Summary Comments Regarding Proposed Main Modifications€¦ · Business Park, including the ‘Key Development Issues’ identified for the site. Summary Comments Regarding Proposed

SURREY WASTE LOCAL PLAN 2019-2033

WT LAMB HOLDINGS LTD

PARTICIPANT ID: 158

FEBRUARY 2020

Introduction 1. This response to the Surrey Waste Local Plan Proposed Main Modifications (hereafter SWLP) is

submitted on behalf of WT Lamb Holdings Ltd (hereafter WTL). WTL own land at Lambs Business Park, South Godstone, including a former quarry area on a freehold basis.

2. The site is identified for inclusion as a ‘strategic waste allocation’ in the emerging SWLP1. It is also identified as an allocation in the Submission Tandridge District Council Local Plan (hereafter TDCLP), wherein it is acknowledged that the exceptional circumstances exist to remove the site from the Metropolitan Green Belt2. Whilst the site’s allocation in the TDCLP primarily relates to employment development, there is recognition that in line with the emerging SWLP that the western extent of the site is suitable for waste management purposes in the manner set out in the emerging SWLP. Both allocations reflect the landowner’s development aspirations for the site as set out in the accompanying Development Framework Document.

3. Given the site’s allocated status in the emerging SWLP it follows that WTL are generally supportive of it. This representation provides clarity on the specific policies within the emerging SWLP that WTL are supportive of.

4. However, without prejudice to their general support for the emerging SWLP, there are a number of matters which are of a concern to WTL. These concerns relate to matters raised through previous consultations versions of the SWLP and at the Examination in Public, as well as concerns with some of the Proposed Main Modifications outlined in this consultation.

5. These representations, which form our Client’s complete response to the SWLP Proposed Main Modifications comprise:

• A summary of our representations to the Proposed Main Modifications; • Site Description; • Development Proposals at Lambs Business Park; • Relevant legislative framework, national planning and guidance. • Concerns relating to some of the strategic policies outlined in the Part 1 SWLP; and • Specific responses to the Proposed Main Modifications in respect of the allocation at Lambs

Business Park, including the ‘Key Development Issues’ identified for the site.

Summary Comments Regarding Proposed Main Modifications

6. In summary, our representations are follows:

• WTL are generally supportive of the SWLP Proposed Main Modifications, including the allocation of land at Lambs Business Park for waste management purposes. The allocation

1 Policy 11a. 2 Policy SES003.

UID 16



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corresponds to the landowner’s development aspirations for the site.

• WTL are supportive of the SWLP’s spatial strategy and locational hierarchy. Both have been used by the WPA to assess the pool of sites and areas available to meet needs in the most sustainable manner. The Policy 11a sites were deemed through this robust technical process to be the most suitable and sustainable. In accordance with the need for a clear and unambiguous policy framework and to accord with principles of the plan-led system, the Policy 11a sites should be afforded a primary role in meeting needs over the plan-period. At present, Policies 2 and 10 do not provide that clarity and afford a similar status to all potential sites, including the ILAS and previously unidentified sites. To overcome this issue a cascade approach is required which focuses on the Policy 11a allocations in the first instance. Our suggested amendments to both policies are set out in Appendix 1 and 2 of this representation.

• WTL are supportive of the increase in the capacity of a new waste management facility at Lambs Business Park to ‘medium to large’ as set out in Main Modification 38.

• It is agreed that the development proposals at Lambs Business Park would need to contribute to improvements to the A22 Eastbourne Road/Tilburstow Hill Road Junction as set out in Main Modification 39. Work by WTL has identified two improvement options that could be delivered in highways land.

• The use of the railway to transport material into and out of Lambs Business Park is a shared ambition between WTL and the WPA. However, there is no evidence before the Examination in Public to justify a capacity limit being placed on a new waste management facility if it used a highways only transportation solution. Conversely, the evidence before the Examination in Public would indicate that with mitigation, the highways network could support a large-scale facility at the site that used a highways only transportations strategy. According WTL do not support this element of Main Modification 39.

• WTL are supportive of the introduction of general amenity into the key development issues for Lambs Business Park as proposed by Main Modification 39.

7. Our detailed comments in respect of the individual Proposed Main Modifications are set out below.

Site Description and the Proposed Development at Lambs Business Park

8. As indicated above, these representations are submitted on behalf of WTL who own Lambs Business Park on a freehold basis. The site is identified as a strategic waste allocation in the emerging SWLP3. For context, the following section provides a description of the site and confirms our Client’s development aspirations for it.

Site Description 9. WTL’s entire land holding4, comprises a parcel of land located approximately 1km to the west of

3 Under Policy 11a of the SWLP. 4 A site location plan is provided at Figure 2 of the accompanying Development Framework Document.



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South Godstone. It measures 13.4ha in size and is currently located within the Metropolitan Green Belt5. It is divided into two distinct parcels as follows:

• The eastern land parcel is identified as being a Strategic Employment Site within the TDC Adopted Core Strategy6. This portion of the site houses a number of existing buildings in commercial use, which are of varying ages and quality. The eastern part of the site measures approximately 5.4ha; and

• The western land parcel, which lies outside of the existing employment designation, was historically used as a quarry with permission for clay extraction, inert landfill and the importation of aggregates via the rail siding. According to the planning permission, WT Lamb have until 2047 to restore the quarry to its original condition. This part of the site measures some 8ha. A 300m railway siding located to the north of the quarry area is retained by WTL. In addition to this, the main railway track operated by Network Rail has a further siding of 300m in length which is connected to WTL’s privately-owned siding.

10. The site significantly slopes from the northwest towards the south and is bounded by:

• The Reading to Tonbridge Railway Line (including a Channel Tunnel Freight Line) to the north;

• Countryside, largely in agricultural use, to the south (although permission exists for the extraction of oil and gas – see permission 2015/0170);

• Maple Wood and countryside, which is largely used for agricultural purposes, to the west; and

• Field parcels and residential premises located on Terracotta Road (all the residential premises on Terracotta Road are within the ownership of WTL) and Ruston Avenue to the east (none of which are in the ownership of WTL).

11. The site is well screened by substantial boundary hedges to the west and south, which support a significant number of trees. The boundaries to the north and northwest are formed and screened by Maple Wood and the heavily wooded railway embankment. As indicated above, the remaining land in the surrounding environs is open countryside, largely within agricultural use. Agricultural field boundaries also therefore screen views into and out of the site.

12. An Area of Great Landscape Value is located to the north of the site, whilst a Site of Nature Conservation is located to the north and west (Maple Wood). Birchen Coppice to the south is a Potential Site of Nature Conservation Importance. Areas of high archaeological potential are located to the south west.

13. Further information about the site and its landscape context is provided in the accompanying Development Framework Document.

Proposed Uses

14. WTL are committed to both restoring the former quarry site and developing a new green technology park on the areas of the site that have already been previously used. Their development aspiration is

5 The entire site is proposed to be inset from the Metropolitan Green Belt under Policy SES003 of the Submission TDCLP. 6 Policy CSP22 refers.



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for the site to be substantially redeveloped for:

• a c.5,418 sq.m combined cycle energy centre (up to 49MWe), incorporating a renewable biofuel production plant;

• 2 no. 9,245sq.m data centres (over 2-3 storeys) with associated supplementary energy centre (decentralised CCGT);

• the use of the southern most part of the former pit areas as flood alleviation and a nature reserve;

• the intensification and redevelopment of underutilised areas of the Business Park (c.3.03ha) to provide higher-value and more productive employment space; and

• educational/learning opportunities to be explored.

15. A Development Framework Document is provided with this representation. It sets out WT Lamb’s redevelopment aspirations for Lambs Business Park in more detail.

Legislative Framework and National Planning Policy and Guidance Waste Framework Directive

16. Directive 2008/98/EC, which has been transposed into UK law, establishes the basic concepts and definitions relating to waste management. It also outlines basic waste management principles, including the requirement for waste to be managed without endangering human health and harming the environment.

17. The Directive also requires Authorities to:

• Apply the waste hierarchy when planning for and considering options for waste management, encouraging the reuse, recycling and recovery of waste (including energy from waste facilities), with disposal being the least favoured option; and

• Have regard to the ‘proximity principle’, which encourages communities to manage their own waste.

National Planning Policy Framework

18. The NPPF (2019) establishes the Government’s planning policies and provides guidance on how

these are expected to be applied. It must be taken into account when preparing a development plan7 and it should be read in conjunction with the Government’s National Planning Policy for Waste8.

19. It outlines that the planning system should be genuinely plan-led9 and that inter alia local plans should be prepared with the objective of contributing to the achievement of sustainable development; be aspirational, but deliverable; be shaped by effective engagement; contain policies that are clearly written and are unambiguous; be accessible through the use of digital tools; and serve

7 Para. 1 of the NPPF. 8 Para. 4 of the NPPF. 9 Para. 15 of the NPPF.



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a clear purpose.

20. Development Plans are required to include strategic policies that address an area’s priorities for development10. They should set out an overall strategy for the pattern, scale and quality of development, make sufficient provision for waste management infrastructure; conserve and enhance the natural, built and historic environment and include measures to address climate change11.

21. Local plans should positively seek opportunities to meet the needs of the area and be sufficiently flexible to adapt to rapid change12. Strategic policies should also, as a minimum, provide for the objectively assessed needs of the area, as well as any needs that cannot be met within neighbouring areas, unless:

• The application of policies within the NPPF that protect areas or assets of importance provide a strong reason for restricting the scale, type of distribution of development in the plan area; or

• Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits of meeting the needs, when assessed against the policies in the NPPF taken as a whole.

National Planning Policy for Waste 22. The National Planning Policy for Waste (hereafter NPPW) was published in October 2014. It outlines

that the planning system can play a pivotal role in delivering the Country’s waste planning ambitions, inter alia, through:

• Driving waste management further up the waste hierarchy; • Ensuring waste management is considered alongside other spatial planning matters; • Providing a framework in which communities and businesses are engaged to take

responsibility for their own waste, in line with the proximity principle; and • Securing the re-use, recovery or disposal of waste without endangering human health and

without harming the environment.

23. In particular, relevant to the preparation of the new SWLP, waste planning authorities are required to:

• Use a proportionate evidence base on which to establish waste planning policies; • Identify the need for new waste management facilities; • Identify the need for suitable sites and areas for waste management infrastructure; and • Monitor and report on the take-up of allocated sites and areas, the existing stock and

changes in the stock of waste management facilities and their capacity waste arisings and the quantities of waste recycled, recovered and disposed of.

24. The NPPW also establishes a set of criteria against which the suitability of sites for new or enhanced

waste management facilities should be assessed.

10 Para. 17 of the NPPF. 11 Para 20 of the NPPF. 12 Para. 11 of the NPPF.



PARTICIPANT ID: 158

FEBRUARY 2020

Strategic Policies – Implementation of the Spatial Strategy

25. As indicated above, whilst our Client is broadly supportive of the SWLP Proposed Main Modifications, they have a number of concerns with the strategic policies proposed in the Part 1 Plan. These concerns, which have been raised both though responses to previous consultations on the emerging SWLP and at the Examination in Public itself, principally relate to the implementation of the proposed spatial strategy. Despite highlighting these concerns to the Waste Planning Authority (hereafter WPA) over several years, it appears that alterations in the manner requested are not proposed to the emerging SWLP Proposed Main Modifications. Consequently, these remain legitimate concerns that are rightfully raised through this consultation response. Our detailed considerations are set out below.

The Spatial Strategy 26. The emerging SWLP’s seeks to accommodate the need for additional waste capacity by safeguarding

existing waste sites, proposing extensions and enhancements to existing waste facilities and allocating land for the development of new facilities in suitable locations13. It expresses a preference towards new waste management facilities being located on previously developed land, sites and areas identified for employment uses and redundant agricultural and forestry buildings and their curtilages.

27. The spatial strategy was informed by a number of ‘key building blocks’14. The building blocks cover a range of considerations, including providing sufficient new waste management capacity to meet needs; the need for different types and scale of waste management facilities; allowing for otherwise ‘inappropriate development’ in the Green Belt where Very Special Circumstances can be identified; recognising the dispersed nature of Surrey’s population by including a mix of locations; affording a priority to developments on previously developed land, but recognising that greenfield development could also be required; and favouring locations that are well connected in terms of the main transport network and the use of sustainable modes of transport, including rail.

Site Selection Process – The Need for Green Belt Sites 28. The spatial strategy was used by the WPA to inform a locational hierarchy15 which seeks to direct

new and improved waste management facilities to sites in the following preferential order:

1. Sites and areas outside the Green Belt, including allocated waste sites, existing waste sites, Industrial Land Areas of Search (hereafter ILAS) and other suitable sites;

2. Sites and areas within the Green Belt, including allocated sites, existing sites within the Green Belt and other suitable sites; followed by

3. Sites and areas which are likely to result in significant adverse impacts to ‘areas or assets of particular importance’.

13 Section 2.2 of the Waste Planning Authority’s ‘Report on Delivering the Spatial Strategy’ (April 2019). 14 Para. 4.1.1.1 of the SWLP Part 1. 15 Para. 4.1.1.4 of the SWLP Part 1.



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29. By recognising the importance that should be placed on meeting needs from previously developed

land, including existing employment sites, but by also acknowledging that greenfield sites, including Green Belt land, could be also be required to meet needs, the WPA’s spatial strategy and the locational hierarchy are consistent with national planning policy and guidance16. It follows that WTL do not object to either the spatial strategy, or the locational hierarchy.

30. Both the spatial strategy and the locational hierarchy were used by the WPA to provide a framework against which an assessment of all potential sites and areas could be undertaken to ensure that needs are met in the most sustainable manner.

31. As identified within the SWLP’s evidence base and in line with its locational hierarchy, the WPA firstly undertook a detailed assessment to establish the amount of additional waste management capacity that could be provided from the intensification of existing waste sites and from within industrial and other employment sites (referred to as ILAS). Neither source of supply, individually or together, could provide the amount of deliverable land required to meet needs17.

32. Specifically, in relation to the ILAS, the WPA’s evidence base concluded that “due to commercial and practical considerations and competition from other land uses, such land cannot be wholly relied on to deliver the required waste management capacity over the Plan period.18”

33. Such a conclusion is also supported by historic delivery rates of new waste management capacity. Evidence prepared by the WPA has demonstrated that a limited quantum of capacity from industrial estates and other industrial and employment land has been delivered between April 2008 and March 2017 (just 3%)19. Consequently, the WPA conclude that such land “may only be relied upon in the new SWLP to a limited extent20”.

34. Given the analysis presented above it was necessary for the WPA to assess other specific sites that weren’t either existing waste or employment sites were also assessed in line with the spatial strategy and the locational hierarchy21. The identified sites were subject of an initial ‘sieving’ exercise, wherein all the Council’s assessment considerations were first applied in parallel (Scenario 1), followed by a secondary exercise (Scenario 2) which did not consider each site’s land status. As outlined in the WPA’s evidence, it is only once the Green Belt policy constraint (Scenario 3) and the Green Belt and the land status sieves were both disapplied (Scenario 4), that an adequate portfolio of sites was identified that could be used to meet the County’s existing and future waste needs22. The 5 sites that were not excluded at the third sieving stage are those identified as allocations in the Policy 11a of the SWLP23.

35. The Policy 11a allocations have therefore been selected to ensure that there is a sufficient identifiable source of deliverable sites to meet identified needs24. Indeed, following this robust

16 Paras. 4 and 6 of the National Planning Policy for Waste and the National Planning Practice Guidance at paras. 018 Ref ID: 28-018-20141016 and 041 Ref ID: 28-041-20141016. 17 Paras. 3.1.4.1 and 3.2.4.2 of the WPA’s ‘Report on Delivering the Spatial Strategy’ (April 2019). 18 Para. 5.3.3.3 of the SWLP Part 1 Plan. 19 Table 1 of the SWLP’s ‘Delivery of Waste Management Capacity in Surrey 2008-2017.’ 20 Para. 4.2.2 of the SWLP’s ‘Delivery of Waste Management Capacity in Surrey 2008-2017.’ 21 SWLP’s ‘Site Identification and Evaluation Report’ (April 2019). 22 Paras. 4.2.2.2. and 4.2.3.2 of the ‘Site Identification and Evaluation Report’ (April 2019). 23 Para. 4.4.1.4 of the ‘Site Identification and Evaluation Report’ (April 2019). 24 Para. 4.3.2.1 of the Part 1 Waste Local Plan and para. 5.2.7 of the Statement of Common Ground between the Surrey District and Boroughs (June 2019).



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technical site selection assessment it is the Policy 11a allocated sites that the WPA considers as being the “most suitable locations” to accommodate the County’s existing and future waste management needs over the plan period25.

36. Of all the sites and areas assessed as part of the SWLP’s evidence base, it is the Policy 11a allocations that perform best against the spatial strategy and the locational hierarchy. Their selection strikes the most appropriate balance between the application of the spatial strategy and providing the necessary certainty that the required capacity will be delivered, and in a manner which does not result in significant adverse impacts. They therefore have a pivotal role in ensuring the SWLP is positively prepared, effective, justified and consistent with national planning policy.

Need to Afford a Primacy to the Policy 11 Allocations 37. Given their status as the most suitable and sustainable sites considered by the WPA and consistent

with the plan-led process, the Policy 11a allocations should be afforded the primary role in providing new waste management facilities to meet the County’s waste management requirements over the plan period.

38. This would ensure that a clear and unambiguous locally derived planning policy framework for addressing the County’s waste management priorities was provided. It would enable all those with an interest in the planning system, including investors, residents, infrastructure providers and the County’s District and Boroughs with the certainty on how a decision maker is likely to react to a development proposal. This would accord with the need for a clear and unambiguous policy framework as set out in the NPPF26.

39. As outlined above, the WPA have and will encourage the County’s District and Boroughs to inset the Policy 11a allocations from their Green Belt boundaries when they are preparing or reviewing their local plans. For such alterations to be made, the Districts and Boroughs will require the necessary level of certainty that these sites will be required for waste management purposes over the plan period. Without such certainty it is unlikely that each local planning authority would be able to demonstrate that the exceptional circumstances exist to make such alterations.

