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MINERAL RESOURCE ASSESSMENT, PRESTON FIELDS (SOUTH), SALTERS LANE, For PRESTON FIELD LAND TRUSTEES

February 2021

GWP Consultants LLP Registered No. OC326183 Registered Office: Upton House, Market Street, Charlbury, Oxfordshire, OX7 3PJ, UK

Report Title: Mineral Resource Assessment, Preston Fields (South), Salters Lane, Faversham Client: Preston Field Land Trustees

Job: PRESFLD Report Number: 201112 Version: v.02 Issue Status: Final Prepared by: Dr Isobel Brown Issue Date: 4th February 2021

Issue History: Issue Date Description Admin Technical Approver No Review Review Dr Alan Dr Alan v.01 02.12.20 Draft Report issued to Client CL Cobb Cobb Dr Alan Dr Alan v.02 04.02.21 Final Report issued CL Cobb Cobb

Approver Signature:

Dr Alan E Cobb Chief Geotechnical Engineer BSc PhD MIMMM CEng FGS

This document is based on GWP report template v.1.08 and Normal template v3.10 17/04/19

This report has been prepared by GWP Consultants LLP (GWP) on the specific instructions of our Client. It is solely for our Client’s use for the purpose for which it is intended in accordance with the agreed scope of work. Any use or reliance by any person contrary to the above, to which GWP has not given its prior written consent, is at that person’s own risk and may be an infringement of GWP’s copyright. Furthermore the report is issued on the understanding that GWP’s general terms and conditions of engagement are accepted, copies of which are available on request.

CONTENTS

1. INTRODUCTION ...... 1 1.1 Background ...... 1 1.2 Scope of report ...... 1 2. INFORMATION SOURCES ...... 1 2.1 Geology and survey...... 1 2.2 Site specific reports ...... 2 2.3 Reports concerning adjacent development land ...... 2 2.4 Brickearth extraction ...... 2 2.5 Planning and Policy ...... 2 2.5.1 Minerals ...... 2 2.5.2 Local planning ...... 2 2.6 Other ...... 3 3. PLANNING CONTEXT ...... 3 3.1 National Planning Policy Framework (NPPF) ...... 3 3.2 Mineral and Waste Local Plan 2013-2030 (Early Partial Review) ...... 3 3.3 Swale Borough Council: Local Plan ...... 4 3.3.1 Local Plan Adopted 2017 ...... 4 3.3.2 Swale Housing Delivery Test Action Plan August 2019 ...... 5 3.3.3 Local Plan Review ...... 5 4. THE DEVELOPMENT SITE ...... 5 4.1 Location ...... 5 4.2 Topography ...... 5 4.3 Mineral safeguarding ...... 6 4.4 Constraints ...... 6 4.5 Proposed development ...... 6 5. GEOLOGY AND SAFEGUARDED MINERAL ...... 6 5.1 Regional geology ...... 6 5.1.1 Bedrock ...... 6 5.1.2 Superficial deposits ...... 6 5.2 Extent of Brickearth Deposits ...... 6 5.2.1 Current permitted reserves ...... 7 5.2.2 Mineral Sites Plan 2012 – Mineral Sites Preferred Options Consultation ...... 7 6. RESOURCE ASSESSMENT ...... 7 6.1 Geology ...... 7 6.2 Evidence for the extent, thickness and quality of brickearth ...... 7 6.3 Evidence for prior brickearth excavation within the site ...... 8 6.3.1 Historic maps ...... 8 6.3.2 Ground levels ...... 8 6.3.3 Estimated thickness of remaining brickearth ...... 8 6.4 Resource estimate...... 8 6.4.1 Margins ...... 8 6.4.2 Thickness of brickearth ...... 9 6.4.3 Quantities ...... 9 6.4.4 Quality ...... 9 6.5 Prior extraction ...... 9 6.6 Use of excavation arisings within the development ...... 10

Mineral Resource Assessment Preston Fields Preston Field Land Trustees 201112 v.02 04/02/21 i

6.7 Economic assessment ...... 10 6.7.1 Benefits ...... 10 6.7.2 Costs ...... 10 6.8 Potential for sterilization of mineral outside site boundary ...... 10 7. CONCLUSIONS ...... 10

TABLES

Table 1 Estimated quantities of recoverable brickearth

DRAWINGS

Drawing Number Drawing Title Version

PRESFLD2011-1 Site location and planning context b PRESFLD2011-2 Topography b PRESFLD2011-3 Geological setting (superficials) b PRESFLD2011-4 Geological setting (bedrock) b PRESFLD2011-5 Topographic evidence of prior working of the site b PRESFLD2011-6 Constraints and resource areas assessed b

APPENDICES

Appendix 1 Relevant Borehole Logs Appendix 2 Proposed development layout

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MINERAL RESOURCE ASSESSMENT, PRESTON FIELDS (SOUTH), SALTERS LANE, FAVERSHAM

