Covers Quarry, Westerham , Kent, TN16 2ER

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Inquiry held on 3 - 6 June 2025 and 11 - 12 June 2025 Site visit made on 2 June 2025 by Stephen Normington BSc, DipTP, MRICS, MRTPI, FIHE, FIQ an Inspector appointed by the Secretary of State Decision date: 30/07/2025 Appeal Ref: APP/W2275/W/25/3358947 Covers Quarry, Westerham, Kent TN16 2ER • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) against a refusal to grant planning permission. • The appeal is made by Morants Promotions Ltd against the decision of Kent County Council. • The application Ref is SE/18/3435 (KCC/SE/0495/2018). • The development proposed is the stabilisation and restoration of Covers Farm Quarry using imported engineering materials to restore the site to grassland, including landscape planting and an ecological receptor area together with a temporary road and ancillary buildings. Decision 1.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The appeal is allowed and planning permission is granted for the stabilisation and restoration of Covers Farm Quarry using imported engineering materials to restore the site to grassland, including landscape planting and an ecological receptor area together with a temporary road and ancillary buildings at Covers Quarry, Westerham, Kent TN16 2ER in accordance with the terms of the application, Ref SE/18/3435 (KCC/SE/0495/2018), subject to the conditions set out in the attached schedule in Annex E. Preliminary Matters 2. I made an extensive accompanied visit to the site and its wider surroundings on the afternoon of Monday 2 June 2025, before the opening of the Inquiry, to gain general familiarisation with the site and the locations referred to in the evidence provided in the Inquiry. The site visit followed an extensive and comprehensive itinerary prepared by the parties and Westerham Town Council. At the Inquiry, it was agreed that a further accompanied site visit was unnecessary. 3. Prior to the opening of the inquiry a Statement of Common Ground (SoCG)1 was submitted and signed by the Council and the Appellant on 17 April 2025. 4. The planning application was accompanied by an Environmental Statement (ES)2.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Prior to the opening of the Inquiry a request was made for the submission of further environmental information pursuant to the provisions of Regulation 25 of the Town and Country Planning (Environmental Impact Assessment) Regulations (as amended) 2017 (the EIA Regulations). In response to this request an Environmental Statement Addendum (May 2025)3 was submitted. This Addendum was subject to public consultation for 30 days, expiring on 28 June 1 CD 12.8 2 CD4.1 – CD4.4.4 3 CD4.6 https://www.gov.uk/planning-inspectorate

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Prior to the opening of the Inquiry a request was made for the submission of further environmental information pursuant to the provisions of Regulation 25 of the Town and Country Planning (Environmental Impact Assessment) Regulations (as amended) 2017 (the EIA Regulations). In response to this request an Environmental Statement Addendum (May 2025)3 was submitted. This Addendum was subject to public consultation for 30 days, expiring on 28 June 1 CD 12.8 2 CD4.1 – CD4.4.4 3 CD4.6 https://www.gov.uk/planning-inspectorate

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 2025. I have taken into account the comments received in response to this public consultation exercise in the determination of this appeal. However, I am satisfied that the ES, as supplemented by the Addendum, meets the requirements of Schedule 4 of the EIA Regulations. 5. The Inquiry was closed in writing on 30 June 2025 following receipt of an updated schedule of suggested planning conditions and the expiration of the public consultation period on the ES Addendum. 6. The planning application was determined pursuant to the provisions of the Kent Minerals and Waste Local Plan 2013-30. In March 2025, prior to the opening of the Inquiry, the Council adopted the Kent Minerals and Waste Local Plan 2024-39. The Council’s reasons for the refusal of planning permission refers to the policies of both the adopted (2013-30) development plan at the time the decision was made and the, as then, emerging (2024-39) development plan. I have determined this appeal on the basis of the recently adopted Kent Minerals and Waste Local Plan 2024-39. Main Issues 7.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Having taken into account the evidence before me and from what I heard at the Inquiry, the main issues are: • The relevance of the extant planning permission and alternatives. • The need for the proposed development to resolve stability issues with particular regard to hydrological and geotechnical considerations. • The effect of the proposed development on the character and appearance of the site and surrounding area. • The need for inert waste management in the County and whether the amount of inert waste proposed to be imported is justified and available to achieve the restoration objectives of the appeal site. • The effect on the openness of the Green Belt and whether the proposal would be inappropriate development in the Green Belt having regard to the National Planning Policy Framework (the Framework) and relevant development plan policies. • Whether the effects of the proposed development on highway safety and the efficient operation of the highway network, the effect of noise on sensitive receptors and the effect on heritage assets or other matters weigh in the planning balance.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision • The planning balance with particular regard to whether the proposal is inappropriate development within the Green Belt and whether it would constitute sustainable development. Reasons The appeal site and planning history 8. The appeal site comprises a former sand quarry together with an area of agricultural land to the east that forms the proposed route of the temporary access https://www.gov.uk/planning-inspectorate 2

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision • The planning balance with particular regard to whether the proposal is inappropriate development within the Green Belt and whether it would constitute sustainable development. Reasons The appeal site and planning history 8. The appeal site comprises a former sand quarry together with an area of agricultural land to the east that forms the proposed route of the temporary access https://www.gov.uk/planning-inspectorate 2