40. At present neither Policy 2 or Policy 10 provide this necessary clarity that the allocations will be required to meet needs over the Plan period, with both appearing to afford the same status to all potential sources of supply, including the ILAS and hitherto unidentified sites. This creates uncertainty over how the County’s waste needs are to be met over the Plan period. In effect, it allows for a similar site selection process to occur during the development management process, setting aside the significant and robust technical evidence made to inform the SWLP.

41. To address this, there is a need for the Plan’s policies to be based on a cascade approach, where the rightful primacy is afforded to the Policy 11a sites over other potential sources of supply, including the ILAS and other unidentified sites. Planning permission for new waste facilities at the ILAS and other unidentified sites should only be granted if the Policy 11a allocated sites haven’t been brought forward, or it is proven that the need for new waste management capacity is higher than the SWLP envisaged.

25 Para. 1.3.1 of the Part 2 Plan refers. 26 Para. 16 refers.



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42. Such an approach would ensure that conformity with the spatial strategy and locational hierarchy are

balanced alongside other considerations and ensuring that the SWLP is sound (including being both justified and effective).

43. We therefore suggest that Policy 2 and 10 are amended. Our proposed amendments are provided in Appendix 1 and 2 of this representation.

44. WTL have also previously raised concerns about the wording of Part B of Policy 2, which is only applicable to schemes that promote the co-location of uses and deliver the benefits sought by national planning policy27.

45. As presently written, proposals that only sought the development of a waste management facility and did not deliver any of the co-location benefits sought by national planning policy, would not be required to demonstrate conformity with the second element of the Policy. It is therefore suggested that Part B of Policy 2 is re-written to employ a more positive planning policy framework, whereby all applications for waste management facilities are required to consider whether wider benefits can be delivered. Our suggested wording is provided at Appendix 1.

Specific Responses to the Proposed Main Modifications in Respect of the Proposed Allocation at Lambs Business Park

46. The Policies and supporting text relevant to Lambs Business Park, South Godstone, are outlined in both parts of the emerging SWLP. WTL’s representations for each part of the Plan are outlined below in turn.

Part 1 Plan 47. As with the Submission version of the SWLP, the north western extent of Lambs Business Park is

proposed for allocation under Policy 11a.

48. The site’s allocated status as a Strategic Waste Site is fully supported by WTL. As outlined in responses to previous consultation versions of the SWLP and at the Examination in Pubic, WTL have continued to make a significant investment in preparing the necessary technical work required to both promote the site through the plan-making and development management processes. This investment and the resultant technical work28 demonstrates that the proposals are genuinely deliverable.

49. It is noted that the site is still afforded a ‘third-tier’ position within Policy 11a as it is currently located within the Metropolitan Green Belt. Given this existing designation, the site’s policy position is understood and is presently correct. However, since the SWLP Hearing Sessions were concluded, the site was subject of further examination at the TDCLP Examination in Public29. No significant issues were raised either by participants or the Local Plan Inspector. TDC also outlined their continued

27 Para. 4 of the NPPW refers 28 The technical work is summarised within WTL’s Matter 5 Hearing Statement and Appendices (Rep UID 158). 29 Site allocation SES003 was subject of examination at the TDCLP Matter 7 Hearing Session.



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support for the site’s redevelopment in the manner proposed in the accompanying Development Framework Document, including the proposed waste management uses, as well as the insetting of the entire site from the Metropolitan Green Belt.

50. Consequently, on adoption of the TDCLP the site will be located outside the Metropolitan Green Belt and its position in Policy 11a’s hierarchy will significantly improve from policy test (c) to (a).

Part 2 Plan 51. A number of Main Modifications are proposed for Lambs Business Park in the SWLP Part 2 Plan.

These Main Modifications are broadly consistent with what was agreed between the WPA and the Examination in Public participants, including WTL, at the SWLP Matter 5 Hearing Session. It therefore follows that WTL are supportive of the majority of amendments proposed but do have some concerns that the suggested alteration made in respect of highways was not agreed and is not supported by the evidence before the Examination.

52. WTL’s specific comments for each modification made in the Part 2 Plan for Lambs Business Park are provided in turn below.

Main Modification 38 - Indicative Scale at Lambs Business Park

53. The Submission version of the SWLP artificially constrained the scale of any new waste management facility at Lambs Business Park to a ‘medium’ sized facility, unless the railway siding was used, in which case a larger facility may be suitable. As identified within WTL’s Hearing Statement to the Matter 5 Hearing Session30 and as agreed at the Hearing Session itself, this perceived constraint was as a result of transportation concerns.

54. As indicated in the technical work submitted by WTL to the SWLP Examination in Public, the landowner is committed to utilising the privately-owned railway siding and the wider railway network to transport waste into the site and to export any product. The supporting technical evidence demonstrates that the use of the railway in the manner proposed is both realistic and achievable31.

55. It is common ground between the WPA and WTL that a largescale waste management facility which utilised the railway network could be accommodated on Lambs Business Park without having a significant adverse impact on the safety and the capacity of the transportation network.

56. However, whilst it remains WTL’s intention to utilise the railway network to transport waste and product into and out of the site, for the reasons outlined in the their Highways Technical Note32, there is no justifiable reason to limit the scale of the waste management facility to a medium size if an alternative highways only transportation strategy was adopted.

57. Such a conclusion is also consistent with the SWLP’s highways technical evidence, which concludes that due to the “limited congestion, the very low collusion rate and the reasonably low impact of the additional site traffic on the existing highways network, it appears that the site is suitable for larger

30 Para. 38. 31 Paras. 4.6 to 4.9 of Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158). 32 Section 5 of Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158).



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facility types33.”

58. It is also instructive to note that within the Statement of Common Ground between the WPA and TDC that there is agreement that the site is potentially suitable for a large-scale facility of beyond 120,000 tonnes per annum34.

59. Given this evidence, and as agreed with the WPA at the Matter 5 Hearing Session, WTL supports Main Modification 38 which seeks to increase the site’s indicative capacity to a “medium to large” facility. The Modification will ensure that the SWLP is both positively prepared and justified.

Main Modification 39 – Key Development Issues for Waste Management Proposals at Lambs Business Park

60. Three alterations are proposed for the ‘Key Development Issues’ identified for Lambs Business Park. These are as follows:

• Improvements to the Junction between the A22 (Eastbourne Road) and Tilburstow Hill Road (D395);

• New wording relating to the HGV movements from the Business Park; and • Recognition that there are sensitive receptors (housing) on Terracotta Road.

61. WTL’s response to each suggested amendment are outlined below in turn.

Improvements to the A22 and Tilburstow Hill Road Junction

62. As identified in both the County Council’s evidence35 and the highways technical evidence prepared by WTL36, the preferred routing from Lambs Business Park will be south on the D395 Tilburstow Hill Road towards the junction between it and the A22 Eastbourne Road.

63. The impact that a new waste management facility at Lambs Business Park will have on this Junction in isolation and in combination with proposed developments in the surrounding area37 has been assessed on three separate occasions.

64. The Transportation Study undertaken by the County Council to inform the SWLP concluded that when factoring in the cumulative impact of development proposed in the surrounding environs, including a new waste management facility at Lambs Business Park, that the A22 Eastbourne Road/Tilburstow Hill Road Junction would need to be redesigned. The County Council’s work suggested that both a roundabout and signalised junction design should be tested at the location, with the modelling outputs from each option used to determine which mitigation scheme should be pursued38.

65. A similar assessment was undertaken to inform the emerging TDCLP. Taking account of the

33 Para. 9.3.5 of the SWLP’s Transport Study (July 2018). 34 Para. 6.8 refers. 35 Para. 9.3.1 and 9.3.2 of the SWLP’s Transport Study (July 2018). 36 Para. 4.10 of Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158). 37 New employment development is proposed at Lambs Business Park under Policy SES003 of the TDCLP. A new Garden Village is also proposed at South Godstone under Policy SGC01 of the emerging TDCLP. 38 Para. 9.4.1 of the SWLP’s Transport Study (July 2018) refers.



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development proposed in the surrounding area, the work39 identified the need for new traffic signals at the A22 Eastbourne Road/Tilburstow Hill Road Junction. The assessment concludes that with this mitigation that delays at the Junction would reduce by 17% in the AM peak and 9% in the PM peak when compared to the existing situation40. As a result of this work, Policy SES003 of the emerging TDCLP requires, subject to further assessment41, for any redevelopment proposals at Lambs Business Park to deliver improvements to the Junction.

66. Additional transport work has most recently been prepared by WTL42. The work, which assessed the ‘worst-case’ impact of the proposed development43, concluded that the Junction would experience operational difficulties in 2024 as queuing and delays increase to an unacceptable level in the PM peak period.

67. Given these conclusions, WTL agree that the appropriate improvements to the A22 Eastbourne Road/Tilburstow Hill Road Junction are necessary. Consequently, WTL are supportive of this element of Main Modification 39. The Modification is required to ensure that the SWLP is justified and effective. It would also correlate with the emerging Policy context in the TCDLP.

68. It is instructive to note that WTL’s evidence base work assessed two improvement options for the A22 Eastbourne Road/Tilburstow Hill Road Junction; a roundabout and a signal-controlled junction. It found that both options, which could be delivered within existing highways land, would operate satisfactorily even when factoring in the ‘worst case’ traffic associated with the redevelopment of Lambs Business Park.

HGV Movements

69. Main Modification 39 alleges that transportation connections to and from Lambs Business Park are “restricted” and that “there is little opportunity to increase total HGV movements using the Business Park.” The Modification indicates that any large-scale waste use is therefore likely to require the reopening of the existing rail sidings in order to utilise the rail network. This proposed Modification was not agreed at the Matter 5 Hearing Session and has been included by the WPA retrospectively.

70. As indicated above, WTL are supportive of the use of their privately-owned railway siding to transport waste and product into and out of the site. Accordingly, the use of the railway is an aspiration shared by WTL and the WPA.

71. However, despite this shared aspiration, there is still a need for any constraint being placed on the capacity of a waste management facility at the Business Park to be justified. In this context and as is demonstrated in the following paragraphs, there is no evidence before the SWLP Examination in Public that would justify a capacity constraint being applied to a new waste management facility at Lambs Business Park that relied on a highways only transportation strategy. Instead, the evidence supports Main Modification 38, that the capacity of the site should be “medium to large” regardless

39 Strategic Highway Assessment: Mitigation (June 2018). 40 Table 2-6 of the Strategic Highway Assessment: Mitigation (June 2018) refers. 41 The need for a contribution to improvement the Junction will be dependent on the conclusions of an up-to-date transport assessment and relative to the size, type and nature of the proposed development. 42 Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158). 43 As indicated in Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158), the worst case scenario assumes that all movements associated with the complete redevelopment of Lambs Business Park as outlined in the accompanying Development Framework Document would be via the highways network and that all traffic to and from Lambs Business Park will route via the A22 Eastbourne Road/Tilburstow Hill Road junction.



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of the transportation strategy pursued.

72. As indicated above, the County Council prepared a Transport Study to inform the SWLP. The work assessed the likely vehicular flows associated with various types of waste management facilities, at various capacity levels. For Lambs Business Park the evidence demonstrated that the resultant increase in flows in the majority of instances would be less that 1% for the A22 Eastbourne Road, which “was deemed an acceptable increase.”

73. Indeed, even when HGV’s were considered in isolation it was concluded that whilst there would be a larger increase (26% was identified as being the largest increase for gasification and pyrolysis, which are not being proposed by the landowner) it would still have a “minimal” impact44. The work also confirmed that the Business Park currently has good access for HGV’s to the south45. Whilst the impact would be greater for Tilburstow Hill Road, no mitigation was identified as being necessary on that stretch of road.

74. With mitigation in the form of an improvement to the A22 Eastbourne Road and Tilburstow Hill Road Junction, the County Council’s assessment concludes that given the limited congestion, low collision rate and the low impact of additional traffic from the site as a result of new waste management facilities on the existing highways network, the site is suitable for larger types of facility46.

75. The only potential constraints identified in the evidence base document relates to the distance of the proposed allocation from the strategic highways network and the impact that the emerging Garden Village could have on the scale of facility being proposed. The distance from the site to the strategic highways network it not a clear constraint that would justify a limit being applied to the size of a waste management facility at the Business Park and the potential impact of the Garden Village is not a matter for this emerging Local Plan.

76. No further highways evidence has been prepared by the County Council since the SWLP Hearing Sessions were closed and consequently it must be concluded that there is no evidence before the Examination in Public to justify a capacity constraint being imposed on a new waste management facility at Lambs Business Park that adopted a transportation strategy that was solely dependent on the highways network.

77. In contrast, the evidence before the Examination confirms that the cumulative impact of the development of the site under the ‘worst-case’ scenario, in combination with other nearby developments could, with mitigation at the A22 Eastbourne Road and Tilburstow Hill Road Junction be satisfactorily accommodated in the highways network47. In both cases, the HGV flows resulting from the proposed development of Lambs Business Park were an intrinsic part of the modelling exercise48.

78. Given the above, there is no justification for the inclusion of the following sentence as a Key Development Issue for Lambs Business Park:

44 Para. 9.2.8 of the SWLP’s Transport Study Site Assessment. 45 Para. 9.5.2 of the SWLP’s Transport Study Site Assessment. 46 Para. 9.2.8 of the SWLP’s Transport Study Site Assessment. 47 Please refer to paras. 5.18 to 5.30 of Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158) and the TDCLP Strategic Highway Assessment: Mitigation (June 2018). 48 Refer to Appendix D of Appendix 4 of the Participant Statement prepared by WTL for the Matter 5 Session (Ref UID 158).



PARTICIPANT ID: 158

FEBRUARY 2020

“Transport by road is restricted with little opportunity to increase total HGV movements using the business park. Any large-scale waste use is therefore likely to require the reopening of the existing rail sidings in order to utilise the rail network.”

79. It follows that the sentence should be deleted in future iterations of the SWLP.

80. As indicated in the schedule of Main Modifications, the inclusion of the sentence was to emphasise the importance of considering rail access. Whilst that is understood, it is also instructive to note that any forthcoming planning application for a waste management facility at the Business Park would need to satisfy Policy 15 of the emerging SWLP in any event.

General Amenity

81. Proposed Main Modification 39 includes a new reference to their being sensitive receptors (housing) on Terracotta Road.

82. The inclusion of this reference was agreed with WTL at the Matter 5 Hearing Session on the basis that the SWLP stated that Lambs Business Park was capable of accommodating a medium to large facility. As this has been reflected with Main Modification 38, WTL supports its inclusion with Main Modification 39.

Summary 83. Our suggested changes to the Part 2 Plan as it relates to Lambs Business Park are outlined in

Appendix 3 of this consultation response.

LRM Planning February 2020



PARTICIPANT ID: 158

FEBRUARY 2020

Appendix 1 – Suggested Amendments to Policy 2 Policy 2 – Recycling and Recovery (other than inert C, D & E and soil recycling facilities) A. Planning permission for the development of recycling or recovery facilities (other than inert C,

D & E and soil recycling facilities) and any associated development will be granted at the following locations and in the following priority order:

i) The site is allocated in the Surrey Waste Local Plan for waste development (Policy 11). ii) The activity involves the redevelopment of a site, or part of a site, in existing waste

management use. iii) The site is otherwise suitable for waste development when assessed against other policies

in the Plan. B. Applications for new Development of waste recycling and recovery activities co-located with

other waste and non-waste development will be supported where it can be should be supported by evidence to demonstrated that there are potential benefits from the colocation of the proposed waste use with other waste and non-waste uses has been considered. Such benefits which may include:

i) More efficient production, in terms of quantity or quality, of recyclate and waste

derived fuels. ii) Fewer lorry movements would be required as a result of co-location. iii) An additional beneficial use is associated with waste recycling and recovery

operations at the site e.g. efficient contribution to an energy network.



PARTICIPANT ID: 158

FEBRUARY 2020

Appendix 2 – Suggested Amendments to Policy 10 Policy 10 – Areas suitable for development of waste management facilities Planning permission will be granted for the development of facilities (excluding permanent deposit) at the following locations and in the following priority order:

i) Sites allocated under Policy 11a – Strategic Waste Site Allocations or ii) Policy 11b – Allocation of a Site for a Household Waste Materials Recycling Facility. iii) On land identified as an ‘Industrial Land Area of Search’ as shown in the policies maps. iv) On any other land identified for employment uses or industrial and storage purposes by district

and borough councils. v) On land considered to be previously developed and/or redundant agricultural and forestry

buildings and their curtilages. vi) On land that is otherwise suitable for waste development when assessed against other policies in

the Plan.



PARTICIPANT ID: 158

FEBRUARY 2020

Appendix 3 – Suggested Amendments to the Key Development Issues Identified for Lambs Business Park

Green Belt The site is within the Green Belt but proposed to be removed through the emerging Tandridge Local Plan.

Transport

The site is accessed from Tilburstow Hill Road (D395), which links to the A22 (Eastbourne Road) to the south, east and north. Appropriate improvements to this junction will be required depending on the scale of the facility and utilisation of rail.

Proposals that seek to utilise the existing rail network and siding in order to support sustainable transport patterns will be encouraged.

Transport by road is restricted with little opportunity to increase total HGV movements using the business park. Any large-scale waste use is therefore likely to require the reopening of the existing rail sidings in order to utilise the rail network.

Biodiversity

The Mole Gap to Reigate Escarpment SAC is located within 10km of the site.

The Godstone Ponds SSSI is located 2.5km from the site, and the Mole Gap to Reigate Escarpment SSSI is located 8.4km from the site.

Maple Wood SNCI (an Ancient Woodland) adjoins the site and Furze Wood SNCI is 0.2 km north of the site.

Great crested newts are recorded nearby and likely to be present on the site.

General Amenity There are sensitive receptors (housing) situated along the access road to the site (Terracotta Road).

Landscape The Surrey Area of Great Landscape Value designation commences immediately to the north of the site, and the site is sensitive in terms of landscape character and visual amenity.



PARTICIPANT ID: 158

FEBRUARY 2020

Heritage The South Park Conservation Area is 0.4km north east, and a Scheduled Monument (Medieval moated site, Lagham Manor, South Godstone) is 0.75km east.

Aerodrome Safeguarding This site falls within the airport safeguarding zone of Gatwick Airport.