1. INTRODUCTION 1.1 Background Preston Field Land Trustees has instructed GWP Consultants LLP (GWP) to carry out a mineral resource assessment (MRA) for land at Preston Fields (South), Salters Lane, Faversham, Kent. Preston Field Land Trustees are seeking planning permission for a development of 70 residential homes on land which lies within a mineral safeguarding area for brickearth identified in the Policy CSM5 of the Kent Mineral and Waste Local Plan 2013-2030 (adopted 2020) and in the accompanying Mineral Safeguarding Map for Swale Borough Council. The proposals do not constitute Development Exempt from Mineral Safeguarding as set out in Clauses 4, 6 and 7 of Policy DM7 of the KMWLP. This report has been prepared in order to demonstrate that one of relevant Clauses 1, 2, 3 and 5 of Policy DM7 does apply. 1.2 Scope of report This assessment comprises a desk study which broadly follows guidance for such a report in the Safeguarding Supplementary Planning Document adopted by Kent County Council in April 2017 and Mineral Safeguarding Practice Guidance jointly published by the Mineral Products Association and the Planning Officers Society. After a review of information available it was concluded that the site did not warrant the expense of intrusive site investigation. Accordingly the assessment covers the following matters:  Description of the proposal site;  Local geology;  The potential mineral quality and extent;  An assessment of the constraints to mineral development;  An estimate of the mineral resource (quantity) affected by the development;  Consideration of markets;  The effect of prior extraction on the deliverability, design, programming, and viability of the proposed non-mineral development;  Environmental impact of prior extraction;  Potential sterilization of another mineral by the development;  Concluding statement.

2. INFORMATION SOURCES The following information sources have been used to carry out this mineral assessment: 2.1 Geology and survey  2m DTM lidar survey available from data.gov.uk.  Site level survey carried out by RL Surveys in July 2016.  Holmes, S. C.A. 1981 Geology of the Country around Faversham. Mem. Geol. Surv. G.B, Sheet 273. 117p.  Geology of Britain Viewer (bgs.ac.uk).  BGS borehole database (bgs.ac.uk). Relevant borehole logs are included in Appendix 1.  Google Earth Aerial Images 1940-2019.  Ordnance Survey historical maps available for viewing at https://maps.nls.uk/os/ and reproduced in the Heritage assessment by Orion Heritage Ltd.

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2.2 Site specific reports  Land at Preston Fields, Faversham, Kent. Heritage desk-based assessment Orion Heritage Ltd. October 2020.  Report on the agricultural significance of some 33 acres (13.2ha) at Preston Fields, Faversham, Kent. Furneaux & Co. and Land Management Consultant. 1996 For Faversham Borough Council Local Plan.  FPCR Environmental and Design Ltd. Drawing No. 7391-L-08_A-02 Capacity Sketch Dated 22 January 2021 for Preston Field Land Trustees, Land at Preston Fields-South, Canterbury Road, Faversham. Included as Appendix 2. 2.3 Reports concerning adjacent development land  Minerals Assessment, Erection of up to 250 dwellings with all matters reserved except for access, Preston Fields, Faversham. August 2017. How Planning LLP for Preston Field Land Trustees.  Factual Report in Support of a Mineral Resource Assessment at land off Ashford Road, Faversham, Kent ME13 8XW. Leap Environmental Ltd. Report Ref. LP1510/MRA 21st December 2017.  Factual Report in Support of a Mineral Resource Assessment at land adjacent to Perry Court Farm, Faversham, Kent ME13 8XW. Leap Environmental Ltd. Report Ref. LP2049/MRA 11th October 2019. 2.4 Brickearth extraction  Variation of conditions 1 and 3 of planning permission SW/03/430 to extend the period of working and final restoration at the existing Hempstead House brickearth site until 31 October 2020 at land to the south of the A2 and East of Panteny Lane, Bapchild, Sittingbourne – SW/13/939 (KCC/SW/0227/2013)  Phased extraction of brickearth, advance planting, access improvements, restoration and replanting back to agricultural use at Paradise Farm, Lower Hartlip Road, Hartlip, Sittingbourne, Kent – SW/16/507594 (KCC/SW/0277/2016) 2.5 Planning and Policy 2.5.1 Minerals  Kent Minerals and Waste Local Plan 2013-2030 –Adopted September 2020 (as amended by Early Partial Review).  Kent Minerals and Waste Local Plan 2013-2030 Mineral Sites Plan. Kent County Council Adopted September 2020.  13th Annual Minerals and Waste Monitoring Report 1st April 2018 to 31st March 2019. Kent County Council May 2020.  Kent County Council Safeguarding Supplementary Planning Document Adopted April 2017.  Kent Mineral and Waste Local Plan 2013-30 Adopted July 2016.  Kent Minerals and Waste Development Framework Evidence Base for the minerals and Waste Core Strategy. Strategy and Policy Directions Consultation. Minerals Topic Report 3: Other Minerals. May 2011. 2.5.2 Local planning All documents are available from swale.go.uk  Bearing Fruits 2031: The Swale Borough Local Plan Adopted July 2017.  Swale Housing Delivery Test Action Plan August 2019.  Swale Borough Council Local Development Scheme March 2020-2023.  Local Plan Review – site selection steer for housing and employment land allocations. 29 October 2020. LPR

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2.6 Other  Mineral Safeguarding Practice Guidance. Mineral Products Association and the Planning Officers Society v 1.4 April 2019. Available at Mineralproducts.org.