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 and haul road. The site lies within the Green Belt and within the Kent Downs National Landscape Area. 9. The site comprises two areas of former mineral extraction quarries occupying the northern and southern parts of the main site. These former sand pits are approximately 30m and 15m deep respectively and both have filled with water to differing levels. 10. The southern part of the site was granted planning permission (Ref. 75/01088/HIST) for the removal of overburden and the use of additional land for the extraction of sand. Extraction is believed to have ceased in the late 1970’s when the site was used for the stacking of tile waste under a series of planning permissions. 11. The northern part of the appeal site was granted planning permission (reference 83/01511/HIST4) in April 1985 (the extant 1985 permission) for the removal of overburden and extraction of sand in phased workings with subsequent phased restoration. This permission remains extant via a series of planning applications for the extension of time to allow for the restoration of this part of the appeal site. The latest of these applications is being held in abeyance by the Council pending the outcome of this appeal.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision 12. Sand extraction from both quarries took place from the Folkestone Bed Sands which are overlain by Gault Clay. As the geological ‘dip’ of the strata is to the north, the depth/thickness of the Gault Clay increased as the quarrying activities progressed northwards. This resulted in the removal of extensive Gault Clay overburden (up to 20 metres) to recover the sand beneath. Sand extraction ceased around 2008. 13. The approved restoration plan5 for the northern part of the site shows a predominantly open agricultural based field system with a series of gently sloping fields either side of a central valley feature that flows from a small pond feeding into a central field drainage system that runs south towards the southern pit. However, the restoration scheme remains largely unimplemented. 14. Although some restoration work on the south part of the site was undertaken, the central area was reworked with what is now referred to as the ‘gault clay saddle’ as part of the excavation of the northern quarry under the extant 1985 permission.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Overall, the appeal site remains largely unrestored and is characterised by a significant northern water body (the north lake) and a smaller sized southern water body surrounded by a mosaic of unmanaged habitats, including broadleaved semi-natural woodland, scrub and ruderal vegetation and grassland together with areas of bare ground comprised of exposed Gault Clay. 15. To the north of the proposed haul route is Westerham Wood SSSI, which comprises Gault Clay Ancient Woodland. The southeast of the site adjoins the Farley Common Local Wildlife site, which comprises a mosaic of grassland and oak woodland. The ‘Devil of Kent’ Ancient Woodland is located to the northwest of the site. 16. There are some residential properties on Farley Common lying to the southeast of the appeal site which are located on the northwestern edge of Westerham. 4 CD14.1 5 CD2.4 https://www.gov.uk/planning-inspectorate 3

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 Covers Farm lies to the southwest and comprises a Grade II listed farmhouse and an area of commercial buildings and yard on the site of an old brick and tile works. The proposed development 17. The appeal scheme proposes the importation of approximately 800,000 cubic metres (m3) of suitable engineering infill materials, comprising inert waste arising from construction sites (predominantly comprising clays, subsoils, naturally occurring stone and soils). The materials would be imported by HGV’s via a temporary access and haul road which would be constructed from the east of the main site area to a proposed additional arm of the existing A233 Beggars Lane/London Road roundabout junction. The haul road would traverse over agricultural land within the ownership of the appellant, running parallel to the M25, to join the Croydon Road entrance into the appeal site. 18. The proposals would result in the infilling of the north lake to create a restored landform which would comprise a shallow valley containing a wetland swale.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision This swale would divert the surface water drainage to a remodelled southern waterbody where it would infiltrate into the natural groundwater through the sands of the Folkestone Beds. 19. The restored site, including the haul route, would be returned to agricultural afteruse to be managed as part of the ‘Squerryes Estate’ which is owned and managed by the Appellant. The restoration scheme is proposed to be completed within six years of the commencement of the development and would also include features such as the valley wetlands, hedgerows and woodland areas. 20. The Appellant contends that the appeal proposals are necessary to stabilise the landform in the north of the site where there is evidence of the failure of the Gault Clay slopes. The proposals would result in the creation of an effective drainage system and the restoration of the former quarried areas to facilitate a return to a productive agricultural after use, which are contended to be in accordance with the key principles of the previously consented restoration schemes for the northern and southern quarries. 21.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The SoCG identifies that there are no outstanding technical or environmental objections to the proposed development from statutory consultees, subject to the imposition of suitable conditions. These include, amongst others, Natural England, Kent Downs Area of Outstanding Natural Beauty (AONB) Unit, the Environment Agency, National Highways and Kent County Council in its capacity as highway authority. 22. The main focus of the Council’s two reasons for the refusal of planning permission primarily relate to the question of whether the proposals constitute appropriate development in the Green Belt and whether the proposal constitutes sustainable development, with regard to the quantity of infill material required to address the geotechnical/land stability and drainage issues. Planning Policy Context 23. The SoCG identifies that the Development Plan for the purposes of section 38(6) of the Planning and Compulsory Purchase Act 2004 and Section 70 (2) of the Town and Country Planning Act 1990, against which the appeal proposals fall to be considered consists of: https://www.gov.uk/planning-inspectorate 4

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 • Kent Minerals and Waste Local Plan 2024 to 2039 (2025) (KMWLP); • Sevenoaks Core Strategy (2011); • The Sevenoaks Allocations and Development Management Plan (2015) (SADMP). 24. The Sevenoaks Core Strategy and SADMP do not contain any policies for minerals and waste development but relate to development generally. The Council did not refer to any conflict with the policies contained within these development plans in the reasons for the refusal of planning permission. However, I have taken into account the policies in the Core Strategy and SADMP and whether there is any conflict or significant addition to the main policies that I consider to be relevant to the determination of this appeal as set out below. 25. The only policies referenced in the reasons for the refusal of planning permission are policies CSW 1, CSW 11 and DM 4 of the KMWLP. I consider that these, and the other policies of the KMWLP identified below, comprise the most important policies in the development plan that are relevant to the determination of this appeal. 26.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Policy CSW 1 (Sustainable Development) sets out that when considering waste development proposals, the Council will take a positive approach that reflects the presumption in favour of sustainable development contained in the Framework. 27. Policy CSW 2 (Waste Hierarchy) requires, amongst other things, that proposals for waste management must demonstrate how the proposed capacity will ensure that waste to be managed at the facility will be managed at the highest level of the Waste Hierarchy practicable. 28. Policy CSW 11 (Permanent Deposit of Inert Waste) supports the grant of planning permission for the permanent deposit of inert waste where inert waste is being deposited for a beneficial use such as the restoration of landfill sites and mineral workings and not as part of a disposal operation. The policy further sets out that planning permission will also be granted where the waste is to be used in an engineering operation, other than the restoration of landfill sites and mineral workings, where it is demonstrated that there is no local Kent demand for its use in such restoration operations; and, the development involves the minimum quantity of waste necessary to achieve the benefit sought. 29.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Paragraph 6.11.2 of the KMWLP provides supporting text to Policy CSW 11 and identifies that the most recent capacity assessment shows consented capacity for the permanent deposit of inert waste in Kent may only be sufficient to meet Kent's need over the plan period to 2039. It further states that while sites in Kent currently receive a lot of inert waste originating out of the county, particularly from London, the continuation of this waste import throughout the plan period would likely require development of additional capacity to accommodate this waste. The paragraph concludes that, in light of this, Policy CSW 11 provides support to operations involving the permanent deposit of inert waste. 30. Paragraph 6.11.3 also provides supporting text and sets out that without the import of inert waste the ability to restore existing permitted mineral workings would take a lot longer. Policy CSW 11 seeks to ensure that a high priority is given to using inert waste that cannot be recycled in the restoration of existing https://www.gov.uk/planning-inspectorate 5

