to communities; and Objective 5) to ensure that KCC continues to make effective use of planning and development control powers to reduce the impact of freight traffic. Wrotham PC - this site is adjacent to the grounds of Wrotham School and Grange Park School which is a special school that caters for severely autistic children. Both schools are sensitive noise receptors in a planning context. We would therefore advocate that topsoil is bunded to the west of the proposed quarry to provide noise mitigation to these school premises. It is recognised that the area of the bunding is within the AONB but this would be a temporary measure that would indeed protect the rest of the AONB from noise pollution. Attached to this response is a Tonbridge & Malling Borough Council reply to questions raised regarding AQMAs within Tonbridge and Malling. The document lists existing AQMAs and of particular relevance, a new AQMA that is to be declared across Borough Green. This new AQMA will be exacerbated Mineral Sites Preferred Options Commentary Report Kent County Council 31 6
Consultee Response Sites Gravel and Sand
by increases of traffic on the A25 passing through Borough Green. We therefore consider it essential that traffic generated by any planning consents arising from this allocation must do so on the proviso that arrangements are made to use the Nepicar Quarry exit onto the A25, with a left turn only constraint to direct the traffic away from Borough Green and straight onto the primary road network.
Support allocation subject to conditions. Mitigation suggestions in the event of allocation: (1) Conditions covering landscaping, Kent Downs method and phasing of working and restoration, aftercare and land management which mitigate impact on views from the Kent Downs AONB AONB scarp and restore the original landscape character; (2) Impact on Grange Park School and lorry routing and timing on to the Maidstone Road to protect the users of the Maidstone Road and primary school users (St Mary’s Platt).
We are concerned that the HRA has identified this site as possibly having an in-combination impact on the North Downs Woodlands SAC with Waste Site 61: SCA Packaging, New Hythe, Aylesford, however, whilst Site 61 is scoped in for further assessment for impact of emissions, Site 105 is scoped out. We would query why this decision has been taken and ask for clarification. We are concerned that the increase in 78 vehicles has been described as minimal. Although individually the sites may not have an impact on the SAC, the aim of an in-combination assessment is to ascertain what the current level of impact is and how the proposed development throughout the area will affect the site when viewed as a whole. Although the vehicle movements may be small, this increase could be enough to cause the SAC to exceed the critical load for nitrogen deposition. Many developments could state that the increases are small however, when looked at as a whole, they could be causing a significant impact on the European network. For this reason, we recommend that a county-wide study be undertaken in relation to NOx, to ascertain the true in-combination impacts of the plan on all the European sites at threat when viewed in combination with other plans. We object to the conclusion of the HRA that there will be no impact from this site on the Natura 2000 network. This site is in close proximity to Site 6 and on the Kent Wildlife periphery of the Greensands Heath and Commons BOA; it will therefore be important to examine the in-combination impacts of this Trust site on Valley Wood and Wrotham Golf Course LWS and the ancient woodland fragments within the area. As stated for Sites 6 and 24, there are possibilities to recreate and connect the heathland and woodland habitats within the area if the operators work together each reflecting the other sites' restoration plans. We are therefore concerned that the proposed restoration for this site is to amenity grassland and woodland. Such restoration will not fully realise the biodiversity benefits and it is our view that amenity grassland would not provide appropriate mitigation for the impacts both individually and in-combination with Site 6 on the LWS adjacent to the site. Unless appropriate safeguards to conserve the habitats contained within the LWS and a resilient restoration package is devised to mitigate any residual impact on the LWS and extend habitat, we would object to the allocation of this site. Further biodiversity gains and connectivity could be achieved if the existing quarry could also be restored to heathland with woodland connections. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator, the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
• Concerned about the increase in traffic on A25 as the road is already over-burdened • All traffic needs to turn left only - none to go west • Access via Nepicar roundabout would be a good idea • Concerned about the hours of quarrying and noise from plant is very General Public disturbing • Footpaths - they are used by many people so need to remain • Noise of extra machinery and cumulative impact on the highway network will have a detrimental effect on the immediate vicinity which includes a primary school and residential dwellings. 32 Kent County Council Mineral Sites Preferred Options Commentary Report
Sharp Sand and Gravel Sites
Site 2: Beltring Green Farm, East Peckham
Responses for Site 2: Beltring Green Farm, East Peckham
Object 0 Proposed extension to the existing Arnolds Lodge Farm Quarry. Operators J Clubb Ltd are currently working the area to the north of this site and transporting the mineral via a 4 responses Support 0 conveyor over the River Medway to the processing plant. The operator intends to use the Sand and Gravel Sites
6 same transportation method for this site. Adjoining uses include a railway line, the A228, Comment 4 agricultural land, a public house and the existing quarry.
Consultee Response
Development Management
A more visually prominent site in the Green Belt within Tonbridge & Malling Borough Council. This site would only be in operation for 4-6 years. Attention would need to be given to ensure effective restoration. LWSs would need to be protected.
Transport Maidstone Borough The proposal involves an extension to the existing quarry at Arnolds Lodge Farm. It is also proposed to transport the quarried minerals Council to the processing plant on the opposite side of the River Medway via a conveyor belt over the river. Therefore the need for HGV’s to transport the material is very low and so the impact of the development on the local road network will also be limited.
However, the processing plant will now most likely be processing a larger amount of material and so the need for more HGVs to ship the products from this plant will be greater. Nonetheless, Maidstone Borough Council does not have control over this existing use, and so this development is acceptable in transport terms.
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
This site is within the Medway Low Weald Wetlands and Grasslands BOA and is likely to have a direct and indirect impact individually Kent Wildlife and in-combination with other sites on LWSs within the corridor. The site is adjacent to Stoneham and The Lees LWS and Hale Street Trust Ponds and Pastures LWS. In the Mineral Sites Options consultation three sites were proposed within this area which would impact on a number of LWSs. Kent Wildlife Trust welcome the exclusion of two of these sites (i.e. Sites 3 and 4) for further consideration, as this Mineral Sites Preferred Options Commentary Report Kent County Council 33 6
Consultee Response Sites Gravel and Sand
will alleviate some of the impact on the important water systems that are present within the area. The proposed mitigation of reed beds and ponds could have a significant biodiversity benefit as habitat creation would connect the Shoreham and the Lees Yalding LWS and East Peckham Ponds LWS with Hale Street Ponds LWS, and will help to deliver targets 2 and 8 of the BOA.
However, this is an extremely sensitive area ecologically with four LWSs connected into the water system within the locality and further sites dependant on a reliable water source within the wider landscape. It is therefore essential that there is no impact on the sites either directly via habitat loss or indirectly through changes in the water system either individually or in-combination with other sites. It is imperative that there is a full investigation of the hydrology and water flow of the area before this site is allocated. We recommend that safeguards are written into the final policy that no essential water feed to the surrounding LWSs should be impacted within any quarrying operations and it should be ensured that there is no contamination or pollution of the water system from the proposed operations.
To ensure management of the re-created habitat we would recommend that the final policy specifies that a landscape scale management and monitoring strategy and appropriate funding for management in the long term is secured as part of any permission granted.
CPRE Have concerns that the site is near to Beltring Road and that this road is prone to flooding from time to time. Would like to see a proper Maidstone management scheme for this development and the same comments apply to this site that it borders onto the former Steve Ham Quarry District Site in gravelly Way Road next to Site 4: Woodfalls Farm, Yalding. Committee 34 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 17: Moat Farm, Capel
Responses for Site 17: Moat Farm, Capel
Object 1 Proposal for 1.5 million tonnes of sand and gravel extraction. It is currently a flat expanse of agricultural/pastoral land. Adjoining uses include Moat Farm buildings (including 10 to 7 responses Support 1 12 residential caravans) an existing quarry (Stonecastle Farm Quarry), agricultural land Comment 5 and another proposed quarry site; Site 49: Land North & South of Hammer Dyke. Sand and Gravel Sites 6 Consultee Response
Tunbridge Tunbridge Wells BC is concerned about the cumulative impact of working three adjacent sites (17, 49 and 71) together with the existing Wells quarry, which will over time affect a significant swathe of a local landscape character area. The close proximity of another two proposed Borough sites (1 and 2) can only increase the adverse impacts from the viewpoint of the sustainability appraisal. The cumulative impact of Council developing all three sites would be completely unacceptable in our view, unless specific conditions are strictly enforced.
Capel Parish Further investigation of Site 17 should be carried out as the consultation lacks sufficient data on this site. Council
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
This site is just outside the Medway Low Weald Wetlands and Grasslands BOA. Kent Wildlife Trust welcomes the hydrological investigations proposed but would recommend that any water systems running through the site be protected from harm within the final policy. We would also advise that the need to ensure no contamination of the water system is also highlighted.
We are pleased to note that the ancient woodland will be excluded from the site and protected from damage. The mitigation measures required should be detailed within the final policy. The restoration measures of phased wetland restoration are appropriate for this site and will help to deliver target 2 of the BOA statement. Kent Wildlife Trust We continue to have serious concerns regarding the individual and in-combination impacts of this site. It is a large site extracting 1.5 million tonnes of sand and gravel and we would question whether the adjacent East Tunbridge Copse Dykes and River Medway LWS can be safeguarded from such extensive quarrying activities. There are also high risks that other sites dependant on the water supply within the area would be impacted.
To ensure management of the re-created habitat we would recommend that the final policy specifies that a landscape scale management and monitoring strategy and appropriate funding for management in the long term be secured as part of any permission granted. Mineral Sites Preferred Options Commentary Report Kent County Council 35 6
Consultee Response Sites Gravel and Sand
CPRE Maidstone Support the fact only one site will be excavated at a time. However, a proper reclamation plan needs to be approved and enforced. District Committee
Sites 17, 49 and 71 - all three of the Stonecastle Farm sites should be environmentally considered together, so that the short and long Environment term solutions to the watercourses are determined from the outset. The longer term impacts on the hydrogeology of this area, and Agency ecology, in relation to biodiversity and the water framework directive will need to be taken into account in this planning process.
Woodland We object to Site 17. The Northern tip of this site contains small area of ancient wood (Grid Ref. TQ644466). In addition to this there Trust is a small area of ancient woodland adjacent to the site. Development of this site will result in the loss of and damage to ancient woodland. 36 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 49: Land Adjacent to Hammer Dyke, Capel
Responses for Site 49: Land Adjacent to Hammer Dyke, Capel
Object 2 This site is a proposed extension to the existing Stonecastle Farm Quarry for 2 million tonnes of sand and gravel extraction. It is currently low lying agricultural/pastoral land. 7 responses Support 2 Adjoining uses include a railway line, farmland and buildings, residential properties, the proposed Site 17: Moat Farm and the existing quarry. The site is located close to the Comment 3 Sand and Gravel Sites northern boundary of the Kent High Weald AONB. 6
Consultee Response
Tunbridge Tunbridge Wells BC is concerned about the cumulative impact of working three adjacent sites (17, 49 and 71) together with the existing Wells quarry, which will over time affect a significant swathe of a local landscape character area. The close proximity of another two proposed Borough sites (1 and 2) can only increase the adverse impacts from the viewpoint of the sustainability appraisal. The cumulative impact of Council developing all three sites would be completely unacceptable in our view, unless specific conditions are strictly enforced.
Capel Parish Capel PC is strongly opposed to any development of Site 49 because of its serious impact on the landscape and amenity of the northern Council part of the Parish which would be completely dominated by such a proposal.
This site is not within the BOA but is in close enough proximity to the East Tunbridge Copse Dykes and River Medway LWS to have serious impacts on the LWS and the adjoining sites. As with the previous sites, we welcome the safeguards that are proposed to endeavour to protect the ancient woodland and the sensitive designated sites and wetland habitats incorporated within the corridor. In respect of the ancient woodland, we recommend that details of how this was to be achieved are laid out within the final policy.
We continue to have serious concerns regarding the individual and in-combination impacts on the BOA and the LWSs it contains. We Kent Wildlife question how the aim to protect the water system present on site can be achieved when 2 million tonnes of aggregate is to be extracted, Trust especially when viewed in-combination with other sites adjacent to the LWSs. There are also high risks that other sites dependant on the water supply within the area would be impacted.
To ensure management of the re-created habitat we would recommend that the final policy specifies that a landscape scale management and monitoring strategy and appropriate funding for management in the long term is secured as part of any permission granted. Mineral Sites Preferred Options Commentary Report Kent County Council 37 6
Consultee Response Sites Gravel and Sand
CPRE Maidstone Support the fact only one site will be excavated at a time. However, a proper reclamation plan needs to be approved and enforced. District Committee
Sites 17, 49 and 71 - all three of the Stonecastle Farm sites should be environmentally considered together, so that the short and long Environment term solutions to the watercourses are determined from the outset. The longer term impacts on the hydrogeology of this area, and Agency ecology, in relation to biodiversity and the water framework directive will need to be taken into account in this planning process.
We object to Site 49. This site contains ancient woodland (Grid Ref. TQ632466) within the site boundary. There are three additional Woodland blocks of ancient woodland adjacent to this site. Most notably ancient woodland at Grid Ref. TQ642460 which directly abuts the site Trust boundary. Development of this site will result in the loss of and damage to ancient woodland.
This firm acts as land agents for Hadlow Estate near Tonbridge owned by the trustees of Goldsmid Settled Estates. We have made RH & RW representations at earlier stages of the consultation process and are pleased that Sites 49 and 71 have been identified as preferred Clutton option sites. We continue to support the inclusion of Sites 49 and 71 in the next stage of the plan. 38 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 71: Stonecastle Farm, Whetsted
Responses for Site 71: Stonecastle Farm, Whetsted
Object 1 A proposed western extension to the existing Stonecastle Farm Quarry for 1.07mt of sand and gravel extraction. The site area is currently farmland. Adjoining uses include the 10 responses Support 3 existing quarry, woodland and agricultural land. The area is located to the north of the Comment 6 High Weald AONB. Sand and Gravel Sites 6 Consultee Response
Tunbridge Tunbridge Wells BC is concerned about the cumulative impact of working three adjacent sites (17, 49 and 71) together with the existing Wells quarry, which will over time affect a significant swathe of a local landscape character area. The close proximity of another two proposed Borough sites (1 and 2) can only increase the adverse impacts from the viewpoint of the sustainability appraisal. The cumulative impact of Council developing all three sites would be completely unacceptable in our view, unless specific conditions are strictly enforced.
Capel Parish Capel PC has no objection to the extension of Site 71, subject to restoration and environmental safeguards. Council
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
This site is not within the BOA but is in close enough proximity to the East Tunbridge Copse Dykes and River Medway LWS to have serious impacts on the LWS and the adjoining sites. Although we note that there are requirements to safeguard the watercourses crossing the site and the LWS, and that surveys are required, there is no requirement for a hydrological survey.
We continue to have serious concerns regarding the individual and in-combination impacts on the LWSs. We question how the aim to Kent Wildlife protect the water system present on site can be achieved when 1.07 million tonnes of aggregate is to be extracted, especially when Trust viewed in-combination with other sites. There are also high risks that other sites dependant on the water supply within the area would be impacted.
To ensure management of the re-created habitat we would recommend that the final policy specifies that a landscape scale management and monitoring strategy and appropriate funding for management in the long term is secured as part of any permission granted. Mineral Sites Preferred Options Commentary Report Kent County Council 39 6
Consultee Response Sites Gravel and Sand
CPRE Maidstone Support the fact only one site will be excavated at a time. However, a proper reclamation plan needs to be approved and enforced. District Committee
Sites 17, 49 and 71 - all three of the Stonecastle Farm sites should be environmentally considered together, so that the short and long Environment term solutions to the watercourses are determined from the outset. The longer term impacts on the hydrogeology of this area, and Agency ecology, in relation to biodiversity and the water framework directive will need to be taken into account in this planning process.
We object to Site 71. This site contains two separate but adjacent blocks of ancient woodland (Grid Ref. TQ658469 and TQ658468) Woodland within the NE extremity of the site. Ancient woodland at Grid Ref. TQ657465 is directly adjacent to the site. Without significant buffering Trust (in excess of 100m) there will be a severe negative indirect impact on these three woods. Development of this site will result in the loss of and damage to ancient woodland.
This firm acts as land agents for Hadlow Estate near Tonbridge owned by the trustees of Goldsmid Settled Estates. We have made RH & RW representations at earlier stages of the consultation process and are pleased that Sites 49 and 71 have been identified as preferred Clutton option sites. We continue to support the inclusion of Sites 49 and 71 in the next stages of the plan.
Lafarge Aggregates Support - we are pleased to see that our proposed site at Stonecastle has been allocated Ltd
General Current site is due to be restored as reed beds. At present reeds are only established on one of the four beds. The company have Public (Only 1 attempted to plant reeds but they have been destroyed by geese or swans. No effort appears to have been made to protect the reeds Comment to enable them to become established. Received) 40 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 73: Lydd Quarry Extensions (Areas A - D), Lydd
Responses for Site 73: Lydd Quarry Extensions (Areas A - D), Lydd
Object 9 Five parcels of land were proposed as extensions to the existing Lydd Quarry, which spans across the county border into East Sussex. Four of the areas are preferred options. The 17 responses Support 1 fifth (Area E), an extension to Allen's Bank, is not a preferred option. The land is currently agricultural with one redundant building. Adjoining uses include residential properties, Comment 7 Sand and Gravel Sites farming, the existing quarry and a caravan park. 6
Consultee Response
East Sussex As the quarry at Lydd (Site 73) straddles the Kent and East Sussex border, it is of particular interest for cooperation and plan making. County We look forward to continuing the joint working on aggregate production and restoration of the site. Council
SDC object for the following reasons: (1) Local/residential amenity - sites are in close proximity to residential dwellings, with Site C actually backing on to residential dwellings and gardens; (2) Traffic/transport implications and access to the sites. This has been Shepway recognised as a major issue in previous planning applications. However, no criteria are proposed at all in the consultation document; District (3) Biodiversity (the extension will fall within the Dungeness, Romney Marsh and Rye Bay SSSI and is adjacent to Ramsar/SPA areas); Council (4) Open Landscape - the site is set within an open landscape and likely to be visible from various vantage points; (5) Heritage - listed building in close proximity (Tourney Hall), potential for historical remains; (6) Utilities; (7) No clear economic benefit for the local community, potential for harm to the local economy in the Romney Marsh which suffers from rural deprivation.