3. PLANNING CONTEXT 3.1 National Planning Policy Framework (NPPF) The NPPF seeks to avoid the sterilisation of minerals resources and Paragraph 143 provides that local planning authorities should set out policies to encourage the prior extraction of minerals where practical and environmentally feasible if it is necessary for non-minerals development to take place. The NPPF provides at Paragraph 146 that Minerals Planning Authorities should provide for a steady and adequate supply of industrial minerals. More specifically, there are requirements to maintain reserves for specific minerals. The NPFF does not specifically include brickearth, however the Inspector’s report on the examination of the KMWLP 26 April 2016 stated ‘Brickearth is not a mineral identified in the NPPF as requiring a stock of permitted reserves to be provided. However, it is analogous to brick clay, for which 25 years reserves are required to be maintained. It is reasonable that the same landbank should be maintained for brickearth’. 3.2 Kent Mineral and Waste Local Plan 2013-2030 (Early Partial Review) The KMWLP Early Partial Review was adopted in September 2020. Policies relevant to Preston Fields (South) are Policy CSM 2 and DM7. Policy CSM 2 Supply of Land-won Minerals in Kent The KMWLP (September 2020) provides an assessment of the current reserves of land won mineral in the county against the requirements over the plan period. No non-permitted sites for brickearth extraction were identified in Policy CSM2 or the accompanying Mineral Sites Plan also adopted in September 2020. Policy CSM 2 states:

2. Brickearth and Clay for Brick and Tile Manufacture The stock of existing planning permissions at Paradise Farm, Orchard Farm, Hempstead House and Claxfield Road for brickearth clay for brick and tile making is sufficient for the plan period. Applications for sites supplying brickearth and clay for brick and tile making will be dealt within in accordance with the policies of this Plan. The existence of a stock of permitted reserves of at least 25 years (as reported in the latest Annual Monitoring report) to support the level of actual and proposed investment required for new or existing plant and the maintenance and improvement of existing plant and equipment will be a material consideration.

The permitted reserves, supplying Wienerberger’s Smeed works, have an estimated life of less than 25 years (reported as 21-22 years in the KCC 2018-2019 monitoring report).

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Policy DM7 Safeguarding Mineral Resources Mineral safeguarding areas Map for the Borough of Swale is included in the KMWLP (Adopted September 2020). The site, Preston Fields (South) is largely within the safeguarding area for brickearth. KCC have adopted revised criteria against which to assess development sites that are located within mineral safeguarding areas. These are set out in Policy DM 7.

POLICY DM7 Planning permission will only be granted for non-mineral development that is incompatible with minerals safeguarding where it is demonstrated that either:

1. the mineral is not of economic value or does not exist; or 2. that extraction of the mineral would not be viable or practicable; or 3. the mineral can be extracted satisfactorily, having regard to Policy DM9, prior to the non- minerals development taking place without adversely affecting the viability or deliverability of the non-minerals development; or 4. the incompatible development is of a temporary nature that can be completed and the site returned to a condition that does not prevent mineral extraction within the timescale that the mineral is likely to be needed; or 5. material considerations indicate that the need for the development overrides the presumption for mineral safeguarding such that sterilisation of the mineral can be permitted following the exploration of opportunities for prior extraction; or 6. it constitutes development that is exempt from mineral safeguarding policy, namely householder applications, infill development of a minor nature in existing built up areas, advertisement applications, reserved matters applications, minor extensions and changes of use of buildings, minor works, non-material amendments to current planning permissions; or 7. it constitutes development on a site allocated in the adopted development plan where consideration of the above factors (1-6) concluded that mineral resources will not be needlessly sterilised.

3.3 Swale Borough Council: Local Plan 3.3.1 Local Plan Adopted 2017 The current Local Plan covers the period 2020 to 2023. To meet the target of 13,192 new homes by 2031 the plan identified two development areas south of Faversham between the A2 and the M2 located east and west of Ashford Road – the main route into Faversham from the M2 (Sites 1 and 2 on Drawing No. PRESFLD2011-1). Policy A16 Land at Preston Fields, Faversham – 217 dwellings. Policy MU 7 Perry Court Farm, Faversham 370 dwellings and 18,525m3 office/industrial space. The position of Swale Borough Council (SBC) on minerals was set out in Section 4.1 of the Local Plan.