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 permitted mineral workings, in preference to uses where inert waste is deposited on land (e.g. bund formation or raising land to improve drainage etc). 31. Policy DM 2 (Environmental and Landscape Sites of International, National and Local Importance) sets out, amongst other things, that minerals or waste proposals in a National Landscape will be required to ensure that they are not likely to cause significant harm to the integrity, character, appearance and function, biodiversity and geodiversity interests of sites of international, national and local importance. In a National Landscape, great weight will be given to conserving and enhancing its landscape and scenic beauty. 32. Policy DM 4 (Green Belt) relates to development within the Green Belt and sets out that proposals for minerals and waste development within the Green Belt shall comply with national policy. 33. Policy DM 5 (Heritage Assets) sets out, amongst other things, that proposals for minerals and waste developments will be required to ensure that Kent's heritage assets and their settings, are conserved in a manner appropriate to their significance.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Proposals should result in no unacceptable adverse impact on Kent's historic environment and, wherever possible, opportunities should be sought to enhance historic assets affected by the proposals. 34. Policy DM 10 (Water Environment) identifies, amongst other things, that planning permission will be granted for minerals or waste development where it does not exacerbate flood risk, both now and in the future (taking account of climate change recommended uplifts) and that measures to reduce flood risk where possible are encouraged. 35. Policy DM 11 (Health and Amenity) sets out that minerals and waste development will be permitted where it can be demonstrated that the development is unlikely to generate unacceptable adverse impacts from noise, dust, litter, vermin, vibration, odour and emissions (including emissions from vehicle movements associated with the development). 36. Policy DM 18 (Land Stability) advises that planning permission will be granted for minerals or waste development where it is demonstrated that it will not result in land instability.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Paragraph 7.16.1 provides supporting text to the policy and sets out that proposals should demonstrate measures to ensure that quarry faces and slopes are stable and will not result in landslip, either within the site or on adjoining land, both during and after the lifetime of the development and during restoration and aftercare. Paragraph 7.16.2 requires a report to assess stability and address the physical capability of the land, possible adverse impacts of any instability, possible adverse impacts on adjacent land, possible impacts on local amenity and conservation interests and requires consideration of any proposed remedial or precautionary measures. 37. Policy DM 19 (Restoration, Aftercare and After-use) sets out that planning permission for minerals extraction and temporary waste management development will be granted where satisfactory provision has been made for the highest possible standard of restoration and aftercare such that the intended after- use of the site is achieved in a timely manner, including where necessary for its long-term management. https://www.gov.uk/planning-inspectorate 6

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 38. The above policy also requires restoration plans to address a range of issues where relevant in relation to the restoration and aftercare, including a site-based landscape strategy for the restoration scheme; key landscape and biodiversity opportunities and constraints; ensuring connectivity with surrounding landscape and habitats; slope stability following restoration; water and drainage issues; sources and types of infill materials. 39. Policy DM 13 (Transportation of Mineral and Waste) identifies, amongst other things, that where development requires road transport, proposals will be required to demonstrate that the proposed access arrangements are safe and appropriate to the scale and nature of movements associated with the proposed development such that the impact of traffic generated is not detrimental to road safety. In addition, the policy also sets out that proposals should demonstrate, through the submission of a transport assessment, that the highway network is able to safely accommodate the traffic flows that would be generated and that the impact of traffic generated does not have an unacceptable adverse impact on the environment or local community. 40.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Policy DM 20 (Ancillary Development) sets out that proposals for ancillary development within or in close proximity to mineral and waste development will be granted planning permission provided that the proposal is necessary to enable the main development to proceed or operate successfully. It further sets out that there should be environmental benefits in providing a close link between the ancillary development and the existing permitted uses at the site that outweigh any environmental and community impacts from the proposed development. The extant 1985 permission and alternatives 41. There was no dispute in the Inquiry that the extant 1985 permission generally provides for the northern part of the site to be restored to an agricultural use. The approved restoration scheme6 involves the reprofiling of the site such that the gradient of all slopes is between 1 in 5 (11 degrees) and 1 in 4 (14 degrees). Surface water is shown to be drained into both a small North Lake and small South Lake with water levels being maintained at 116mAOD and 115mAOD, respectively. Infiltration of water in both lakes, but particularly the south lake, is envisaged into the underlying permeable sands of the Folkestone Formation. 42.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Partial site restoration commenced in parallel with continuing sand extraction up to mid-2000s when quarry operations ceased. As a result, the approved restoration scheme was not completed and the time period for compliance has been repeatedly extended7. 43. The evidence suggests8 that the northern half of the site remains largely unrestored with unstable over-steep slopes that are not suitable for arable or crop farming; unsuitable for re-planting; prone to significant soil erosion; and, prone to instability. In addition, the proposed surface water drainage scheme was never completed. Currently surface water drainage is unmanaged and is resulting in ponding in the North Lake with little or no drainage to the underlying ground, as was proposed in the approved restoration scheme. Furthermore, it was generally accepted in the Inquiry that if the surface water drainage issue is not addressed 6 CD14.1.1 7 CD12.8 SoCG Planning History. 8 CD2.3 https://www.gov.uk/planning-inspectorate 7

