Badgers Mount Residents Association

Submission to the County Council Minerals & Wastes Sites Development Framework Options Consultation

Waste Sites (8) Chelsfield Ammunition Depot (8)

1 Objection by Badgers Mount Residents Association To the Kent County Count Minerals and Waste Sites Development Plan Document

Options Consultation

Waste Sites Section 8 – Treatment / Materials Recycling Facility

Site 8 - Chelsfield Ammunition Depot, Badgers Mount

Badgers Mount Residents Association strongly objects to the inclusion of Site 8, Chelsfield Ammunition Depot, Shacklands Road, Badgers Mount, in the Consultation Document for a Treatment / Materials Recycling Facility in the Waste Sites section of the Consultation Document.

DESIGNATIONS

• Green Belt (PPG2)

• Area of Outstanding Natural Beauty (PPG7)

• Groundwater Source Protection Zone (SPZ iii)

• Local Wildlife Site (SNCI)

• RSPB Reserve

• Ancient Woodland (TPO)

• Air Quality Management Area

2 CONSTRAINTS

• Proximity to Residential Properties / Village Hall

• Proximity to Outdoor Recreational Areas

• Public Footpaths

• Impact of Increased Traffic and Associated Safety Aspects

• Alternative Sites Available

• E U Directives and European Convention on Human Rights

• Impact of Noise, Dust, Vibration & Light Pollution on Amenity of Residents,

Tourists and the Community in General

DESIGNATION CONSTRAINTS

There are a number of designation constraints covering the site or the area adjacent to it including:-

Green Belt

The whole site is within the Metropolitan Green Belt which restricts inappropriate development.

Planning Policy PPG2 on Green Belts states that:

"The re-use of buildings inside a Green Belt is not inappropriate development providing., (a) it does not have a materially greater impact than the present use (b) strict control is exercised over the extension of rei;sed buildings, and over any associated uses of land surrounding the building ng which might conflict with the openness of the Green Belt and the purposes of including land in it (e g. because they h7MYe extensive external storage, or extensive hardstanding, car parking, boundary walling or fencing);"

3 The proposed use of the site will have a materially greater impact on the whole area compared to the use made by the MOD which was so low-key that the majority of residents were unaware of any activity on the site. If this site became a waste recycling facility, it would contravene the policy requirement of maintaining and preserving the Green Belt. Severe restrictions are put on householders wanting to carry out extensions etc. yet this application is completely against such controls.

Area of Outstanding Natural Beauty

The whole site is within the North Downs Area of Outstanding Natural Beauty (AONB). Planning Policy PPG7 concerning Sustainable Development in Rural Areas states that:

"Nationally designated areas comprising National Parks, the Broads, the New Forest Heritage Area and Areas of Outstanding Natural Beauty (AONB), have been confirmed by the Government as having the highest status of protection in relation to landscape and scenic beauty. The conservation of the natural beauty of the landscape and countryside should therefore be given great weight in planning policies and development control decisions in these areas The conservation of wildlife and the cultural heritage are important considerations in all these areas "

A large industrial site of the type proposed would be extremely harmful to the AONB. It will create noise, dust and gaseous pollution from both the machinery and vehicles working on the site and light pollution from the floodlighting which will be required for the site to operate 24/7 as proposed. The applicant has already installed a large bright yellow steel gate which is completely out of place in a rural area. The AONB Policy states that an over-riding need must be proved to over-ride the AONB Policies. There is nothing in the applicant's proposal to demonstrate such a need. Furthermore, there is already a waste recycling facility less than one kilometre away, at Oak Tree Farm, London Road, Badgers Mount. This confirms there is no justifiable 'need' for another recycling facility in this area, least of all one located in a rural village location within close proximity to high value properties.

4 Groundwater Source Protection Zone

The whole of the area of the North Downs, including Site 8, are in a designated Groundwater Source Protection Zone for water extraction in the Darenth Valley.

Local Wildlife Site

The adjacent woodland is a designated Local Wildlife Site. Deer, badgers, bats and dormice, which are all protected species, together with much other wildlife including numerous birds, foxes, rabbits and squirrels inhabit the adjacent woodland. Their habitat would be disturbed by the dust, noise and light pollution from an industrial operation.

