Waste Sites Development Plan Document Options Consultation (May 2011) Commentary Report (November 2011)

Kent County Council—Waste Sites Options Commentary Report Kent Minerals And Waste Development Framework

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 1 Kent County Council—Waste Sites Options Commentary Report

Produced by :

Planning and Environment

Environment and Enterprise

Kent County Council

Invicta House Tel: 01622 696815

County Hall Email: [email protected]

Maidstone Web: www.kent.gov.uk/mwdf

Kent ME14 1XX Textphone: 08458247905

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 2 Kent County Council—Waste Sites Options Commentary Report

Contents Page

1. Abbreviations 4

2. Introduction 5

3. Site Proposals 7

4. Responses for Waste Sites DPD 9

5. Energy From Waste 11

6. Hazardous Landfills 27

7. Non-Hazardous Landfill 31

8. Treatment/Materials Recycling Facility Sites for Consideration 35

9. Composting Sites for Consideration 59

10. Household Waste Recycling Centres & Transfer Sites for 75 Consideration

11. Inert/Construction, Demolition and Excavations Landfill & 99 Landraise Sites for Consideration 12. Environmental Improvement to Closed Bio-degradable Land- 129 fill Sites for Consideration 13. Glossary 143

14. Biodiversity Comments Glossary 148

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 3 Kent County Council—Waste Sites Options Commentary Report

Abbreviations

AONB Area of Outstanding Natural Beauty MGB Metropolitan Green Belt

AQMA Air Quality Management Area MOD Ministry of Defence

BAP Biodiversity Action Plan NNR National Nature Reserve

BOA Biodiversity Opportunity Area PINS Planning Inspectorate

CPRE Campaign to Protect Rural England PPS Planning Policy Statement

DPD Development Plan Documents PROW Public Right of Way SA Sustainability Appraisal EIA Environmental Impact Assessment SAC Special Area of Conserva- HER Historic Environment Record tion HGV Heavy Goods Vehicle SLA Special Landscaped Area

HRA Habitats Regulation Assessment SNCI Site of Nature Conserva- tion KCC Kent County Council SPA Special Protection Area

KHS Kent Highway Services SSSI Site of Special Scientific Interest KWT Kent Wildlife Trust SWS Southern Water Site LDF Local Development Framework TMBC Tonbridge and Malling LWS Local Wildlife Site Borough Council

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 4 Kent County Council—Waste Sites Options Commentary Report

2.0 Introduction

2.1 The Waste Sites Development Plan Document (Options Stage 2.5 As well as the submitted comments the Council received a num- Commentary Report is the follow up document of the consultation for ber of petitions; the Waste Sites Development Plan Document – Options Consultation. The consultation period ran from the 31st May to the 26th July, however there was an extension until the 9th of August. Petition Amount of Signatures Charing-Sites 201 10,110,16,62,69,74,77,85,866,62,69,74,77,85,86 and 87 2.2 This document collates and summarises the responses for each of Hollowshore and Ham Farm- Sites 89 616 the sites to show the main reasons for support or objection from or- & 90 & 90 ganisations and members of the public. The aim of this report is to create a clear and concise document showing the main issues put forward. If people wish to read full responses these can be accessed through the online consultation portal at; http://consult.kent.gov.uk/ This brought the total number of responses to 1876 portal.

2.6 The Council has received detailed reports on sites from the resi- 2.3 These comments will be recorded as part of the site assessment. dents of Lenham, Badgers Mount and Shoreham Parish Council. Data collection and site visit reports will then be formulated, taking into consideration the emerging Minerals and Waste Core Strategy policies Reports were given to Minerals and Waste Development Framework and changes to national planning policy. The Preferred Options are (MWDF) team outside of the consultation but the comments from due to be published and consulted upon in May 2012. these internal consultees are considered to be important in informing the site selection process and so have been summarised for this re-

port. 2.4 The Waste Sites Options consultation received the following responses; Total Number of Responses 1059 Objection 908 Comments 87 Support 64

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 5 Kent County Council—Waste Sites Options Commentary Report

2.7 Sites with the most responses/objections

Site Refer- Name 2.9 There were some recurring concerns which applied to many of the sites. These comments included; ence Number

8 Chelsfield Ammunition Depot 84 Highstead, Herne Bay • The suitability of roads 85 Charing Quarry • Damage to homes, both structurally and in terms of value 18 Covers Farm • Sites that are in or near to designated land 87 Charing Quarry (Waste 3) 89 Hollowshore • Public safety 90 Ham Farm (Withdrawn) • Impact on biodiversity 93 Highstead Pits, Sittingbourne

2.8 The other waste sites received responses from within KCC or outside organisations but had fewer or no comments from members of the 2.10 Space is restricted in this report. All comments are valued and will public. be taken into consideration in the site assessment process. Full responses can be accessed via the online consultation portal;

http://consult.kent.gov.uk.

2.11 The graphs found in this report are to represent the number of responses for each site. The internal responses we received from heritage, biodiversity and highways are not included in this data.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 6 Kent County Council—Waste Sites Options Commentary Report

3 Site Proposals 3.4 Non-Hazardous Landfill Sites for Consideration

3.1 The following is a list of all sites submitted for consideration for Site Reference Number Name Page Number waste uses. The list contains their site reference number and the rele- 15 Burntwick Island 31 vant page in this document. 22 Rushenden Marshes 33 3.2 Soft Sand Sites for Consideration 3.5 Treatment/Materials Recycling Facility Sites for Consideration Site Reference Number Name Page Number Site Reference Number Name Page Number 13 Allington Waste Manage- 11 ment Facility 8 Chelsfield Ammunition 35 Depot 46 Sheppy Ltd, Ashford Road, 13 Hollingbourne 12 Newington 37 47 Sheppy Ltd, Rushenden 15 14 Longfield Farm, Paddock 39 Road, Queenborough Wood 48 Argent Road, Queenbor- 17 20 Tovil Recycling 41 ough 27 Otterpool Quarry, Sellindge 43 54 Richborough Power Station 19 51 Ridham 45 55 Ightham Sandpit Gasifica- 21 52 Weatherlees 47 tion Plant 59 Shelford Waste Manange- 49 58 Land at Manor Way Busi- 23 ment Facility ness Park, Swanscombe 63 Pinden Quarry 51 61 SCA Packaging, New Hy- 25 the, Aylesford 64 Richborough Hall 53 79 TilmanStone Works 55

3.3 Sharp Sand and Gravel Sites for Consideration 88 Sevington Recycling Depot 57 3.6 Composting Sites for Consideration Site Reference Number Name Page Number Site Reference Number Name Page Number 60 Norwood Quarry and Land- 27 fill Extension 23 Blaise Farm 59 63 Pinden Quarry 29 52 Weatherlees 61

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 7 Kent County Council—Waste Sites Options Commentary Report

65 Land North of Stevens & 63 3.8 Inert/Construction, Demolition and Excavation Landfill & Land- Carlotti raise Sites for Consideration

79 Tilmanstone Works 65 Site Reference Number Name Page Number 82 Milton Manor Farm 2 67 12 Newington Industrial Estate 101

83 Westbere 69 17 Moat Farm 103 18 Covers Farm 105 84 Highstead, Herne Bay 71 24 Land North of Addington 107 85 Charing Quarry (Waste) 73 41 Cryalls Lane 109 50 Ightham Sand Pit 111 3.7 Household Waste Recycling Centres & Transfer Sites for consid- 56 Hegdale Quarry 113 70 Stonecastle Farm Quarry 115 Site Reference Number Name Page Number Lake 11 Lees Yard & Adjacent Site 75 79 Tilmanstone 117

12 Newington Industrial Estate 77 87 Charing Quarry (Waste 3) 119 89 Hollowshore 121 13 Allington Waste Manage- 79 ment Facility 90 Ham Farm 123 28 Waterbrook Park 81 93 Highstead Pits 3, Sitting- 125

30 Church Marshes 83 95 Stone Gate 127

31 Studd Hill 85 3..9 Environmental Improvement to Closed Bio-degradable Landfill 37 Cobbs Wood industrial 87 Estate Site Reference Number Name Page Number 38 Southwall Road 89 39 Chilmington 129 42 Pedham Place 91 40 North Farm WTS and 131 43 Stoneyead 93 HWRC 41 Cryalls Land, Sittingbourne 133 44 Land at Church Marshes 95 54 Richborough Power Station 135 57 Pike Road Eythorne Exten- 97 sion 66 North Farm Landfill 137 72 Unit 14 Canterbury Indus- 99 67 Chilmington Green 139 trial Estate 68 Sleedwood Landfill, Dover 141

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 8 Kent County Council—Waste Sites Options Commentary Report

5 Waste Sites Development Plan Document

Support 0

Responses regarding the complete Waste Sites Development Comment 9 Responses Plan Document

Object 4

0246810

Responses

Port of London Authority None of the sites set out in the options consultation document are located in close proximity to the River Thames and therefore the PLA has no comments to make on the individual sites. However, it would appear to be useful in the introductory text to emphasise the point from the Core Strategy concerning the Council's aspirations regarding co-location of facilities. Therefore, whilst this document relates to the identification of waste sites it would also provide the opportunity in appropriate locations and circumstances to co-locate minerals facilities at these sites. Kent Wildlife Trust The Trust is concerned regarding the level of impact that some of the sites would cause to our most valuable Natura 2000 and Ramsar sites. Although we understand that not all these sites will come forward in the final document, many of the sites proposed will either have a direct or indirect impact on these sites both individually and in-combination with other development proposed within the locality, within the Local Authorities LDFs and large infrastructure projects. Of particular concern is the impact from a number of sites proposed for both Minerals and Waste development on, and in the vicinity of, the Medway Estuary and Marshes SPA and Ramsar sites. These sites are heavily used by resident and migratory bird populations. In a number of cases it is proposed that there be direct land take from a European network site whilst on adjacent sites valuable grazing marsh likely to be used by the bird populations and other species for which the sites are designated will be lost.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 9 Kent County Council—Waste Sites Options Commentary Report

Protect Kent 1. We oppose the use of any agricultural land for waste management activities, including all those listed within the documents. Suitable brownfield sites, land within industrial areas, and land designated for industrial development should always be the preferred siting for such activities.

2. We have serious concerns about the impacts of all traffic movements on and in the vicinity of the proposed sites. In particular, the nuisance caused by heavy goods vehicles in the form of air pollution, dust, noise, vibration, congestion, road traffic hazards, unsecured loads, and road surface wear. We would expect a full traffic study for each site and appropriate controls over impacts to be imposed though conditions within any permissions given.

3. We note that some sites are large areas designated for comparatively small plant. A reduction in their plan area to that required for the waste activity only may make these sites more acceptable.

4. Far greater detail is required on the proposals for the waste sites to enable an informed decision to be made. In particular, information is necessary on waste types and volumes, sources, processing and storage, end use, energy (heat and power) end use, emission controls, environmental impacts, and restoration. We would expect all these factors and others to be fully considered in any final decision, and subsequently ac- counted for through conditions incorporated into any permissions issued. RSPB Habitats Regulations AssessmentThe RSPB is concerned that a number of sites presented here are within close proximity to or involve direct land take from a Special Protection Area ("SPA") Ramsar site and/or Spe- cial Area of Conservation ("SAC").

SPAs ad SACs are European sites protected under the Habitats Regulations 2010. As a matter of government policy Ramsar sites are given the same level of protection as European sites.

Strict legal tests set out under the Habitats Regulations must be fulfilled before a spatial plan such as this one can go ahead. Regulation 61(1) states that where a plan has a likely significant effect on a European site (alone or in combination) there needs to be an appropriate assessment.

East Sussex County Council Acknowledgement that there has been a long history of cross border waste movements in Para . 2.5.7 is welcome, however the Strategy does not adequately consider the use of facilities to serve a wider geo- graphical area in order to make the best use of the available infrastructure.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 10 Kent County Council—Waste Sites Options Commentary Report

5 Energy from Waste

Site 13

Allington Waste Management Facility Support 4

5.1 This proposal is to develop an additional fourth line to the Comment 3 Responses current energy from waste incinerator. This fourth line will provide an additional capacity of circa 200,000 tonnes per annum. The site has also been promoted to provide a House- Object 0 hold Waste Recycling Centre and to expand the existing Ma- terials Recycling Facility. 012345

Responses District/ Borough TMBC - The site lies outside of the Aylesford settlement confines. Countryside protection policy CP14 of the TMBC's applies. Parish Council Ditton -This Parish Council's main concern is the lack of household waste recycling facilities in the Tonbridge & Malling Area - our local residents have to use Tovil or Cuxton. This Council would therefore support the development of a Household Waste facility at Allington as proposed as a possible site in the waste consultation document.

Tovil - Support is given to the suggestion of an additional Household Waste facility at Allington, which is sorely needed to reduce congestion and unsustainable vehicle movements within Maidstone Borough and parts of Tonbridge and Malling. Southern Water Southern Water – Strong Planning Policies will be needed to protect underground sewers and/or water mains at this site. Source Protection Zones - Not assessed as outside supply area. Heritage The site lies in an area with archaeological potential relating to the Bronze Age, Iron Age and Roman findings nearby. Previous quarrying and development at the site has clearly had a significant impact on its archaeological potential though how far this extends across the site, particularly in the western areas is not known. The site lies on the Hythe Beds which has a potential for the presence of Palaeolithic sites. A number of WWII pillboxes are recorded to the east and south of the site. Biodiversity EPS, UKProtect, Local, UKSite and LocalSite protected species within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 11 Kent County Council—Waste Sites Options Commentary Report

Highways HGV Route along A20. No planned Highway improvements.

Kent Wildlife Trust No objections to the expansion of the current recycling activities or the addition of a facility to recycle household waste. KLIS shows a number of woodland strips along the boundaries of the site. These should be preserved and enhanced within the proposed development. Kent County Council Waste Manage- Fully supports the provision of an HWRC at this location. Extensive land/site searches have been carried dur- ment ing the last eighteen months to seek to establish a suitable location that best meets the needs of T&M residents and also provide additional much needed capacity for Maidstone. This site meets those requirements. Protect Kent Acceptable, subject to a more detailed assessment.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 12 Kent County Council—Waste Sites Options Commentary Report

Site 46

Sheppy Ltd, Ashford Road, Hollingbourne Support 0

5.2 This site is promoted to produce combined heat and Comment 3 Responses power by making use of waste woods from construction.

Object 5

0246

Responses

District/Borough Maidstone- The Council has concerns about the prominence of this site on raised land and the potential negative impact of quarrying in this area on the historic environment in close proximity to the site (i.e Leeds Castle and gardens).

Utility Companies Southern Water- Within SWS waste water area Heritage The proposed site lies in Holmesdale which has a rich archaeological resource. Investigations just to the north west of the site during construction of the CTRL discovered remains ranging from Mesolithic to Iron Age date. Roman, Saxon and medieval finds have been recorded in the wider landscape.

The site lies close to a Listed Building at Oakfield House and another being the lodge to LeedsCastle. The

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 13 Kent County Council—Waste Sites Options Commentary Report

Biodiversity EPS, UKProtect, Local, LocalSite protected species located within site.

Highways Access to this site onto the A20 would be via the gate at the south western corner. Visibility from this point appears adequate. There are no capacity problems on the A20 (other then an intermittent queue in the vicinity of junction 8 of the M20 in the morning peak) or additional development likely in the area. Kent Downs AONB The site would contribute to provision of renewable energy through energy recovery from wood waste using a biomass combined heat and power plant and benefits from good access to the A20/M20. There would be potential adverse impacts to be overcome in relation to identified constraints adjacent to the site, with potential impacts on landscape, biodiversity and heritage of site operations.

Natural England Natural EnglandThe location is close to the Kent Downs AONB. Potentially any stack associated with a CHP unit could be visible from the AONB. This would be a visual intrusion in a rural area and could interrupt views from the AONB.

Kent Wildlife Trust This site is adjacent to Leeds Castle Estate Meadows and Woodland LWS designated for its ancient woodland, marsh and wetland habitats. Safeguards should be incorporated into the design of any heat and power plant to limit the emissions and ensure no harm to the LWS. It will also be important that the LWS is buffered by at least 15m of natural habitat to ensure that the roots of the tree stock are protected and that construction within the sites does not affect the hydrology of the surrounding area. Visit Kent The site is adjacent to the county's leading tourism attraction Leeds Castle and within Kent Downs Area of Outstanding Natural Beauty. Potential emissions from the plant, increase traffic movement and other environmental factors would have detrimental impact on visitors.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 14 Kent County Council—Waste Sites Options Commentary Report

Site 47

Sheppy Ltd, Rushenden Road, Queenborough Support 0

5.3 This site currently has a waste management permit for Comment 3 Responses fertilisers. The proposal is to produce combined heat and power from wood construction waste. Object 2

01234

Responses

District/Borough Swale - The Council object to this site if the proposals were to increase the negative impacts that the existing use would already have on the planned regeneration of the area. Depending on the scheme it is likely to be completely at odds with the Council’s housing led regeneration aspirations. It needs to be compatible with Swale’s wider regeneration and uplift aspirations.

The site is adjacent to an SPA. There are potential impacts on residential amenity due to site operations and transport. The land is extremely contaminated at present and would need significant investment to be remediated. There is a potential visual impact form and to the historic town of Queenborough .The Council would sit on the fence if the proposals were for a CHP plant which would be in line with the adopted Master- plan. There would be the need for large scale mitigations however.

Utility Companies Southern Water- No proximity to source protection Zones. Within Wastewater, Wastewater infrastructure

Heritage Within the site no buildings remain that predate the 1940s though there may be earlier industrial structures and buried remains present. The marshes themselves may include evidence of earlier activity including remains of prehistoric, Roman and medieval date as have been found nearby on Sheppey in similar deposits. The remains of wrecks and maritime activities that took place in the creek may be found on the site. The creek was used for naval purposes including the careening of vessels on the flats within the site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 15 Kent County Council—Waste Sites Options Commentary Report

The saltings in the north part of the site are part of the Queenborough Conservation Area. The historic planned medieval town and its wharf lie on the north part of the creek. A number of Listed Buildings lie on the south side of South Street overlooking the site. Queenborough Castle, a Scheduled Monument lies buried to the north east but is screened by a number of creekside properties.

Biodiversity UkProtect, Local, Eurosite, UKSite, LocalSite protected species within Site. EPS Protected species within 1km of site.

Natural England Individually these sites may not present a landscape issue but in-combination they potentially could have a significant impact on views from the Kent Downs AONB. Streams crossing the sites are likely to contain the white tailed crayfish which is protected under the Wildlife and Countryside Act 1981.

Highways The site can be accessed off Rushenden Road, close to its junction with the soon to be completed Rushenden Relief Road. The are unlikely to be any capacity issues.

Natural England Site adjacent to Medway Estuary and Marshes SPA, Ramsar and SSSI. If this site is taken forward the Coun- cil must make it clear that any application that comes forward will need to fully assess impacts on the interest features of these sites and will need to be subject to an Appropriate Assessment under the Conservation of Habitats and Species Regulations 2010.

Kent Wildlife Trust This site is adjacent to the Medway Estuary and Marshes SPA, Ramsar and SSSI sites designated for their breeding, passage and migratory birds and for their marshland habitat which supports a number of important invertebrate and flora species. Within the site itself KLIS identifies coastal habitat which may be utilised by the bird species for which the European sites are designated. The site is also adjacent to The Creek likely to be of value to the bird population.

RSPB Site is situated within 500m of an internationally designated nature conservation site. situated immediately adjacent to Medway Estuary and Marshes SPA/Ramsar.

Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the unknowns are resolved before permission is applied for; the development of the site is integrated with the proposals for Rushenden / Queenbor- ough; the heat generated has a specific use at the outset (ideally within the new development).

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 16 Kent County Council—Waste Sites Options Commentary Report

Site 48

Argent Road, Queenborough Support 0

5.4 This site is promoted to produce combined heat and Comment 3 Responses power from waste wood from construction.

Object 0

01234

Responses District/Borough Swale - The Council conditionally have no objection to this site if the energy produced could be used locally by the adjacent industrial estate or the housing in Rushenden. There may be the possibility of linking it up to the Rushenden Retro-fit project. The Council would also need to be satisfied that there would be no significant effects upon the SPA/RAMSAR. There are potential impacts on residential amenity due to site operations and highways concerns.

Utility Companies Southern Water - No Proximity to source protection zones. Within wastewater, wastewater infrastructure crossing, SWS water supply area and wastewater treatment works area. Heritage The proposal site lies on elevated ground adjacent to the Rushenden marshes. Such a location has been found to be favourable for ancient activities elsewhere on Sheppey and in particular close by at Neatscourt.

Biodiversity LocalSite protected species within site. EPS, UKProtect, Local, Eurosite, UKSite protected species within 1km of site.

Highways This is a small site that would be served from the existing industrial estate roads around the Cullet Drive area of Queenborough/Rushenden, and is unlikely to give rise to any HGV capacity issues. This is particularly the case considering the improved access soon to be available to this area with the completion of the Rushenden Relief Road to link directly out to the A249. Purpose built road from Rushenden Road through to Neatscourt and the A249 to open up area for major redevelopment of Queenborough and Rushenden. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 17 Kent County Council—Waste Sites Options Commentary Report

Natural England The extension of the mineral workings to the south east of the existing Stonecastle Farm Quarry brings the workings closer to the boundary of the High Weald AONB and may impact on the setting of the AONB. It is therefore important that if any or all of these sites are taken forward the workings and restoration are suitably phased to minimise any visual impacts.

Kent Wildlife Trust This site is near to SandwichBay to Hacklinge Marshes SSSI designated for its habitats, rare flora and fauna and migratory bird populations. It is within very close proximity to the Sandwich and Pegwell bay NNR, the ThanetCoast and Sandwich Bay SPA and Ramsar site. This site also is designated as an SAC.

RSPB Site is situated within 500m of an internationally designated nature conservation site. Situated approximately 300m from Medway Estuary and Marshes SPA/Ramsar.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 18 Kent County Council—Waste Sites Options Commentary Report

Site 54

Richborough Power Station Support 2

5.5 The landowner has promoted this site for an energy from Comment 4 Responses waste facility producing approximately 15Mw. The landowner is also promoting the reworking of the existing landfill. The site can also be found in Chapter 11: Environmental Improve- Object 7 ment to Closed Biodegradable Landfill Sites.

02468

Responses Parish Council Thanet - While the exact nature of the facility is not known we believe that the County Council should make its locational decisions based on the “precautionary principle“. Any necessary facility should be constructed in a less sensitive location than Richborough which was identified in the Kent Waste Local Plan 1998, where the potential to cause damage or nuisance to the very significant conservation interests and to a very extensive urban area does not exist. A more rural location away from such concentrated centres of population would be appropriate.

Dover - Support in principle for the use of Richborough for EFW subject to the need for it in light of the underused capacity at Allington and any revisions to the forecasts in the Core Strategy. Support would also be subject to any direct and indirect impacts on the environment and local communities. The current Area Specific policy AS14 in the saved Dover District Local Plan also indicates that any new development should visually upgrade the A256, all new buildings should be low rise, does not increase the risk of flooding and provision is provided for archaeology. These should be considerations for any new allocation/policy.

Sandwich Town Council - There are concerns that this area is within an area of constraint (SNC) and is adjacent to SSSI and Ramsar sites, Special protection Area and Nature Reserve. It also lies on a flood plain. The council would also question where the waste for the proposed site will be coming from as there are adequate provisions already in place to deal with existing waste at the adjacent Thanet waste site which recycles 90% of the waste it receives. The council is also concerned about the possible effect on air and water quality.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 19 Kent County Council—Waste Sites Options Commentary Report

Parish Council Eastry - The Parish Council are opposed to the reworking of the land fill site. This site has been in place for many years and the vast majority of it is has now reverted to open countryside. The members feel that reworking this site would be detrimental to the local environment.

They are also concerned that this site is not central to any area; this means that any waste arisings heading for the incinerator will need to be brought in from great distances, and as the levels of waste arisings are fal- ling the travel involved would prevent the site from being environmentally viable.

Woodnesborough - Object to the proposal to provide an incinerator to provide energy from waste and rework the landfill site. The environmental impact on the Bird reserve in the vicinity of the site is of concern as is the possibility of hazardous fumes from the incinerator. This site is on the flood plain. There is historical precedent for this site being inundated. It is not sound or rational to locate such a facility on the flood plain. Utility Companies Southern Water - No proximity to Source Protection Zones. Within SWS Wastewater area, SWS supply area and Water supply infrastructure crossing. Heritage The proposals lie in an area which is extremely sensitive in terms of the historic landscape of the former Want- sum Sea Channel. Archaeological remains associated with the historic use of the sea channel, the River Stour and the associated marshlands could lie in the area. Evidence of medieval and post-medieval reclamation and marginal activities or industry could also be present. The area is overlooked by the Roman fort, port and town of Richborough which is a Scheduled Monument and an important historic tourist attraction. The power station is itself of industrial archaeological interest. Environment Agency The whole 121 hectare site includes a long stretch of the River Stour and adjacent levels. These are important areas for wildlife. The River Stour is an important green corridor, and its protection and enhancement should be a key objective of any proposal. Natural England The extension of the mineral workings to the south east of the existing Stonecastle Farm Quarry brings the workings closer to the boundary of the High Weald AONB and may impact on the setting of the AONB. It is therefore important that if any or all of these sites are taken forward the workings and restoration are suitably phased to minimise any visual impacts. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the nature of the 'reworking' is fully defined. Note: it is unclear whether the proposed 'reworking' of the site will involve any additional landfill which will potentially result in impacts on nature conservation interests both within and adjoining the site. RSPB Site is situated within 500m of an internationally designated nature conservation site. situated approximately 200m from Medway Estuary and Marshes SPA/Ramsar.