UID 16a

Fig 1: illustrative layout

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Lambs Technology Park | Section 1

Introduction 1.1 Background

This document has been prepared by LRM Planning on behalf of WT Lamb and sets out proposals in respect of the future of Lambs Business Park at South Godstone.

WTLambhavebeenoperatingatthesiteforover100years,usingitforthepurposeofmanufacturinghighqualityrooftilesandbricks.Theworksusedtheprivatelyownedrailsidingtoimportcoalandtoexportbricksandtilesmanufacturedonthesite. Given the nature of these uses, the site has been heavily used for industrial and manufacturing processes, with the railway being at the heart of the site’s success.

Morerecentlyhowever,thedemandfortraditionallymanufacturedproductshaslessened and the uses of the buildings on the site have altered. The eastern area of the site has been redeveloped as an industrial estate, whilst the western area is used foraggregaterecyclingandinertwasterecoveryactivities.

ItisnowWTLamb’saspirationtodevelopamodernandhigh-qualitytechnologyparkonthesite.Theirdevelopmentaspirationsseekthesite’sredevelopmenttoprovide two data centres; a decentralised combined cycle energy centre (combined heatandpower),incorporatingarenewablebiofuelproductionplant;andtheintensificationoftheexistingsitetoaccommodateassociatedhighervalue,moreproductiveemploymentuses.

Over the past 4 years, WT Lamb have been working with Tandridge District Council and Surrey County Council to form a future strategy for the redevelopment of Lambs BusinessPark,whichhasculminatedinPolicySES03ofthedraftLocalPlanandthesite’sidentificationwithinPolicy11aofthedraftSurreyCountyCouncilWastePlan,as an allocated waste site.

1

N

Includes OS Data © Crown copyright and database rights2016 OS 0100031673

Th s d awing uses survey informa ion by others The accuracyof this in ormat on has not been ve if ed Place by Des gncannot be he d iab e or any erro s or om ssions in th sinfo mation or any design changes which may be equi ed asa consequence of rel ance on such in ormat on Dimen ionsshou d be ve if ed on site before fina ising detai ed design ofany e ement of the proposa s

App ication S te

KEY

Ownership

Fig 2: red line plan

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The Site2.1Introduction

Thetotalsite(figure2)areais13.4hainsize,andcomprisesofaparceloflandlocated approximately 1km to the west of South Godstone. It is located wholly within theMetropolitanGreenBeltandisdividedintotwodistinctparcelsasfollows:

• theeasternlandparcel(5.4ha)isidentifiedasbeingaStrategicEmploymentSitewithintheAdoptedTandridgeDistrictDevelopmentPlan.ThereisadistinctdifferenceintheageandqualityofthecommercialunitswithinPark.Whilstunitsto the east and south are considered to be modern and meet the commercial demand for such space, units to the north and west are largely buildings associated withtheformerbrickworks.AsofApril2018theseunitslargelydonotsatisfyUKBuildingRegulationsEnergyPerformanceCertificate(EPC)standards,andarenotsuitableformodernbusinessneedswithoutsignificantinvestment,whichisnotviable.Thesitebenefitsfromalivepermissiontomanufacturefacingbricksandthermallytreatclayproducts.Inaddition,thereisanextantpermissionforfurtherB use buildings; and

• thewesternlandparcel(8ha),whichliesoutsidetheemploymentdesignation,currentlybenefitsfromaplanningconsentforuseasaspentrailwayballastdepot.Thequarrybenefitsfrompermissionforclayextraction,inertlandfillandadepotforhandlingre-saleablerailwayballast.WTLambhaveuntil2047torestorethequarrybacktoitsoriginalcontours,orcontinueclayextractionandprocessingspent railway ballast.

A 300m railway siding is located to the north of the site, and is owned by WT Lamb. This siding is connected to the rail network via Network Rail live points and

2

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signalling.Inadditiontothis,themainrailwaytrackoperatedbyNetworkRail has a further siding of 300m in length which is directly connected to WT Lamb’s own siding.

Thesitesignificantlyslopesfromthenorthwesttowardsthesouthandisbounded by:

• the Redhill to Tonbridge Railway Line (including the Channel Tunnel Freight Line) to the north;

• open countryside, which is largely used for agricultural purposes and includesaliveoilandgasinstallationclosetothesite,tothesouth;

• Maple Wood and open countryside which is largely used for agricultural purposes, to the west; and

• fieldsandresidentialpremiseslocatedonTerracottaRoad(allofwhicharein the ownership of WT Lamb) and Rushton Avenue to the east.

Thesubjectsiteiswellscreenedbysubstantialboundaryhedgestothewestandsouth,whichsupportasignificantnumberoftrees.Theboundariesto the north and northwest are formed and screened by Maple Wood and the heavily treed railway embankment and rising land behind. As indicated above, the remaining land in the surrounding environs is open countryside andinagriculturaluse.Agriculturalfieldboundariesthereforescreenviewsinto and out of the site.

An Area of Great Landscape Value is located to the north of the site, whilst a SiteofNatureConservationislocatedtothenorthandwest(MapleWood).BirchenCoppicetothesouthisaPotentialSiteofNatureConservation.

Areasofhigharchaeologicalpotentialarelocatedtothesouthwest.Allarelocated outside of the Business Park.

Location

The site is located approximately 1km to the west of South Godstone which is theclosestsettlementtothesite.Godstoneisaround3kmtothenorthwith Central London about 40km further to the north.

The A22 runs to the east of the site. This runs through South Godstone and connectsdirectlytotheM25atJunction6andtoLondonbeyond.ItalsoprovidesfurtherconnectionstothesoutheastofEnglandviatheM23andA23 including to Gatwick, Brighton and forms the main route to the South Coast.

SiteaccessisprovidedtotheeastviaTerracottaRoadwhichisapproximately600metresinlength.ThisisaprivateroadaccessedfromTilburstowHillRoad. Tilburstow Hill Road runs adjacent to the A22, to Godstone where it meetstheB2236andA25.

GodstonetrainstationislocatedtothesouthofSouthGodstoneandthetrack runs directly adjacent to the north boundary of the site and includes a siding under the ownership of WT Lamb.

Fig 4: aerial view of the entire site

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Brickworks and Quarry

Godstone Brickworks and Clay Quarry has a long and complex planning history.Asignificantnumberofplanningconsentsrelatingtothequarryworkings and associated buildings, have been granted by Surrey County Council (SCC) and Tandridge District Council (TDC) over the course of the site’soperationalhistory.Theextantconsentsrelatingtotheunrestoredworkingareapermitclayextractionandrestorationthroughimportation of inert material.

Twoextantplanningconsentsgovernoperationsonsite:

1. Application TA/80/675 dated 7th January 1981 (The 1981 Consent);

• Landfilloperationson5.8hectares;• Railwaysiding(includingweighbridgeandsiteoffice);and• Depot to handle redundant spent railway ballast.

2. Application TA99/155 dated 30th August 2002 (The 2002 consent)

• Continuationofwinningandworkingofbrickclayfrom5.64hectares;• Retentionofcertainbrickmakingfacilities;and• Junctionimprovementstoprivateaccessroad.

Therestorationprovisions,includingcontoursandaphasedprogrammeofrestoration,aresubjectofaSection106Agreementdated8thAugust2002,andrelatetobothlandparcelssubjectoftheabovepermissions.Restorationofthesitethroughinfillwithinertmaterialiscommontoboththe1981and2002consentsandtoacombinedscheme.Thedepotarea,withinthe1981consent area is excluded from this legal agreement. Vehicle movements for

importationofinfillbylorrywascappedat30perday(15inloaded,15outempty).

The1981consentpermitsthereprocessingorrecyclingofspentrailwayballast imported by rail. Limited volumes of recycled aggregates can be exported from the site, restricted to 20 lorries per week, and the balance usedinrestorationofthePhase4quarryvoidtocompletetherestoration of this area.

Phase 1 was previously restored with the approval of the Environment Agency.AnEnvironmentAgency(hereafterEA)WasteRecoveryPermit(WRP)hasbeengrantedtorestorePhases2andthisrestorationisnearcompletion.Phase4nowbenefitsfromaWasteRecoveryPermit(WRP)andtherestorationofthisareawillcommenceshortlyfollowingthesuccessfulrecoveryofsiltsandaggregatesfromthearea,permittedunderEAlicenceEPR/EB3107CQA001.AWRPforPhase3willfollowthesuccessfulrestorationofPhase4.Thiswillensurethatallareasareprofessionallyrestored with inert material in due course.

Current use

Fig 11: quarry

Fig 12: entrance to the business park

Fig 13: older brick buildings

Fig 14: modern units

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Lambs Business Park

There are at present, a range of businesses across the eastern part of the site invariousbuildings,structures,yardsandcompounds.UsespredominantlycompriseindustrialB2andB8uses.Inaddition,thereisalsoanextantpermission for brick making on site.

Anextantpermissiononthesouthwesternportionofthesiteexistsfortheerectionof1,920sq.mofB1,B2andB8uses(fig16).

Asnoted,theParkcomprisesofacombinationofmoremodernbuildingsandthose that are associated with the old brickworks. The older structures and compoundsaredeterioratinginquality(c.8,000sq.m)andwillneedsignificantinvestmentiftheyaretomeetforthcomingBuildingRegulations,inorderforthemtocontinuetobelet.

Indeed,sinceApril2018theseunitshavebeensubjecttotheEPCrequirements. The vast majority of these buildings do not have an EPC ratingaboveGandthereforeWTLambcannolongergrantanewtenancy(includingarenewal).Inaddition,theywillnotbeabletocontinuetoletanyof these buildings from 1 April 2023. Whilst it is possible that buildings can be refurbishedtoimprovetheirEPCrating,commercialpropertyadviceprovidedtoWTLambhasconfirmedthatthiswillbeunviable.Inanyevent,evenwitharefurbishmentprogramme,onlyoneofthebuildingsiscapableofmeetingthe required level. Consequently, by 2023 at the latest, these buildings will be vacant and redundant.

Fig 15: more modern units

Fig 16: the existing 2006 scheme for a new block 12 and 13 (alongside the existing block 10)

page 20

AspartoftheinitialHELAAcallforsites(2015),3potentialoptionswereconsideredbyWTLambforthesiteandweresubmittedtoTandridgeDistrictCouncil.Fromthoseoptionstheschemehas evolved over the past four years based on technical input, the requirements of operators and the ongoing advancement of technology.

Theschemeevolutionisbasedon:

1. the need to secure the long term future of the Business Park given thelackofviabilityininvestinginupgradingexistingbuildingsandcompounds;

2. utilisingtheareaofthesitewithextantpermissionfor1,920sq.mofB1,B2andB8uses;

3. therestorationofthequarry;

4. capitalisingontheuniqueandsustainableopportunitiesofferedbythe railway sidings to service the site;

5. the provision of a high tech, modern and sustainable land use;

6.potentialforfurtherinvestmentinthewiderParksubjecttotheinitialphase;and

7.The ongoing advancement of technologies and ever increasing efficienciesinenergyproduction.

Scheme Evolution

ThefavouredoptionfromtheHELAAsubmissionwas“C”,whichincluded:

• ac.6,795sq.menergyrecoveryfacility;• 2no.10,284sq.mdatacentres(over2-3storeys)withassociated

supplementary energy centre (decentralised CCGT); and

• theuseofthesouthernmostareasoftheformerquarryasfloodalleviationandasanaturereserve.

Fig 17: HELAA favoured option

Fig 20: illustrative 3D view of the site

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Proposed LambsTechnology Park3.1Introduction

Overthepastfouryearssignificanttechnicalworkhasbeenundertakeninordertofeedintothesite’sdevelopmentplanpromotionandafutureplanningapplication.Duringthistimetechnologieshaveevolvedandnewmoreadvancedtechniquesarenowavailabletoensuremaximumefficiencyandsustainability.Basedonthesignificantamountoftechnicalworkundertaken and feasibility studies, the proposal comprises:

• 2no.9,245sq.mdatacentres(over2-3storeys)withassociatedsupplementary energy centre (decentralised CCGT) that meet the highestspecificationspossible;

• ac.5,418sq.mcombinedcycleenergycentre(upto49MWe),incorporatingarenewablebiofuelproductionplant;

• theuseofthesouthernmostpartoftheformerpitareasasfloodalleviationandanaturereserve;

• theintensificationandredevelopmentofunderutilisedareasoftheBusinessPark(c.3.03ha)toprovidehigher-valueandmoreproductiveemployment space; and

• educational/learningopportunitiestobeexplored.

3

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Background

Theschemeisbasedon2datacentreswithintheexistingLambsBusinessParkutilisingtheareasubjectofanextantplanningpermission for B employment uses and the area in need of redevelopment.Theschemealsoincludestheconstructionofacombinedcycleenergycentre,witharenewablebiofuelproductionplant, within the former quarry area. Power generated from the combined cycle energy centre would be supplied directly to the data centresandtherenewablebiofuelproductionplant.AnyresidualelectricalenergywillbesoldtotheNationalGridorprovidedtootherusers.

Asabi-product,theheatgeneratedfromtheelectricityproductiongenerationwillbeused:

1. within the combined cycle energy centre to increase the plant’s electricalproductionefficiency,viatheuseofaboilerandasecondary turbine;

2. tosupplytherenewablebiofuelpelletproductionplantwithhighquality heat to dry refused derived fuel (RDF), via either a water or an air heat exchanger (to produce biofuel pellets);

3. to supply heat and cooling to the data centres; and/or

4. forexistingorplanneddevelopmentinthesurroundingenvirons,utilisingaheatsupplycontract.

Thebiofuelproductionplantwillprocess150,000tonnesofRefuseDerived Fuel (RDF) each year to create biofuel pellets.

WTLambarecommittedtoreopeningtherailwaysidingtothenorth of the site. Work undertaken on their behalf has shown the points to be live and Network Rail acknowledges that the siding is aliveoperation.Wherefeasible,therailwaywillbeusedtoimportfeedstocksfortheoperationoftherenewablefuelproductionplantandtotransportthefinalrecycledfuelproduct(solidbiofuelpellets)andanyotherbi-productsincludinghighervalueelementsremovedfromthefuelproductionprocess,foronwardrecyclingandrecovery, from the site.

Subjecttothefuturesuccessoftheproposals,thereispotentialforadditionalinvestmentandthefurtherregenerationofthePark,toprovideadditionalhightechnologyuses.

The combined cycle energy centre, the two data centres and the renewablefuelbiofuelplantareproposedonc.5.8haofthesitewithredevelopment/intensificationopportunitiesidentifiedonafurther c.3.03ha

Fig 21: illustrative master plan

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Key design principles

A number of key principles have guided the proposals, which include:

• utilisinghigh-tech,sustainabletechnologiestomapoutthefutureoftheParkand lead future growth in Tandridge District;

• theincorporationofappropriate,bestpracticedesignthatwillenhancetheexistingIndustrialestateandformerquarry.Itisenvisagedthattheproposalswouldbecomeanexemplarforotherhigh-techschemesofthistype;

• investment and the redevelopment of parts of the site that are otherwise unviabletorenewandwillbecomeunlettableandredundantoverthenextfew years;

• making use of the area of the Business Park that already has planning permissionforanadditional1,920sq.moffloorspacethathasbeenimplemented,buthasnotbeeneconomicallyfeasibletocontinue;

• enhancingthelandscapeandamenitypotentialofthesitethroughminimising the visual impact of the proposal and the provision of on site open space,landscapingandsurfacewaterattenuationincludingthroughtheearlyrestorationofthequarry;

• decreasingtheexistingvisualandamenityimpactsuponthelocalareathatarisefromtheexistingusesatthesite;

• re-useofoneoftheveryfewprivatelyownedrailwaysidingsintheUKtoenable a sustainable, low impact supply of material to the site for use within therenewablebiofuelproductionplantandtheexportofbiofuelpellets;and

• maximisingopportunitiesforbiodiversityenhancement.

Fig 22: aerial view

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Benefits of co-location

The development of the combined cycle energy centre, a renewable biofuel productionplant,datacentresandadditionalemploymentopportunitiesonthissitehasanumberofsignificantsustainabilitybenefitsthatwouldbelostifanyofthe land uses were not taken forward. These include:

• alargeproportionofresidualotherwisenon-recyclable(RDF)withahighbiogenic content arising in Surrey is exported out of County to be processed. Thedevelopmentofarenewablefuelproductionplantonthesitewouldensurethat this material is handled closer to where it is formed;

• thereisaprovenneedfornewwastemanagementandprocessingfacilitieswithin Surrey;

• the railway siding provides an unusual opportunity for the renewable fuel productionplanttoreceiveresidualwastestothesiteviaasustainablemodeoftransport (rail);

• theenergydemandsofboththerenewablefuelproductionplantandthedatacentresareideallysuitedtotheco-locationofadecentralisedenergycentre;

• research has shown that the ICT industry emits around 2% of global CO2 emissions.Withthedemandfordatacentresandcloudfacilitiesincreasing,withoutmoresustainablesolutionsthisfigurewillincrease;and

• The residual heat from the energy centre could be used to dry RDF material in therenewablebiofuelproductionplantandtoheatandcoolthedatacentres.Theuseofwasteheatgeneratedasabi-productfromtheenergycentregreatlyassists in reducing the electrical energy demand from the data centres.

Fig 23: aerial view

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Data Centres4.1Introduction

WT Lamb are working with Arup in order to design bespoke Data Centres (UseClassB8).

Itisexpectedthatthedatacentreswouldmeettheexemplarspecificationsofhighendoperators.ThedatacentresareproposedwithintheexistingBusiness Park (the eastern parcel), including the part of the site with extant planningpermissionforB1,B2andB8uses(andidentifiedwithintheLocalPlanevidencebaseasbeingsuitableforBuse)andthedegradedexistingunits.

4 Fig 24: data centre

What is a data Centre?

A data centre is a facility that is used to house computer systems and associated infrastructure, such as storage systems. Typically, a data centre will house a large group of networked computers for the remote storage,processinganddistributionoflargeamountsofpersonalandcorporatedata.Allcloud-basedstorageandevenbankinginformationisnow largely stored within data centres. In some circumstances this data ismirroredinmultipledatacentresaroundtheworldtoensurethatthedata isn’t lost in the event of an unexpected incident.

page 30

highqualityfibreopticconnectionsfrommultipleproviders.

