APPLN. NO.:      :02/0522/SCC                    Hithermoor Quarry, Leylands Lane, Stanwell
VALID DATE       :19/04/2002                     Moor, and Stanwell Quarry, Stanwell Moor
EXPIRY DATE      :09/08/2002                     Road, Stanwell.
CTTEE DATE       :14/08/2002 (AD)
                                                 At Hithermoor: Mineral extraction together
                                                 with mineral processing, including material
                                                 from windfall operations, recycling of
                                                 construction and demolition wastes together
                                                 with concrete and tarmacadam production
                                                 and restoration to nature conservation, public
                                                 access and agriculture.

                                                 At Stanwell: Restoration to agriculture garden
                                                 and parkland using material from the
                                                 recycling operation at Hithermoor Quarry.

                                                 As shown on drawing nos. 1/HS, 6/HS,
                                                 6/HS/1, HM/10, HM/10R, 7/HS/1-4, 8/HS, and
                                                 8/HS/1 for Bretts Aggregates Ltd.

WARD: Stanwell North

This application has been “called in” by the Secretary of State and is due to be considered at
a public inquiry in October. Surrey County Council is due to consider its position on the
current application in September. The Inquiry was also due to consider a second application
by Bretts for similar facilities at Hithermoor, but without the link to the Stanwell site and an
alternative proposal by RMC for the Stanwell site but both these applications have recently
been withdrawn.

1.    Borough Local Plan

(a)   Hithermoor Quarry

      -     Green Belt
      -     Area Liable to Flood
      -     Public Safety Zone (strip of land in north)
      -     Site of Nature Conservation Importance (River Colne along eastern boundary
            and pond in north west)
      -     Archaeological site (two area to south)

(b)   Stanwell Quarry

      -     Green Belt
      -     Site of Nature Conservation Importance (two areas in NW and SW part of site)
      -     Archaeological site (strip of land close to SE boundary)

2.     Relevant Planning History

(a)    Hithermoor Quarry

2.1.   Various permissions since 1953 for sand and gravel extraction and related plant. In
       1999 an application was submitted for determination of new planning conditions for the
       restoration of the site. This required extraction to be completed by the end of 2000
       and restoration by the end of 2002. Planning history since then is as follows:-

       PA/99/0514              Determination of new planning          Granted
                               conditions.                            08/03/2000

       PA/01/038               Variation of Condition 1 of            Granted
                               SP/99/0514 so that mineral             30/05/2001
                               extraction from the site ceases no
                               later than 31.12.02 (Restoration
                               date extended to 31.12.03)

       PA/01/0970              Importation of as-raised sand and    Granted
                               gravel amounting to 80,000 tonnes    20/02/2002
                               from Great Fosters Hotel for a
                               temporary period until 28/02/02 with
                               stockpiling and processing until

       PA/01/0987              Variation of Condition 10 of           Granted
                               SP/88/110 as amended by                24/01/2002
                               subsequent permissions to permit
                               the asphalt plant and ancillary
                               accommodation for a further
                               temporary period (expiring

2.2.   The effect of these permissions is to require extraction to be completed and plant to be
       removed by the end of this year and the site to be restored by the end of next year.

(b)    Stanwell Quarry

2.3.   Various permissions since 1964 for gravel extraction and processing. Recent
       applications are:-

       PA/99/681               Determination of new planning          Granted
                               conditions for mineral working,        13/12/2000
                               restoration and after care.

       PA/99/718               Operation of a recycling plant for     Withdrawn
                               the production of secondary            July 2002
                               aggregates and soils with the
                               ancillary storage of imported inert
                               construction and demolition waste
                               and recovered materials.

3.    Description of Current Proposal

3.1   This application involves extending the life of the existing mineral working at
      Hithermoor, relocating all processing activity to a new compound close to the M25,
      where a recycling facility is also proposed, and improving the restoration scheme for
      the site with provision for public access.

3.2   The application also involves the RMC-owned site at Stanwell (formerly Stanwell
      Place) which is proposed to be restored in a way that replicates the recently withdrawn
      scheme currently proposed by RMC (PA/99/718 – see above) but with all processing
      taking place at Hithermoor, including using waste material from the recycling facility at
      Hithermoor for restoration work.