Facilitating the sustainable use of minerals and waste 4.1.65 In the event that reserves are identified on sites allocated for development by this Local Plan, we will ensure that the developer works with the Minerals Planning Authority to ensure the timely working of the site, provided that there is a sustainable and viable outlet for the resource which allows extraction without an unreasonable impact on development coming forward in line with the safeguarding minerals and prior extraction policies contained in the Kent Minerals and Waste Local Plan.

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3.3.2 Swale Housing Delivery Test Action Plan August 2019 The housing Land Supply Statement dated February 2019 identified that housing delivery was not meeting the targets of the local plan. SBC carried out an analysis of the reasons for this. SBC observe that the impact that removal of brickearth prior to development will have on timing of development is uncertain but recognise that there may be solutions such that the sites contributing to the 5 year supply will not be delayed. Referring to KMWLP partial review which at the time had not been adopted, and specifically on prior extraction of brickearth, SBC commented; ‘If the resource cannot be economically extracted to allow for timely delivery of non-minerals development, this is a significant issue going forward’. 3.3.3 Local Plan Review The Local Plan will cover the period 2022 to 2038 and set out the framework for meeting the development needs for the Borough. The timetable for the review is set out in the document Local Development Scheme 2020-2023. The identified housing need for the period 2022 to 2038 is 1,038 per year. The preferred approach agreed in July 2020 identified that 3,500 homes should be planned for Faversham. There is a clear need to identify strategic sites for housing development and associated infrastructure in order to accommodate this scale of increase. The option strongly promoted by SBC is an extension of Faversham to include virtually all land between the M2 and A2 east of Preston Fields. The areas are shown on Drawing No. PRESFLD2011-1. Preston Fields (South), which was originally intended to form a green buffer against the M2, is now assessed as ‘suitable and deliverable’ for housing and provides an opportunity for a critical road link through the site to the proposed new development areas to the east. The commentary for the site (Ref 18/178) states ‘Provided that a revised allocation includes design and landscape parameters to support a landscape buffer along the boundary of the M2, this section of the site should be allocated for housing through the LPR process.’ The delivery of Preston Fields (South) is therefore a critical element of the proposed expansion of Faversham to the south.

4. THE DEVELOPMENT SITE 4.1 Location The site location is shown on Drawing No. PRESFLD2011-1. The site occupies an area of c. 4 hectares immediately north of Junction 6 of the M2 and less than 1km south of central Faversham. Salters Lane lies on the eastern boundary of the site, rising up on an embankment to cross the M2 at the southeast corner of the site. To the north lies the Preston Fields development site with outline planning for 250 homes. Access to the site is from Ashford Road to the west via a 200m long track. The western boundary abuts the former Preston Nursery site and low density residential properties along Ashford Road. The M2 cutting and embankment mark the southern boundary of the site. The majority of the site is open arable farmland. An access road from Salters Lane separates the farmland from an uncultivated area of c. 1.1ha in the south of the site abutting the M2. 4.2 Topography The site largely lies in the floor and lower sides of a dry asymmetric chalk valley. Levels in the valley floor fall northwards from 28mAOD at the M2 embankment to 24mAOD at the northern site boundary. The west side of the valley is distinctly steeper than the east and there are clear signs of man-made level changes across the site. Ground contours superimposed on a hillshade image generated from publicly available LiDAR data emphasise these features. Contours inside and outside the site are shown on Drawing No. PRESFLD2011-2. An old brickearth excavation approximately 2m deep immediately south of Junction 6 is clearly identifiable by the abrupt change in ground level. A small chalk quarry occupies the eastern side of the valley 200m north of the site.

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4.3 Mineral safeguarding The geological setting of the site is shown on Drawing Nos. PRESFLD2011-3 and 4. The site is underlain by superficial deposits of clay and silt ‘Head’ lying on bedrock of the Thanet Formation or the Seaford Chalk Formation. The Brickearth Safeguarding Areas as shown on the KCC Mineral Safeguarding Map of the Borough of Swale are coincident with areas of ‘Head – clay and silt’. The site lies entirely with the safeguarding area for brickearth. 4.4 Constraints A high pressure gas main is located at the northern boundary of the site. The approximate position is shown on Drawing Nos. PRESFLD2011-5 and 6. We are not aware of records of any other services. The site lies entirely within an outer source Protection Zone II with the exception of the southwest corner of the site which lies in Source Protection Zone I. There are no other statutory designations or local designations that would affect working mineral on the site. 4.5 Proposed development Preston Field Land Trustees are seeking planning permission for the development of 70 residential properties and associated access roads. The site forms an extension of the Preston Fields development site to the north. The latest layout is shown in Appendix 2. This layout is under review in consultation with SBC and discussed in Section 3.3.3.