Object - these new sites must not go ahead, not before the following is solved: (1) High unemployment on the Romney Marsh (as these pits cause vast damage to our area without giving anything back); (2) That the sites must be filled in after they have been dug out (as Lydd Town the Romney Marsh is the third highest flood risk in the country and open bodies of water become a flood risk, as they do not absorb Council excess water); (3) Bring back a functioning rail service to the town, so that export of gravel can go by rail and not by our already weak road network; (4) Subsidise any loss in house prices of those living in the town, compared to the housing market in New Romney. Site 73 should not be considered at all, KCC and SDC have already taken far too much from the Romney Marsh without giving enough back.
KCC Heritage We welcome the exclusion of Area E. Wording for "subject to" criterion (4) (listed buildings), change 'proposed’ to ‘agreed’.
This site is located within a very sensitive area within the Romney Marshes to Rye Bay SSSI and adjacent to the Dungeness SAC. The Kent Wildlife proposals are for extensive quarrying within the area which could impact on the ecological viability of the Natura 2000 designation. The Trust HRA has identified the risks from dewatering of quarries stating, "Additionally, minerals sites located near habitats where a balance of Mineral Sites Preferred Options Commentary Report Kent County Council 41 6
Consultee Response Sites Gravel and Sand
saline and fresh water is critical have the potential to affect flows through processes such as dewatering, leading to impacts such as reduced freshwater flows to estuaries and saline intrusion". We are therefore surprised that the HRA has concluded that no site will lead to impacts due to dewatering. The Dungeness complex relies on a sensitive balance between the saline and freshwater habitats to support the rare flora and invertebrates on site and ensure the survival of the important Great Crested Newt population which is part of the designation. For the above reasons we feel that it is imperative that this site be scoped in for the possible impacts due to dewatering with a full assessment on the viability of the proposed quarrying within the MWDF process. We understand that there are sensitive ditches within the area that will need to be conserved or mitigated. The land take could provide a supporting habitat for SPA birds and the noise associated with the proposed operations may cause impact on the designated bird species. We therefore welcome the fact that this issue has been scoped into the HRA for further assessment. This should be done as part of the MWDF process; not at application stage. We are also concerned regarding the analysis that there will be no in-combination impacts as a result of the proposed minerals excavation within East Sussex, due to the report prepared as part of the Sussex MWDF. We have not seen the report alluded to and have a number of queries as to the nature of the assessment such as: • Did the assessment take into account the proposed mineral workings within Kent when considering in-combination impacts? • Did the proposed mitigation measures include the in-combination impacts of both schemes together? We wish to discuss this work further to clarify the nature of the assessment and would request sight of any report produced by Sussex County Council to ensure that the mitigation covered increased impacts as a result of the work proposed within Kent. It is our view that a further study assessing the impacts and possible mitigation should be commissioned for the Kent sites with all development in Kent and Sussex being appraised if this has not already been undertaken. It is essential that this is undertaken as part of the MWDF process to ensure that this project is viable and will not contravene the Conservation of Habitats and Species Regulations 2010 and must be completed before allocation of this site. In-combination impacts are also possible as a result of the plans within Rother and Shepway districts, especially in respect of tourism. This issue has been highlighted within both Local Authority Core Strategies and there are initial plans to undertake surveys and devise an access strategy to endeavour to mitigate increased impacts as a result of the plans. We can see no reference to assessment for in-combination impacts as a result of the above plans with only the minerals workings in Sussex being identified as an issue. There may be scope for KCC to support this work financially and commit to only deciding to permit this site if the studies show that all impacts can be mitigated. We do not agree that the Lydd airport expansion can be discounted as it is a permitted project by Shepway District Council and therefore any possible in-combination impacts should be included as part of any assessment. This is particularly pertinent in the case of nitrogen deposition. We are extremely concerned regarding the lack of detail and assessment, especially in relation to in-combination impacts. If this site is not investigated thoroughly for impacts and viability as detailed and resilient mitigation measures put in place to safeguard the Dungeness complex from individual and in-combination impacts, we would strongly object to the allocation of this site.
The design of extensions to Lydd Quarry must take into account how existing watercourses can be protected or enhanced as part of Environment the process. In addition, the profile of the waterbodies must aim to provide a fringe of aquatic vegetation to prevent long term erosion Agency that is occurring elsewhere around former gravel pits that do not have adequate protection.
We are concerned that the impact on European Sites and SSSIs cannot be ruled out. URS seems content to leave close consideration Natural of the issues until the planning application stage. This appears to be a risky strategy. The plan should only make allocations where there England is confidence that the land can be successfully developed without compromising the local natural environment (inter alia). The URS 42 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
suggestion that there is "no reason to conclude that risk can't be resolved" uses a double negative, and implies some uncertainty. The allocations should be considered in sufficient detail to allow statements such as "there are no risks", "the potential impacts (namely...) can be resolved by conditions and agreement" etc.
Royal Society Risk of disturbance to Annex 1 birds and European Protected Species using the open water bodies. Potential direct loss of habitat if the for the open fields are used by significant numbers of potential SPA/potential Ramsar site birds. Potential hydrological impacts, on water quality Protection of and flow. Potential air quality impacts. Birds
We seriously object to this application as previously stated. We are against development in this unique area and sincerely trust this plan will be turned down. The removal of any further minerals from this area would cause no end of devastation to residents and we Sand and Gravel Sites Friends of therefore request that this application be thrown out. We seriously urge KCC to think about the problems and upset this excessive and
6 Lydd continuous work would cause. Please give some thought to the residents and visitors to this wonderful corner of Kent. We feel that no thought is given to our people and urge you to put yourselves in our shoes – would you be happy with such devastation?
Brett Aggregates We fully support KCC's allocation of this preferred mineral extraction option. Ltd
The underground infrastructure that crosses the site needs to be protected so that it can continue to fulfil its function. Future maintenance Southern and upsizing must be secured through easements of between 6 and 13 metres. Diversion of the infrastructure may be possible at the Water developer's expense, provided a feasible alternative route is available. The proposed site also abuts Lydd Wastewater Treatment Works. It is important that the development is compatible with this existing use.
• I am appalled that KCC would even consider any further sites or are they happy to turn Lydd into one big gravel pit? I can't even imagine what effect this would have on my home life, let alone the value of my house • For goodness sake please leave Lydd alone. First a threat of a nuclear dump, now gravel pits. No thank you. Lydd is a very pleasant little town, we would like it left as it is • This proposal would General make Lydd an island and cause noise and pollution. Also, the site will come right up to our back gardens • Area D is adjacent to the Public cricket ground which is an amenity used by a lot of local people. I suggest the eastern border with the quarry is screened in someway, possibly trees. Area C - there should be a buffer zone between the quarry and the adjacent housing • What precautions would be in place to protect children and adults from the quarry (i.e. fencing and security)? What would Bretts put back into Lydd and the community (i.e. support local projects etc)? Mineral Sites Preferred Options Commentary Report Kent County Council 43 6 This page has been left blank intentionally. adadGae Sites Gravel and Sand 44 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Crushed Rock (Ragstone) Sites
Object 0
1 response Support 0 Responses relating to crushed rock (ragstone) sites.
Comment 1
Consultee Response
The document does not provide any ragstone sites capable of ensuring that a steady and adequate supply of ragstone is available for the plan period following exhaustion of existing permitted reserves at Hermitage Quarry. In the light of the NPPF guidance, the local evidence to hand and the Minerals Planning Authority decision of May 2011, it is surprising that future ragstone reserves have not been
Crushed Rock (Ragstone) Sites identified for release in the document. Exceptions Policy - at the Stakeholder Group Meeting on the 18 July 2012 it was announced that Civitas KCC is considering adding an Exceptions Policy to the Core Strategy and this would be in the pre-submission consultation in February 7 Planning 2013. I am not aware of any reference in the evidence base provided to date for the MWDF for such a policy. I trust supporting evidence will be available with a future consultation as indicated. Whilst such a policy may well be advantageous it should not be at the expense of identifying sufficient preferred sites to deliver the required steady and adequate supply of minerals in Kent. Full response, including comments on the Mineral Sites Preferred Options Evidence Base available here. Mineral Sites Preferred Options Commentary Report Kent County Council 45 7 This page has been left blank intentionally. rse ok(asoe Sites (Ragstone) Rock Crushed 46 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Silica Sand Sites
Object 1
1 response Support 0 Responses relating to silica sand sites.
Silica Sand Sites Comment 0 8
Consultee Response
Object - we do not agree with the interpretation of the NPPF that you make in paragraph 6.3.
In the Mineral Site Assessment, May 2012 KCC states:
"6.3.3 The National Planning Policy Framework requires Mineral Planning Authorities to ensure that landbanks of at least 10 years are maintained at individual silica sands [sites]".
This is not exactly what the NPPF says. Paragraph 146 states that:
"Mineral planning authorities should plan for a steady and adequate supply of industrial minerals by...
• Providing a stock of permitted reserves to support the level of actual and proposed investment required for new or existing plant and Kent Downs the maintenance and improvement of existing plant and equipment, as follows AONB - at least 10 years for individual silica sand sites".
The word ‘landbanks' does not appear - a landbank is a sum of individual permitted reserves across a series of sites, whereas this policy applies to individual sites. We appreciate that the NPPF is poorly worded to the point of lacking clarity. KCC has chosen to interpret it to mean in effect 'every silica sand site must always have enough reserves for production for at least 10 years'. However, the construction of the policy is couched in terms of supporting investment in plant, and can be interpreted less controversially to mean that 'permissions should be granted for at least 10 years to support actual and proposed investment in plant' (and the next clause of NPPF paragraph 146 refers to providing 15 year permissions "for silica sand sites where significant new capital is required"). In our view the latter interpretation is more sensible and realistic. We doubt that it is the intention of the NPPF to offer all existing silica sand sites an unqualified right to be given unending extensions for the indefinite future on demand to ensure continuation of current output for at least the next 10 years. Mineral Sites Preferred Options Commentary Report Kent County Council 47 8 This page has been left blank intentionally. iiaSn Sites Sand Silica 48 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 24: Land North of Addington Lane, Trottiscliffe
Responses for Site 24: Land North of Addington Lane, Trottiscliffe
Object 1 Proposed extension to the existing Addington (Wrotham) Quarry. The site area currently consists of arable fields. Adjoining uses include agriculture, country lanes and the existing Silica Sand Sites Support 1
8 3 responses quarry site. It is located within the Kent Downs AONB. The upper sands are intended for building sand and the lower deposit is suitable for use as industrial sand (silica sand). Site Comment 1 24 can also be found in Chapter 6: Sand and Gravel Sites.
Consultee Response
Object to the allocation for silica sand and/or soft sand and inert fill. Silica sand - we do not agree with the statement made in TRM9: Mineral Sites Assessment, page 21: "It is likely that mineral extraction at this location meets the 'exceptional test' required for development Kent Downs in an AONB due to silica (industrial) sand being the main deposit in the site". This is an assertion for which no justification has been AONB provided in the Preferred Options Document as set out in our comments in Appendix 1. Fill - inert fill to provide for restoration would prolong the life of the site and not necessarily provide for final good restoration. There is no need to provide sites for inert fill.
This site is further to the north of the Greensands Heaths and Commons BOA than the previous site and is adjacent to TW29 Ryarsh Woods LWS. Within Kent Wildlife Trust’s previous consultation response we highlighted the need to ensure that there was no change to the hydrology of Ryarsh Wood LWS and the water supply to the woodland as a result of the proposed quarrying. The LWS is designated as it contains wet ancient woodland which is dependent on the water supply to the streams and ditches that interlace Site 24. We can find no reference to the safeguarding of the water supply within the site specific considerations. We recommend that safeguards to ensure the water supply and hydrology of the LWS are not impacted are incorporated within the policy for this site.
We welcome the recommendation that heathland or acidic grassland will be created however, due to the sensitivity of the area, we are Kent Wildlife concerned that there is still a suggestion that this site will be restored to agriculture. Due to the possible impacts on Ryarsh Wood LWS Trust it is our view that it is essential that within the final policy a commitment is secured to restore the site back to acidic grassland or heath to help deliver the BOA target.
We recommend that a joint restoration, management and monitoring program be devised incorporating Site 6, 105 and Site 24 and the LWSs that may be impacted. As this site is an extension to the Addington (Wrotham) Quarry there are opportunities to extend the heathland and grassland habitat into the area being worked at the present time. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator, the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint. Mineral Sites Preferred Options Commentary Report Kent County Council 49 8
Consultee Response Sites Sand Silica
If hydrological impacts on the LWS are not assessed as part of the final Development Plan Document and appropriate mitigation, restoration and management measures incorporated into the final policy, we would object to the allocation of this site.
The inclusion of the Wrotham (Addington) Quarry extension area as a source of high quality silica sand is supported.
The recoverable resource of high quality silica sand amounts to 1.1 million tonnes rather than the 968,000 tonnes referred to. The quarry has only limited reserves of high quality silica sand remaining and it is particularly important to ensure there is a continuation of this source of supply. Extensive sampling and analyses of the silica sand has proven a high quality resource with very high silica levels, low levels of impurities and a consistent grain size.
The silica sand would be suitable for use in a variety of industrial applications including: • Foundry castings for marine engines, medical Hanson equipment and architectural engineering • High performance floor screeds • Roofing felt • Fire cements and bricks, fire resistant paints Aggregates and chemical resistant cements • Special precast products • Sports and leisure uses - equestrian surfaces, sports pitches, golf courses, play areas.
The quarry contains extensive processing plant capable of washing, grading and drying the sand into a variety of products. 80% of silica sand sales are of dried sand. The quarry has one of only 2 sand drying plants in the south east of England. In the NPPF silica sand is seen as an essential raw material for many industrial processes. It is sparsely distributed and is a valuable resource of national importance. Planning authorities are advised to ensure an adequate and steady supply of silica sand available. At least 10 years reserves should be provided for individual silica sand sites. The extension area would provide 10 years supply of silica sand at Wrotham. 50 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Chalk Sites for Cement Manufacture
Object 0
1 response Support 0 Responses relating to chalk sites for cement manufacture.
Comment 1
Consultee Response
Lafarge's interest relates to the Medway Cement Works and the text in paragraphs 7.1 to 7.5. This is supported, except for seeking one Lafarge amendment to the wording. Add (underlined) the following: "...the site operators have indicated that, if and when the site is to be developed Cement UK beyond its initial stages, the proposed design, geographic layout and life of the plant would need to be...". The suggested alteration is Plc in the interests of clarity, to avoid any implication that the 2001 planning permission has not been implemented, and I hope is not contentious. Chalk Sites for Cement Manufacture 9 Mineral Sites Preferred Options Commentary Report Kent County Council 51 9 This page has been left blank intentionally. hl ie o eetManufacture Cement for Sites Chalk 52 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 63: Pinden Quarry Extension, Dartford
Responses for Site 63: Pinden Quarry & Landfill Extension, Dartford
Object 8 Proposed north-west extension and deeper excavation of the existing chalk quarry. The site is currently an unused area adjoining restored mineral workings and the existing 13 responses Support 0 Pinden Chalk Quarry and recycling facilities. The site is adjacent to a LWS. Site 63 can also be found in the Waste Sites Preferred Options Commentary Report, Chapter 7: Comment 5 Hazardous Landfill and Chapter 9: Treatment/Materials Recycling Facilities.
Consultee Response
Sevenoaks DC is concerned at the increase in traffic that may result from these proposals, especially in relation to the A25. Any allocation/planning permission should fully consider the impact of additional traffic on access routes through adjoining districts and consider conditions to restrict the number of vehicle/lorry movements. Dartford BC object to Site 63 for the following reasons: (1) If an increased level of extraction is agreed, a large landbank will be created, thus going against the guidance of the NPPF; (2) No evidence District/Borough is provided that major engineering projects will be implemented in the area over the next 10 to 15 years, that would require the significant Councils additional amounts of engineering chalk that are proposed; (3) There is no evidence to suggest that existing reserves are insufficient to satisfy future demand; (4) No evidence is provided to justify the need for the quarry extension for hazardous waste landfill (asbestos); (5) The proposed extension would result in longer, less sustainable HGV journeys (6) No evidence has been provided to show that there would be sufficient suitable fill to enable full restoration within a reasonable time.