3.3   The Hithermoor site is located south east of M25 Junction 14. It lies to the west of
      Stanwell Moor village and north of Staines Moor. The site has a total area of 73

3.4   It is a longstanding mineral working site most of which has been extracted and
      restored. The applicants state that 3.4 ha remain to be extracted (located under
      existing processing plant and the access road) with an estimated reserve of 300,000
      tonnes, and 5.5 ha remain to be filled.

3.5   It is proposed that all the processing plant be sited in a new compound to be
      established on the western side of the site close to the M25. The compound would
      have an area of 6 ha and would contain the following plant:-

          Sand and gravel processing plant. Existing plant stationed elsewhere on the site
           would be relocated. This consists of a mobile plant in two trailer mounted
           sections. The majority of the plant is below 4 metres in height with the feed
           conveyor to the plant reaching a height of 5.7 metres. The plant would process
           the remaining minerals extracted from Hithermoor and from Stanwell Place and in
           addition the application proposes that the plant would process sand and gravel
           imported from “windfall” sites elsewhere. This would represent an extension of
           the permission previously granted to process 80,000 tonnes of imported material
           from a single outside site (01/0970 see planning history). The current application
           envisages an annual output of around 100,000 tonnes per annum over a 10 year
           period, which includes sand and gravel reclaimed from the recycling process.
           Just over half the processed material would be utilised by the ready mixed
           concrete plant and the coated roadstone plant and the remainder sold off site.

          Ready Mixed Concrete Plant. The existing plant, which produces concrete using
           aggregate from processed sand and gravel production, would be replaced by two
           new plants. These would be to a more modern design, each in the main 7 metres
           high reaching a maximum height of 9 metres. The new plant would be designed
           to enable a proportion of recycled concrete aggregate (to be produced from the
           proposed recycling facility) to be substituted for primary aggregate. The two
           plants will produce concrete with differing proportions of recycled material to meet
           differing market requirements.

          The Coated Roadstone Plant. This plant will be relocated and upgraded with
           additional enclosures and improved noise abatement facilities. The upgrade will
           enable it to use a proportion of secondary aggregates in the production process.

           The plant will have a height of 11 metres with a chimney rising to 15m. It is
           envisaged that approximately 60% of the material used in the production process
           could be obtained from processed sand and recycled material from the adjoining
           production sites.

          The Recycling Operation. This is a new facility that would process waste material
           including concrete, brick and concrete, road planings and mixed hard waste
           containing soils and clay to produce secondary aggregate, soils, limited quantities
           of London Clay, sand and gravel suitable for processing and residual material that
           can be used as landfill for site restoration. The recycling operation is anticipated
           to produce annually around 85,000 tonnes of secondary aggregates, of which
           70% would be utilised by the concrete and roadstone plant, 70,000 tonnes of
           sand and gravel for processing, and sufficient residual material for the restoration
           of the site.

3.6   The processing area would be accessed by a realigned access road from Leylands
      Lane. It would be screened from Stanwell Moor village by a soil screen with a height
      of between 3 and 5 metres. An acoustic panel fence would be constructed along the
      western boundary. The application shows a corridor of land reserved alongside the
      M25 for the possible future construction of Airtrack and Central Railways.

3.7   Under the application, the site at Hithermoor would first be worked and restored (apart
      from the site of the relocated processing plant) over a four year period. The Stanwell
      site would then be worked and restored over a six year period using the Hithermoor
      mineral processing and recycling plant to process mineral extracted and supply
      material for restoration so that no processing or recycling facilities are sited at
      Stanwell. All the processing plant would then be removed from the Hithermoor site at
      year 11 and restoration completed.

3.8   The approved scheme of restoration for the Hithermoor site, involves restoring most of
      the site to agriculture with some woodland planting and no provision for public access.
      The current application proposes enhancements to provide for:-

          A greater area of woodland and scrub focussed on the western part of the site
           closest to the motorway.
          Improved provision for nature conservation including creation of a wet grassland
           area adjoining Staines Moor, and wet meadow areas.
          A network of permissive footpaths linking to adjoining rights of way to provide
           public access to the site.

      The enhanced restoration is proposed to be completed in a phased manner over an
      eleven year period.

3.9   At Stanwell the restoration proposals replicate the enhanced scheme of restoration
      proposed by RMC in their withdrawn application for a recycling facility. These involve
      restoring part of the site to parkland with provision for nature conservation and public
      access and foregoing the right to extract minerals from some sensitive areas.