Kent County Council Waste Will support proposals that bring about sustainable waste infrastructure projects in areas where these are Management needed. Richborough fits that criteria. Part of the site includes the KCC former Richborough Landfill which will be reworked. There is the potential to create additional void space and this is welcomed. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 20 Kent County Council—Waste Sites Options Commentary Report

Site 55

Ightham Sandpit Gasification Plant Support 0

5.6 This site forms part of an existing sand quarry. This area Comment 4 Responses of land is being promoted as a Gasification plant producing 20Mw of energy. Object 3

012345

Responses District/Borough TMBC - The site outside of the Aylesford settlement confines. Countryside protection policy CP14 of the TMBC'S applies. Parish Council The site has been previously worked as a sand quarry. Buried archaeological potential in the area of the proposed plant will have been lost. A listed building lies just south of the proposed site at Cricketts Farms and the Grade 2 Registered Park and Garden and ListedBuilding at Ightham Court lies to the South West.

Utility Companies Southern Water - Within SWS wastewater area. Within SWS water supply area. Not assessed for source protection, as outside supply area.

Heritage The site has been previously worked as a sand quarry. Buried archaeological potential in the area of the proposed plant will have been lost. A listed building lies just south of the proposed site at Cricketts Farms and the Grade 2 Registered Park and Garden and ListedBuilding at Ightham Court lies to the South West.

Biodiversity UKProtect located within Site. EPS and LocalSite located within 1KM of site.

Highways HGV route along A25. No planned Highways Improvements. Only proposed development to date is a large residential development off of Quarry Hill Road (no application has been submitted to date).

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 21 Kent County Council—Waste Sites Options Commentary Report

Kent Downs AONB Challenges long term restoration of the site unless related to methane collection from fill and only of a temporary nature, otherwise makes industrialisation permanent and challenges long term restoration to agriculture which is required. Natural England The position brings an unwelcome industrial building into the AONB. It also prevents the restoration of the site if the Council decide to allow the mineral allocation here. If a gasification plant is deemed appropriate in the area its position should be closer to the existing works outside of the AONB and closer to the existing built environment. Protect Kent Rejections recommended. An isolated site, which could be better located. Due to the site being within Kent Downs AONB, site is a potential Local Wildlife Site, waste would need to be imported to the site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 22 Kent County Council—Waste Sites Options Commentary Report

Site 58

Land at Manor Way Business Park, Swanscombe Support 0

5.7 The site is being promoted for a gasification power Comment 2 Responses station using solid recovery fuel waste such as non- recyclable cardboard, paper and waste wood. The site Object 1 would produce 22Mw of energy, exporting 20Mw.

00.511.522.5

Responses

District/Borough Dartford - Dartford - Paper and cardboard waste is declining. KCC is looking to dispose of material such as waste wood at the Allington incinerator. It is therefore questionable if there will be sufficient material to supply the facility, and also that such material will have to be brought in from a wide catchment, primarily out of County, which will not be very sustainable.

The site lies within the proposed Swanscombe Peninsula site which is identified in Diagram 7 ‘Thames Water- front Priority Area’ and subject to policy CS6 ‘Thames Waterfront’ in the Submission Core Strategy which was Examined in May 2011. Policy CS6, with Proposed Changes, identifies Swanscombe Peninsula for mixed-use development, subject to compatibility with adjoining uses. This includes employment which may include a low/ zero carbon Combined Heat and Power Plant utilising Bells Wharf and Whites Jetty for the transport of goods and material.

A location to the north of the site promoted at Manor Way Business Park is preferred as this provides for waste feedstock to be brought in by river and for the facility to be served by a much wider feedstock catchment as Kent is well provided for by incinerator capacity.

The safeguarding of the promoted site would undermine the potential to deliver incinerator capacity at Swanscombe Peninsula in line with the Submission Core Strategy.

Utility Companies Southern Water- Within SWS wastewater area.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 23 Kent County Council—Waste Sites Options Commentary Report

Heritage The proposed waste site lies in the site of a former chalk quarry and later paper mill and cement works. The site has been presently developed with a business park. Although gravel deposits nearby have a potential for important Palaeolithic remains and later prehistoric finds have been made in the area, the chalk quarry is likely to to have fully removed the potential for finding such remains except around its edges.

Biodiversity EPS, UKProtect And Local all within site boundary. UKSite and Local Site all within 1km of site.

Kent Wildlife Trust The site is on Swanscombe Peninsular which is known to contain populations of invertebrates of national importance. These species colonise open mosaic habitats on previously developed land. Within our response we advised that a more detailed assessment of its ecological value than that presented in the draft ES chapter, was required particularly with regard to invertebrates for the planning application to fulfil the requirements of Planning Policy Statement 9: Biodiversity and Geologi- cal Conservation. It was also noted that reptiles are present on site and mitigation measures would

Protect Kent Acceptable, subject to a more detailed assessment.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 24 Kent County Council—Waste Sites Options Commentary Report

Site 61

SCA Packaging, New Hythe, Aylesford Support 2

5.8 This is the former site of the SCA packaging factory. Comment 7 Responses The site has been promoted for an Integrated Waste Management plant including an energy from waste facil- Object 1 ity and front end recycling.

02468

Responses District/Borough TMBC - The site lies within a designated Employment site. Parish Council Wrotham - Accept that an Integrated Waste Management Plant on this site is an excellent location for this activity.

New Hythe Lane

which has been the site of very significant new residential dwelling build over recent years. WPC view is that, whatever environmental improvements are made this is an inherent weakness to any future potential expansion of the site.

The strengths of the site for the purpose proposed are in the opportunity presented to make the maximum use of the excellent wharfage and one of the few unused factory related rail sidings still available in West Kent. We recommend that the use of this site should be designated in the WDF such that at least 50% of all materials measured by weight or volume whichever is the greater to be transported to and from the site should be carried either by water or rail.

This measure would then have the effect of preserving the wharf and railhead for the future in accordance with national requirements and alleviate pressure on the poor local road network.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 25 Kent County Council—Waste Sites Options Commentary Report

East Malling and Larkfield Parish Council - We note the comment the site is on previously developed land with no constraints identified and it is considered it performs well against sustainability criteria. We would however wish to record there is considerable concern locally about potential lorry traffic being generated by the site especially but not only by the residents of the new residential developments as "The Lakes" and "LeybournePark" nearby. These have altered the character of the area.

Utility Companies Southern Water - Within SWS wastewater, wastewater infrastructure crossing and close to SWS wastewater treatment works. Heritage The proposed waste site lies in an area that is rich in archaeological remains with remains of Palaeolithic, Bronze Age, Iron Age Roman and Anglo Saxon having been found in this area of the Medway Valley though often on the opposite side of the Medway. The site of the medieval Chapel of St John and its graveyard is thought to lie in the northern part of the site. The chapel was taken down in 1940 to enable expansion of the present works. The site has been heavily developed since the early 20th century, initially being part of the Aylesford Paper Mill.

Biodiversity UKProtect, Local protected species within site. EPS, UKSite and LocalSite within 1km of site.

Highways HGV Route along Leybourne Way onto A228. No planned highway improvements.

Kent Wildlife Trust The Trust has no objection to the proposed integrated waste management plant. However the site is in a sensitive location with a number of important ecological sites adjacent that could be impacted from emissions and drainage from the site. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: transportation difficulties are resolved, including the consideration of rail and river modes. Kent County Council Waste There is no immediate need for additional MSW infrastructure at this location but does recognise the consider- Management able merit of the site, particularly given it's proximity to the local highway network .

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 26 Kent County Council—Waste Sites Options Commentary Report

6 Hazardous Landfill Site 60

Norwood Quarry & Landfill Extension Support 2

6.1 This is an existing site extracting London Clay and Comment 3 Responses hazardous waste landfill, in particular the flue ash from the Allington energy from waste incinerator. There are two possible site extensions promoted: one to the east Object 0 and one to the north of the existing site. 01234

Responses District/Borough Swale - The Council conditionally has no objection to this site as it would contribute to increased capacity for hazardous waste landfill and extend the life of existing mineral and waste operations at this site. The site util- ises existing infrastructure and access and is a largely unconstrained site.

However, the Council would object if proposals were shown to increase traffic levels above current volumes due to impact upon capacity and amenity of residents on the Lower Road. The Council would also object if landscape impacts and impact on residential amenity were not capable of being successfully mitigated.

There could be residential amenity impacts due to the noise and dust from the operations. It is felt that the

Heritage Important archaeological remains of Mesolithic, Neolithic, Bronze Age, Iron Age and Saxon date have all been

Biodiversity UKProtect protected species located within site. EPS and Local located within 1km of site. Highways Prolonging the existing operations at this site are likely to be acceptable based on current traffic levels. An increase in HGV activity would need to be assessed to see what affect it may have in Lower Road and the operation of key junctions along its route to meet the A249 at Cowstead Corner.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 27 Kent County Council—Waste Sites Options Commentary Report

Kent Wildlife Trust No objection to the proposed extension to the above site. Woodland is present within the extension. This should be conserved if possible and if lost should be replaced within the restoration. We welcome the aim to restore some of this site to woodland and ponds. Protect Kent Acceptable, subject to a more detailed assessment.

Kent County Council Waste KCC (Waste) Fully support the objectives. There is a need to ensure continuity of capacity beyond 2016 for Management the disposal of the Allington residues using established best practice and technology. This site meets that criteria.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 28 Kent County Council—Waste Sites Options Commentary Report

Site 63

Pinden Quarry Support 2

6.2 This is an existing site which is currently extracting Comment 2 Responses chalk and providing a hazardous landfill site for asbestos waste. The site is providing a facility for disposing of asbestos for the south east. The proposal also includes Object 3 the development of a materials recycling facility and transfer station. This site can also be found in the Miner- 01234 als Sites DPD.

Responses District/Borough Dartford - Site is within Green Belt, Area of Archaeological Potential, Wind turbine Development Safeguard- ing.

Subject to HSE Inner Consultation Area of Transco Pipelines and HSE Middle Consultation Area of Transco Pipelines. National Grid Transition Gas Pipeline Consultation Zone. Smoke Control Order-Bean. Public Right of way on Western Boundary.

There is no evidence that additional capacity beyond that already consented needs to be identified. Parish Councils Southfleet-Object The Parish Council considers the inclusion of the Pinden proposed future options in the Kent MWDF to be detrimental to the future of the surrounding area.

New Barn East-Object - Site would create too many lorry movements, which would have a detrimental impact on local lanes and villages. Heritage Bronze Age, Iron Age and Roman Remains have all been found during past investigations at Pinden Quarry. Remains include evidence of Roman Occupation and burials.

As development could potentially affect buried archaeological deposits a programme of archaeological works should be implemented in advance of development.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 29 Kent County Council—Waste Sites Options Commentary Report

Biodiversity UK and Local protected species and local designated site within 1km. Kent Wildlife Trust This site is adjacent to Disused Railway Cutting Longfield LWS. However the LWS 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 KLIS shows that the proposed extension is within woodland. Although not ancient in origin it will be important to endeavour to preserve as much of this habitat within the proposal and any lost should be replaced either within the locality or as part of the restoration plan.

RSPB It would be important to ensure there were no negative impacts on the adjacent local wildlife site (SNCI), including hydrological impacts. Restoration of this site should complement the adjacent local wildlife site. This site is near the Thames-side Green Corridors BOA, which recommends restoration to acid grassland, heathland and species-rich neutral grassland.

Amec UK Ltd-National Grid The site is located within close proximity to one of National Grid’s high pressure gas transmission pipelines.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 30 Kent County Council—Waste Sites Options Commentary Report

7 Non-Hazardous Landfill Site 15

Burntwick Island Support 0

7.1 This site will provide dredged material and inert con- Comment 1 Responses struction and demolition waste for construction of engineered bunds. The dredgings will be sourced from the River Medway and River Thames. Object 3

01234

Responses District/Borough Swale - The Council object due to the site’s location within the SPA and RAMSAR. It is difficult to imagine how these issues could be satisfactorily addressed and how there could be maintenance of high environmental standards. The Council also questions how such standards could be maintained given rising sea lev-

Parish Councils Upchurch - It is interesting to note that the proposed restoration of this area is given as Nature Conservation. It is known that the Environment Agency, in its Shoreline Management Plan, leaves the protection of the shoreline in this area to nature. Together with increasing water levels this restoration may been seen as positive for the habitat and wildlife by increasing the land available

The operations would need to overcome potential adverse impacts on constraints in the areas of Special Pro- tection Area and RAMSAR designation. This would be through maintenance of high environmental standards

Heritage Burntwick Island lies in an area of the Medway estuary which is rich in archaeological sites , many of which have become inundated due to rising sea levels. These are marginal areas were highly attractive in Roman times for the production or pottery and salt working. As can be seen on the Ordnance Survey mapping of the island, Roman pottery kilns have been found on the margins of and close to the proposed waste sites. It is very likely that well preserved remains of prehistoric and Roam date are present within the proposed sites. Examination of aerial photographs of the island reveal the presence of ditches, earthworks and other features which may relate to early use of the island.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 31 Kent County Council—Waste Sites Options Commentary Report

The island saw use in the 19th and 20th centuries by the admiralty. It is suggested that the island was used as a burial place for the nearby lazaratte and quarantine stations in Stangate Creek. RN Sydney Barnard, who died while treating yellow fever at the quarantine station, is buried in a marked grave of the island complete with railings and a memorial.

Biodiversity EPS, Uk Protect Local, Eurosite, Uk Site, LocalSite protected species located within the site. Highways No road links to the site exist. Any roads that would be built to serve this site would be to likely to take access through Upchurch and Lower Halstow, where the roads are unsuitable for any regular HGV traffic.

Kent Wildlife Trust BurntwickIsland is part of the Medway Estuary and Marshes Special Protection Area and Ramsar sites and is also designated as an SSSI. KLIS shows that coastal habitats are present throughout the site including salt marsh and inter-tidal mud. Kent Ornithological Society inform us that this is the single most important site for seabirds in Kent.

Species which nest here include Black-headed Gull, Mediterranean Gull (with 250-300 breeding pairs, it is the second largest roost in the UK), Sandwich Tern (400-500 breeding pairs) as well as smaller numbers of Her-

Environment Agency A proposal at this location is likely to impact on a range of inter-tidal habitats within the SSSI, SPA and Ram- sar. It is difficult to see how this wouldn’t be highly detrimental to the nature conservation interests here. This would be against the KCC’s nature conservation policies.

Natural England The entire area is within the Medway Estuary and Marshes SPA, Ramsar and SSSI. The area concerned is a mosaic of saltmarsh and mudflats that are important feeding and roosting areas for SPA and Ramsar over- wintering birds.

Natural England has concerns that the a number of SPA Bird species within the Medway are in decline and consequently the Medway Estuary and Marshes SSSI has been assessed as being in Unfavourable Recover- ing condition while the reasons for these declines are investigated.

It is Natural England's view that the inclusion of this site would not meet the requirements of the Conservation of Habitats and Species Regulations 2010

General Public Responses Site would disastrous for both wintering and breeding water birds, many species of which are suffering declines in populations both nationally and internationally.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 32 Kent County Council—Waste Sites Options Commentary Report

7 Non-Hazardous Landfill Site 22

Rushenden Marshes Support 0

7.2 The site is currently a dredging disposal site. The Comment 1 Responses proposal is to import dredgings by barge and pump ashore methods for disposal and recovery. Also the importation of inert wastes for the construction of internal Object 3 bunds and other engineering uses is proposed. 01234

Responses District/Borough Swale - The Council object to this site as although this is an existing site that could provide opportunities for habitat creation after the operation closes, a planning application for this site is likely to be sought for economic development connected with the strategically important proposals at the Port of Sheerness (Wind turbine manufacture). Waste disposal proposals would present tensions with these economic ambitions.

The site is adjacent to international and national wildlife designations and would therefore require major environmental assessment and mitigation. Any landscape impacts will be dependent on the exact nature of the proposals. Utility Companies Southern Water – No Proximity to Source Protection Zones. Within SWS wasterwater, SWS infrastructure crossing SWS water supply and close to SWS wastewater treatment work areas. Heritage The proposed dredgings disposal site includes the buried former coastline of Sheppey which is reflected to some extent in the location of alluvium on the geology maps. Areas around Rushenden and the historic town of Queenborough are slightly elevated areas which once stood proud in their wet and marshland surroundings. Such areas were favourable for ancient settlement, the surrounding marshland providing plentiful resources. Evidence of Iron Age and Roman activities adjacent to the historic shoreline has been recently investigated in connection with the construction of the new bridge and road into Sheppey.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 33 Kent County Council—Waste Sites Options Commentary Report

7 Non-Hazardous Landfill

The former marshlands would potentially provide favourable conditions for a range of activities including salt working. Evidence of probable medieval saltworking within the boundaries of the proposed disposal site is identified on the Historic Environment Record. A number of earthworks are described and located to fall within the proposed site and it is possible that further earthworks could be present which have not been identified to date.

The alluvium could also contain important information regarding the sedimentological development of the Swale and the palaeo-environmental history of this area. The alluvium could also provide favourable conditions for the preservation of waterlogged organic archaeological remains.

Other entries in the Historic Environment Record within the vicinity of the development proposals refer to remains and features of maritime interest. A number of hulks and wreck sites are known to lie close to the proposed pipeline and it is very likely that similar remains would survive buried within the intertidal areas and marshland.

I am aware that the proposal has an existing permission for dredgings disposal and this operation has affected part of the site. Any new areas that have been hitherto unaffected by disposal could result in the burying of archaeological remains including extant earthworks. Other impacts could arise from the construction of em- bankments and lagoons and from the works on intertidal areas for any new dredgings pipeline to the site. Biodiversity EPS, UKProtect, Local and Localsite protected species within site. EuroSite and UKSite protected species located within 1km of site. Highways Access for HGVs to Rushenden Road is currently through Main Road, Queenborough, which is not ideal. The Rushenden Relief Road is nearing completion, and will provide an appropriate direct link to the A249. How- ever, is it unclear where this site will access Rushenden Road, and I would be concerned over use by HGV’S of the southern section of Rushenden Road through the residential housing estate.

Rushenden Relief Road is a purpose built road from Rushenden Road through Neatscourt and the A249 to

Natural England The site is adjacent to the Medway Estuary and Marshes SPA, Ramsar and SSSI.We understand that the western half of the site has already been subject to dredging/landfill and has been filled. Also that that there are plans for other activities on the eastern half of the site.

Given the site’s history Natural England are not minded to object to the inclusion of this site. However, the plan must make it explicit that any application that comes forward will need to fully assess impacts on the interest features of these sites, including usage of the site by SPA birds. Additionally any application will need to be subject to an Appropriate Assessment under the Conservation of Habitats and Species Regulations 2010.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 34 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 8

Chelsfield Ammunition Depot Support 1

8.1 The site will be used as a storage facility for high Comment 4 Responses PSV stone road planings for recycling. The recycled stone will then be used to make new asphalt for new road surfaces. Object 164

0 50 100 150 200

Responses District/Borough Sevenoaks District Council – Planning permission was granted for the use of the site for secure storage within Use Class D8. Parish Councils Dunton Green- Objection on grounds that the existing road network is not suitable for HGV’s. Shoreham-object AONB designation, Green Belt, Harm to Ancient Woodland, Local Wildlife Site, Harm to Bio- diversity, Increased road congestion. Utility Companies Southern Water-Not assessed as outside supply area Heritage The site contains an ammunition depot/explosives research facility that dates back to the Second World war. The site has a close relationship with research facilities at nearby Fort Halstead.

The site has features associated with its military use during World War Two and The Cold War, which are likely to be of archaeological significance. Biodiversity UK Protect and local species within site. European protected species within 1km. UK and Local designated sites within 1km. Highways There is currently adequate capacity available on roads required by the site. No planned highway improvements. Fort Halsted redevelopment could impact upon the local highways, although this is unlikely. Kent Downs AONB There is no justification for locating this facility in Kent Downs AONB. The Kent Downs AONB Unit object to its inclusion as an allocated site in the M&W Core Strategy. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 35 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Natural England While part of this can be considered a Brownfield site the proposal could potentially further degrade the AONB in an area that is already under urban pressure. Any proposal would need to deal sensitively with boundaries to minimise visual impacts.

Additionally, at least half of the site is ancient woodland. Care would need to be taken to avoid loss to this important BAP habitat. PPS9 states that "They [Local planning authorities] should not grant planning permission for any development that would result in its [ancient woodland] loss or deterioration unless the need for, and benefits of, the development in that location outweigh the loss of the woodland habitat. " Please refer to our Standing Advice on ancient woodland on our website for more details on how to avoid impacts.

Kent Wildlife Trust This site covers a large area of the Woodlands West of Shoreham LWS designated for its ancient woodland and calcareous habitats. Ancient woodland is irreplaceable. Kent Wildlife Trust objects strongly to the allocation of this site as it will lead to the loss of a significant area of ancient woodland and have an irreversible impact on an LWS. Both ancient woodland habitat and LWSs are protected from impact under PPS9 paragraph 10 and 9 respectively.

National Trust This site contains ancient woodland (grid ref TQ 500618). The expansion of this site would result in the direct loss of and damage to ancient woodland.

Protect Kent Objection Lawful Development Certificate restricts storage to the bunkers on site.

Shoreham Society Objection – AONB. Development only under exceptional circumstances which have not been demonstrated.

Woods Under Threat The site is adjacent to ancient woodland-consideration must be given to the indirect impacts of waste facilities adjacent to ancient woodland.

Conway Ltd We chose to purchase the Chelsfield site as it offers us the same discreet yet accessible storage and distribu- tion facility as enjoyed by the MOD since 1936. The 12 acre site is tucked away in a wooded area extending to over 50 acres. Access to the site is off the A224, some 1.5 miles from the access road to the M25 at junction 4. There is no congestion on the A224 before the M25 access road and Shacklands Road; the most traffic on the A224 is at weekends with visitors to the Pole Hill Garden Centre. There is, therefore, little to no impact on residential amenity. The landscape in terms of shielding is to be enhanced with the erection of a 10m wide x 5m high bund planted with trees indigenous to the area. General Public Responses Green belt area-Site is within an area of Ancient Woodland, which is covered by Tree Preservation Orders. - Congestion on local lanes which would struggle to cope with any increased traffic use by heavy goods vehicles.- Local roads do not have pavements and area used by children travelling to and from school.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 36 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 12

Newington Support 0

8.2 This site is an existing industrial estate located adja- Comment 3 Responses cent to a former extraction site for brickearth. The landowners have promoted the site for consideration for waste uses and to expand the site into the former Object 26 brickearth areas. 0102030

Responses District/Borough Swale- The Council object to all the proposals for this site as even though part of the site is an existing industrial site, the proposal also includes some greenfield undeveloped land.If this site was allocated consideration would be required to mitigation to reduce any impacts on residential amenity of site operations and access.This is an existing industrial estate so whilst this would involve the loss of B class employment land/jobs, proposals could also create new jobs.

Any increase of traffic in Newington could negatively impact the AQMA. Swale Borough Council declared an Air Quality Management Area (AQMA) number 1 in Newington in March 2009 and this specifically covers the A2 road through the village. The AQMA was declared as a result of monitoring the air quality which was found to exceed the Air Quality Objective for Nitrogen Dioxide (NO 2 ).This is primarily due to the pollutant being emit- ted by motor vehicles using the constricted High Street. The outcome of work carried out is that source appor- tionment for the pollutant NO 2 shows that heavy goods vehicles make a significant contribution and the Coun- cil is committed to reducing the pollutant, and hence the number of vehicles, particularly HGVs that use the road. If either of these sites were to come on stream as suggested in the framework, the lorry movements through the village of Newington which need to serve the sites will be completely unacceptable, considerably worsening the air quality to local residents. Parish Councils Newington PC-Object- Newington High Street is the subject of a AQMA. the junction of the A2 with Bull Lane, if not the narrowest, then it is one of the narrowest points on the whole of the A2 from Dover to London. It is not possible for a HGV and a small car to pass each other at this point

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 37 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Utility Companies Southern Water: Strong planning policies will be required to protect underground sewers and/or water mains at the site. Within SWS wastewater area. SWS wastewater infrastructure crossing site. Within SWS supply area. SWS water supply infrastructure crossing site.

