Kent County Council– Supplementary Site Options …...Kent County Council– Supplementary Site...

Kent County Council– Supplementary Site Options Commentary Report (October 2011)

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Kent Minerals And Waste Development Framework

Minerals and Waste Sites Development Plan Document Supplementary Options Consultation (October 2011) Commentary Report (February 2012)


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Produced by :

Planning and Environment

Environment and Enterprise

Kent County Council

Invicta House Tel: 01622 221610

County Hall Email: [email protected]

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

Kent ME14 1XX


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Contents Page

1 Abbreviations 4

2 Introduction 5

3 Site Proposals 7

4 Responses for Supplementary Options Document 8

5 Secondary and Recycled Aggregates/ Material Recy-cling Facilities

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6 Soft Sand Sites with Inert Landfill 12

7 Brickearth Sites 16

8 Energy from Waste Sites 22

Sites for Consideration: Significant Amendments to Existing Sites-

9 Inert Landfill Site Amendments 28

11 Soft Sand Sites and Inert Landfill Amendments 32

12 Chalk Sites and Hazardous Landfill Amendments 34

13 Sharp Sand and Gravel Site Amendments 36

14 Glossary 38

10 Chalk Sites with Inert Landfill Amendments 30


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AONB Area of Outstanding Natural Beauty

AQMA Air Quality Management Area

BAP Biodiversity Action Plan

BOA Biodiversity Opportunity Area

CPRE Campaign to Protect Rural England

DPD Development Plan Documents

EIA Environmental Impact Assessment

HER Historic Environment Record

HGV Heavy Goods Vehicle

HRA Habitats Regulation Assessment

KCC Kent County Council

KHS Kent Highway Services

KWT Kent Wildlife Trust

LDF Local Development Framework

LWS Local Wildlife Site

MGB Metropolitan Green Belt

NNR National Nature Reserve

PINS Planning Inspectorate

PPS Planning Policy Statement

PROW Public Right of Way

SA Sustainability Appraisal

SAC Special Area of Conservation

SLA Special Landscaped Area

SPA Special Protection Area

SSSI Site of Special Scientific Interest

TMBC Tonbridge and Malling Borough Council


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2.0 Introduction

2.1 The Supplementary Sites Development Plan Document (Options Stage) Commentary Report is the follow up document to the consultation for the Supplementary Sites Development Plan Document. The consultation period ran from October 24th 2011 to the 19th of December 2011. 2.2 This document collates and summarises the responses for each of the sites to show the main reasons for support , objec-tion or commenting from organisations and members of the pub-lic. The aim of this report is to create a clear and concise docu-ment showing the main issues put forward. If people wish to read full responses they may access them through the online consul-tation portal at; http://consult.kent.gov.uk/portal. 2.3 Those responses put forward will be recorded as part of the site assessment. Data collection and site visit reports will then be formulated, taking into consideration the emerging Minerals and Waste Core Strategy policies and changes to national planning policy. The Preferred Options are due to be published and con-sulted upon in May 2012.

2.4 The Supplementary Sites ‘options’ consultation received the following responses;

2.5 In addition to the comments the Council also received site reports from resident associations and parish councils. Reports were given to the Minerals and Waste Development

Framework (MWDF) team outside of the consultation but the comments from these internal consultees are considered to be important in informing the site selection process and so have been summarised for this report.

Total Number of Responses 362

Objection 278

Comment 74

Support 10

Total Number of Responses 362

Objection 278

Comment 74

Support 10

http://consult.kent.gov.uk/portal�


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2.7 Sites with the most responses/objections;

2.8 The other sites had responses from within KCC or outside or-ganisations but had fewer or no comments from members of the public.

2.9 There were some recurring concerns which applied to many of the sites. These comments included; •The suitability of roads for HGVs •Water Contamination •Sites that are in or near to designated land •Public safety •Impact on biodiversity 2.10 Space is restricted in this report. All comments are valued and will 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 represent the number of re-sponses for each site. The internal responses we received are not included in this data.

Site Refer-ence Number

Name

100 Double Quick Farm, Lenham Heath

101 Barbary Farm, near Faversham 102 Barrow Green Farm, Teynham

104 Land between Orpington Bypass and M25

16 Beacon Hill Quarry Amendment

Site Refer-ence Number

Name


101 Barbary Farm, near Faversham 102 Barrow Green Farm, Teynham

104 Land between Orpington Bypass and M25

16 Beacon Hill Quarry Amendment


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Site Number Name Page Number

99 Broomway Limited, Dartford 10

104 Land between Orpington Bypass and M25, Sevenoaks

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107 Land at Lower Road, Swanscombe

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3 Site Proposals 3.1 The following is a list of all sites submitted for considera-tion in the Supplementary Sites Option Consultation. The list contains their site reference number and the page number where they can be found in this document.

3.5 Energy from Waste Sites

AMENDMENTS- 3.6 Inert Landfill Sites

9 Ightham Sand Pit, Ightham 28

3.2 Secondary and Recycled Aggregates/ Material Recycling Facilities

3.3 Soft Sand Sites with Inert Landfill


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105 Borough Green Sandpit, Borough Green

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98 Jeffries Site, Teynham, Sitting-bourne

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101 Barbary Farm, Norton Ash, Near Faversham

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102 Barrow Green Farm, Teynham, Sittingbourne

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3.4 Brickearth Sites

3.7 Chalk Sites with Inert Landfill

3.10 Sharp Sand and Gravel Sites

3.8 Soft Sand Sites and Inert Landfill

3.9 Chalk Sites and Hazardous Landfill

71 Stonecastle Farm (Western Exten-sion)

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63 Pinden Quarry (Western Extension) 34

50 Ightham Sand Pit (Western Exten-sion), Borough Green

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16 Beacon Hill, Quarry, Charing 30

103 Pfizer Ltd Sandwich Side, Sand-wich

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4.0 Supplementary Sites Development Plan Document

Responses regarding the complete Supplementary Sites Development Plan Document

Responses

RSPB A number of principles are appropriate to the restoration all of the sites detailed in the document, and it is useful to set these out here: 1. The number of after-uses should be limited to ensure objectives are not unduly compromised. We recommend that the Council acknowledge BAP priority habitat as a valid "stand-alone" target for restoration because in so doing this acknowledges the importance of mineral sites in delivering the Government's BAP targets. 2. Habitat creation should contribute to BAP targets, and be established early on in the planning process. 3. The number of habitats that sites are restored to should be limited. Large blocks of a smaller range of habitats on any one site tend to perform better ecologically and are often simpler to man-age in the long-term, than an over-complex mosaic of many different habitats. 4. Habitat creation should complement the adjacent sites of importance for biodiversity, so as to buffer, link and extend them thereby increasing their robustness and resistance to change. 5. Biodiversity Opportunity Areas (BOAs) should be used to guide decisions regarding restoration to priority habitats. BOAs are partnership-led, conservation sector-backed strategic areas within Kent that offer the best opportunity to restore or recreate BAP priority habitat.

Swale Borough Council Several of the sites are a cause for concern due to their position within what is known as the North Kent Fruit Belt, an important part of the Borough of Swale. As the population increases, demand for food will increase and we need to be sure that the removal of grade one agricultural land from pro-duction is justifiable in terms of the need and demand for brickearth. All of the sites would be increasing heavy traffic on the A2 and this cumulative impact needs to be carefully considered against the demand for brickearth. The County Council as the Highway Author-ity needs to be content that this would not pose an adverse effect on traffic flows or road safety.


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Responses

Protect Kent 1. We have serious concerns about the large number of sites proposed for mineral extraction, particularly soft sand sites, near the villages of Harrietsham, Lenham and Charing, and there-abouts. A total of 9 minerals sites were proposed originally, with a further one being added through the supplementary proposals. We strongly recommend that all of these sites be consid-ered together, in conjunction with the five waste sites proposed, with special attention paid to cu-mulative impacts. This is most significant when examining traffic and transport impacts.

2. In a similar manner, we have concerns about the concentration of waste sites proposed for the Richborough area in the east of Kent. To the north of Sandwich there are four separate waste sites being proposed, plus one supplementary, (in addition to two minerals sites). Again, the con-centration of similar activities could pose a great strain on the area, in particular from traffic and transportation. Once again, cumulative effects must be considered.

3. Beyond these two specific areas, we also believe that a phased approach should be taken to the development, and therefore granting of planning permission, to sites of similar purpose, par-ticularly minerals sites. Having a number of sites across Kent supplying the same material will un-necessarily add to the already intolerable congestion on our rural roads.

Environment Agency We would request a main policy on groundwater protection and Water Framework Directive as previously identified and constraints maps to show SPZs and existing water courses. The consul-tations maps should also highlight the presence of watercourses.

Sport England Sport England encourages the early consideration of restoration options for recreational, formal and informal sport use. Mineral working and landfill can provide opportunities for restoration to sport and recreation after-uses. Such after-uses can help support the rural economy and provide tangible benefit to Kent's communities. Depending on the nature of the opportunity such sports might include (but not limited to) Equestrian; Canoeing; Angling; Cycling; Orienteering; Motorsports; Triathlon; Sailing; Windsurfing and Water-skiing.