3.10 The application is supported by an Environmental Impact Assessment. This includes
     sections covering:-

          Noise
          Geology
          Archaeology
          Ecology
          Highways
          Hydrology

      The application is also supported by an assessment of the Best Practical
      Environmental Option which is recommended for applications involving waste. This
      concludes that the preferred option is to carry out “high level” recycling at Hithermoor
      using residuals to restore both Hithermoor and Stanwell (ie the current application).
      The withdrawn Hithermoor only proposal with recycling at Stanwell under the separate
      RMC application is also considered viable. The option of no recycling at Hithermoor
      and of a basic operation at Hithermoor in competition with the RMC proposal at
      Stanwell are both rejected as not viable.

4.    Consultations

4.1   Head of Environmental Health – No objection on noise grounds subject to the
      implementation of mitigation measures proposed by the applicant. On Air Quality
      issues the Council has power to control emissions from the proposed plant under the
      Pollution Prevention and Control Regulations. In view of Spelthorne’s status as an Air
      Quality Management Area the Head of Environmental Health recommends that the
      applicant produce an Air Quality Strategy for the control/reduction of nitrogen oxides
      from the plant and associated vehicle movements. It is also recommended that a
      strategy to guard against contamination of soil and groundwater and a condition to
      prevent on-site burning.

4.2   Surrey Wildlife Trust – (copy of reply to Surrey County Council) Request additional
      information on a number of aspects of the proposals for Hithermoor and Stanwell in
      order to evaluate the nature conservation implications.

5.    Third Party Representations

5.1   Fifty-four letters have been received, including one on behalf of the Stanwell Moor
      Residents Association and one on behalf of the Association for the Preservation of
      Staines Moor. These raise the following issues:-

      -   Contrary to Green Belt policy
      -   Site should be restored now and no extension of activities should be allowed
      -   Impact of pollution, dust and consequential health impacts
      -   Noise disturbance
      -   Impact on flooding
      -   Traffic impact – including lack of restrictions on vehicles entering village
      -   Past record suggests applicants cannot be trusted to adhere to proposed
          restoration timetable
      -   Processing plant should be located on industrial land – Terminal 5 construction site
      -   Little benefit to community from revised restoration proposals
      -   Public access not offered for 10 years
      -   No account of material from proposed windfall sites in assessing impact
      -   Accuracy of noise and visual impact assessment questioned

      -    Potential impacts on Staines Moor due to resultant flooding and pollution
      -    No need if RMC proposal at Stanwell allowed
      -    Adverse impact on residents of reopening of Stanwell site for mineral working
           under combined scheme

6.    Issues

      -     Green Belt Policy
      -     Benefits and impact of the processing plant and recycling facility
      -     Quality of the restoration proposals and their relationship to the proposed plant
      -     Impact on flooding
      -     Relationship to the RMC site at Stanwell Place

7.    Planning Considerations

      Green Belt

7.1   The Hithermoor site lies in the Green Belt. Although the existing concrete and coated
      roadstone plant are substantial structures the site as a whole is generally open in
      character and makes an important contribution to the Green Belt in the north western
      part of the Borough.

7.2   Government guidance states that minerals can only be worked where they are found
      and that minerals extraction need not be inappropriate development in the Green Belt.
      However the processing and recycling facilities proposed are not forms of development
      regarded as appropriate in the Green Belt and policy is therefore that permission
      should be refused unless very special circumstances exist.

7.3   The applicants maintain that the proposals are either not inappropriate or justifiable on
      grounds of very special circumstances. They argue that:-

      1.    Mineral working and infilling of former mineral workings is acceptable.

      2.    The waste-related development complies with Waste Local Plan policy in that the
            facilities are for a temporary period not exceeding the life of the restoration of the
            mineral working, they produce materials for infilling and restoring the site, they do
            not delay restoration and maintain high environmental standards, and they
            produce material of a high specification for beneficial use.

      3.    There is a need for inert waste recycling facilities and a lack of alternative suitable

      4.    The proposal accords with the Government’s Waste Strategy which encourages
            the development of improved quality and standards for recycled materials.

      These arguments are examined in the following sections.