Heritage The proposal site lies adjacent to the A2 Watling Street which has its origins as the main London to Dover road in Roman times. The Roman road alignment is generally considered to fall to the south of the present line and may cross the site. Roman and later activity including cemetery sites is often found flanking the road. Brickearth deposits in the area may contain remains of Palaeo- lithic and Mesolithic date. Palaeolithic hand axes have been found north east of the site in New- ington.

The site has been in places previously quarried and developed though the full extent of impact from this is presently not assessed. Biodiversity UK protected species within site. European and Local protected species within 1km. Highways HGV capacity-unlikely to present too many issues, depending on the scale of the operations. It should be noted however, that Newington Air Quality Management Zone exists. Planned Develop- ments-Spade Lane, Upchurch- Expansion of existing B2/B8 commercial site. Kent Wildlife Trust No objections to the development of this site for the recycling and storage of waste.

RSPB We encourage restoration to biodiversity on this site, for example species rich grassland could be created. Should the restoration be to an industrial estate as proposed, biodiversity should still be included, for example by including ponds. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: development of the site is limited to the boundary of the existing industrial area; conditions are put in place to control HGV traffic movements through Newington; the route of the public Right of Way crossing the site is re- aligned to the site perimeter conditions are put in place to minimise or negate impacts on neighbouring residents. General Public Responses -Inadequate roads- lorries will not be able to pass each other along Newington High Street. -Air pollution- Already very high along High Street -Noise, smell and Dust impacts on residents - Vibration from HGV’s -Currently used for grazing horses -Will have a negative impact on local businesses -Close to Badgers Setts-protected under the Badger Protect Act 1992

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 38 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 14

Longfield Farm, Paddock Wood Support 0

8.3 This is an existing waste site for car breaking and Comment 2 Responses metal recycling. The site is promoted as a proposal to build a recycling centre for sorting of skip waste from construction projects and domestic skips from with 10- Object 2 15mile radius. 00.511.522.5

Responses District/Borough Paddock Wood Town Council - Paddock Wood Town Council is concerned that this proposal may impact on the adjoining residential properties with increased vehicle movements and an increase in dirt and dust.

Utility Companies Southern Water-Not assessed as outside supply area Heritage There are no known archaeological remains in the area of this site other than the late medieval building at Lit- tle Old Hay to the immediate south of the site. The site has been in use as a scrap yard which would have caused an impact on archaeology present.

Little Old Hay is a Grade II Listed Building. Biodiversity EPS, UKProtect, Local and LocalSite protected species within 1km of site.

Kent Wildlife Trust No objections to the conversion and extension of this site to a recycling centre. There is a woodland block adjacent to the site which though not ancient in origin is likely to be important for wildlife within the area. This should be preserved and buffered within the design of the recycling plant. Protect Kent Acceptable, subject to a more detailed assessment.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 39 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility General Public Responses Affect the quality of life of local residents. Detrimental affect on the local countryside and wildlife.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 40 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 20

Tovil Recycling Support 0

8.4 This site has been proposed for materials recycling Comment 1 Responses facility and transfer station for inert commercial and industrial waste and construction and demolition waste. The site will accept skip waste from Maidstone and sur- Object 3 rounding areas. 01234

Responses District/Borough Maidstone - The Council has already objected to development at this site on the basis that in the absence of evidence to the contrary, the noise generated by plant, machinery and general working on the site is likely to cause significant harm to the residential amenities of the occupants of the proposed dwellings to the north west of the site. The Council has also previously expressed concerns that the local highway network (particularly Straw Mill Hill and its junction with Tovil Hill) is not adequate to deal satisfactorily with the additional traffic this site would

Parish Councils Tovil - Objection is raised to site 20 at paragraph 8.4.in Tovil. The report itself refers to constraints related to air quality and amenity. In addition there is no compelling need and the allocation of the site appears to conflict with emerging policies in particular DM1, DM8, DM10 and DM17. Utility Companies Southern – Not accessed as outside supply area. Within SWS wastewater and wastewater infrastructure crossing zones. Heritage The proposed waste site appears to be located entirely within a former quarry which dates back to the late 19th and early 20th century. During quarrying a Romano-British burial ground was discovered to the immediate north west of the site. The sandstone deposits in this area have the potential to contain Palaeolithic fissure sites. Evidence of these may survive in the edges of the quarry. Industrial archaeological remains associated with the quarry works may survive within the site although the site has been heavily developed since quarrying.

The Loose Valley Conservation Area lies immediately east of the proposal site. A number of Listed Buildings lie within the Conservation Area including Upper Crisbrook Mill and Hayle Mill. The full re- Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Biodiversity UkProtect protected species located within site. EPS, Local and LocalSite protected species located within 1km of site. Highways highways issues were considered, and concluded that there were no objections, subject to appropriate conditions being imposed. These included improvement to the site access junction with Straw Mill Hill and a new footway/cycle way. A cap on the total annual throughput (as suggested by the applicant) was also conditioned. The various conditions would ensure that the development could deal with highway and safety issues. Details of the improvements were attached to the documents that were submitted to the KCC Planning Committee. There is no highway capacity objection. Kent Wildlife Trust No objections to the conversion and extension of this site to a recycling centre. There are woodland blocks incorporated within the boundaries of site which are part of a wider complex. This habitat is likely to be important for wildlife within the area and should be preserved and buffered within the design of the recycling plant. Protect Kent Rejection recommended, due to: the potential adverse impacts on neighbouring residents, especially from the MRF; the impact of increased HGV traffic along narrow roads in Tovil.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 42 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 27

Otterpool Quarry, Sellindge Support 0

8.5 The County Council is currently considering a plan- Comment 4 Responses ning application for an anaerobic digestion facility and materials recycling facility will be takei co-mingled recy- clables primarily from commercial and industrial waste. Object 0

012345

Responses Parish Councils Upchurch - In the list of Exiting Mineral Sites in Kent Subject to Periodic Review can be found Otterham Brick- works, Otterham Quay. This is the waste fill site to the south of Canterbury Lane and West of Seymour Road. The site is listed as a dormant site for Mineral Extraction. The consultation document gives this detail for information only.

Utility Companies Southern Water – Not accessed, as outside supply area. Within Wastewater area.

Heritage The proposed waste site falls within a disused quarry. The surroundings of the quarry are archaeologically sensitive with remains dating from the prehistoric through to World War II Lympne Airfield in the local landscape. Within the quarry, which dates back to the early 20th century the archaeological potential will have been removed though there is some potential for Palaeolithic fissure sites within any exposed quarry edging.

The nearest Listed Buildings are close by at Otterpool Manor just to the west of the proposal site. Another lies to the south at Upper Otterpool and a third north at Railway Cottages. The nearest Scheduled monument is some distance away at Westenhanger Castle Biodiversity UKSite located within site. EPS, UKProtect, Local and LocalSite located within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 43 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Kent Wildlife Trust No objections to an anaerobic digester and recycling facility on this site. This site is adjacent to Otterpool Quarry SSSI designated for its geological importance. The SSSI should be protected from harmful impacts. Kent Down AONB The site would contribute to waste materials recycling and anaerobic digestion of biomass material. The site is a previously worked site with good access to the A20. There are adjacent constraints to the site with a Site of Special Scientific Interest, which would warrant consideration to mitigation of any adverse impacts on biodiversity.

Protect Kent Planning approval has already been given for this site; permission may be issued before the Core Strategy. Kent Downs AONB This is in the setting of the KDAONB and only put forward due to its previous use and a mineral extraction site. The KDAONB object to this use of the site which will jeopardise final restoration in an area not allocated for industrial development in the LDP.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 44 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 51

Ridham Support 1

8.6 The site currently has planning permission for an in- Comment 4 Responses vessel composting facility, a materials recycling facility, aggregates recycling, a biomass combined heat and power boiler. The operator is considering Anaerobic Di- Object 1 gestion in conjunction with the existing In Vessel Com- posting and the production of Refuse Derived Fuel (RDF)/Solid Recovered Fuel (SRF). 0246

Responses District/Borough Swale - The Council has no objection to this site as long as mitigation for the adjacent SPA/RAMSAR is adequate. Access to the A249 would need to be considered and modelled.Consideration should be given to bringing in the waste by rail.

Parish Councils Iwade – Object. Ridham Dock is once again identified in this document as an area for waste disposal/ recycling. Iwade Parish Council has grave concerns that Ridham Dock is becoming the main dumping ground for rubbish in Kent; with an increasing number of waste facilities being located in this environmentally sensitive area. To date we have the approved Eon Incinerator at Kemsley Mill; the already operating incinerator at the same Mill; the Countrystyle Biomass Burner; the proposed Evonik Biomass Burner; SITA's proposed recycling plant at Building 15B; Knauf's Gypsum plant (we suffer the fall out from the white dust) and the car fragmenta- tion plant. At one time there was mention of attracting clean industry to Ridham, to provide employment and encourage people to purchase the nearby new housing at Iwade and Kemsley Fields but this has never come to fruition. Of equal concern is the A249, which is already having problems with the large amount of lorry movements. We note that Highways argue that they can see no issues with this roadway, but our Borough and County Councillors agree that the A249 is fast becoming congested with traffic and it wont be long before it is unable to cope with the sheer volume. Utility Companies Southern Water – No Proximity to Source Protection Zones. Within SWS wastewater and water suppler area.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 45 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Heritage The proposed waste site lies in an area that has been reclaimed from marshland in the last century. Archaeo- logical remains associated with the exploitation of the marshlands from prehistoric times and from the use of Milton Creek, including wrecks, could lie buried within alluvial deposits on the site. The site has been developed and remains are likely to be buried at depth. Parish Councils Upchurch - In the list of Exiting Mineral Sites in Kent Subject to Periodic Review can be found Otterham Brickworks, Otterham Quay. This is the waste fill site to the south of Canterbury Lane and West of Seymour Road. The site is listed as a dormant site for Mineral Extraction. The consultation document gives this detail for information only. Biodiversity UKProtect, Local and LocalSite protected species within site. EPS, EuroSite and UKSite within 1km of site.

Highways Depending on the number of HGV movements anticipated, the local highway network is likely to be able to accommodate this site. Once the Sittingbourne Northern Relief Road creek crossing is opened, significant traffic movements may have an impact on the operation of the junctions along Barge Way and Swale Way, including the junction with the A249, which is likely to be at capacity during the peak periods.

Sittingbourne Northern Relief Road will link Swale Way from Kemsley through Church Marshes to Castle Road, including Creek Crossing. Planned Developments – Kemsley Fields development area and Ridham Dock, including power plants. Biodiversity UKSite located within site. EPS, UKProtect, Local and LocalSite located within 1km of site. Natural England Adjacent to Swale SPA, Ramsar and SSSI. The site already has permission for a biomass CHP unit. Kent Wildlife Trust This site is adjacent to the Swale SPA, Ramsar and SSSI. Within the HRA, impacts on the European designations due to runoff or emissions should be investigated and Natural England consulted before the site is allocated. Kent Wildlife Trust has no objection to waste facilities on this site provided all impacts are mitigated. There is open water preset on site that is likely to contribute to the habitat of the Ramsar site. This should be protected and buffered within any development. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: impacts on the adjacent nature conservation designations are understood and mitigated for.

Kent County Council Waste Support Management

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 46 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 52

Weatherlees Support 1

8.7 The operator has two sites to the south of this site; Comment 1 Responses one existing and one proposed site. This site would be allocated for potential further expansion of existing operations and new waste treatment technologies to drive Object 4 up the hierarchy later in the plan period. 012345

Responses District/Borough Thanet- Current planning application for change of use to a solar park. The land is not allocated for development in the adopted 2006 Thanet Local Plan. It is in a Landscape Character Area and Wantsum Flood Risk Area. It is close to the route of East Kent Access Road improvement scheme. Also in close proximity to Richborough Power Station and adjacent to Weatherlees Wastewater Treatment Works.

Sandwich - The council is aware that permission to erect solar array panels at the northern end of this site has already been agreed. There are concerns that emissions to air and water from the proposals will affect the performance and surface of these solar panels and will infringe the human rights of the owners. The Sustain- ability Appraisal is supported, particularly in relation to the adjacent SSSI and Ramsar sites, Special protection Area and Nature Reserve. The area is also on a flood plain Utility Companies Southern Water-Object- On the grounds of proximity to its waste water treatment works, unless appropriate planning policies can be agreed which protect the works and safe guard their continued operation and future expansion. Biodiversity UK and Local protected species within site. European protected species, Euro, UK and Local designated site within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 47 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Heritage The proposed waste site lies in an area of considerable archaeological potential relating to known discoveries close-by of Neolithic, Bronze Age, Iron Age, Roman and medieval date. In particular substantial excavations on the adjacent East Kent Access Road development revealed remains of a Neolithic / Bronze Age monument, evidence of Bronze Age settlement, an Iron Age enclosure and two medieval farmsteads, one of which extends towards the proposal site. The archaeology is mainly focused on the higher land immediately east of the site which forms the spine of the Ebbsfleet peninsula which once extended into the mouth of the Wantsum sea channel. The present site is sited on land that has been reclaimed from the Wantsum since medieval times. Archaeology, including well preserved organic remains associated with the use of the sea channel and its subsequent reclamation of the land may be found buried with alluvial deposits. Natural England The site is adjacent to Sandwich Bay to Hacklinge Marsh SSSI, and close to Sandwich Bay Special Area of Conservation (SAC), Thanet Coast and Sandwich Bay SPA and Ramsar Site. Natural England has concerns that this area is coming under increasing pressure from commercial activities. There are plans for an energy park on the Richborough Power Station site as well as waste processing. With no firm proposals for this site it is difficult to assess the impacts. However, if this is taken forward the Council will need to consider the in- combination impacts that these sites will have on the interest features of the protected sites. Any application should be accompanied by an HRA under the Conservation of Habitats and Species Regulations 2010. Kent Wildlife Trust As stated within the SA this site is adjacent to Sandwich Bay to Hacklinge Marshes SSSI designated for its habitats, rare flora and fauna and migratory bird populations. It is within very close proximity to the Sandwich and Pegwell bay NNR, the Thanet Coast and Sandwich Bay SPA and Ramsar site. National Trust The location of this site in close proximity to the Pegwell / Sandwich Bay SSSI / SPA / SAC/ Ramsar site is such that further assessment is required to establish the likely extent of environmental impact and the scope for mitigation, prior to any allocation being made in the plan. RSPB This site is adjacent to Sandwich Bay to Hacklinge Marsh SSSI and is near the Thanet Coast and Sandwich Bay SPA/Ramsar site. As such we agree with the conclusion of the Sustainability Appraisal that this site "will warrant consideration to any impacts on biodiversity". Consideration of impacts will need to be given to not only this site, but to this site in combination with the existing Thanet Waste Site, the proposed site North of Stevens and Carlotti. (site 65 below) and Richborough Underground Limestone Mine (crushed rock site 78). A restoration plan should be proposed to restore this site to grassland which complements the adjacent SSSI. Operator/Owner Lee Evans Planning- We support the allocation of the land adjoining Weatherlees Waste Water Treatment Works for development for waste related uses as set out in the representations submitted by ourselves in Oc- tober 2010 General Public Responses Damage to environment Bird migratory route

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 48 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 59

Shelford Waste Management Facility Support 1

8.8 This site currently comprises of an engineered land- Comment 2 Responses fill for non-hazardous waste, inert recycling centrem composting facility, power generation plant utilising the landfill gas and has planning permission for a materials Object 3 recycling facility. The site has been promoted for further, non-specific waste uses. 01234

Responses District/Borough Canterbury City Council - No details are provided to enable appraisal of any future changes to the site at this stage or the potential cumulative impacts. However, since this is an established waste facility, the Council has no objection to it proceeding through this process, although further consideration will be required once further details of expansion are known. Proposals on this site need to pay particular attention to any impact on local landscape character and or role, and minimisation of the impact of the landfill use on nearby residential properties. The existing activities have already had a significant impact. Further, existing traffic movements are a significant issue in the Canterbury area and in particular Broad Oak. There is potential archaeological interest on the site, and there is ancient and semi ancient woodland both on the site and adjacent to it. No further damage should be permitted. The Little Hall and Kemberland Wood and Pasture LWS is located on the site, and West Blean and Thornden Woods SSSI is located north and east of the site. These constraints need to be recognised in the sustainability appraisal. Utility Companies Southern Water – Not accessed as outside supply area. Within SWS wastewater area. Entec - National Grid does not object to the proposals outlined, however the following points should be taken into consideration. National Grid does not own the land over which the overhead lines cross, and 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.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 49 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Heritage Important archaeological remains of prehistoric, Roman and Saxon date have been investigated in areas of Shelford Quarry. Any proposals involving works in unquarried areas will require archaeological measures. An area of potential Saxon cemetery on the eastern side of the quarry is particularly sensitive.

The Allcroft Grange Conservation Area lies immediately adjacent to the proposal site to the north west and includes a small area that falls within the site. The Tyler Hill Conservation Area lies to the north west. The Sturry Conservation Area lies immediately to the south east of the proposal site. Biodiversity EPS, UKProtect, Local, and LocalSite protected species within site. UkSite protected species within 1km of site. Kent Wildlife Trust Site is adjacent to West Blean and Thornden Woods SSSI designated for its ancient woodland which is an integral part of the wider Blean Complex which includes SAC designations. The SSSI supports an outstanding population of birds, rare invertebrates and a breeding population of hazel dormouse. Site 59 incorporates part of Little Hall and Kemberland Woods and Pastures LWS designated for its ancient woodland and biodiverse grassland. There are no details within the document regarding the waste uses planned for this site. If this was to include further landfill it would lead to the direct loss of ancient woodland incorporated within the LWS and would be likely to have a detrimental impact on the hydrology and health of the adjacent SSSI. It is Kent Wild- life Trust’s view that further details are required regarding the proposed waste uses on site before allocation is considered. If such uses will lead to either direct loss of the ancient woodland contained within the site boundary or damage to the habitats within the SSSI either directly or indirectly through changes in hydrology or emissions we would object to the allocation of this site. National Trust This site contains Shelford/Beecham, Childs Forstal Wood. Further expansion would cause additional loss of and damage to ancient woodland. Protect Kent Rejection recommended, due to: the number of unknowns about this site; the lack of clarity on specific uses; the lack of detail on the proposed materials recycling; existing difficulties with road access; impact on landscape; impact on neighbouring residents; impacts on public rights of way; inclusion of ancient woodland

Woodland Trust There are a number of minerals and waste sites that have ancient woodland within their boundary. These sites should not be taken forward as they result in the loss of and damage to ancient woodland. These sites are as follows: Kent County Council Waste KCC (Waste) fully supports the proposal to expand the waste uses at the site. However good technology be- comes overtime in reducing the amount of material that needs to go to landfill there will likely be a need for Management this basic level of disposal for some time yet.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 50 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 63

Pinden Quarry Support 0

8.9 This is an existing chalk extraction and asbestos Comment 4 Responses landfill site. The site has been submitted for expansion and to develop a materials recycling facility and transfer station. This site can also be found in Chapter 6: Haz- Object 5 ardous Landfill and the Minerals Sites DPD.

0246

Responses District/Borough Dartford- Site is within Green Belt, Area of Archaeological Potential, Windturbine Development Safeguarding. Subject to HSE Inner Consulation Area of Transco Pipelines and HSE Middle Consultation Area of Transco Pipelines. National Grid Transition Gas Pipeline Consultation Zone. Smoke Control Order-Bean. Public Right of way on Western Boundary.

There is no evidence that additional capacity beyond that already consented needs to be identified. The Min- erals Topic Report 3: Other Minerals, May 2011 identifies need for up to 1,135,000 tonnes of agricultural chalk and 945,000 tonnes of chalk for engineering and construction uses, which together provide an estimated need for 2,080,000 tonnes over the plan period The Topic Paper shows that there is a reserve of consented agricultural chalk of 2.422 million tonnes, and at paragraph 4.2.4 states that this is a conservative estimate and is far in excess of anticipated requirements for agricultural chalk. Thus there is more than adequate supply to meet need The Topic Paper sets out that at 1st January 2011 there was an estimated reserve at Pinden of 1.28 million tonnes. Of the permitted reserve figure over half (53%) is at Pinden Quarry. There is therefore no justification for identifying Pinden Quarry for more agricultural chalk extraction. Parish Councils Southfleet-Object The Parish Council considers the inclusion of the Pinden proposed future options in the Kent MWDF to be detrimental to the future of the surrounding area for the reasons given above; and asks KCC that they not be included.

New Barn East-Object -Would create too many lorry movements, Would have a detrimental impact on local lanes and villages-Impact many residential properties.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 51 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Utility Companies Amec UK Ltd-National Grid- The site is located within close proximity to one of National Grid’s high pressure gas transmission pipelines.

Heritage Bronze Age, Iron Age and Roman remains have all been found during past investigations at Pinden Quarry. Remains include evidence of Roman occupation and burials.

As development could potentially affect buried archaeological deposits a programme of archaeological works should be implemented in advance of development. Biodiversity UK and Local protected species and local designated site within 1km.

Kent Wildlife Trust This site is adjacent to Disused Railway Cutting Longfield LWS. However the LWS 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 KLIS shows that the proposed extension is within woodland. Although not ancient in origin it will be important to endeavour to preserve as much of this habitat within the proposal and any lost should be replaced either within the locality or as part of the restoration plan. RSPB It would be important to ensure there were no negative impacts on the adjacent local wildlife site (SNCI), including hydrological impacts. Restoration of this site should complement the adjacent local wildlife site. This site is near the Thames-side Green Corridors BOA, which recommends restoration to acid grassland,

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 52 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 64

Richborough Hall Support 5

8.10 This is an existing site permitted as an integrated Comment 5 Responses waste management centre. A recent planning application has been submitted to the County Council to refur- bish the site for a new materials recycling facility build- Object 2 ing. 0246

Responses District/Borough Thanet - Concern is raised regarding potential damage to the nearby internationally designated habitats and the perception of Thanet as an attractive destination both in terms of tourism and economic investment. Ve- hicle movements are of particular concern.

Dover - Support the use of this site subject to direct and indirect detrimental impacts on the environment and community.The current Area Specific policy AS14 in the saved Dover District Local Plan also indicates that any new development should visually upgrade the A256, all new buildings should be low rise, does not increase the risk of flooding and provision is provided for archaeology. These should be considerations for any new allocation/policy. Sandwich - There are no objections to the proposals for this site. Thanet Waste Services is currently manag- ing the site well. The Sustainability Appraisal is sound and is supported.

Utility Companies Southern Water – No Proximity to source protection zones. Within Wastewater, wastewater infrastructure crossing water supply areas.

Heritage The main archaeological potential of this site lies in the alluvium deposits of the former Wantsum Sea Channel and the process of its reclamation. A programme of geoarchaeological assessment was carried out with the recent development of the site. Archaeological works may be appropriate dependent upon the form of further development. The site may lie within views from Richborough Castle, a Scheduled Monument and important historic tourist attraction.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 53 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Kent Wildlife Trust Manages much of this wider area and would be concerned regarding the impacts of an extended waste site within this locality. The coastal marshland habitats present and the species which inhabit them are sensitive to pollution and changes in hydrology. Any decrease in water quality would not only affect the habitats present but could impact on food availability for and cause disturbance to migratory birds as well as being deleterious to the rare flora and fauna species known to occur on site including the recently released sand lizard and nat- terjack toad population. Project Kent Acceptable, subject to a more detailed assessment. RSPB Site is situated approximately 100m from Thanet Coast and Sandwich Bay SPA/Ramsar. Any development in these locations therefore has the potential to adversely affect the important habitats and species for which the sites have been designated. Therefore, each of these sites needs to be carefully considered as part of the HRA.

We consider that at this stage in the plan-making process sites which lie in close proximity to European protected sites are likely to impact important elements of biodiversity. As such, and prior to an assessment under the Habitats Regulations demonstrating no adverse effect on the nearby European sites, we consider these sites do not meet Sustainability Objective 2: “Ensure that development will not impact on important elements of the biodiversity resource. Lee Evans Planning A new MRF building is to be constructed on Site A - the existing Richborough Hall site - following the relo- cation of the Inert Materials Processing Activity to Site B - land north of Stephens and Carlotti.

The Inert Materials Processing Facility will be supplemented by a Soil Washing Facility and an Anaerobic Digestion Plant to deal with green and food waste.

The potential environmental impact of the development proposals was assessed through the Environ- mental Impact Assessment undertaken as part of the Planning Application.