Chalk Sites for Agriculture and Engineering Use Longfield and New Barn PC object for the following reasons: (1) Potential adverse impacts relating to the natural beauty of the area, the presence of an ancient woodland site within 1km, and heritage remains that have already been discovered with the potential for
10 further archaeology to be found; (2) Presence of the high voltage overhead electricity line on the boundary of the site and the high pressure gas pipeline which crosses the site; (3) Extraction/waste deposition has had a negative impact on the area for a considerably long time and extending the usage for these needs when there are many other sites available for all or some of these purposes should Parish be seriously considered; (4) The B260 is already showing signs of being unable to adequately deal with the current number of HGVs; Councils (5) With the development of 149 new homes within a short distance of the proposed extension and a new Academy, these proposals will affect even more residents. Southfleet PC object for the following reasons: (1) The site is surrounded by a number of villages and settlements mainly served by narrow country roads already carrying a high level of commercial and domestic traffic; (2) As the need to bury asbestos is finite (it no longer being used as a material), what other hazardous waste would be put into Pinden Landfill?; (3) The landscaping arrangements have not been successful and there are local complaints about the amount of chalky dust which is causing a nuisance (i.e. the large stockpile of chalk at the quarry which has become a considerable feature in the landscape); (4) There appears Mineral Sites Preferred Options Commentary Report Kent County Council 53 10 Consultee Response hl ie o giutr n niern Use Engineering and Agriculture for Sites Chalk to be no mention of: (a) PRoWs DR28, DR29, and DR48, which run south-west from Highcross Road. Any future extension of the Pinden operations would have an effect on these footpaths; and (b) the line of ancient Boundary Stones situated at the boundary between the Darenth and Southfleet Parishes. Darenth PC object for the same reasons disclosed above.
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
Although this site is adjacent to Disused Railway Cutting Longfield LWS, it is restricted to the railway cutting and the proposed extension is to the NW of the existing quarry and therefore should have no impact on the LWS. However, Kent Landscape Information System Kent Wildlife shows that the proposed extension is within woodland. Although not ancient in origin it would be beneficial to preserve as much of this Trust habitat. The LWS contains chalk grassland and the surrounding habitat contains neutral grassland. Therefore due to the sensitive nature of the infill, it may be more beneficial to create species rich grassland with its nature being dictated by the final conditions on site.
Friends of the Earth We are particularly concerned that Site 63 will be used for both the extraction of chalk and storage of asbestos, which would seem to Sevenoaks be incompatible activities. Group
Object for the following reasons: (1) The allocation is based on the volume of sales from Site 63 in 2011. Sales data from one site, for one year only cannot possibly indicate a much greater need for this chalk for the next 20 years; (2) Has KCC established whether the chalk sales are for agriculture or engineering use and not just as infill into another quarry site? It would be scandalous if it turns out that chalk is being removed from one site in North Kent just to infill another local old chalk quarry. At present this seems to be the only Southfleet explanation for the dramatic fourfold increase in demand from this one site; (3) KCC have not established that there is a regional or Parish national need to increase the reserves in Kent for chalk for agriculture or engineering use as indicated in the Preferred Options Document; Residents' (4) The local residents know they have to put up with this quarry until 2042 after the Northern Extension was granted permission a few Association years ago. Recently the quarry has been given permission to excavate to a much deeper level to 'win' more chalk and make a bigger hole in the ground. So in only a very few years, the quarry operators are changing 'the goal posts' from that which was originally stated/agreed. Any further expansion would make a mockery of the KCC strategy and planning process and require many additional vehicle movements, create more dust and more noise despite KCC trying to maintain the present operating conditions and limits.
Site 63 is crossed by a National Grid high pressure underground gas transmission pipeline. We require that no permanent structures are built over or under pipelines or within the zone specified in the agreement, materials or soil are not stacked or stored on top of the pipeline route and that unrestricted and safe access to any of our pipeline(s) must be maintained at all times. Site 63 is also bounded AMEC E&I to the NW by a National Grid high voltage overhead electricity transmission lines. National Grid does not object to the proposals outlined UK (for however, the following points should be considered: (1) National Grid does not own the land over which the overhead lines cross, and National Grid) it obtains the rights from individual landowners to place our equipment on their land. Potential operators of the sites should be aware that it is National Grid policy to seek to retain our existing overhead lines in-situ because of the strategic nature of our national network. We advise developers and planning authorities to take into account the location and nature of existing electricity transmission equipment when planning a development; (2) Statutory electrical safety clearances must be maintained at all times (distances available here). 54 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
• No checks are carried out by any agencies to ensure hazardous waste is being transported safely • Loads could be transported by rail, taking HGVs off the roads and away from residents’ homes • Landscaping arrangements have failed and the existing quarry is a General blot on a once beautiful landscape • No mention of the massive housing development in Longfield which must have a significant impact Public on road capacity • Expansion of the site in the Green Belt is not enhancing the neighbourhood • What volume of hazardous waste is anticipated, how soon will it fill? • Completion of restoration by 2042 does not deal with the possible eyesore and necessity for ongoing restoration and screening • Is there a limit on the number of skips that can be stored on the site? Chalk Sites for Agriculture and Engineering Use 10 Mineral Sites Preferred Options Commentary Report Kent County Council 55 10 This page has been left blank intentionally. hl ie o giutr n niern Use Engineering and Agriculture for Sites Chalk 56 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Brickearth Sites
Object 1
1 response Support 0 Responses relating to brickearth sites. Brickearth Sites Comment 0 11
Consultee Response
In-combination impacts of Sites 98, 101 and 102
The Trust is concerned that the above sites could have an in-combination impact on the Swale SPA and Ramsar sites especially when viewed in-combination with Site 91. We apologise for not identifying the possible in-combination impacts of these sites on the SPA and Ramsar within the Mineral Site Options consultation. This is due to the three brick earth sites being submitted at a late stage within the process.
Although the habitats within and adjacent to the sites are grade 1 agricultural land, there is a risk that the level of quarrying proposed could impact on the hydrology of the SPA and Ramsar Sites. As the water flow is paramount to the functioning of the European sites and the survival of the bird species for which the SPA is designated, it is our view that all the above sites should be scoped into the HRA for possible impacts on the hydrology with an overall hydrological assessment undertaken for the three brickearth sites. We note that this issue has not been identified within the initial assessment and we would value the opportunity to discuss this further. Kent Wildlife Trust In relation to all four sites there may be a chance that the agricultural land contains supporting habitats for the SPA bird species. We note that this issue is identified within the initial HRA for Site 101. We would question why this site has been scoped in, whilst the other three sites which will also cause loss of agricultural land, have been scoped out. We recommend that wintering and breeding bird surveys are undertaken on all habitats to be lost before final submission of the Development Plan Document, to ensure that no supporting habitat is lost.
Finally, we would recommend that the in-combination impacts of noise from all four sites are considered within the HRA. We note that Site 91 has been identified for possible noise impacts and is very close to the SPA. We feel that alone this site is unlikely to have a significant impact unless it contains supporting habitat however, in-combination impacts are possible due to the extraction activities within the surrounding area. Due to the above concerns we would object to the HRA conclusions that Site 98 and 102 can be scoped out of the HRA at this point. If in-combination impacts are found to be present due to the above pressures then it maybe pertinent to phase the three brickearth sites to ensure that only one site is operational at any time to alleviate impacts. Mineral Sites Preferred Options Commentary Report Kent County Council 57 11 This page has been left blank intentionally. rcerhSites Brickearth 58 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 19: Paradise Farm, Hartlip and Newington
Responses for Site 19: Paradise Farm, Hartlip and Newington
Object 56 This site is proposed for the extraction of brickearth. It would be worked once a year for Brickearth Sites a six week period and restoration would be progressive with the working of the site. The 61 responses Support 0 11 site is mostly covered by orchards. It is surrounded by further orchards, agricultural land, Comment 5 horse meadows and the gardens of residential properties.
Consultee Response
Object due to the potential impact on the AQMA in Newington and the noise/dust pollution to nearby residential properties. The site could also have potential landscape impacts and would also require access on to a rural lane. If Site 19 should go ahead, the following Swale safeguards need to be applied: (1) Access must be either through the Newington Industrial Estate or onto Lower Hartlip Road at least Borough 100m from any residential dwelling. Access should preferably be via Newington Industrial Estate only; (2) Extraction may only take place Council for a continuous six week period between May and September in any year: (3) No extraction shall take place within 100m of any dwelling: (4) Details of the proposed screening should be agreed before commencement of any extraction; (5) Development must be subject to restoration of the site to agricultural use. The other recommended conditions in the Preferred Options Document are supported.
Hartlip PC object to the inclusion of Site 19 for the following reasons: (1) Highways - direct access to the A2 and the Lower Hartlip Road are not feasible; (2) Impact on the local community - 50 twenty ton lorries entering and leaving the village each day for 6 weeks of each year for 23 years would mean that many residents would not have any peace for the rest of their lives. There is a lot of wildlife in the area which would be badly affected by such industrialisation. Noise and dust would cause health problems for people living in the locality. A footpath which is close to the site is much used, including children walking to school. Such development would lead to a significant change to the character of the village which, at present, is predominantly orchards. The soil is good quality agricultural soil. Newington already has air quality problems and the approval of Site 19 would only accentuate this. Hartlip PC is of the view that there Parish are other sites which would not have the same impact on the road system, on quality of life and which are more sustainable should be Councils preferred. Newington PC Planning Committee object for the following reasons: (1) AQMA and Distance - Newington High Street (A2) is the subject of an AQMA. Site 19 is 800m away. The proposal would generate 3,000 additional HGV movements through an already established air quality black spot which would be exacerbated by the fact that extraction would be limited to a six week period in each year. This will result in an additional HGV movement every 5 minutes; (2) Nearest dwelling - Site 19 shares a common boundary with residential homes; (3) Nearest settlement - Site 19 shares a common boundary with Orchard Drive, a residential estate which is part of the built up village; (4)Nearest public or outdoor recreation area - Site 19 at its eastern end, borders three important community areas: the village recreation ground, Newington allotments and Newington Community Woodland. All three sites are frequently used; (5) Listed Mineral Sites Preferred Options Commentary Report Kent County Council 59 11 Consultee Response rcerhSites Brickearth buildings - there are numerous listed buildings within 800m of Paradise Farm; (6) The A2 runs through the centre of the village and the junction of the High Street with Bull Lane is one of the narrowest points on the whole of the A2. It is difficult to envisage how it could be argued that the A2 at this pinch point could safely accommodate the volume of additional HGV movements.
The description of the heritage potential of the site is misleading. Our advice outlined the potential for prehistoric, Roman and later KCC Heritage remains. The "subject to" section should refer to the need for a programme of archaeological work in advance of development and the mitigation of impacts on listed buildings.
This site is identified in the Mineral Sites Options consultation and HRA as being within the locality of Queendown Warren SAC and we highlighted the possible impacts as a result of nitrogen deposition within our response. We agree with the HRA that due to the phased nature of the work to be undertaken and the limited time for these works (12 weeks per year), that there are unlikely to be significant individual impacts as a result of the brickearth extraction. However, we are concerned that we can find no reference to analysis of in-combination impacts as a result of other proposed projects that may be using the road network. It is our view that the issue of in-combination impacts of nitrogen deposition should be considered at a county scale as part of the MWDF process, with vehicle Kent Wildlife movements and destinations being identified and impact calculated. This is especially pertinent for this site due to the fact that the critical Trust load for calcareous grassland is already being exceeded on site and significant new development is proposed within the Swale Core Strategy. If the above nitrogen deposition study is not undertaken and all in-combination impacts fully assessed within the HRA and final Development Plan Document,we would object to allocation of this site. Due to its sensitive location within the locality of Queendown Warren SAC and the residual and in-combination impacts on the SAC that may be caused by the increase in vehicle movements, we are surprised that the restoration plan is to agriculture. It is our view that if extraction is to be permitted within the locality of any SAC, opportunities for biodiversity conservation should be included within the restoration plan to ensure positive gains for wildlife outweigh the negative impacts that will result from the proposed quarrying.
Natural The URS conclusion that the air quality on Queendown Warren SAC is already above critical load and the development of Site 19 would England make it worse, suggests that the allocation of the site should be critically reviewed.
Our objections are as follows: (1) Extraction will create dust and residue thus causing discomfort to our members and have an effect on the produce growing; (2) Brickearth removal will create continuous noise which will impact on members' enjoyment of their allotment. Work on allotments can only be carried out in daylight hours and the expected constant movement of lorries will give no respite for those Newington trying to maintain their plots; (3) Pollution caused by machinery and HGVs is likely to have a detrimental effect on members' health, Allotment wellbeing and comfort, and could potentially contaminate organically managed fruit and vegetables; (4) Restoration of the ground would Association be 1 to 3m below the original level. In view of this, the water holding capacity of the allotment site is likely to be affected and the ability of the allotment site to retain moisture would be demised; (5) The proposed area comes right to the boundary of the allotment, thus exposing plots to all of the above and compromising their security; (6) Three key facts have not been stated: • What time of the year is the earth removal to take place? • How many days of the week? • How many hours a day? 60 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
We suggest the following amendment (underlined) to "subject to" criterion (1): "The access to and from the brickearth area being either Wienerberger through the nearby Newington Industrial Estate or onto Lower Hartlip Road north of Paradise Farm. If the latter, a full transport assessment Ltd must accompany any planning application and any recommendations for improvements must be addressed by the operator at their own expense prior to development commencing".
Site 19 is located within groundwater SPZ 2. Development should therefore only be permitted if adequate mitigation measures can be Southern implemented to the satisfaction of the Environment Agency. Such measures must ensure that the vulnerability of the groundwater source Brickearth Sites Water to contamination is not increased, and that public health and the quantity of water supplies are protected. 11 • Local roads are not suitable for HGVs (very narrow and in poor condition) and cannot accommodate the weight of traffic from three proposals (i.e. Site 19, enlargement of the Newington Industrial Estate and a lorry park at Scott’s Hill). Proposal will exacerbate situation by generating additional HGV movements, thus increasing congestion, pollution and wear and tear on our roads • Increased risk of pedestrian and vehicular accidents (school children in particular) • Extraction will create noise, pollution and dust severely affecting General residents’ health and quality of life • No indication of the buffer area has been allocated • If this extraction must take place, owner/operator Public should pay for the widening of Wormdale Road to provide proper access out on to the A249, thus avoiding the village • Additional traffic will further worsen air quality in the area which is already very poor • Wildlife would be badly affected by such industrialisation (i.e. badgers, bees, birds, insects, foxes) • Duration of extraction is unacceptable as extraction will blight the village and its residents for 6 weeks every year, for 23 years • Loss of rich agricultural soil • Proposal will spoil one of Kent’s prettiest villages • Damage to footpaths. Mineral Sites Preferred Options Commentary Report Kent County Council 61 11 This page has been left blank intentionally. rcerhSites Brickearth 62 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 98: Jefferies Site, Teynham
Responses for Site 98: Jefferies Site, Teynham
Object 5 The site is proposed for progressive brickearth extraction with on-going restoration back
Brickearth Sites to agricultural land. The brickearth working would be undertaken in east to west strips Support 0
11 progressing from north to south. The brickearth reserves to the north of the site have also 8 responses been previously worked and restored. The site is currently arable farmland. Adjoining uses Comment 3 include farmland (some of which is restored brickearth workings), an orchard and residential/farm houses.
Consultee Response
Swale Borough Swale BC conditionally has no objection to this site due to it being an existing operation due to run for only three years. Council
The archaeological potential of the site has not been mentioned and the site should be subject to a programme of archaeological work KCC Heritage in advance of development.
Kent Wildlife Object to the HRA conclusions that Site 98 and 102 can be scoped out of the HRA at this point. Trust
We object to the proposed site for the following reasons.
(1) The London Road is not suitable to handle any more HGV traffic.
(2) The London Road is a very dangerous high speed road, KCC need to make safety improvements before any additional HGV traffic London Road is allowed on the road. These include a 50mph speed limit between Teynham and Provender Lane and traffic lights at the Nouds Lane, Protest Group Lewson Street, Norton Cross and Provender Road junctions to protect road users and local residents. All have been sites of major accidents.
(3) The London Road is in a very poor state of repair with many raised manholes, bare patches, signs of wear, gaps, poor repairs and high levels of vibration caused by HGV traffic over the damaged road surface. Mineral Sites Preferred Options Commentary Report Kent County Council 63 11 Consultee Response rcerhSites Brickearth We will not put up with anymore HGV traffic on the London Road until the above is in place. It is time for KCC to get the London Road under control and protect its residents.
Our objection to the site is to the detrimental effect on agricultural land and countryside, and to the number of lorry movements. 140 The movements a day will significantly impact on the traffic in Sittingbourne. Since the brickearth is for the Weinerberger Smeed Dean Sittingbourne brickworks, all traffic in the absence of a completion of the Northern Relief Road to the A2, will either have to travel down Murston Society Road/Church Road/Dolphin Road, or into the town to travel along Eurolink Way. Either route is already congested and unsuitable for heavy lorries.
The site is located within groundwater SPZ 2. This signifies that the area requires a high level of protection to safeguard public water Southern supplies. Development should therefore only be permitted if adequate mitigation measures can be implemented, to the satisfaction of Water the Environment Agency. Such measures must ensure that the vulnerability of the groundwater source to contamination is not increased, and that public health and the quantity of water supplies are protected.