5. GEOLOGY AND SAFEGUARDED MINERAL 5.1 Regional geology 5.1.1 Bedrock The site is underlain largely by the Seaford Chalk Formation (Upper Chalk) which forms the northeast dip slope of the . The chalk is unconformably overlain by up to 30m of sand, silt and clay of the Paleogene age Thanet Formation which caps some of the higher ground on the south of the outcrop area and the higher ground immediately west of the site along Ashford Road. North of Faversham the Thanet Formation is overlain sequentially by the Lambeth Formation, the Harwich Formation and the Formation which forms low lying coastal area. 5.1.2 Superficial deposits Superficial deposits on the chalk dip slope are largely of Clay-With-Flints, a weathering product formed locally by a variety of processes during the Neogene and Quaternary periods. Overlapping the outcrops of both Chalk and Thanet Formation are well-drained, yellow-brown, firm, often stone-free, silty clay, silt and fine sandy silt brickearth deposits. These cover substantial areas south and east of Faversham and west to Sittingbourne. These typically homogeneous deposits with characteristic closely spaced columnar fissures may reach 6m thickness in local pockets, but more typically are 2.5 to 3m where well developed. The BGS gives the following description ‘Varies from silt to clay, usually yellow-brown and massive. Poorly sorted and poorly stratified, formed mostly by solifluction and/or hillwash and soil creep.’ The composition is variable reflecting the bedrock material, such that bedrock sand, chalk, flint gravel and London Clay is all more or less incorporated into the brickearth. Gravel from earlier head deposits or river gravels may also be included. At Kings Field in Faversham thin gravel horizons were reported in the brickearth and a horizon of sarsen stones at the base above the Thanet Sand. Unsorted gravel may be found in association with brickearth or either as interbedded lenses or underlying brickearth. 5.2 Extent of Brickearth Deposits Brickearth occurs through north Kent from Rainham in the west, through Newington, Sittingbourne, Faversham and Canterbury to Walmer near Deal. Deposits also occur inland from Ramsgate and Herne Bay.

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Wienerberger’s Smeed Dene works is the only brickworks in Kent using local brickearth. The works are located on the northeast side of Sittingbourne and the permitted reserve is 7km further west near Hartlip. 5.2.1 Current permitted reserves The only currently permitted reserve reported in the KCC 2018/2019 monitoring report is at Paradise Farm which will start to supply the Wienerberger Smeed works near Sittingbourne in 2021. The estimated reserve life is 21 to 22 years. 5.2.2 Mineral Sites Plan 2012 – Mineral Sites Preferred Options Consultation Four sites were put forward  Site 19: Paradise Farm c. 678,000t (22.6 years) put forward by Wienerberger and now consented.  Site 98: Jefferies Site c. 95,000t (3 years) - an extension to the existing site was assessed by Wienerberger to be non-economic to work.  Site 101: Barbary Farm c. 1.24mt (25 years) - a new site near Faversham put forward by Ibstock.

 Site 102: Barrow Green Farm c .760,000t (25 years) - a new site near Sittingbourne put forward by Ibstock. Ibstock hold very significant unconsented brickearth resources. They have no operational brickworks in Kent, producing the ‘stock’ bricks from their site at Ashdown in West Sussex a distance of over 120km. Wienerberger will need to address the long-term supply for the works if Barrow Green Farm or Barbary Farm do not become available to them. However brickearth is extensively developed and can be exploited and restored with less impact than other mineral workings. Development sites could also represent windfall sites if sufficiently viable in terms of economics, project timing, stockpile capacity etc for both Wienerberger and the developer.

6. RESOURCE ASSESSMENT 6.1 Geology The site is underlain by superficial deposits of clay and silt ‘Head’ brickearth lying on bedrock of the Seaford Chalk Formation. Old gravel workings are noted on historical OS maps at the site of The Orchard development on Canterbury Road north of the site (see Drawing No. PRESFLD2011-1). And may represent a head gravel deposit within the brickearth. Chalk is at or near outcrop in the valley floor. 6.2 Evidence for the extent, thickness and quality of brickearth No boreholes have been drilled on the site. The closest boreholes and trial pits for which information are publicly available are shown on Drawing No. PRESFLD2011-5. Ten boreholes relate to the construction of M2 Junction 6:  Brickearth is absent or very thin (0.3m) over chalk bedrock in 3 boreholes beneath the Salters Lane crossing on the eastern side of the dry valley.  2.94m of brickearth with flints above chalk in one borehole on the western side of the valley at c. 31mAOD – a similar level to the southwestern corner of the site. It is reasonable to infer that the thickness and quality of brickearth at the two locations might be similar.  Five boreholes along the line of Ashford Road with 0.9m to 1.35m of sandy clay brickearth above fine sand of the Thanet Formation and a sixth intersected 2.16m of sandy clay with sparse gravel. Investigations for the Perry Court development site west of Ashford Road found brickearth to be absent above Thanet Sand bedrock in the area closest to the M6 junction. Very limited investigations by Wienerberger in 2017 and reported in the Mineral Assessment for that site by How Planning LLP, indicated that brickearth was probably present over much of larger Preston Fields site to the north of the current site boundary. They observed that level changes on site were