The decision to grant Planning Permission acknowledges that technical and environmental issues can be appropriately dealt with in the developments. General Public Responses Objections due to sites numerous orchids Site located on a large bird migratory route.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 54 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 79

Tilmanstone Works Support 1

8.11 This is the site of a former brickworks. The site is Comment 1 Responses proposed as an expansion to the operator's existing and proposed site in the area. It is unknown at this stage Object 2 what the site will be used for, is it therefore being considered for a variety of waste uses. 00.511.522.5

Heritage The proposed waste allocations site lies in an area rich in archaeology. The majority of the site is formed by the spoil tip of the former Tilmanstone Colliery, the deposits of which are a RIGS site. The north west quarter of the site is undeveloped and would retain considerable archaeological potential. The surrounding area is rich in buried archaeology which can be seen on aerial photographs as crop mark sites. In particular a significant set of enclosures and trackways lies immediately south west and other crop marks in the area include the traces of Bronze Age barrows. Remnants of the East Kent Light Railway cutting survive crossing the northern part of the site. Biodiversity European, UK and Local protected species and Local designated site within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 55 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Kent Wildlife Trust Kent Wildlife Trust has no objections to an aggregate recycling plant on this site.

Project Kent Object- Rejection recommended, due to: the number of unknowns about this site; the lack of clarity on specific uses; its distance from likely sources of waste; its proximity to the village of Elvington; the possible impact on the public right of way along the southern boundary of the proposed site; the majority of the site being a Regionally Important Geological Site RSPB RSPB- We would encourage restoration of this site to biodiversity, for example to woodland to complement the nearby Ancient Woodland.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 56 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 88

Sevington Recycling Depot Support 1

8.12 The site is currently utilised as a construction and Comment 3 Responses demolition waste recycling facility. The site has been promoted for a variety of waste uses including anaerobic Object 0 digestion, energy from waste and mechanical biological treatment facility. 01234

Responses Utility Companies Not assessed, as outside supply area. Within Wastewater area. Heritage The proposal lies in an area with high archaeological potential with buried archaeological remains of prehistoric, Roman and medieval date known to lie in the area of the site and the surroundings. In particular an area of Middle Bronze Age cemetery and settlement has been recorded at Waterbrook Park within the site. An area of Late Iron Age settlement has been recorded in the north part of the site.

A Scheduled Monument, the Boys Hall moated manor lies to the west of the proposal site and a Listed Build- ing at Imber to the immediate east. .

Past development is likely to have had a heavy impact on potential archaeology over most of the site though there may be limited areas, particularly on the fringes of the site that have not been disturbed. Biodiversity EPS, UKProtect protected species within site. LocalSite protected species within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 57 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Highways The access to this site is assumed to be from Cheesmans Green Lane. The narrow width of this lane and the sharp bends on this section are cause for concern, therefore more information is required on expected HGV movements and access requirements.

There are planned improvements to the A2070 as a result of the proposed. Further details can be found under the planning application (10/00672/AS) for the Cheeseman’s Green Development to the west of the site. This will result in improvements to Waterbrook roundabout which will result in increased capacity. A 40mph speed limit is also proposed at the roundabout to reduce vehicle speeds here.

The Cheeseman’s Green Development of approximately 1,100 houses will be paying towards to costs of the improvements works on the A2070 and the Waterbrook roundabout. Kent Wildlife Trust No objection to a construction and demolition waste recycling facility on this site. However this area is already being heavily impacted by development planned within Ashford. South Willesborough Dykes LWS is being impacted by large housing developments which will increase recreational pressure and infrastructure projects such as pipelines which will cause direct habitat loss. Site 88 and Waterbrook Park site 28 contain a complex of ditches which ultimately feed into the South Willesborough Dykes LWS. It will be important that any in combination impacts between these two sites are assessed alongside plans within the Ashford Local Plans and large infrastructure projects. The ditch network should be conserved and enhanced and the water quality should not be impacted by the recycling processes planned. In mitigation for any impact due to loss in water quality on the LWS we recommend that a financial contribution be made to one of the restoration projects being set up within the area.

We are also aware that there is a good population of great crested newts who use the Waterbrook site and therefore are likely to use Site 88 as well. Regard will need to be given to their protection within any development planned. The site is adjacent to the railway line which is being enhanced as a result of a number of developments. As an important migratory corridor for the wildlife of Ashford it is important that this linear feature is buffered and hedgerow and long grass habitat created along its length. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the proposed uses are clarified; compatibility with Ashford Growth Area proposals are understood; impacts on public rights of way are mitigated for.

Kent County Council Waste KCC (Waste) Recognise the potential for this site and this location given the nature of the current use and Management proximity to the local Highway infrastructure.

Operator/Agent Traffic generated from this facility would be, on average, 18 loads per day, making 36 daily lorry movements. However, the site has the benefit of an existing fail siding, therefore waste materials could be brought to the site from further afield without having an impact on the local road network.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 58 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 23

Blaise Farm Support 1

9.1 The site currently has a temporary planning permis- Comment 3 Responses sion for an anaerobic digestion facility for 100,000 tonnes per annum of non-hazardous waste until 2028. The proposed development for a small-scale renewable en- Object 1 ergy electricity generating instillation utilising material from biological treatment process has also been submitted as a planning application. 01234

Responses District/Borough TMBC – The site lies within the MGB and open countryside. The site also lies adjacent to a LWS. This site currently has a temporary permission for an anaerobic digestion facility for 100,000 tonnes per annum of non- hazardous waste until 2028. The proposed development for a small-scale renewable energy electricity generating installation utilising material derived from biological treatment process has also been submitted as a planning application. Utility Companies The proposed waste management facility lies in an area with a background potential for archaeological remains and in particular remains of prehistoric date. The remains of a medieval chapel lie just to the north of the proposal site and this is protected as a Scheduled Monument. The quarry has a potential for Palaeolithic fissure sites within the Ragstone bed rock. Biodiversity LocalSite protected species within site. EPS, UKProtect, Local protected species within 1km of site.

Highways HGV Route along A228. No planned highway improvements. Proposed improvements within Kings Hill that will increase vehicular traffic.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 59 Kent County Council—Waste Sites Options Commentary Report

9 Composting Kent Wildlife Trust Site is adjacent to Mereworth Woods designated for its ancient woodland habitat. It will be important to ensure that there is no direct or indirect impact on the woodland when considering the proposed uses for this site. Emissions from anaerobic digesters can damage ancient woodland flora with increases in sulphur emissions and decreases in air quality leading to the death of rare lichens and ground flora which are an integral part of the ancient woodland structure. Within the design of the development increases in emissions and decreases in air quality should be limited as much as possible with any residual impact on the adjacent habitats being mitigated and compensated. Kent County Council Waste Fully support the operation of this site. Currently about 25% of contracted green/food waste is directed to this Management facility.

General Public Responses Concerned with traffic and infrastructure damage. Noise and Light pollution

Aquifer pollution

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 60 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 52

Weatherlees Support 1

012345

Responses

District/Borough Thanet- Current planning application for change of use to a solar park. The land is not allocated for development in the adopted 2006 Thanet Local Plan. It is in a Landscape Character Area and Wantsum Flood Risk Area. It is close to the route of East Kent Access Road improvement scheme. Also in close proximity to Richborough Power Station and adjacent to Weatherlees Wastewater Treatment Works.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 61 Kent County Council—Waste Sites Options Commentary Report

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 62 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Site 65

Land North of Stevens & Carlotti Support 4

9.3 This will be a mixed use site, working alongside the Comment 4 Responses current Thanet Waste site at Richborough Hall to the south of this site. This site will include an anaerobic digestion plant, an inert waste crusher and a screening Object 2 and washing plant. This site can also be found in the minerals sites DPD. 012345

Responses

District/ Borough Thanet- Concern is raised regarding potential damage to the nearby internationally designated habitats and the perception of Thanet as an attractive destination both in terms of tourism and economic investment. Vehi- cle movements are of particular concern. It is noted that an application for transfer and construction of expanded inert materials facility including soil washing plant and anaerobic digester plant has been granted on Land North of Stevens and Carlotti.

Sandwich- There are no objections to the proposals for this site. Thanet Waste Services is currently manag- ing the site well. The Sustainability Appraisal is supported.

Utility Companies Southern Water- Strong planning policies will be required to protect underground sewers and/or water mains.

Heritage As development could potentially affect buried archaeological deposits a programme of archaeological works should be implemented in advance of development. This can be secured through a condition on any consent. Development should consider and avoid any impact on the setting of Richborough Castle

Biodiversity UK and Local protected species within site. European, UK and Local designated sites within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 63 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility

Highways There is adequate HGV capacity available on the adjoining road network for this site. The site falls within the area included within the Kent Access Phase which is under construction just to the north of the land.

Natural England The site is close to Sandwich Bay to Hacklinge Marsh SSSI, Sandwich Bay SAC, Thanet Coast and Sandwich Bay SPA and Ramsar Site. Concerns that this area is coming under increasing pressure from commercial activities. There are plans for an energy park on the Richborough Power Station site as well as waste processing. The development of this site would create a built barrier between the SPA, SAC and Ramsar and the Ash Levels and Richborough pasture LWS that potentially could be supporting SPA bird species. If the Council would need to consider the in-combination impacts of the various proposed sites. Any application should be accompanied by an HRA.

RSPB This site is in close proximity to the Thanet Coast and Sandwich Bay SPA/Ramsar site, the Sandwich Bay SAC

The National Trust The location of this site in close proximity to the Pegwell / Sandwich Bay SSSI / SPA / SAC/ Ramsar site is such that further assessment is required to establish the likely extent of environmental impact and the scope for mitigation, prior to any allocation being made in the plan.

Kent Wildlife Trust As stated within the SA this site is adjacent to Sandwich Bay to Hacklinge Marshes SSSI designated for its habitats, rare flora and fauna and migratory bird populations. It is within close proximity to the Sandwich and Pegwell bay NNR, the Thanet Coast and Sandwich Bay SPA and Ramsar site. This site also is designated as an SAC. The habitats are sensitive to pollution of the coastal and marshland habitats and the species which inhabit them. Any decrease in water quality would not only impact on the habitats present but could impact on food availability for and cause disturbance to migratory birds as well as the rare flora and fauna species. We are already very concerned regarding the in combination impacts on Sandwich and Pegwell Bay from recreational pressure and habitat destruction. KWT do not feel that these sites can tolerate any further pressure and therefore objects to any development within the locality likely to have an impact on the habitats and species. KWT is particularly concerned regarding the in-combination impacts of this development with the plans for sites 54, 64 and 52. It will be important within the HRA that impacts be thoroughly assessed. If impacts cannot be mitigated then we recommend that this site be excluded from the plan. This site is also adjacent to Ash Level and South Richborough Pasture LWS. There is an extremely rich biodiversity on site. We would object to any development that impacts on this.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 64 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 79

Tilmanstone Works Support 1

9.4 This site is a former brickworks. The site would be Comment 1 Responses viewed as an expansion to the operators existing and proposed sites in the area. It is unknown at this stage what the site will be used for, it is therefore being con- Object 2 sidered for a variety of waste uses. 00.511.522.5

Parish Council Tilmanstone - I note that the operator of the proposed site has yet to give any information concerning their proposed use therefore it is impossible for the local community to voice any objection or indeed support for the project. Without the necessary information how can we as a community take part in your 'consulation' what assurances do we have that you will not go ahead without having our views if the operator deliberately delay their response on information. This would make a nonsense of the ' consultation process'. Utility Companies Southern Water-Strong planning policies will be required to protect underground sewers and/or water mains.

Heritage The proposed waste allocations site lies in an area rich in archaeology. The majority of the site is formed by the spoil tip of the former Tilmanstone Colliery, the deposits of which are a RIGS site. The north west quarter of the site is undeveloped and would retain considerable archaeological potential. The surrounding area is rich in buried archaeology which can be seen on aerial photographs as crop mark sites. In particular a significant set of enclosures and trackways lies immediately south west and other cropmarks in the area include the traces of Bronze Age barrows. Remnants of the East Kent Light Railway cutting survive crossing the northern part of the site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 65 Kent County Council—Waste Sites Options Commentary Report

9 Composting Biodiversity European, UK and Local protected species and Local designated site within 1km.

Kent Wildlife Trust Kent Wildlife Trust has no objections to an aggregate recycling plant on this site. Project Kent Rejection recommended, due to: the number of unknowns about this site; the lack of clarity on specific uses; its distance from likely sources of waste; its proximity to the village of Elvington; the possible impact on the public right of way along the southern boundary of the proposed site; the majority of the site being a Region- ally Important Geological Site. RSPB We would encourage restoration of this site to biodiversity, for example to woodland to complement the nearby Ancient Woodland.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 66 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 82

Milton Manor Farm 2 Support 1

9.5 This site is located to the south of the existing min- Comment 3 Responses eral processing plant. The proposed site would be used for the composting of mixed green organic waste sourced from Canterbury. Object 0

01234

Responses District/Borough Canterbury City Council - Overhead electricity lines cross this site. The Great Stour, which runs alongside the site, is designated LWS (Great Stour: Ashford to Fordwich). An assessment would need to be made relating to landscape impact of development, particularly when viewed from the northern valley side. The assessment presented in the consultation document, together with the sustainability appraisal, do not recognise nor consider these constraints. The Council must, therefore, object to the proposal at this stage.

There is a potential archaeological interest on the site which is situated in close proximity to a medieval manorial settlement, centred on Milton Manor and the Church of St John the Baptist. There is a potential for permanent loss of archaeological remains both from the setting up of a facility and its continued operation.

The City Council is also concerned about the impact on the adjacent Grade 2 listed Church of St John the Baptist and the impact on the setting of this building. The barn at Milton manor a little distance away is also Grade 2 listed. Utility Companies Southern Water – Not assessed, as outside supply area. Within Wastewater, wastewater infrastructure crossing and close so wastewater treatment works areas.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 67 Kent County Council—Waste Sites Options Commentary Report

9 Composting Heritage The proposed waste site lies in an area which has archaeological potential relating to the route of a Roman road just to the east, prehistoric, Roman and medieval finds in the general area including the remains of a Ro- man building to the south and the close proximity of St Nicholas Church, a 13th Century Grade II* Listed Build- ing. The church lies immediately north east and adjacent to the present quarry site and west of this site. A Listed barn can also be found on Milton Manor Farm to the north. The northern end of the proposed site takes in a strip of land that is depicted running between the road and the church on early historic maps. This is a potential historic landscape feature which potentially relates to the setting of the Listed Building.

The extent to which this site has been affected by previous works is unknown and it is assumed that significant archaeological potential is retained. Biodiversity EPS, UKProtect, Local protected species within site. LocalSite protected species within 1km of site. Kent Wildlife Trust This site is near to Larkey Valley Wood SSSI and LNR and the Great Stour (Ashford to Fordwich) LWS and is adjacent to Site 81 within the minerals sites document. In-combination impacts will need to be considered on both these sites. Larkey Valley Wood SSSI and LNR is designated for its woodland habitats which could be impacted indirectly by the recycling activities planned with possible impacts to the flora through neutrophication from runoff as a result of the recycling of green waste and emissions due to increased transport and the process itself. Any impacts will need to be identified and appropriate mitigation and compensation measures put in place to ensure no impact on the SSSI The Great Stour Ashford to Fordwich LWS is already heavily impacted by the development planned within the Ashford area and therefore a resilient set of guidelines are being developed as to how to protect the river corridor. Although Site 82 is unlikely to impact directly on the LWS there is a threat that runoff from the green recycling could cause harm to the water quality within the river system. It will be important within any permission granted to ensure that safeguards are incorporated within the design to ensure no runoff from the site. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: impacts on neighbouring environmental SNCI designations are fully understood and conditioned for in any permission. Operator/Agent The area of land shown on the identification drawing, will import in the region of 30,000 tonnes of green mixed organic waste for composting. The material source is expected to come from the district of Canter- bury City, but not restricted to Canterbury City. Traffic generated from this facility would be, on average, 15 loads per day, making 30 daily lorry movements. It expected that HGV's bringing green waste into the site for composting will also be utilised for taking composted material out of the site for delivery to construction/ landscaping projects in the locality.

As a member of the Mineral Products Association (MPA), Brett have been working with the Carbon Trust to develop and implement a carbon reduction programme in the aggregates and aggregate products sector. Carbon reduction has also been the focus of the work of the UK minerals forum. By providing a permanent green waste composting facility at this site, energy is not being wasted elsewhere on producing new raw materials, thereby reducing emissions and providing a sustainable re-use of green waste. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 68 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 83

Westbere Support 2

9.6 This is a restored former sand and gravel quarry. Comment 1 Responses The site is promoted for the composting of 30,000 tonnes of green mixed organic waste from Canterbury. Object 2

0 0.5 1 1.5 2 2.5

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 69 Kent County Council—Waste Sites Options Commentary Report

9 Composting Heritage This proposed waste site lies in an area with archaeological potential particularly relating to the adjacent Can- terbury to Thanet Roman road to the south and the finds of Roman and Saxon burials that have been made in the area close by. It is presently not clear as to whether this site has suffered from previous quarrying or development though the pond in the eastern part of the site suggests some workings.

The Westbere Conservation Area lies immediately south of the site. Biodiversity EPS, UKProtect, Local protected species within site. LocalSite protected species within 1km of site. Kent Wildlife Trust This site is within close proximity around 700m to Stodmarsh SSSI SAC SPA and Ramsar sites. As the designations largely relate to the wetland habitats within this sites and the rare flora and fauna using the habitats it will be imperative that strict safeguards are attached to any planning permission to ensure no impact on the habitats and species for which the site is designated due to neutrophication and habitat degradation. Within the HRA indirect impacts should be assessed with appropriate mitigation and compensation measures put in place for any impacts identified. Protect Kent Rejection recommended, due to: significant impacts on neighbouring residential areas, including nuisance caused by odours, vermin, insects, etc; impacts of traffic on the village and surrounding narrow roads; distance from sources of waste. Kent County Council Waste Support proposals that bring about sustainable increased capacity. Management Kent Downs AONB Relationship with final quarry restoration: the composting operation will extend the life of quarry to be permanent and challenge the final proposed afteruse of the site. Without this permanent use the major access could be restored and the whole site put back into a rural afteruse in the long term. There is no justification for a long term facility. Owner/Operator Brett Aggregates Ltd - The area of land shown on the above identfication drawing, will import in the region of 30,000 tonnes of green mixed organic waste for composting.

The material source is expected to come from the district of Canterbury City, but not restricted to Canter- bury City.

Traffic generated from this facility would be, on average, 15 loads per day, making 30 daily lorry movements. It expected that HGV's bringing green waste into the site for composting will also be utilised for taking composted material out of the site for delivery to construction/landscaping projects in the locality.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 70 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 84

Highstead, Herne Bay Support 1

9.7 This site currently has planning permission for quar- Comment 3 Responses rying with restoration to agriculture. The site is promoted for composting of recycled green mixed organic waste sourced from Thanet and Canterbury. Object 11

0 5 10 15

Responses District/Borough Canterbury City Council - The site is currently operating as a minerals site, but the proposal would contribute to composting facilities of organic waste from Thanet and Canterbury.

The majority of the site has been excavated and restored. There has been a previous permission for importation of inert material and restoration of land to agricultural use and the City Council would be unlikely to support anything beyond what has been previously consented. Consideration would also need to be given to the impact on Conservation Areas to the east and south - Upper Grounds and Highstead. There is likely to be a traffic impact on surrounding rural roads unless access is restricted to and from Thanet Way. Previously undis- turbed land may have archaeological interest due to the close proximity on the Roman Road. There may be an impact on adjacent agricultural production - orchards. The assessment presented in the consultation document, together with the sustainability appraisal, do not recognise nor consider these constraints.

Parish Council Herne and Broomfield - In the absense of any details about traffic movements and where these vehicles for the recycling centre will access from, especially those coming through from Canterbury. The parish council wishes to object to this proposal from Bretts.The village of Herne certainly does not want to see a significant increase in heavy lorries going to this site in Chislet and the Hoath road is also not a suitable option.

Bapchild Parish Council - Object

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 71 Kent County Council—Waste Sites Options Commentary Report

9 Composting Utility Companies Southern Water – Not assessed, as outside supply area. With wastewater and wastewater infrastructure crossing area. Heritage The proposed waste site lies in an area of considerable archaeological potential with important prehistoric and Roman finds having been recorded within the site and the surrounding landscape. The site itself has undertaken a programme of quarrying and archaeological investigations carried out in conjunction with those works have recorded important remains of Bronze Age, Iron Age and Roman date. While the majority of the site has been worked, removing the archaeological potential, there may be areas that have survived the workings.

The Under the Wood conservation Area lies immediately to the east of the proposal site and other Conserva- tion Areas occur to the south at Hoath and Highsted.

Kent Wildlife Trust We have no objections to the siteing of green organic waste facility on this site. There is a strip of woodland along the western boundary of the site which should be protected from any indirect impact and buffered. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the area used for recycling 'green' waste is better delineated; this area is also restored for agriculture after use; all other areas within the site are restored to agriculture immediately. Owner/Operator Brett Aggregates Ltd - The area of land shown on the identification drawing, will import in the region of 30,000 tonnes of green mixed organic waste for composting.

The material source is expected to come from the districts of Thanet and Canterbury City, but not restricted to these districts.

Pollution to the area

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 72 Kent County Council—Waste Sites Options Commentary Report

9 Composting Site 85

Charing Quarry (Waste) Support 1

9.8 This site is adjacent to the existing mineral process- Comment 3 Responses ing plant. The site has been promoted for the composting of 30,000 tonnes of green mixed organic waste from Ashford. Object 289

(Responses include a resident petition of 201 signatures) 0 100 200 300 400

Responses Heritage This proposed waste site lies within an area of high archaeological potential. Investigations at Charing Quarry have revealed remains of an Iron Age and Romano British farmstead and occupation site. Remains have included structures, cremation burials and an extensive ditched field and boundary system. The western part of this proposal site, the last parts of the quarry to be extracted was investigated by the Kent Archaeological Rescue Unit in the 1980s and 90s. It appears that the full area of the proposed waste site has been subject to quarrying and therefore there is only potential for archaeology in any unquarried fringes. There is a potential for Palaeolithic fissure sites in the sandstone and there remains a possibility that such fissures may be seen in the faces of the quarry.

There is a Listed Building close to the application site at Little Swan Street Farmhouse and another south at Swan Street. Biodiversity EPS, UKProtect, local and LocalSite protected species with 1km of site. Highways The site is an existing sand extraction pit so it is assumed that access will be from the existing site access on Hook Lane. Hook Lane has been widened in recent years to improve access to the existing site, there KHS cannot foresee any issues with this site. There no planned improvements to Hook Lane. There are no planned developments that are likely to impact on road capacity.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 73 Kent County Council—Waste Sites Options Commentary Report

9 Composting

Natural England The site is close to the boundary of the Kent Downs AONB. While this is an existing quarry we have concerns that the proposed facility would industrialise a rural area within sight of the Kent Downs. This would be a permanent facility rather than the limited life of the quarry. It would also be a lost opportunity to restore the quarry for biodiversity gain. Kent Wildlife Trust This site is adjacent to Spring Wood ancient woodland. Although we have no objections in principal to a green waste facility in this location it will be important to consider the in combination impacts of this development with Site 74, 77 and 86 of the Minerals Sites document. Kent Downs AONB The site is within a former quarry adjacent to existing mineral processing plant which would contribute to composting facilities of organic waste from Ashford. The site is largely unconstrained so adverse impacts should be mitigated by ensuring that high environmental standards can be achieved at the site. Relation- ship with final quarry restoration: the composting operation will extend the life of quarry to be permanent and challenge the final proposed after use of the site. Without this permanent use the major access could be restored and the whole site put back into a rural after use in the long term. There is no justification for a long term facility. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the area used for recycling 'green' waste is better delineated; this area is also restored for agriculture after use; all other areas within the site are restored to agriculture immediately; impacts of additional HGV traffic on the local roads are understood and mitigated for; potential cumulative impacts of HGV traffic generated by others sites (minerals and waste) within this area must be controlled. To minimise land take we recommend that this proposal is co- located with the proposed recycled aggregate facility under Site 86. Owner/Operator Brett Aggregates Ltd - The area of land shown on the allocation drawing, will import in the region of 30,000 tonnes of green mixed organic waste for composting.

The material source is expected to come from the district of Ashford, but not restricted to Ashford.

Traffic generated from this facility would be, on average, 15 loads per day, making 30 daily lorry movements. It expected that HGV's bringing green waste into the site for composting will also be utilised for taking composted material out of the site for delivery to construction/landscaping projects in the locality.

General Public Reponses Increase in traffic movements causing further congestion on our country roads Damage to water courses

detrimental effect on wildlife

Pollution

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 74 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer Site 11

Lee’s Yard and Adjacent Site Support 0

10.1 This proposal is to extend the existing site. The site Comment 2 Responses is used for the transfer of industrial and commercial waste. Object 0

00.511.522.5

Responses District/Borough Dartford – Within Greenbelt, Groundwater Aquifer, Windturbine Development Safeguarding. Subject to – Smoke Control Order 5, Southern Gas Networks Pipeline Consultation Zone. HSE Inner/Middle/ Outer Consultation Zones. Area of Archaeological Potential. Housing at Breaburn Park, Bexley to the north. LB Bexley identify land adjacent to the site on the north side as site of Borough importance for Nature Conser- vation.