• Concern over the amount of extra HGVs going through our village and in fact past our front door and many other properties • Proposal was not publicised well enough by KCC or our local council • 140 movements onto an already congested A2 will bring misery to the General people of Teynham • We can't cross the road now without taking risks, there is only one crossing by Crispins • The pollution from these Public extra lorries will have an effect on our lives, our childrens lives and wildlife • The A2 was not designed to take the traffic we have to endure now, at certain times of the day now it is gridlocked. Sites like this should have good access, Teynham does not. 64 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 101: Barbary Farm, Norton Ash
Responses for Site 101: Barbary Farm, Norton Ash
Object 37 Proposal for the extraction of brickearth. The extraction area and tonnage would be Brickearth Sites sufficient to provide for a 25 year tranche of supply, with progressive restoration taking 41 responses Support 1 11 place throughout the extraction period. The site is currently used for soft fruit and arable Comment 3 farming. Adjoining uses include the A2, farmland, residential properties and a cricket club.
Consultee Response
Object due to: (a) impacts on residential amenity from noise and dust pollution; and (b) impact on the AQMA in Ospringe where there is already an exceedence of the National Objective for Nitrogen Dioxide with HGVs making a significant contribution. Although extraction Swale is only for 6 weeks, this is still likely to worsen air pollution. Mitigation should site go ahead: (1) No extraction shall take place within Borough 100m of any dwelling; (2) Details of the proposed screening should be agreed before commencement of any extraction; (3) No vehicles Council carrying brickearth from this site or returning to it empty shall use the A2 through Ospringe unless in an emergency. This avoids any increase in lorries making the air quality worse in the AQMA; (4) Progressive restoration must be carefully managed to allow the site to return to the highest agricultural grade possible; (5) The other recommended conditions in the Preferred Options Document are supported.
Teynham PC oppose Site 101 for the following reasons: (1) Excavation will generate an intolerable increase in lorry movements; (2) The potential hazard of lorries accessing and exiting along the A2; (3) Concerns over possible noise. Norton, Buckland and Stone PC object for the following reasons: (1) Traffic - the volume of traffic generated would inevitably lead to a major increase in traffic density, which would only exacerbate an already hazardous situation. Site entrances would themselves constitute a hazard, with HGVs turning and other problems such as mud on the road. Traffic would have to pass through the already overloaded bottlenecks on the A2 of either Teynham or Ospringe on its way to East Sussex. Furthermore, the approved Norton Ash Garden Centre Site (some 400m west of the Parish proposed access to the A2) is expected to generate considerable traffic, in addition to that which this busy stretch of road already Councils accommodates. It should be noted that the Barbary Farm site was previously rejected for this use due to traffic concerns and the situation has only worsened since that time; (2) Environmental and land use - the land at Barbary Farm is classed as Grade 1 under the Agricultural Land System. Government guidance decrees that for all planning purposes this classification of land should only be developed as a last resort. It is doubtful if the land, even after restoration, would maintain this classification; (3) Economic - retention of Site 101 in its current state represents far greater value to the area and Kent in general, than its downgrading to service the small yellow brick industry, contributing nothing to the well-being of the locality, and being to the detriment of both employment and the economy of the area.
Early evaluation of the site is recommended to determine whether the northern part of the site should be developed or not. Clearer KCC Heritage wording may be needed for the protection of the northern part of the site if important archaeology found to be present. Mineral Sites Preferred Options Commentary Report Kent County Council 65 11 Consultee Response rcerhSites Brickearth Natural It is important to know if the site is currently used by SPA birds and to review the situation at the planning application stage. This approach England should be considered on a number of sites where data is incomplete.
Royal Society for the Barbary Farm is 1km south of The Swale SPA/Ramsar site and may be a supporting habitat. Need to see survey work for this site to Protection of see whether it currently supports Annex 1 listed birds. Birds
We object to the proposed site for the following reasons: (1) The London Road is not suitable to handle any more HGV traffic; (2) The London Road is a very dangerous high speed road, KCC need to make safety improvements before any additional HGV traffic is allowed on the road. These include a 50mph speed limit between Teynham and Provender Lane and traffic lights at the Nouds Lane, Lewson London Road Street, Norton Cross and Provender Road junctions to protect road users and local residents. All have been sites of major accidents; Protest Group (3) The London Road is in a very poor state of repair with many raised manholes, bare patches, signs of wear, gaps, poor repairs and high levels of vibration caused by HGV traffic over the damaged road surface. We will not put up with anymore HGV traffic on the London Road until the above is in place. It is time for KCC to get the London Road under control and protect its residents.
Support KCC's allocation of Site 101. We make the following points concerning objections to the site: (1) Need for extraction - the NPPF reaffirms the 25 year supply of clay at paragraph 146. This stipulates the “provision of a stock of permitted reserve to support the level of actual and proposed investment required for new or existing plant”; (2) Traffic - we have identified concerns that "an additional 400 lorry movements will be created" which is not the case. An application to extract from Site 101 would replace the extraction at Hempstead and thus there will be no net increase in lorry movements on the highways. For a short period of time it will be necessary to have an Ibstock Brick overlap of the working ceasing at Hempstead House and commencing at Barbary Farm to allow for the blending of clays; (3) Noise and Ltd dust - Ibstock maintain an impeccable relation with the residences neighbouring our Hempstead House site as extraction only takes place during daytime hours and dust is managed using water bowsers and temporary dust fencing as necessary; (5) Archaeology - Ibstock will continue to work closely with our archaeological consultants and KCC in relation to the potential presence of archaeological features at the site; (6) At the point of preparing the planning application for Site 101 (if allocated), Ibstock will complete screening and scoping (as necessary) in accordance with Environmental Impact Assessment regulations. Full response available here.
• Local roads are already very dangerous, in poor condition and are unsuitable for HGVs • Additional HGV movements will increase pollution and reduce road safety, resulting in many more accidents • Noise, mud and dust from extraction will affect residents’ properties and quality of life, especially those suffering from respiratory conditions • Loss of view • Adverse effect on property values • Visual blight General of development • Ruination of rich agricultural farmland • Adverse effect on natural environment (mature hedgerows, migratory birds, Public kestrels, Grey Partridge, Common Buzzards, owls, bats, badgers) • Footpaths and PRoWs will be lost • Listed buildings will be put at risk in Teynham and Ospringe due to vibration and pollution from increased traffic and congestion • Archaeological concerns that the route of the Roman Road from Dover and London run within the site • Extraction is unsustainable due to the number of road miles involved in transporting loads outside of Kent • Extraction would provide very little for the local economy and community. 66 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 102: Barrow Green Farm, Teynham
Responses for Site 102: Barrow Green Farm, Teynham
Object 29 This site is proposed for the extraction of brickearth. The extraction area and tonnage
Brickearth Sites would be sufficient to provide for a 25 year tranche of supply, with progressive restoration Support 1
11 32 responses taking place throughout the extraction period. The site is currently agricultural land and orchards separated by mature hedges and trees. Adjoining uses include residential/farm Comment 2 buildings and land.
Consultee Response
Object due to: (a) impacts on residential amenity from noise and dust pollution; and (b) impact on the AQMA in Ospringe where there is already an exceedence of the National Objective for Nitrogen Dioxide with HGVs making a significant contribution. Although extraction Swale is only for 6 weeks, this is still likely to worsen air pollution. Mitigation should site go ahead: (1) No extraction shall take place within Borough 100m of any dwelling; (2) Details of the proposed screening should be agreed before commencement of any extraction; (3) No vehicles Council carrying brickearth from this site or returning to it empty shall use the A2 through Ospringe unless in an emergency. This avoids any increase in lorries making the air quality worse in the AQMA; (4) Progressive restoration must be carefully managed to allow the site to return to the highest agricultural grade possible; (5) The other recommended conditions in the Preferred Options Document are supported.
Teynham PC continue to oppose Site 102 for the following reasons: (1) Excavation will generate an intolerable increase in lorry movements; (2) The potential hazard of lorries accessing and exiting along the A2; (3) Concerns over possible noise. It is also stressed that should Site 102 go ahead, any access via Lower Road would be totally unacceptable. Norton, Buckland and Stone PC object for the following reasons: (1) Traffic - the volume of traffic generated would inevitably lead to a major increase in traffic density, which Parish would only exacerbate an already hazardous situation. Site entrances would themselves constitute a hazard, with HGVs turning and Councils other problems such as mud on the road. Traffic would have to pass through the already overloaded bottlenecks on the A2 of either Teynham or Ospringe on its way to East Sussex; (2) Economic - retention of Site 102 in its current state represents far greater value to the area and Kent in general, than its downgrading to service the small yellow brick industry, contributing nothing to the well-being of the locality, and being to the detriment of both employment and the economy of the area.
The archaeological potential of the site has not been mentioned. Further archaeological assessment including field evaluation required KCC Heritage in advance of development.
Kent Wildlife Object to the HRA conclusions that Site 102 and 98 can be scoped out of the HRA at this point. Trust Mineral Sites Preferred Options Commentary Report Kent County Council 67 11 Consultee Response rcerhSites Brickearth Royal Society for the Not clear why Site 102 has not been screened in whereas Site 101 has. Site may be supporting habitat for The Swale SPA/Ramsar. Protection of Need to see survey work for this site to see whether the site currently supports Annex 1 listed birds. Birds
We object to the proposed site for the following reasons: (1) The London Road is not suitable to handle any more HGV traffic; (2) The London Road is a very dangerous high speed road, KCC need to make safety improvements before any additional HGV traffic is allowed on the road. These include a 50mph speed limit between Teynham and Provender Lane and traffic lights at the Nouds Lane, Lewson London Road Street, Norton Cross and Provender Road junctions to protect road users and local residents. All have been sites of major accidents; Protest Group (3) The London Road is in a very poor state of repair with many raised manholes, bare patches, signs of wear, gaps, poor repairs and high levels of vibration caused by HGV traffic over the damaged road surface. We will not put up with anymore HGV traffic on the London Road until the above is in place. It is time for KCC to get the London Road under control and protect its residents.
Support KCC's allocation of Site 102. We make the following points concerning objections to the site: (1) Need for extraction - the NPPF reaffirms the 25 year supply of clay at paragraph 146. This stipulates the “provision of a stock of permitted reserve to support the level of actual and proposed investment required for new or existing plant”; (2) Traffic - we have identified concerns that "an additional 400 lorry movements will be created" which is not the case. An application to extract from Site 102 would replace the extraction at Hempstead and thus there will be no net increase in lorry movements on the highways. For a short period of time it will be necessary to have an Ibstock Brick overlap of the working ceasing at Hempstead House and commencing at Barrow Green to allow for the blending of clays; (3) Noise and Ltd dust - Ibstock maintain an impeccable relation with the residences neighbouring our Hempstead House site as extraction only takes place during daytime hours and dust is managed using water bowsers and temporary dust fencing as necessary; (5) Archaeology - Ibstock will continue to work closely with our archaeological consultants and KCC in relation to the potential presence of archaeological features at the site; (6) At the point of preparing the planning application for Site 102 (if allocated), Ibstock will complete screening and scoping (as necessary) in accordance with Environmental Impact Assessment regulations. Full response available here.
• Additional HGVs will have a detrimental effect on air quality, residential amenity and property, and road safety • Local roads are in a poor state of repair and are unsuitable for additional HGV movements which will create vibration and further damage the road surface • Destruction of mature hedgerows will result in the loss of wildlife • Archaeological concerns that the route of the Roman Road from Dover and London run within the site • Extraction will produce dirt, dust, noise and congestion • Brickearth removal will result in the loss of Grade 1 agricultural land, thus running counter to Government guidance for sustainable development in rural areas. Only 2 to 3% of land in the British Isles is of the quality found at the site • Effect on Whiteleaf Farm - continuously spooked horses would be a danger General to all involved and a major health and safety issue • Risk of contamination to local water supply • Damage to listed buildings • A PRoW Public is situated within the site area. This needs to be fenced off from extraction work to protect users, with crossing points for machinery and vehicles carefully signposted and monitored • Access from the site on to the A2 London Road should be carefully considered. This is a very fast road and any HGV traffic joining or leaving the A2 would be extremely hazardous without formal controls (i.e. a slip road on and off the site or traffic light controls) • To the east of Lewson Street is the last remaining original cherry orchard in the whole of Swale. This area of land should be removed from the proposal, protected and not destroyed • Consultation process has failed to engage with residents who will be directly affected by the site • Extraction will accentuate subsidence along the frontage of the London Road. 68 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 60: Norwood Quarry & Landfill Extension, Minster and Eastchurch
Responses for Site 60: Norwood Quarry & Landfill Extension, Minster & Eastchurch Clay Sites
12 Object 2 Proposed extension to the existing quarry for clay extraction, as well as hazardous waste landfill for flue ash from the Allington EfW incinerator. Two possible site extensions are Support 1 promoted: one to the east and one to the north of the existing site. Site is currently arable, 8 responses agricultural land. Adjoining uses include the existing quarry and landfill, agricultural land Comment 5 and Norwood Manor with its associated buildings and garden. Site 60 can also be found in the Waste Sites Preferred Options Commentary Report, Chapter 7: Hazardous Landfill.
Consultee Response
Swale Borough Council conditionally have no objection to this site as it will utilise existing infrastructure and access, and will provide a needed supply of London Clay. This is subject to the need to ensure adequate mitigation for traffic movements, and mitigation of impacts Swale on visual/residential amenity. The site should be restored once it closes. It is felt that the northern extension is a more viable option than Borough the eastern one due to potential landscape impacts. However, we would object to the proposal if: (1) It increases traffic levels above Council current volumes on the Lower Road; (2) Landscape impacts and impacts on residential amenity were not capable of being successfully mitigated; (3) Any residential amenity impacts are created due to the noise and dust from the operations.
Minster-on-Sea PC - environmental intrusion is considered more intrusive on the east of the existing site. One of the sites is located 200m from an underground reservoir on Chequers Hill. If clay is taken away it might compromise the support of the reservoir. Also worth noting that the water run-off route flows through the existing Bagshot beds via middle Minster and ends up as the Scrapsgate Drain. The tarmac approach to the site floods the A2500 Lower Road during heavy rain and presents a serious risk to road users. This current problem needs addressing. There are concerns about the loss of Grade 2 Farmland. There are also concerns about the site's close proximity to neighbouring properties and the impact of the proposal on the vista and amenities residents might reasonably be expected to enjoy. The consultation process does not appear to be targeting those that need to know. Only two people, both of whom were parish Parish councillors attended the information session at Thistle Hill. Councils Eastchurch PC object to the eastern extension due to the lie of the land, which would make it impossible for any environmentally acceptable landscaping to be provided to mitigate what would be a serious blot on the landscape. The current workings are shielded by some natural contours and the bund which was installed blends well with this. The proposed area is low lying and any bunding would provide no natural feature at all. For many years since the landfill site was inaugurated, there has existed a liaison group, chaired by this parish, and attended by local residents together with representatives of the site management, the Environment Agency, KCC, Swale Borough Council and Minster Parish Council. Problems related to the site have been discussed and dealt with on a regular basis. When planning was sought for the previous extension and the Allington waste processing plant, we were assured by Waste Management that Mineral Sites Preferred Options Commentary Report Kent County Council 69 12 Consultee Response lySites Clay it would be a 10 year project and after that time the current cell would be sealed and landscaped and that there would be no further working at the site. Given the high level of local concern, ourselves and others reluctantly agreed to offer no objection on the basis of this assurance as to the terminal life of the site. We trust that this agreement will be honoured and we will do everything possible to ensure that is so.
KCC Heritage Further archaeological assessment including field evaluation required in advance of development.
Kent Wildlife Trust has no objection to the proposed extension to the above site. Woodland is present within the extension. This should Kent Wildlife be conserved if possible and if lost, should be replaced within the restoration. As this site is adjacent to the North Kent Marshes BOA, Trust we recommend that it is restored largely to wetland habitats. We welcome the aim to restore some of this site to woodland and ponds but would advise that to gain the optimum ecological enhancement, agricultural uses should be excluded from the restoration plan.
Friends of the Earth We are particularly concerned that Site 60 will be used for both the extraction of clay and for storage of flue residues from Allington. We Sevenoaks advocate that scientific analysis of these residues be carried out and mined for materials, which can be recycled. Group
We respond on behalf of FCC Environment (formerly Waste Recycling Group Ltd). FCC fully supports the allocation of the proposed extensions to the existing Norwood site for both clay extraction and hazardous waste landfill.
We wish to make two minor comments on the Site Information schedule included in both plans. Stephen Bowley (1) The operator should be changed to FCC Environment. Planning Consultancy (2) Regarding "subject to" criterion (2), we would ask that the phrase "Restoration to original ground levels..." be replaced by "Restoration to agreed ground levels". The approved restoration contours of the existing site are above original ground levels due to the site engineering and landscaping requirements, and the same situation is likely to occur for the extension areas - particularly the eastern extension. The proposed wording therefore provides the necessary flexibility at the planning application stage.
I am not convinced that the A249 is suitable for more lorries coming on and off the Island. Lower Road is also fairly narrow and heavily congested during the summer as it is the main road through to Leysdown. It is a shame that Swale Borough Council and KCC seem General determined to try and sink us under the weight of more and more lorries and housing rather than regenerating the area and bringing Public (Only 1 money in that way. I am also concerned about the effect that the lorries and the ash will have on the air quality in the surrounding area. Comment My daughter has asthma and part of the reason we moved here was to escape the built up area and main road that we lived on. Will Received) there be a knock on effect on the surrounding agricultural land as surely there will be seepage from the site onto the fields? Also, I would have attended the local meeting but I was unaware that it was happening. 70 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Mineral Importation Sites
Object 0
1 response Support 0 Responses relating to mineral importation sites.