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probably the result of earlier extraction over part of the site and estimated that perhaps 0.6 to1.5m thickness was still present. Agricultural Land Classification survey (ALC) carried out in 1996 identified thin over chalk in the floor of the valley. This area is identified on Drawing No. PRESFLD2011-5. Soils over the remainder of the site were recorded as at least 1m deep. 6.3 Evidence for prior brickearth excavation within the site 6.3.1 Historic maps Brickearth excavation and brickmaking are documented on Ordnance Survey maps from 1877, 1898 and 1908. In 1877 the southern part of the site is identified as ‘’. Excavation in the southern part of the site and brick works immediately to the west is shown on the 1898. Trace of excavation is absent in the 1908 map, but the brickworks are retained. There is no clear indication of the maximum extent of workings in the brickearth on the site. The historic maps are included in the report Land at Preston Fields, Faversham Kent Heritage Desk-based Assessment October 2020 by Orion Heritage Ltd. 6.3.2 Ground levels The lower slope of the valley south from Canterbury Road is considerably steeper than the eastern slope. This may be largely the result of asymmetric deposition of superficial deposits over the chalk bedrock. However there is evidence of an artificial cut into the hillside close to the northern site boundary and a 1-1.5m step along the western site boundary. In the southern part of the site, the step increases to c. 2.5m along the line of excavation shown on 6 inch 1898 Ordnance Survey map. These level changes are shown on Drawing No. PRESFLD2011-5. 6.3.3 Estimated thickness of remaining brickearth Areas where brickearth is absent or inferred to have been previously largely worked are shown on Drawing No. PRESFLD2011-6.  2 to 3m of brickearth may remain in the southwest corner of the site.  Brickearth has been largely removed from the remaining area of the southern part of the site.  Brickearth is entirely absent on the eastern side of the site where chalk is in outcrop beneath thin soil.  Evidence suggests that 1 to 1.5m of brickearth has been removed from the western valley side. Some thickness of brickearth remains but is unlikely to be greater than c. 1m thick with probable thinning to the east. 6.4 Resource estimate 6.4.1 Margins In order to estimate a resource within an area where mineral is identified as present, unworked margins left as buffer zones are applied for environmental or geotechnical reasons. Amenity buffer zones from residential properties typically have regard to impacts of noise, dust and visual intrusion. These will vary depending on the potential impact on the receptor and the nature of operations. Margins to engineering structures such as road embankments and cuttings are also subject to geotechnical analysis and risk assessment. Mitigation measures such as screening bunds and site management procedures may be put in place on a site to reduce impact and potentially reduce the required buffer zone. Greater nuisance levels may be permitted for temporary or short term activities. The following margins have been applied:  20m from the southwest site boundary with residential property.  10m margin from the southern site boundary adjacent to the M2 cutting and embankment.  10m from remaining site boundaries to accommodate amenity bunds. The resulting areas are shown on Drawing No. PRESFLD2011-6.

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6.4.2 Thickness of brickearth Estimated remaining in situ thickness of brickearth in the northern area is 1m and in the southwest is 2.5m. The southwest corner on the site falls within a Source Protection Zone I and the remainder of the site in Source Protection Zone 2. A retained thickness of 0.75m of brickearth in the floor of the excavation has been applied for protection of groundwater. Applying this criterion to the two identified resource areas, excavation of the larger area becomes impractical. 6.4.3 Quantities The estimated quantities based on assumptions and margins set out above are shown in Table 1 below.

Table 1 Estimated quantities of recoverable brickearth

North South Area (m2) 8,000 3,500 Estimated in situ thickness (m) 1 2.5 Estimated thickness available (m) 0 1.8 Estimated recoverable volume (m3) 6,300 Estimated recoverable tonnage (t) 10,700

Volume is converted to tonnage using a density of 1.7t/m3 , the same value used by Wienerberger in the Paradise Farm Planning Application. 6.4.4 Quality There is no direct quality data from site, however a borehole located at a similar level in the valley side 200m south (TR05NW13 in BGS database) describes ‘firm brown silty clay with flints’ above chalk bedrock. The presence of gravel will incur additional processing costs and make brickearth unsuitable for supply to Wienerberger. The current sites operated by Wienerberger are principally on Thanet Sand bedrock rather than chalk, and a different composition and grain size is likely to require additional blending. 6.5 Prior extraction Proposals for prior extraction are tested against Policy DM9 of the KMWLP Adopted September 2020 This states that:

Planning permission for, or incorporating, mineral extraction in advance of development will be granted where the resources would otherwise be permanently sterilised provided that: 1. the mineral extraction operations are only for a temporary period; and, 2. the proposal will not cause unacceptable adverse impacts to the environment or communities Where planning permission is granted for the prior extraction of minerals, conditions will be imposed to ensure that the site can be adequately restored to a satisfactory after-use should the main development be delayed or not implemented.