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 the water levels in the North Lake will continue to rise and would likely eventually overtop (typically at about 120mAOD) and flood the adjoining land and the B2024 Croydon Road (typical level 118.5mAOD) to the north-east of the site. 44. The evidence identified above provided by the Appellant’s Geotechnical Consultants at the time the appeal planning application was being considered by the Council, suggests that where Gault Clay fill material has been used for restoration, in order to ensure stability, slopes should be no greater than 1 in 5.5 or less. It is contended that the approved restoration scheme would not satisfy this requirement. Furthermore, based on a comparison of the existing topographical survey with the proposed approved restoration scheme pursuant to the 1985 extant permission, suggests that an estimated further 300,000m3 of imported fill would be required to undertake the approved restoration scheme. 45. The approved restoration scheme did not propose or envisage a North Lake of the size that currently exists.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The evidence is compelling that the approved restoration scheme can now only be achieved by the importation of a considerable amount of inert fill material to reduce the size of the North Lake and stabilise the slopes. In this regard, the Council recognise that it is unlikely that the approved restoration scheme can now be implemented9 and I have no evidence to suggest that any formal enforcement action has been, or is being, pursued to secure its implementation. 46. There was some dispute in the Inquiry whether the extant 1985 permission provides for the importation of inert waste into the site. The description of the development in that permission does not include the deposit of inert waste. However, condition ‘x’ of the permission requires that no materials shall be used for disposal or infilling other than provided within the waste disposal site licence. Reading this permission as a whole suggests that the importation of inert fill was likely anticipated as a means of delivering the approved restoration scheme, otherwise condition ‘x’ would not be necessary. 47.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision On the basis of the submitted evidence, I consider that it is unlikely that the approved restoration scheme is capable of being delivered without the importation of a significant amount of inert fill material. Even then, there are matters of slope stability to consider, which I set out later in this decision, which are relevant in determining the amount of inert fill required. Overall, I find that consideration of the 1985 approved restoration scheme as a credible fallback position cannot be relied on without an acceptance that a significant amount of inert fill importation would be necessary to achieve this. 48. I recognise that the Council could instigate enforcement proceedings to secure compliance with the restoration requirements of the extant 1985 permission. However, that permission did not envisage that the void following the mineral extraction operations would be filled with a substantial lake and be subject to land instability issues. In this context, it is difficult to consider how the approved restoration scheme could be implemented without steps requiring the remedy of the breach of planning control requiring the removal of the lake and the resolution of the inherent land stability problems.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Given the current condition of the site, and from considerations below, such steps could only reasonably be achieved by the importation of a substantial amount of inert fill, not least to ensure the careful 9 CD10.6 - Paragraph 6.19 https://www.gov.uk/planning-inspectorate 8

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Given the current condition of the site, and from considerations below, such steps could only reasonably be achieved by the importation of a substantial amount of inert fill, not least to ensure the careful 9 CD10.6 - Paragraph 6.19 https://www.gov.uk/planning-inspectorate 8

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 filling of the North Lake without any rapid dewatering which could have a resultant detrimental effect on slope stability. 49. Prior to the opening of the Inquiry the Council provided an alternative indicative concept restoration scheme10. This scheme would involve the use of on-site material to create an acceptable landform. This would include the utilisation of existing soil, and vegetation to create a terrain that is suggested to blend in with the surrounding landscape. It is suggested that this alternative scheme would avoid any significant importation of fill by utilising suitable materials already on the site. The scheme would involve the retention of a large North Lake with drainage to a remodelled South Lake. 50. Notwithstanding the fact that this scheme is an ‘indicative concept’, there was dispute in the Inquiry regarding the extent to which soil resources are present on the site to support planting and seeding. The Appellant contends that there are two very small stockpiles in the north and west that may contain some soil, but no others and suggests that these would contain approximately 12,800m3.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision I have no contrary evidence to suggest that the Appellant’s calculation of potential soil resource may be incorrect. Although the technical evidence suggest that the concept scheme would provide an appropriate water management strategy11 I have no evidence of any cut and fill balance calculation to demonstrate its deliverability. 51. There was generally agreement between the main parties in the Inquiry that a soil depth of 1m would be necessary to provide a suitable growing medium on the site. On the basis of the calculations of the available potential soil resource present on the site, there would be insufficient material to achieve a 1m restored soil profile throughout the site. Although the Council maintain that no soil import would be necessary, on the basis of the foregoing, I do not share that view. The evidence provided by the Appellant12 suggests that significant amounts of soil (likely to be in excess of 200,000m3) would still be needed to achieve a suitable growing medium on the concept restoration scheme. 52.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Taking the above factors into account, I find that the delivery of the approved restoration scheme and the Council’s concept scheme would still be reliant on the importation of material into the site in order to achieve the objective set out in the 1985 permission of achieving an agricultural based restoration. In these circumstances, without such importation, I have found that the 1985 approved restoration scheme would not be a credible fallback position. Furthermore, the ‘indicative concept’ restoration proposal has no planning status, other than serving as an indication of how the site could alternatively be restored with the retention of a substantial area of the northern lake. 53. There was no indication in the Inquiry that the indicative concept scheme would form the basis of any planning application by any party nor is there any accompanying detail environmental information to support its delivery in planning terms. Its status is only that of indicating one way the site could be restored and I recognise that there could be numerous variations of other alternative restoration schemes.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Notwithstanding the fact that the Appellant suggests that the indicative concept scheme would involve the partial removal of ancient woodland, for the 10 CD10.9.1 – Appendix 3 to Adrian Lynham Proof of Evidence. 11 CD10.12 12 INQ15 https://www.gov.uk/planning-inspectorate 9

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Notwithstanding the fact that the Appellant suggests that the indicative concept scheme would involve the partial removal of ancient woodland, for the 10 CD10.9.1 – Appendix 3 to Adrian Lynham Proof of Evidence. 11 CD10.12 12 INQ15 https://www.gov.uk/planning-inspectorate 9

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 foregoing reasons I have attached little weight to this scheme in the consideration of the appeal proposals before me. Stability and Sustainable Drainage 54. The former quarry has been excavated through Gault Clay to expose and remove the underlying sand. The upper slopes of the northern quarry are formed in Gault Clay. It was undisputed in the Inquiry that Gault Clay is well known for experiencing slope stability failures13 and is prone to such instability even on slopes of 7o. The geotechnical witnesses on behalf of both main parties agree that slope stability at the appeal site needs to be addressed. 55. There is considerable documented survey evidence of continued shallow slope failure on the site 14. The evidence confirms that the existing Gault Clay slopes have shown signs of instability, predominantly in the form of shallow, translational type failures. Slope failures have also been documented in previous reports since the early 1990’s as part of the 1985 planning permission (SE/83/01511) for the working of the northern quarry. I observed areas at the site visit where movement in the Gault Clay slopes, particularly in SLOPE 4, had occurred. 56.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The evidence suggest that such failures are typical where the upper layers of the exposed Gault become softened due to both overburden relief and water ingress, reducing their shear strength. It is therefore likely that there are areas of failed Gault Clay on the northern slopes that are at, or close, to residual strength due to existing progressive slope failure. This ongoing slope instability is progressively creeping towards the direction of the M25 Motorway. The Gault Clay is a high/very high plasticity clay which means it is weak with respect to slope stability and is easily weakened by water ingress. 57. As the slope failures progressively move northwards, they allow further water ingress with resultant weakening of the material. There is a historical incident to the west of the site where a slope failure in the Gault Clay occurred in 2000 near Junction 6 of the M25 and extended 80m upslope from the Motorway. The clay cutting slope gradients ranged between 1:4 to 1:5 and failure in the Gault Clay occurred at a depth of some 10m over a distance of some 200m15. 58.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The credible evidence of the Appellant’s geotechnical witness identifies that it is generally accepted that in order to achieve a safe cutting slope and minimise long term risk to the M25 and surrounding properties the northern slopes will need to be at 1 in 5.5. This is also consistent with research into the stability of cutting slopes in Gault Clay16. Some of the current slopes in the Gault Clay are at a gradient of 1 in 4. 59. Stability analysis shows that the current northern slope (SLOPE 4) is unstable and there is a very real potential for a deep translation failure to affect the M25 Motorway. The Appellant’s Assessment of Options17 suggest that filling up against the unstable slopes is the only reasonably practical and economic option for the site. Dewatering the northern lake would potentially destabilise the slopes and it is common ground that such action would present a serious risk of slope 13 Proof of Evidence – Steven Wilson paragraph 2.1.1 14 ID2.1, ID2.2, ID2.3 15 CD2.1 16 ID2.5 and Proof of Evidence – Steven Wilson 17 CD2.3 https://www.gov.uk/planning-inspectorate 10