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5.0 Site 99 Broomway Limited, Swanscombe

The site consists of an existing Construction, Demolition and Excavation (CDE) waste proc-essing facility which currently does not have planning permission, and a proposed extension which would enable a fully enclosed waste proc-essing building to be developed.

Responses

Dartford Borough Council Dartford Core Strategy Policy CS7 ‘Employment Land and Jobs’ protects existing employment areas, includ-ing Manor Way Business Park, for B1, B2, B8 and A2 uses. The proposed use does not comply with this pol-icy and is likely to generate fewer jobs than ‘B’ uses. The site lies within the Thames Waterfront Priority Area which identifies Swanscombe Peninsula as a key development site for mixed-use development including housing. The intensification of the waste processing activities at Manor Way would be incompatible with this proposed development. The Core Strategy proposals for Swanscombe Peninsula make provision for Environ-mental Technology uses in an alternative location which is more compatible with the proposed development of the rest of that site. Waste processing could more easily be accommodated in that location than on the Manor Way site. It would also enable the transport in and out of materials to be by water.

Biodiversity No designated areas within site boundary. SSSIs, NNR and LWS within 1km. Current state of the site and barriers between it and the natural areas mean they are unlikely to present a significant constraint. Depend-ing on site use, there is potential for indirect effects on natural habitats. There are designated species re-cords for the 1km square in which the site is situated.

Heritage The chalk quarry is likely to have fully removed the potential for finding such remains except around its edges. The site is overlooked by Grade II* Listed All Saints Church to the south. Development should con-sider and avoid any impact on the setting of the Listed building at All Saints Church.

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Responses

Highways (KCC) The access to this site is via Manor Way. If the proposal is granted permission, a contribution should be sought to traffic signal control at the Manor Way/ A226 London Road junction. This would be combined with contributions from an existing S.106 agreement for a development on Craylands Lane, and from the newly proposed Lower Road site (Ref 107). This junction improvement would allow HGVs to enter and leave the side road safely, and protect pedestrians crossing the A226.

Protect Kent Acceptable, subject to a more detailed assessment, and provided that: impact of site on neighbouring Air Quality Management Area can be shown not to cause significant harm or additional pollution that will affect the Area; conditions are put in place to minimise or negate impacts on neighbouring residents.

Kent Wildlife Trust As noted in Kent Wildlife Trust's response to Site 58 of the original consultation this site is on Swanscombe peninsular which is known to contain populations of invertebrates of national importance. These species colo-nise open mosaic habitats on previously developed land. We recommend that there should be a detailed as-sessment of the site's ecological value particularly with regard to invertebrates to ensure conformity with Plan-ning Policy Statement 9 Biodiversity and Geological Conservation. Individual impacts should be considered as well as in-combination impacts with Site 107 of this consultation. Records show that reptiles are also present within the area. If present on this site then mitigation measures will need to be formulated for these species if the site is allocated

Lee Evans Planning We support an allocation of this site for inert waste processing. In addition to construction, demolition and excavation wastes, the owners also intend to accept and process mixed loads of commercial and industrial wastes, for separation within the building and transfer on for recycling.

Environment Agency No objection from a flood risk perspective however a new waste permit would be required, but proposal wel-comed if all processing was to be brought under cover and controlled.


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6.0 Site 100 Double Quick Farm, Lenham Heath

The site is proposed for 1.2 million tonnes of sand extraction, followed by refilling of a similar amount of inert waste over a five to six year pe-riod. The proposed restoration includes replant-ing to create grazing land and returning the site to the existing levels and contours.

Responses

Charing Parish Council We strongly object to the inclusion of this site within the MWDF. The site is next to dwellings and only served by narrow lanes. The dwellings would not only suffer the noise and dust expected from extraction but - if followed by land-fill - would then suffer a second time. The highways to and from the A20 are narrow and unsuitable for heavy lorries and only one vehicle wide in places with few passing places.

RSPB This site is within close proximity to the Greensand Heaths and Commons BOA, and as such we would advo-cate restoration to woodland, heath land and acid grassland. Driving towards a landscape-scale conservation approach it would be beneficial if the restoration plans for this site reflected restoration plans on proposed ex-traction sites nearby, for example Boltons Field Lenham site (site 75) and Burleigh Farm & Tile Lodge (site 77), should this site be progressed. We note that restoration to grazing land is proposed. Should this be fol-lowed through, biodiversity gains could still be achieved.

Biodiversity LWS and Ancient Woodland within 1km of site. SSSI within 5km. These are unlikely to present significant constraint. Present on and near to the site are habitat indicators of potential for impacts on protected spe-cies as a result of development at the site. The presence of natural habitats nearby means that there is po-tential for indirect impacts on designated species.

Heritage Archaeological potential with a Neolithic Axe, prehistoric flints, Romano British Pottery, a coin and Anglo Saxon brooch having been found at Lenham Forstall to the west. The Lenham Beds have a potential to con-tain Pleistocene deposits in fissure sites. Remnants of an early hedgerow may lie on the eastern boundary. As development could potentially affect buried archaeological deposits a programme of archaeological works should be implemented in advance of development.

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Responses

Protect Kent Rejection recommended, due to: poor access to the A20 and unsuitability of country lanes for HGVs, im-pacting on the general amenity and quality of life in the locality and of local communities; issues regarding pedestrian safety; potential visual impact on views from the AONB.

Lenham Parish Council As noted in the SA, access would indeed be "via country lanes which may [we say, definitely would] be unsuit-able for lorries". Both the site and the access road to it are close to residential properties. We question the viability of the site. 1.2 million tonnes from 2.3 ha seems a high figure. End result would be a deep hole in the ground which could only be restored by infilling, as proposed by the operator. Grave risk to the aquifer.

Environment Agency This site is in an SPZ3, depth to groundwater and a necessary attenuation layer would need to be determined if this site was to go ahead. This decision would be made on detailed site assessment and further discussions if this site was included. The need for inert landfill needs further assessment as the Great River Stour source area is downstream of this site. No objection from a flood risk perspective.

Challock Parish Council The increase in traffic movements would greatly affect Challock along the A252. Concerns about the environ-mental impact this would have. We share the same water source as Charing residents and feel very strongly the valid points Charing Parish Council have made in its objections.

Weald of Kent Protection Society

We object to increased lorry traffic on unsuitable roads. In addition, there are several private houses adjacent to the site and it is difficult to see how access could be gained without causing severe disruption and incon-venience to the inhabitants.

Highways (KCC) The site is unacceptable; approach roads to the site from the A20 either via Lenham Forstal Road/Forstal Road or through Charing Heath are winding and are not wide enough to accommodate HGV’s.

General Public Responses Increased traffic, Poor access, Noise, availability of suitable inert landfill, adverse impact on flora and fauna, damage to historic hedgerows and orchards, pollution of water courses, danger to pe-destrians and horse riders, damage to railway bridges, loss of historic sites which have yet to be in-vestigated, smell, dust, light, overlooked by Downs (AONB) public footpaths destroyed, damage to cars parked on road, additional buildings needed on site, site is in an SPZ3

Kent Wildlife Trust There are two Local Wildlife Sites situated within the locality that could be impacted by changes in hydrol-ogy from the proposed quarrying and possible pollution from the proposed infill. Impacts on these sites should be investigated if the site is to be allocated. As stated previously we would advise that rather than the site being in-filled and restored to grazing land there is the opportunity to manage this quarry for wildlife. This is especially pertinent in this area as the sand quarries are known to contain rare invertebrate and bird species. There are opportunities to extend this network within any aftercare plan if this site is allocated.


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6.1 Site 105 Borough Green Sand Pit, Borough Green

The submission proposes a northerly extension to the existing sand extraction pit area with sub-sequent infilling of inert waste.

Responses

Platt, Borough Green, Wrotham Parish Council and CPRE Tonbridge and Malling District Committee

The proposal is unacceptable due to the potentially adverse affect of subsidence on the M26 motorway. The potentially adverse effect of the sudden noise of machinery on severely autistic children in the adjacent school. Given the scale of existing minerals operations in the local area, there are serious concerns over the cumulative impacts of additional sites on the highway network, pedestrian safety, along the main routes that would be used by HGVs, and the general amenity and quality of life of Borough Green and Platt by residents.

RSPB We support the proposed restoration to woodland, incorporating biodiversity enhancements; however we would strongly encourage a restriction in the number of end-uses and habitats, as this will increase the eco-logical functionality of the site. We support the conclusion of the Sustainability Appraisal that ‘the site will pro-vide opportunities for the flood risk mitigation for the surrounding area and habitat creation' and suggest that to strengthen this site could be restored to wetland habitat. By restoring to wetland habitats the site would pro-vide increased capacity to provide ecosystem services such as flood storage and alleviation.

Biodiversity Ancient Woodland present within 1km. SSSI and LWS within 5km. Unlikely to present a significant constraint. Designated species recorded within 1km of the site. Habitat indicators for protected species present on and near the site.

