28 February 2018
“The Green Party is not opposed to the extraction of minerals, however we believe the value of such minerals should accrue to the communities most affected rather than to private interests (see Green Party Policy statements below).
Tonbridge & Malling Green Party understands the need for building materials in Kent and we would rather see these sourced locally than transported from other parts of the country.
However, there are a number of aspects to the proposals for soft sand extraction at Ryarsh and the other identified site, at Lenham, which are unsatisfactory and mean that we cannot support either site going forward for inclusion in the Kent Minerals & Waste Local Plan (KMWLP).
1) Although the current KMWLP refers to a “need” for 5m tonnes of soft sand, KCC has referred to “more recent calculations” giving a need of just under 2m tonnes. There is clearly a big difference between these two figures.
We want the need established definitively before any site is selected for inclusion and to understand whether this need is for Kent alone or also to meet demand from outside the county?
2) There is concern in Ryarsh and surrounding communities about the potential impact on health of mineral working at this site, particularly in relation to the extraction of silica sand.
We believe genuinely independent advice should be sought on the potential health hazards of soft sand and silica sand extraction. We should also like to know what measures the operator proposes and/or KCC will insist on to ensure any adverse health impacts are eliminated?
3) The current designation of the site is “agriculture land” and the proposed restoration after 24 years is to “agriculture land”. We would like confirmation of the planning status of the land following restoration.
Our understanding is that mineral extraction is a “temporary land use” and the land does not become “brownfield” simply because it has been worked.
We seek confirmation of this and that any subsequent development proposal would be treated as if the sandpit had never existed.
4) The proposal from the operator is that site traffic enters and leaves via the A20 and Roughetts Road. We believe it will be difficult for large lorries to enter and exit Roughetts Road safely, particularly where they have to cross a carriageway. We would like to know what mitigation measures the operator proposes to ensure traffic can move safely and whether other access routes have been considered.
5) Additional HGV movements will worsen air quality, not just in the locality but across the wider area, including the A25 through Borough Green and the A20 through Larkfield - both of which have AQMAs.
Tonbridge and Malling Borough Council’s Green Belt Study (2016) says:
“The Green Belt at Ryarsh surrounds all sides of the settlement. The area is characterised by fields and some more densely wooded areas, located to the north-west and south-east. There is evidence of past industrial and employment uses, with a former quarry and Ryarsh brickworks (which is being developed for residential purposes).
Agricultural land in the area is graded Good to Moderate (Agricultural Land Classification map London and the South East (ALC007) - Natural England).
The surrounding countryside forms part of the AONB and is overwhelmingly rural in nature, with generally open fields.”
We are concerned about the accumulated impact of development here and elsewhere in this part of the borough which will change the character of the area from rural to urban/industrial as well as increasing traffic congestion.
In summary, we are opposed to this proposal until the need for extraction on this scale, at this and other sites has been demonstrated through genuinely independent assessment.
If this site is included in the KMWLP we support any and all efforts to mitigate the impact of extraction and insist that the health of local people should be the overriding priority.
The options being proposed for the Kent County Council Kent Minerals &Waste LOcal PLan are the subject of a public consultation, open until 29th March. Make your views known here: http://consult.kent.gov.uk/portal/second_call_for_sites_2016/mineral_sites_plan_-_options_consultation
Green Party Policies
We have national policies on Natural Resources which state, amongst other things, that:
Minimal damage should be caused to the natural environment, including the reduction of genetic and ecological diversity, by extracting … natural resources for industrial use. (NR303)
All mineral rights should be held in trust by the State on behalf of the communities which occupy the land. (NR421)
Planning consent to exploit minerals will be subject to both local and national agreement. It will be a requirement of such consent that the environmental impact of any work is minimised and for extraction activities to maximise the resources obtained. The affected land should be returned to a similar or improved ecological status. (NR421)
Research into the recycling of secondary raw materials should be intensified. (NR313)