Timing of any mineral extraction will have to fit with the timing of delivery of the site and probably within one summer and therefore a short term, temporary operation.

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The southern area of the site is identified in the current development layout as retained as a green buffer between the development and the M2. Extraction of brickearth in this area would result in lower ground levels, reducing the screening impact of the area and therefore creating adverse environmental impact unless restored with arisings from elsewhere on site or by imported fill material. Extraction of superficial cover above Source Protection Zone 1 in the chalk aquifer will increase the risk to the aquifer. Retaining material in situ will reduce the available thickness of mineral in the northern resource area to impractical level. It is concluded that extraction of mineral is not compatible with a satisfactory restoration of the site and acceptable impacts on the environment. 6.6 Use of excavation arisings within the development There is a requirement for amenity screening in the southern site area. The landform has not been designed, however a 5m high landscape bund with 1 vertical in 3 horizontal slopes requires a minimum of 7,500m3 of material which is expected to come from arisings during development construction including brickearth. 6.7 Economic assessment 6.7.1 Benefits This resource assessment has identified the presence of approximately 11,000t of recoverable brickearth in the southwestern corner of the site. If the entire resource proves suitable for brickmaking this represents approximately 2.5 months supply to the Smeed Dene works and could potentially extend the reserve life of Paradise Farm by the same amount. The financial benefit to the development is likely to be insignificant. In 2017, Wienerberger stated that they would pay £2 a tonne for brickearth. At that time, the reserves for the Smeed Dene brick works was less than 5 years. Wienerberger now have long term reserves at Paradise Farm and any pressure on sourcing brickearth from other problematic ‘windfall’ sources such as development sites will be reduced. 6.7.2 Costs The site represents a small resource of problematic quality which will require costly site investigation and testing by Wienerberger to prove suitability for the brick manufacture. Excavation of the southern area will have adverse environmental impacts for screening and landscape amenity unless restored back to existing levels or higher. Excavation arisings from construction will be required for landscaped screening against the motorway in the southern area. Detailed cut/fill balance for the development is not available at the time of writing, however it is anticipated that if brickearth is extracted, imported fill material will be required to achieve the environmental benefits of the southern buffer strip. Approximately 1100 additional HGV movements will be required (return movements of 20t trucks) increasing noise and traffic nuisance on Ashford Road. Excavation of brickearth can only take place during dry weather making dust emissions a hazard and scheduling site work more complex and costly. 6.8 Potential for sterilization of mineral outside site boundary The development will not sterilise mineral resources outside the site boundary. The fields north of the site have received outline planning permission and no mineral extraction is proposed.

7. CONCLUSIONS The additional costs incurred in restoring the site, importing fill, restoration of the excavation in addition to operational uncertainties and environmental impacts far outweigh any marginal benefits to the development of the sale of brickearth if it should prove suitable quality. Wienerberger are the only market in Kent for brickearth as a raw material for brick manufacture. The presence of a raw material suitable for the Smeed works can only be confirmed by costly sampling and testing (including test manufacture of bricks) by Wienerberger. In the event of such testing taking place, the result may be that the quality and quantity do not represent a mineral

Mineral Resource Assessment Preston Fields Preston Field Land Trustees 201112 v.02 04/02/21 Page 10 of 11

resource. Nevertheless, assuming the material on site is suitable, this assessment has demonstrated ‘that extraction of the mineral would not be viable or practicable’ (DM7 Clause 2).

GWP CONSULTANTS FEBRUARY 2021

Mineral Resource Assessment Preston Fields Preston Field Land Trustees 201112 v.02 04/02/21 Page 11 of 11 b Date Version 04.02.2021 02.12.2020 158000N 162000N 161000N 160000N 159000N Scale 1:25,000 at A4

1 M2 AEC Checked Drawing No

603000E IB Drawn Issued with draft report Revision and compilation notes Final PRESFLD2011 Site location and planning context Preston Field Land Trustees Preston Fields (South) a b 04.02.2021 Version Client Project Date Drawing Ref

602000E 602000E Site area 2. 3. [email protected] www.gwp.uk.com +44 (0)1608 810093 +44 (0)1608 810374 tel fax web e-mail

M2 J6 consultants

Faversham

601000E 1. 601000E 1b. NOTES LEGEND 4. GWP Consultants LLP. Registered No. OC326183. Market Street, Charlbury Oxfordshire OX7 3PJ Registered Office: Upton House, Market Street, Charlbury, Oxfordshire OX7 3PJ. UK Upton House United Kingdom Adjacent sites under development or with outline South East Faversham proposed development area planning permission Site boundary Perry Court Land adjacent to Perry Court Orchards, Canterbury Road

Preston Fields

Brogdale Road M2 N 1. 1b. 3. 2. 4. 1.