Heritage The site lies in an area of general archaeological potential particularly relating to Romano-British finds to the south west and south east. Permission to develop this site should include provision for archaeological works.

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Responses

Kent Downs AONB Part of the proposed quarry and inert fill site is within the Kent Downs AONB and will be marginally visible from the scarp. It is important that the whole site is progressively restored to high standards, and that these are enforced. There is concern over the proximity of the school on the Wrotham Road and other close resi-dents. It is important that the materials are exported and imported via the south onto the Maidstone Road through the existing route. However local road safety in this area is also an issue.

Kent Wildlife Trust Kent Wildlife Trust has no objection to extraction within this site. However the site is within 170m of Park Wood which is identified as ancient woodland. It is important within the assessment process that hydrological and dust impacts are fully investigated and mitigated. We welcome the aspiration to re-create habitats but due to the value of un-restored quarries to biodiversity consideration should be given to the viability of enhancing the quarry for wildlife with no plans for infill.

Protect Kent Rejection recommended, due to: location within Kent Downs AONB affecting the environmental and visual amenity of the locality; significant HGV movements affecting nearby residential amenity (including a local pri-mary school); loss of public rights of way; the availability of other sand quarries in the vicinity providing more suitable alternative options; part of land required for transport needs - policy CP26-2 in T&M’s LDF.

Highways Agency We would wish to be consulted prior to any planning application to extend the Borough Green Sandpit (Site 105) northwards. We would require that sufficient land is preserved on the northern edge of the site to safe-guard the integrity of the motorway and allow us to continue to maintain our asset.

Environment Agency This extension would bring extractive activities very close to the SPZ4 associated with the public abstraction to the southwest. No objection from a flood risk perspective however, a watercourse which may accept high-ways drainage from the M26 motorway appears to form the western boundary of the site. We recommend no works are undertaken within eight metres from the watercourse. From a biodiversity perspective, Borough Green Sand pit has small streams that probably only run for part of the year. The existing sand pits may al-ready impact on drainage in the area.

Natural England Whilst this site is an extension of an existing quarry it is partly within the Kent Downs AONB. The Council will need to be satisfied that the site meets the “exceptional circumstances‟ required under PPS7 and alternatives have been explored before taking forward.

Cemex Cemex support the inclusion of site 105-Borough Green Sandpit as a sand site with restoration via inert fill.

Highways (KCC) Accessed via an industrial estate road onto the A25. The junction is heavily used by HGV’s and there is a history of local concerns being highlighted. The road widths and footway widths here are limited and passing lorries do pass close to pedestrians. A school is near to the junction and whilst the junction bell mouth utilises as best as possible the space available, left turn exit lorry movements often entail manoeuvring over the cen-tre line towards westbound traffic which can in turn edge westbound traffic closer to the southern footway. I would recommend that any extension of Borough Green Sand Pit is best undertaken via the Nepicar site.


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7.0 Site 98 Jeffries Site, Teynham

The site is proposed for progressive brickearth extraction with on-going restoration back to agri-cultural land. The brickearth working would be undertaken in east to west strips progressing from north to south. The brickearth reserves to the north of the site have also been previously worked and restored. Responses

Swale Borough Council The Council object to this site due to the noise and dust pollution and resulting impact on residential amenity to nearby residential properties from both the excavation process and the access by up to 47 lorry movements per day. Access is down a rural lane which is a cause for concern. It is however accepted that the 6 week per annum operation would reduce any potential impact and it is accepted that there is a high demand for brickearth locally. Also, the site would only be worked for 3 years and the depth of extraction is relatively low. If this site was allocated it would be essential that it was restored to agricultural use after its closure.

Teynham Parish Council The Jeffries site is an extension to an existing brick earth site but the other two sites are new. The Parish Council's Planning Committee wishes to object to the excavation particularly to sites 101 and 102 because of the intolerable increase in lorry movements (a total of 400 per day from the two sites), the potential hazard of lorries accessing and exiting the Barrow Green site (site 102) along the A2 and because of concerns of possi-ble noise. It has also stressed that should the application for site 102 be successful that any access via Lower Road would be totally unacceptable.

Biodiversity Ancient Woodland is present within 1km. SPA, Ramsar, SSSI, NNR and LWS are within 5km. These are unlikely to present a significant constraint. The site setting is primarily arable land, with apparently minimal ecological interest. Impacts to hedgerows would require ecological assessment.

Heritage A buffer which includes screening should be maintained between the site and the Listed Building to the south and Jeffries to the east. Prior to permission for any development, the impact of the proposals upon the Listed Building should be fully assessed and mitigation measures undertaken to avoid impact on its setting.

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Responses

Environment Agency It is not clear from the text if this site will be backfilled once brickearth is extracted or if low level restoration is envisaged. If all brickearth is removed then the principle chalk aquifer geology would be exposed. There would be concerns for local abstractors (mainly agricultural) and turbidity issues in groundwater quality result-ing from any disturbance to the aquifer via increased infiltration rates. It is unclear if restoration were to be with infill, what type is proposed. Only inert landfill would be accepted over the chalk aquifer. The need for further inert disposal sites is also in question. No objection from a flood risk perspective.

South East Local Enterprise Partnership

This will destroy or at best irreversibly degrade Grade 1 productive farmland, which is in short supply in our region. It does strike me as a strange and illogical proposal in a time when food security is becoming a na-tional issue and our political leaders are grasping the value of food production to the economy, especially of the South East. The applicant has stated that when the works are finished this land will be returned to agricultural use. However, the proposal is to remove the very nature of the land, the deep brickearth soils. I question the res-toration, as once Grade 1 land is torn up all that can replace it is landscaped land that may look like fields but the grade 1 properties will have been lost. Alarmingly, in the last 30 years we have lost 30% of our farmed land.

General Public Responses The removal of Grade 1 agricultural land should be opposed. Site is in North Kent Fruit belt. Brickearth is not a sustainable building material. Traffic from extra lorries. Pollution. Any companies involved should be local so the local area prospers from the works. Ospringe is already identified as having poor air quality due to traffic. Sittingbourne is a traffic bottleneck. The Sittingbourne Relief Road needs to be completed before this could be considered.

Protect Kent Rejection recommended, due to: implications of increased road traffic on the A2 such as pedestrian safety; impacts on the residential amenity and general quality of life of the residents of Teynham, Sittingbourne and Faversham that the A2 passes through; the need for the material is not proven.

Kent Wildlife Trust Kent Wildlife Trust has no objections to the extraction of brick earth from this site. There are no sensitive habitats within the surrounding area with land being predominantly agricultural.

Highways (KCC) The site has a short boundary with the highway at Claxfield Road which is not suitable for large volumes of traffic, nor for HGVs. Claxfield Road has a number of 90 degree bends with poor forward visibility and no means of improving these as the land is outside of the development site. There is no point along the front-age of the site which is suitable for an access. Claxfield Road has a substandard junction with A2, controlled by a stop sign with inadequate visibility to the right. The site is remote from amenities in Teynham and from bus route on A2.


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7.1 Site 101 Barbary Farm, near Faversham

This site is promoted for the extraction of brickearth. It is proposed for an extraction area and tonnage sufficient to provide for a 25 year tranche of supply, with progressive restoration taking place throughout the extraction period.

Responses

Swale Borough Council The Council has no objection to this site. The proposed screen planting along the boundaries would minimise visual impact and water management opportunities which have been identified. We have concerns that land opposite on the north side of the A2 had its brickearth extracted decades ago and still lies wet in winter.

Norton, Buckland and Stone Parish Council

Sites would individually generate a volume of 200 lorry movements per day. The A2 trunk road has been the site of several fatal accidents. The land at Barbary Farm is employed in fruit growing. The land is classed as Grade I under the Agricultural Land System (ALC) ‘Excellent'. PPS7 decrees that for all planning purposes this classification of land should only be developed as a last resort.

Teynham Parish Council The Parish Council's Planning Committee wishes to object to the excavation particularly to sites 101 and 102 because of the intolerable increase in lorry movements (a total of 400 per day from the two sites).

Biodiversity Ancient Woodland and LWS are less than 300m away. SPA, Ramsar, SSSI and NNR within 5km. There is hedgerow connectivity to the site, these may present an ecological constraint and requires proper assess-ment. The site setting is primarily arable land. Impacts to hedgerows would require ecological assessment. Additional habitat indicators of protected species are present close to the site.

Lynsted & Kingsdown Parish Council

Enquiries with Kent Highways established that there is no traffic data for the A2 in the vicinity of the proposed sites since 2007. It is not therefore possible to make any sound judgement without additional traffic flow data. There is also no indication of the destination or journey times for these lorry movements. LKPC would strongly suggest that such surveys be undertaken before these two sites are considered further.

Highways (KCC) Sufficient capacity on A2, may require mitigation at junctions on A249. Frontage of site is in 60mph zone.

Responses

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Responses

Ibstock Brick Ltd If an application was sought to extract from either Barrow Green or Barbary it will replace the extraction at Hempstead and thus there will be no net increase in lorry movements on the highways. Both of the sites we refer will be subject to consideration as part of the EIA process to consider in any application; Local sensitiv-ity, ecology, archaeology etc. We are already aware of the ALC rating as Best and Most Versatile and are able to demonstrate our ability to extract brickearth and restore to the highest standards.