      Acceptability of Mineral Working and Infilling

7.4   No objection can be raised to the principle of completing mineral working and infilling
      on an approved working site. However, it should be recalled that this is a site where
      revised planning conditions have established a timetable for the completion of working
      and restoration. The original timetable set in 1999 required working to cease by the

      end of 2001 and restoration to be completed by the end of 2003. Subsequently, the
      date to complete working was extended to the end of 2002. Despite this timetable no
      progress has been made in completing extraction and restoration since 1999, and, as
      a result, it now seems that the approved timetable for completion of working cannot
      realistically be met.

7.5   Clearly it is undesirable to sterilise reserves but the weight to be attached to this
      concern has to be affected where no attempt appears to have been made by the
      applicant to complete extraction under the agreed timetable.

      Benefits and Impact of the Processing Plant and Recycling Facilities

7.6   The recycling of construction waste material to produce secondary aggregate does
      offer sustainability benefits in that it creates an alternative to primary aggregate
      thereby relieving pressure on new workings. There are also benefits in locating
      recycling facilities at landfill sites in that the recycling process creates a waste residue
      that can be disposed of on site rather than having to be transported off site. Most
      landfill sites in this area are likely to be in the Green Belt.

7.7   The adjacent siting of the concrete and coated roadstone production plants also offers
      sustainability benefits in that they can utilise material from the sand and gravel
      processing and the recycling facility.

7.8   There are, however, potential harmful consequences:-

      1.   A significant new commercial site would be created in the Green Belt with a
           number of substantial structures and associated stockpiling of material. There
           would be an increase in activity and the openness of the Green Belt would be
           reduced as a result. In part the impact would be due to additional facilities (the
           extra concrete plant and the recycling operation) and in part due to prolonging the
           presence of existing facilities that are required to be removed by condition (sand
           and gravel processing, the concrete plant and the coated roadstone plant).

      2.   There would be a visual impact from the new processing site. Whilst the location
           towards the western end of the site and the proposed bunding would mitigate the
           impact from Stanwell Moor village to the east there are potential views from the
           M25 and Junction 14 and from the Moor Lane bridleway to the west. There is a
           gain from the removal of the existing concrete and coated roadstone plant which
           have a significant visual impact but that is in any event required by condition.

      3.   There are additional traffic movements associated with the applications. The
           applicant’s traffic assessment suggests that the site at present generates 400
           vehicle movements per day. This is forecast to rise to 559 movements per day.
           The applicants argue that this will result in an increase of less than 3% in traffic
           flows on Junction 14 and less than 1% on traffic flows on the M25 and Airport
           Way. They argue that some of the traffic will be diverted from other facilities and
           will not therefore be additional movements on the network. This assessment
           needs to be reviewed. Pending a response from the County Highway Authority a
           “holding” objection is recommended.

      4.   The proposed production compound is in an area identified as liable to flood. The
           applicant’s assessment suggests that the compound lies outside the flood plain
           and that the impact on the water environment would be acceptable. Pending a
           response from the Environment Agency a holding objection on flooding grounds is

      5.   There are potential noise and air quality impacts and concerns have been raised
           by local residents on these aspects. However, the advice from Environmental
           Health is that the noise impact is acceptable subject to the mitigation measure
           proposed and that pollution control legislation can control air quality impact. It
           should be noted that the proposed compound is further from residential properties
           than the existing concrete and roadstone plants.

      Alternative Sites

7.9   The applicant has carried out an assessment of alternative sites and has identified
      existing facilities within a 10km radius. The assessment shows that a number of
      existing sites are either unauthorised or subject to conditions requiring the use to
      cease. The applicant also points out that no sites are allocated in the Surrey Waste

7.10 Lack of alternatives is a consideration where need is demonstrated but it is not
     considered sufficient to justify the establishment of extensive new facilities at a mineral
     site within the Green Belt that is close to the end of its natural life.

      The Restoration Proposals

7.11 In considering the revised restoration proposals regard must be had both to the quality
     and speed of restoration.

7.12 In terms of quality the proposed scheme for the Hithermoor site does offer benefits
     over the existing scheme. While the approved scheme provides for an acceptable
     restoration package placing the emphasis on agriculture with some woodland planting,
     the proposed scheme offers nature conservation benefits and amenity benefits from
     the additional woodland and some extra screening from the M25. It also offers public
     access albeit permissive. These improvements are legitimate considerations in
     assessing the proposals.