Comment 1
Consultee Response Mineral Importation Sites Paragraphs 11.1 and 11.2 recognise the importance of marine sourced aggregates. East plan area aggregates make a significant Marine
13 contribution to the economy of London and the south east so it is reassuring that they are noted here (as imports into Kent) and the Management need to safeguard wharves for landing of aggregates. As the document only considers sites for quarrying and they do not appear directly Organisation relevant to development of marine plans in the south east we have no further comments to make. Mineral Sites Preferred Options Commentary Report Kent County Council 71 13 This page has been left blank intentionally. iea motto Sites Importation Mineral 72 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 1: East Peckham Rail Depot, East Peckham
Responses for Site 1: East Peckham Rail Depot, East Peckham
Object 0 The proposal is to make the East Peckham Rail Depot into a permanent facility. It is currently an active, operational mineral importation railhead situated in a quarry having 3 responses Support 0 previously been granted temporary planning permission. The site is located within the Comment 3 Green Belt close to its boundary. Mineral Importation Sites Consultee Response 13 Development Management - this is an existing quarry site which is within the Green Belt in Tonbridge & Malling Borough Council. Existing Maidstone access is off the A228. The main issues are environmental/visual impact. We do not consider there to be any issues, aside from the Borough management of extraction through phasing and restoration until complete. Transport - this rail depot currently has temporary planning Council permission for the same use that is proposed to be made permanent. Given there are no changes to the existing development the permanent permission is unlikely to cause an unacceptable impact on the road network.
This site is within the Medway Low Weald Wetlands and Grasslands BOA and adjacent to Site 2. Although we have no objections to the continued operation of the depot due to the significant impact of Sites 2, 17, 49, and 71, we recommend that there should be no further impact from this site to the water system feeding the adjacent Stoneham and Lees LWS and the protection of the ancient woodland. Kent Wildlife We welcome the proposed screening which will extend the woodland within the area, but would recommend that the quarry be enhanced Trust for biodiversity with habitat re-creation being to wetland habitats, reflecting the targets of the BOA. Stringent safety measures should be included to ensure that there is no contamination of the surrounding LWS from operations on site and no in-combination impacts with the above sites.
We have identified that wastewater infrastructure crosses the site, and that the site abuts East Peckham Wastewater Treatment Works. The underground infrastructure that crosses the site needs to be protected so that it can continue to fulfil its function. Future maintenance and upsizing of the infrastructure must be secured through easements of between 6 and 13 metres. Diversion of the infrastructure may Southern be possible at the developer's expense, provided a feasible alternative route is available. The proposed site also abuts East Peckham Water Wastewater Treatment Works. It is important that the development is compatible with this existing use. We expect a policy that allocates this site for mineral development to recognise these constraints, and ensure that the existing infrastructure and Wastewater Treatment Works are protected. Mineral Sites Preferred Options Commentary Report Kent County Council 73 13 This page has been left blank intentionally. iea motto Sites Importation Mineral 74 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Secondary and Recycled Aggregates
Object 0
1 response Support 1 Responses relating to secondary and recycled aggregates.
Comment 0
Consultee Response
The current Area Specific policy AS14 in the saved Dover District Local Plan states that any new development should visually upgrade Dover District the A256, all new buildings should be low rise, the risk of flooding should not be increased and provision should be made for archaeology. Council There is uncertainty whether this policy will be included in the Land Allocations Document and it is requested that such criteria should form the basis of any new allocation/policy in the Waste Sites Development Plan Document. Secondary and Recycled Aggregate Sites 14 Mineral Sites Preferred Options Commentary Report Kent County Council 75 14 This page has been left blank intentionally. eodr n eyldAgeaeSites Aggregate Recycled and Secondary 76 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 21: F M Conway, Rochester Way, Dartford
Responses for Site 21: F M Conway, Rochester Way, Dartford
Object 1 Proposed extension to the current secondary and recycled aggregate processing facilities. FM Conway have an existing site on the border of Dartford and the London Borough of Support 0 Bexley. The site processes waste from roads and pavements to produce recycled 4 responses aggregates used in asphalt for future road and pavement bases and surfaces. Adjoining Comment 3 uses include part of Dartford Heathland A2, a crushing plaster board company, a builders yard and a very small waste operation.
Consultee Response
LB Bexley's environmental health department has previously received significant numbers of complaints from residents of the Braeburn Park estate concerning excessive noise and dust emissions. Additionally, residents have taken the opportunity, when consulted on a planning application for the site, to express views of total opposition to the principle of development and the operations being undertaken at the site.
In commenting on the discharging of conditions of planning application reference DA/06/417, officers have stated that they will continue Secondary and Recycled Aggregate Sites London to monitor the impacts on residents and would impress upon KCC the necessity to have an effective and robust monitoring and, if required Borough of
14 enforcement, regime in place to address matters should the requirements of the conditional permission not be met. Bexley It is concerning to note that in the KCC Preferred Options Documents, neither noise or dust impacts are mentioned in the “Site Specific Considerations” table, and the only residential impacts are noted in the SEA summary, these being a "possible landscape and community impact" on the housing. LB Bexley raises serious concerns about potential noise and dust impacts from any extension of this site, and therefore does not support the preferred option, which recommends support for an increase in capacity at this site.
Dartford Whilst Dartford Council makes no objection to the proposed extension, we have been made aware of possible concerns from residents Borough in the London Borough of Bexley living nearby and assume that these will be included in the London Borough of Bexley's own response Council to the consultation.
KCC Heritage This site should be subject to a programme of archaeological work in advance of development. Mineral Sites Preferred Options Commentary Report Kent County Council 77 14 Consultee Response eodr n eyldAgeaeSites Aggregate Recycled and Secondary This site is within the Thameside Green Corridor and is opposite Dartford Heath LWS. As stated within the Mineral Sites Options consultation, there is a risk of increased emissions due to the processes on site and the extra vehicles that the proposed extension of the recycling facilities will generate. This will need to be assessed in-combination with Waste Site 11: Lees Yard and Adjacent Land, Rochester Way, Dartford and could be included within the county-wide project. Kent Wildlife As heathland can be damaged by NOx in particular, we welcome the commitment to provide mitigation for any impact on the heathland Trust habitat. We would recommend that this be in the form of a contribution for the habitat restoration being undertaken within the LWS by Groundwork UK. If the built structure is to be extended there are also opportunities to provide additional heathland or acidic grassland habitat in the form of a green roof. We recommend that clauses detailing appropriate mitigation be incorporated within the site policy to ensure no impact on the adjacent LWS. 78 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 65: Land North of Stevens & Carlotti, Richborough
Responses for Site 65: Land North of Stevens & Carlotti, Richborough
Object 1 A proposed mixed use site for minerals and waste, working alongside the current Thanet Waste site at Richborough Hall to the south of this site. The proposal includes an anaerobic Support 1 digestion plant, an inert waste crusher and a screening and washing plant. The site is 6 responses currently derelict land in the process of being redeveloped for waste uses. Adjoining uses include industrial use, meadows and a former landfill. Site 65 can also be found in the Comment 4 Waste Sites Preferred Options Commentary Report, Chapter 10: Sites for Green Waste Treatment.
Consultee Response
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
This site is within the Lower Stour BOA as is Waste Site 54: Richborough Power Station A, Minster and Waste Site 64: Richborough Hall, Sandwich. As identified within the HRA, all sites are in close proximity to a number of sensitive Natura 2000 designations. We are
Secondary and Recycled Aggregate Sites concerned that the HRA only identifies in-combination vehicle movements. It is imperative that the impact of the emissions produced as a result of the waste and recycling processes planned, and predicted vehicle movements, be assessed both individually and
14 in-combination with the other sites within the plan. Other pressures such as recreational pressure due to the proposed development in Dover and Thanet, and direct habitat loss and disturbance as a result of the pipelines, wind farms and coastal path should also be considered within the assessment of in-combination impacts. It is our understanding that if further information is acquired during the planning process of a site, including at the detailed stage, a HRA should be required and appropriate mitigation agreed to alleviate impacts. Therefore, in the light of the proposed nitrogen deposition study, if Sites 54 and 64 are found to have an individual or Kent Wildlife in-combination impact not identified within the original assessment and still require detailed planning permission for any aspect of the Trust development, the planning permission will need to be reviewed and impacts assessed with appropriate mitigation measures formulated for any impact not mitigated within the original application. Assessment of individual and in-combination impacts should be undertaken as part of the MWDF process and not deferred to application stage as recommended within the HRA. The impacts of emissions from the procedures proposed and the additional vehicle journeys as a result of these developments should be included in a county-wide study on nitrogen deposition with individual and in-combination impacts being fully mitigated within any plan. Without such an assessment at a strategic level, KCC will not be able to evidence that there will be no significant impact on the European network and therefore will not be in conformity with the Conservation of Habitats and Species Regulations 2010 and thus we would strongly object to the allocation of all three sites (i.e. 54, 64 and 65). This site is adjacent to Ash Level and South Richborough Pasture LWS. We continue to have concerns regarding the indirect impacts on the habitats contained within the LWS, which is an extensive area designated for its grazing Mineral Sites Preferred Options Commentary Report Kent County Council 79 14 Consultee Response eodr n eyldAgeaeSites Aggregate Recycled and Secondary marsh wet dykes, ditches and scrapes, water bodies and river habitats. There is an extremely rich biodiversity on the site including rare invertebrates such as the shinning ramshorn snail, 12 species of dragonfly, 135 species of moth, 22 species of butterfly, good populations of 3 reptile species, water vole and brown hare. The site is of importance for farmland, migratory and breeding birds, with some SPA species using the site. We are very concerned that due to the nature of the LWS, the activities planned for this site in combination with Sites 64 and 65 will cause damage to the LWS through pollution and impact on the water flows. It is imperative that impacts are considered at a policy level with appropriate mitigation provided if this site is to be allocated. However, we can see no safeguards within the plan to protect the LWS from harm. Pending the outcome of these discussions, we object to the allocation of this site. As these sites are permanent facilities, there is not as much opportunity to provide positive gains for biodiversity as in the Mineral Sites Development Plan Document. However, there are opportunities to provide enhancement to the site not being used for waste purposes. Due to the sites' location within a BOA and their proximity to sensitive Natura 2000 sites, we recommend that any facility should be designed to fulfil the BOA targets (the most appropriate of which would be to protect and enhance existing BAP priority habitats and designated sites). Although calcareous grassland is not specifically mentioned in this context depending on the geology, there may be opportunities to create a chalk grassland green infrastructure within the site and opportunities to create a green roof reflecting the habitats currently found on site and within the locality. Although we understand that as planning permission has been permitted this enhancement cannot be required, we recommend that if possible, agreement is reached provide the above enhancements to achieve the maximum gains for biodiversity and alleviate some of the possible impact.
Environment The proximity of the site to the many designations in the area and the fact that it is adjacent to the River Great Stour will require further Agency work and appropriate environmental protection measures to ensure that the proposed operations to not harm the environment.
Site is 300m from Thanet Coast and Sandwich Bay SPA and Ramsar Site and Sandwich Bay SAC. Potential noise/disturbance impacts Royal Society from recycling operational activity and associated increased vehicular movements. Potential hydrological impacts from the washing of for the aggregates, both from discharge and from increase demand on existing resources. Potential impacts from transport of materials by road, Protection of and associated nitrogen deposition. Need to know more detail on route, numbers of vehicular movements, and potential impacts on Birds SAC should be undertaken. An in-combination assessment of impacts on the European sites from the furthering of sites within the Richborough Corridor should be performed.
Support the allocation of Site 65. Would, however, question whether there is a need to refer to the East Kent Access Phase 1C under the Site Specific Considerations, now that this new scheme has been completed. Would also question the comments under Strategic Thanet Waste Environmental Assessment Summary - HRA. We would advise that studies in respect of noise, transport and air quality were undertaken Services Ltd as part of the planning application/environmental statement and impacts considered acceptable. We would therefore comment that it is not necessary for such studies to be undertaken to support an allocation in the Waste Plan.
We have identified that water supply infrastructure crosses the site. This infrastructure needs to be protected so that it can continue to fulfil its function. Waste development on the site must ensure that it does not compromise its functioning. Future maintenance and Southern upsizing of the infrastructure must be secured through appropriate easements. Diversion of the infrastructure may be possible at the Water developer's expense, provided a feasible alternative route is available. We expect a policy that allocates this site for waste development to recognise this constraint, and ensure that the infrastructure is protected. 80 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 72: Unit 14, Canterbury Industrial Estate, Hersden
Responses for Site 72: Unit 14, Canterbury Industrial Estate, Hersden
Object 4 Site proposed for secondary and recycled aggregate production and for use as a waste transfer station for commercial and industrial, inert and excavation waste. The site is a 11 responses Support 1 former colliery tip now in use for general storage. Adjoining uses include industrial estate units, a railway line and the River Stour. Site 72 can also be found in the Waste Sites Comment 6 Preferred Options Commentary Report, Chapter 9: Treatment/Materials Recycling Facilities.
Consultee Response
Canterbury We support Site 72 as long as the development does not encroach on the adjacent LWS and a HRA is carried out to ensure no City Council detrimental impact on the adjacent Stodmarsh Ramsar/SPA/SAC/SSSI/NNR.
Object - (1) It is incomprehensible to consider that there will be no adverse impacts on the environment which is already protected by the Stodmarsh SAC/SPA/Ramsar site; (2) Increased congestion at the level crossing at Sturry and the nature of transported materials KCC Elected which are liable to dispersion whilst stationary; (3) The very nature of the materials being recycled will prejudice and destroy the wetlands Member for habitat as well as impact on the newly opened animal sanctuary; (4) The Site Specific Considerations state that there are "no known Secondary and Recycled Aggregate Sites Herne and planned developments likely to impact on road capacity". However, there is the latest planning intent by Hill Reed Developments to build Sturry up to 800 dwellings in three tranches at Hersden which will affect the A28; (5) The roads within the industrial park have not been adopted 14 by Kent Highway Services and are outside KCC control. It is not good enough to state that "the roads appear to to be suitable for HGV access". Do we have a weight limit at all? It would also be useful to know the number of vehicles required per day and over what hours.
Westbere PC object for the following reasons: (1) Site 72 is very close to a LWS, SSSI, Ramsar and RIGS designation. The proposal would have serious detrimental effects on this important area of conservation; (2) The Westbere Parish Plan advocates Land Use Designation and Zoning to 2050 incorporating phased development on Site 72. The proposals in the plan are intended to have only beneficial effects by improving the environment for the future; (3) We would be interested to know whether the businesses adjacent to the site have been made aware of the impacts that minerals and waste sites can have; (4) Site 72 is adjacent to the heavily populated Parish area of Hersden, thus making it an unsuitable option due to impacts on air quality, water quality, noise and disturbance; (5) The proposal Councils would generate more HGVs on the already overloaded A28 at a time when KCC's objective should be to lessen the stress on this route, particularly in view of the more frequent closure of the Sturry level crossing following the launch of the High Speed Trains. Wickhambreaux PC object for the following reasons: (1)The air quality of the area may be affected, presumably by the dust that is produced. Measures should be put into place to minimise this; (2) Water Quality - despite the site being separated from the SSSI in the area by the railway embankment, the Parish Council need assurances that no pollution will leach into the major river or main drains; (3)Noise - the recycling aggregate will certainly involve mechanical crushing. The Parish Council need to be assured that all possible steps will be taken to Mineral Sites Preferred Options Commentary Report Kent County Council 81 14 Consultee Response eodr n eyldAgeaeSites Aggregate Recycled and Secondary minimise noise; (4) Clearer information is required to the exact nature of the waste to be processed and how large the building/enclosure dealing with the waste will be; (5) Light Pollution - will there be flood lights on site? If so, how long will they be on for and when?; (6) The site has also been placed in Flood Zone 1. Measures will need to be put into place to ensure polluted surface run-off water doesn't go into the SSSI or the main rivers; (7) Traffic - the site would generate excessive vehicular movements coming through Canterbury and Sturry, which will in turn increase traffic on the already very busy A28. Furthermore, the proposed Collective Waste Management Contract (involving possibly six main districts) will generate additional traffic both coming into and leaving Canterbury.
Object for the following reasons: (1) The site is totally unsuitable as the A28 would find it very difficult to absorb the amount of HGVs required to feed this site; (2) The access to the site would need a high level of maintenance work to enable it to cope with the increased HGV traffic as it is currently in very poor condition; (3) The site is very close to a SSSI/Ramsar designation and would have a serious detrimental effect on this very important area of conservation and its wildlife; (4) The Westbere Parish Plan highlights the importance of Marshside developing the industrial park with sympathetic consideration of the adjacent Ramsar site in order to produce beneficial effects through Ward improvement of the environment for the future. It also mentions the need for the River Stour to be environmentally protected due to the wonderful and varied wildlife that it supports; (5) Site 72 is unsuitable due to its proximity to the heavily populated village of Hersden, which has some 800 houses, many with young families. The proposal would worsen air and water quality and cause noise and disturbance; (6) Traffic congestion on the A28 is constant. The site would only exacerbate this, thus increasing pollution and noise.
The description of the archaeological potential of the site is misleading as there is high potential but unknown previous impact. Further KCC Heritage archaeological assessment including field evaluation required in advance of development.