RSPB Reserve

There is a designated RSPB reserve within the site, adjacent to the entrance / access road. This reserve extends into Andrew's Wood which adjoins the site. The birds' habitat would be harmed by the dust, noise and light pollution from the type of industrial operation proposed.

Ancient Woodland Three sides of the working area of the site are bounded by designated Ancient Woodland, which cover about half of the original MOD outer security area and are part of Jenkins Neck Wood. The woodland comprises a mixture of mature oak, ash, birch and similar large trees together with sweet chestnut and other smaller trees which are occasionally coppiced. All woodland around the site is subject to a Woodland Tree Preservation Order (No. 7/2011). The biodiversity of the woodland would potentially be affected by dust and pollution from the proposed works.

Air Oualitv Management Area

The M25 is approximately 330 metres from the site and has a designated Air Quality

5 Management Area extending on both sides along its length. Increased exhaust gas pollution from extra vehicles and the industrial machinery operating on the site could increase pollution in the M25 corridor.

LAND USE CONSTRAINTS

Adiacent Properties The nearest building to Site 8 is Badgers Mount Memorial Hall, which is 95 metres from the inner site boundary and abuts the outer boundary. The Hall is the only community meeting venue in Badgers Mount and is used for many activities which may be affected by the proposed use of the site, including a children's arts and craft group, children's dancing classes, Pilates and Yoga lessons which require concentration, singing rehearsals by an award winning ladies a-capella choir, dog training, coffee mornings with fortnightly visits by the mobile library, women's institute, many meetings, parties and church services. These would all be affected by noise, vibration and dust pollution from the proposed works. Some of the regular hirers have already indicated that they would move to another venue, which would affect the viability of the Hall, if there was such pollution.

The nearest houses are less than 100 metres from the site boundary. A total of over 270 houses, comprising all of Badgers Mount and some in Halstead, are within 600 metres of the inner site boundary. Houses near the site along Highland Road, which is an unadopted road without street lighting, will be affected by noise and dust pollution and also light pollution as it will be necessary for the applicant to install extensive floodlighting to operate the site 24/7 as proposed. As all vehicles working in a site of the type proposed have to be fitted with audible reversing devices for Health and Safety, the noise from the beepers will be a constant annoyance over a wide area, day and night. All houses near the site, and especially those along the main roads, will be severely affected by increased traffic movements, especially when HGVs are accessing the site at night, causing noise and vibration.

Reports concerning F M Conway Ltd's site at Dartford clearly demonstrate that it is virtually impossible to control dust and noise pollution which are extremely harmful to

6 nearby residents in properties a similar distance from that site as the Badgers Mount and Halstead houses. A considerable proportion (nearly 10%) of the population of the UK suffers from asthma which is made worse by high levels of dust in the atmosphere.

The operation of this site would cause a very significant loss of amenity to residents over a wide area and lead to a significant drop in property prices.

Nearby Businesses

The nearby businesses of Polhill Garden Centre, the Toby Carvery and adjacent small businesses and farms are less than 400 metres from the site and will be affected by noise and dust pollution from the proposed works which could affect their business and ultimately employment. Polhill Garden Centre and the Toby Carvery have outdoor eating areas which could be affected by noise, dust and fumes. Customers would not want to eat in a dusty and noisy environment, so the businesses would lose trade. Whitegates Farm is a short distance down Shacklands Road and they fear that pollution may arise from the site being used as a waste recycling facility and the harm that it may do to their livestock. They keep sheep, pigs, geese, ducks and chickens on the farm. They fear all will be affected by dust pollution and the egg production could also be affected by noise pollution.

Outdoor Recreational Area

Andrews Wood is a public outdoor recreation area and visitor attraction. It is part of the extensive Shoreham Woods which cover 189 hectares between Badgers Mount and Shoreham and adjoins the south and eastern outer boundaries of the applicant's site. The woods are used extensively by - people from a wide area for walking, rambling, picnicking, dog walking, or just to see the flora and fauna, particularly the bluebells which carpet the woods in spring. Many people arrive by public transport and walk along Shacklands Road to access Andrews Wood and walk to Shoreham by the network of paths through the woods. Similarly Badgers Mount and Halstead residents walk to the woods. As Shacklands Road does not have a footpath, the risk to pedestrians is significant. Families often cycle down Shacklands Road too, which would become

7 impossible if the site was to become a waste facility given that minerals would need to be transported along Shacklands Road on a 24/7 basis. Furthermore, we believe structurally the road is not suitable for regular heavy duty use by HGV's.