Utility Companies Southern Water-Not assessed, as outside supply area. Heritage The proposed waste site is an area of very high archaeological potential with important prehistoric remains having been recorded close by to the site. There include Palaeolithic remains found during excavation of the sand and gravel on the quarry site to the north east plus Bronze age remains including a possible burial and a metal work hoard just to the east.

While the majority of the site has been affected by past quarrying and subsequent development, there are potentially substantial areas left with significant archaeological potential in particular the area adjacent to Roch- ester Way.

There are no Listed Buildings close to the site other than a Listed boundary post in the housing estate to the north. Dartford Heath to the south of Rochester Way is a historic park and garden although this appears to be screened from the proposed development site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 75 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer Biodiversity UKProtect, Local protected species located within site. UKSite, LocalSite protect species within 1km of site. Kent Wildlife Trust Dartford Heath LWS is opposite the site. If the recycling process is likely to release any element that will reduce the air quality in the area this may damage the heathland habitat within the LWS. In compensation for any reduction in the air quality from increased operations on this site we recommend that a contribution be made to the management of Dartford Heath LWS. In combination impacts with Site 21 within the Mineral Sites Document will need to be considered especially in relation to emissions during the process and from increased traffic. Protect Kent Acceptable, subject to a more detailed assessment.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 76 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer Site 12

Newington Support 0

10.2 This site is an existing industrial estate located ad- Comment 3 Responses jacent to a former extraction site for brickearth. The land owners would like the site to be considered for waste uses and to expand the site into the former brickwork Object 26 area. 0102030

Upchurch PC-Any of the possible uses would have environmental impacts for the Newington Residents- If the uses are permitted, assuming they replace activities already on site then traffic movements should be neutral. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 77 Kent County Council—Waste Sites Options Commentary Report

8 Treatment/Materials Recycling Facility Utility Companies Southern Water: Southern Water: Strong planning policies will be required to protect underground sewers and/or water mains at the site. Within SWS wastewater area. SWS wastewater infrastructure crossing site. Within SWS supply area. SWS water supply infrastructure crossing site. Heritage The proposal site lies adjacent to the A2 Watling Street which has its origins as the main London to Dover road in Roman times. The Roman road alignment is generally considered to fall to the south of the present line and may cross the site. Roman and later activity including cemetery sites is often found flanking the road. Brickearth deposits in the area may contain remains of Palaeo- lithic and Mesolithic date. Palaeolithic hand axes have been found north east of the site in New- ington.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 78 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 13

Allington Waste Management Facility Support 4

10.3 This proposal is to develop an additional fourth line to Comment 3 Responses the current energy from waste incinerator. This fourth line will provide an additional capacity of circa 200,000 tonnes per annum. The site has also been promoted to provide a House- Object 0 hold Waste Recycling Centre and to expand the existing Ma- terials Recycling Facility. 012345

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 79 Kent County Council—Waste Sites Options Commentary Report

Highways HGV Route along A20. No planned Highway improvements. Kent Wildlife Trust No objections to the expansion of the current recycling activities or the addition of a facility to recycle household waste. KLIS shows a number of woodland strips along the boundaries of the site. These should be preserved and enhanced within the proposed development. Kent County Council Waste Manage- Fully supports the provision of an HWRC at this location. Extensive land/site searches have been carried dur- ment ing the last eighteen months to seek to establish a suitable location that best meets the needs of T&M residents and also provide additional much needed capacity for Maidstone. This site meets those requirements. Protect Kent Acceptable, subject to a more detailed assessment.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 80 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 28

Waterbrook Park Support 0

Comment 2 Responses 10.4 This site is promoted as an extension to the existing site at Sevington. The site has been promoted for use as a household waste recycling centre and a waste transfer station. Object 1

0 0.5 1 1.5 2 2.5

Responses Utility Companies Southern Water – Not assessed, as outside supply area. Within Wastewater area, Wastewater infrastructure crossing site. Heritage The proposal lies in an area with high archaeological potential with buried archaeological remains of prehistoric, Roman and medieval date known to lie in the area of the site and the surroundings. In particular an area of Middle Bronze Age cemetery and settlement has been recorded at Waterbrook Park within the site and is likely to remain preserved within areas of the western half of the site. To the south and west of the site, extensive Late Iron Age settlement has been recorded while areas of Late Iron Age settlement have also been recorded in the north parts of the site.

A Scheduled Monument, the Boys Hall Moated Manor lies to the west of the proposal site and a listed Building at Imber to the east.

Development is likely to have had a heavy impact on potential archaeology in the northern parts of the site and less so in the southern. Biodiversity EPS, UKProtect protected species located within site. Local and LocalSite protected species located within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 81 Kent County Council—Waste Sites Options Commentary Report

Highways The access to the site is an existing one from Waterbrook Avenue and the A2070. As this is an existing permitted site KHS cannot see any issues with HGV capacity to the site.

There are planned improvements to the A2070 as a result of the proposed. Further details can be found under the planning application (10/00672/AS) for the Cheeseman’s Green Development to the west of the site. This will result in improvements to the Waterbrook roundabout which will result in increased capacity. A 40mph speed limit is also proposed at the roundabout to reduce vehicle speeds here.

The Cheeseman’s Green Development of approximately 1,100 houses will be paying towards to costs of the improvement works on the A2070 and the Waterbrook roundabout.

Kent Wildlife Trust Has concerns regarding a household wastes and waste transfer facility especially in combination with Site 88. This site is much closer to South Willesborough Dykes LWS and therefore the impacts on the water quality are likely to be more severe. This area is already being heavily impacted by development planned within Ashford. South Willesborough Dykes LWS is being impacted by large housing developments which will increase recreational pressure and infrastructure projects such as pipelines which will cause direct habitat loss. We understand that there are initial plans for Waterbrook to be developed for housing. Both Site 88 and Site 28 contain a complex of ditches which ultimately feed into the South Willesborough Dykes LWS. It will be important that the ditch network is enhanced and the water quality is not impacted by any recycling processes planned. In mitigation for any impact due to loss in water quality on the LWS we recommend that a financial contribution be made to one of the restoration projects being set up within the area. We are also aware that there is a good population of great crested newts who use the Waterbrook site and therefore are likely to use Site 88 as well. Regard will need to be given to their protection within any development planned. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the proposed uses are clarified; compatibility with Ashford Growth Area proposals are understood; impacts on public rights of way are mitigated for. Kent County Council Waste Manage- Recognises the potential for this site and this location given the nature of the current use and proximity to the ment local Highway infrastructure.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 82 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 30

Church Marshes Support 1

10.5 The site is located adjacent to the existing Church Comment 3 Responses Marshes household waste transfer centre and waste transfer station.

Object 1

01234

Responses

District/Borough Swale - The Council strongly object to this site (see also site 44) due to concerns as to the impacts of the site on the Council’s significant country park investment (£2 million) in the locality. With potential remedial work taking place adjacent the site the Council sees this area as offering longer potential for an extension to the country park. If expansion of the existing site is also being promoted, the Borough Council would also object to this in view of considerable impact on the Country Park.

Should KCC consider pursuing this site, it would be in preference, as far as the Borough Council is concerned, to site 44. In doing so, the Council would wish to discuss with the County Council the potential for bringing the remaining land in their ownership into the country park as a future phase.

The site is also close to an SSSI and SPA so would need careful mitigation if it proceeds. The Council would be happy to work with KCC to find an alternative, more suitable site for Sittingbourne HWRC. Utility Companies Southern Water – SPZ2 – Outer Protection Zone. Within wastewater, wastewater infrastructure crossing, water supply area and wastewater treatment works.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 83 Kent County Council—Waste Sites Options Commentary Report

Heritage The proposal site lies on the west side of Milton Creek which was an important focus of activity from early times. The alluvium deposits upon which the site lies have the potential to contain well preserved remains associated with the use of the creek and its associated marshlands from the prehistoric through to the 20th century when the area became important for the manufacture of bricks. Early medieval burial remains have been found during brick earth quarrying close to the site and Roman burial remains have been discovered elsewhere in the marshlands bordering the creek.

Alongside the creek a number of hulks of barges can be seen together with the remnants of old wharfs that once served the brickworks. Industrial archaeology remains associated with the brick making industry may also survive on the site. The Sittingbourne and Kemsley Light Railway, an historic railway which ran from the Sit- tingbourne Paper Mill to Ridham Docks lies on the northern side of the site. This rail way is an important historic visitor attraction.

Biodiversity UKProtect, Local and LocalSite protected species within site. EPS and UKSite protected species within 1km of site. Highways This site is already used for this purpose, and access taken from the privately Gas Road, off Mill Way. No Con- cern with continued use of this route at current levels.

Natural England These sites are alongside Milton Creek. Any development should consider the use of the adjacent Milton Creek by birds notified as interest features of the nearby Swale SPA. The Saxon Shore Way runs along the creek side here connecting the new Church Marches Country Park to the centre of Sittingbourne. Any development should be sensitive to the landscape and character of the area. There is the potential for the development to enhance and improve this important long-distance route. Kent Wildlife Trust We would have concerns regarding a new household waste transfer centre in this area due to the high ecological sensitivity and the fact that Church Marshes has been enhanced in mitigation for impact on the European sites and bird disturbance by a number of planned developments within the area. It would appear from the map that a small part of Milton Creek LWS is incorporated within the site and the proposed new location for this facility is much nearer to this important creek than the previous household waste transfer centre. We do not therefore agree with the SA that there are no significant constraints. Protect Kent Acceptable, subject to a more detailed assessment.

Kent County Council Waste Manage- Fully support. The existing Waste Transfer Station and HWRC are in need of upgrading to allow a more efficient and sustainable operation. One option being considered is to replace the existing structure and operation ment with a new "state of art" purpose built facility. Advantages would see the retention of an existing operation in an existing location.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 84 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 31

Studd Hill Support 2

10.6 This site is adjacent to the existing Herne Bay house- Comment 2 Responses hold waste recycling centre. The site has been promoted to extend and upgrade the existing facility. Object 0

0 0.5 1 1.5 2 2.5

Responses District/Borough Canterbury City Council - The proposal at this existing household waste recycling centre is for the extension and upgrade of current facilities.

The Council is in ownership of this site and supports this proposal in principle. The Council, however, would like to be involved in detailed discussions on policy wording in relation to possible future proposals, site access etc. There are, however, some constraints not identified in the document or sustainability appraisal that must be taken into account in any future expansion of the existing facility. In particular the site is within the Green Gap and as such any development should not affect its open character or result in isolated new development. The site has the potential to support a number of protected species and therefore appropriate survey work needs to be undertaken. Access to the site is a further constraint and if movements to the site are expected to significantly increase, then consideration should be given to closing the public access to the site from Westbrook Lane and replacing this with the new access from the Old Thanet Way. These issues should be recognised in the document and considered further in advance of allocation of this site. Utility Companies Not Assessed as outside supply area. Within Wastewater area. Heritage The main archaeological potential in this area arises from an early Iron Age occupation site found in the general area and the remains of an 19th /20th century isolation hospital in the southern part of the site.

The nearest Listed Buildings are at Studds Farm to the north of the railway.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 85 Kent County Council—Waste Sites Options Commentary Report

Biodiversity EPS, UKProtect, Local, Eurosite and UKSite protected species within 1km of site. Kent Wildlife Trust This site is within 250m of Pastures at Chestfield and Greenhill Thanet Way LWS designated for its unim- proved pasture and damp grassland habitats. As the development is within a present recycling facility we have no objections in principle provided it is ensured that there is no pollution or runoff of the adjacent neutral grassland and no impact on the biodiversity within the LWS. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the current unknowns are resolved; the extension to the site does not include activities other than existing. Kent County Council Waste Manage- Fully promote this proposal which seeks to expand the existing HWRC to provide a better more sustainable ment service with better facilities, access and recycling facilities.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 86 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 37

Cobbs Wood Industrial Estate Support 1

10.7 This site is adjacent to the existing Chart Leacon house- Comment 2 Responses hold waste recycling centre. The site is proposed for a new waste transfer station at this site. Object 3

01234

Responses

Heritage The main archaeological potential of this area relates to the location adjacent to the Great Stour which has been an attractive location for early activities and settlement. The site lies on an area of 3rd Terrace River Gravels which have potential for Palaeolithic remains. Biodiversity EPS Protected species located within site. UKProtect, Local and LocalSite protected species located within 1km of site. Highways The access to the site is an existing one from Brunswick Road and Chart Road. There are currently issues with capacity on the A28 Chart Road as this road is congested at peak times and the road is operating in excess of capacity. KHS will therefore need further details about the proposed increase in traffic at this site until we can comment further.

There are planned improvements for the A28 Chart Road which will include the full duelling of the road. This will be delivered as part of the Chilmington Development of Approximately 7,000 houses. The planned improvements will be fully funded by this development and other developments in the local area.

A new road called Victoria Way has been built from Brookfield Road (South of the site) to Ashford Town Cen- tre and opened at the end of March 2011. This should help to reduce the amount of vehicles using Chart road by approximately 20%. Until this road is opened we cannot comment on the reduced traffic levels on Chart Road.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 87 Kent County Council—Waste Sites Options Commentary Report

Kent Wildlife Trust has no objection to a new waste transfer station on this site. As the site abuts the railway line and many developments within Ashford are enhancing this important migratory corridor for wildlife we recommend that the railway be buffered with hedgerow and long grass habitat created along this corridor. Project Kent Acceptable, subject to a more detailed assessment. Kent County Council Waste Manage- Fully promote this project. The proposed development site lies within an existing industrial estate and the ment majority of the development site includes an existing HWRC. To this end the principle of waste related development is established.

The proposed development will reduce the need for multiple refuse collection vehicles from across the Ash- ford area to travel to the Allington facility on a daily basis.

There would be fewer vehicles required to transport the waste from Ashford to Tonbridge and Malling. These would be purpose built bulky vehicles with larger payloads, up to 3 times the capacity of refuse collection vehicles.

As a result there would be less HGV traffic in Ashford, on the M20 and on the approaches to the Allington Energy from Waste plant.

Fewer refuse collection vehicles, which currently spent up to 2 hours each per day delivering waste to the Energy from Waste plant, would be required. The number of rounds would reduce, because each refuse collection vehicle could service more households during the working day.

Recycling rates for the Ashford area would have the potential to increase from 14% to a level in excess of 50%. This is similar to the rate achieved by other waste collection authorities in Kent which have compre- hensive kerbside collections.

Kent's current recycling rate is 39% for the county as a whole; the additional contribution which could be made by Ashford Borough Council towards recycling would make the difference to enable Kent to achieve the national waste strategy target. General Public Responses The local road infrastructure has already reached its capacity any additional use of this site would be highly determent environmentally to residents

The site is too close to a residential area

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 88 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 38

Southwall Road Support 3

10.8 This site is located adjacent to the existing Southwall Comment 3 Responses Road household waste recycling centre. This site is promoted to incorporate a revised larger household waste recycling centre. Object 1

01234

Responses District/Borough Dover - Whilst this site is supported in principle, the traffic impact on the surrounding road network should be investigated before this site is allocated. A recent employment planning application for a neighbouring piece of land (Minters Yard) met with considerable local opposition, which included transport and access concerns. The area to the west of the site has also been identified in the Dover District Core Strategy as an area for urban expansion of around 290 residential units (there is a current planning application for 230 units). This site should only be allocated if there is no major increase in truck movements above the current situation or, if there is an increase, there are suitable measures to ensure that the road network is improved. Any proposals must also consider the impact of additional noise and vibration on local residents. Deal Town Council - recommends no further expansion of this site due to the effect on the well-being of local residents. Any traffic increase along these already crowded narrow access roads would have a negative impact on those who live near to this site. Deal Town Council would however encourage investigation of the facility to shred plastics at this site to reduce the amount of heavy vehicles required for the transportation of waste. Parish Council Sholden - strongly objects to any futher expansion to this facility for the following reasons: Access to the site is already compromised, Any further expansion will result in the surrounding area becoming unwork- able, Access is currently via narrow residential streets and then onto the busy A258, the only route into and out of Deal, Development of Minters Yard and the Builder Centre (both in Southwall Rd area) has been passed and will therefore increase traffic even more, in particular HGV's and lorries, Proposed housing development in Sholden (500 houses) will compromise the road systems even more should they go ahead. Any further expansion should only occur once the infrastructure of the area has been upgraded to cope with it. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 89 Kent County Council—Waste Sites Options Commentary Report

Utility Companies Southern Water – No Proximity to Source Protection Zones. Within Wastewater areas. Heritage The Southwall Road HWRC is situated in an area with high potential for encountering prehistoric, Iron Age and Roman remains on the margins of the reclaimed marshland to the north west of Deal and Sholden. Biodiversity EPS, UKProtect, Local, Eurosite, UKSite, LocalSite protected species within 1km of site. Kent Wildlife Trust has no objections to the extension of the recycling facility in this area. However we would caution that investigations be made regarding any impact on the ditch network within the surrounding habitat to ensure no pollution or deterioration of water quality within this system. The ditch network ultimately feeds into the Thanet Coast and Sandwich Bay Ramsar site. Final plans should ensure no impact on this designated site. Protect Kent Acceptable, subject to a more detailed assessment.

Kent County Council Waste Manage- Fully promote this proposal which seeks to expand the existing HWRC to provide a better more sustainable ment service with better facilities. The proposal is improve the existing cramped facilities by incorporating adjacent land within KCC ownership. The proposal does not anticipate any significant increase in traffic wishing to access the site as a result of these proposed works.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 90 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 42

Pedham Place Support 2

10.9 This site is located adjacent to the existing Pedham Comment 2 Place household waste recycling centre. Although this site Responses has recently undergone a complete refurbishment, this area is promoted for potential expansion in the future. Object 2

00.511.522.5

Responses District/Borough Sevenoaks - The sustainability appraisal is considered to be appropriate in terms of the issues raised. Sub- ject to the appropriate mitigation measures being put in place, to protect the landscape and air quality, (see General Concerns regarding Air Quality), the District Council has no objection to the principle of this site being allocated. Any proposals would need detailed traffic assessments to provide accurate data to feed into air quality assessments to quantify any air pollution impacts.

Parish Council Farningham Parish Council's response to the consultation of the proposals at Pedham Place is one of strong objection on the following grounds: proximity to AONB, MGB, Ancient Woodlands (SSSI); across the road from Pedham Place golf (a tourist/visitor attraction); sharing access road with existingdomestic waste recycling, MRF and Highways Depot (including salt/grit store); traffic queuing to enter the domestic waste recycling frequently backs up onto A20 and blocks the roundabout and the A20 itself; width of highway is a limitation already; state of footpath (ie the absence of one); road used for parking vehiclesfor adjacent MRF; other waste site (MRF and domestic waste recycling) using the same access to primary road network; road capacity can barely handle existing volume of HGVs never mind more; and of course the AQMAs which KCC/KHS always forget even exist (this area is already at 95% to 150% of EU safe levels of NO2 ). The fact that the size (area) is listed as "unknown" plus its capacity, operational life and the accessare also "unknown"illustratesKCC is havingan unresearchedblind punt.' In addition,KCC show the use only as "waste" and the proposed restoration in 2030 or wheneveris also"unknown" - the proposal is ill-conceived, and totally un-researched- it is totally unsuitable, asKCC'sresearch would prove if this had been undertaken.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 91 Kent County Council—Waste Sites Options Commentary Report

Heritage The main archaeological potential of this area relates to the nearby finding of prehistoric flint tools inc a tranchet axe immediately to the east. The site is presently developed with a depot. Biodiversity EPS, UKProtect, Local and LocalSite protected species located within 1km of site.

Highways Adequate capacity currently available on the roads required by the site. No Planned highways improvements. No Major development schemes planned. Kent Wildlife Trust We have no objections to a waste recycling plant within this location.

Protect Kent Rejection recommended, due to: the number of unknowns about this site; the need for this expansion is not clearly justified; potential visual impact from the AONB. Kent County Council Waste Manage- Fully promote this proposal which seeks to expand the existing HWRC to provide a better more sustainable ment service with better facilities. The proposal is to improve the existing facilities by incorporating adjacent land within KCC ownership should this become available. The proposal does not anticipate any significantin- crease in traffic wishing to access the site as a result of these proposed works. General Public Responses The site is unsuitable, above all because its extended use will exacerbate already severe problems of air quality in the area, with a particular impact on the village of Farningham and the surrounding area. The area already has high levels (95 - 150% of EU recommended safe levels) of NO2 emissions, and is included in the extended Sevenoaks AQMA area 1. Heavy vehicle emissions are a key factor in the air quality problems of the area. The proposal would make this significantly worse.

Secondly, there are implications for the road network in the area. Thesame access (to the A20)is already used by the existing Household Waste Recycling Centre, a KHS depot and the Ideal Waste Paper operation. This already creates traffic tailbacks that can and do spill onto the main A20. Again, the proposed extension of activity would exacerbate the problem. The access from the main road is quite narrow, certainly for HGV use, and in particular when there are many cars tailed back on it. 'Width of the public highway' and 'other waste/ mineral sites using the same access to primary road network' are acknowledged as constraints on sites in the Waste Sites DPD.

Finally, the site is (as the map in the Waste DPD makes clear all but surrounded by AONB and is close to ancient woodland, and would have a severely damaging effect on them.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 92 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 43

Stoneyard Support 1

10.10 This site is located adjacent to the existing Sheerness Comment 2 Responses household waste recycling centre. This site has been promoted as a potential expansion of the existing facility. Object 1

00.511.522.5

Responses District/Borough Swale - The Council object to this site as even though this is an existing site and an improvement would be welcome, this proposed site is not conducive with SBC’s regeneration aspirations for Sheerness. The Coun- cil would be happy to work with KCC to find an alternative, more suitable site for this HWRC centre.

The site is next to scheduled monuments and therefore careful consideration needs to be given as to the proposal’s impact on this. Utility Companies Southern Water – No Proximity to Source Protection Zones. Within wastewater, waste supply area and wastewater treatments works. Heritage The proposal site lies immediately outside the historic defences of Sheerness dockyard. The defences adjacent to the western boundary of the site survive as a moat which is protected as a Scheduled Monument. Ar- chaeology associated with the construction of the defences could survive in the area. Biodiversity EPS, UKProtect, Local and LocalSite all within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 93 Kent County Council—Waste Sites Options Commentary Report

Highways Capacity on Brielle Way or Bridge Road is unlikely to be an issue here, although it is unclear where access will be taken from. There are likely to be difficulties if access is taken through to Bridge Road between the bus depot and the railway station, as movements are likely to interfere with the operation of the existing taxi rank, and will be in close proximity to the Millennium Way traffic signals and access to the bus depot.

No planned road improvements. No planned Developments. Kent Wildlife Trust We have no objections to a waste recycling plant within this location however it will be important to ensure that there is no impact on the water quality within The Moat either from runoff or other pollution. Protect Kent Acceptable, subject to a more detailed assessment.

Kent Wildlife Trust We have no objections to a waste recycling plant within this location. Kent County Council Waste Manage- Fully promote this proposal which seeks to expand the existing HWRC to provide a better more sustainable service with better facilities for Sheppey residents. The nearest alternative is located off the Island at Sitting- ment bourne. The proposal is to improve the existing facilities by incorporating adjacent land within KCC control. The proposal does not anticipate any significant increase in traffic wishing to access the site as a result of these proposed works.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 94 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 44

Land at Church Marshes Support 1

10.11 This site has been promoted as a potential location for Comment 2 Responses a new household waste recycling centre and waste transfer site. The new facilities would be a replacement for the existing Church Marshes operation. Object 1

00.511.522.5

Responses

District/Borough Swale—The Council strongly object to this site as it would have devastating effects on its Church Marshes Country Park project and potentially the wider Sittingbourne Town Centre regeneration objectives. Development would also be potentially detrimental to biodiversity and landscape in the locality as it is close to the SNCI. This site may also be affected by the current northern relief road scheme and construction. The site also has poor access to it. The Council would be happy to work with KCC to find an alternative, more suitable site for Sittingbourne HWRC. Heritage Site lies west of Milton Creek which was an important focus of activity in early times. The alluvial deposits upon which the site lies have the potential to contain well preserved remains associated with the use of the creek and its associated marshlands from the prehistoric through to the 20th century. The majority of the site is presently covered by substantial deposits of Landfill. The site is 400m south of the Castle Rough medieval moated site, a scheduled monument. The Sittingbourne and Kemsley Light Railway, an historic railway lies on the west edge of the site. Biodiversity EPS, UKProtect, Local and Local site located within the site. UKSite located within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 95 Kent County Council—Waste Sites Options Commentary Report

Responses Kent Wildlife Trust We would have concerns regarding a new household waste recycling centre in this area due to the high ecological sensitivity and the fact that Church Marshes has been enhanced in mitigation for impact on the Euro- pean sites and bird disturbance by a number of planned developments within the area. A part of Milton Creek LWS is incorporated within the site and the proposed new location for this facility is much nearer to this important creek than the previous household waste transfer centre.