This site is within the Lower Stour Wetlands BOA and adjacent to Former Hersden Quarry LWS. We welcome the exclusion of the LWS from the site but would continue to have concerns regarding possible impacts due to pollution and emissions on the important lichen heath community within the LWS. To ensure no impact on the LWS, safeguards should be incorporated within the site policy to ensure no pollution as a result of the washing of aggregates and no nutrients are released as a result of the recycling of domestic waste proposed within the Waste Sites Development Plan Document. If a facility is to be provided as part of the development there may be opportunities to establish a lichen heath green roof to extend the rare habitat on the LWS into the site. Of more concern are the possible impacts on Kent Wildlife the Stodmarsh SPA, SAC, Ramsar and SSSI designations immediately adjacent to the site. In-combination with the waste uses proposed Trust for this site there are risks that the marshes could be polluted due to contaminants entering the water system as a result of the washing of aggregates, deterioration of air quality which could impact on the sensitive flora, and disturbance due to noise on the SPA bird species. We note that noise, air and water quality are identified within the HRA however, it is recommended that impacts should be investigated at the application stage. It is our view that any impacts need to be identified before allocation, with appropriate mitigation measures incorporated into the final site policy. If assessment of impact and mitigation is left until the application stage, KCC cannot guarantee that there will be no impact on the Natura 2000 and Ramsar network as a result of the proposed uses and the plan will not be in conformity with the Conservation of Habitats and Species Regulations 2010.
Environment The proximity of this site to Stodmarsh makes it one that will require further investigation to ensure no adverse effect on the Reserve. Agency 82 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultee Response
Concerned about impacts on European Sites & SSSIs. URS seems content to leave close consideration of the issues until the planning application stage. This appears to be a risky strategy. Allocations should only be made where there is confidence that the land can be Natural successfully developed without compromising the local environment (inter alia). The URS suggestion that there is "no reason to conclude England that risk can't be resolved" uses a double negative, and implies some uncertainty. Allocations should be considered in sufficient detail to allow statements such as "there are no risks", "the potential impacts (namely...) can be resolved by conditions and agreement" etc.
Royal Society for the Immediately adjacent to Stodmarsh SAC, SPA and Ramsar Site. Potential noise/vibration disturbance from recycling operational activity Protection of and associated increased vehicular movements. Potential hydrological impacts from the washing of aggregates - discharge and demand. Birds
Measures needed to minimise noise and air pollution, and to prevent pollution from leaching into the river and major drains (i.e. water General quality). No details available of the likely working hours - assuming even a normal working day, light pollution would be an issue, especially Public (Only 1 during the short days of winter. A28 - the prospect of thousands of HGV movements along this already inadequate road is truly horrendous. Comment Surface water run-off and flooding risk - the consultation document cites “commercial confidentiality” as a reason for not discussing this. Received) This is specious. An open assessment of the likelihood of run-off and its impact should be factored into the consultation. Secondary and Recycled Aggregate Sites 14 Mineral Sites Preferred Options Commentary Report Kent County Council 83 14 This page has been left blank intentionally. eodr n eyldAgeaeSites Aggregate Recycled and Secondary 84 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 91: Animal Products Site, Faversham
Responses for Site 91: Animal Products Site, Faversham
Object 40 The site is proposed for aggregate recycling (construction and demolition waste). The site 48 responses Support 1 is currently non-active but with planning permission for waste uses. Adjoining uses include recycling facilities and restored quarry workings. Comment 7
Consultee Response
Swale Borough Swale BC conditionally has no objection to this site as it will primarily retain its existing use of glass recycling but now include Council construction waste recycling. Furthermore, by making an existing facility permanent this would protect existing jobs.
Faversham Town Faversham Town Council object to the allocation of Site 91. The Members of the Town Council endorse fully the comments that Council have been made by Oare Parish Council.
We object for the following reasons: (1) Noise - crushing CDE waste into aggregate will be extremely noisy inevitably affecting the
Secondary and Recycled Aggregate Sites village to the detriment of villagers and the rural environment; (2) Dust - this will be produced during the crushing of such materials and will affect the locality visually and with unknown health risks to residents; (3) Traffic nuisance - the proposed 40,000 tons at 20
14 tons per lorry means 2000 lorries going in and coming out annually (i.e. 4000 lorry movements in total). This will add to the noise levels heard in Oare, it will make the local roads even more dangerous to cyclists (especially on the Western Link where recently installed traffic islands already push cars and lorries towards the kerb and onto cyclists) and will add to the current load on the A2 where Ospringe is already subject to high pollution levels; (4) Pedestrians - the small road along Oare Creek is also part of the Saxon Oare Parish Shoreway footpath and is a well used route for walkers heading to the creekside. Extra lorry movements will be a hazard; (5) Landscape Council and wildlife (wetland birds and bats) - this site is adjacent to SSSI and Ramsar designated sites and across the creek from a Kent Wildlife Trust reserve adjoining Pheasant Farm. It is also in an area prized for its marshland landscape (featuring in the Faversham Walks guide). The noise and dust of crushing machinery in constant use will detrimentally affect this locality; (6) Oare creek is a marina used by small boats, crushing concrete next door to it will adversely affect that leisure business; (7) KCC did not sufficiently communicate the event on the 18 June in Oare Village Hall to local residents; (8) The name 'Animal Products Site' is misleading and could have caused those residents who were not here during the bone processing time (more than a decade ago) not to realise the location is adjacent Oare Creek. Furthermore, the site is no longer an operating glass recycling facility (incorrectly stated as such in your document) and when it was so used, the level of lorry movements was well below that now proposed. Mineral Sites Preferred Options Commentary Report Kent County Council 85 14 Consultee Response eodr n eyldAgeaeSites Aggregate Recycled and Secondary Gordon I would like to register my objection to Site 91. I believe that if this site is selected the noise and pollution will affect the surrounding Henderson MP area including Oare Creek, which is used for leisure purposes. I am concerned also that the local highway infrastructure would not (Sittingbourne support the increase in traffic, particularly large lorry movements and that these movements would be a hazard for pedestrians and and Sheppey) cyclists alike. I hope that you will reconsider selecting Site 91 as an option and investigate more suitable land available.
KCC Heritage This site should be subject to a programme of archaeological work in advance of development.
There is unlikely to be an individual impact on the Swale SPA from this site due to the open landscape within the area. However, we Kent Wildlife are pleased to note that Site 91 has been scoped into the HRA for noise impacts. We do have concerns that there could be an Trust in-combination impact in respect of loss of supporting habitats and noise when assessed in-combination with Sites 98, 101 and 102.
Royal Society for 100m from Swale SPA and Ramsar Site. Potential noise disturbance impacts if the site was to be used for noisy waste recycling (e.g. the Protection of CDE waste). It should be clarified in the document whether this site is to be used for noisy CDE waste. If so, potential impacts on Birds The Swale SPA/Ramsar would need to be fully assessed.
Brett Aggregates We fully support KCC's allocation of this preferred recycling option. Ltd
We object on the grounds that the access track alongside Oare Creek is totally unsuitable for heavy traffic, both structurally and environmentally. The track is made up of brick rubble placed on the saltings. It was resurfaced several years ago and has only held up due to the lack of heavy traffic since then. The track is a public footpath forming part of the Saxon Shore Way, and it is regularly Youngboats Ltd used by large groups of walkers. Over 100 private pleasure craft are berthed at this part of Oare Creek in the vicinity of the access track. The owners keep them here because of the peace and tranquillity of the area. If this change of use is allowed the access should be diverted to the main route through the quarry as shown in the planning permission granted in 2000 (application no. SW/99/0081).
• Oare Village Hall consultation workshop was not properly advertised prior to the event, nor on the day (i.e. sign outside the hall was hardly noticeable). Many people had no idea it was taking place • Name of site is misleading as it has not been used for bone processing for 15 to 20 years • Crushing equipment would worsen existing noise and pollution issues from current facility and the nearby Gist site • Site already has a bad existing record of being in operation outside permitted hours of working • Dust would be a health and environment hazard to all who live in Oare, both human and wildlife • Access roads are unsuitable for HGVs as they are narrow and in poor condition • Lorry noise would echo around the creek • Additional traffic will worsen road safety and exacerbate congestion, particularly across the Western Link and Oare Road. This will also add to additional traffic generated by the completion General Public of two developments on the former Lakeside Fabrications and Seager Road Foundry sites • Additional HGVs will worsen road safety along the Saxon Shore Way • Full investigation needed to consider the effects of additional traffic on The Swale Ramsar/SPA/SSSI sites before this is allowed to proceed • Adverse affect on natural environment and local wildlife (wetland birds, bats, Little Egrets, kingfishers, Barn Owls) • Disturbance to boating activity on the creek, with disruption to those at Youngboats • Proposal would add nothing to local services/community facilities and provides little in the way of employment opportunities • SEA states that the proposal is unlikely to cause any significant effects as it will continue to operate primarily as a glass recycling facility. This is misleading as the site has actually been proposed for aggregate recycling and the glass recycling plant has not been operational for over a year. 86 Kent County Council Mineral Sites Preferred Options Commentary Report
Site 99: Broomway Ltd, Swanscombe
Responses for Site 99: Broomway Ltd, Swanscombe
Object 1 The site consists of an existing Construction, Demolition and Excavation (CDE) waste processing facility which currently does not have planning permission. The proposal for 4 responses Support 1 the site includes an extension which would enable a fully enclosed waste processing building to be developed. Adjoining uses include a car breakers, recycling facilities and Comment 2 London Road (A20).
Consultee Response
Dartford BC object to Site 99. Dartford Core Strategy Policy CS7 'Employment Land and Jobs' protects existing employment areas, including Manor Way Business Park, for B1, B2, B8 and A2 uses. The proposed use does not comply with this policy. The site lies within the Thames Waterfront Priority Area (Core Strategy Policy CS6 and Diagram 7) which identifies Swanscombe Peninsula as a key development site for mixed-use development including housing. The intensification of the waste processing activities at Manor Dartford Borough Way would be incompatible with this proposed development and is contrary to Dartford's adopted Core Strategy policy for the area. Council The Core Strategy proposals for Swanscombe Peninsula make provision for Environmental Technology uses in an alternative location which is compatible with the proposed development of the rest of that site. It would also enable the transport in and out of materials Secondary and Recycled Aggregate Sites by water. The Mineral Sites Plan Preferred Options Document states that the site is close to a groundwater source protection Zone
14 3. This is wrong as the site lies within the zone. The Strategic Flood Risk Assessment wrongly states that the site is not within groundwater source protection Zone 3. It is unclear whether the impacts of the use on the protection zone have been considered.
This site is situated within the Thameside Green Corridors BOA, the peninsula has been included in the mapping due to its possible national importance for rare invertebrates. We had raised concerns during the Issues and Options stages however, having consulted entomologists familiar with the site, we can confirm that Site 99 does not contain habitat known to be of importance to these species. We therefore do not object to allocation of this site. There are opportunities for this site and Waste Site 107: Land at Lower Road, Kent Wildlife Swanscombe to recreate habitat for invertebrates through green infrastructure and green roofs, and help to deliver BOA target 4. We Trust have discussed the invertebrate issue with Lafarge as part of the Dartford MWDF process and prepared a Statement of Common Ground. There are opportunities to contribute to a landscape scale project for both these sites in cooperation with development proposed within the Dartford MWDF process. We recommend that clauses are written into site policies for both the above sites to increase and extend the habitat for these important species.
Broomway Ltd Support the allocation of the site as a site for secondary and recycled aggregates. Mineral Sites Preferred Options Commentary Report Kent County Council 87 14 Consultee Response eodr n eyldAgeaeSites Aggregate Recycled and Secondary Ace Car Breakers occupy a site immediately to the north of Site 99 identified for the production of secondary and recycled aggregates Ace Car and to the west of Site 107 identified for an energy from waste plant. It is considered that the whole area up to Manor Way to include Breakers the whole of the Ace Car Breakers site should be identified for waste management uses. It would seem to be an ideal site for such uses due to the physical separation from the nearby community of Swanscombe afforded by the quarry face. 88 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 3: Arnolds Lodge Farm West, East Peckham
Object 0 Reasons for not allocating site: This site has been withdrawn by the operator as a permanent planning permission has been granted for the East Peckham mineral importation 1 response Support 1 railhead facility. As part of that permission, the operator has agreed to reduce the amount of land-won aggregates that is extracted from this area with an eventual cessation of Comment 0 extraction of land-won sand and gravel at East Peckham Quarry.
Consultee Response
Kent Wildlife We support the exclusion of Site 3 for further consideration as this will alleviate some of the impact on the important water systems Trust that are present within the area. Site 3: Arnolds Lodge Farm West, East Peckham Mineral Sites Preferred Options Commentary Report Kent County Council 89 ie4 odal am Yalding Farm, Woodfalls 4: Site
Responses for Site 4: Woodfalls Farm, Yalding
Object 0 Reasons for not allocating site: It has been withdrawn by the operator as a permanent planning permission has been granted for the East Peckham mineral importation railhead 3 responses Support 2 facility. The operator has agreed to reduce the amount of land-won aggregates that is Comment 1 extracted from this area with an eventual cessation of extraction at East Peckham Quarry.
Consultee Response
The reasons for not allocating this site are not understood. The need for sharp sand and gravel for the plan period is such that even Kent Downs with a rail head with a permanent planning permission this site should be considered as a future supply for sharp sand and gravel. AONB If there are other constraints on the site (as indicated in the SA) these should be stated as reasons for not progressing this site with the operator.
Kent Wildlife We support the exclusion of Site 4 for further consideration as this will alleviate some of the impact on the important water systems Trust that are present within the area.
CPRE Maidstone Support that the site has been withdrawn from consultations. Wish to make the point that the former minerals site at Stoneham District Quarry, Gravelly Ways Road had never properly been reclaimed. Committee 90 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 5: Filston Lane, Shoreham
Object 0 Reasons for not allocating site: This site lies in the Kent Downs AONB and in the Green Belt. Whilst mineral extraction need not be incompatible with the designation criteria for Support 10 the Green Belt, mineral extraction here is unlikely to meet the 'exceptional circumstances' 11 responses required under the NPPF regarding development in an AONB. There are other proposed Comment 1 sand and gravel sites which are not within the Kent Downs AONB, which are preferable. Also the site is not suitable due to poor highway access from the rural lane network.
Consultee Response
Sevenoaks Support not allocating this site.
Site 5: Filston Lane, Shoreham District Council
KCC Elected Member for Support KCC's decision to categorise this site as 'not allocated' in the Preferred Options consultation. Darent Valley
Kent Downs Support not allocating this site. However, there are many other environmental constraints that should be listed in the reasons for not AONB allocating this site.
Badgers Mount Support - we are pleased to hear that it is not your intention to put Site 5 forward to the next stage of the MWDF on the basis that Residents the site is within a rural village, the area lies within the Kent Downs AONB and is in the Green Belt. Association
Support the decision not to select this site for inclusion in the list of preferred options. As stated, the area lies within the Kent Downs The Shoreham AONB and is in the Green Belt, adjacent to the village of Shoreham, very near the village school. The very limited highway access Society compounds the argument which has properly led to the non-allocation of this proposed site.
Chelsfield Village Support - pleased to see these sites are currently not allocated. Nice to see a public display of the plans. Society
General Public 4 members of the public supported the non-allocation of this site, 1 provided a comment. Full responses available here. Mineral Sites Preferred Options Commentary Report Kent County Council 91 ie7 emtg uryWsel xeso,Aylesford Extension, Westerly Quarry Hermitage 7: Site
Responses for Site 7: Hermitage Quarry Westerly Extension, Aylesford
Object 1 Reasons for not allocating site: The landbank of consented reserves of ragstone is more than sufficient for the plan period; no site allocations for crushed rock sites are necessary. 5 responses Support 3 However, it is acknowledged that there are technical and competition issues with the majority of the crushed rock reserves being held in one large site. These issues will be Comment 1 addressed through a policy in the Core Strategy.
Consultee Response
Object - the reserves at Blaise Farm are of poor quality and are not suitable to provide dressed stone that is needed in the county, Wrotham Parish whereas Site 7 can produce dressed stone but only for about four more years when reserves will be worked out. It will then be Council necessary to import dressed stone from other counties contrary to national guidance.
Support - paragraph 5.1 is based upon information provided by the applicants for Site 7. The question of whether the quality of the material in the reserves at Blaise Farm is inferior in comparison with those proposed at Hermitage Quarry has yet to be tested at the public inquiry and cannot be relied upon at this stage as a basis for the formulation of the site's policy. To effectively formulate future policy, the extent to which the consented Blaise Farm material is able to meet the quality requirements of the demand for crushed Woodland Trust rock aggregates locally needs to be independently quantified. If the quality of the Blaise material is adequate, it would then demonstrate conclusively that there is no need for further reserves to be permitted, which would strengthen the wording of paragraphs 5.5 to 5.7. Whilst the NPPF requires policy formulation to avoid a non-competitive situation arising, this needs to be put in the context that crushed hard rock is used for purposes which are exchangeable with other aggregate sources, both land-won and marine. Accordingly, within the county there are multiple sources of aggregate available, therefore there is no anti-competition issue arising.