Public FootRaths

Public footpaths SR8 and SR669 pass along the north and west outer boundaries of the site, and SR6 commences from the south-eastern corner of the site to take walkers into Andrews Wood and on into the whole of Shoreham Woods recreational area. These paths are very well used by ramblers, dog walkers etc. and their pleasure using them would be spoilt by the proposed use of Site 8.

Traffic

The applicant has stated that there would be 28 vehicle movements each day. We would question the accuracy of this figure as an indication of the actual traffic volume likely to be using the site on a daily basis. This is an average figure throughout the year for HGVs only and takes no account of seasonal and work load fluctuations, actual vehicle loadings, operatives cars and other vehicles which will also be accessing the site. As less resurfacing is carried out in winter we would suggest that a figure of 100, or even 150, vehicle movements per day is more realistic at peak times. As resurfacing on major roads is now mainly carried out at night, this would mean that large numbers of HGVs will be accessing the site at night.

The roundabout adjacent to the site experiences congestion during the rush hours, and this is considerably worse when there,is an obstruction on the M25 and drivers exit at junction 4 to use the A224 and A25 to get to junction 6 at Godstone, when all the roads in the area can become gridlocked.

The Hewitts roundabout at junction 4 of the M25, where the link road joins the A21 and A224, already suffers from serious congestion during the rush hours. The addition of the applicant's vehicles would add to this.

8 The applicant's HGVs accessing the site at all hours of the day and night would cause significant noise and vibration pollution to all properties in the area. Empty lorries are notorious for rattling and banging which would be very disturbing, particularly at night.

As previously stated, Shacklands Road is well used by pedestrians both to access Andrews Wood and also by local school children who walk unaccompanied to catch the school bus. As Shacklands Road is narrow and does not have any form of pavement or footpath, or lighting, they will be put at greater risk, particularly during the winter months when natural lighting conditions are poor. Shacklands Road is also frequently used by cyclists who would similarly be put at increased risk.

As the entrance to the site is only about 40 metres along Shacklands Road from the roundabout, HGVs accessing the site, particularly when leaving, will pose a serious hazard to other traffic in Shacklands Road.

Many pedestrians cross the A224, either from the houses east of the Bypass to go to Station or the bus stops in Old London Road, or from the west of the Orpington Bypass to walk through the various woods, often with their dogs. While there are islands to "protect" pedestrians while crossing, it is very uncomfortable to be standing on them with vehicles passing at speed both sides. Dogs can be seriously affected by such situations. The addition of yet more HGVs would make this even worse.

Planning Permissions The site was originally an MOD ammunition storage depot serving the south east of . Their operations were always of a low key nature such that most people rarely noticed any activity on the site or vehicle movements.

The applicant has obtained a Lawful Development Certificate for Existing Use from Council for Class B8 storage and distribution, with storage in the 11 bunkers and with a maximum of 19 vehicle movements per day based on evidence provided by Defence Estates. The applicant's proposal for storage of road planings would be a major material change from this certificate.

9 The site is not allocated within the Sevenoaks District Council Local Development Framework for future development.

Alternative Sites There are a number of other similar sites within the Consultation Document which would provide similar services but do not appear to have the Constraints detailed above applying to them, including the applicant's own site at Dartford. We also understand that the applicant has a number of similar sites within the area which could be utilised.

As the applicant's own brochures claim that a large amount of their work is for London Boroughs, it appears that they intend transporting the material for excessive distances when nearer sites could be used. This will lead to extra exhaust gas pollution whereas the overall policy is to reduce them.

There is an existing waste site operating approximately one kilometre from this site so there is no justification or proven need for this proposal.

EU Directives

There are EU Directives requiring authorities to draw up action plans to reduce and control environmental noise and pollution. If this application for Site 8 is allowed, this would be going in the opposite direction by increasing noise and pollution.