Natural England These sites are alongside Milton Creek. Any development should consider the use of the adjacent Milton Creek by birds notified as interest features of the nearby Swale SPA.

The Saxon Shore Way runs along the creek side here connecting the new Church Marches Country Park to the centre of Sittingbourne. Any development should be sensitive to the landscape and character of the area. There is the potential for the development to enhance and improve this important long-distance route. Protect Kent Rejection recommended, due to: site 30 being the more favourable location, with fewer impacts on adjacent SNCI.

Kent County Council Waste KCC (Waste) Fully promote this proposal. Since the existing Church Marshes facility opened in 1999, the range of materials requiring separate handling and transfer in the bulk waste transfer building has increased Management considerably. Likewise the range of materials handled through the HWRC area. Operationally it is considered that the facility needs a major upgrade and redevelopment to meet current and potential future needs. How- ever, in light of the access road issues, before major investment, the question of the suitability of the location also needs to be fully considered.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 96 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 57

Pike Road Eythorne Extension Support 1

10.12 This site is promoted as an extension to the existing Comment 2 Responses waste transfer station located at Tilmanstone Works on the Pike Road Industrial Estate. Object 1

00.511.522.5

Responses District/Borough This site appears to have a similar use on it already. Subject to landscape impact, no objection to the use of this site for the expansion of the Household Waste Recycling Centre. Any proposals must, however, also consider the impact of additional noise and vibration.

Utility Companies Not assessed, as outside supply area. Within wastewater area.

Heritage The proposed waste site lies in an area that is rich in buried archaeological remains. Aerial photographs of the fields around the former colliery site show crop marks indicating the presence of features such as enclosures, prehistoric barrows, trackways and settlement. The site has been developed as a coal yard in the past which is likely to have affected any archaeology present though deeply buried features may survive.

Biodiversity UKProtect and LocalSite protected species within 1km of site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 97 Kent County Council—Waste Sites Options Commentary Report

Kent Wildlife Trust We have no objection to the extension of the waste transfer centre at this site.

East Kent Friends of the Earth Group Object General Public Responses Logical extension but it must be remembered this is a rural area and again the effects of extra traffic has a serious implication for the amenity of adjacent settlements.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 98 Kent County Council—Waste Sites Options Commentary Report

10 Household Waste Recycling Centres & Transfer

Site 72

Unit 14 Canterbury Industrial Estate Support 0

10.13 The site is proposed for use as a waste transfer station Comment 1 Responses taking municipal and commercial 7 industrial waste plus inert and excavation waste. The site also been promoted to produce secondary and recycled aggregates. Object 2

0 0.5 1 1.5 2 2.5

Responses District/Borough Canterbury City Council- There is an existing permission (05/0430) for use of land for storage and distribu- tion of reclaimed buildings materials and erection of a building. This was granted in 2009 and is valid until 2014. Only part of the permission has been implemented, namely the use of the land for storage of materials. The Council would not support anything significant beyond this permission as this is adjacent to a sensitive site: Stodmarsh SPA /Ramsar/SSSI/NNR. Any intensification of use would require screening for Appro- priate Assessment under the Habitat Regulations. The lower south western part of the site is also a Local Wildlife Site for which a recent survey has been undertaken and which has reaffirmed the importance of this site for wildlife and habitats. This site also complements the adjacent highly important Stodmarsh site Should this site progress to later stages in the Plan making process then the boundary should be redrawn to exclude the Local Wildlife site.

Parish Councils Westbere- Object-The parish council are wholly against any further development in Westbere for the taking of waste that no one else in the Canterbury area wants. Westbere already has the Viridor waste plant and the Ling Metals development - the effects of which are yet to be realised. An additional waste site would further detract from the Site of Special Scientific Interest (SSSI) land which already suffers from noise, smoke, dust and light pollution. In addition such a site would add to the number of large lorries along the A28 by the village, already a very busy road. These units are not huge units, the councillors also felt that there would be inadequate room for lorries to unload and to turn around. Having an SSSI in the parish, the parish council seeks to protect and enhance it for future generations. It is not clear what waste is being proposed for this site. It could contaminate the land.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 99 Kent County Council—Waste Sites Options Commentary Report

Heritage The proposed minerals and waste site lies in an area with considerable archaeological potential. The main Ro- man road linking Canterbury and Thanet runs along Island road to the north. Investigations in the area of the industrial park to the north have recorded important archaeological remains relating to Iron Age and Roman settlement. Bronze Age remains have also been recorded to the north east. The archaeological potential for the site may have been affected by previous development works including a colliery on the site though the extent of such impact is presently not known.

The nearest Listed Building is at Westbere Court to the north west of the proposal site and the industrial estate. The estate is likely to screen the site from the Listed Building.

Biodiversity UK and Local Protected Species and Local Designated site within site. European Protected species and Euro- pean and UK designated site within 1km.

Environment Agency Due to the close proximity to the Stodmarsh Special Protection Area (SPA)/Special Area of Conservation (SAC), any proposed facility at this location would have to an appropriate assessment in accordance with the Habitats Directive to determine whether its was likely to have an adverse effect on SPA/SAC.

Natural England This site would further extend the Canterbury Industrial Park towards the boundary of the Stodmarsh SAC, SPA, Ramsar and SSSI. Stodmarsh is important for its wetland habitat, assemblages of plants, invertebrates, and breeding and over-wintering birds. It is sensitive to increases in noise and light pollution and impacts to hydrology. It is Natural England’s view that further information is required to ascertain whether the proposed development will impact on interest features of the Natura 2000 sites and the SSSI, before it is taken forward. RSPB This site is immediately adjacent to the Stodmarsh SPA/Ramsar site, SAC, SSSI and NNR. The site is also adjacent to, and includes part of, a local wildlife site (SNCI). As outlined in the Sustainability Appraisal "part of the site incorporates a local wildlife site (SNCI) and the site lies to the north of a Special Protection Area/ Ramsar site/National Nature Reserve designation, which will warrant consideration to any impacts on biodiversity We expect this site to be thoroughly assessed within the HRA to ensure no adverse effect on the adjacent designated sites. Further, since the life of the operation is "unknown", we suggest that a restoration plan may be relevant. The site should be restored to compliment the local sites Protect Kent Acceptable, subject to a more detailed assessment, and provided that: impacts on neighbouring environmental designations (SNCI, Ramsar, etc) are fully understood and conditioned for in any permission; overlap with adjacent SNCI is excluded from the site; the full scope of waste processing activities are known, agreed and managed; levels of noise are quantified. Regard also needs to be given re possible conflict with potential expansion of Hersden village, through the Canterbury City Council LDF. General Public Responses SSSI and a Natura 2000 site Degrade and detract from land managed for future generations

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 100 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 12

Newington Support 0

11.1 This site is an existing industrial estate located ad- Comment 3 Responses jacent to a former extraction site for brickearth. The landowners would like to expand the industrial estate into the former brickworks. This will require inert fill to Object 26 raise the land level. 0102030

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 101 Kent County Council—Waste Sites Options Commentary Report

Utility Companies Southern Water: Strong planning policies will be required to protect underground sewers and/or water mains at the site. Within SWS wastewater area. SWS wastewater infrastructure crossing site. Within SWS supply area. SWS water supply infrastructure crossing site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 102 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 17

Moat Farm Support 0

11.2 This site has been promoted for sand and gravel Comment 3 Responses extraction. The site promoter has suggested using inert waste for infilling as part of the restoration. This site can also be found in the Minerals Sites DPD. Object 2

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Responses District/Borough TMBC- This site is located in an area with several existing permitted sites and call for sites submissions. The site has a public footpath crossing the western half of the site and is located north of the South Downs Area of Outstanding Natural Beauty.

Parish Council Capel PC-The council thinks that further investigation of Moat Farm should be carried out as the consultation lacks sufficient data on this site.

Utility Companies Southern Water- Within SWS wastewater area. Heritage The proposed mineral extraction of this site may have an impact on the setting of Listed Buildings and in particular that at Moat farmhouse. Prior to permission for extraction, the impact of the proposals upon the Listed Buildings should be fully assessed and mitigation measures undertaken to avoid impact on their setting. In terms of potential impact on buried archaeological remains, quarrying should be possible on areas of this proposal site but would need to be accompanied by archaeological measures.

Biodiversity Local protected species within site. European and UK protected species within 1km of site. Local designated

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 103 Kent County Council—Waste Sites Options Commentary Report

Highways HGV route along B2017 and A228.

Kent Downs AONB This proposal for use of inert waste material in restoration proposals supports the minerals application in relation to supply of sand and gravel from this site. There are a lot of unknowns in relation to this joint submission that makes appraisal of this site difficult at this stage. The site lies to the north the South Downs AONB which would warrant consideration to any landscape and visual impacts on the AONB, given any potential cumulative impacts with existing permitted sites within the area. Consideration is required as to what benefits the site

Environment Agency This site has the potential for nature conservation value following restoration. The existing watercourses on the site should be taken into consideration through the allocation process. The text incorrectly identifies the South Downs AONB as being nearby. Natural England The extension of the mineral workings to the south east of the existing Stonecastle Farm Quarry brings the workings closer to the boundary of the High Weald AONB and may impact on the setting of the AONB. The workings and restoration would need to suitably phased to minimise any visual impacts.

The National Trust The Northern tip of this site contains small area of ancient wood. In addition to this there 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.

Kent Wildlife Trust Within the locality of East Tonbridge Copses and Dykes and River Medway LWS designated for its freshwater and river habitats, wet woodland and grassland. Providing hydrological investigations were carried out to ensure no impact on the LWS, safeguards were put in place to preserve the health of the water system and restoration was to wetland and dyke habitat KWT would not object to quarrying within this site.

RSPB This site would be suitability restored to wetland habitat. It currently has a number of streams or drains running through the site, including the Alder Stream and the Hammer Dyke. Further, this site is in the Medway and Low Weald Wetlands and Grasslands BOA. This site is south of an adjacent quarry, Stonecastle Farm which is being restored to wetland habitats. By restoring to wetland habitat also, this site will help contribute to a larger wetland complex which will function better ecologically.

Woods Under Threat The northern tip of this site contains a small area of ancient wood. In addition to this there 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.

General Public Responses Ancient Wood within boundary

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 104 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 18

Covers Farm Support 0

11.3 Covers Farm is an existing quarry. The operator Comment 6 Responses intends to alter the currently permitted restoration scheme, adding gentle gradients arable land and woodland. Object 88

0 20406080100

Responses

District/Borough Tandridge - In strategic terms inert fill of waste such as is proposed should not rely on a route via the A25, an east west route that crosses Tandridge District and which passes through historic villages and Conserva- tions Areas at Bletchingley, Godstone and Limpsfield in the District, all of which are already affected by traffic using the A25. Traffic generation is an important issue given the current traffic conditions on the A25 and concern is expressed about the impact of traffic on local amenity in terms of noise, fumes and vibration on properties along the A25 in the District. Concern is also raised as to the wider impact on the other settlements along the A25 in the District, Oxted and Nutfield, and on properties on any routes likely to be used by HGVs.

Sevenoaks - The sustainability appraisal highlights the need to protect the character of the landscape and the historic park. If the proposal were to lead to an increase in traffic movements both within and on routes accessing the site, the District Council would have serious concerns regarding the proposal . This is a very important issue as it would effect air quality, pollution, noise levels and the amenities of near by residents and of those along the access routes (see General Concerns regarding Air Quality and Noise, below). Fur- ther information should be provided on whether the new proposal leads to any increase in traffic movements beyond that identified in the approved restoration scheme, before any decision on the allocation is made.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 105 Kent County Council—Waste Sites Options Commentary Report

Parish Councils Oxted are vehemently opposed to any proposal to include Covers Farm as an infill site in the Kent County Council Minerals and Waste Plan. There is widespread local opposition from parishioners, resident groups, neighbouring parish councils and the district council. Oxted Parish Council fully supports Tandridge District Council's objection, on the grounds set out below: Kent Downs AONB Whilst there are potential opportunities for a new supply of sand and gravel from this site, there are a lot of unknowns, in terms of estimated output, life of operation, access and vehicle movements that make appraisal of this site difficult at this stage. The site lies to the north the South Downs AONB which will warrant consideration to any landscape and visual impacts on the AONB, given any potential cumulative impacts with existing permitted sites within the area. Consideration is required to what benefits the site could bring through restoration proposals.

Heritage General background potential for Roman remains. The western boundary is formed by an early medieval boundary, the earthwork for which is preserved as a Scheduled Monument to the south of the site. Development proposals should avoid impact on this boundary. There may be historic landscape constraints in the southern area of the site which forms part of a historic park listed in the Kent Gardens Compendium. The registered Historic Park and Garden of Squerreys Court lies to the south of the site and the Westerham Conservation Area to the south east. Covers Farm immediately to the south is a listed building. Biodiversity EPS, UKProtect, Local and Local Site all located within site. Uk Site located within 1Km of site. Highways Yes but impacted upon at times of congestion as a result of M25 traffic incidents. To the east Riv- erhead, bat and ball junction and Seal on the A25 are all AQMA listed. Concerns likely to be raised by adjacent authorities.

No planned road improvements. National England The site is within the Kent Downs AONB. Restoration contours should be guided by the original land form and Local Landscape Character. Natural England would also advocate the after use of the site incorporates biodiversity improvements and open access for the nearby settlement of Westerham. General Public Responses unacceptable traffic implications Site is located within the AONB and the Green Belt.

Already frequent traffic congestion along the A25 either side of Covers Farm

Vibration, damage, air, noise & dust pollution

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 106 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 24

Land North of Addington Support 2

11.4 This site has also been proposed for sand Extrac- Comment 3 Responses tion. The site will require inert fill for restoration.

Object 2

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Responses District/Borough TMBC- The site is a proposed extension to the existing Addington (Wrotham) Quarry. The site is within the Kent Downs Area of Natural Beauty and contains Folkestone beds sand. The upper sands are intended for building sand and the lower deposit is suitable for use as industrial sand.

Utility Companies Southern Water- Within SWS waster water area.

Heritage High potential for the presence of important archaeological remains. Further archaeological assessment including field evaluation is necessary. May have an impact on the setting of Listed Buildings at Woodgate and Woodgate Cottages.

Biodiversity European Protected Species within site. UK and Local protected species within 1km of site. UK and Local designated sites within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 107 Kent County Council—Waste Sites Options Commentary Report

Natural England Site within Kent Downs AONB. Whilst this site is an extension of an existing quarry it extends the operation to the north of Addington Lane on the opposite side to the existing workings and potentially opens up the possibility of extending quarrying operations eastward. The Council will need to be satisfied that the site meets the "exceptional circumstances‟ required under PPS7. Kent Downs AONB The KD AONB will resist and object to this site. It prolongs the life of a plant and activity in the AONB that should never have received planning permission. Restoration quality is not good and not guaranteed. The landscape impact on the AONB is not justified by either the need for soft sand, or not particularly high grade silica sand. Alternative sources outside the AONB should be sought and a robust attitude to defending the AONB against further incursion should be taken. Only then will alternative sites outside the AONB designation come forward form the operators. Grant of permissions in the AONB should only be contemplated in exceptional circumstances. Allocation likewise exceptional circumstances cannot be identified and this site

The National Trust Object- 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 is hitherto open countryside, and is likely to be highly visible from the Downs.

Protect Kent Rejection recommended, due to: site being within the Kent Downs AONB; cumulative landscape and visual impacts; proximity to SNCI and Ancient Woodland that is already impacted by quarrying in the vicinity; impact on public rights of way.

RSPB This site is within the Greensands Heaths and Commons BOA for which heathland and acid grassland are advocated for restoration. We would encourage restoration of this site to one of these habitats, or to woodland to complement the nearby site. Should the restoration be to agriculture as proposed, biodiversity gains should still be included, for example ponds and species rich hedges.

Kent Wildlife Trust This site is within 86m of Ryash Wood LWS designated for its ancient woodland. The woodland and the site's ecological health is dependant on its hydrology being damp in nature Although we do not object to this site being excavated as it is a natural extension of the existing quarry, attention should be given to protection of the LWS from the impacts of dust and other pollutants.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 108 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 41

Cryalls Lane Support 1

11.5 This project requires impiorting significant quanti- Comment 1 Responses ties of soil type material but will need to be generated appropriately to ensure that the integrity of the adjacent nature reserve is maintained. This site can also be Object 4 found in Chapter 11: Environmental Improvements to Closed Biodegradable Landfill Sites. 012345

Responses District/ Borough Swale - The Council object to this site and any potential should be discounted due to access and residential amenity issues. The Council would also require further information as to the means by which the biodiversity of the existing and adjacent sites would be maintained and enhanced. There may be a residential amenity and highways problems with transporting in large amounts of soil, especially as access is via a rural lane. The Council accept that a gas control system would help the long term sustainability of the site, but has res- ervations about the amount of engineering works needed. It is already a nature reserve and the impact on the biodiversity and the impact on the amenity of the residents requires close scrutiny. There is not sufficient information on which to base a full judgement.

Heritage Development of the Cryalls Lane site could potentially affect buried archaeological deposits in areas that have survived quarrying. A programme of archaeological works should be implemented in advance of development. This can be secured through a condition on any consent.

The proposals may have an impact on the amenity of the Borden Conservation Area and the setting of Listed Buildings in Borden and at Cryalls Farmhouse. Prior to permission for development, the impact of the proposals upon the Listed Buildings and the Conservation Area should be fully assessed and mitigation measures undertaken to avoid impact on their setting. Where significant impact on the setting of the Listed Buildings or Conservation Area can not be avoided then consideration should be given to refusal of the permission for that area. The full re- Kent County Council—Waste Sites Options Commentary Report

Biodiversity EPS, UKProtect protected species within 1km of site.

Highways Access from Cryalls Lane via Adelaide Drive would be considered acceptable through these residential street, and the alternative routes through Wises Lane to reach the A2, or through Borden are narrow and not conduc- tive to HGV traffic. No planned road improvements. No planned developments.

Kent Wildlife Trust The site is shown within the Kent habitat survey as the richest area for biodiversity within the locality and we understand it is a nature reserve. We have concerns regarding the destruction of what appears to be regeneration of a valuable habitat for wildlife. We however acknowledge that public safety needs to be paramount. If restoration works are required to ensure gas is controlled then we would not object to the proposed works. We would be concerned however if large amounts of soil are imported on site and would question the need for the importation of soil. The site should be returned to neutral grassland once installation of the gas control system is completed. Unless these terms are imposed, we object to the allocation of this site.

Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the unknowns are understood and resolved; the gas control and recovery proposals are clarified; proposed restoration is agreed and conditioned beforehand; "soil type materials" as inert fill is imported for restoration purposes only; the impacts of HGV traffic on neighbouring roads are understood and mitigated for.

Kent County Council Waste KCC (Waste) are promoting a scheme that will undertake very necessary repairs and replacement works to Management the failing gas control system. The site is a former landfill site which over time has significantly subsided to the extent that existing environmental protection measure might soon be compromised if re-engineering works are not carried out.

The site is currently a well established Nature Reserve and the proposal seeks to build on and to enhance these qualities through careful working and management of the project. The finished scheme will provide a sustainable long term opportunity for the benefit and enjoyment of the community. General Public Responses The area is known as a nature reserve and is used by walkers The road access to this site is totally insufficient

The environmental impact of noise and dust,

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 110 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 50

Ightham Sand Pit Support 0

11.6 Site submitted for sand extraction as an extension Comment 4 Responses to the existing quarry. The site restoration proposal include the need for inert fill. Object 4

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Responses District/ Borough TMBC- The site lies within the MGB and open countryside. The site also lies adjacent to a LWS. See policies CP 3, CP 7, of the TMBCS and NE 1 of the MDE DPD. Parish Council Borough Green- It is without doubt crucial to safeguard mineral deposits from development so supplies remain available for the future. However, this site is particularly sensitive because of its proximity to Ightham Court a Grade 2 Listed 16 th Century house and Historic Gardens, both included in the Historic Buildings and Gardens section of the T&MBC LDF MDE-DPD Annexe E. The environment and setting of Ightham Court and its gardens must be preserved form this sort of development. The site is also within Greenbelt and the North Downs AONB.There are currently ample supplies of the soft sand within the immediate area without using this Western Extension.

This view is taken from Celcon’s site access road across the fields to Ightham Court. It is the only remaining part of the green wedge to Ightham. It is part of the Kent Downs Area of Outstanding Natural Beauty and will be lost if Site 50 continues into the MDF. The chimneys of Ightham Court, a Grade II Listed Building can be seen to the right.

H+H Celcon has not quarried sand in Ightham Sandpit since the late 1980s and has no visible equipment in place to do so. Therefore extending the quarry does not carry the normal benefits of transference of plant.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 111 Kent County Council—Waste Sites Options Commentary Report

These fields are in the Kent Downs Area of Outstanding Natural Beauty and should only be considered if there were no alternative sources of a valuable commodity. Since there is an abundance of sand quarries in the vicinity and in Kent, sand is not a valuable commodity, there are alternative sources and therefore this area should be preserved intact.

Utility Companies Southern Water- Within SWS wastewater area Not assessed for source protection, as outside supply area Heritage The northern part of the proposal site falls within the Grade 2 Registered Park and Garden at Ightham Court. Ightham Court is a Listed Building as are a number of features in its gardens.

There is a background prehistoric and Roman Potential in this area including the potential for Palaeolithic fissure sites. Neolithic flints and a Roman cremation have been found west of Ightham Court. A rectangular feature can be seen on the Google Earth aerial photo of the site. Biodiversity EPS, UKProtect and LocalSite located within 1km of site

Highways HGV Route along A25. No Planned Highway improvements. No proposed improvements. Only proposed development is a large residential development off of Quarry Hill Road (No application has been submitted to date).

Kent Downs AONB The mapping of the sites 50, 55 and 9 have become confused. Therefore it is difficult to comment. However the Kent Downs object to the extension of working for minerals, the gasification plant location and the filling of any of the sites. (A proper overall programmed plan of restoration for the whole site and care of biodiversity

General Public Responses Site in the Green Belt and the North Downs AONB Close proximity to Ightham Court which is a listed building

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 112 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 56

Hegdale Quarry support 0

11.7 This is an existing site which extracts chalk for use as comment 2 Responses agricultural lime, yard chalk and constructional fill. The site is within the Kent Downs Area of Outstanding Natural Beauty. object 2

0 0.5 1 1.5 2 2.5

Responses

Utility Companies Southern Water- Within SWS waste water area. Heritage No archaeological measures are necessary in connection with the proposals. Development should consider and avoid any impact on the setting of the Listed Building at Hegdale Farmhouse

Biodiversity European and UK protected species and local designated site within 1km.

Highways The access to the site is an existing one from the A251 (which is a lorry route) KHS cannot therefore foresee any issues with this site. There are no planned improvements or developments.

KCC Enforcement Needs to reflect the fact that the site is subject to a proscribed scheme of working; with restoration to original levels. That in turn requires the removal of some 10,000 m3 of development spoil, tipped (without planning permission) within the adjoining dry valley. The material is required to be dispensed with in a phased way, as quarry backfill. The importance of the above is that there is a requirement to restore the site and in doing so, repair the damage to a protected valley feature within the AONB. For that reason an extension to the site area should be considered, to ‘bring-in’ this ‘extra’ area. The premise should be that whatever is proposed incorporates these enforcement requirements. They are integral to the current planning permission and cannot be set aside.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 113 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Natural England This is within the Kent Downs AONB. While an existing quarry consideration needs to be given to whether it is appropriate to extend the life of the quarry given its sensitive location. Given the location within the AONB we would question the ac- ceptability of increasing activity by processing inert and excavation waste.

Kent Wildlife Trust Site 56 is within the locality of ancient woodland and it will be important within the proposed processing of inert and construction waste that there is no pollution of the ancient woodland. Kent Wildlife Trust has no objections to the proposed plans provided the above safeguards are included in any permission granted.

RSPB It would be important to ensure there were no negative hydrological impacts on the adjacent Ancient Woodland sites and on the adjacent Postling Wents Woods SINC. Restoration of this site should complement the adjacent Ancient Woodland, as such restoration to native broadleaf woodland would be appropriate. In addition, it should be ensured that the treatment of waste does not negatively affect the adjacent Ancient Woodland.