The commentary on Site 7 is somewhat incomplete in that “no site allocations for crushed rock sites are necessary” in view of the support of KCC for the release of reserves at the westerly extension site via the planning application process. Again, without prejudice to GAL’s preferred position of securing an allocation in the Mineral Sites Plan, it is suggested that the text accompanying Site 7 should be amended to read: “Reason for not allocating site: KCC have resolved to grant planning permission for the westerly extension site Gallagher 7, and if permitted by the SOS, the development is likely to be implemented in advance of finalising the Mineral Sites Plan. The Aggregates Ltd decision of KCC in this regard was influenced by the need to release additional reserves to ensure continuity of production and to maintain steady and adequate supplies, notwithstanding the arithmetic landbank of permitted reserves. The majority of those reserves are located at another site (Blaise Farm). It is acknowledged that there are technical and competition issues with the majority of the crushed rock reserves being held in one large site (Blaise Farm). These issues will be addressed through a policy in the Core Strategy” (amendments underlined).
General Public 2 members of the public supported the non-allocation of this site. Full responses available here. 92 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 8: Chelsfield Ammunition Depot, Shoreham
Object 0 Reasons for not allocating site: This is in the Green Belt and AONB and is surrounded on three sides by ancient woodland which is also a LWS. The decision notice for an appeal Support 35 into a Sevenoaks Council Lawful Use Certificate for this site has recently been published; 36 responses the appeal was allowed. The inner part of this site therefore has B8 use (storage or distribution uses). However, the use of this site for aggregate recycling would be a change Comment 1 from the lawful use and there are other proposed sites in Kent outside the Green Belt and AONB which are preferable.
Consultee Response
Sevenoaks Support - pleased to note that this site has not been taken forward as an allocation. District Council
KCC Elected Member for Support KCC's decision to categorise this site as 'not allocated' in the Preferred Options consultation. Darent Valley
Kent Downs Support not allocating this site. AONB
Site 8: Chelsfield Ammunition Depot, Shoreham Support the non-allocation of Site 8 because of the potential impact on ancient woodland, resulting in the loss or deterioration of Woodland Trust irreplaceable habitats.
Badgers Mount Support - we are extremely pleased to hear that it is not your intention to put Site 8 forward to the next stage of the MWDF on the Residents basis that the site is within a rural village and not suitable for huge industrialisation of this sort and that the class use of the site (B8) Association is not applicable for waste and mineral recycling.
The Shoreham Support the decision not to select this site for inclusion as a preferred option. Site 8 is in the Green Belt, in an AONB and is surrounded Society by woodland. As stated, there are alternative sites which do not sit in such exceptionally environmentally sensitive areas.
Chelsfield Village Support - pleased to see these sites are currently not allocated. Nice to see a public display of the plans. Society
General Public 28 members of the public supported the non-allocation of this site, 1 provided a comment. Full responses available here. Mineral Sites Preferred Options Commentary Report Kent County Council 93 ie1:Puke od Charing Road, Pluckley 10: Site
Responses for Site 10: Pluckley Road, Charing
Object 1 Reasons for not allocating site: (1) This site is not a preferred option as there are other proposed soft sand sites in the locality which can offer better solutions for the routing of Support 1 lorries to and from the extraction sites onto the A20. The preferred option sites avoid the 2 responses need to route lorries through local villages. (2) The site has been withdrawn from the silica Comment 0 sand sites section of the plan by the operator. There is no technical information available to support its suitability for use for industrial/silica sand requirements.
Consultee Response
Kent Downs Support not allocating this site. AONB
This representation is made on behalf of the landowner, who wishes to object to the non-allocation of Site 10.
This site, together with adjacent mineral bearing land, lies within an Area of Search in the Kent Minerals Local Plan: Construction Aggregates (adopted December 1993) being the current development control document (Note: The relevant policy in the Local Plan is a 'saved' policy in terms of the Planning and Compulsory Purchase Act 2004).
In the Evidence Base for the Mineral Sites Preferred Options Document, comment is made regarding the unsuitability of Site 10 as a preferred option. In paragraph 6.1.10 the constraint for Site 10 is given as being that the "increase in traffic onto Pluckley Road is not acceptable to Kent Highways".
Mr Jonathan This view is challenged by Mr Lam, not least because during the process of consultation with Kent Highways in the run-up to the Lam preparation and submission of a planning application to develop Site 10 (submitted December 2011), Kent Highways agreed that subject to traffic calming measures being undertaken before the junction of Station Road (the northerly continuation of Pluckley Road), there would be no objection to the proposal - in other words Kent Highways were satisfied that the level of traffic associated with the proposal was acceptable contrary to the statement made by KCC in the Evidence Base.
It is therefore submitted that KCC should review its reasoning for the non-allocation of Site 10, take full and proper account of the detailed studies that have been undertaken regarding the suitability of Pluckley Road as a means of accessing Site 10 (details of which will be lodged separately with KCC as part of this consultation) and similarly take account of the views expressed by officers of Kent Highways during pre-planning application discussions held in 2011 when officers were recorded as agreeing that Pluckley Road was an acceptable access for Site 10. Full response available here. 94 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 12: Newington Industrial Estate, Newington
Object 0 Reasons for not allocating site: Area around existing industrial estate site is a greenfield site in part, which should not be developed when there are other suitable brownfield sites Support 2 that can be developed elsewhere in Kent. If the area were reduced just to the boundary of the existing site, an allocation would sterilise it from being developed for industrial uses 3 responses which would not be in the best interest of the Kent economy. However, there is no need Comment 1 to allocate a specific site here as this can be covered by the Core Strategy policy which will identify industrial sites suitable for waste management uses; this would not then preclude this estate from being used for industrial uses.
Consultee Response
It is noted that Newington Industrial Estate has not been designated as an allocated site for secondary and recycled aggregates and W.T. Lamb inert landfill however, the current developed industrial area may have the potential for future waste management use, although not Properties to the extent of sterilising it from being further developed for industrial uses.
General Public 2 members of the public supported the non-allocation of this site. Full responses available here. Site 12: Newington Industrial Estate, Newington Mineral Sites Preferred Options Commentary Report Kent County Council 95 ie1:Bao ilQar,Charing Quarry, Hill Beacon 16: Site
Responses for Site 16: Beacon Hill Quarry, Charing
Object 0 Reasons for not allocating site: It is within the Kent Downs AONB and LWS. The proposed access road onto the A252 would cut through ancient woodland which is also a LWS, Support 2 impact upon adjacent residential properties and impact on two ancient trackways as well as possible manorial boundary markers. An extension to a chalk extraction site in this 2 responses sensitive location is unlikely to meet the NPPF test of 'exceptional circumstances' when Comment 0 alternative sources of chalk exist in the County. There is a potentially significant impact that this proposal will have on springs which are down gradient and domestic abstractions which could be impacted by deterioration in groundwater quality.
Consultee Response
Kent Downs Support not allocating this site. AONB
Support the non-allocation of Site 16 because of the potential impact on ancient woodland, resulting in the loss or deterioration of Woodland Trust irreplaceable habitats. 96 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 25: Ham Farm, Faversham
Object 0 Reasons for not allocating site: It was proposed for an extension to the existing quarry with subsequent infilling with inert waste. However, the sand and gravel deposit underlying 4 responses Support 3 the site was subsequently determined as uneconomic and the operator requested to Comment 1 withdraw the site from consideration.
Consultee Response
Support not allocating this site. This site was originally promoted in the Call for Sites in October 2010. We subsequently carried out trial trenching over this area in order to prove the presence of sand and gravel in support of this proposed allocation. Of the trial pits Brett Aggregates excavated, we only found gravel in 1 out of the 7 pits. All 7 pits were dug to a depth of approximately 4 metres, therefore, it has Ltd
Site 25: Ham Farm, Faversham become apparent that this area is not going to have any value for future mineral extraction. For this reason, we have informed KCC that we are no longer supporting the promotion of Ham Farm.
General Public 2 members of the public supported the non-allocation of this site, 1 provided a comment. Full responses available here. Mineral Sites Preferred Options Commentary Report Kent County Council 97 ie2:Hlosoe Faversham Hollowshore, 26: Site
Responses for Site 26: Hollowshore, Faversham
Object 1 Reasons for not allocating site: It forms a part of the Swale Estuary and Marshes SPA/Ramsar site. Sand and gravel extraction will damage or destroy the Ramsar features 6 responses Support 3 on site and significantly disturb the SPA bird interest. There are alternative sites available. The inclusion of this site as a preferred option would not meet the requirements of the Comment 2 Conservation of Habitats and Species Regulations 2010.
Consultee Response
Object - the aggregates bearing reserve at Hollowshore extends to approximately 25 hectares. The workable mineral deposit is estimated to be 1.15 million tonnes.
Reserves of sand and gravel in this area are in decline and there will be a need for this material during the new plan period. By allowing for an extension to an existing quarry, utilising contiguous sand and gravel reserves, will assist in the continued supply of important mineral to the local market, without the requirement to establish a new sand and gravel processing plant, along with all of the infrastructure and new highway access arrangements that a greenfield site would require. With no allocation of this site, the deposit is unlikely to be worked economically in the foreseeable future, which will result in the loss and potentially permanent sterilisation of a valuable sand and gravel deposit. Brett Aggregates Ltd The reasons for KCC not promoting this site are that it forms part of the Swale Estuary and Marshes SPA/Ramsar site. It is suggested that sand and gravel extraction will damage or destroy the Ramsar features on site and significantly disturb the SPA bird interest. It is also suggested by KCC that the inclusion of this site as a preferred option would not meet the requirements of the Conservation of Habitats and Species Regulations 2010.
We have considered relevant European and UK case law together with guidance issued by the Department for Environment, Food and Rural Affairs (DEFRA) in connection with the Birds and Habitats Directives and we would ask for this site to be reconsidered. Full response available here.
Safeguarding Support - very happy and content to see that Hollowshore and the adjoining farmland will not be worked for minerals or used for Solutions waste disposal. This is a good decision to preserve what is a priceless and renowned landscape and habitat.
General Public 2 members of the public supported the non-allocation of this site, 2 provided comments. Full responses available here. 98 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 45: Dunbrik Depot, Sundridge
Object 0 Reasons for not allocating site: This site is within the Green Belt and AONB and use for 1 response Support 1 aggregate recycling would be a change from the existing use. There are other suitable, better located sites outside the AONB and Green Belt. Comment 0
Consultee Response
Sevenoaks Support - pleased to note that this site has not been taken forward as an allocation. District Council Site 45: Dunbrik Depot, Sundridge Mineral Sites Preferred Options Commentary Report Kent County Council 99 ie5:IhhmSn i etr xeso,Ightham Extension, Western Pit Sand Ightham 50: Site
Responses for Site 50: Ightham Sand Pit Western Extension, Ightham
Object 2 Reasons for not allocating site: This quarry extension is situated within the Kent Downs AONB and part of the site forms a part of a Historic Park and Garden. Quarrying here Support 3 would substantially affect the Park and Garden and adjoining listed building (Ightham Court). Mineral extraction here is unlikely to meet the 'exceptional circumstances' required 5 responses under NPPF. This states that, 'Local Planning Authorities should, as far as is practical, Comment 0 ensure sufficient levels of permitted reserves are available from outside...Areas of Outstanding Natural Beauty...' There are other proposed soft sand sites which are not within the Kent Downs AONB which are preferable.
Consultee Response
Ightham PC object - we request that the Western Extension is allocated for the following reasons: (1) H&H UK is the major employer in Ightham Parish and it is imperative that as such it is able to continue to be commercially viable and that these jobs are protected; (2) At present, H&H UK (Celcon) imports Pulverised Fuel Ash (PFA) by lorry from Kingsnorth Power Station. This coal burning power station is scheduled to close in 2015. To continue the manufacture of aerated concrete blocks at the Ightham site, the firm will need to use sand, the material used throughout all its other European operations, bar one; (3) The sand can either be imported by lorry along the congested A25 through the residential areas of Borough Green, which is environmentally both unsound and unnecessary, or sourced from the proposed adjacent Western Extension; (4) The site sand assets have been “reserved” by the firm for many years Parish Councils to meet this eventuality and the possibility of their extraction in the future accepted; (5) The statement that Site 50 is made up of a Historic Park and Garden is wrong and utterly misleading. Best local knowledge indicates that the trees were removed and the land turned over to agriculture as part of the Second World War effort. This area of land should be re-designated by the appropriate authority as a matter of urgency and the correct current usage recognised; (6) Site 105 is completely sheltered from the existing residential conurbation surrounding Ightham Court by mature woodland dating from circa the mid 1940’s; (7) An appropriate statement of backfilling with inert fill and the site being returned to agriculture on completion of sand abstraction should be included; (8) The community at large has everything to gain from this site being included. Wrotham PC support the non-allocation of Site 50 as it is within the AONB and would have impacted the setting of the listed Ightham Court and its Historic Gardens.
Kent Downs Support not allocating this site. AONB
Peer Spanner Object to the non-allocation of this site for similar reasons to Ightham PC. Full response available here.
General Public We note that Site 50 has not been allocated and are supportive of this decision (only 1 comment received). 100 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 56: Hegdale Quarry, Challock
Object 0 Reasons for not allocating site: It is within the Kent Downs AONB and adjacent to an area of ancient woodland. It has an agreed scheme of working and restoration requiring the Support 2 restoration of the adjacent valley feature removing some 10,000m3 of spoil tipped without 2 responses planning permission. An extension to a chalk extraction site in this sensitive location is Comment 0 unlikely to meet the NPPF test of 'exceptional circumstances' when alternative sources of chalk exist in the County. The site is also sensitive given its proximity to the chalk aquifer.
Consultee Response Site 56: Hegdale, Challock Kent Downs Support not allocating this site and support the need to enforce the agreed scheme of working and restoration and removal of illegally AONB tipped spoil.
Support the non-allocation of Site 56 because of the potential impact on ancient woodland, resulting in the loss or deterioration of Woodland Trust irreplaceable habitats. Mineral Sites Preferred Options Commentary Report Kent County Council 101 ie6:Nwad am Charing Farm, Newlands 62: Site
Responses for Site 62: Newlands Farm, Charing
Object 0 Reasons for not allocating site: (1)There are other proposed soft sand sites in the locality which can offer better solutions for the routing of lorries to and from the extraction site Support 1 onto the A20. The preferred option sites avoid the need to route lorries through local 1 response villages. (2) This site has been withdrawn from the silica sand sites section by the operator. Comment 0 There is no technical information available to support its suitability for use for industrial/silica sand requirements.
Consultee Response
Kent Downs Support not allocating this site. AONB 102 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 69: Burleigh Farm, Charing
Object 0 Reasons for not allocating site: It covers most of the same area as Site 77 (Burleigh Farm & Tile Lodge, Charing) which is a preferred option allocation. The route from the site to 1 response Support 1 the A20 via the existing Charing Quarry entrances using the existing plant and Comment 0 infrastructure, as proposed in site 77, is a better solution than this option.
Consultee Response
Kent Downs Support not allocating this site due to preferable haul route via Site 77. AONB Site 69: Burleigh Farm, Charing Mineral Sites Preferred Options Commentary Report Kent County Council 103 ie7:CaigQar xeso,Charing Extension, Quarry Charing 74: Site
Responses for Site 74: Charing Quarry Extension, Charing
Object 0 Reasons for not allocating site: This small extension to an existing quarry would impact upon important archaeological remains. As it is situated in the garden of a listed building Support 1 it would affect the setting of the building. A stream which feeds into the Great Stour crosses 1 response this site and would have to be diverted. Any benefits in terms of need for this relatively Comment 0 small amount of mineral are not proportionate to the impacts that its extraction would cause.
Consultee Response
Kent Downs Support not allocating this site. AONB 104 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 78: Richborough Limestone Mine, Sandwich
Object 0 Reasons for not allocating site: The landbank of consented reserves for crushed rock is more than sufficient for the plan period; no site allocations for additional crushed rock sites Support 4 are necessary. However, it is acknowledged that there are technical and competition 4 responses issues with the majority of the crushed rock reserves being held in one large ragstone site. These issues will be addressed through a policy in the Core Strategy. A policy Comment 0 supporting the prospecting of this underground limestone resource will also be in the Core Strategy.
Consultee Response
Dover District Support the decision not to allocate the limestone mine but still have outstanding concerns in relation to the policy for the prospecting Council of this underground limestone resource in the Core Strategy.
We accept that the landbank for crushed rock is at its limit for the plan period and we support KCC's acknowledgement that there are technical and competition issues with the majority of the crushed rock reserves being held by one large ragstone site. Indeed, Brett Aggregates bullet point 7, paragraph 145 of the NPPF actively discourages planning authorities from tying up large landbanks in very few sites, Ltd which may stifle competition. We support KCC in recognising that the emerging Core Strategy will address this issue and we fully support a policy that would allow for the prospecting of this underground limestone mine within the Core Strategy.
The representations below are submitted on behalf of our client, BFL Management Ltd, who own the Richborough Power Station, and landfill site and adjacent land to the south of the River Stour. Part of their ownership is covered by Site 78. As currently identified Site 78: Richborough Limestone Mine, Sandwich in the adopted Construction Aggregates Extraction Local Plan (1993) as an area of approximately 492 hectares to the west of the River Stour and a route through the southern portion of the Richborough Power Station site to the A256 and beyond. This designation does not have suitable consideration of the redevelopment potential of the Richborough Power Station site and adjoining land, and Montagu Evans there is the need ensure that any future mineral extraction does not inhibit the ability for development to come forward. We note that LLP Site 78 has not been allocated as part of the Preferred Options consultation and support this approach. We concur with KCC’s view that an allocation is not required, and that crushed rock reserves can be delivered by other sites and through the policies of the Minerals Core Strategy. We support this approach as it will reduce restrictions on the ability of the Richborough Power Station site to come forward for development, unimpeded by this designation. However, we note that there is to be a general policy within the Minerals Core Strategy, and this must be worded in a manner which will not blight the redevelopment of the site.