JE & JW Clinch Farming Part-nership

This is some of the highest grade horticultural soil in the country. Its potential for soft and hard fruit produc-tion is second to none. The loss of such a valuable resource is irreversible. This site is in an area of excep-tional horticultural production with all the ancillary industries close to hand.

Protect Kent Rejection recommended, due to: impact on residential amenity of nearby residents; impact on nearby Ancient woodland; implications of increased HGV traffic such as pedestrian safety; impact on the residential amenity of settlements that the A2 passes through; the need for the material is not proven. Disruption to residents, an-cient woodland and localities will be severe from the extensive size of the site and length of operation.

Kent Wildlife Trust The site is 349m away from SW01 Ospringe Valley LWS designated for its ancient woodland and chalk grass-land habitat. It will be important to ensure there are no impacts on these habitats from the proposed quarrying. The increases in traffic should also be assessed in regard to the impact of increased emissions on the ancient woodland and chalk grassland within the area.

Swale District Committee CPRE

These two sites are both on top, grade 1, Agricultural land. They have been used for the growing of fruit for many years. This area is proud of having the first formal cherry orchards planted by Henry VIII's fruiterer, in this unique fruit growing soil. If permission is given for extraction, this valuable land will be rendered unusable for future fruit growing. To save on transport costs and the environment, we now need to grow as much local produce as we can. It cannot be right to use an area of the finest Grade 1 land for strip mining.

Environment Agency It is not clear from the text if this site will be backfilled once brickearth is extracted or if low level restoration is envisaged. If all brickearth is removed then the principle chalk aquifer geology would be exposed. There would be concerns for local abstractors (mainly agricultural) and turbidity issues in groundwater quality result-ing from any disturbance to the aquifer via increased infiltration rates.

General Public Comments Soil is Grade 1 agricultural land. Would not be suitable for fruit production once the land is restored. 200 lorry movements on a road that has had fatal accidents. Excavations have found part of Watling Street, the Roman Road between Dover and London. Flooding issues.

Heritage Investigations in the area to the east of the site at Syndale have indicated presence of the Roman road and roadside settlement. It is recommended that the northern part of the site which is likely to include the Roman road is not included in the allocation site. A buffer, which includes screening, should be maintained between the quarry site and the Listed Buildings to the west at Barbary.


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7.2 Site 102 Barrow Green Farm, Teynham

This site is promoted for the extraction of brickearth. It is proposed for an extraction area and tonnage sufficient to provide for a 25 year tranche of supply, with progressive restoration taking place throughout the extraction period.

Responses

Swale Borough Council The Council has no objection to this site. Proposed screen planting along the boundaries would minimise the visual impact and water management opportunities which have been identified. We have concerns the land opposite on the north side of the A2 had its brickearth extracted decades ago and still lies wet in winter.

Norton, Buckland and Stone Parish Council

It is suggested the sites would individually generate a volume of 200 lorry movements per day. The stretch of the A2 trunk road has been the site of several fatal accidents. The council believes that the retention of these sites in their current state represents far greater value to the area and Kent in general, than their downgrading to service the small yellow brick industry, contributing nothing to the well being of the locality.

Teynham Parish Council Objection because of the intolerable increase in lorry movements (a total of 400 per day from the two sites), the potential hazard of lorries accessing and exiting the Barrow Green site (site 102) along the A2 and be-cause of concerns of possible noise. Any access via Lower Road would be totally unacceptable.

Biodiversity SPA, Ramsar, SSSI, NNR, LWS and Ancient Woodland are present within 5km. These are unlikely to pre-sent a significant constraint. The site setting is primarily arable land. Habitat indicators of protected species are present on and around the site.

Lynsted & Kingsdown Parish Council

Unsuitability proposed access route along Lower Road, Teynham, which is a narrow country lane and unsuit-able for this volume of traffic. Enquiries with Kent Highways established that there is no traffic data for the A2 in the vicinity of the proposed sites since 2007. It is not possible to make any sound judgement without addi-tional traffic flow data. There is no indication of the destination or journey times for these lorry movements.

Highways (KCC) Sufficient capacity on A2, may require mitigation at junctions on A249. Frontage of site is in 60mph zone.

Responses

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Ibstock Brick Ltd If an application was sought to extract from either Barrow Green or Barbary it will replace the extraction at Hempstead and thus there will be no net increase in lorry movements on the highways. Both of the sites we refer will be subject to consideration as part of the EIA process to consider in any application; Local sensitiv-ity, ecology, archaeology etc. We are already aware of the ALC rating as Best and Most Versatile and are able to demonstrate our ability to extract brickearth and restore to the highest standards.

JE & JW Clinch Farming Part-nership

This is some of the highest grade horticultural soil in the country. Its potential for soft and hard fruit produc-tion is second to none. The loss of such a valuable resource is irreversible. This site is in an area of excep-tional horticultural production with all the ancillary industries close to hand.

Protect Kent Rejection recommended, due to: proximity to Teynham and the impact on residential amenity and quality of life of the residents; impact of a significant number of HGV movements on pedestrian safety and residential amenity of settlements that the A2 passes through; the need for the material is not proven.

Kent Wildlife Trust KWT has no objections to the excavation of brick earth within this site. Both the site and the surrounding area is largely agricultural land and therefore likely to be of low ecological value. There is a small woodland block adjacent to the site which should be protected and buffered within any excavation plan. As in all cases KWT would advise that the after use of this site be for biodiversity rather than restored back to agriculture.

Swale District Committee CPRE

These two sites are both on top, grade 1, Agricultural land. They have been used for the growing of fruit for many years. This area is proud of having the first formal cherry orchards planted by Henry VIII's fruiterer, in this unique fruit growing soil. If permission is given for extraction, this valuable land will be rendered unusable for future fruit growing. To save on transport costs and the environment, we now need to grow as much local produce as we can. It cannot be right to use an area of the finest Grade 1 land for strip mining.

Environment Agency It is not clear from the text if this site will be backfilled once brickearth is extracted or if low level restoration is envisaged. If all brickearth is removed then the principle chalk aquifer geology would be exposed. There would be concerns for local abstractors (mainly agricultural) and turbidity issues in groundwater quality result-ing from any disturbance to the aquifer via increased infiltration rates.

General Public Comments Soil is Grade 1 agricultural land. Would not be suitable for fruit production once the land is restored. 200 lorry movements on a road that has had fatal accidents. Excavations have found part of Watling Street, the Roman Road between Dover and London. Flooding issues.

Heritage A buffer, which includes screening, should be maintained between the quarry site and the Listed Building to the south. Prior to permission for any development, the impact of the proposals upon the Listed Building should be fully assessed and mitigation measures undertaken to avoid impact on its setting. Similarly the impact of the proposals upon the setting of the Conservation Area at Teynham should be assessed.


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8.0 Site 103 Pfizer Limited, Sandwich Site

The Pfizer site has been primarily put forward for the continued operation of its existing waste activities and for the future development of these to include recycling. The site would han-dle hazardous, non– hazardous and Commer-cial and Industrial (C&I) wastes.

Responses

Dover District Council The land has recently been designated as an Enterprise Zone, there is a Government requirement to prepare a Local Development Order (LDO). Work on this is at an early stage. Pfizer is currently in the process of offer-ing the site for sale, intentions for the site by any incoming owner are not known. Owing to this uncertainty it is proposed that the District Council liaise with the KCC Minerals & Waste Team in the preparation of the LDO to ensure consistency of approach with the Minerals & Waste LDF.

Southern Water Only the Pfizer sites (ref. 103) fall within Southern Water's water supply area. The sites are not located within a groundwater Source Protection Zone. No risk has therefore been identified to the quality and potential yield of water resources. No underground water mains have been identified which cross the three sites.

Kent Wildlife Trust We are concerned that due to the nature of the LWS the activities planned for this site in combination with sites 54, 64, 52 and 65 may cause damage to the LWS through pollution and impact on the water flows. Although this site individually may be able to be mitigated when viewed with the other plans within the local-ity it is likely to cause an impact on the wetland habitats for which the LWS is designated.

Protect Kent Acceptable, subject to a more detailed assessment, provided that: impacts on the nearby Ramsar Site and SPA are carefully managed and mitigated against.

Biodiversity SPA, SAC, Ramsar and SSSI immediately adjacent to all three parts of proposed site. These may present a constraint to development, requiring proposer assessment of potential impacts. LWS within 1km.

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Environment Agency No objection. The site benefits from some flood protection but remains at risk from both tidal and fluvial flood-ing under medium to significant events. Areas for storage of waste would be considered more vulnerable therefore a Flood Risk Assessment would be required to demonstrate the proposal can be made safe against flooding. This may require waste storage areas to have separate flood protection. The promoted site has ex-isting environmental permits for the treatment of waste. Recovery of waste heat will be dependent on the de-mand from development identified through the enterprise zone.