Protect Kent Object- Rejection recommended, due to: a very sensitive site, in the middle of the AONB, adjacent to Ancient Woodland; distance from sources of construction waste. Note: we believe the site should be restored as soon as possible, in line with the existing permission.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 114 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 70

Stonecastle Farm Quarry Lake Support 1

11.8 Site has also been proposed for mineral extraction. Comment 4 Responses The restoration proposals for this quarry require inert fill. This site can also be found in the Minerals Sites DPD. Object 0

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Responses District/ Borough TMBC- Part of the site lies outside the Borough Boundary. The area of the site that lies within the TMBC area lies within the MGB. This is an extension to the existing Stonecastle Farm Quarry. The site is within close proximity to other permitted sites and call for sites submissions. The area is located to the north of the South Downs Area of Outstanding Natural Beauty. Parish Council Capel- Has no objection to the extension of the existing Stonecastle Farm site, subject to restoration and environmental safeguards

Utility Companies Southern Water- With SWS waste water area. Heritage The Stonecastle Farm Quarry site has a general archaeological background potential with particular potential for prehistoric sites as have been recorded in areas of the quarry during archaeological monitoring. Monitoring of the existing quarry works has also identified timbers of possible prehistoric, Roman or Saxon date. A number of WWII defensive sites such as pillboxes, spigot mortars and a decoy site are located along the Medway to the north and features associated with these may fall within the site in unquarried areas. Quarrying on the scale of this proposal site could have a very significant impact on the historic landscape. Although the existing quarry workings have had their affect on the historic landscape, many of the channels and boundaries present within the proposal site today are also present on early maps. A number of hedgerows also appear to survive from the 1st Edition Ordnance Survey map. A medieval moated site lies to the south west of the proposal site at Moat Farm. Listed Buildings lie to the south of the site at Whetsted, Little Eden Farm and Moat Farm.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 115 Kent County Council—Waste Sites Options Commentary Report

Biodiversity Local and UK protected species and Local designated site within site. European protected species within 1km.

Highways HGV route along A228.

Environment Agency There would be concerns about impacts on the Hammer Dyke and the vast number of other waterbodies found across this site. Similar to Site 17 there is potential to enhance these watercourses and make restoration proposals positive for nature conservation.

RSPB RSPB- these sites cover an extensive area and incorporate many of the dykes and ditches that feed East Tonbridge Copses and Dykes and River Medway LWS. The LWS is designated for its freshwater and river habitats, wet woodland and grassland. It contains important assemblages of dragonflies and damselflies as well as rich communities of birds The sites are in much closer proximity to the LWS than site 17 and incorporate a number of blocks of ancient woodland. Although we welcome the habitat re-creation proposed we feel that it is likely that the impact on the LWS would be too great to be viable if either of the sites were allocated and the in-combination impacts of both sites would almost invariably cause unsustainable impacts to the water environments within the LWS. Operator/Agent LaFarge Aggregates Ltd— Lafarge have waste interests at Stonecastle Quarry Lake, and have submitted this site through the previous call for sites for the Waste Site Allocations DPD. Details of this proposed site will be expanded upon below. Lafarge would note that the Plan should make clear the use of inert restoration materials in the restoration of sand and gravel quarries within the County which is a valuable use of the resource and helps deliver enhanced restoration to conservation, agriculture and other beneficial land use. This is often associated with recovery and recycling operations to segregate the recyclable elements of the construction and demolition waste stream, located at specific sites or quarries.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 116 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 79

Tilmanstone Support 1

11.9 The site is a former brickworks. The site has been Comment 1 Responses promoted as an expansion to the operator’s existing and proposed sites in the area. It is unknown at this stage what the site would be used for, it is therefore being Object 2 considered for a variety of waste uses. 00.511.522.5

Responses District/ Borough Dover- Existing industrial use, high unemployment area, potential economic benefits apparent and identified in core strategy. However the site has a poor road network and is close to residential areas. Pollution, noise and health risks would need further assessment. No objection but with caution. Parish Council Tilmanstone - I note that the operator of the proposed site has yet to give any information concerning their proposed use therefore it is impossible for the local community to voice any objection or indeed support for the project. Without the necessary information how can we as a community take part in your 'consulation' what assurances do we have that you will not go ahead without having our views if the operator deliberately delay their response on information. This would make a nonsense of the ' consultation process'. Utility Companies Southern Water-Strong planning policies will be required to protect underground sewers and/or water mains. Heritage The proposed waste allocations site lies in an area rich in archaeology. The majority of the site is formed by the spoil tip of the former Tilmanstone Colliery, the deposits of which are a RIGS site. The north west quarter of the site is undeveloped and would retain considerable archaeological potential. The surrounding area is rich in buried archaeology which can be seen on aerial photographs as crop mark sites. In particular a significant set of enclosures and trackways lies immediately south west and other cropmarks in the area include the traces of Bronze Age barrows. Remnants of the East Kent Light Railway cutting survive crossing the northern part of the site.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 117 Kent County Council—Waste Sites Options Commentary Report

Biodiversity European, UK and Local protected species and Local designated site within 1km. Kent Wildlife Trust Kent Wildlife Trust has no objections to an aggregate recycling plant on this site. Protect Kent Object- Rejection recommended, due to: the number of unknowns about this site; the lack of clarity on specific uses; its distance from likely sources of waste; its proximity to the village of Elvington; the possible impact on the public right of way along the southern boundary of the proposed site; the majority of the site being a Regionally Important Geological Site RSPB We would encourage restoration of this site to biodiversity, for example to woodland to complement the nearby Ancient Woodland.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 118 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 87

Charing Quarry (Waste 3) Support 1

11.10 This site is a former sand and gravel quarry. The Comment 3 Responses operator requires the construction and demolition waste for restoration Object 294 (Responses include a resident petition of 201 signatures)

0 100 200 300 400

Responses Heritage This proposed waste site lies within an area of high archaeological potential. Investigations at Charing Quarry have revealed remains of an Iron Age and Romano British farmstead and occupation site. Remains have included structures, cremation burials and an extensive ditched field and boundary system. The majority of this proposal site has been quarried. The quarrying was subject to archaeological monitoring and investigation by Archaeology South East and remains of prehistoric and roman date were recorded. The final extent of present quarrying remains unclear and the proposal site includes areas that have not been quarried, particularly on the western edge of the site and to the south and south east. In these areas there remains the potential for survival of archaeological remains. There is a potential for Palaeolithic fissure sites in the sandstone and there remains a possibility that such fissures may be seen in the faces of the quarry.

There is a Listed Building close to the application site at Little Swan Street Farmhouse, another south at Swan Street and west at Cherry Tree Road. Biodiversity EPS Protected species within site. UKProtect, Local and LocalSite protected species within 1km of site.

Highways The site is an existing sand extraction pit and so it is assumed that access will be from the existing site access on Hook Lane. Hook Lane has been widened in recent years to improve access to the existing site, therefore KHS cannot foresee any issues with this site. There are no planned improvement to Hook Lane. There are no planned developments that are likely to impact on the road.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 119 Kent County Council—Waste Sites Options Commentary Report

Kent Downs AONB In the setting of the Kent Downs AONB. Important that the N facing slope is well restored and wooded to ensure the scar of the sand batter is not seen from the north.

Kent Wildlife Trust This site is adjacent to Spring Wood ancient woodland. We do not agree with the restoration plan recommended. The restoration plan should be biodiversity enhancement rather than low level agriculture as proposed. (See KWT response to Policy DM16 After use of the Core Strategy for further details regarding our position on restoration) It will be important to consider the in-combination impacts of this development with Site 74, 77 and 86 of the Minerals Sites document and site 85 within the Waste sites document. The Trust objects to the allocation of this site pending the outcome of the in-combination evaluation and revisions to the restoration proposals.

Kent Downs AONB The site is within a former sand and gravel quarry and the proposal would provide construction and demolition infill as part of the restoration proposals. There are no significant constraints identified in relation to the site that could not be mitigated through maintaining high environmental standards during operations. In the setting of the Kent Downs AONB. Important that the N facing slope is well restored and wooded to ensure the scar of the sand batter is not seen from the north. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: proposed restoration is agreed and conditioned beforehand; inert fill is imported for restoration purposes only.

Owner/Operator Charing Quarry currently has the benefit of a planning permission for mineral extraction and processing.

The location of the proposed area, lying to the North West of the existing mineral processing plant at the quarry, is shown on the identification drawing.

Brett have employed the services of SLR to undertake a Hydrogeological Risk Assessment, to asses the factors of revising the restoration proposals, incorporating the importation of inert Fill In addition, water monitoring boreholes have been established over the site and groundwater levels and quality data are being collated. Attached is a report from SLR summarising in detail the results of these surveys to date.

The conclusion of this report states that "the installation will only accept inert materials which do not require testing under the Directive and Environment Guidance, and therefore the site is not required to collect leachate. Further, it is noted that the engineering requirements are much reduced for inert sites relative to non-hazardous or hazardous sites, such that an artificial sealing liner and low permeability are not required. General Public Responses Increase in traffic movements causing further congestion on our country roads. Noise, Smell, Security lights and Security

Many sites are easily viewed from the ‘Area of Outstanding Natural Beauty’ and ‘Special Landscape Area’.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 120 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 89

Hollowshore Support 1

Comment 11.11 A proposed extension to a sand and gravel 3 Responses quarry. This site would require inert fill for restoration.

Object 674

(Responses include a resident petition of 616 signatures) 0 200 400 600 800

Responses

District /Borough Swale- The Council conditionally object as the Council would need to be (a) satisfied that there would be no significant effects upon the SPA/RAMSAR; and (b) that any adverse landscape impacts could be minimised/ mitigated. It is assumed that the stability of the sea wall would not be undermined. However, if it was deemed that this site was essential to meet the needs of sand and gravel across Kent then the Council feel that this site would be preferable over the other sand and gravel sites in Swale.

Faversham Town Council– Considers that these sites identified in the Framework Consultation are totally unsuitable for inclusion in the Plan because of their status and would urge Kent County Council to remove these two environmentally important and sensitive sites from the Plan.

Utility Companies Southern Water-Within SWS waster water area.

Heritage Has a high potential for the presence of important archaeological remains. Further archaeological assessment including field evaluation is necessary. May have an impact on the setting of Listed Buildings the Shipwright Arms and at Ham Farm. The impact of the proposals upon the Listed Buildings should be fully assessed. The proposed allocation site should include a substantial buffer around the Shipwright Arms.

Biodiversity European, UK and Local protected species within site. European and UK designated site within site, Local designated site within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 121 Kent County Council—Waste Sites Options Commentary Report

Highways Access from Ham Road would be problematic, due to its single track nature with lack of passing places. Planned road improvements- Ham Road/Priory Row junction-alterations to kerbline. Faversham Foundry. Oare Road-New traffic signalled junction to serve housing development on site of former Faversham Foundry. Environment Agency There would be serious concerns for any allocation at this site, due to the wetland sensitivities.

RSPB Object-These sites form part of The Swale Estuary and Marshes SPA/Ramsar site. Direct land take from the SPA/Ramsar site will have a significant adverse effect on the SPA. While we agree with the finding of the SA we do not believe that mitigation is possible. Only in the absence of alternatives and where there are imperative reasons of overriding public interest could such a proposal go ahead. Natural England Within the Swale SPA, Wetland of International Importance under the Ramsar Convention and SSSI. Sand and gravel extraction will damage or destroy the Ramsar features on site and significantly disturb the SPA bird interest. There are alternative sites and the inclusion of these sites would not meet the requirements of the Conservation of Habitats and Species Regulations 2010. Kent Wildlife Trust As identified within the SA these sites are within an extremely sensitive area with a plethora of national and international designations associated with the Swale Estuary. They are in very close proximity to two of our sites Oare Marshes and South Swale. We appreciate that the restoration plans incorporating shallow water bodies and ditches may improve this area for wildlife but the loss of grazing marsh habitat is likely to be too high a cost. Protect Kent Rejection recommended, due to: the site is designated as SSSI, SPA, Ramsar; impacts on adjacent Sched- uled Monuments; impact on public right of way; potential access difficulties. Landowner Support- The source of aggregates at Hollowshore is from a known geological deposit, of known quality, which has served the local construction markets for many years. It also benefits from an existing mineral processing plant on the adjacent site at Faversham Quarry. Faversham Quarry has excellent and established links to the local highway network. The designation does not preclude mineral extraction and if carefully managed, the restoration of the site following mineral extraction will offer a better and more bio-diverse environment.

General Public Response 616 objections from patrons of the Shipwrights Arms- -protected as an SSSI and designated RAMSAR-People who use a near by boat yard will be disrupted-The marsh harbours and is a breeding ground for vulnerable and endangered flora and fauna- Also used as a base for migratory birds.-The local pub relies on passing trade in the summer from walkers on the marsh.-A considerable area between two critical waterways, Faver- sham Creek and Oare Creek would be affected-Noise-Special Protection Area under the EC Birds Directive. - Negative impact on tourism-Will take many years for the site to recover-Used for leisure activities such as dog walking and bird watching

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 122 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 90

Ham Farm Support 0

11.12 A proposed extension to a sand and gravel Comment 1 Responses quarry. The site would require inert fill for restoration.

Object 651

(Responses include a resident petition of 616 signatures) 0 200 400 600 800

Responses District / Borough Swale- The Council conditionally object as the Council would need to be (a) satisfied that there would be no significant effects upon the SPA/RAMSAR; and (b) that any adverse landscape impacts could be minimised/ mitigated. It could also have potential landscape impacts. It is assumed that the stability of the sea wall would not be undermined. However, if it was deemed that this site was essential to meet the needs of sand and gravel across Kent then the Council feel that this site would be preferable over the other sand and gravel sites in.

Faversham Town Council– Considers that these sites identified in the Framework Consultation are totally unsuitable for inclusion in the Plan because of their status and would urge Kent County Council to remove these two environmentally important and sensitive sites from the Plan. Utility Companies Southern Water-Within SWS waste water area.

Heritage The proposed minerals site has a high potential for the presence of important archaeological remains. Further archaeological assessment including field evaluation is necessary. The proposed mineral extraction of this site may have an impact on the setting of Listed Buildings and in particular those at Ham Farm and Ham Farm Cottages. Prior to permission for extraction, the impact of the proposals upon the Listed Buildings should be fully assessed and mitigation measures undertaken to avoid impact on their setting. Biodiversity European, UK and Local protected species within site. European and UK designated site within site, Local designated site within 1km.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 123 Kent County Council—Waste Sites Options Commentary Report

Environment Agency Object- There would be serious concerns for any allocation at this site, due to the wetland sensitivities. Natu- ral England will comment further on its importance as part of the SPA/Ramsar and SSSI. Natural England Both these sites are within the Swale SPA, Wetland of International Importance under the Ramsar Convention (Ramsar Site) and SSSI. Sand and gravel extraction will damage or destroy the Ramsar features on site and significantly disturb the SPA bird interest. The inclusion of these sites would not meet the requirements of the Conservation of Habitats and Species Regulations 2010, nor will it meet the test of soundness under PPS12. Kent Wildlife Trust As identified within the SA these sites are within an extremely sensitive area with a plethora of national and international designations associated with the Swale Estuary. They are in very close proximity to two of our sites Oare Marshes and South Swale. We appreciate that the restoration plans incorporating shallow water bodies and ditches may improve this area for wildlife but the loss of grazing marsh habitat is likely to be too high a cost. RSPB Object-These sites form part of The Swale Estuary and Marshes SPA/Ramsar site. Direct land take from the SPA/Ramsar site will have a significant adverse effect on the SPA. While we agree with the finding of the Sus- tainability Appraisal we do not believe that mitigation is possible. Further, we do not agree with the conclusion that this effect would be negated by the progressive working of the site. We expect this site to be thoroughly appraised as part of the HRA. Only in the absence of alternatives and where there are imperative reasons of overriding public interest could such a proposal go ahead. Protect Kent Object- Rejection recommended, due to: the site is designated as SSSI, SPA, Ramsar; impacts on adjacent Scheduled Monuments; impact on public right of way; potential access difficulties. Owners Support- Brett have been working with their Consultants, Bioscan, to make sure that all relevant data is being gathered so far as the ecology of the area is concerned. It will be necessary to engage with Natural England to talk about the most appropriate method of any extraction. Brett's consultants feel there is an opportunity to actually enhance the quality of this part of the marsh through careful consideration of the way in which the work is done. This Reserve offers the opportunity of winning a reasonably substantial amount of aggregate within a reasonably small surface area . It is difficult to imagine a site that could in these terms be more "sustainable" involving a very short distance back to the Plant site, and much of that route could probably be accommodated within private land. General Public Comments 616 objections from patrons of the Shipwrights Arms- -protected as an SSSI and designated RAMSAR-People who use a near by boat yard will be disrupted-The marsh harbours and is a breeding ground for vulnerable and endangered flora and fauna- Also used as a base for migratory birds.-The local pub relies on passing trade in the summer from walkers on the marsh.-A considerable area between two critical waterways, Faver- sham Creek and Oare Creek would be affected-Noise-Special Protection Area under the EC Birds Directive. - Negative impact on tourism-Will take many years for the site to recover-Used for leisure activities such as dog walking and bird watching

The full re- Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 93

Highstead Pits 3, Sittingbourne Support 0

11.13 Inert waste is likely to be needed for restoration Comment 2 Responses but there are no details at this stage.

Object 180

0 50 100 150 200

Responses District / Borough Swale - The Council strongly object to this site due to the SNCI, the highway concerns and residential amenity issues. The unknown nature of the proposals, allied with their scale, would have the potential for significant environmental harm over a considerable period of time.

The Council would dispute the ‘restoration’ label to these proposals. These quarries were excavated many years ago and KCC have previously confirmed that they would not enforce restoration condition given nature conservation interests on the site. All 3 pits have biodiversity interest and are an SNCI and it is adjacent to ancient woodland. There would be major amenity and visual impact concerns due to the traffic and the operation. There would be local highway concerns due to the increase in lorry traffic. There are additional houses close to the north of the site which are not shown on the plan provided. (Eden Park.)

Parish Council Rodmersham – Negative impact on the water table including risk of contamination to the water table. This site was included on a previous waste and mineral consultation many years ago but was later rejected/ withdrawn because Southern Water raised serious concerns about contamination leeching into the water table. We believe that nothing has changed, the water table on occasions fills the bottom of the pits. Negative impact on the wildlife that inhabits the pits, the nearby ancient woodland and environs. Negative impact on archaeology. We refer specifically to ancient archaeology referred to in the book "Woodstock an archaeology mystery" by Lesley Feakes (ISBN 1-873953-33X). Negative impact on the environment- additional traffic generated from waste disposal vehicles travelling along small country lanes could damage the rural lanes Nega- tive impact on residents - affecting residentail amenity - light/noise/smell etc The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 125 Kent County Council—Waste Sites Options Commentary Report

Utility Companies Southern Water – Located within Special Protection Zone 2. Within Wastewater Water supply area and Wa- ter supply infrastructure crossing. Heritage The three former chalk quarries lie within an archaeologically sensitive area with Neolithic, Iron Age and Ro- man finds having been made in the area in the past. Iron Age and Roman burials were excavated in the area of the quarry to the north of Cromer Road. A number of finds have been noted in the area of Highsted Wood to the south east of the southern quarry.

The nearest Listed Building is Highsted Farm 200m to the south east Biodiversity EPS, Local and LocalSite protected species located within site. UKProtect protected species located within 1km of site. Highways Access links to these sites are not suitable for significant levels of HGV traffic, and would pass along significant lengths of residential roads, albeit busy access routes into Sittingbourne from the rural areas to the south. Use of these sites is likely to lead to a worsening of performance of a number of junctions along the route, including the Woodstock Road/Ruins/Barn Road/ Tunstall Road junction as well as those along the length of Bell Road that currently experience difficulties during peak times. Planned road improvements – Woodstone Road/Ruins Barn Road/ Tunstall Road Junction alternation. Planned dvelopments –expansion of Kent Sci- ence Park. Kent Wildlife Trust This site incorporates the whole of Highsted Quarries LWS designated for its regenerated chalk grassland habitats and bird populations. If these quarries were filled with inert waste all biodiversity present would be lost. For this reason Kent Wildlife Trust objects to the proposed infilling of this site. We do not agree with the SA that high environmental standards would need to be maintained and the site restored to a high standard as this would cause irreversible damage to the biodiversity interest. We object to the proposed plans and recommend that the quarry be managed for wildlife with no infilling taking place. Protect Kent Rejection recommended, due to: the number of unknowns about the proposal; the site is a longstanding un- restored site that has well established nature conservation interests and is designated as a local wildlife site (SNCI); there is no requirement to restore it; impact on residential amenity as a result of HGV movements. Operators/Agent Paul Sharpe Associates LLP - It appears that Kent Wildlife Trust has indeed designated the site (3 No. pits) as an SNCI (now Local Wildlife Site) and it is this designation that is now incorporated into the Swale Borough Local Plan 2008. However, the biodiversity value of the site is declining as birch regeneration be- comes dominant and whilst the site undoubtedly retains some nature conservation value, its classification as a Local Wildlife Site must be in doubt. General Public Responses Road access to the area is very narrow and cannot be made wider because of the quarries themselves Noise and dust to neighbouring properties

Important local wildlife site The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 126 Kent County Council—Waste Sites Options Commentary Report

11 Inert/Construction, Demolition and Excavation Landfill & Landraise

Site 95

Stone Gate Support 0

11.14 The site is currently operating as an inert landfill Comment 2 Responses site. The landowners would like the site to be considered for a wider range of waste’s than currently approved to include non-hazardous wastes. Object 3

01234

Responses District / Borough Dartford - The site is bordered by residential areas. Given the proximity of established residential communities adjacent to the pit, should further tipping be permitted it should only be with inert waste.

The Submission Core Strategy (programmed for adoption in September 2011) identifies the site as a key development site (Policy CS 4 and Diagram 5). The site forms part of Dartford’s 5 year housing land supply and the site is the subject of a current planning application for predominantly residential use. A non-inert use would be incompatible with the development of the site. Utility Companies National Grid - National Grid does not object to the proposals outlined, however the following points should be taken into consideration. National Grid does not own the land over which the overhead lines cross, and 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.

Southern Water – No proximity to Source Protection Zones

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 127 Kent County Council—Waste Sites Options Commentary Report

Heritage Although this site lies in an area which is rich in archaeology particularly of Iron Age and Roman date, previous quarrying and landfill operations on the site are likely to have removed this potential. There remains potential for archaeological deposits, particularly Pleistocene gravels to remain exposed in the quarry faces.

Biodiversity UKProtect protected species located within site. EPS, Local, UKSite and LocalSite protected species located

Kent Wildlife Trust We have no objection to this site infilling with other forms of waste including non hazardous waste providing there are no impacts on the calcareous habitats created within the Bluewater complex adjacent to the site.

Protect Kent Rejection recommended, due to: the number of unknowns about this site; the lack of clarity on specific uses; impact on neighbouring residential property and amenity. General Public Responses Site too close to residential areas Loss of a significant area of Local Wildlife

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 128 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 39

Chilmington Support 1

12.1 Environmental Improvements to Closed Bio- Comment 2 Responses degradable Landfill Sites

Object 0

00.511.522.5

Responses Utility Companies Southern Water – Not assessed as outside supply area. With wastewater area.

Heritage The proposed waste site lies in an area with significant archaeological potential which is presently being assessed through the wider development of Chilmington Green. A Roman road is projected to run through the present site and the Hythe beds which the site lies on has the potential to contain Palaeolithic fissure sites.

It is believed that the majority of the site has been previously quarried and landfilled and potential is therefore limited to the fringes and sides of the site. The nearest Listed Building is sited at Little Moat Farm 400m to the west and a Scheduled Monument, Moat farm lies 500m to the east. Both sites are screened from the present site by the tree belt mentioned above, however removal of this may expose the setting of the Listed building to the development works.

Development of this site is unlikely to cause archaeological impact on buried deposits.

The tree belt acts as a screen between the landfill site and the Listed Building and Scheduled Monument at Moat Farm to the north west. Prior to permission for development, the impact of the proposals upon the Listed Building and the Scheduled Monument should be fully assessed and mitigation measures undertaken to avoid impact on their setting including improved screening if necessary

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 129 Kent County Council—Waste Sites Options Commentary Report

Biodiversity European, UK and Local protected species and Local Designated site within 1km.

Highways The access to this site would be from Bucksford Lane and Mock Lane/ The narrow width of these lanes is cause for concern. Therefore more information is required on expected HGV movements and access improvements. There are no current planned improvements to Mock Lane or Bucksford Lane. There are no planned developments that are likely to impact on road capacity

Kent Wildlife Trust We have no objection to either the improvement of the pollution control system, waste recovery or removal of the cap and installation of energy from waste plant. We support the aim to reduce pollution emanating from this site and welcome the uses envisaged for the waste product.

Protect Kent Protect Kent - Acceptable, subject to a more detailed assessment, and provided that: the unknowns are understood and resolved; impacts of traffic on neighbouring roads are understood and mitigated for; the proposals are compatible with the Growth Area Plans for the Chilmington Green area.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 130 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 40

North Farm WTS and HWRC Support 1

12.2 This site is the former North Farm Landfill Site and is Comment 2 Responses located adjacent to the North Farm waste transfer station and household waste recycling centre. The site has been promoted for consideration for waste recovery operations using Object 0 the former landfill and potential for a gasification plant for wood wastes. 00.511.522.5

Responses Utility Companies Southern Water – Not assessed as outside supply area. With wastewater area.