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 failure. Therefore, the appeal proposals provide for granular fill to be placed below water. The technical evidence identifies that cut materials that could be generated on site are not suitable for this purpose so imported material will be required. 60. The evidence suggests18 that delivery of the existing approved restoration scheme would require the need to dewater the current North Lake. This would not be technically feasible as it could exacerbate the risk of failure of SLOPE 4, as well as adjoining slopes. The proposed restoration scheme would involve the compartmentalisation and backfilling with granular fill below existing water levels which would provide a beneficial long-term effect to slope stability, with factors of safety improving as the restoration is brought up to final fill levels to both shallow and potential deep seated critical slip surfaces. 61. It is not possible to predict with any degree of certainty when progressive failures in the northern slopes on the appeal site may pose a risk to the M25 motorway. However, both geotechnical witnesses identify that a medium to long term risk is present.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Notwithstanding the considerable and concerning slope stability evidence provided, the comprehensive evidence of slope failures at the site suggests that stabilisation works are necessary to provide a stable landform, regardless of the impact on the M25. 62. I have also taken into account the submitted Assessment of Alternative Options19 which assesses the importation of various amounts of fill, including no importation options, on slope stability and surface water run-off. This provides a factor of safety for each option considered. Option 1 is the do-nothing scenario to leave the site as is. Option 2 involves the provision of structural retaining walls with no fill import but would leave the topography as existing. Options 3, 4, 5 and 6 involve varying amounts of fill import of 300,000m3, 600,000m3, 800,000m3 (the appeal scheme) and 1,000,000 m3 respectively. 63. The assessment identifies that Options 1 (as is) and 3 would have the worst frequency of potential slope failure because of the generally steeper slope gradients. The estimated factors of safety are all less than unity ranging between 0.6 to 0.8 and 0.7 to 0.9, respectively.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Option 4 is also inadequate for stability with factors of safety ranging between 0.71 and 1.06 (average factor of safety of 0.87). Options 5 (appeal scheme) and 6 have the overall best average factor of safety against instability of 1.36 and 1.43. The assessment identifies that engineering solutions (Option 2) are too costly or unsafe to construct given current site conditions. 64. There was considerable discussion in the Inquiry regarding the extent to which the approved restoration scheme and the Council’s indicative concept scheme may also resolve the stability issues on the site associated with Gault Clay. However, my determination of this appeal is based squarely on the proposed development before me. In such circumstance, is not for the appeal process to evaluate the relative merits of alternative schemes, particularly in circumstances where the indicative concept scheme has not been the subject of any planning application that has been formally considered by the Council. Furthermore, as set out above, such scheme is not accompanied by the relevant technical and environmental assessments that would be necessary to support such application. 18 ID2.1 19 CD 2.3 https://www.gov.uk/planning-inspectorate 11

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 65. There was also discussion whether there was sufficient investigative data to support the solution proposed by the Appellant involving the importation of the 800,000m3 of inert fill. However, I am satisfied that the evidence provided by the Appellant’s geotechnical witness is compelling in that there is enough information in order to construct a reasonably cautious ground model and that engineering options are limited. 66. Notwithstanding other considerations which are set out later in this decision, the submitted evidence leads me to conclude that there is an accepted and compelling stability issue associated with the current condition of the appeal site. The proposed development would comprehensively address this issue. 67. Turning now to drainage, there is common ground that the northern lake is on a trajectory of overtopping onto Croydon Road, as supported by the evidence which demonstrates predominantly annual rises in water level. The Council’s reasons for the refusal of planning permission do not identify any inadequacy in the proposed drainage scheme or that the proposed development would give rise to unsatisfactory drainage or flood risk grounds. 68.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The proposed drainage scheme comprises a self-contained shallow ‘valley’, incorporating surface water drainage via a ‘cascade’ of attenuation ponds to a common point in the south-east corner of the site and into a remodelled southern pond. It is proposed to drain surface run-off via infiltration-based drainage, taking advantage where possible of outcropping natural Folkestone Formation sands in this area of the site. 69. The aim of the drainage strategy is to limit, as far as practicable, runoff from the site, and thereby to minimise the impact on downstream receptors. The proposed scheme would attenuate runoff to greenfield rates to avoid increasing flood risk from the River Darent which is downstream of the site. 70. I have no compelling and contrary evidence to suggest that the proposed drainage scheme would be technically flawed, inadequate or would not comprehensively deal with the potential flood risk associated with the northern lake. 71. The proposed development would result in a stable landform for the long term which would satisfactorily address the land instability problems within the site and any threat to adjoining land, including the potential risk to the M25.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision It would also ensure that the site can be satisfactorily sustainably drained and permanently remove the current potential flood risk associated with the rising water levels in the North Lake. Consequently, there would be no material conflict with the provisions of Policies DM 10 and DM 18 of the KMWLP. I have attached substantial weight to these stability and drainage benefits in the determination of this appeal. Character and appearance 72. The Council do not cite landscape or visual harm as a reason for the refusal of planning permission. However, the Appellant identifies that the restoration objectives of the site, in part, contribute to the justification for the amount of inert fill that is proposed to be imported into the site. Furthermore, it is contended that the restoration scheme would be a significant environmental and public benefit that needs to be considered in the overall planning balance. https://www.gov.uk/planning-inspectorate 12