Sandwich Town Council This site is incorrectly named. Pfizer is no longer responsible for the site and the area is known as Discov-ery Park. If the proposal were to widen the waste streams and handle waste from anyone and anywhere, including hazardous waste from overseas then Sandwich Town Council would strongly object. The council is concerned about increased traffic movements. The site is in close proximity to a RAMSAR site, a SSSI, a nature reserve, the ancient town and cinque port of Sandwich and Stonar Lake. There are plans by Natural England for the Coastal Access Path to run in close proximity to the facility.

Natural England We note that these are existing sites. If they continue at the same level of activity Natural England would have no comment. However, if the activity and/or use of the sites are to change then an assessment will be re-quired on the potential impacts on the adjacent European sites.

RSPB This site is located immediately adjacent to Thanet Coast and Sandwich Bay SPA/Ramsar site, Sandwich Bay to Hacklinge Marsh SSSI, designated for its breeding wintering and migratory birds, and Sandwich Bay SAC. As such, this option must be thoroughly assessed as part of the HRA process to ensure that there is no Likely Significant Effect on the European Sites. Impacts should be assessed both alone and in combination with other plans and projects, and the in-combination effect of sites in the Minerals and Waste Sites Options DPD.

Eastry Parish Council The Council are concerned that the plant will not be able to handle additional waste from external sources. They are also concerned that as the plant was not built for this specific purpose that it will not have the neces-sary equipment to prevent air pollution.

Cliffsend Residents’ Associa-tion

The Cliffsend Residents' Association committee voted unanimously to support this proposal. The rotating kiln high temperature incinerator on this site is a very advanced specialist unit with very strict emission controls. Few of these exist in this country, and it is still required on the Pfizer site to deal with chemical waste which is currently being generated on site; and this will continue. If it were closed the waste from the Pfizer site would have to be transported elsewhere for safe disposal. It makes sense to make full use of these existing facilities, rather than close them and have to construct new facilities / enlarge existing units elsewhere.

Heritage The sites are within view of the important Roman port of entry at Richborough which includes a Scheduled Monument. Proposals should avoid impact on the setting of Richborough Castle. The potential impact on the setting of the monument should be assessed in advance of development proposals and mitigation measures put in place to address any impacts.


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8.1 Site 104 Land between Orpington Bypass and M25

This area of land has been put forward for use as a biomass facility which would use waste wood to generate electricity. The material would arise from a range of sources including Com-mercial & Industrial and Municipal Solid Waste, 60% of which would be sourced from Kent.

Responses

Shoreham Parish Council It is 2.3 kilometres from an existing waste recycling facility. An incinerator at this location would create unac-ceptable harm to the local environment. More than 1,000 people living within 1.5 kilometres of the site would be adversely affected. Several national designations, such as AONB and Green Belt, would be compromised. This is not a Kent solution for a Kent problem 40% of the fuel is expected to be sourced from outside Kent.

Dunton Green Parish Council Environmental concerns in regard to the potential emissions from such an energy to waste facility and traffic impact concerns given that there is no indication as to whether the expected 24 lorry movements per day will be over a 24 hour period or condensed into a shorter working day, such as 8 hours.

Halstead Parish Council The M25 slip road and busy A21/A224 roundabout is not suitable for increased traffic; possible fumes and smoke from the facility could cause problems on the roads; Any fumes or smoke produced would have ad-verse affect on the air quality; This is an area of ancient woodland which should be protected.

Sevenoaks District Council In light of the harm this proposal could cause to the openness of the Green Belt, the AONB land-scape, character, and biodiversity of the area, as well as the potential impact on traffic movement and air quality, the District Council should strongly object to the principle of this site being allocated.

RSPB The RSPB is concerned that this site involves direct land take from ancient woodland, a local wildlife site (SNCI), and Kent Downs AONB. The proposed site would therefore have an adverse impact on these sites.

Biodiversity A LWS and Ancient Woodland are sited within the boundary of this site. Habitat indicators of protected spe-cies are present on and around the site. Would need to demonstrate the need and benefits of development for this site that would outweigh the importance of Ancient Woodland habitat.

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Woodland Trust We object to the abovementioned sites being identified for further development as they will result in the direct loss of ancient woodland. These should not be taken forward unless the protection of ancient woodland can be guaranteed. Recognition of the potential indirect impacts on ancient woodland from adjacent development must be recognised.

CPRE Sevenoaks District Committee

The site is in the Kent Downs AONB. The site includes an area of ancient woodland, which requires protection because it is irreplaceable and also because it supports a long-established and stable ecology. The site is close to the M25 corridor, which has been identified as an Air Quality Management Area.

Kent Downs AONB The impact of this development on the AONB and the Ancient woodland and local amenities is high. Con-straints - AONB, Ancient woodland, County Wildlife site.

Kent Wildlife Trust Objection to the allocation of this site as a biomass facility as it would lead to the direct loss of ancient wood-land and chalk grassland which is designated as part of the SE09 Woodlands West of Shoreham LWS.

Protect Kent Rejection recommended, highly sensitive site location within the Kent Downs AONB, significant visual im-pacts; impacts on Ancient Woodland and adjacent RSBP reserve; impacts on biodiversity given its location in a County Wildlife site; traffic congestion and road safety given location adjacent to a major road interchange.

Highways Agency We would oppose any proposals to provide direct access onto the roads for which we are responsible, irre-spective of the local benefits. We would also expect any planning applications for minerals and/or waste facili-ties that come forward to be supported by a transport assessment if they have the potential to have a material impact in traffic terms on the motorway and all purpose trunk road network.

Environment Agency No objection in principle provided no treated timber stored on open surfaces. Drainage from wood piles stored in open would need to be controlled to some extent.

Natural England It is within the Kent Downs AONB and would have an urbanizing effect. Additionally, given its rural location there would appear to be no demand for the waste heat and this represents a wasted opportunity. Suitable sites outside of the AONB should be considered before this site comes forward.

General Public Comments Local Wildlife Site, AONB, MGB, Ancient Woodland. Increased traffic, Ground Source Protection Zone, 1,000 people live within 1.5km, pollution, damage to wildlife-deer, badgers, dormice and bats, damage to local busi-nesses, visitors to Shoreham Woods, waste wood could be more usefully recycled, chimney would be visible to houses, ash could reach local residents.

Heritage The proposed development site lies in an area with background archaeological potential relating to the find-ings of the Mesolithic flint artefacts nearby. Permission to develop this site should include provision for ar-chaeological works.


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8.2 Site 107 Land at Lower Road, Swanscombe

This area of land has been put forward as a lo-cation for an Energy from Waste facility. An esti-mated 20 MW would be produced from the gasi-fication of non-recyclable, commercial waste consisting of sorted and blended cardboard, pa-per, waste wood and non-specific biomass ma-terial.

Responses

Dartford Borough Council Dartford Core Strategy Policy CS7 ‘Employment Land and Jobs’ protects existing employment areas, includ-ing Manor Way Business Park, for B1, B2, B8 and A2 uses. The proposed use does not comply with this pol-icy and is likely to generate fewer jobs than ‘B’ uses. Paper and cardboard waste is declining. KCC is looking to dispose of material such as waste wood at the Al-lington incinerator. It is therefore questionable if there will be sufficient locally sourced material to supply the facility. Material will have to be brought in from a wide catchment, primarily out of County. Transport of the feed stock over long distances by road is not sustainable. The preferred location on the Swanscombe Penin-sula would enable water transport of the materials. The Sustainability Appraisal of the site states that it is not in a groundwater source protection zone. This is incorrect as the site lies within source protection zone 3.

Biodiversity There are international (SPA, Ramsar), national (SSSIs, NNR) and local sites (LWS) within 1km but the bar-riers between the site and the natural areas mean that they would be unlikely to be a significant constraint. Depending on the site use, there is potential for indirect effects on natural habitats. There are designated species records for the 1km square in which the site is situated. There are some ‘natural’ areas within the site boundary that have the potential to present opportunities for designated species. Present on the site are habitat indicators with potential for impacts on protected species as a result of development.

Heritage The chalk quarry is likely to have fully removed the potential for finding remains except around its edges. The site is overlooked by Grade II* Listed All Saints Church to the south. Development should consider and avoid any impact on the setting of the Listed Building at All Saints Church.

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Kent Wildlife Trust As noted in Kent Wildlife Trust's response to Site 58 of the original consultation this site is on the Swanscombe peninsular which is known to contain populations of invertebrates of national importance. These species colonise open mosaic habitats on previously developed land. We recommend that there should be a detailed assessment of the site's ecological value particularly with regard to invertebrates to ensure conformity with Planning Policy Statement 9 Biodiversity and Geological Conservation. Individual impacts should be considered as well as in-combination impacts Site 99 of this consultation. Records show that reptiles are also present within the area. If present on this site then mitigation measures will need to be formulated for these species if the site is allocated.

Protect Kent Acceptable, subject to a more detailed assessment, provided that: negative impacts to Air Quality Manage-ment Areas and the sensitive Botany Marshes are understood and conditions put in place to mitigate against these; impact of HGV traffic must be managed within the permission, particularly with regard to pe-destrian safety; conditions are put in place to minimise or negate impacts on neighbouring residents.