Development of this site is unlikely to cause archaeological impact on buried deposits.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 131 Kent County Council—Waste Sites Options Commentary Report

Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the unknowns are understood and resolved; the waste recovery operations are clarified; impacts of traffic on neighbouring roads are understood and mitigated for.

Kent County Council Waste KCC (Waste) would actively support proposals which brought about an sustainable after use for this site. Management Given the proximity to the existing Waste Transfer Station proposals for energy recovery would be particularly welcome.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 132 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 41

Cryalls Lane, Sittingbourne Support 1

12.3 This is a former landfill which is now a nature reserve. Comment 1 Responses The site is promoted to provide engineering works to install gas control systems on the site. The site requires reinstatement of the gas control system on the site. Object 4

012345

Biodiversity EPS, UKProtect protected species within 1km of site.

The environmental impact of noise and dust

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 134 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 54

Richborough Power Station Support 2

12.4 Tha landowner has promoted the site to rework the ex- Comment 4 Responses isting landfill site. The site has also been promoted for an energy for waste incinerator. This site can also be found in Chapter 4: Energy from Waste. Object 7

02468

Responses District/ Borough Dover - Support in principal subject to the need for it in light of the underused capacity at Allington. Support would also be subject to any direct and indirect impacts on the environment and local communities. Dover District Local Plan also indicates that any new development should visually upgrade the A256, all new buildings should be low rise, does not increase the risk of flooding and provision is provided for archaeology.

Sandwich Town Council - There are concerns that this area is within an SNCI and is adjacent to SSSI and Ramsar sites, SPA and Nature Reserve. It also lies on a flood plain. The council would question where the waste for the proposed site will be coming from. Also concerned about the possible effect on air and water quality. Reworking/mining of existing landfill would not be supported due to proximity to the river. Could lead

Parish Council Eastry - Opposed-This site has been in place for many years and the vast majority of it is has now reverted to open countryside. Members feel that reworking this site would be detrimental to the local environment. Woodnesborough - Object- The environmental impact on the Bird reserve is of concern as is the possibility of hazardous fumes from the incinerator. The long term advantages of the site are also in doubt. The site location is environmentally unsound in terms of traffic movement. Utility Companies Southern Water – No proximity to Source Protection Zones. Within SWS Wastewater area, SWS supply area and Water supply infrastructure crossing.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 135 Kent County Council—Waste Sites Options Commentary Report

Heritage Development in the area outside of the existing power station site is likely to have a significant impact on the historic environment. Any proposals for development in this area should include an assessment of the potential effects on the historic landscape, the setting of Richborough Castle and mitigation measures to address those effects. If unacceptable impact can not be avoided then development should be refused. Biodiversity UKProtect, Local, UKSite, LocalSite protected species within site. EPS, EuroSite protected species within 1km Environment Agency The whole 121 hectare site includes a long stretch of the River Stour and adjacent levels. These are important areas for wildlife. The River Stour is an important green corridor, and its protection and enhancement should be a key objective of any proposal. Natural England The extension of the mineral workings to the south east of the existing Stonecastle Farm Quarry brings the workings closer to the boundary of the High Weald AONB and may impact on the setting. It is important that if this site is taken forward the workings and restoration are suitably phased to minimise any visual impacts. Kent Wildlife Trust This site is near to Sandwich Bay to Hacklinge Marshes SSSI. It is within very close proximity to the Sandwich and Pegwell bay NNR, the Thanet Coast and Sandwich Bay SPA and Ramsar site. This site also is designated as an SAC. Development of site 54 will result in loss of a sizeable part of the LWS which KLIS shows as containing neutral grassland likely to be grazing marsh. For this reason we object to the allocation of the part of the site within the landfill area which is designated as LWS. RSPB The Site is situated within 500m of an internationally designated nature conservation site. situated approximately 200m from Medway Estuary and Marshes SPA/Ramsar. The National Trust This site is close to our property at Pegwell Bay / Sandwich Bay much of which is designated SSSI, National Nature Reserve, SPA, RAMSAR site and Special Area of Conservation. These proposals are likely to have significant impacts on the area and we propose that further assessment is undertaken to ensure that any adverse effects can be successfully and fully mitigated before any allocation is made in the Plan. Protect Kent Acceptable, subject to a more detailed assessment, and provided that: the nature of the 'reworking' is fully defined. Note: it is unclear whether the proposed 'reworking' of the site will involve any additional landfill which will potentially result in impacts on nature conservation interests both within and adjoining the site. Kent County Council Waste Will support proposals that bring about sustainable waste infrastructure projects in areas where these are Management needed. Richborough fits that criteria. Part of the site includes the KCC former Richborough Landfill which will be reworked. There is the potential to create additional void space and this is welcomed. General Public Response The area is primarily industrial so little residential amenity impact is anticipated, Infrastructure improvements when complete, will provide suitable access to site,Site suitable for processing but not burning of waste, Local environment is special with numerous orchids, some rare and we are on a large bird migratory route, Damage to stored vehicles near by, Subject to Ramsar and SSSI, Technology unproven, Gasification is viewed as incineration.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 136 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 66

North Farm Landfill Support 0

12.5 The site has been proposed for the capping of the land- Comment 2 Responses fill and to use the waste to generate energy. The operator would also like to utilise the landfill surface for electricity production using photo-voltaic cells. Object 1

00.511.522.5

Responses Utility Companies Southern Water – No promimity to source protection zones. Within wastewater area, infrastructure crossing site, waster supply area and water supply infrastructure crossing site.

Heritage The archaeological potential of this general area mainly relates to prehistoric findings in the area of Barnett’s Wood to the west of the railway line. No finds have been made in the immediate area and the site appears to have been heavily quarried in the past. There is some remnant potential in alluvial areas to the north of the site where it is unclear if the land has been quarried.

The railway viaduct on Powder Mill Lane at the north west tip of the site is a Listed Building.

Development of this site is unlikely to have significant archaeological implications on the basis of present knowledge although there may be some potential remnant on the northern edge. Archaeological measures can be secured through a condition on any consent.

The proposed development of this site may have an impact on the setting of the Listed viaduct at Powder Mill Lane. Prior to permission for development, the impact of the proposals upon the Listed viaduct should be fully assessed and mitigation measures undertaken to avoid impact on its setting. Where significant impact on the setting of the Listed Buildings can not be avoided then consideration should be given to refusal of the permission in the area which affects its setting.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 137 Kent County Council—Waste Sites Options Commentary Report

Biodiversity UK Protect Protected species within site. EPS, Local, UK Site and Local Site protected species within 1km of site. Highways Current capacity is currently under investigation at peak times. There are some local improvements being investigated, A21 improvements currently on hold This is a development area with committed and not implemented developments.

Natural England The site is adjacent to the High Weald AONB.

Any proposals for this site should take into account the setting of the AONB. Current restoration proposals will need to be considered. If the area was to be restored to improve biodiversity and/or provide accessible green space for local residents these would need to be reconciled with the proposed use for PV.

Kent Wildlife Trust This site is adjacent to a LWS and LNR. There is the potential for waste recovery process to damage the woodland and grassland habitats present within the designated site. It will be imperative that there are strict conditions on any waste recovery operations to ensure no pollution of the habitats within the adjacent site.

Protect Kent Rejection recommended, due to: the number of unknowns about this site; the proposal to install photo-voltaic cells across the site, and the visual impact on the AONB. Note: we suggest these two proposals be separated: the capping of the landfill is acceptable, but the installation of pv is not. This is not a matter for the M&WDF and should not influence any decision on the capping proposal.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 138 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 67

Chilmington Green Support 0

12.6 The site has been proposed to improve the cap of an old Comment 3 Responses landfill site in order to reduce the amount of gassing into the atmosphere. Install an energy from waste plant which runs off landfill gas and bio-fuel. Utilise the landfill surface for electric- Object 0 ity production using photo-voltaic cells.

01234

Responses Utility Companies Southern Water – Not assessed as outside supply area. With wastewater area. Heritage The proposed waste site lies in an area with significant archaeological potential which is presently being assessed through the wider development of Chilmington Green. A Roman road is projected to run through the present site and the Hythe beds which the site lies on has the potential to contain Palaeolithic fissure sites.

It is believed that the majority of the site has been previously quarried and landfilled and potential is therefore limited to the fringes and sides of the site.

The nearest Listed Building is sited at Little Moat Farm 400m to the west and a Scheduled Monument, Moat farm lies 500m to the east. Both sites are screened from the present site by a tree belt.

Development of this site is unlikely to cause archaeological impact on buried deposits unless works include expanded the site outside the boundaries of previous quarrying and landfill. If that is the case then further assessment and archaeological investigation and recording may be appropriate secured through an appropriate condition.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 139 Kent County Council—Waste Sites Options Commentary Report

Biodiversity EPS, UKProtect. Local and LocalSite protected species with 1km of site.

Highways The access to this site would be from bucksford lane and Mock Lane. The narrow width of these lanes is cause for concern, therefore more information is required on expected HGV movements and access requirements. There are currently no planned improvements to Mock Lane or Bucksford Lane. There are no planned developments that are likely to impact on road capacity.

Kent Wildlife Trust We have no objection to the extension of the waste transfer centre at this site.

Protect Kent This site is already included as number 39 - Chilmington. The proposals for each entry (pages 132 and 142 of the Waste Sites document) should be amalgamated, and the Sustainability Appraisal needs to be consistent.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 140 Kent County Council—Waste Sites Options Commentary Report

12 Environmental Improvements to Closed Bio-degradable Landfill Sites

Site 68

Sleedwood Landfill, Dover Support 0

12.7 the site has been proposed for the capping of the landfill Comment 5 Responses and to use the waste to generate energy. The operator would also like to utilise the landfill surface for electricity production using photo– voltaic cells. Object 4

0246

Responses District/ Borough Dover - The ‘capping' of this site could involve the use of specialised clay. The use of lorries to move the clay to the site would have a detrimental impact on the AONB & SNCI as the current tracks to the site would have to be widened. There would also be a detrimental impact on the AONB through the noise and vibration associated with such vehicles. There is also concern as to how the trucks would get to the site.

If there is no requirement to ‘cap' the site then the use of this site would be supported in principle, subject to any detrimental impact on the surrounding environment. The use of photo-voltaic cells on the site would probably not have a detrimental impact on the AONB. The site is well contained and not visible in the wider landscape. This use, however, is not a waste use and should not be considered in this Site Allocations Document.

Utility Companies Southern Water – Not assessed, as outside supply area.

Biodiversity UKProtect, LocalSite protected species within site. EPS, Local and UKSite protected species within 1km of site. Heritage If development works are proposed which fall outside of previously quarried and filled areas then further archaeological assessment including field evaluation is necessary. Development should consider and avoid any impact on the setting of the Listed Buildings and Scheduled Monument at St Radigund’s Abbey. The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 141 Kent County Council—Waste Sites Options Commentary Report

Natural England The site is within the Kent Downs AONB and the St Radigund‟s Valley Local Wildlife Site. This site is on the western side of Dover where there are already urban incursions into the AONB. Waste recovery operations and a PV farm at this location would extend the urban influence further into the AONB. The Council will need to be satisfied that the site meets the “exceptional circumstances‟ required under PPS7 before taking forward. Kent Wildlife Trust This site incorporates the whole of St Radiguns Valley LWS designated for its neutral and calcareous grassland habitats. The proposed plans to cap the site and to install photo voltaic cells would destroy any biodiversity interest present on this site. For the above reasons the Trust would strongly object to the plans and would

Kent Downs AONB There are a number of constraints at this site and consideration would be required to potential landscape and visual impacts given the proximity of the AONB to the site and potential scale of the restoration proposals. Inadequate roads in AONB for importation of the clay capping.. Query of whether there is a problem at present that needs addressing on pollution grounds? Is methane leaking at present and in what quantities? Is there a leachate problem that requires capping to reduce water ingress? Does it merit capping? Photovol- taics are a matter for the LPA at a later date. Not an issue for the M&W core strategy. The site is identified in plan as being in the proximity of the AONB It is actually in the AONB. It has been mapped wrongly in the Waste document. Protect Kent Protect Kent - Rejection recommended, due to: the number of unknowns about this site; the proposal to install photo-voltaic cells across the site, and the visual impact on the AONB; potential disruption to the SNCI. Note: we suggest these two proposals be separated: the capping of the landfill is acceptable, but the installa-

Kent County Council Waste KCC (Waste) would actively support proposals which brought about an sustainable after use for this site which Management took into account the need to re-engineer the existing (part) gas control and leachate control systems. East Kent Friends of the Earth Incineration is extremely carbon intensive with typical incinerators emitting more greenhouse gases than a gas Group fired power station. They also create a demand for waste that is at odds with efforts to prevent waste. The technology is yet to be proven. Little effort has been made to consult local people and councils. As Thanet Water currently recycles 90% of waste nearby, how can incineration be justified just for the extra 10%. The extra pressure on local roads by more lorry movements cannot be justified. General Public Responses Site is located at the top of a hill on a rural single track road. All of the area including the site is SNCI, ancient woodland and ANOB

The White Cliffs Countryside Land Management Project regards the whole valley as nationally valuable chalk grassland with rare species of orchid and butterfly.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 142 Kent County Council—Waste Sites Options Commentary Report 14 Glossary

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 as constructional fill or railway ballast. Aggregates / Soils Recycling Rubble, hardcore and soil from construction and demolition projects can often be re-used on-site. 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. Agricultural Waste The regulations for this waste stream have recently altered meaning farmers can no longer managed all of their own waste on the farm. The new agricultural waste regulations affect whether or not waste can be burnt, buried, stored, used on the farm or sent elsewhere. Mostly covers animal slurry/by products and organic waste, but also scrap metals, plastics, batteries, oils, tyres etc. Amenity A land use which is not productive agriculture, forestry or industrial development; can include formal and informal recreation and nature conservation. Anaerobic Digestion (AD) Anaerobic digestion is a natural process. It is the breakdown of organic material in the absence of air. It is a mature technology in other European countries where it is used as a waste management method. It is carried out in an enclosed vessel and produces methane which powers an engine used to produce electricity. The useful outcomes of anaerobic digestion are electricity, heat and the solid material left over called the digestate. Both the heat and the electricity can be sold if there is a market and the digestate can either be sold or used for agricultural purposes (landspread). Its use is currently small-scale and it can only be used for part of the waste stream e.g. sewage sludge, agricultural waste and some organic municipal and industrial waste. Annual Monitoring Report Records progress in implementing the Local Development Scheme and the performance of policies against targets in Develop- (AMR) ment Plan Documents. Indicates what action an authority needs to take if it is not on track or policies needs to be revised/ replaced. Area of Search (AoS) 'Areas of Search' are broad areas where knowledge of mineral resources may be less certain than in other types of site allocations, but within these areas planning permissions could be granted to meet any shortfall in mineral supply, if suitable applications are made. B Biodegradable waste Any waste that is capable of undergoing natural decomposition, such as food and garden waste, paper and cardboard. Biodiversity The variety of all life on earth (mammals, birds, fish, invertebrates, plants etc). Brownfield Site Site previously used for or affected by development. It may be abandoned or in a derelict condition. C Combined Heat and Power Technology produces power (electricity) whilst capturing the usable heat produced in the process. It is a single, integrated and (CHP) more efficient method of production.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 143 Kent County Council—Waste Sites Options Commentary Report 14 Glossary

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”. As well as paper, card, plastic and glass, for example, it is likely to include timber, metal, paints, textiles, chemicals, oils and food waste. Composting This is 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. It is mostly made up of stone, concrete, rubble and soils but may include (Also see Demolition Waste) some timber, metal and glass.

D Degradable (or Putrescible) Waste which will quickly or slowly biodegrade or decompose, releasing environmental pollutants. Types of material include Waste wood and wood products; paper; plasterboard; ash; concrete; plastic; leather; rubber; textiles; cardboard; vegetable matter; food processing wastes; sewage sludge; metals and chemical combinations thereof; coke; coal; mica; diatomaceous earth; slag; (Also called Non-Hazardous boiler scale; soap, cellulose, floor sweepings; sacks; electrical fittings and appliances; machinery; cosmetic products; tarred ma- Waste) terials; carbon; ebonite; pottery; china; enamels; abrasives; trees; bushes; grass; flowers and other vegetation. Demolition Waste

(Also see Construction Masonry and rubble wastes arising from the demolition or reconstruction of buildings or other civil engineering structures. Waste) A portfolio of documents. Collective term for the Development Plan Documents, the Local Development Scheme, the Statement Development Framework of Community Involvement, Annual Monitoring Report, and any supplementary planning documents. These are the spatial planning documents (plans) required by the Local Development Framework. These set out spatial plan- Development Plan Document ning policies and proposals for an area or topic. They replace the former Local Plan and include the core strategy, detailed de- (DPD) velopment control policies, site specific allocations of land, area action plans (where needed) and a proposals map. E The generation of heat and power from burning waste, the production of fuels from other forms of treatment, and the combustion Energy from Waste (EfW) of landfill gas and gas from anaerobic digestion to create electricity. All Development Plan Documents will be subject to an independent examination before a planning inspector. The inspector's Examination in Public (EiP) report is binding on the local authority.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 144 Kent County Council—Waste Sites Options Commentary Report 14 Glossary

H 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; acids; alkaline solutions; asbestos; fluorescent tubes; batteries; oil, fly ash; industrial solvents; oily sludges; pesticides; pharmaceutical compounds; photographic chemicals; waste oils; Hazardous Waste 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. It should be used only to describe wastes that contain sufficient of these materials to render the waste as a whole hazardous within the definition given above. Waste from a domestic property, caravan, residential home or from premises forming part of a university or school or other educational Household Waste establishment; premises forming part of a hospital or nursing home. I Waste from any of the following premises: factory; provision of transport services (land, water and air); purpose of connection of the Industrial Waste supply of gas, water, electricity, provision of sewerage services, provision of postal or telecommunication services. Waste which will not biodegrade or decompose (or will only do so at a very slow rate). Types of materials include uncontaminated top- Inert Waste soil; subsoil; clay; sand; brickwork; stone; silica; and glass. L 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 Landfill such a way that pollution or harm to the environment is prevented. Former mineral workings have historically been used for this purpose. A by-product from the digestion by anaerobic bacteria (rotting) of putrescible matter present in waste deposited on landfilled sites. The Landfill Gas gas is predominantly methane together with carbon dioxide and trace concentrations of a range of other vapours and gases.

LDF Local Development Framework: A series of documents, which when adopted will replace adopted local plans.

M A building where waste can be taken in bulk for separation, recycling or recovery of waste materials. This is usually municipal waste, Materials Recovery Facility but some sites take commercial and industrial waste. Some may also take construction and demolition waste to be crushed and (MRF) screened. Metropolitan Green Belt. A statutory green belt around London. It includes designated parts of Greater London and the surrounding MGB counties of Bedfordshire, Berkshire, Buckinghamshire, Essex, Hertfordshire, Kent and Surrey I the South East and East of England Regions. MOD Ministry of Defence Municipal solid waste is that waste which is collected and disposed of by or on behalf of a local authority. It will generally consist of Municipal Solid Waste household waste, some commercial waste and waste taken to civic amenity waste collection/disposal sites by the general public. In (MSW) addition, it may include road and pavement sweepings, gully emptying wastes, and some construction and demolition waste arising from local authority activities. It is typically made up of card, paper, plastic, glass, kitchen and garden waste.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 145 Kent County Council—Waste Sites Options Commentary Report 14 Glossary

P Planning Policy Statements are prepared by the government after public consultation to explain statutory provisions PPS and provide guidance to local authorities and others on planning policy and the operation of the planning system. PROW Public Right of Way Both systems involve heating the waste in varying amounts of oxygen to produce a gas. Neither system is yet as Pyrolisis / Gasification energy efficient as incineration; there is more residual waste left over which has to be burned or landfilled. The technology is not yet well established for waste management and is more widely used in industry. R Sites of international importance to birds which inhabit wetlands. Ramsar is the name of the place where the Wet- Ramsar Sites lands Convention was signed. Recovery The collection, reclamation and separation of materials from the waste stream. A facility that recovers value, such as resources and energy, from waste prior to disposal, includes recycling, ther- Recovery Facilities mal treatment, biological treatment and composting facilities. Recycled Aggregates Aggregates produced from recycled construction waste such as crushed concrete, planings from road surfacing etc. The collection and separation of materials from waste and subsequent processing to produce new marketable prod- Recycling ucts. A concentration or occurrence of material of intrinsic economic interest in or on the Earth's crust in such a form, Resource quality and quantity that they are reasonable prospects for eventual economic extraction. Resource Recovery The extraction of useful materials or energy from solid waste. Operations designed to return an area to an acceptable environmental state, whether for the resumption of the for- Restoration mer land use or for a new use following mineral working. Involves the reinstatement of land by contouring, the spreading of soils or soil making materials etc. S Safeguarding Protecting sites that have potential for relevant development (waste and minerals) from other development. Sharp Sand and Gravel Naturally occurring mineral deposit in Kent. Once extracted is is mainly used in the production of concrete products. Nationally important monuments and archaeological areas that are protected under the Ancient Monuments and Scheduled Ancient Monument (SAM) Archaeological Areas Act . These sites are notified under Section 28 of the Wildlife and Countryside Act 1981 by English Nature whose responsibility is to protect these areas. These are important areas for nature conservation i.e. valuable flora, fauna or Sites of Special Scientific Interest (SSSIs) geological strata. English Nature needs to be notified of planning proposals in or adjacent to the designated areas. National Nature Reserves (NNRs), terrestrial RAMSAR sites, Special Protection Areas (SPAs) and Special Areas of Conservation (SACs) are also SSSIs under national legislation. Sites which are generally well defined and where there is an implied presumption in favour of their being developed Site (Specific) Allocations during the plan period The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 146 Kent County Council—Waste Sites Options Commentary Report 14 Glossary An evaluation process for assessing the environmental impacts of plans and programmes. This is a statutory Strategic Environmental Assessment requirement of the M&WDF system. A stage of the Development Plan Document preparation process where the document is 'submitted' to the Secre- Submission tary of State for independent examination by a planning inspector. The document is published for public consultation prior to submission. An evaluation process for assessing the environmental, social, economic and other sustainability effects of plans Sustainability Appraisal (SA) and programmes. This is a statutory requirement. A widely quoted definition of sustainable development is “development that meets the needs of the present with- Sustainability out compromising the ability of future generations to meet their own needs”. The definition also encompasses the efficient use of natural resources. T 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 Transfer Stations recoverable wastes, such as construction waste and scrap metal prior to onward transportation for disposal or processing. W 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 Waste is therefore defined as any substance or object which the holder or the possessor either discards or intends or is required to discard. This definition is inserted into s.336(1) of the TCPA 1990, as part of the conse- quential 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 com- mencement - see reg.1). A Local Authority with responsibility for waste planning, including the determination of waste related planning applications. In areas with two tiers of local government (counties and districts), the County Councils are the Waste Planning Authority (WPA) WPAs. National Parks are also WPAs. Unitary Authorities, such as Medway Council, deal with waste planning and all other planning issues within their areas. Suggests that the most effective environmental solution may often be to reduce the amount of waste generated – reduction; where further reduction is not practicable, products and materials can sometimes be used again, ei- Waste Hierarchy ther for the same or a different purpose – preparing for re-use; failing that, value should be recovered from waste, through recycling, composting or energy recovery from waste; only if none of the above offer an appropriate solution should waste be disposed. Permit granted by the Environment Agency authorising treatment, keeping or disposal of any specified descrip- Waste Management Permit tion of controlled waste in or on specified land by means of specified plant. This refers to urban wastewater, including domestic, industrial and surface run off. This raw waste water is proc- Wastewater essed through treatment plants to produce treated effluent and sewage sludge.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 147 Kent County Council—Waste Sites Options Commentary Report 14 Glossary for Biodiversity Comments

Species Data EPS (European protected species) animals listed in Annex IV of the EU Habitats Directive, transposed into UK law in the Conservation Regulations 2010.

UKProtect Animals and Plants protected under the Badger Act, Wildlife and Countryside Act Schedule 5/9.1 (killing and injuring), Wildlife and Countryside Act sch8.

Local Species designated in the 2007 Biodiversity Action Plan list; birds designated as Red or Amber in the Birds of Conservation Concern 3 listing; species listed in the Kent Red Data Book.

Site Data

EuroSite Sites designated as Special Protection Area, Special Area of Conservation and/or Ramsar Site.

UKSite Sites designated as Site of Special Scientific Interest and/ or National Nature Reserve.

LocalSite Sites designated as Local Nature Reserve, Local Wildlife Site, Ancient Woodland and/or Biodiver- sity Action Plan Habitat.

The full responses for the Mineral Sites Development Plan Document Consultation can be found at: http://consult.kent.gov.uk/portal/waste-dpd/waste-options?tab=list 148