Crispin Blunt

Conservative Party | Reigate

Shagbrook - Potential Mineral Zone 60

Roger Hargreaves,
Head of Planning
Surrey County Council,
County Hall,
Kingston-upon-Thames.
Surrey, KT1 2DY

1st December 2004

Dear Mr Hargreaves,

MINERALS DEVELOPMENT FRAMEWORK – PMZ 60 SHAGBROOK

It is my view and so far the unanimous view of my constituents as expressed to me that Shagbrook should not be included in any future Minerals Development Framework. The environmental consequences for the local community and the cumulative impact of a number of existing mineral exploitations in close proximity would be devastating.

I am concerned by the serious long term implications for any major mineral development on this site adjacent to an SSI and in an Area of Outstanding Natural Beauty. In my opinion it would be bordering on the criminal to expose this site, nestling as it does under the North Downs escarpment in the middle of the London green belt, to a probable four decades of extraction and subsequent waste infill. Imposing such an environmental price on an area already under enormous environmental pressure should be avoided if the nation has any reasonable practical alternative supplies of sand available to it.                                                                                                                
Key Issues include:

Access

The only possible access onto the A25 would be on the Buckland Bends,   a notorious accident black spot.

Environment

The Shagbrook site is located within the Green Belt and is traversed by Rights of Way.

Existing mineral workings already restrict land available for the community to enjoy.

The site includes an area of Ancient Woodland – which we cannot  afford to lose.

The provision of buffer zones for planting would not alter the fact that there would be a significant visual impact, coupled with a substantial potential noise impact for residential properties within 70m of PMZ 60, in addition there would be the environmental impact of potentially four decades of extraction.

Ecology and Nature Conservation

The hydrological integrity of the Shag Brook and Reigate Heath would both be broken.  
                
Conclusion
               
I have seen County Councillor Susie Garnier’s submission with which I entirely concur.  This is absolutely not the place to undertake such an excavation.
                                                                     
You will be aware of the work of the Sand Action Group, and the considerable publicity the issue has raised in the media. These are symptoms of a deep concern over the issue within the local community.   I look to the County to avoid this concern stretching into years and consuming enormous amounts of voluntary effort in a prolonged campaign.  The voluntary time of local people could be much better used elsewhere, and this is a cost that will not be measured if this site is not struck out of the Minerals Framework. I fully support the local community in preventing the Shagbrook Development, and I would be grateful for my views to be included in the consultation. 
 
Yours sincerely,

Crispin Blunt

---

SURREY COUNTY COUNCIL MEMBERS ROOM
SUSIE GARNIER – Member for Reigate Central

31st October,2004

Roger Hargreaves,
Surrey County Council,
County Hall,
Kingston-upon-Thames.

Dear Mr Hargreaves,

POTENTIAL MINERAL ZONES – MINERALS DEVELOPMENT FRAMEWORK – PMZ 60 Shagbrook

With reference to our telephone conversation, I write to confirm that I firmly consider that the Shagbrook zone should not be included in the potential zones for consideration in the Minerals Development Framework that will be going out to the next stage of formal consultation – it should be excluded now.

The technical reasons are overwhelming, with potentially disastrous environmental consequential impact and disruption to local communities.  The cumulative impact of a number of existing mineral exploitations and yet another - in such close proximity – has not been considered in this present document.  Nor has the amenity or condition of adjoining residents and their homes been addressed sufficiently. 

You, I know, are also aware of the large public attendance at the meeting in Dorking recently.

The Shagbrook site is located within the Area of  Great Landscape Value and traversed by Rights of Way.  Due to the already existing mineral workings, any further loss would simply cut up the local countryside even more and impose an ever decreasing area for the community to walk in and enjoy. 

Within the site is an area of Ancient Woodland – so much ancient woodland has been lost over the past years we cannot afford to lose any more.

Reigate Heath, SSSI (Site of Special Scientific Interest) adjacent, would be at serious risk due to the effect of local hydrology – the document itself records the need to protect the hydrological integrity of both Reigate Heath, and indeed the Shag Brook.

I am overall very concerned by the lack of  rigour and consistency in this document regarding the presentation of the isssues relating to the Shagbrook site and which lead, in my view, mistakenly, to the conclusion that this site should be included at this stage.

For instance – the Key Issues for this PMZ60 (page 157) are given as Transport, Noise and Ecology and Nature Conservation :-

KEY ISSUES

Transport – The document says for this item (60.2 page 157) “It is unclear whether any new access to the A25 would meet the required standards, but if it did it is likely to involve the removal of considerable amounts of vegetation in order to provide visibility.  In visual terms, this would be a significant visual impact.”  [Emphasis added]

So the key issue here is visual and there is not mention of actual transport issues – such as could the road network sustain the impact of more vehicles.  Also, what does the above extract paragraph mean?  Any new access to the A25 would surely have to meet the required standards – but probably what should have been said here is that the only possible access onto the A25 would be on the Buckland Bends!!  A notorious accident black spot.

Para 60.5 page 159 asserts “The Landscape and Visual assessment  has indicated that with the provision of buffer zones for planting there would be no significant adverse impacts resulting from mineral extraction on the land.”

This is clearly in direct conflict with para 60.2.  There would be a significant visual impact.  As far as the Landscape is concerned – the potential adverse impact is apparently not a Key Issue – it is not discussed.!!  Only this isolated statement.

Noise  -   para 60.2 page 157  “Potential noise impacts for residential properties within 70m of PMZ.”

Yet for zone PM59 it is for within 150m of PMZ??

Ecology and Nature Conservation

“Potential working of this PMZ should be in accordance with Policy SE7 and SE9 of Surrey County Council Structure Plan Deposit Draft December 2002 incorporating proposed modifications June 2004.” 

Referring to para 60.5 page 159 – it reads

“The key issues would appear [sic] therefore to relate to hydrology and restoration.  The hydrological integrity of the Shag Brook and the Reigate Heath would both need protecting.

This should have been included as a Key Issue explicitly. Since it was not, mitigation has also not been explicitly addressed in para 60.3 page 158.

Neither in these ‘Key Issues’ is any explicit reference made to the potential loss of the Ancient Woodland on the site – not addressing this is frankly extraordinary.

I find that the issues combined and the cumulative impact of all the relevant technical and environmental constraints of this site, including adverse impact on residents and the community and the incomplete attention to/presentation of Key Issues should encourage you to positively exclude this zone from the Minerals Development Framework now, so that it is not included in the revised document that will be produced following this round of public and member consultation.

Yours sincerely,

Susie M. Garnier
Surrey County Councillor

Cc David Davis, Helyn Clack