Environment Agency This site would need a permit for gasification plant. - no objection in principle although drainage would need to be sealed surface and historic land contamination issues would need to be assessed/dealt with as part of any permission.

Highways (KCC) A contribution for junction improvement would also be sought from this site.

Kent County Council–

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9.0 Site 9 Ightham Sandpit Amendment

The proposal is for inert waste infilling of the ex-isting Ightham Sand Pit. This site is within the Kent Downs AONB. Amendment– Site 9 has only been put forward by the operator for inert waste infilling, not an extension of the existing extraction area.

Responses

Tonbridge and Malling Bor-ough Council

There are concerns over the impact on the open setting of Borough Green and Platt of these large scale pro-posals and the resultant impact this would have on residential amenity. There are serious concerns over the cumulative impacts of additional sites on the highway network, pedestrian safety, the integrity of houses and other buildings along the main routes that would be used by HGVs, and the general amenity and quality of life.

Platt Parish Council, Borough Green Parish Council, Wrotham Parish Council and CPRE Tonbridge and Malling District Committee.

Local residents have experienced years of hardship caused by HGV traffic. Much of the site is reserved under Tonbridge and Malling’s LDF as protected land reserved for the Borough Green and St Mary Platt Bypass un-der policy CP26-2. There is no logic in undoing the previously restored land. Petrochemical and other pollut-ants heavily contaminate the existing ‘inert infill’. The successful habitat creation has spawned wildlife, most particularly in the form of Great Crested Newts (GCN’s). Many other species have been observed in the area. We are concerned that the taking forward of these new sites will have a collective impact on the openness and setting of these communities within the Green Belt.

Ightham Parish Council Ightham Parish Council was disturbed by the additional findings that were presented to the Public Enquiry on the Borough Green Bypass concerning the alleged pollutants that had been tipped into this pit histori-cally. It urges the owners to cover and restore this site in the manner as outlined as a matter of urgency. Ightham Parish Council supports the proposed works for the reasons as described in the SA.

Kent Downs AONB The Kent Downs AONB object to any further extension, or reworking and /or filling of the site and call for the proper restoration of the whole area to agriculture at the levels originally intended to avoid any further im-pact on the AONB and the environs of Ightham Court, an historic house and park within the AONB.

Amendments -

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Biodiversity The site does not have any designated areas within the site boundary. There are local sites (LWS) within 1km and national and local sites (SSSI and LWS) within 5km. These are unlikely to present a significant constraint. There are designated species records for the 1km square in which the site is situated. There are habitat indi-cators of protected species presence on and around the site, including; woodland, hedgerow, pond, ditches and rough grassland.

RSPB This site falls within the Greensand Heaths and Commons BOA. As such, restoration to broadleaf native woodland, acid grassland or heathland would be appropriate. We would recommend the restoration be com-plemented by biodiversity restoration on the adjacent Ightham Sand Pit site (site 50), should this site be pro-gressed. Should the restoration be to agriculture as proposed, biodiversity gains should be included in the res-toration plan to add value to the restoration, for example the inclusion of ponds and species rich hedges.

Kent Wildlife Trust As stated previously we would recommend that quarries are only in-filled in exceptional circumstances with redundant quarries being managed for biodiversity as standard practice. Management for biodiversity rather than restoration to agriculture would be preferable from an ecological standpoint whether or not the decision is taken to restore the site.

Protect Kent Rejection still recommended due to: Kent Downs AONB, potential Local Wildlife Site, evidence of colonies of Great Crested Newts, part of land required for transport needs - policy CP26-2 in Tonbridge & Malling's LDF. In addition, poor backfilling in the past has led to contamination of a zoned water protection area.

Environment Agency This site already has some existing fill, investigations have shown it is mixed and has some levels of contami-nation, which locally may be affecting groundwater. Any further works in this area would need to do a compre-hensive assessment of existing materials and re-process and /or remediate materials appropriately prior to any further deposit of additional inert materials. The overall application is not a problem in principle but exist-ing site circumstances would need to be addressed rather than just buried by additional inert fill.

Natural England We note that this site is for infill with inert fill only and withdraw our previous comments. Any restoration will need be sympathetic to the sites position within the Kent Downs AONB.

Heritage In large areas any archaeological potential will have been lost. There is a background prehistoric and Roman potential for Palaeolithic fissure sites. A Listed Building lies just south of the proposal site at Cricketts Farm and Grade II Registered Park and Garden and Listed Building at Ightham Court lies to the south west. There is unlikely to be a need for archaeological mitigation. Development should consider and avoid any impact on the Listed Buildings.


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10.0 Site 16 Beacon Hill Quarry Amendment

Existing site producing chalk for agricultural lime Amendments–The site has been submitted for both minerals and waste uses but was only re-ferred to in the Mineral Sites Options document. There is also a new access route to the site pro-posed.

Responses

Charing Parish Council Existing access to this site is inadequate and proposed new access is unacceptable. Chalk can be quarried outside the KDAONB, and there is no requirement for further inert waste facilities. The SA Commentary reads:- "Inert landfill pro-posed could impact upon the groundwater”. No risk of contamination of the Principal Aquifer or SPZ 3 is justifiable.

Challock Parish Council Increase in traffic movements would greatly affect Challock along the A252 which would see HGV’s and plant machinery moving out of the site at Beacon Hill Quarry at a rate of one every 3 minutes. Concerns about the environmental impact this would have. We share the same water source as Charing.

Westwell Parish Council The proposed new access road to alleviate the significant increase in traffic movements would cut across Ancient Woodlands, an AONB and an SSSI. There is an added complication in view of the Chalk Downs importance as a source of water via aquifers, for much of Kent and in particular the parish of Westwell.

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.

Protect Kent Rejection still recommended due to: a very sensitive site, in the middle of AONB, adjacent to a SSSI, sur-rounded by Ancient Woodland; site is also a Regionally Important Geological Site and part SNCI; disruption to the locality and local communities should not be allowed to continue for another 20 years.

Biodiversity SSSI, LWS and Ancient Woodland lie within and immediately adjacent to the boundary of this site and the pro-posed access route crosses the LWS and Ancient Woodland. Designated species records for the site and the 1km square in which it is situated. There are habitat indicators of protected species on and around the site.

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Highways (KCC) It is noted that the site is an existing Chalk Pit. The entrance area would need to be widened to allow Heavy Goods Vehicles to pass one another. In addition, the visibility splays at the site entrance where it connects with the A252 would need to meet requirements of 2.4m by 120m.

RPSB The RSPB is concerned that this site involves direct land take from ancient woodland, a local wildlife site and falls within the Kent Downs AONB. It is unclear from the diagram provided whether this site would involve di-rect land take from Charing Beech Hangers SSSI and we would welcome clarification on this point. We would recommend restoration to native woodland to complement the adjacent habitat.

Woodland Trust We object to the sites being identified for further development as they will result in the direct loss of ancient woodland. These should not be taken forward unless the protection of ancient woodland can be guaranteed. We therefore request that where site allocation is taken forward sufficient buffering between the development and woodland be identified in policy at this stage to allow it to be built into any development plans.

Kent Downs AONB The AONB resist any intensification of chalk quarrying or import of materials due to high impact on the road network, impact on the North Downs Way and impact of any new route on ancient woodland, track way and a local wildlife site, impact on the aquifer and challenge to the RIGS. AONB Management Plan Access and En-joyment, Biodiversity, Woodland, Geology and Natural Resources policies apply.

Kent Wildlife Trust Due to the threatened loss of Local Wildlife Site habitat and ancient woodland on site and within the access route, the possible impacts on the adjacent woodland designated as SSSI and the impacts that infilling the quarry is likely to cause to the flora and fauna within the designated habitats the Trust objects to the allocation of this site for mineral and waste uses.

Environment Agency Concern with regards to depth of dig, there are springs down gradient and local domestic abstractions which could be impacted by any deterioration in groundwater quality. Depth of dig is likely to be restricted therefore sufficient materials should be left in-situ to ensure an attenuation layer.

Charing Archaeological Group

Objection. The main objection of the Charing Archaeological Group (CAG) is to the haul road, as this will se-verely impact two ancient trackways and possible manorial boundary markers, originally tree stubs.

General Public Comments Lies over SPZ3-streams/boreholes supply drinking water– No further allocations are required for chalk– Lanes inadequate for HGV’s-Within AONB and SLA-Noise-Dust-Impact on two ancient track ways. Kent Gliding Club, birds would be hazard-Used by walkers and horse riders-damage to flora and fauna– closest dwelling less than 10m– Provision of Chalk is vital for agricultural industry

Heritage The old lime kilns and their immediate surrounding should be avoided by and protected from any develop-ment or quarry works. Development could affect buried archaeological deposits including remains of indus-trial archaeological interest.


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11.0 Site 50 Ightham Sand Pit (Western Extension)

Amendment– The proposal features sand ex-traction but the site was accidently omitted from the Soft Sand Sites section in the Minerals Site Options consultation document and only pub-lished in the Inert/Construction, Demolition and Excavation chapter of the Waste Document.