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 73. The planning application was accompanied by a Landscape and Visual Impact Assessment20 (LVIA) which was updated as part of the ES Addendum21. The appeal site lies within the Kent Downs National Landscape. The Kent Downs AONB Landscape Character Assessment Update 2020 puts the site in LCA 4A Darent Valley. There are 3 Local Character Areas within this: Knockholt, Shoreham, and Chevening. The site lies within the Chevening sub-area. The Kent Landscape Character Assessment 2004 and the Sevenoaks District Landscape Character Assessment 2017 are also relevant. 74. Whilst there are several descriptions of the character of the area in the above documents, it is generally characterised by rolling hills, wooded areas and agricultural land. The primary objectives of the proposed restoration scheme are identified as returning the site to its natural state as far as possible and that the restored landscape is reinstated in sympathy with the existing and historic landscape features of the area. 75.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The Kent Downs Area of Outstanding Natural Beauty (National Landscape) Management Plan 2021-2026 sets out aims and principles for the positive conservation and enhancement of the Kent Downs for a five-year period. The goal of the Management Plan is “to ensure that the natural beauty and special character of the landscape and vitality of the communities are recognised, valued, enhanced and strengthened well into the future”. 76. The former quarry workings have left the appeal site significantly altered with respect to topography and denuded vegetation. In my view, the appeal site has an un-natural appearance that contrasts and detracts from the character of the surrounding landscape within this part of the National Landscape. It is characterised by a dominant and unplanned northern lake with large areas of unrestored slopes, some of which remain unvegetated. Neither of these characteristics were envisaged, or form part of, the approved restoration plan of the extant 1985 permission. 77. The proposed restoration scheme would provide for the reprofiling of the site to create a relatively shallow valley feature with the formation of a central wetland to manage surface water.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Key elements of the restoration include the retention of neutral grassland in the north west corner of the site for ecological enrichment; provision of low input pasture on the western, eastern and northern valley slopes; creation of a central footpath route connecting Farley Common with the Devil of Kent Wood with areas of woodland planting along the route; and, the provision of a new hedgerow and woodland edge planting in areas around the periphery of the site. 78. The restoration scheme would result in the reintroduction of landscape features which would acceptably fit with the surrounding landscape context. Furthermore, the return of the land to beneficial agricultural use is entirely consistent with the 1985 permission restoration objectives. Overall, I consider that the restoration proposals would provide a significant benefit to the character of this part of the National Landscape and provide substantial biodiversity opportunity. 79. The Kent Downs AONB Unit had no objection to the proposed restoration scheme and recognised that it is appropriate to local landscape character and would 20 CD3.10 21 CD4.6 https://www.gov.uk/planning-inspectorate 13

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 represent a significant improvement to the current condition of the site. In addition, during the Council’s consideration of the planning application, no objections regarding the restoration proposals were raised by Natural England, the Environment Agency, Kent Wildlife Trust, the Council’s Ecological Service and the Council’s Public Rights of Way Unit. The Council’s Landscape Consultants (Amey) advised that, in principle, the landscaping appears to be appropriate on the understanding of the need to address stabilisation issues. Although construction effects on landscape character were identified as being of short duration and not significant, the restoration would be moderately beneficial on completion and major beneficial as the landscape matures22. 80. The LVIA also considers the visual effects of the proposed development during the operational period, on completion of the restoration works and on maturity of the planting. The appeal site is relatively visually contained by surrounding landform and vegetation so that views into the former quarry working area from public viewpoints are limited.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision However, there are some receptors with framed or partial views of the temporary compound and haul route. These include a few residences on the north side of Westerham at Buckhams Thorn Road and on the north-east side of Farley Common including some properties on Granville Road. Taking into account the existing topography and vegetation, the proposed development within the existing quarry area would have negligible/minor adverse visual impact during the operational period. 81. The temporary haul route and compound will be seen by a small number of visual receptors including some houses on the northern edge of Westerham and from Croydon Road, which the haul road will cross. Most of the haul road runs within the transport corridor of the M25, to the north of the town. The use of the haul road will be temporary and of relatively short duration (estimated 5 years) and visual impact would be primarily as a consequence of the construction of the screening bunds. Taking into account the surrounding topography and existing vegetation, I consider that the visual impact of the haul road during the operational period would be minor adverse. 82.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision On restoration, the haul route would be restored back to its current condition, with all surfacing materials removed. Where vegetation has been removed this would be replanted using native species as appropriate. The short-term effect following the immediate implementation of the restoration scheme would be minor adverse as the replanted features will be immature. However, the medium to long term effect will be negligible once the replanted areas have re-established. 83. The Inquiry also heard evidence of the landowners ‘objectives’ for the site and a desire to achieve Grade 3 agricultural land following restoration. The Council considered that such objectives were a contributory factor in determining the amount of fill proposed to be imported into the site. However, my determination of this appeal requires consideration of whether the proposed amount of fill to be imported would cause material planning and environmental harm particularly, amongst other matters, whether it would cause harm to the character and appearance of the surrounding area and the wider National Landscape.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this context, my considerations are on the basis of the scheme before me and the attainment of Grade 3 agricultural land would be a consequential result of the proposed restoration scheme. 22 CD10.1 and Proof of Evidence – Robert Rummey – page 18 https://www.gov.uk/planning-inspectorate 14

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this context, my considerations are on the basis of the scheme before me and the attainment of Grade 3 agricultural land would be a consequential result of the proposed restoration scheme. 22 CD10.1 and Proof of Evidence – Robert Rummey – page 18 https://www.gov.uk/planning-inspectorate 14