Support - area is designated as a LWS. Mining would cause substantial subsidence and flooding. Flooding already occurs in the General Public area during heavy rain periods. Farmers are reliant on the ditch and dike systems, which will disappear if this plan is approved (only 1 comment received). Mineral Sites Preferred Options Commentary Report Kent County Council 105 ie8:FvrhmQar,Faversham Quarry, Faversham 80: Site
Responses for Site 80: Faversham Quarry, Faversham
Object 0 Reasons for not allocating site: It has an approved restoration scheme and does not justify 2 responses Support 2 permanent development as it is effectively a greenfield site which should not be developed whilst there are suitable, deliverable brownfield sites elsewhere in Kent. Comment 0
Consultee Response
• I fully support this decision. The site adjoins environmentally sensitive and SPA/Ramsar areas, and noise from the site is a General Public disturbance to those visiting this unspoilt area • As all the Faversham/Oare sites have been removed I have nothing further to add; except for the very general statement that the natural environment should be enhanced, not destroyed. 106 Kent County Council Mineral Sites Preferred Options Commentary Report
Responses for Site 86: Charing Quarry (Waste 2), Charing
Object 1 Reasons for not allocating site: It has an approved restoration scheme and does not justify 2 responses Support 1 permanent development as it is effectively a greenfield site which should not be developed whilst there are suitable, deliverable brownfield sites elsewhere in Kent. Comment 0
Consultee Response
Kent Downs Support not allocating this site. AONB
Object
We asked that this be a permanent facility in KCC's original Call for Sites in October 2010. As this site has a restoration scheme, KCC have not allocated this as they do not agree that it should be permanent, as it is effectively a greenfield site.
May we therefore suggest that this site be allocated as a temporary site for construction and demolition waste recycling, which is a Brett Aggregates complimentary activity to the landfilling activity? Having both landfilling and recycling activities operating at the same location also Ltd
Site 86: Charing Quarry (Waste 2), Charing makes the site more attractive to customers, as they only have to make one journey with full loads of waste that can and cannot be recycled.
This will encourage a speedier restoration timetable site making this a very viable and logical operation to have located in this part of Kent, serving the Maidstone market, the life of which can be tied to the working and restoration of Burleigh Farm (Site 77). Mineral Sites Preferred Options Commentary Report Kent County Council 107 N epne Sites Response' 'No Sites for which no response was received
Site 52: Weatherlees, Minster (not allocated)
Site 73: Lydd Quarry Extension - Allen's Bank (Area E), Lydd (not allocated)
Site 79: Tilmanstone, Eythorne (not allocated)
Site 81: Milton Manor Farm, Chartham (not allocated)
Site 92: Land at Bax Farm, Tonge (not allocated)
Site 100: Double Quick Farm, Charing (not allocated) 108 Kent County Council Mineral Sites Preferred Options Commentary Report
Consultation Response Rates
Mineral Sites Development Plan Options Consultation
The following table lists the 10 most responded-to sites for the Mineral Sites Development Plan Options consultation which invited
Appendix 1 members of the public, industry stakeholders and statutory bodies to submit their views on the sites outlined in the Mineral Sites Development Plan Document(3).
Table 2. The 10 most responded-to sites for the Mineral Sites Development Plan Options consultation (31 May – 9 August 2011).
Site Total responses
8: Chelsfield Ammunition Depot, Shoreham (not allocated) 166
5: Filston Lane, Shoreham (not allocated) 141
76: Chapel Farm, Lenham* 139
75: Boltons Field, Lenham Heath* 109
7: Hermitage Quarry Westerly Extension, Aylesford (not allocated) 108
62: Newlands Farm, Charing** (not allocated) 102
10: Pluckley Road, Charing** (not allocated) 100
69: Burleigh Farm, Charing** (not allocated) 90
86: Charing Quarry (Waste 2), Charing** (not allocated) 90
77: Burleigh Farm & Tile Lodge, Charing** 86
* A petition objecting to this site was also received containing 77 signatures
** A petition objecting to this site was also received containing 201 signatures
3 Available at http://consult.kent.gov.uk/portal/min-dpd/min-options?pointId=1823889 Mineral Sites Preferred Options Commentary Report Kent County Council 109 pedx1 Appendix
Mineral Sites Preferred Options Consultation
The following table lists the 10 most responded-to sites for the Mineral Sites Preferred Options consultation which invited members of the public, industry stakeholders and statutory bodies to submit their views on the sites outlined in the Mineral Sites Preferred Options Document(4).
Table 3. The 10 most responded-to sites for the Mineral Sites Preferred Options consultation (28 May – 23 July 2012).
Site Total responses
19: Paradise Farm, Hartlip and Newington* 61
77: Burleigh Farm & Tile Lodge, Charing 56
91: Animals Products Site, Faversham 48
101: Barbary Farm, Norton Ash 41
8: Chelsfield Ammunition Depot, Shoreham (not allocated) 36
75: Boltons Field, Lenham Heath** 32
97: Shrine Farm, Postling 32
102: Barrow Green Farm, Teynham 32
76: Chapel Farm, Lenham** 28
73: Lydd Quarry Extensions (A - D), Lydd 17
* A petition objecting to this site was also received containing 92 signatures
** A petition objecting to this site was also received containing 463 signatures
4 Available at http://consult.kent.gov.uk/portal/min-dpd/min_pref-options?pointId=2189750 110 Kent County Council Mineral Sites Preferred Options Commentary Report
Change in Response Rates for Allocated Sites
The following table details how response rates have changed for mineral proposals which have remained as options within both the Mineral Sites Development Plan Document and Mineral Sites Preferred Options Document.
Appendix 1 Table 4. Difference in response rates for the 25 mineral proposals which are preferred option sites.
Responses Responses (Mineral Sites (Mineral Sites Change in Site Development Plan Options Preferred Options response rate consultation) consultation)
Site 6: Land Adjacent to Platt Industrial Site, Platt 16 12 - 4
Site 24: Land North of Addington Lane, Trottiscliffe (Soft Sand) 9 5 - 4
Site 75: Boltons Field, Lenham Heath 109 32 - 77
Site 76: Chapel Farm, Lenham 139 28 - 111
Site 77: Burleigh Farm & Tile Lodge, Charing 86 56 - 30
Site 97: Shrine Farm, Postling 11 32 + 21
12 Site 105: Borough Green Sand Pits Extension, Wrotham (added during Supplementary Options 8 - 4 Consultation)
Site 2: Beltring Green Farm, East Peckham 5 4 - 1
Site 17: Moat Farm, Capel 9 7 - 2
Site 49: Land Adjacent to Hammer Dyke, Capel 12 7 - 5
Site 71: Stonecastle Farm, Whetsted 9 10 + 1
Site 73: Lydd Quarry Extensions (Areas A - D), Lydd 19 17 - 2
Site 24: Land North of Addington Lane, Trottiscliffe (Silica Sand) 5 3 - 2
Site 63: Pinden Quarry Extension, Dartford 9 13 + 4 Mineral Sites Preferred Options Commentary Report Kent County Council 111 pedx1 Appendix Responses Responses (Mineral Sites (Mineral Sites Change in Site Development Plan Options Preferred Options response rate consultation) consultation)
Site 19: Paradise Farm, Hartlip and Newington 47 61 + 14
12 Site 98: Jefferies Site, Teynham (added during Supplementary Options 8 - 4 Consultation)
22 Site 101: Barbary Farm, Norton Ash (added during Supplementary Options 41 + 19 Consultation)
22 Site 102: Barrow Green Farm, Teynham (added during Supplementary Options 32 + 10 Consultation)
Site 60: Norwood Quarry and Landfill Extension, Minster 3 8 + 5
Site 1: East Peckham Rail Depot, East Peckham 6 3 - 3
Site 21: F M Conway Rochester Way, Dartford 3 4 + 1
Site 65: Land North of Stevens & Carlotti, Richborough 11 6 - 5
Site 72: Unit 14, Canterbury Industrial Estate, Hersden 7 11 + 4
Site 91: Animal Products Site, Faversham 5 48 + 43
6 Site 99: Broomway Ltd, Swanscombe (added during Supplementary Options 4 - 2 Consultation) 112 Kent County Council Mineral Sites Preferred Options Commentary Report
A
Aggregate Inert particulate matter which is suitable for use (on its own or with the addition of cement or bituminous material) in construction as concrete, mortar, finishes, road stone, asphalt, or drainage course, or for use Glossary as constructional fill or railway ballast.
Aggregates/Soils Rubble, hardcore and soil from construction and demolition projects can often be re-used on-site. Recycling Alternatively, it can be taken to purpose built facilities for crushing, screening and re-sale. There are also temporary facilities at some quarries landfill sites where material can be recovered for re-sale or use on site.
Amenity Elements that contribute to the overall character or enjoyment of an area.
Appropriate As assessment of whether a development proposal ‘either alone or in combination with other proposed Assessment sites’ would have a significant, adverse effect on the integrity of a European site against the site's conservation objectives.
B
Biodiversity The variety of all life on earth (such as mammals, birds, fish, invertebrates, plants).
Brownfield Site Site previously used for or affected by development. It may be abandoned or in a derelict condition.
C
Commercial waste Waste from premises used mainly for trade, business, sport, recreation or entertainment, as defined under section 5.75 (7) of the 1990 Environmental Protection Act. May include paper, card, plastic, glass timber, metal, paints, textiles, chemicals, oils and food waste.
Composting The breakdown of plant matter by the action of micro-organisms and other organisms into usable end-products. It is an important method of processing organic waste because it reduces the amount of potentially polluting waste going to landfill or incineration.
Construction waste Waste arising from any development such as vegetation and soils from land clearance, remainder materials and off-cuts from building sites, road schemes and landscaping projects. Mostly consists of stone, concrete, (Also see Demolition rubble and soils but may include some timber, metal and glass. Waste) Mineral Sites Preferred Options Commentary Report Kent County Council 113 Glossary D
Demolition waste Masonry and rubble wastes arising from the demolition or reconstruction of buildings or other civil engineering structures. (Also see Construction Waste)
Dene-hole Underground structure consisting of a number of small chalk caves entered by a vertical shaft.
Development Portfolio of planning documents. Collective term for key Plans, the Local Development Scheme, the Framework Statement of Community Involvement, Annual Monitoring Report and any supplementary planning documents.
E
Energy from Waste Generation of heat and power from burning waste, the production of fuels from other forms of treatment, (EfW) and the combustion of landfill gas and gas from anaerobic digestion to create electricity.
European Sites The collective term for Special Areas of Conservation (SACs) and Special Protection Area (SPAs) designations that comprise the Natura 2000 pan-European network.
European Protected Species listed in Annex IV of the EU Habitats Directive, transposed into UK law by The Conservation of Species Habitats and Species Regulations 2010.
Examination in Public All Plans will be subject to an independent examination before a planning inspector. The inspector's report (EiP) is binding on the local authority. 114 Kent County Council Mineral Sites Preferred Options Commentary Report
F
Flood Zones The Environment Agency produces a flood map showing areas where there is the potential to flood. There are four different Flood Zones; Flood Zone 1, 2, 3a and 3b. These show the scale of the probability of Glossary flooding. Flood Zone 1 has a low probability of flooding (less than 1 in 1,000 annual probability of flooding) increasing up to Flood Zone 3b, which has a high probability (1 in 20 or greater annual probability of flooding).
G
Groundwater Source Groundwater source catchments designated by the Environment Agency to protect groundwater from Protection Zones contamination. Divided into Zones 1, 2, 3 and 4 depending on distance from the extraction point.
H
Habitat Regulation Assessment required under European Legislation (Habitat Regulations, 1992) to determine whether a plan, Assessment (HRA) either alone or in combination with other relevant projects and plans, is likely to result in a significant effect upon European sites. Where is significant effect cannot be ruled out in the initial stages of plan making, a subsequent stage of the HRA known as Appropriate Assessment will be required.
Hazardous waste Controlled waste that is dangerous or difficult to treat, keep, store or dispose of, so that special provision is required for dealing with it. Hazardous wastes are the most dangerous wastes and include toxic wastes such as ; acids, alkaline solutions, asbestos, fluorescent tubes, batteries, oil, fly ash, industrial solvents, oily sludges, pesticides, pharmaceutical compounds, photographic chemicals, waste oils and wood preservatives. If improperly handled, treated or disposed of, a waste that, by virtue of its composition, carries the risk of death, injury or impairment of health, to humans or animals, the pollution of waters, or could have an unacceptable environmental impact.
I
Industrial waste Waste from any of the following premises: factory; provision of transport services (land, water and air); purpose of connection of the supply of gas, water, electricity, provision of sewerage services, provision of postal or telecommunication services.
Inert waste Waste which will not biodegrade or decompose. Types of materials include uncontaminated topsoil, subsoil, clay, sand, brickwork, stone, silica and glass. Mineral Sites Preferred Options Commentary Report Kent County Council 115 Glossary L
Landfill The deposition of waste onto hollow or void space in the land, usually below the level of the surrounding land or original ground level in such a way that pollution or harm to the environment is prevented. Former mineral workings have historically been used for this purpose.
Local Protected Species designated in the 2007 Biodiversity Action Plan (BAP) list; birds designated as Red or Amber in Species the Birds of Conservation Concern 3 listing; species listed in the Kent Red Data Book.
M
Mineral Resource A concentration or occurrence of material of intrinsic economic interest in or on the Earth's crust in such a form, quality and quantity that they are reasonable prospects for eventual economic extraction.
'Mothballed' Sites that are currently inactive.
N
National Nature Areas designated with the aim of securing protection and appropriate management of the most important Reserve (NNR) areas of wildlife habitat, and to provide a resource for scientific research.These Reserves are a selection of the very best parts of England’s Sites of Special Scientific Interest (SSSI) as designated by Natural England.
R
Ramsar Sites Sites of international importance to birds which inhabit wetlands. Ramsar is the name of the place where the Wetlands Convention was signed.
Recycled aggregates Aggregates produced from recycled construction waste such as crushed concrete and planings from road surfacing.
Recycling The collection and separation of materials from waste and subsequent processing to produce new marketable products.
Restoration Operations to return an area to an acceptable environmental state, whether for the resumption of the former land use or for a new use following mineral working. 116 Kent County Council Mineral Sites Preferred Options Commentary Report
S
Safeguarding Protecting sites that have potential for relevant development (waste and minerals) from other development.
Glossary Sharp Sand and Naturally occurring mineral deposit in Kent. Once extracted it is mainly used in the production of concrete Gravel products.
Sites of Special Sites designated by Natural England for their flora, fauna, geological or physiographical features of special Scientific Interest interest under the Wildlife and Countryside Act 1981 (amended 1985). (SSSIs)
Site Allocations Sites which are generally well defined and where there is an implied presumption in favour of their being developed during the plan period
Strategic An evaluation process for assessing the environmental impacts of plans and programmes as set out in the Environmental Environmental Assessment of Plans and Programmes Regulations 2004. Assessment
Strategic Site A key site of importance for minerals or waste uses, potentially of county-wide significance.
Submission A stage of the plan preparation process where the document is 'submitted' to the Secretary of State for independent examination by a planning inspector. The document is first published for public consultation prior to submission.
Sustainability An evaluation process that systematically identifies and evaluates the economic, social and environmental Appraisal (SA) impacts of a plan. It incorporates the requirements of a Strategic Environmental Assessment.
Sustainability A widely quoted definition of sustainable development is “development that meets the needs of the present without compromising the ability of future generations to meet their own needs”. Sustainability seeks to balance social, economic and environment issues including the efficient use of natural resources. Mineral Sites Preferred Options Commentary Report Kent County Council 117 Glossary U
UK Protected Animals and plants protected under the Protection of Badgers Act 1992 and the Wildlife and Countryside Species Act 1981.
W
Waste The Town and Country Planning Act 1990 has been amended so there is no dispute over whether 'waste', in terms of the planning regime, is defined in accordance with European law. It states that: "Waste" includes anything that is waste for the purposes of Directive 2006/12/EC of the European Parliament and of the Council on waste, and that is not excluded from the scope of that Directive by Article 2(1) of that Directive". Waste is therefore defined as any substance or object which the holder or the possessor either discards or intends or is required to discard(5).
Waste Recovery The collection, reclamation and separation of materials from the waste stream.
Waste Transfer Facilities which receive waste (normally from a local area), where the waste is bulked up and transported further afield in larger lorries (or in some cities by barges) for disposal or recovery. Some transfer stations sort out the recoverable wastes, such as construction waste and scrap metal prior to onward transportation for disposal or processing.
5 This definition is inserted into s.336(1) of the TCPA 1990, as part of the consequential amendments made by the Environmental Permitting (England and Wales) Regulations 2007 SI 2007/3528 (the "EPR 2007"), as from 6 April 2008. See Schedule 21, para. 19 of the EPR 2007 (and its commencement - see reg.1) This document is available in alternative formats and can be explained in a range of languages.
Please call 01622 221609 or email [email protected] for details.
Produced by: Planning and Environment Environment and Enterprise Tel: 01622 696815 Kent County Council Email: [email protected] Invicta House, County Hall Web: www.kent.gov.uk/mwdf Maidstone, Kent ME14 1XX Textphone: 08458 247 905