Responses



Platt Parish Council, Borough Green PC, Wrotham PC and CPRE Tonbridge and Malling District Committee

Object– Unacceptably impacts on the setting of two listed buildings and a historic garden. Ightham Sandpit previously negligently miss-managed. Site is next to breeding ponds for Great Crested Newts. Proposal would cause substantial HGV movements along the A25 and adversely affect Borough Green, Platt and Seal. Col-lective impact from other sites in area.

Biodiversity There are local sites (LWS) within 1km and national and local sites (SSSI and LWS) within 5km. These are unlikely to present a significant constraint. There are designated species records within 1km of the site. There are habitat indicators of protected species presence on and around the site, including: Woodland, Hedgerow, Pond, Ditches, Grassland and Buildings.

Ightham Parish Council The Ightham Parish Council recognises the strategic importance of the sand deposits beneath this site and the need for protection of the surface from development so as not to sterilize this resource. The importance of the "historic park" should be reviewed as it has been neglected for such a long period of time that it has lost its relevance. Consideration should be given to re-classifying this land accurately. At the appropriate time in the planning process it will be essential to ensure by Condition that any void created by mineral abstraction is re-stored back to the original ground level with inert fill and soft landscaped in a sympathetic manner. The pro-posal in Section 10.1 is supported by Ightham Parish Council.

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Heritage Proposals that could cause harm to the Registered Park and Garden and its setting should be refused. Similarly any impact on the setting of listed buildings at Ightham Court should be fully assessed and avoided. Given the location of this allocation site it is highly likely that quarrying would substantially affect the Park and Garden and Listed Buildings and it would be preferable that the proposal is completely re-moved from the allocations.

RSPB This site falls within the Greensand Heaths and Commons BOA. As such, we would recommend restoration to broadleaf native woodland, acid grassland or heathland. We would recommend the restoration be comple-mented by biodiversity restoration on the adjacent Igtham Sand Pit site (site 9) should this site be progressed.

Kent Downs AONB The KDAONB object on grounds of visual intrusion in the AONB, and the challenge to the Historic park and house of Ightham Court. The Kent Downs AONB resist the further extension of Ightham Sand pit into the AONB. There is no justification for need for soft sand to be provided from the AONB as there are other alter-native sites available outside the AONB and close to the site.

Environment Agency No objection but as for Site 9, any works to existing watercourses will require the prior written consent from us.

Kent Wildlife Trust As this site comprises improved grassland Kent Wildlife Trust has no objection in principle to the extension. However the site is within 500m of Bourne Valley Wood LWS designated for its ancient woodland and stream habitats and within 1.2km of Oldbury and Seal Chart SSSI. Due to the importance of hydrology to the Local Wildlife Site and the importance of fungi, mosses and liverworts within the SSSI it will be important to investi-gate the hydrological impacts of the proposed quarrying on the LWS and the pollution impacts on both sites to ensure that impacts can be mitigated.

Protect Kent Rejection recommended due to: the current state of the site as a restored quarry, not an existing working one as implied. Re-opening the site for extraction will negate the landscape restoration thus far and threaten the visual amenity of the local area, given that the site is within the Kent Downs AONB, providing the setting for two listed buildings and a Historic Park that are noted for protection in Tonbridge and Malling’s LDF.

Natural England Whilst this site is an extension of an existing quarry it extends the operation into the Kent Downs AONB. The Council will need to be satisfied that the site meets the “exceptional circumstances‟ required under PPS7 and alternatives have been explored before taking forward.

H&H UK Ltd Just a quick line following a meeting with H&H UK LTD (Celcon) regarding the proposed quarry on the west-ern reserves. I pointed out to my client that you (KCC Planning) were not over keen on permitting mass export from these reserves. We have therefore agreed that rather than prejudice the site being promoted they would accept a lesser amount of export reserving larger quantities for use in the block works.


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12.0 Site 63 Pinden Quarry (Western Extension)

Amendment: At the operator’s request the pro-posal has been enlarged to include a section of the adjacent land.

Responses

Dartford Borough Council No sound evidence of need is provided to justify the extension for chalk extraction or for hazardous waste landfill (asbestos). The two proposed extensions would result in additional traffic movements on Green Street Green Road. Longer, less sustainable lorry journeys would result if Pinden extends its catchment area to be-come the main source of agricultural and engineering chalk in the County and extends its catchment area for the disposal of asbestos waste, which already covers the South East, East of England and London. The site lies within the Green Belt and the timely restoration of the site is an important consideration.

Southfleet Parish Council The sites geographical location is circled by a number of villages and settlements. The current limitation of 500 vehicle movements per day in relation to the carriage of chalk and waste etc appears to be reaching the situation where there will be difficulty in keeping to the limit. Pinden Quarry is not the only source of chalk in Kent, or in neighbouring counties: the situation is not one of "chalk has to come from Pinden." Pinden is not the only recycling/waste facility: other than asbestos, waste does not have to come to Pinden.

Biodiversity This site does not have any designated areas within the site boundary. There are local sites (LWS and An-cient Woodland) within 1km and national site (SSSI) within 5km. These are unlikely to present a significant constraint. Designated species have been recorded within 1km of the site. The site setting is primarily ar-able and grazing land. However, there are habitat indicators of protected species presence on and around the site: including: hedgerow, grassland and pond.

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Responses

RSPB We are concerned about potential impacts on the adjacent local wildlife site (SNCI), including hydrological impacts. This site is near the Thames-side Green Corridors BOA, and as such we would recommend restora-tion to acid grassland, heathland and species-rich neutral grassland.

Southern Water All but two of the potential sites fall within Southern Water's wastewater area, the two exceptions being Pin-den Quarry Western Extension (ref. 63) and Land between Orpington Bypass and M25 (ref. 104). No con-straint to the layout/working of the site has been identified, as none of the sites have been found to be crossed by underground sewers or associated facilities

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. We would like to correct our previous response regarding woodland on site. There is no woodland within the extension and we wish to apologise for the incorrect information.

Environment Agency No objection

Protect Kent Acceptable, subject to a more detailed assessment.

Highways (KCC) A transport assessment carried out in July 2011 for a proposal to deepen the northern extension suggested that the peak hour HGV flows were in the order of 17 in the am peak and 11 in the pm. I would not wish to make any objection on capacity or safety grounds to the western extension provided that future flows re-mained around the same level, although I recognise that the continuing presence of HGVs on the B260 will not be welcomed by local residents.

AMEC E&I UK (for National Grid)

Pinden Quarry is crossed by one of National Grid's high pressure underground gas transmission pipelines. Local authorities have a statutory duty to consider applications for development in the vicinity of high pressure (above 7 bar) pipelines and to advise the developer on whether the development should be allowed on safety grounds on rules provided by HSE. In order to enable Local Authorities to discharge this duty and also to en-sure that National Grid's pipelines are protected from uncontrolled development in the vicinity of the pipeline they should follow the guidance set by national grid.

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.


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13.0 Site 71 Stonecastle Farm Quarry (Western Extension)

Amendment– The Mineral Site Options consul-tation site map showed the existing extraction area of the quarry rather than the proposed ex-tension area.

Responses



RSPB We support the restoration proposed on this site, and its contribution to the BAP priority habitat creation. This area has three large proposed allocations (sites 17, 49 and 71) which, if permitted, could all be restored to wetland habitat maximising the region's contribution to the BAP habitat creation targets and forming an area which is resilient to change and is self-sustainable. We would recommend aiming to direct the restoration of these sites in a complimentary way, in order to achieve net gain for biodiversity.

Biodiversity A Local Wildlife Site lies adjacent to the site’s northern boundary, crossing into the site at some points. As-sessment of impacts to the LWS would be required. Designated species have been recorded on the site. There are habitat indicators of protected species presence on and around the site, including: River, Ditch, Pond, Grassland, Woodland and Hedgerow.

Kent Wildlife Trust Kent Wildlife Trust is still concerned regarding the in-combination impacts of Sites 49 and 71 on East Ton-bridge Copses and Dykes and River Medway LWS. The knowledge that the land showed for allocation has already been permitted and the fact that the permitted boundaries incorporate some of the LWS increase our concerns. If impact has already occurred within the LWS due to mineral extraction we object to any fur-ther impact unless appropriate mitigation can be formulated.

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Heritage Further assessment of the potential impact of proposals in unquarried areas of this site on the historic land-scape and its surviving features is necessary to determine whether quarrying of such areas is appropriate. May have an impact on the setting of listed buildings. Prior to permission for extension of the areas of ex-traction, the impact of the proposals should be fully assessed with mitigation measures undertaken.

Protect Kent Rejection still recommended due to visual impact from the AONB, severe impact on local roads by HGVs, impacts on public rights of way. Note: while it is acknowledged that the revised site is much smaller, the main impacts will be just as significant, although perhaps over a shorter term.

Lafarge Aggregates Ltd Following representations made on our behalf by Alliance Planning in July this year, we are pleased to see that the correct information for Stonecastle Farm Quarry has been resubmitted in this document.

