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SSAGE/LOSRA
Suggested
response to the
SURREY COUNTY COUNCIL MINERALS SITE RESTORATION PLAN
CONSULTATION DOCUMENT Part B – Consultation questions – Minerals Site Restoration SPD Our comments are specific to:
Preferred Area L Watersplash Farm
Comments are as follows:
1. The proposals miss the opportunity to take a bold approach
which addresses the needs of residents and develops the potential of the site. 2. The land is currently Grade 1 & 2
agricultural land used for market gardening. The primary restoration theme proposes to take the land back to agriculture. 3. After
infill with inert material, it will not be practical to return the site to Grade 1 agricultural land. Experience with Hazelwood
Golf Course demonstrates that it is difficult to create good quality soil to sustain the current level of intensive market
gardening. It is likely that it will only sustain uses associated with below Grade 2 land, which are less economically sustainable. 4. The working
of the site will require agriculture to be abandoned for the duration of mining. It is unlikely that after several years of
gravel extraction, regardless of the quality of the land, the economic circumstances would exist for a return to the current
activity. 5. If agriculture at a sustainable level proves to be impractical, the land may not find a suitable tenant and
fall into disrepair or neglect, leaving it open to opportunist targeting by housing developers keen to open up Green Belt
land. This does not represent a responsible strategy and residents will not accept a restoration proposal which has implicit
uncertainty attached to it. 6. The proposal envisages breaking up the site by the creation of a nature reserve corridor following
the line of the River Ash. This is fine, but once again is indicative of a half-baked approach, further compromising the potential
for agricultural use. Fragmenting the site into two separate smaller areas makes it more difficult and less economic to work. 7. It is
rightly recognised that the integrity of the River Ash and its surrounds as an SNCI justifies this area of land being protected
during working, and also maintained as a public access nature conservation corridor. 8. We support the proposals of
linking the public footpath with the Millennium Park to the north and establishing woodland and/or reedbeds in the south-eastern
corner in the silt lagoon area. 9. These proposals suggest a solution which would guarantee the future of the land and secure its
benefit for the wider population in a manner which the current proposal does not. The entire area could
be given over to the creation of a nature reserve with public access, combining a variety of habitats. 10. We would propose a design
for the site which would encompass different types of landscape and habitat including grassland, semi-wooded parkland and
a modest area of open water, in order to encourage a wide variety of flora and fauna. This would require the involvement of
professional and qualified environmental experts and wildlife trusts and local residents’ groups. 11. This would establish a secure
and predictable future for the site, rather than leaving it open to vagaries of the agricultural economy and potential unwelcome
predatory attack by developers. |
Part C – Consultation questions – Aggregates Recycling
DPD C.1
1. The presumption
against aggregates recycling on sites in the countryside and, more particularly Green Belt should be upheld. Nonetheless,
recognising this is not necessarily practical in order to meeting the objectives of the Plan we support the use of sequential
testing to identify suitable sites. However, this must be done in an open and transparent way to challenge
the merits, or otherwise, of any site selected for aggregates recycling.
2. Green Belt sites should only be given temporary planning permission for aggregates recycling.
3. The majority of concreting aggregates is found in North West Surrey’s Green Belt area.
It is incumbent upon SCC to minimise the adverse impact of aggregate recycling on residential areas.
4. Only those sites which have the infrastructure to support recycling facilities should be
considered. SCC must consider the cumulative adverse impact of aggregate extraction, on-site aggregate
recycling and dedicated long term recycling facilities (listed in para 3.26).
5.To allow the three activities, referred to in 4 above, to take place at Charlton Lane and Watersplash
Farm would in our view put unacceptable pressures on the local infrastructure and generate adverse environmental impacts on
the densely populated areas of Shepperton, Halliford and Sunbury.
6.
Charlton Lane is an established waste management facility
and we believe has the infrastructure in place to handle additional recycling. It is located away from
residential housing and has land around the facility for possible expansion.
7. Watersplash Farm should not be used for recycling aggregates if the same activity is to take place at Charlton
Lane. Our preference is for the existing facilitates at Charlton Lane to be expanded for aggregate recycling
in preference to Watersplash Farm. In our opinion, Charlton Lane being only 0.7 miles from Watersplah Farm
is close enough to make recycled inert waste commercially viable for infilling at Watersplash Farm. |
C.4
In principle,
we support that proposal that temporary aggregate recycling facilities should be located on sites to be restored to their
existing levels. However, in the case of Watersplash Farm the dual activities of aggregate extraction and
recycling will have major adverse environmental and transport impacts. This will be further exacerbated
if Charlton Lane is selected as a recycling facility. |
C.5
1. Watersplash Farm is located close to densely populated residential areas.
A high concentration of gravel extraction and recycling at Watersplash Farm and Charlton Lane, if selected as a primary
aggregate recycling centre, will create unacceptable environmental impacts on the residential areas in terms of traffic, noise
and air pollution.
2. Surrey County Council acknowledges that
recycling facilities are very likely to attract a greater volume of C, D and E waste. Introducing a waste
management facility at Watersplash Farm will significantly increase traffic movements. The Council’s
own transport studies already show the local highways are either at or exceed their capacity.
3. Air quality around Watersplash Farm is low and NO2 levels exceed EU statutory levels. Aggregates
recycling will only reduce air quality further.
4. We agree with Policy AR2 that only temporary planning permission should be granted for recycling.
5. Watersplash Farm is 0.7 miles from Charlton Lane. In
our opinion, the commercial viability of two aggregates facilities is questionable when both will be competing for a finite
level of material to recycle.
Watersplash Farm should only be
considered as a site for aggregate recycling if:
a. Charlton Lane
is not selected as a recycling facility.
b. Screening, washing and crushing
is carried out in buildings (3.15) to minimise noise, dust and odour on nearby residential homes.
Watersplash
Farm is located in a semi-urban area. A building to house recycling activities would not have a major visual
impact on the local amenity.
6.
SCC state that they will undertake further detailed assessment. This should be carried out prior
to putting forward sites for aggregate extraction and aggregates recycling. The CC should carry out a Transport
Assessment prior to putting forward sites in the Plan to establish if the local infrastructure is capable of handling the
considerable increase in traffic which the Council acknowledges will result. |
C.6
We support
Policy AR3. Waste operators should be encouraged to recover the maximum amount of material for re-use. |
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