• Site Prominence: The sites should have security fencing, should not be visually prominent and have one access. Sites that are visible from main roads would not pass the assessment criteria.

How the Data Centre will operate

Alongsidethesuccessfulimplementationofthecombinedcycleenergycentreandassociatedelectricalimportandexportgridconnection(costbornebythe Developer), WT Lamb would develop the data centres. It is envisaged that these will be leased to a global business and the Council is already aware of the companies who have expressed an interest in occupying them.

Thefirstdatacentretobeconstructed(UnitD1)wouldbec.9,245sq.m(over2-3storeys)onafootprintofapproximately3,141sq.m.Thebuildingcouldbeconstructed in a manner which took advantage of the fall of the land in order to minimise landscape impact.

Without the presence of an onsite energy centre, each data centre would consume approximately 20MWe of electricity from the Grid (equivalent to the powertosupplyc.41,500homes)andrequiresignificantlocalinfrastructureupgrades.However,thisproposal,whichwillseetheconstructionofbothfacilitiesandallowsforthedevelopmentofacombinedheatandpowersystem,designedbyArup.Thenecessarychillingofthecomputerfacilitiescouldbeprovidedonthebasisofabsorptionchillingfromthelowgradesurplusheatprovidedbytheenergygenerationprocesses.

Overathirdofthefloorspaceofadatacentrewilltypicallyaccommodateabsorptionchillersrequiredtocoolthefacility,withtheremainingfloorspacebeingusedtohousetheICTequipmentandancillaryspace.There is a need to ensure that the environment of a data centre is controlled(bothintemperatureandhumidity),bothtooptimisetheperformanceandtheoperationalintegrityofthesystemstherein.

Data centre operators have industry standard criteria when assessing the suitability of sites for such use. These can be met by the site and include:

• Accessibility by train: For sites around London, there is a requirement that theycanbeaccessedbyanengineerwithina1-hourtraveltimeofLondonBridge.

• Accessibility by road:InlocationsaroundLondon,therequirementisforsitestobelocatedwithina15-minutedrivetimeofajunctionconnectedto the M25.

• Accessibility by helicopters: For sites around London, this means being within an hour’s commute from London Bridge, via a helicopter.

• Flood Risk:Toensurethatdatacentresarenotatriskofflooding,theindustry standard requirement is for them to be located in Flood Zone 1, witha1in1,000yearriskofflooding.

• Mains Power Supply: A large main power source should be available.

• Duel Power:Tominimisetheriskofdatacentresbeingoff-lineforextended periods, data centres should have several sources of power available.

• Fibre Optic Connections:Itisessentialthatdatacentreshaveaccessto

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Fig 25: aerial of the data centres

Fig 26: view of the potential data centres

Fig 27: aerial of the data centres

Fig 28: potential view of the data centre

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• thesitehasanextremelylowprobabilityofflooding.Theexistingpitareascouldbeutilisedtocreatefloodattenuationmeasures;

• thereissufficientspacetoaccommodatethedatacentresandtheirancillary infrastructure;

• closeproximitytoLondonbymultiplemodesoftransport,includingrail,airand road;

• accessiblefromM25(6-10minutesfromJunction6);

• the site is discrete and secure; and

• flightpathstoGatwickAirportonlycrossthesiteinparticularandrareconditions.

Giventhecharacteristicspresentedabove,andparticularlytheco-locationof the combined cycle energy centre which will supply heat and power for the data centre in a low carbon manner, the site is considered to provide a uniqueopportunity.Thishasbeenrecognisedbyanumberofinternationaltechnology companies and a notable Silicon Valley investment house.

Illustrative design parameters

Basedontherequirementsofnumerousoperators,anumberofassumptionshavebeenmadeinrelationtothekeydesignparametersofthebuildings.

• Heights: up to between 12 to 15m;

• DataCentreArea(floorspace):c.9,245sq.mperunit.

Suitability of the site for a data centre

WTLambhaveundertakenasignificantamountofresearch into understanding the site requirements for data centre operators. Thecharacteristicsthatmakethissouniqueandattractivetosuch operators include:

• theopportunityfortheproductionofelectricityonsiteutilisingaconnectiontotheNationalGaspipelineandalternativelyacombinationofatraditionalgasconnectionandalocalisedgasfield,therebyminimisingparasitictransmissionlosses;

• theabilitytosourceadequatepowerfrommultiplesources,includingthegrid and Energy Centre alongside each data centre;

• the use of low grade heat from the energy centre to reduce the power requirements of each data centre;

• thebudgetestimatesfordeliveringapowersupplytothesitecanbeviablyachieved at a cost borne to the developer;

• fibreopticprovidershaveconfirmedlocalpointsofpresencethatcanserve the site. This ensures that the tenant would have a choice of supplier, sufficientcapacityandtheabilitytoachievemultiplefibreopticentrypointstopreventadisruptionofservice;

• giventhebuiltdevelopmentinthesurroundingarea,existinggroundconditionsareunlikelytoposeaconstrainttoeithertheconstructionortheoperationofadatacentre;

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CitiDataCentre,Frankfurt,Germany©ArupAssociates CitiDataCentre,Frankfurt,Germany©ArupAssociates

CitiDataCentre,Frankfurt,Germany©ArupAssociates HongKongExchangesClearingDataCentre©KennyIp

Fig 29: the Citi data centre in Frankfurt



Fig 32: internal storage

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Combined Cycle Energy Centre5.1Introduction

WT Lamb are currently developing a scheme that incorporates an up to 49MWe combined cycle energy centre. The centre will either be powered viaaconventionalgasconnectionorcouldutiliseboththeexistingandconsentedgasfieldtothesouthofLambsBusinessParkandaconventionalgasconnection.

ThepromoterandprospectiveapplicantisworkingwithanumberofinternationalandlocalpartnerstodesignthisfacilityandarebasingthedesignonanumberofprovenschemesinboththeUKandmainlandEurope.Theuseofcombinedcyclegasturbinesensuresthattheoverallgenerationandoperatingefficiencyoftheplantismaximisedandwillcreateasectorleading decentralised Combined Heat and Power (CHP) facility.

Acombined-cyclepowerplantusesbothagasandasteamturbinetogethertoproduceelectricityupto50%moreefficientlyfromthesamefuelthanatraditionalsimple-cycleplant.Thewasteheatfromthegasturbineisroutedtothenearbysteamturbine,whichgeneratesextrapower.Thesignificantresidualheatafterthisinitialprocess,canbeusedonthewidersite,including other elements of the proposed development.

5Fig 33: Combined Cycle Energy Centre

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Theproductionof49MWewouldensurethatallthepowerneedsoftheproposeddatacentresandtherenewablebiofuelproductionplantwouldbemetinfull,withthepotentialforanyresidualpowertobesuppliedtotheGrid or other users.

The residual heat (up to 49MWth) produced by the Combined Cycle Energy Centre will be used in one, or a number of the following:

1. supplytherenewablebiofuelproductionplantwithheattodryRDFviaeither a water or an air heat exchanger;

2. heat and cool the proposed data centres; and

3. toheatandcoolexistingandproposeddevelopmentsinthesurroundingarea.

Theon-siteuseofheatandpowerbytherenewablebiofuelproductionplantandthedatacentresenablesveryhighlevelsofenergyefficiencytobe achieved at the site. The provision of heat and power to both uses from thedecentralisedenergyplantminimiseselectricalparasiticlosses(throughreductionoftransmissiondistance),minimisesheatwastageandreducesthedirect and indirect environmental impacts of the Business Park.

AllaspectsoftheoperationwillbedesignedtomeetthehighestemissionstandardsrequiredbytheEUIndustrialEmissionDirective(IED).

Combined Cycle Energy Centre and Renewable Fuel Production Plant Illustrative Design Parameters

Given the interdependence between the combined cycle energy centre andtherenewablefuelproductionplant,bothusescouldbelocatedinonebuilding.Basedonaninitialindicationoftherequirementsofseveraloperators,anumberofassumptionshavebeenmadeinrelationtothekeydesign parameters of the buildings:

• Heights:ridgeupto10mfromexistinggroundlevels;

• Stack: minimum c.35m. above ground level; and

• Area(footprint):c.5,418sq.m.

Fig 34: inside an energy recovery facility and example of industry standard plant

arrangement for energy production

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Theplantcontainsanumberofprocessingoperationstosystematically

upgradetheRDFmaterialtoafinishedbiofuelproductreadyforpelletisation.Allmaterialswillbesuppliedbycontracttoanagreedspecificationandbeprocessedtoformafinalfuelproductthatcanbeusedasasubstitutecoalalternativetoconventionalsolidfuels.

Theproductionprocessshallincludethefollowingkeystages:

• InitialAcceptanceandQualityControl;

• Shreddingandseparation;

• Screening and removal of any recyclable materials;

• Screening and removal of contaminants;

• Drying,withtheuseof6-10MWthofresidualheatfromtheenergyrecovery facility;

• MillingandPelletising;

• QualityControlandTesting;and

• Onwardtransportationtoendusersbyrail.

ThetypicalcustomersforthefuelwillbethedomesticandEuropeancement,steelandcoalfiredpowersectors.Thereprocessingofwastewithintherenewablefuelproductionplantconstitutesarecyclingoperation.NoRDFwillbecombustedorgasifiedonthesite.

Combined Cycle Energy Centre and Renewable Fuel Production Plant Illustrative Design Parameters

Asnotedonpage36,giventheinterdependencebetweenthecombinedcycleenergycentreandtherenewablebiofuelproductionplant,bothusescould be located in one building. Based on the work undertaken to date the parameters are as follows:

• Heights:ridgeupto10m(abovegroundfloorlevel);

• Stack: c.35m. above ground level; and

• Area(footprint):c.5,418sq.m.

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Redevelopment ofRemainder of the Business Park7.1Introduction

In preparing the proposals it is clear that there is also an opportunity for the intensificationandredevelopmentofcurrentlyunder-utilisedareasoftheBusiness Park (c.3.03ha). This provides an opportunity for higher value and moreproductiveemploymentspace.Someofthenewemploymentuseswill be required as ancillary space to the data centre uses. These areas are in additiontothec.5.5harequiredtoaccommodatethetwodatacentres,thecombinedcycleenergycentreandtherenewablebiofuelproductionplant.

This includes a developable area within the former Quarry area and areas that aresuitableforintensificationwithintheBusinessPark(figure35).

ItisWTLamb’sambitiontodeveloptheseareasforuseswhichwillcomplement the development proposals set out herein and are necessary ancillary uses.

7

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Fig 35: other areas of the Business Park identified for intensification

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Technical Considerations8.1Introduction

In order to help shape proposals, a range of background studies and investigationshavebeenundertaken.

Thissectionsetsoutasummaryofthekeyfindingsoftheseassessmentsandistobereadinassociationwiththevariousreportsthathavebeenprepared.Itconsiderstheinitialpotentialimpactsoftheproposalstogiveanoverviewof their acceptability, including:

• NationalPolicy(LRMPlanning);• Socioeconomicconsiderations(HardistyJonesAssociations);• Landscape Impact (Arup);• Ecology (Arup);• Transport (Miles White Transport);• Air Quality (Sol Environment);• Heritage (Cotswold Archaeology on behalf of Arup);• Hydrology (Arup); and• Waste (Sol Environment).

8

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Based on the technical work undertaken in respect of the site andproposals,thereareanumberofkeyconsiderationsforfuture development:

SOCIO-ECONOMIC

• ThesitehasthepotentialtobringsignificanteconomicbenefitstotheCounty.Itwillregenerateanelementofabusiness park that will otherwise be lost as an employment resourceandprovideamodernTechnologyParkthatisfitforfuture use; and

• Whenoperationaltheproposalcancontribute£35minnetannual GVA at the economic market level.

LANDSCAPE

• The site is very well visually contained within the local area. ThisisconfirmedbytheLandscapeAssessmentthathasbeenundertaken by Arup;

• ThisreflectsthefindingsofstudiesundertakenonbehalfofTandridge District Council and Surrey County Council;

• Given the restricted visual catchment area and local tree coverage, it can comfortably accommodate development; and

• Theoptionsprovidenumerousopportunitiestoenhancethevisual amenity of the site.

ECOLOGY

• Giventhenatureofthesite,thereislowpotentialforbiodiversity on site. There is however an opportunity through the proposals to include localised enhancements on site; and

• Impacts of the proposals are considered to be negligible.

TRANSPORT

• TheCouncil’sSPGforthesiteconsidersthatupto1,264twoway daily trips are acceptable (excluding Minerals consents). Since the SPG was prepared there have been numerous bettermentsinthelocalarea;and

• It is expected that improvements can be made to the A22/TilburstowHillRoadJunctiontohelpaccommodatedevelopment if required.

Key Opportunities

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AIRQUALITY

• The combined cycle energy centre and renewable biofuel productionplantwillneedtobecompliantwiththeIndustrialEmissionsDirective.SolEnvironmenthavemodelled the air quality impacts and consider that there are unlikely to be adverse impacts.

HERITAGE

• Buildingsonthesiteareofinsufficientqualityorconditiontowarrantprotectionandtherewillbenoimpact upon any historical asset in the area;

HYDROLOGY

• Thesiteisinfloodzone1.Thereisalowprobabilityofsurfacewaterfloodingbutthiscanbeimprovedfurtherthroughdetailedsitedesignandonsiteattenuation.

WASTE

• Arenewablebiofuelproductionplantwillprovidecapacitytosustainably treat approximately 150,000 tonnes of RDF per annum;

• Currently some 212,000 tonnes are sent outside of Surrey and a further 232,000 tonnes of local authority derived LACW and C&Iwasteislandfilledeachyear;

• Assuchtheschemeprovidesasignificantopportunitytotreatupto34%ofexistingwastewithintheCounty;

• Futureprojectionofwastearisingwithinthecountyindicatean increase of up to 33% of Local Authority Collected Waste (LACW) and Commercial & Industrial (C&I) waste by 2035; and

• The rail siding provides a unique opportunity to bring RDF to site in a uniquely sustainable manner.

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Tandridge Local Plan is being examined under the provision of the 2012 versionoftheNationalPlanningPolicyFramework(NPPF)andtheSurreyWaste Plan is subject to the 2019 version of the NPPF. As the bulk of the landusesrelatetothejurisdictionofTandridgeDistrictCouncil,thissectionisbased on the 2012 version of the NPPF.

Para. 14 of the NPPF (2012) provides the Government’s core planning principles that the planning system should support. Relevant to this proposal, the principles include:

• proactivelydriveandsupportsustainableeconomicdevelopmenttodeliverinter alia, the business, industrial units and the infrastructure that the country needs;

• promotethevitalityofourmainareasandprotectingtheGreenBeltsaround them;

• supportthetransitiontoalowcarbonfutureinachangingclimate;

• contribute to conserving and enhancing the natural environment and reducingpollution;and

• encouragetheeffectivereuseofland.

Para.18identifiesthattheGovernmentiscommittedto“securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future”.

Moreover,para.19statesthattheGovernmentiscommittedtoensuringthatthe planning system does everything it can to support sustainable economic

growth.Therefore“significant weight should be placed on the need to support economic growth throughout the planning system”.

Accordingly,localplanningauthoritiesshouldplanproactivelytomeet thedevelopmentneedsofbusinessandsupportaneconomyfitforthe 21st century.

IntermsofGreenBeltdesignations,para.79oftheNPPFoutlinesthatthefundamental aim of Green Belt policy is to “prevent urban sprawl by keeping land permanently open".

In this regard the Green Belt serves 5 purposes:

1.tochecktheunrestrictedsprawloflargebuilt-upareas;

2. to prevent neighbouring towns merging into another;

3. to assist safeguarding the countryside from encroachment;

4.topreservethesettingandspecialcharacterofhistorictowns;and

5.toassistinurbanregeneration,byencouragingtherecyclingofderelictandother urban land.

Onceestablished,LocalPlanningAuthoritieswithGreenBeltsintheirareashould establish Green Belt boundaries in their Local Plan. These boundaries shouldonlybealteredinexceptionalcircumstances,throughthepreparationor a review of a Plan.

National Planning Policy

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The development pressures in Tandridge District Council, which cannot be metonnonGreenBeltsites,providestheexceptionalcircumstancestowarrantanalterationtotheMetropolitanGreenBelt.

Para. 143 of the NPPF states that in preparing Local Plans, the Local Authority should put in place policies which ensure that worked minerals land is reclaimed at the earliest opportunity. This scheme provides that opportunity.

Whilst Lambs Business Park and the adjacent former quarry is located withintheMetropolitanGreenBeltaspresentlydefinedbytheAdoptedDevelopmentPlan,analysisofGreenBeltfunctionconfirmsthatdevelopmentinthislocationwouldnotcompromiseanyoftheNationalPlanningPolicyGreen Belt purposes.

Inparticular:

• theLambsBusinessParkconstitutesexistingbuiltdevelopment;

• Proposals to redevelop the Park, which include an extension to the west, would not undermine the primary purpose of the Metropolitan Green Belt, which is to keep land permanently open in the areas surrounding London which is located to the north. Consequently, the proposed development would not reduce the area of open space between the subject site and the metropolitan area of London;

• thesubjectsitecannotbeconsideredasbeingalargebuilt-uparea.Nonetheless,boundariesofthesubjectsitearewelldefinedbybuiltdevelopment and natural features. Within the envelope created by these constraints, development of up to 30m can be accommodated with littlevisualharm.Thestrongexistingboundarieswouldensurethanany

development could not be considered as being unrestricted sprawl;

• the expansion of the subject site is not considered to cause merging of settlementsandareas.Thedistancebetweenthesubjectsiteandthesurroundingsettlementsissignificantthereforeamodestreductioninthegap would not lead to coalescence;

• the site is divided into two character areas, which include built developmentassociatedwiththeexistingBusinessParkandtheformerquarry.ClearlygiventhequantumofdevelopmentwithintheexistingBusinessPark,theeasternportionofthesitecannotbecontributingto the purpose of keeping the countryside from encroachment. It is acknowledged that extending the Business Park to the west would technicallyconstituteencroachmentintothecountryside.However,thealterationwillpermitdevelopmentonasitewhichhaslandusescurrentlyassociatedwithinit,willnotberestoreduntil2047,hasastrongdefensibleboundary and can visually accommodate development of up to 30m. The developmentproposalscouldevenimproveaccesstorecreationalareaswithin the countryside, as well as the site’s visual amenity;

• theproposeddevelopmentwouldnotimpactonthesettingorspecialcharacter of any historic towns; and

• theGreenBeltdesignationonthesitehaspreventedthesitefromutilisingitsfullpotential.Whilstdevelopmentinthewesternportionofthesitewouldnotconstitutedevelopmentonpreviouslydevelopedland,forthereasons set out above, it must be considered as being more preferable than a site that has had no previous use associated with it.