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 84. Taking the above factors into account, there would be some adverse visual effects during the operational phase of the proposed development. However, none of these would be of an extent that would warrant the dismissal of this appeal. Restoration would provide significant visual and landscape benefits in the medium to longer term. This would result in a landscape that would be consistent with the surrounding landscape character and would contribute to the enhancement of the landscape and scenic beauty of the National Landscape. 85. Consequently, the proposed development would be consistent with the provisions of Policy DM 19 of the KMWLP and there would be no material conflict with the provisions of Section 15 of the Framework. The landscape benefits that would be provided by the appeal scheme, by providing restoration that is more commensurate with the character of the landscape, are afforded substantial weight in the determination of this appeal. Inert waste need and justification for the amount 86.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Paragraph 6.11.2 of the KMWLP provides supporting text to Policy CSW 11 and identifies that the most recent capacity assessment shows consented capacity for the permanent deposit of inert waste in Kent may only be sufficient to meet Kent's need for the plan period. It further sets out that while sites in Kent currently receives a lot of inert waste originating out of the county, particularly from London, the continuation of this waste import throughout the plan period would likely require development of additional capacity to accommodate this waste. 87. The evidence provided in the Kent Waste Needs Assessment 2022 Update23 in relation to Construction, Demolition & Excavation (CD&E) Waste Management Requirements in Kent suggests a total cumulative capacity requirement for this waste stream of approximately 11.8 million m3 over the plan period to 2039. This is set against available capacity in remaining void space of approximately 5.7million m3 over the plan period. 88. Paragraph 6.11.3 of the KMWLP sets out that an important issue is that without the import of waste the ability to restore existing permitted mineral workings would take a lot longer.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The paragraph states that Policy CSW 11 seeks to ensure that a high priority is given to using inert waste that cannot be recycled in the restoration of existing permitted mineral workings, in preference to uses where inert waste is deposited on land. 89. Taking the above factors into account, I am satisfied that there is a demonstrable need for continued inert CD&E waste disposal capacity in Kent over the Plan period. Furthermore, it is clear that the Council recognises the importance of the use of such material in the restoration of mineral working sites in preference to disposal on land. 90. I have no other contrary compelling reasons to suggest that the evidence of Mr Accleton24 may be incorrect. This is both in relation to the 270,000m3 of inert CD&E waste that Erith are contracted to manage from projects in London and the wider south east during 2025/26 or that in a typical year, the company manages more than 500,00m3 of such material. Furthermore, I have no other compelling contrary reasons to suggest that the required 160,000m3 of inert fill importation 23 CD8.1 24 Proof of Evidence – Stuart Accleton https://www.gov.uk/planning-inspectorate 15

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 per annum that would be necessary to achieve the proposed restoration of the site would not be achievable. It is clear that this volume is well within the amount of such inert material that Erith handles annually. 91. I accept that Erith may not be the eventual contractor appointed to provide the proposed required fill to the site. However, given the identified need for sites to import inert CD&E in Kent, the demonstrated availability of such material, and the verbal evidence provided by Mr Accleton, I am satisfied that the appeal site would provide an attractive commercial opportunity for the importation of in CD&E waste to other operators in London and the southeast, even if Erith were not the appointed contractor. Consequently, I have no compelling reasons to suggest that there may be any substantial deficiency in the availability of the required annual amount of fill material necessary to deliver the proposed restoration scheme or that there would be a corresponding delay in the indicated time period within which restoration would be achieved. 92. I recognise that the planning application form25 identified the development as being and inert landfill development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision However, from the description of the proposed development provided on the form, the explanatory text provided in Section 22, and the supporting documents, it was clear that the purpose of the importation of the material was to provide stability and restoration of the site. In my view, the nature of the planning application form at the time provided little option but to complete the “inert landfill” section of the form. However, the description of the proposed development, and the need for imported suitable engineering materials was clear. I have therefore attached little weight to the tenuous suggestion that the primary purpose of the development at the time of submission was that of an inert landfill operation. 93. The Council’s reasons for the refusal of planning permission do not define any objections to the landform proposed, the site levels or the agricultural after-use. I have found above that the proposed restoration scheme is consistent with the surrounding landscape. The proposed site levels would be above those that exist on the site now, following the cessation of extraction, but would be below the ground levels that originally existed prior to the mineral extraction operations.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The Council also recognise that it is unlikely that the approved restoration scheme can now be implemented. In any event, I have found above that the approved restoration scheme would also likely require a significant amount of fill to secure the removal of the current northern lake and achieve the approved ground levels. 94. The proposed landform and restoration objectives of the appeal proposals would be consistent with the character of this part of the National Landscape and effectively provide a recognised and accepted need for restoration of the site. The proposed levels would be below those that previously existed. Furthermore, the proposed slopes would be provided at gradients to be stable and safe for the use of agricultural machinery. The slope gradients would also reduce soil erosion and runoff from all cultivated land to avoid excessive silt accumulation in the SuDS system. Consequently, I do not find that the amount of infill material required to achieve this acceptable restoration proposal can reasonably be considered to be excessive. 25 CD1.16 – 3.a https://www.gov.uk/planning-inspectorate 16

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 95. There was considerable discussion whether the proposal would constitute a waste disposal or recovery operation within the context of the Waste Framework Directive26 and associated case law. In this case, the import of inert waste is necessary to perform a function, either as engineering fill, inert fill or as subsoil and topsoil to support the proposed restoration to agriculture. The essential characteristic of the proposed development requires the use of waste to serve a useful purpose and perform a clear function in the restoration of this former mineral working to an acceptable landform and address the current stability and drainage issues. In this context, I consider that the proposal constitutes a waste recovery operation and not a waste disposal activity. Consequently, the proposal would not be positioned at the bottom of the waste hierarchy and there would be no conflict with the provisions of Policy CSW 2 of the KMWLP. 96. The Council also referred to numerous case law during closing submissions. However, I consider that the principal objective of the appeal proposal is to use waste to secure restoration of the site rather than a primary intention to dispose of waste.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Furthermore, given the current condition of the site it is not reasonable to conclude that the approved restoration scheme or the appeal scheme could be delivered without the importation of some inert fill. There is no compelling evidence before me to suggest that there is sufficient material already available on the site which could displace the need for importation of fill material that would enable the North Lake to be filled and the approved restoration contours of the 1985 permission to be attained. 97. Part 1 of Policy CSW 11 is permissive in its drafting and clearly supports the permanent deposit of inert waste for a beneficial use such as the restoration of mineral workings and not as part of a disposal operation. There was considerable discussion regarding parts 2 and 3 of the policy which, unlike part 1, are linked by the conjunctive ‘and’. Reasonable reading of part 1 of the policy suggest that this is not conjunctive and specifically relates to the beneficial use of inert waste in restoration of landfill sites and mineral workings.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Part 2 relates to waste being used in engineering operations, other than the restoration of landfill sites and mineral workings where it is demonstrated that there is no local Kent demand for its use in such restoration operations. The conjunctive provides for consideration of part 3 which requires that such development involves the minimum quantity of waste necessary to achieve the benefit sought. 98. Whilst I accept that the drafting of the policy can be interpreted as being unclear, part 2 expressly excludes the restoration of mineral workings and the focus of part 3 appears to have the purpose of ensuring that material remains available for restoration purposes and provides a degree of reasoning why parts 2 and 3 are linked. The text in paragraph 6.11.3 supports such approach by recognising that Policy CSW 11 seeks to ensure that a high priority is given to using inert waste that cannot be recycled in the restoration of existing permitted mineral workings, in preference to uses where inert waste is deposition to land. 99. I have found above that the proposed restoration scheme is acceptable and would require approximately 800,000m3 of material being imported to achieve this.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Therefore, even if I were to be persuaded that parts 2 and 3 of the policy are applicable then the minimum quantity of material to achieve the scheme before me remains at approximately 800,000m3. 26 INQ39 https://www.gov.uk/planning-inspectorate 17