7.13 In terms of speed, the restoration at Hithermoor is proposed to be completed within
     four years, apart from the processing site which remains for 11 years. The plans
     suggest that public access would not be available until after the plant has been

7.14 This should be compared with the existing approved scheme which originally proposed
     to complete restoration by the end of this year and has since been extended by one
     year to 2003. The applicant claims that the current proposals will not delay the
     completion of restoration, arguing that the recycling facility will generate a guaranteed
     supply of restoration material. But it must be concluded that the timescale for
     completing restoration is extended significantly, unless the requirements of the
     approved scheme are to be ignored.

7.15 It should also be noted that the new processing compound is proposed to be sited on
     an area that has already been worked and restored and is currently in agricultural use.
     The proposal would undo an acceptable scheme of restoration previously completed.

7.16 The applicants argue that their restoration proposals will facilitate the improved
     management of Staines Moor SSSI. The ecological assessment states that
     management of the southern part of the site should complement and even enhance
     the status of the grasslands at Staines Moor. This would include development of a
     strategy to create favourable conditions at Staines Moor. It should be noted that
     Staines Moor, which is owned by the applicants, does not form part of the application
     site and the application contains no proposals for specific additional safeguards to
     protect the Moor or for its improvement. Subject to the views of nature conservation
     organisations it is difficult to see that there are benefits for Staines Moor that can carry
     weight in assessing the proposals as a whole.

7.17 The application also offers the prospect of completion of extraction and restoration of
     Stanwell Place without any processing on site. The restoration scheme, previously
     considered in the context of the RMC application, offers significant enhancements in
     terms of creating an area of parkland with public access and areas of nature
     conservation value that are retained or created. The right is foregone to extract from
     some sensitive areas. The majority of the site, however, is still restored to agriculture.
     The restoration proposals for Stanwell Place also need to be seen in the context of a
     requirement to review the previous restoration proposals which were solely for

7.18 Whilst there are benefits to the Stanwell Place site in achieving restoration without the
     impact of processing, these are achieved at the expense of extending the life of
     another minerals site in the Green Belt which is already subject to an agreed
     programme of restoration.

7.19 Some of the problems with the RMC proposal for Stanwell could have been resolved
     by relocating the recycling facility within the site so that it did not impact on the site of
     Nature Conservation Importance at Stanwell Place.

7.20 In contrast, if the principle is established of using the processing plant at Hithermoor to
     handle material from another working, the prospect must be considered of similar such
     proposals in the future prolonging the operation of the plant even further beyond the
     period required to complete the restoration of Hithermoor. Indeed the applications
     envisages that the processing facility at Hithermoor could process material from
     “windfall” sites, although the amount of such material is not quantified. In Green Belt
     terms the justification for the processing plant at Hithermoor is reduced if neither the
     imput to the facility nor the output from the facility comes from the Hithermoor mineral
     working site.

      Overall Conclusion

7.21 In conclusion it is recognised that the application offers benefits in improving provision
     for recycling of waste and offer sustainability benefits in siting related processing
     facilities in adjacent locations. However, it is not considered that a mineral working site
     in the Green Belt that is close to the end of its natural life is an appropriate location for
     the introduction of new and enhanced recycling and production facilities, particularly
     when as in this case where there is a recently established timetable for completing

        restoration in the near future over a short timescale. There are enhancements to the
        quality of the final restoration but it is not considered that the scale of benefit the
        applicant proposes justifies the extent of development in the Green Belt nor the delay
        in final restoration of the Hithermoor site.

7.22    At the time of finalising this report a number of Surrey County Council consultations
        were outstanding including these from County Highways and the Environment
        Agency. Holding objections are proposed on traffic and flooding grounds which
        would not be pursued if consultee replies show that the proposals are acceptable in
        these respects.

8.     Recommendation

       That Surrey County Council be advised that this Council:-

       A:   OBJECTS to the proposals at Hithermoor and Stanwell (02/0522/SCC) on the
            following grounds:-

       1)   The development is contrary to Green Belt policy and the proposal as a whole
            demonstrates insufficient justification to overcome the presumption against
            inappropriate development in the Green Belt.

       2)   The proposed plant would have a detrimental impact on the visual amenities of
            the area.

       3)   On the basis of the information currently available the Council is not convinced
            that the proposal is acceptable in terms of traffic impact or impact on flooding and
            the water environment.


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