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HardistyJonesAssociateshaveundertakenaSocio-EconomicImpactAssessmentofthepotentialschemeandhaveconsideredthepotentialbenefitsthattheproposalsmaybringtothelocalandwiderareas.

Tandridge District lies within the county of Surrey in South East England. The District is immediately adjacent to Greater London and straddles the M25 motorway.TheDistrictalsobordersthecountiesofKent,WestSussexandEast Sussex. The Tandridge Economic and Business Development Strategy (2014)identifiestheFunctionalEconomicMarketArea(FEMA)forTandridgeDistrict including the London Borough of Croydon, Reigate & Banstead, Crawley, Mid Sussex and Sevenoaks. Less pronounced links with Bromley and Wealden are noted.

AsaresultoftheproximitytoLondonthereisahighdegreeofout-commutingandalowlevelofself-containmentwithintheDistrict.Only39%ofworkplace-basedemploymentintheDistrictisfilledbyresidentsoftheDistrict,with77%filledbyresidentsoftheFEMA.

Our Local Plan, Issues and Approaches (Tandridge District Council, 2015) notesthatTandridgeDistricthastheleastcompetitiveeconomyinSurreywiththesecondlowestGVAinthewiderarea(definedastheM3andCoastto Capital LEP areas).

ThepopulationofTandridgeDistrictwasestimatedat87,500in2018(ONS,PopulationEstimates)andhasbeenrisinggraduallyoverthelast25years.Overthetenyearsbetween2008and2018theDistrict’spopulationhasincreasedby7.4%,slowerthanthe8.4%acrosstheSouthEast(SE)asa

wholeandbroadlyinlinewiththe7.5%ofGreatBritain(GB).60.4%ofthepopulationisaged16-64whichisslightlybelowboththeSouthEast(SE)andGB averages.

Overallthelabourmarketpositionappearsfairlyhealthy.EconomicactivityratesintheDistrict(78.9%)in2018areveryslightlylowerthantheSEaverage, but above GB. This is a result of low rates for females compared to the benchmark areas, with male rates very high.

Employmentratesshowasimilarpattern,currentlyabovebothSEandGBaverages and have been for the past four years. Time series data shows the TandridgeDistrictratefluctuatingaroundtheSEaverage,mostlikelyduetonormallevelsofstatisticalvariationduetosmallersamplesizesatthedistrictlevel.

TandridgeDistricthasamuchhigherproportionofitsworkforcethatisself-employedrelativetoboththeSEandGBaverages.ThisispotentiallyareflectionoftheruralnatureoftheDistrictaswellasthesectoralmix,includingalargeconstructionsector.

Occupationaldatashowshigherproportionsofresidentsemployedasmanagers,directorsandseniorofficialsand,inprofessionalandassociated/technicaloccupationsaswellasskilledtrades.Thesedataalsoreflectthepresenceofhighlevelsofself-employment(ownermanagers)andconstructionsectoractivity.Thismayreflectthequalificationsprofileoftheresidentworkforce,withmorequalifiedtoNVQ4andabove(degreelevel)than the SE average. Resident pay is above SE and GB averages.

Socio-Economic

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ONSJobsDensitydataestimates39,000jobswithintheDistrict(2017).Whencomparingthenumberofjobstoresidents,ajobsdensityof0.73isestimated,belowtheGBfigure(0.87)andjustbelowtheSE(0.86).Thisfigurehasbeenquitevolatileinrecentyears,sosomecautionshouldbeexercised.TimeseriesdatasuggeststhefigurehaspreviouslybeensubstantiallylowerthanthebenchmarksandrarelyabovetheSE.

Constructionisasignificantsector–justoverdoublethesizeoftheSEandGBinproportionalterms.TheconstructionsectorinTandridgeDistrictcurrently employs 3,500 workers, with a further 22,500 employed in the FEMA(26,000intotal).Thelocalmanufacturingsectorissmall.

Potential economic impacts

The impacts of the proposed development have been considered in detail, based on two no. 9,245sq.m data centres with associated supplementary energycentre(decentralisedCCGT),ac.5,418sq.mcombinedcycleenergycentre(upto49MWe)incorporatingarenewablebiofuelproductionplantandtheintensificationandredevelopmentofunderutilisedareasoftheBusinessParktoprovidehigher-valueandmoreproductiveemploymentspace.

The complex and high technology uses which are proposed will support a substantialinitialcapitalinvestmentof£473million.Suchaninvestmentwillsupportarangeofactivitywithinthelocaleconomyduringtheconstructionphase. Detailed economic impact analysis indicates approximately 402 personyearsofemploymenttoresidentsofTandridgeDistrict,generatingwagesof£14millionandGVAof£44millionovertheconstructionperiod.

Whenconsideringbenefitsacrossthewiderfunctionaleconomicmarketarea,some596personyearsofemploymentareanticipatedtoaccruetoresidents,generating£20millioninwages.Duringtheoperationalphase,theproposeddevelopmentoptionswillsupportarangeofemploymentwhichwilldeliveranet growth in jobs to local residents. The high value of the uses will generate higher wages and GVA than is currently secured on site and contribute a boost to local GVA.

Detailedeconomicimpactanalysisindicates207FTEnetadditionaljobstoresidentsofTandridgeDistrict,generating£7millioninannualwages.InGVAtermstheproposeddevelopmentisestimatedtodeliverc.£14millioninnetadditionalannualGVAintheDistrict.

AttheFEMAlevel,some465FTEjobsareestimatedtobesecuredbylocalresidents,supporting£14millioninwagesannually,andgenerating£35million in annual GVA.

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A baseline landscape and visual impact assessment (LVIA) has been undertaken by Arup which has fed into the design process. It has assessed a number of key views and concludes that the site is visually contained duetotheexistingtopographyandsurroundingvegetation.Asaresultthesite is well screened and based on the proposed parameters, the proposed development will be screened from the most important viewpoints within a 10km radius study area.

Topography and Landscape features

Thesiteitselfsignificantlyslopesfromthenorthwesttowardsthesouthwithlevelschangesandearthworksonthewesternsectionasaresultofongoingquarryingworks.Withinthewesternsectionthereisasinglebodyofstandingwater again related to the quarry and the drainage of the site, with a wetland pondonthesouth-westerncorner.

Tothenorthandnorth-westadensematuremixedwoodlandpopulatesthe railway embankment and extends 200m beyond to form a larger area designatedasSiteofNatureConservation(MapleWood).Thesite’ssouthboundary is also formed by a dense mature mixed woodland which evolves intoatreebeltalongthesouth-easternsection.Furtherwestandsouth,opencountrysideislargelyusedforagriculturalpurposeswithscatteredpropertiesand large estates related to the farming history of the area. A mature tree belt continuestobepresentalongthesite’seasternboundarywithopenfieldsandresidencesattheendofTerracottaRoadandRushtonAvenue.Thenortheasternsectionofthesitedoesnotfeatureatreebeltandthereforeitis

boundedbytheexistingrailway.

Beyond the site area and in the local context there is a network of roadside hedgerows,scatteredwoodlandsandtreegroups.Maturetreebeltsandmixedhedgerowsalsotendtoformstrongboundariestodefinelargeopenfieldswithinthesettingofanundulatingtopography.

Landscape planning context

Therearenointernationallandscapedesignationsrelatingtothesiteoritsimmediate surroundings. The site lies within the Metropolitan Green Belt.

An Area of Great Landscape Value (AGLV) is located immediately to the north of the site and across the railway line embankment and the Surrey Hills Area of Outstanding Natural Beauty (AONB) is located 5km to the north.

Two Registered Parks and Gardens of importance are located within the studyarea.TitseyParkislocated7kmtothenortheastandGattonPark7kmtothenorthwestofthesite.VariousConservationAreas,gradeIIListedBuildings and Schedule Monuments are located around the study area. However,noneofthesehaveasignificantvisualconnectionwiththesite.

There are no Public Rights of Way (PRoW) crossing or the site.

The Tandridge District Council’s Part 3 Green Belt Assessment indicates that “as a matter of planning judgement, that this site does justify the exceptional circumstances necessary to recommend amendment of the Green Belt boundary".

Landscape

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Landscape Receptors

These are individual elements of the landscape fabric and the area’s landscape characterthatmaybeaffectedbytheproposeddevelopment.Topographyand Landscape features are summarised on page 50.

Landscape Character

Landscapecharacterisdefinedas:

“A distinct, recognisable and consistent pattern of elements, be it natural (soil, landform) and/or human (for example settlement and development) in the landscape that makes one landscape different from another, rather than better or worse” (Natural England).

ThesiteanditsimmediateareaofvisualenvelopelieswithinNationalCharacter Area (NCA) 121 ‘Low Weald’ which is described as follows:

‘TheLowWealdNationalCharacterArea(NCA)isabroad,low-lyingclayvalewhich largely wraps around the northern, western and southern edges of theHighWeald.Itispredominantlyagricultural,supportingmainlypastoralfarmingowingtoheavyclaysoils,withhorticultureandsomearableonlightersoilsintheeast,andhasmanydenselywoodedareaswithahighproportionof ancient woodland. Around 9 per cent of it falls within the adjacent designatedlandscapesoftheSurreyHills,KentDownsandHighWealdAreasofOutstandingNaturalBeautyandtheSouthDownsNationalPark.Around23percentoftheareaisidentifiedasgreenbeltland.’

‘Theareaisgenerallywetandwoody.Itisdissectedbyfloodplainsand

itsimpermeableclaysoilandlow-lyingnaturemakemanyareaspronetolocalisedflooding.Pondsarecommon,oftenalegacyofironandbrick-makingindustries.Gillwoodlandisaparticularfeatureandavaluablehabitat,scarceelsewhereinthesouth-eastofEngland.DespiteitsproximitytoLondonandcontinuingpressurefordevelopment,theLowWealdremainsessentiallyruralincharacterwithsmall-scalevillagesnestledinwoodlandandmanytraditionalfarmbuildings,includingoasthouses,whicharetypicalintheeast.’

Visual Baseline

The site is very well contained within the topography and landscape features describedabove.Onlylimitedfilteredviewscanbeaffordedtoadjacentfarmland to the south.

ThesiteisvisuallydisconnectedfromnearbysettlementssuchasSouthGodstone,LaghamManororAnglefieldCorner

Visual receptors

Aruphaveidentifiedanumberofvisualreceptorsinthelocalareawhereitmaybepossibletogainafull,partial,glimpsedordirectviewofthesite.

Selectedpublicandprivatepublicviewpointshavebeenidentifiedfromthedesk study for assessment. These views and their assessments include:

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Local views

• Views 1 and 2, views from users of PRoW 250m to the west of the site -Low sensitivity, medium magnitude of visual change results in a slight significance for this visual receptor.

• View3-ViewsfromLowerSouthPark1kmtothesouthofthesite-Medium sensitivity, low magnitude of visual change results in a slight significance for this visual receptor.

• View4-ViewsfromRedhilltoTonbridgeRailwayLinealongthenortheasternboundaryofthesite-Medium sensitivity, medium magnitude of visual change results in a moderate significance for this visual receptor.

• View5-fromusersofPRoW1kmtothesoutheastofthesite-Low sensitivity, medium magnitude of visual change results in a slight significance for this visual receptor.

• View6-representativeviewsfromusersofTilburstowHillRoad(RomanRoad)-Low sensitivity, low magnitude of visual change results in a slight significance for this visual receptor.

• View7-ViewsfromGodstoneTrainStationplatform750mtotheeastofthesite-Medium sensitivity, low magnitude of visual change results in a slight significance for this visual receptor.

• View8-RepresentativeviewsfromresidencesatTerracottaRoad-Medium sensitivity, negligible magnitude of visual change results in a negligible significance for this visual receptor.

Medium distance views

• View (9) from Long Distance Footpath ‘Greensand Way’ and Tilburstow Hill

• ViewfromGodstoneConservationArea(Noview)

Thesensitivityoftheonlymediumdistancevisualreceptor(9)ismedium.Themagnitudeofvisualchangeforthisreceptorislowandthesignificanceis also negligible.

Long distance views

• View 10 from Surrey Hills AONB and North Downs Way Long Distance Footpath

• View11fromGattonParkRegisteredParkandGarden• ViewfromNationalCycleRoute21atWhitebushes(Noview)• ViewfromOutwoodConservationArea(Noview)

Thesensitivityofthelongdistancevisualreceptorsrangesfromveryhigh(10) to high (11). The magnitude of visual change was negligible in all cases andthereforethesignificancerangesfromnegligible(10)toslight(11).

In light of these views, Arup conclude that the only visual receptor that is likelytoresultinamoderatesignificantimpactistheviewfromtherailwaylineandthiswillonlyeffectpassengersoftrainstravellingtherein.

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Theprincipallandscapeandvisualconstraintsandopportunitiesforthe site comprise:

Constraints

• itslocationwithintheMetropolitanGreenBelt;

• itslocationistothesouthofanAreaofGreatLandscapeValue(AGLV);

• there is a designated Area of Outstanding Natural Beauty (Surrey Hills AONB) 5 km to the north of the site;

• theamenityoflocalresidencesparticularlyatRushtonAvenue,LowerSouthParkandtotheeastofFurzeWood;

• the Redhill to Tonbridge Railway Line immediately to the north of the site forms a physical barrier to the site with regards to access; and

• thesettingandcharacterofthesurroundinglandscapeisveryprominent in the wider context and in contrast with the current land use of the site.

Opportunities

• theCouncilintheir2016LandscapeCapacityStudyconsiderthatthere is medium/high landscape capacity for employment development (subjecttodetailedconsiderations);

• thesitesitsonlowlandandissurroundedbygentlyelevatingland.Thisexistingtopographytogetherwiththeman-maderailwayembankmentprovideanexistingscreenandanenclosedvisualenvelope;

• theexistingmaturevegetationaroundtheperimeterofthesiteprovidesa strong boundary and visual screen;

• toprovidenewnativeplantingwithinthesite;

• tomakeefficientuseofland,whilstrespectingexistingboundaryplanting;

• thepotentialtomaintainandmanagethesitetoenhanceitslandscapesettingandbiodiversity;

• thereisapotentialtoimproveaccessandthereforethevisualamenityofthe Green Belt;

• thepotentialtoprovidespacesforrecreationforthesiteusers;and

• thepotentialtoimprovethecharacterofthesiteandblendedwiththesurroundingarea,respectingandenhancingexistinglandscapefeatures.

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Potential landscape impacts

Arup consider that due to the enclosed and visually contained nature ofthesite,whichisaresultoftheexistingtopography,densematurewoodland and tree belts around its perimeter, in principle the site isappropriateforre-developmentfromalandscapeandvisualperspective,aslongastheexistingwoodlandandhedgerowsareprotected as far as possible.

Arupnoteanumberofkeyconsiderations.

• vehicularaccessfromTerracottaRoadisappropriatefromalandscapeandvisualperspective.Arup’srecommendationistokeepalltheexistinghedgerowsandtreesnexttotheroadandwithintheadjacentfieldboundaries,thereforeanyvegetationlossshouldbeavoided;

• intermsofthelocationofdevelopment,inlandscapeandvisualterms Arup recommend that the combined energy centre is most appropriatelylocatedonthenorth-westerncornerofthesiteaspertheproposals,wheretheexistingembankmentandmaturewoodlandplantingprovideafullscreentothenorthandwest.Existingplantingtothesouthandproposednewplantingandbundtothesouthandwest will help screen the massing of the proposed buildings;

• Arup recommend that development proposals would need to be of an appropriatescaleandmassingsoastonotgiverisetotheperceptionofsettlementcoalescence.Therefore,developmentshouldbesetbackfromtheexistingrailwaylineandpublicroads.Mosttreesonthe north and western boundaries appear to be over 25m in height, moreinsomecases.Thisissignificantlyabovetheheightofbuildings

proposed;

• proposalsneedtobesympathetictoexistingsitefeatures,andsuchfeatures should be retained and respected for the value they bring to the scheme; and

• thesitehastheopportunitytoproviderecreationalvalueassociatedwiththe former quarry. This opportunity should be explored wherever possible. Inadditiontothattheproposedlayoutwillbringnumerousbenefitsforecologyandbiodiversity,particularlyonthewesternsectionofthesites.

Topography

ThesouthwesternsectionofthesitewillberegradedtoformalandscapeareawithaSUDspondatthelowestpointatapproximate76AOD.Newfacilitybuildingsareproposedatexistinglevels(approximately82AODatthe sites highest point). Various new landscape bunds will be located within thesitetohelpblendthenewstructureswiththelandscape.Thesensitivityof this receptor is medium and the magnitude of change is low due to the localisedimprovementswiththenewbunds.Theresultedsignificanceisslight(positive).

Land Use

Duetothecurrentusesofthesitethesensitivityofthisreceptorislowandthemagnitudeofchangelowwhichresultsinanegligiblesignificance.

Landscape Features and Structures

Theexistinglandscapefeaturesandespeciallytheboundaryplanting,provide

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animportantfunctioninthesettingofthesitearea,thereforethesensitivityofthisreceptorismedium.Theproposeddevelopmentintendstokeepalltheexistingboundaryplantingandenhanceitwithnewplantingandlandscapefeaturessuchasanewgrassland,plantedearth bunds and an ecological pond. For these reasons the magnitude ofchangeismedium(positive)andtheresultsignificanceismoderate(positive).