600000E 600000E Imagery date 16.05.2019 Europa Technologies and Google earth & water resources

160200 22

26.0

30.0 30

Former chalk

quarry 22

N 32.0

34.0 32

160000 36.0 24

Salters Lane

26

28 34.0

Ashford Road A251 Dry valley

28 30

159800 34

36 34

36

34

32 30

M2 30 36 32 28 38 31 Embankment M2 Junction 6

32 38 34 36 M2 Cutting 36

32

159600 40 32 42

38

30

40 34

Dry valley

32 34

601200 601400 601600 601800 36

LEGEND Version Revision and compilation notes Date

Site boundary Residential properties a Issued with draft report 02.12.2020

b Final 04.02.2021

Ground surface contours (0.5m intervals) 22

NOTES Client Preston Field Land Trustees · Hillshade image and contours derived from 2017 2m DTM available from data.gov.uk Project · Do not measure from this plan Preston Fields (South)

consultants Topography Upton House tel +44 (0)1608 810374 Market Street, Charlbury fax +44 (0)1608 810093 Date Drawn Checked Scale Oxfordshire OX7 3PJ e-mail [email protected] 04.02.2021 IB AEC 1:4,000 at A4 United Kingdom web www.gwp.uk.com Drawing Ref Drawing No Version GWP Consultants LLP. Registered No. OC326183. earth & water resources Registered Office: Upton House, Market Street, Charlbury, Oxfordshire OX7 3PJ. UK PRESFLD2011 2 b

APPENDIX 1

Relevant Borehole Logs

Appendix Fronts 201112

12/2/2020 Page 1 | Borehole TR05NW6 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648277/images/12578171.html 2/3 12/2/2020 Page 1 | Borehole TR05NW7 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648278/images/12578172.html 2/3 12/2/2020 Page 1 | Borehole TR05NW9 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648280/images/12578174.html 2/3 12/2/2020 Page 1 | Borehole TR05NW10 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648281/images/12578175.html 2/3 12/2/2020 Page 1 | Borehole TR05NW11 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648282/images/12578176.html 2/3 12/2/2020 Page 1 | Borehole TR05NW12 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648283/images/12578177.html 2/3 12/2/2020 Page 1 | Borehole TR05NW13 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648284/images/12578178.html 2/3 12/2/2020 Page 1 | Borehole TR05NW14 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648285/images/12578179.html 2/3 12/2/2020 Page 1 | Borehole TR05NW15 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648286/images/12578180.html 2/3 12/2/2020 Page 1 | Borehole TR05NW16 | Borehole Logs

scans.bgs.ac.uk/sobi_scans/boreholes/648287/images/12578180.html 2/3 APPENDIX 2

Proposed development layout

Appendix Fronts 201112 NOTES This drawing is the property of FPCR Environment and Design Ltd and is issued on the condition it is not reproduced, retained or disclosed to any unauthorised person, either wholly or in part without written consent of FPCR Environment and Design Ltd. This drawing to be read in conjunction with all other relevant drawings and specifications for this project whether produced by FPCR Environment and Design Ltd or others. Any inconsistencies should be notified to the contract administrator and author immediately.

Land at Preston Fields Subject to Ordnance Survey Mastermap - Crown Copyright. All rights reserved. Licence Number: Planning Application 100019980 (Centremapslive.com). N *

0 25 50 75 100m

KEY

Site Boundary 4.1ha * Existing Settlement Existing trees

Existing Access Retained

Potential Residential 1.8ha (up to 70 dwellings , potentially including apartments)

Open Space and Structural Planting

Approved Development at Perry Court Access points to Link Road SALTERS LANE **Link Road from Ashford Road Proposed Site Access

ASHFORD ROAD (A251) ROAD ASHFORD Corridor safeguarded for potential link road

Indicative Main Access Route

Potential Footpaths

Potential Swales leading to Pond within Blue Line (Subject to Engineers recommended design and location)

Land for Accessible Semi-Natural Greenspace, Woodland Planting & Noise Attenuation (if required)

Land Subject to Planning Application

Proposed residential and main access roads (within Blue Line Land)

Orchard (within Blue Line Land) * Equipped Play Area (within Blue Line Land)

Attenuation Pond (Subject to Engineers recommended design and location) M2 *

masterplanning environmental assessment landscape design Preston Field Land Trustees 1:1000 @ A1 urban design ecology FPCR Environment and Design Ltd architecture Lockington Hall 22 January 2021 IAM / SGL arboriculture Land at Preston Fields - South DEVELOPMENT FRAMEWORK PLAN Lockington Derby DE74 2RH

Canterbury Road, Faversham 7391-L-08 rev A fpcr t: 01509 672772 e: [email protected] w: www.fpcr.co.uk CAD file \\Fpcr-vm-04\projects\7300\7391\LANDS\Plans\7391-L-08 FRAMEWORK PLAN rev A.dwg