European Convention on Human Rights

The Human Rights Act requires the Waste Planning Authority to take into account the rights of the public under this act and prevents the Authority from acting in a manner which is incompatible with those rights. Article 1 of Protocol 1 provides that an individual's peaceful enjoyment of their property shall not be interfered with unless necessary in the public interest. No evidence has been put forward to show that there is such an overriding public interest to justify approval of this site.

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World Health Organisation The estimated noise levels could exceed World Health Organisation (WHO) guidelines which state that noise levels above 55dB are a serious nuisance and that long-term levels above 65-70 dBA lead to increased blood pressure and levels of ischaemic heart disease. This is not at all acceptable. The owner has a site at Dartford, and research from the residents there show that they find the noise and other pollution unacceptable.

Fact At the Public Inquiry in 1978 into the proposed to Sevenoaks section of the M25, the Inspector put great weight on the effect of traffic noise on people living near to the road. As a result, the road east of Badgers Mount was moved further away from houses, the level was lowered, and a 4.1 metre earth bund was built between the road and houses. The noise from traffic on the M25 when audible is generally a constant background roar. The proposed operating area of Site 8 is far closer to a greater number of houses than the M25, and the noise generated will be louder, intermittent and variable; • Tonal reversing alarms • Clanking, banging • Engine noises from bucket loaders and excavators • Tonal noise from road sweeper • Tonal noise from aggregate discharge function. These noises would be infinitely more noticeable and harmful than motorway noise. 16 houses are within 400 metres of the M25, whereas there are over 200 houses, 75% of Badgers Mount, within 400 metres of F M Conway Ltd's proposed working area, so the harmful effects of noise will be felt by a far greater number of people.

OTHER SERVICES

Railway The Charing Cross to Hastings railway line passes below the site. Concerns have been raised that intensive operations could affect the tunnel and air shaft.

11 Water Supply

Planning applications for sites within the area have raised concerns from the Environment Agency about the possibility of pollution affecting groundwater aquifer sources as this area is designated as a groundwater protection zone.

Lighting

F M Conway Ltd have stated that they will be using the site 24/7. In order to use the site during the hours of darkness it will be necessary to have extensive lighting on high columns, which would cause significant light pollution to both nearby properties and the wildlife in the adjacent woodland, affecting the biodiversity of the area. As the adjoining woodland is mostly deciduous, the light will be extremely visible in winter, which would be detrimental to the AONB.

CONCLUSION The site has a large number of residential properties in close proximity which would be seriously affected by this proposal. The proposed use of the site would be in contravention of European Directives and the European Convention of Human Rights.

Local wildlife and biodiversity of the area will be seriously affected.

The site is covered by many constraints designed to protect the rural countryside, including AONB, Green Belt and Ancient Woodland.

There is an existing operating site within one kilometre.

F M Conway Ltd have not demonstrated the need for this site to be included in the KCC Minerals Sites proposal document. Furthermore, research suggests that they have a 'chequered planning history in regards to their Dartford site. We do not think it would be appropriate for KCC to reward them by allowing this proposal to go ahead.

The proposed use of the site will cause serious harm to the community, the environment, nearby residents and wildlife.

12 In view of the above, we believe that this proposal is extremely detrimental to the visual amenity, the landscape, the entire village, surrounding villages, and contrary to many designations and constraints. We therefore request that this site is rejected and not allowed to progress to the next stage of the KCC Minerals and Waste Plan. The Badgers Mount Residents Association deem this site unsustainable.

13 APPENDIX

Photograph 1 Aerial view of Site 8 looking east showing proximity to residential properties in Badgers Mount

Photograph 2 Site 8 entrance (yellow gate) showing proximity to A224 roundabout

Photograph 3 View of Shacklands road showing cyclists negotiating traffic

Photograph 4 View of Shacklands Road showing width of road and no footways

Photograph 5 View of Shacklands Road showing width restriction sign with access to Site 8 on left hand side of the road and narrowing of road immediately after the entrance

Map 1 Site 8 (shown in green with the inner working area shown in red).

The site is comparable in area to the majority of the residential area of Badgers Mount and in much closer proximity to houses than the

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