Landscape Character

Thesensitivityofthisreceptorcanbeassessedasmediumdueto its locally valued landscape features and the fact that the key characteristicsofthelandscapeareabletoabsorbsomedevelopment.The magnitude of change is low as the proposed development will retainandsometimesenhancethecharacteristicsofthelandscape.Thereforetheresultsignificanceisslight(positive).

Conclusion

Arupconsiderthatdevelopmentatthesitehasthepotentialtocontributetotheenhancementofthelandscapecharacterandsettingofthesitebyprotectingtheexistinglandscapecharacteristicsandtheincorporationofnew wooded areas especially in and around the disused quarry. The proposed development includes important landscape enhancements i.e. ecological pondwithinthesiteandalongitsboundarieswhichwouldresultinapositiveimpact in the landscape character.

Theinterveningtopographyandvegetationprovideaconsiderablescreeningto the proposed development. There is only one visual receptor for which the proposeddevelopmentprovidesamoderatesignificantimpact(viewpoint4)andthiswillonlyaffecttrainpassengersontherailwayfromReadingtoTonbridge.Onlyslighteffectsareexpectedintherestofthevisualreceptorsapartfromviewpoint8withanegligiblesignificanceeffect.Thelandscapestrategyfortheproposeddevelopmentwillincludemitigationplantingtoreinforcesomeoftheboundaryplantingwiththeaimtoreducesomeoftheabove impacts to the category of negligible. However for viewpoints 1, 2, 3and5thesignificanceoftheireffectsisexpectedtoberetainedasslightduetotheproposed55mhighchimneystackbeingvisuallynoticeableaftermitigation.Inanycasetheseeffectsfromtheproposeddevelopmentareassessedasinsignificant.

This high level LVIA assessment has been undertaken on the basis of a proposed stack height of 55m as a worst case scenario. Technical work undertaken concludes that a stack height of 50m would be acceptable in air qualityterms.Itisworthnotingthatareducedheightofthestackcouldlead

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toaminorreductioninthevisualeffectsfromeachviewpointandwouldretaintheoverallconclusionthattheeffectsoftheproposeddevelopmentareinsignificantinoverallterms

A full detailed LVIA should be undertaken at a later stage where some of the findingsandconclusionsabovemaychangeduetomoredetailedinformationbecomingavailableincludingpotentialchangestotheparametersoftheproposed development.

Importantly, background studies have also been undertaken and conclude that on the basis that the buildings are under 30m high at a development of 75AOD,andthestackis50mtallorunder,therewillbeminimallandscapeandvisualeffectsduetothewoodedcharacterofthearea.

ThelandscapestudypreparedbyLUConbehalfofSurreyCountyCouncil(2018)supportstheallocationofthesite.ItconfirmsthefindingsofArupthat “Buildings with a height of up to 30m will affect the least number of visual receptors within 5km and a chimney stack of up to 40m will affect the least number of visual receptors within 10km. Occasional views of stacks 40m and taller would be experienced from local villages such as Tandridge in the north and Lingfield in the south as well as from scattered dwellings along rural lanes”.

The study also conducted research into the styles of the development that could increase the ability of the site to accommodate a stack over 50m. This will be considered at the detailed design stage.

Inaddition,TandridgeDistrictCouncil’sevidencebaseconsidersthesitesuitablefortheproposeddevelopmentbytheratingofmedium-highcapacity

foremploymentuseandinsettingthesitefromtheGreenBelt.

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Arup undertook an Extended Phase 1 Habitat Survey in May 2015 and based on the survey findings and recommendations, further detailed surveys for bats, dormouse (Muscardinus avellanarius), reptiles and great crested newts (Triturus cristatus) were undertaken on the site by Arup in 2015 with a follow up walkover survey in July 2018. Bat emergence surveys were undertaken by CSA Environmental in 2016 and Greenlink Ecology in 2018.

Deskbasedsurveyworkconfirmedthatthesitedoesnotcontainorholdanystatutoryornon-statutorynatureconservationdesignations,althoughtheMapleWoodSiteofNatureConservationImportance(SNCI) is located adjacent to the western boundary and is designated becauseitsupportsAncientSemi-naturalWoodlandindicatorspecies.

The site does not hold records of protected fauna, although there were numerous records of protected species in a 1km radius; including great crested newts and grass snakes (Natrix natrix).

Thesiteiscomprisedoftwodistinctparcelsofland.Theeasternparceliscomprisedofmultiplecommercialpropertiesofvaryingageandconstruction,withassociatedsoftlandscapingfeatures.Aresidentialcottageisalsolocatedatthenorthernboundaryoftheeasternsite.Thewestern parcel was historically used for quarrying purposes and at the timeofsurveycomprisedoffourpits,bareearth,scrub,semiimprovedgrassland and broadleaf woodland with overgrown hedgerows with trees.

During the period between August 2014 and October 2015 the central

area within the western parcel was cleared under the quarrying permission forclayextraction[TA99/155]andunderappropriateEcologicalClerkofWorks watching briefs. The woodland edges to the north, west and south haveallbeenretainedalongwiththepoorsemi-improvedgrasslandandscrub north of the pond in the south of the site.

Survey findings

Detailedsurveysforgreatcrestednewts,dormiceandreptileswereconducted within the site within suitable habitats, predominantly being within the western parcel. No great crested newts or dormice were recorded during the presence/absence surveys for these species.

Grasssnakesandslowworms(Anguisfragilis)wereconfirmedtobepresentwithinthewesternparcel.AllcommonreptilesareprotectedagainstintentionalkillingorinjuryundertheWildlifeandCountrysideAct1981(as amended) and this translates into a requirement to remove or exclude animalsfromareasthatwillbeaffectedbydevelopment.

A 3m strip of scrub/immature trees was carefully cleared from the northern andwesternboundariesinseveralstagesduringthefirstweekofSeptember2016(i.e.outsidethebreedingbirdseason),whilstclimaticconditionswereoptimalforreptilestobeactiveandabletorespondtodisturbance.Atnopointduringthisclearanceworkwerereptilesrecordedasbeingpresent.AtemporaryexclusionfenceconsistingofUVstabilisedpolythenemembrane was then installed along the northern, southern and western siteboundaries.DuringSeptember/October2016,undersuitableclimaticconditions,theartificialrefugeswerecheckedoveraprogrammeof20

Ecology

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separatevisitsbyexperiencedecologistsforthepresenceofreptiles.

Thetrapping/translocationexercisecontinueduntilatleastfivevisitshadpassedwithoutanyreptilesbeingrecordedasbeingpresent,afterwhichitwasconsideredthatreptileshadbeenremovedfromthewesternpartofthesiteorareonlypresentinundetectablylownumbers.Noreptileswerefoundduringthetranslocationexercise.Smallnumbersofcommonamphibians(smooth newt Lissotriton vulgaris and common toad Bufo bufo) were removedtoasafelocationinsuitablehabitatsbeyondtheexclusionfencingto the south of the overall site.

Nobatroostingbehaviourwasobservedassociatedwithanyofthetreesorbuildingsmonitoredduringthebatsurveyscarriedoutin2016.Batswererecorded foraging within the survey locality but the habitats were not judged tobesignificantforagingresourceforbats.Additionally,nokeyflightlinestoanynearbyroostsorforagingresourceswereidentified.Furthersurveyworkwasundertakenin2018byGreenlinkEcologyltdandconfirmedthatthemajorityofbuildings/treespresenthavelowtonegligiblepotentialforusebybatsandthatthelevelofbatactivityisverylow.However,ithasdetermined that very low numbers of common pipistrelle bats occasionally useasmalltoiletblockand“Bilbo’s”buildingsfordayroostpurposesandappropriatemitigationisrecommended.

No other protected species were recorded during any of the ecological surveys.

Opportunities

Thefocusofthecurrentuseofthesiteiswithintheexistingbusinessparkandactiveaggregaterecyclingandinertwasterecoveryarea,bothofwhich are generally considered to be of low intrinsic ecological value and represent the most suitable areas to support development. Given the nature ofthesite,thereislowpotentialforbiodiversityonsiteasevidencedbytheecological surveys undertaken. There is however an opportunity through the proposals to provide localised enhancements on site.

Intermsofthesitedevelopmentpotential,theeasternextentofthesite,whichiscurrentlythelocationofthebusinesspark,representsthemostsuitable area to develop. This area comprising buildings, hard standing and amenity grassland is considered to be of negligible to low ecological value. Thecentralandnorthernareasofthewesternextentofthesiteisinactiveuse(asnotedabove),andassuchalsooffersnegligibletolowecologicalvalueduetodisturbance.Assuch,thisareaalsoofferspotentialfordevelopment and/or ecological enhancements.

Thereisscopetominimiseecologicalimpactandprovidemitigationmeasures within the site to enhance the habitats for the local species andprovideanoverallbiodiversitygain.Theproposalsallowsignificantscopeforretentionandenhancementofthesehabitats.Moreover,thereissignificantscopeforecologicalenhancementandbiodiversitygainwiththe reinstatement of woodland and grasslands within the quarry area. The habitats created within this area could be species rich habitats designed to promoteandbenefitbiodiversity(e.g.nectar/berryproducingspecies),andenhancethehabitatforlocalbirds,bats,reptilesandinvertebrates.

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Thewoodlands,hedgerows,pondandpoorsemi-improvedgrasslandwhicharelocatedwithinthesouthandwestofthesitedooffermoderateecological value at a local scale. The boundary hedgerows and woodland corridors, including woodland along the rail embankment to the north, are likelytofunctionaslocallyimportanthabitatsforbats,birdsandreptilesaswellasprovidinghabitatconnectivityintothewiderarea.Assuch,itis recommended that these habitats and features are retained and kept as‘darkcorridors’(particularlyforbats),andenhancedwherepractical,ensuringhabitatconnectivitywithinthewiderarea.

Inaddition,recommendationsincludetheuseofnativespeciesorspeciesofknownbenefittowildlifeinanyecologicalenhancementsandsoftlandscaping,andtheincorporationofreptilehibernacula,andbirdandbat boxes as part of any proposed development to provide localised enhancements for these groups.

It is recommended that any redevelopment proposals for the site seek tomaximiseopportunitiestoprovidenewtreeplantingbywayofcompensationforthelossoftrees.Nativetreesareadvocated,whichonceestablishedwillofferopportunitiesforarangeofwildlife,includingbats.Inaddition,newbatroostingfeaturescanbeincorporatedintotheschemethroughtheprovisionofbatboxesonexistingmaturetreestoberetainedor within the fabric of new buildings to compensate for lost features and potentiallyincreaseroostingopportunitiesinthelocalarea.

Potential Ecological Impacts

Duetothepresenceofreptilesbeingdiscovered,thepermittedworkswithinthewesternareaarecontinuingundermethodstatementsandecologicalwatchingbriefsforreptiles(aswellasbreedingbirds).

Thebatsurveyundertakenin2018indicatedthatthereislowlevelusageoftwobuildingsasdayroosts,mitigationmeasureswillthereforeberequiredwithfurthersurveyworkrequiredshoulddemolitionberequiredorproceedbeyondsummer2020.Allbatsareprotectedagainstintentionalkillingorinjury as well as deliberate disturbance to its place of shelter under the ConservationofHabitatsandSpeciesRegulations2012andtheWildlifeandCountrysideAct1981.

Otherconsiderationsincludetheavoidanceofthebird-breedingseason(March-August)foranytree,hedgeroworscrubremoval,andaprogrammeoftreatment/eradicationfortheinvasivenon-nativeCotoneasterspeciesfound at the site would be recommended as part of the future development.

Theairqualityimpactspredictedtooccur(page72to76)asaresultoftheproposal on the SAC, two SSSI sites and SNCI ancient woodland sites are considered to be negligible (based on Sol Environment’s 2019 air quality assessment). It is therefore likely that, through the process of an HRA Appropriate Assessment (when these reported impacts are taken into accountalongsideotherfactorsthatmayinfluencetheintegrityofthequalifyingfeaturesoftheSAC),aconclusionofnosignificanteffectscanbe reached. Similarly, it is also considered likely that through the process of EcIA,potentiallysignificanteffectsontheSSSIsandancientwoodlandsitesfrom air quality impacts can also be ruled out.

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Miles White Transport Limited have prepared a baseline assessment of the local transport network (road and rail). Based on this and consideration of the proposals, they conclude that the local transport network is not a constraint to development.

Site location and access

The site is located approximately 3.2km by road to the west of South Godstone,theclosesturbansettlementofnotetothesite.SiteaccessisprovidedtotheeastviaTerracottaRoad.Thisisaprivateroadapproximately600minlength,subjecttoa20mphspeedrestrictionandaccessedfromasimplepriorityjunctionwithTilburstowHillRoad.

AsmallresidentialareaownedbyWTLambofcirca12dwellingsarelocatedbetween100-250mfromtheTilburstowHillRoadjunction.AteitherendTerracottaRoadnarrowsprovidingoncomingvehicleswithpriority.

Tilburstow Hill Road runs adjacent to the A22, north to Godstone (becomingOldTilburstowRoad)whereitmeetstheB2236(approximately3.5km) and A25 (approximately 4km). To the south Tilburstow Road is around2.2kmfromthejunctionwiththeA22EastbourneRoad.

ThejunctionoftheA22withTilburstowHillRoadisarelativelycomplexstaggeredpriorityjunctionservingthreeminorarmswithbothleftand

right turning boxes.

The A22 runs to the east of the site, this runs through South Godstone andconnectsdirectlytotheM25atJunction6andLondonbeyond.ItalsoprovidesfurtherconnectionstothesoutheastofEnglandviatheM23andA23 including to Gatwick, Brighton and forms the main route to the South Coast. Central London is located approximately 40km north, accessed via the A22.Tothesouthandwestofthesiteislargelygreenfieldagriculturalareas,with limited transport infrastructure.

Directlynorth(around50m)oftheTerracottaRoad/TilburstowHillRoadsiteaccessjunction,atrafficsignalcontrolledjunctionallowsfortrafficcontraflowas the road narrows due to an overhead rail bridge. Advanced warning signs are in place along Tilburstow Hill Road although the 40mph speed limit remainsinplacealongthefrontageofthesiteaccessjunctionapproachingthe railway bridge.

AbridlewayknownasWaterLaneislocatedapproximately630msoutheastof the site, this connects the A22 and Tilburstow Hill Road but has limited access for vehicles.

Transport

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theserunhourlybetween9am-5pmandafter7:30pm,every 30-50minutesbetween5am-9amand5pm-7:30pm,thefinalserviceisat 11:40pm.

Aswellassupportingtheregularpassengerservice,therailroutewhichtravels through Godstone sees up to seven freight trains per day in each direction-whendiversionsfromthemainChannelTunnelFreightroutethroughKentareinplace(usuallyonweekdaynightsandweekends).InadditiontothistrafficsomePurleytoCliffeaggregateservicesoperatevia the route.

Bus movement

TherearefivebusservicesservingthenearbyvillageofSouthGodstone,theseincludethe486,487,509,606and609.Busstopsarelocatedbothnorthandsouth-boundatthejunctionofTilburstowHill Road and Eastbourne Road, along Eastbourne Road and in South Godstone.

The487hasapproximatelyfiveservicesdailypassingthroughSouthGodstone, on Saturday four services and on Sunday and bank holidays twoservices.The486hasapproximatelyfourservicesdailyMondaythrough to Friday, two services on Saturday and no services on Sunday. Forboththe487and486servicestendtobeinthemorningandevening.

The 509 is the most regular bus service, there is approximately 11 services daily between Monday and Friday, with some services that only run on school daysornon-schooldays.Saturdayshaveapproximatelysevenservicesdailyand there are no services on Sunday.

Boththe606and609arepurelyschoolservices,bothhavetwoservicesattwo bus stops in South Godstone daily, these are during the morning and afternoonforschooltimes.

Pedestrian and cycle movement

LeadingfromTerracottaRoadtoTilburstowHillRoadisadesignatedpedestrianfootway, this carries on north along Tilburstow Hill Road under the railway bridgetoadroppedkerbcrossingconnectingtoafootpaththatlinksdirectlytoSouthGodstone.Thispathisapproximately700mfromtheentranceofTerracottaRoadtothebeginningofthebuiltupareaofSouthGodstone.

The local highways network

Inordertoconsiderpotentialimpactsoftheproposals,backgroundtrafficflowshavebeenobtainedusinganAutomatedTrafficCounter(ATC)onTilburstowRoad(justnorthofthejunctionwithTerracottaRoad)between13thand19thJuly2018.TheresultsaresetoutfullywithintheMilesWhiteReport.

Thetypicaltwo-wayweekdaypeakhourtrafficflowsare324and307

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Potential trip generation – data and energy centre

Given that one of the intended uses of the proposed development isfordatacentres,ithasbeenappropriatetoadoptafirstprinciplesapproachtotripgenerationinordertoreflectthespecificdevelopmentrequirements.SpecificdatacentreusesarenotprovidedwithintheTRICS database, therefore this approach is considered to produce a morerepresentativetripgenerationfortheproposeddevelopment.

Therewillbe30fulltimeemployeesonsitecoveringbothdatacentresoperatingona12hourshiftbasis.Shiftchangeovertimeswillproducethehighestemployeetripgeneration,thereforetheassumptionthatshiftchangeoverswouldoccurduringpeakhours,andthatallemployeeswould arrive/depart in single occupancy cars is considered to be a worst case scenario.

Basedontheanticipated6employeesonsiteatanyonetime,theresultanttwo-waytripgenerationis12vehiclesduringthepeakhour,consistingof6inboundand6outboundcarmovements.Onadailybasistherewouldbe36twowaymovementsassociatedwiththedatacentrestaff,ifallvisitedthesiteonanindividualday,initselfhighlyunlikely,butassessmentofthescenarioprovidesaconservativeanalysis.

Intheworstcasesituationthattheenergycentreandgasconnectionbothfail,thenalternativepowersupplywillbesoughttopowergenerators. In order to power the generators 12 hours of fuel is required. This therefore equates to 20 two way movements over the daily period. Assaidthisisaworstcasescenarioandalternativeenergysourcingviarail would be preferred.