Environment Agency The site is within the floodplain of the River Medway and so the proposed works should not include any works which could impede flood flow or result in loss of flood storage. The River Medway is designated as "main river". Under the terms of the Water Resources Act 1991 and bylaws, the prior written consent is required for all works within eight metres from top of bank. This site has the potential for nature conservation value follow-ing restoration. The existing watercourses on the site should be taken into consideration through the allocation process. In particular there are woodland shaws that are likely to be of nature conservation value. For exam-ple one may be ancient in origin, but is too small to be on the ancient woodland inventory.

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 and the workings and restoration are suitably phased to minimise any visual impacts.


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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. Alter-natively it can be taken to purpose built facilities for crushing, screening and re-sale. There are also tem-porary facilities at some quarries landfill sites where material can be recovered for re-sale or use on site.

Amenity A land use which is not productive agriculture, forestry, or industrial development; can include formal and informal recreation and nature conservation.

Annual Monitoring Report (AMR) Records progress in implementing the Local Development Scheme and the performance of policies against targets in Development 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.

Building Sand/ Soft sand A naturally occurring type of construction aggregate found in Kent. It is mainly used for mortar produc-tion and in asphalt.

C

Combined Heat and Power (CHP) Technology produces power (electricity) whilst capturing the usable heat produced in the process. It is a single, integrated and more efficient method of production.

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C

Commercial Waste Waste from premises used mainly for trade, business, sport, recreation or entertainment, as defined un-der section 5.75 (7) of the 1990 “Environmental Protection Act”. As well as paper, card, plastic, 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 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

(also see demolition waste)

Waste arising from any development such as vegetation and soils from land clearance, remainder mate-rials 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 some timber, metal and glass.

D

Degradable (or putrescible) waste

(Also called non-hazardous waste)

Waste which will quickly or slowly biodegrade or decompose, releasing environmental pollutants. Types of material include 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; boiler scale; soap; cellulose; floor sweepings; sacks; electrical fittings and appliances; machinery; cosmetic products; tarred materials; car-bon; ebonite; pottery; chin; enamels; abrasives; trees; bushes; grass; flowers and other vegetation.

Demolition Waste (Also see Construction Waste)

Masonry and rubble wastes arising from the demolition or reconstruction of buildings or other civil engi-neering structures.

Development Framework A portfolio of documents. Collective term for the Development Plan Documents, the Local Development Scheme, the Statement of Community Involvement, Annual Monitoring Report, and any supplementary planning documents.

Development Plan Document These are the spatial planning documents (plans) required by the Local Development Framework. These set out spatial planning policies and proposals for an area or topic. They replace the former Local Plan and include the core strategy, detailed development control policies, site specific allocations of land, area action plans (where needed) and a proposals map.

E

Energy from Waste (EfW) The generation of heat and power from burning waste, the production of fuels from other forms of treat-

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Examination in Public (EIP) All Development Plan Documents will be subject to an independent examination before a planning inspec-tor. The inspector's report is binding on the local authority.

H

Hazardous waste Controlled Waste that is dangerous or difficult to treat, keep, store or dispose of, so that special provision is required for dealing with. Hazardous wastes are the most dangerous wastes and include toxic wastes; acids; alkaline solutions; asbestos; fluorescent tubes; batteries; oil; fly ash; industrial solvents; oily sludge's; pesticides; pharmaceutical compounds; photographic chemicals; waste oils; 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 unac-ceptable 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.

Household waste Waste from a domestic property, caravan, residential home or from premises forming part of a university or school or other educational establishment; premises forming part of a hospital or nursing home.

I

Industrial Waste Waste from any of the following premises; factory; provision of transport services (land, water and air); purpose of connection of the supply of gas, waster, electricity. Provision of sewerage services, provision of postal or telecommunication services.

Inert Waste Waste which will not biodegrade or decompose. Types of materials include uncontaminated topsoil; sub-soil; clay; sand; brickwork; stone; silica and glass.

L

Local Nature Reserve (LNR) Places with wildlife or geological features that are of special interest locally

Landfill gas A by-product from the digestion by anaerobic bacteria (rotting) or putrescible matter present in waste de-posited on landfilled sites. The gas is predominantly methane together with carbon dioxide and trace con-centrations of a range of other vapours and gases.

Landfill The deposition of waste onto hollow or void space in the land, usually below the level of the surrounding land or original ground level in such a way that pollution or harm to the environment is prevented. Former mineral workings have historically been used for this purpose.

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M

Metropolitan Green Belt (MGB) Metropolitan Green Belt A statutory green belt around London. It includes designated parts of Greater London and the surrounding counties of Bedfordshire, Berkshire, Buckinghamshire, Essex, Hertfordshire, Kent and Surrey in the South East and East of Kent regions.

P

Permitted Reserves Saleable minerals in the ground with planning permission for winning and working. Usually expressed in million tonners.

Planning Policy Statements Planning Policy Statements are prepared by the government after public consultation to explain statutory provisions and provide guidance to local authorities and others on planning policy and the operation of the planning system.

Materials Recovery Facility (MRF) A building where waste can be taken in bulk for separation, recycling or recovery of waste material. This is usually municipal waste, but some sites take commercial and industrial waste. Some may also take con-struction and demolition waste to be crushed and screened.

Municipal Solid Waste (MSW) 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 household waste, some commercial waste and waste taken to civic amenity waste collection/disposal sites by the general public. In addition, it may include road and pavement sweep-ings, gully emptying wastes, and some construction and demolition waste arising from local authority ac-tivities. It is typically made up of card, paper, plastic, glass, kitchen and garden waste.

R

Ramsar Sites Sites of international importance to birds which inhabit wetlands. Ramsar is the name of the place where the Wetlands Convention was signed.

Reclamation of Mineral Workings The combined processes of restoration and aftercare following completion of mineral working.

Reserve The remaining concentration or occurrence of workable material of intrinsic economic interest. Generally used for those economic mineral deposits that have the benefit of planning permission.

Resource A concentration or occurrence of material of intrinsic economic interest in or on the Earth's crust in such a form, quality and quantity that they are reasonable prospects for eventual economic extraction.

Recovery The collection, reclamation and separation of materials from the waste stream.

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Restoration Operations designed to return an area to an acceptable environmental state, whether for the resumption of the former land use or for a new use following mineral working. Involves the reinstatement of land by con-touring, the spreading of soils or soil making materials etc .

S

Safeguarding Protecting sites that have potential for relevant development (waste and minerals) from other develop-ment .

Sharp Sand and Gravel Naturally occurring mineral deposit in Kent. Once extracted it is mainly used in the production of concrete products.

Silica Sand (Industrial Sand) Material extracted and used in industrial processes including glass manufacture and the production of foundry castings. It is also used in horticulture and for sports surfaces including horse ménages and golf course bunker sand. It is also known as ‘Industrial Sand’.

Site (Specific) Allocations Sites which are generally well defined and where there is an implied presumption in favour of their being developed during the planned period.

Sites of Special Scientific Interest (SSSIs)

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. valu-able flora, fauna or geological strata. English Nature needs to be notified of planning proposals in or adja-cent to the designated areas. National Nature Reserves (NNRs), terrestrial RAMSAR sites, Special Protec-tion Areas (SPAs) and Special Areas of Conservation (SACs) are also SSSIs under national legislation.

Strategic Environmental Assessment An evaluation process for assessing the environmental impacts of plans and programmes. This is a statu-tory requirement of the M&WDF system.

Submission A stage of the Development Plan Document preparation process where the document is 'submitted' to the Secretary of State for independent examination by a planning inspector. The document is published for public consultation prior to submission.

Sustainability Appraisal (SA) An evaluation process for assessing the environmental, social, economic and other sustainability effects of plans and programmes. This is a statutory requirement.

Sustainability A widely quoted definition of sustainable development is “development that meets the needs of the present without compromising the ability of future generations to meet their own needs”. The definition also encom-passes the efficient use of natural resources.

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T

Transfer Stations Facilities which receive waste (normally from a local area), where the waste is bulked up and transported further afield in large lorries (or in some cities by barges) for disposal or recovery. Some transfer stations sort out the recoverable wastes, such as construction waste and scrap metal prior to onward transporta-tion for disposal or processing.

W

Waste The Town and Country Planning Act 1990 has been amended so there is no dispute over whether ‘waste’, in terms of the planning regime, is defined in accordance with European law. It states that: “waste” includes anything that is waste for the purposes of Directive 2006/12/EC of the European Parlia-ment and of the Council on waste, and that is not excluded from the scope of that Directive by Article 2 (1) of that Directive.”

Waste is therefore defined as any substance or object which the holder or the possessor either discards, intends or is required to discard.

Waste Planning Authority (WPA) 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 WPAs. National Parks are also WPAs. Unitary Authorities, such as Medway Council, deal with waste planning and all other planning issues within their areas.

Waste Management Permit Permit granted by the Environment Agency authorising treatment, keeping or disposal of any specified description of controlled waste in or on specified land by means of specified plant.

Wastewater This refers to urban wastewater, including domestic, industrial and surface run off. This raw waste water is processed through treatment plants to produce treated effluent and sewage sludge.

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