Potential trip generation – combined cycle energy centre and renewable biofuel production plant (fuel delivery)

Developmentwillseetheintroductionofacombinedcycleenergycentreandrenewablebiofuelproductionplant,withfeedstocksbeingtransportedtothesitebyrail.Thisisaviableandappropriateoption,astheexistingLambsrailsidingisproposedtobeutilisedbythesiteoperatorswhowoulduseitfortheimportingofthefuelfeedstocks.Ithasbeenestimatedthatthesitewillrequire approximately 150,000 tons of fuel to be transported from the third party providers sidings to the proposed site for recycling. The requirement totals600tonsperdayforanaverage5-dayweek.Ithasbeenadvisedthatthe rail siding at the site, can accommodate a total of 20 wagons and one locomotiveutilisingitsmaximumlengthof310m.

OneoptionistotransportfuelmaterialfromthethirdpartyRDFprovidersusingKSAwagons.Thisoptionwouldnecessitatetheuseofadailytrainof11xKSAhighcubewagonswhichwouldprovideacubiccapacityof1,661m3andaloadcapacityof649tonnes.Thedensityofthematerialis0.47t/m3,basedonabaleweighing1.025tonnesandhavingacubicareaof2.16m3.This equates to each train possessing a carrying capacity of approximately 780tonnes,basedonamaximumloadof649tonnesitwillbeapproximately83%full.

Contracts would be on a 5 year basis for a minimum of 250 trains per year,andthattherailnetworkhasthecapacityfortheseadditionalfreightmovementsrailinformationprovidedbyDBSchenker.

Forcompleteness,itisnotedthatthetrafficgenerationfiguresetoutinfigure44 is based on the worst case scenario that the rail link is not available.

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Trip generation comparison

BasedonthebaselinesituationfromtheSPG(1,264dailytrips)comparedwiththeestimatednetdevelopmenttrips(1,639dailytripsassetoutintable44)itisclearthattherewillbeanincreasein375dailytrips.Thisisaveryworstcasescenarioandwouldonlytakeeffectiftherailway line was not available.

Potential highways impact

MilesWhitehaveconsideredthepotentialimpactoftheproposalsin respect of Tilburstow Hill Road and the A22/Tilburstow Hill Road Junction.

Tilburstow Hill Road

Theworstcaseadditionof375tripsperdayonTilburstowHillRoadequatestojustover30additionalvehiclesperhour(ifallthesetripsoccurred over a 12 hour period) or 1 vehicle every 2 minutes on average.

SuchanincreasewillnothaveasevereadverseeffectuponTilburstowHillRoad,whichcurrentlyoperateswellbelowcapacity(at27.7%)assumingalinkcapacityof13,000vehiclesperdayasidentifiedinTA46/97TrafficFlowRangesforuseintheAssessmentofNewRuralRoads.

Indeed,anextra375vehiclesovera24hourperiodrepresentsa1%increasetotheexistingtrafficvolumesonTilburstowHillRoad.

A22/Tilburstow Hill Road Junction

Theexistingjunctionwillexperienceoperationaldifficultiesin2024,withandwithoutthedevelopmenttrafficadded,asqueuinganddelaysincreasetoanunacceptable level in the PM peak period (full details are set out within the Miles White report)

Twoimprovementoptions(bothwithinhighwayauthorityland)havebeeninvestigatedforthisjunction,i.e.aroundabout(figure45)andasignalcontrolledarrangement(figure46).

The roundabout would operate well within capacity in 2024 (with and without the development in place) with an acceptable level of queuing anddelay.Similarlythesignalcontrolledjunctionwouldalsooperatewellwithin capacity in 2024 (with and without the development in place) with an acceptablelevelofqueuinganddelay.Itisthereforeclearthatthisjunctioncanbeimprovedtoprovideadditionalcapacitytoaccommodatetheworstcase scenario.

Importantly Miles White note that the Garden Village proposed by the Council at South Godstone is of such a scale that it would provide new infrastructurethatwillsignificantlyalterexistingtrafficpatternsatthisjunction(andinthearea)andpotentiallymeanthattheseimprovementsarenotultimatelyrequired.

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Sol Environment have assessed the potential air quality impacts of the proposal. In order to do this, they have assessed the potential emissions arising from the CCGT plant which would be located in the quarry area. They conclude that air quality is not a constraint for development.

Sol Environment note that the pollutants of most interest which are emittedfromtheCCGTplantaretheoxidesofnitrogen(NOx)and,inparticular,nitrogendioxide(NO2)duetoitsimpactsassociatedwithaciddeposition.Therefore,thisassessmenthasfocussedontheimpactofthe emissions of NOx on human health and habitat sites.

InadditiontoemissionsofNOxfromtheCCGTplant,trafficaccessingtheentireLamb’sBusinessParksite(includingtheCCGTplant,datacentre,renewablebiofuelproductionplant,employmentuseandexistingtraffic)willalsoresultinemissionsofNOx.Therefore,theimpactoftrafficemissionsonhumanandhabitatreceptorsisalsoprovided. For receptors located within 200m of the roadside, there is alsothepotentialforcumulativeimpactstooccurfromthecombinedimpactoftheCCGTplantandtheadditionaltrafficmovements.Therefore,forthesereceptorsacumulativeimpactassessmenthasbeenundertaken.

Background

There are no processes regulated for emissions to air within 2km of the proposed development. There are a number of regulated processes within the district, however, due to the distance from the proposed development site and the nature of the regulated processes, they

areunlikelytosignificantlyaffectambientairqualityinthevicinityoftheproposed development. Emissions associated with these processes are accountedforinlocalairqualitymonitoringdataandestimatedbackgroundpollutantconcentrationsfromDefra.AlthoughnoregulatedsourcesarepresentattheBusinessParkitself,theexistinglanduseiscommercial/industrial.

Local authority review and assessment

AsrequiredundertheEnvironmentAct1995,localauthoritiesmustreviewandassessairqualitywithrespecttotheobjectivesforsevenpollutantsspecifiedintheGovernment’sNationalAirQualityStrategy(NAQS).LocalauthoritiesarerequiredtocarryoutanUpdatingandScreeningAssessment(USA)oftheirareaeverythreeyears.IftheUSAidentifiespotentialareaslikelytoexceedairqualityobjectives,thenadetailedassessmentofthoseareasisrequired.Whereobjectivesarenotpredictedtobemet,localauthoritiesmustdeclaretheareaasanAirQualityManagementArea(AQMA).Inaddition,localauthoritiesarerequiredtoproduceanAirQualityActionPlan(AQAP)whichincludesmeasurestoimproveairqualitywithintheAQMA.

TofulfilitsLocalAirQualityManagementduties,TandridgeDistrictCouncilproduceditslatestAirQualityStatusReport(ASR)inOctober2017.This document includes a summary of the previous rounds of review and assessment.

Tandridge District Council has examined the results from monitoring and has found that all monitored pollutants have been compliant with air qualityobjectives.

Air Quality

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Background pollutant concentrations

AmbientbackgroundconcentrationsofNO2andNOxfor2017havebeenobtainedfromtheDefraUKBackgroundAirPollutionMaps.These1kmgridresolutionmapsarederivedfromacomplexmodellingexercisethat takes into account emissions inventories and measurements of ambientairpollutionfrombothautomatedandnon-automatedsites.Thecurrent background maps were issued in April 2019 and are based on monitoringandmeteorologicaldatafor2017.Forthenine1km2 grids surroundingtheCCGTplantlocation,estimatedNO2concentrationsvarybetween11.8and12.8µgm-3withanaverageof12.3µgm-3. For NOx,concentrationsvarybetween16.3µgm-3and17.8µgm-3 with an averageof16.9µgm-3.

Basedontheinformationprovided,itisassumedbySolEnvironmentthatannualmeanNO2andNOxconcentrationsattheproposeddevelopmentsiteare12.3µgm-3and16.9µgm-3 (mean of the mapped concentrations),respectively.

Methodology

The detailed methodology and all results are set out within the SOL EnvironmentalAirQualityAssessment-TechnicalNote2(August2019).Thisincludesthedetailsoftheassumptionsmade,dispersionmodellingusedforplantemissionsandtrafficemissions,studyparametersandmeteorological data.

Figure47setsoutthelocationofsensitivereceptorsthatweresubjecttomodelling.

Potential impacts

All detailed results are set out within the Sol Environment Air Quality Report. For ease of reference, a summary is set out below.

Human Health - Annual Mean NO2

DuetorelativelylowemissionconcentrationfortheCCGTplantandtheremotenatureofthesite,predictedannualmeangroundlevelconcentrationsofNO2arerelativelylowcomparedtotheAQOforNO2of40µgm-3. Thehighestreceptorconcentrationis0.2µgm-3, just 0.5% of the AQO. CombinedwithlocalbackgroundconcentrationsthePECatthislocationwould be 31.3% of the AQO. Therefore, the impact of the CCGT alone would benotsignificant.

Itshouldbenotedthattheassumedbackgroundconcentrationof12.3µgm-3adjacenttotheA22islikelytobeunderestimatedbasedontheDefra background data as it doesn’t take account of the close proximity of thereceptortoexistingtrafficflowsonthismainroad.Nevertheless,thecontributionofthedevelopmenttoannualmeanNO2concentrationsislowin comparison to the AQO and it is unlikely that the AQO would be exceeded asresultoftheadditionaltrafficonthelocalroadnetwork.

HighestconcentrationsarepredictedforTerracottaRoadas100%ofthedevelopmenttrafficwilltravelalongthisrouteandtheassumedvehiclespeedof 20mph will give rise to higher emissions compared to higher road speeds. Atthislocation,thecombinedimpactis2.6µgm-3(6.6%oftheAQO).However,backgroundconcentrationswillbelowatthisreceptorandthePEC

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is37.3%oftheAQO.Therefore,itisunlikelythatthiswouldbeexceeded.Similarly, the combined predicted impact on Tilburstow Hill Road are around 4%oftheAQObutthePEC’sarewellbelowtheAQOof40µgm-3.

Habitat Sites - Annual Mean NOx

ExceptforFurzeWoodAW,predictedconcentrationsarelessthan1%ofthecriticallevelof30µgm-3.AtFurzeWood,thepredictedconcentrationis1.2%ofthecriticallevel.However,forabackgroundconcentrationof16.9µgm-3thePECwouldbe17.3µgm-3(57.5%ofthecriticallevel)anditisveryunlikelythatthecriticallevelwouldbeexceededasaresultofemissionsfrom the CCGT plant.

For the Mole Gap to Reigate Escarpment SAC and SSSI, predicted concentrationsare1%orlessofthecriticallevelandtheimpactwouldbeassessedasnotsignificant.

FortheGodstonePondsSSSI,thecombinedpredictedcontributionoftheCCGTplantanddevelopmenttrafficrepresents1.6%ofthecriticallevelof30µgm-3.TheAirPollutionInformationService(APIS)providesinformationonNOxconcentrationsforthishabitatwhichrangebetween17.34and21.52µgm-3.Forthehighestbackgroundof21.52µgm-3 the PEC would be22.0µgm-3(73.3%ofthecriticallevel).Therefore,itisunlikelythatthecriticallevelwouldbeexceededasaresultofemissionsfromtheCCGTplantcombinedwiththeimpactoftrafficgeneratedbythedevelopment.

Defra’sMagicMapApplicationidentifiesthispartoftheSSSIasLeighMillPond(Unit7)anareaofstandingopenwaterandcanals.Thesitewassurveyedin2008andidentifiedasunfavourableanddeclining.Thefollowingwas noted:

The pond is clearly an amenity pond, with reinforced margins and little value now in terms of aquatic and marginal habitat. There are small amounts of

Ceratophyllum demersum, and occasional small stands of Typha latifolia. No non-native aquatic plant species were observed. The water is relatively silty. The pond is overstocked with fish including roach and is used for angling.

Inaccordancewiththelatestairqualityguidanceandbestpracticeassessmentmethodologies,thefindingsofthisairqualityassessmenthavebeenassessedbyasuitablyqualifiedecologist(SQE)whohasconcludedthatthe impacts to the local habitat sites, including Godstone Ponds SSSI, from annual NOx depositionarenegligible.

Habitat Sites – Nutrient Nitrogen Deposition

AcriticalloadforGodstonePondsSSSI(standingopenwaterandcanals)is not provided by APIS. Therefore, the PC is compared to the background nutrientnitrogendepositionforthislocationof12.6kgNha-1a-1.

For the Mole Gap to Reigate Escarpment SAC, the predicted nutrient nitrogen depositionrateiswellbelow1%ofthecriticalloadforthehabitatpresentatthislocation,calcareousgrassland.Therefore,thecombinedimpactofthedevelopmentemissionsonthisEuropeansiteareassessedasnotsignificantatthislocation.

FortheGodstonePondsSSSI,thepredictednutrientnitrogendepositionrateis0.5%ofthebackgrounddepositionrateforthishabitatandtheeffectofemissionsonthishabitatisassessedasnotsignificant.

FortheMoleGaptoReigateEscarpmentSSSI,thecombinedcontributionfromtheCCGTplantanddevelopmenttrafficis1.7%ofthecriticalloadwith1.6%fromdevelopmenttrafficand0.1%fromtheCCGTplant.

Defra’sMagicMapApplicationidentifiesthispartoftheSSSIasMargeryWood(Unit24).Thiswaslastsurveyedin2008andtheconditionwasidentifiedasfavourable.Thefollowingcommentswereprovided:

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Very small unit consisting of large mature Oak, with Ash, Beech and Cherry. Scrub layer Hawthorn, Holly, Hazel Field maple and Blackthorn. Ground flora Bracken and Bramble. Very small non intervention mature broadleaved woodland. No rides as such but is on the border to unit 23 where there is a good shrubby transition to open grassland. Plenty of standing and fallen deadwood.

BackgrounddepositionratesforthispartoftheSSSIaregivenbyAPISas26.7kgNha-1a-1(morethanfivetimeshigherthanthecriticalloadof5kgNha-1a-1).Therefore,thepredictedcontributionfromthecombinedemissionsfromthedevelopmentrepresent0.3%ofthebackgroundcontribution.Furthermore,developmenttrafficflowsontheM25(assumedtobe492vehiclesperday)asaresultofthedevelopmentareasmallfraction(0.3%)oftheexisting2017trafficflow.

Inaccordancewiththelatestairqualityguidanceandbestpracticeassessmentmethodologies,thefindingsofthisairqualityassessmenthavebeenassessedbyasuitablyqualifiedecologist(SQE)whohasconcludedthatthe impacts to the local habitat sites, including Margery Wood SSSI, from nutrientnitrogendepositionarenotsignificant.

Habitat Sites – Acidification

Forallhabitats,thepredictedacidificationasaresultofcombinedemissionsfromthedevelopmentarelessthan1%oftherespectivecriticalloads/backgrounddepositionandwouldbeassessedasnotsignificant.

Conclusion

Sol Environment conclude that the air quality and habitats impacts associated withtheproposeddevelopmentarenotconsideredtobesignificantatanyoftheidentifiedecologyandhabitatreceptors.

ThenutrientdepositionassociatedwiththeNitrogenDioxideemissionsfromthe CCGT has been determined in all cases as being negligible.

Thecombinedemissionscontributionofbothprocessandtransportationimpacts are also negligible in all cases, however it is acknowledged that in oneinstance(theMargeryWoodSSSI)thetargetdepositionratesarebeingexceeded.Thisexceedanceisduetotheexistingbackgrounddepositionratesbeing5timeshigherthanthecriticalloadandnotasaresultofthespecificimpacts of the proposed development. Assessment of these results by a suitablyqualifiedecologisthasdeterminedthattheeffectsonthishabitatarelikelytobedeterminedasnotsignificantwhentakingintoaccounttheseadditionalfactors.

Theresultofthisassessmentconfirms,inasimilarmannertotheworkcarriedout by both Surrey County Council and Tandridge District Council that the air quality impacts of the proposed development at Lambs Business Park are acceptable at the scale proposed.

TheuseofahighefficiencygasfiredCCGTasameansofprovidingasitewidelowcarboncombinedheatandpowersolutionalignswiththebothSurrey County Council and Tandridge District Council’s air quality conclusions that the Lambs Business Park is suitably allocated and that air quality impacts do not provide a material constraint to the development.

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Cotswold Archaeology on behalf of Arup have considered the heritage position of the site, and established the relevant baseline situation. They conclude that there is likely to be no impact upon heritage considerations in the area.

Designated heritage assets

TherearenoWorldHeritageSites(asdesignatedbytheUnitedNationsEducational,ScientificandCulturalOrganizationUNESCO)withinthesite or study area.

There are no Scheduled Monuments within the site or within 1km of the site. However, two Scheduled Monuments in the wider area have been taken into account in this assessment, comprising:

• the Medieval Moated site at Lodge Farm (1012999), located c.1.3km southwestoftheSite(Figure48,SAM1);and

• theMedievalMoatedsiteatLanghamManor(1012795),located c.1.1km south east of the Site (Figure 49, SAM2).

ThesitedoesnotliewithinaConservationAreaoranyotherlocallydesignatedheritagearea.OneConservationAreaissituatedwithin1kmof the Site, comprising:

• SouthParkConservationArea(HER161),locatedc.340mnorthwestoftheSite(Figure48CA1).

Thirteen Grade II Listed Buildings and one Grade II* Listed Building have been identifiedasrequiringassessmentintermsofsetting,theseassetsarelocatedwithin the study area and just outside it.

Prehistoric period (Pre c. AD 70)-Noprehistoricfindsorfeaturesarerecorded within the site.

Roman period (c. AD 70 – AD 410)-NoRomanfindsorfeaturesarerecordedwithin the site.

Early medieval and medieval (AD 410 – AD 1540)-Noearly-medievalormedievalfindsorfeaturesarerecordedwithintheSite.Withinthewiderstudyareathereissomeevidenceformedievalactivity.

Post-medieval and modern (AD 1540 – present)-Inthewiderstudyareatheremanyexamplesofpost-medievalandmodernactivityrecordedintheHistoric Environment Record (HER). Within the Site there are early 19th century buildings associated with its use as brickworks. These are explored in greater detail below.

OtherbuildingssuchastheBloomeryatCinderhillc.850mwestofthesiteand the South Eastern Brick Works located within the site are examples of thelocalindustriesthatexpandedintheregionduringthepost-medievalperiod.StanstedHouse,gardenandbarnwhichislocatedc.650mnortheastof the site are recorded in the Surrey HER as good examples of a 19th century house and the garden is currently under review by the Surrey Gardens Trust asalittlealtered19thcenturygarden.

Heritage

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HER.Additionaltothisarerecordsofarchaeologicalexcavations.Thereareno historic hedgerows within the Site, although the hedgerow along the southernboundaryispartiallyshownonthe1840TitheMapandthereforequalifiesas“important”underthehistoricandarchaeologicalcriteriaoftheHedgerowRegulations1997.Thishedgerowisnotadesignatedasset,butretainssomesignificanceasacomponentwithinthelocalhistoriclandscape character. Within the wider area there are two Scheduled Monuments, one Grade II* Listed Building and 13 Grade II Listed Building.

WithintheSitethereisonenon–designatedhistoricassetrecordedontheHER;thisistheoriginalbrickworksfoundedinthelate1800’s.Twobuildings shown on the 1912 OS map associated with the brick works arestillpresentwithinthesite;theserepresenttheearly20thcenturysmallerbrickworks,thewashmillrecordedonthefirsteditionOSmapistheearliestevidenceofbrickortilemakingonthesiteandpre-datestheacceptedfoundationoftheworksin1897.Noabovegroundevidenceforthis feature survives.

GuidanceregardingbrickworksislocatedwithintheListingSelectionGuidefor Industrial Buildings (English Heritage, 2011) which discusses industrial buildingsasawhole(thereishowevernospecificdiscussiondirectlyrelatingtobrickworks).Basedontheseselectioncriteria,itisconsideredthat although the early 20th century structures within the site are of some historicalvalue,theyarenotofaqualityorconditiontowarrantstatutorydesignation,andatbestcanbeseenasbeingoflowheritagevalue.

The proposed development may have an impact on some of the current extant structures of modern origin, these are mainly storage containers and

temporaryunits.Thebuildingsshownonthe1912OSmapstillextantonSitemayundergoalterations.

ModerndevelopmentwithintheSitehasresultedinextensivealterationtothe historic landscape character. Surviving features of the former local historic landscape character comprise the hedgerow along the southern boundary, whichqualifiesas“important”.However,thisdoesnotcompriseadesignatedheritageassets,anddonotconferaspecificlevelofheritagesignificance.

Setting assessment

Two Scheduled Monuments, one Grade II* Listed Building and 13 Grade IIListedBuildingsandSouthParkConservationAreawereassessedwithregardtopotentialchangeswithintheirsettinghavinganimpactontheirsignificance,asdescribed.However,ithasbeenconsideredthatthesitedoesnotimpactupontheirsettingnordoesitformpartofthesettingofanydesignated asset.

Conclusion

It is clear from the assessment undertaken by Cotswold Archaeology that it can be concluded that there are no overarching heritage constraints and the Site could accommodate the proposed uses which would not harm the cultural heritage resource within the surrounding area.

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Arup have undertaken an assessment of hydrology within the local area, including in respect of flood risk and drainage, they conclude that there is very low risk in terms of fluvial or surface water flooding.

The site is located in southern England approximately 50km inland at an elevationofapproximately75mAODatthecentreofthesite.Thereisnoriskfromtidalflooding.

The site is located at the catchment boundary between the Rivers Medway to the east and the River Mole to the west. The main part of the site lies within the catchment of the Ray Brook, the watercourses leavingthesitetotheeastoutfallingviatheRayandEdenBrookstothe River Eden at Edenbridge. The River Eden is a tributary of the River Medway, which it joins at Penshurst, 9km upstream of Tonbridge.

ThesouthwesternportionofthesitehoweverappearstojuststraddlethetopographiccatchmentboundaryandsheetflowsinextremeconditionsmayoutfallintotheheadwatersofatributaryoftheRiverMole to the west, which the watercourses join via the Salfords Stream betweenHorleyandReigate.Inaddition,dischargefromasurfacewaterattenuationfacilitylocatedinthislowpartofthesitecoulddischargetothe western catchment.

As the site is located at the very top of the catchment, the Environment Agency’s broadscale modelling does not provide site level detail on the Flood Map for Planning or the Map of Risk of Flooding from Rivers and Sea(modellingoutput).TheseplansdohoweverdefinetheFloodZonewithin which the site is designated.

The site is shown in Low Probability Flood Zone 1, within which the probabilityoffloodingisestimatedtobelessthan0.1%AnnualExceedanceProbability (AEP), as shown on the Environment Agency’s maps.

Surface water

TheriskofsurfacewaterfloodingisshownontheEAwebsitemapsasgenerallybeingverylowapartfromanareapassingtothewestoftheexistingdeveloped area of the Business Park. Other isolated areas shown in the site areexistingpondsandlocalisedshallowdepressionswithintheareaofthesite now used for aggregate recycling and inert waste recovery.

Lowriskmeansthateachyearthisareahasachanceoffloodingofbetween0.1%and1%.Mediumriskisforchanceoffloodingofbetween1%and3.3%,whilsthighriskisforachanceoffloodingofgreaterthan3.3%.

Floodingfromsurfacewaterisdifficulttopredictasrainfalllocationandvolumearedifficulttoforecast.Inaddition,localfeaturescangreatlyaffectthechanceandseverityofflooding.ForexampletheEAplansbelowforthe‘low probability’ suggest that the origin of the surface water risk is the railway line to the north.

Proposed levels and the surface water strategy will be designed to ensure that surface water is directed away from buildings and into areas with less sensitivitywithinthesiteboundary.Overlandfloodrouteswillbeconsideredand developed at the next design stage.

Hydrology

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Historic flooding

Nohistoricfloodproblemswereidentifiedanywhereinthevicinityofthesitein the Tandridge District SFRA.

Groundwater

Theareaisnotnotedasbeingsubjecttogroundwaterfloodinganditislikelythattherailwaycuttingandtunneltothenorthwestcontrolgroundwaterlevels in the vicinity of the site to some extent.

ThesiteisnotwithinanyGroundwaterVulnerabilityorSourceProtectionZone;therearenosuperficialorbedrockaquiferdesignationscovering the area.

Flood risk from the site

Thequarryareaistobere-landscapedaspartofthedevelopmentproposals.

The landscaping of the area provides the opportunity for controlling and restrictingrunofffromthesiteinastructuredwaytoensurethatsurfacewater from the development area as a whole does not impact on reaches downstream either now or in the future as climate change results in more intense storms and greater storm depths.

A detailed surface water management scheme will be developed in due course,itisexpectedthiswouldbesubjecttoaconditionrequiring finaldetailstobeapprovedbythelocalplanningauthoritybeforedevelopment commences.

Potential impact on hydrology

ThepreliminaryfloodriskassessmentidentifiesthesiteissituatedinLowProbability Flood Zone 1 (<0.1% AEP/1 in 1000 year RP) and that neither a SequentialTestoranExceptionTestisrequiredfordevelopmentonthesite.

Theassessmentdoesshowthatthereisalowprobabilitysurfacewaterfloodriskaffectingthesite.Detailedlandscapeandsurfacewaterdesigncouldaccommodatethisthroughon-sitefloodstorageattenuationbeforedischargeto downstream watercourses.

The reinstatement of the quarry area provides the opportunity for restrictingflowsfromthesitetoexistinggreenfielddischargeratesorbetter,andcateringforclimatechangeimpacts.Indeed,thedetailedquarryreinstatement and landscaping proposals will include measures to ensure that developmentplotswithinthesitehavealevelofprotectionofbetterthan0.1%AEP(1in1000yearRP)fromallsourcesoffloodrisk.Inaddition,onand site surface water discharges will be further restricted to contribute to reductionoffloodriskdownstream.Itisexpectedthatthiscanbedealtwiththrough the detailed design stage.

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Sol Environment have undertaken a summary of the waste baseline situation within Surrey. The baseline demonstrates the significant amount of waste generated from within Surrey that is dealt with either out of the Country or out of County. It concludes that there is significant scope for the proposal to treat locally derived waste in a sustainable manner.

Adetaileddescriptionoftheproposalsissetoutonpage30,however,itisnotedforeaseofreferencethatthebiofuelproductionplantwillutiliseRDFfuelimportedbyrailfromalocalsupplier(suchasDay’s)utilisingtheirrailsidingconnectingtoWTLamb’sprivatelyownedrailsiding.Day’sareoneof a number of local based recycling and aggregate supplier which operates within the County (their nearest usable railheads are located within Woking and Salfords). Compacted or bailed material can be obtained from within Surrey and supplied to the rail siding.

Therenewablebiofuelproductionplantwillprocessapproximately150,000tonnes of waste material per year sourced from municipal, commercial andindustrialprocessingfacilities.AllRDFwillbepre-treatedtoensurethat all recoverable and recyclable materials are removed prior to being transported to the facility. Ordinarily, the waste to be handled by the Plant isunrecyclableandwouldbesenteithertowasterecoveryfacilitiesortolandfill.Instead,thisprocesswillseethewastebeingrecycledtocreateabiofuel.

ThissectionsetsoutthewastebaselineoftheLambsBusinessParksiteandSurrey and the South East of England. The baseline is set out to provide the contextforthegenerationofandthesuitabletreatmentcapacityforwastearising in Surrey. In this case Arup and Sol Environmental have focused

on both commercial and industrial waste streams (C&I) and Local Authority Collected Waste (LACW) in Surrey County Council’s (SCC) Waste Needs Assessment(Table24)(May2019)andfigure52opposite.

Current Waste Generation in Surrey (These waste figures relate to the area within the Surrey Joint Municipal Waste Management Strategy, covering the 11 District and Borough Council Waste Collection Authority).

ThetotalwastearisingintheSWPareawasreportedtobe3,711,000tonnesin2017,(seeFig52).Atotalof536,000tonnes(14%)wasrecordedasLACW,682,000tonnes(18%)asC&Iwaste,and2,494,000tonnes(67%)asCD&Ewaste.

Ofthetotalwasteproduced,in2017,855,000tonnes(23%)wassenttolandfill,2,137,000tonnes(58%)wasrecycledand64,000tonnes(1.7%)wassenttoorganic/foodwasteprocessingand655,000tonnes(18%)wassenttoother recovery.

The 212,000 tonnes of residual LACW sent to energy recovery were exported from the County for treatment. The LACW was recovered at Allington energy fromwaste(EfW)facilityinKent(41%),LakesideEfWinSlough(10%),StobartBiomass,Thurrock(8%)andfacilitiesoutsidetheUK(41%).

Waste

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Waste infrastructure capacity in Surrey and the South East

Theexistingavailablewasteinfrastructurecapacityandtheyearlyinputtonnage, published by the Environment Agency (EA), for Surrey and the South East of England regional area is shown in Fig 53. The LACW and C&IincinerationisassumedtobeEfWcapacityinthiscontext.

There is no EfW capacity available in Surrey, meaning that 100% of waste sent for recovery is exported outside the County, as reported above.Thisisconfirmedinpara3.2.1.2ofthe2019WasteNeedsAssessment.

The total EfW capacity that is currently available in the South East of Englandisoperatingalmostatcapacity,showninFig53,withonlyafurther 45,002 tonnes of remaining capacity across the region.

SueziscurrentlybuildinganEcoParkatCharltonLane,Shepperton.Thefacilityisbeingdeveloped,underinstructionfromSurreyCountyCouncilfor the treatment of a third of the LACW waste produced in Surrey. The EcoparkwillincludeagasificationEfWfacility,whichwilltreatupto55,000 tonnes a year of waste collected from homes in northern Surrey and also from some local businesses. It is due to open in 2019/20.

InlinewiththeJointMunicipalWasteManagementStrategy,SurreyCountyCouncilismovingtowardsitstargetforsendingzerowastebeingtolandfillby2019/20.

This means that, the current 232,000 tonnes per year of LACW and C&I wasteproducedinSurreythatiscurrentlysenttolandfill(seetable24ofthe2019WasteNeedsAssessment)willneedtobetreated.Ifthetotalnon-hazardouswasteinputtolandfillinSurreyisconsideredthisrisesto855,000tonnesperyear,whichmayincludebothCD&Ewasteandnon-hazardouswaste.

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High level consideration of proposals

ThedevelopmentoftheproposedrenewablebiofuelproductionplantatLambsBusinessParkwouldhavevariousassociatedopportunitiesandconstraints.

Opportunities

The proposed facility could accept locally sourced waste material that is currentlyexportedoutofCounty.Thiswouldbeinlinewiththenationalwaste planning policy regarding the proximity principle of waste management.

The waste baseline (fgure 55 over) shows that there is currently 444,000 tonnes per year of LACW and C&I waste which could be used within the biofuelproductionplant.Only212,000tonnes(or47.7%)ofthisiscurrentlysent to other recovery, mostly out of County. To meet the SWP strategy aim ofzerowastetolandfillasignificantincreaseinwastedivertedfromlandfillwill be required. The combined capacity of the Shepperton EfW facility and theproposedLambsBusinessParkrenewablebiofuelproductionplantfacility(with a capacity of 150,000 tonnes per year) would provide the County with 205,000tonnesperyearEfWandtreatmentcapacity,97%ofthewastecurrentlybeingexportedoutofSurreytoEfWand46%oftheresidualLACWand C&I waste currently produced in Surrey.

Thesiteiswellpositionedforarenewablebiofuelproductionplantasitislocatedawayfromahighdensityofresidentialpropertiesandothersensitive

Future Waste Generation and Management Capacity

Between2017and2035,110,808additionalnewhomeswillberequiredtomeetneedsandthelocaleconomyisforecasttogrowby3.1%.Usingtheseinputspredictedwastefiguresfortheperiod2018to2035havebeenpublished (table 54) within the Waste Needs Assessment (2019).

LRMPlanninghascriticallyreviewedtheCountyCouncil’sforecastsandhaveidentifiedanumberofissues.Accordinglyarevisedforecasthasbeenproducedwhichidentifiesthatthetotalwastearisingat2035willbe4,150,020 tonnes.

Year Waste from Households

Commercial & Industrial

Construction, Demolition & Excavation Waste

2017 536,000 682,000 2,494,000

2035 601,020 1,055,000 2,494,000

Fig 54: waste arising forecast

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receptors.

The current site land use is characterised by a range of light industrial activitiesandhasalonghistoryinbrickmanufacturing.Whilethesitelandallocationdoesnotincludeforwastemanagementtherearewasteactivitiescurrentlycarriedoutonthesite,aspartoftheexistinguse.TheLambsBusiness Park site includes a rail head. The majority of RDF would be brought tositeusingthisrailheadwherepossible,limitinganypotentialtrafficimpacton the local road network. There would only be a minor impact from the Lambsrenewablebiofuelproductionplantfacilityfromstaffandmaintenancevehicles.

RDFwillbedeliveredtotheexistingrailheadsoperatedbyalocalsupplier(suchastheDayGroupwhohavefacilitiesatWokingandSalfords)foronwardtransportationtothesitemeaningthatsupplyofRDFtositeshouldnotimpactthetrafficnetworkanywhereinthecounty.

NetworkRail(inaletterdated7thMarch2019)indicatedthatWTLambscould“effectivelystartrunningtrainstomorrow”andthattherefurbishmentandreconfigurationtoaccommodatetheproposedcontainerisedRDFtrainsis“entirelyinlinewiththeoperationalparametersofournetwork”.

Theletterconcludesbysayingthat“yourrailfeddevelopmentalignsbothwithGovernmentpolicyaroundmodalshiftandNetworkRail’sforecastsforfurtherrailfreighttraffic;wethereforewelcometheresumptionofrailfreighttrafficfromGodstone”.

Constraints

Itisconsideredthattheexistingtransportnetworkcanaccommodatetheproposalswithoffsitejunctionimprovements.MilesWhitehaveassessedthepotentialimpactsonthelocaltransportnetworkbasedonaworsecasescenario whereby the rail siding is not available.

Asummaryofthefindingsaresetoutwithinthisdocumentandcanbeviewed in the Miles White Transport Note. Summarily this concludes that there is likely to be an increase of trips from the site, but it advises that improvementscanbemadetotheA22/TilburstowHillRoadjunction(figures45and46).

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Impact of development

Theproposedfacilitywoulddevelopaleadingrenewablebiofuelproductionplant at the Lambs Business Park site. The facility would have a capacity to treat approximately 150,000 tonnes of RDF.

Currently all RDF wastes produced within Surrey are exported for treatment outside the County. For the purposes of this report we have assumed that the proximity principle would be employed in sourcing waste from Surrey and the surrounding area which is in line with the Proximity Principle set out in theupdatednationalwasteplanningpolicy,PlanningforSustainableWasteManagement.

Theproposedrenewablebiofuelproductionplanthasthepotentialtoprovidetreatment capacity within the county for up to 32% of the current waste thatissuitableforrecoverythatiscurrentlysentoutofcountyorlandfilled(463,000tonnes).

TheJointMunicipalWasteManagementStrategyforZeroWastetoLandfillwill result in the need for more waste to be treated. Some of this waste will be diverted higher up the waste hierarchy meaning that further capacity will be required.

TogetherwiththeoperationoftheSuezEfWfacility,currentlyinconstructionat Shepperton, this facility would reduce the need to export residual waste out of the county.

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Conclusion9.1Introduction

This document has been prepared by LRM Planning on behalf of WT Lamb. Its sets out development proposals for Lambs Business Park that would enabletheconstructionoftwodatacentres,acombinedcycleenergycentrewithbiofuelproductionplantandtheintensificationandredevelopmentofother parts of the site.

WTLambhavebeenoperatingatthesitesince1918.Originallythecompany’sfocuswasintheproductionoftilesandhighqualitybricksbuthasmorerecentlyinvolvedtherestorationoftheformerclayworkingsandmanaging the business park which in areas is becoming derelict and there is a strong risk that some buildings will soon become vacant.

It is now proposed to invest in the long term future of the Park. The proposed uses would regenerate Lambs Business Park as a high quality, highly productivetechnologycluster.

Inpreparingandrefiningproposalsasignificantamountofbackgroundworkhas been undertaken by sub consultants on behalf of WT Lamb. This has shaped and informed the proposals and is expected to form the basis for future detailed work.

9

Documents

Summary Comments Regarding Proposed Main Modifications€¦ · Business Park, including the ‘Key Development Issues’ identified for the site. Summary Comments Regarding Proposed