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Therefore, even if I were to be persuaded that parts 2 and 3 of the policy are applicable then the minimum quantity of material to achieve the scheme before me remains at approximately 800,000m3. 26 INQ39 https://www.gov.uk/planning-inspectorate 17

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 100. Taking the above factors into account, the proposed amount of fill importation is reasonable and necessary to achieve the proposed restoration of this former mineral working to a stable landform that would be suitable for agricultural use and would be entirely consistent with the character of this part of the National Landscape. It would utilise waste for a beneficial use to achieve the foregoing and constitute a recovery rather than a waste disposal operation. Furthermore, it would provide continued inert CD&E waste disposal capacity in Kent over the Plan period of the KMWLP and there is no compelling evidence to suggest that the amount of inert fill required would not be available over the proposed duration of the development. Consequently, there would be no conflict with Policy CSW 11 of the KMWLP. Green Belt 101. Mineral extraction and engineering operations are specifically referenced in paragraph 154 of the Framework as being examples of land uses or development that are not inappropriate by definition.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Hence, provided they preserve its openness and do not conflict with the purposes of including land within it, they are not inappropriate development in the Green Belt in national policy terms. These purposes are set out in paragraph 143 of the Framework and include: (a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another; (c) to assist in safeguarding the countryside from encroachment; (d) to preserve the setting and special character of historic towns. Purpose (e) is not relevant in this case. 102. Paragraph 224 of the Framework sets out that proposals for mineral extraction should provide for restoration and aftercare at the earliest opportunity, to be carried out to high environmental standards. The outcome of the proposed development would be the achievement of the restoration of the former quarry for which there is an outstanding restoration requirement pursuant to the extant 1985 permission. In this regard, the proposal would be consistent with paragraph 224. 103.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In considering the proposed development in the context of the Green Belt purposes, I do not consider that it can be reasonably argued that the appeal site adjoins or lies materially near any large built-up areas. It has no function in preventing urban sprawl related to such urban areas. In respect of purpose (b), the site lies within a significant area of countryside located between Limpsfield/Oxted and Westerham. The current characteristics of the site, and that of its proposed agricultural restoration, would not result in any threat of coalescence or merger of these settlements. 104. In terms of (c), the proposed development aims to achieve restoration to an open, agricultural after-use that is itself consistent with the objectives of including land within the Green Belt. With regard to (d) the appeal site is visually contained and does not form part of the setting or special character of historic towns. While Westerham contains a conservation area, which is considered later in this decision, this largely lies to the south of the town centre and the north is characterised by more modern 20th century development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision There is no reference to important views or setting of the appeal site in the conservation area appraisal27. As such, the appeal site performs no function in the setting of historic settlements and would not impact this objective. 27 CD7.3 https://www.gov.uk/planning-inspectorate 18

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision There is no reference to important views or setting of the appeal site in the conservation area appraisal27. As such, the appeal site performs no function in the setting of historic settlements and would not impact this objective. 27 CD7.3 https://www.gov.uk/planning-inspectorate 18

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 105. Taking the above factors into account, the proposed development would not, as a matter of planning judgement, fundamentally undermine any of the purposes of the Green Belt in the area. 106. In considering the effect of the proposed development on Green Belt openness, I have had regard to the case law evidence that was submitted and referred to in the Inquiry. The case, R (Samuel Smith Old Brewery (Tadcaster) and others) v North Yorkshire County Council [2020] UKSC 328 (the Samuel Smith case), amongst other things, identifies that openness is a broad policy concept and is the counterpart of urban sprawl. It further identifies that openness is not necessarily a statement about the visual qualities of the land, though in some cases it may be an aspect of applying the planning judgement involved in applying this broad policy concept. Nor does it imply that freedom from any form of development as the judgement recognises that some forms of development, including mineral extraction, may in principle be appropriate, and compatible with the concept of openness.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision It further states that a large quarry may not be visually attractive while it lasts, but the minerals can only be extracted where they are found, and the impact is temporary and subject to restoration. Furthermore, it identified that as a barrier to urban sprawl a quarry may be regarded in Green Belt policy terms as no less effective than a stretch of agricultural land and that openness is a matter not of legal principle but of planning judgement. 107. In the case Europa Oil and Gas Ltd. v Secretary of State for Communities and Local Government [2013] EWHC 2643 (Admin), paragraphs 67 and 68 of that judgement referred to the consideration of the temporary nature of minerals workings and the reversibility of their impact. Ouseley J noted the special status of mineral extraction under Green Belt policy, stating that a factor that affects appropriateness, the preservation of openness and purposes of the Green Belt “is the duration of development and the reversibility of its effects…..Minerals can only be extracted where they are found”. He also made clear that it is nonetheless for the decision maker to determine the effect on Green Belt openness. 108.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In considering the above cases, it is apparent that there is not a clear distinction between openness and visual impact. The cases recognise the temporary nature of minerals operations, but it is a matter for the decision maker to determine the effect on openness. 109. Although the Council did not identify that the proposed development would cause unacceptable visual impact to the landscape or local receptors in its reasons for the refusal of planning permission, in my view, it is a reasonable expectation that in assessing openness the likely visual impacts of development on the openness of the Green Belt should be considered. It is reasonable to assume that in assessing openness, a determination is necessary whether the proposal offers any visual or spatial effects on the openness of the Green Belt, and whether such effects are likely to be harmful or otherwise. These considerations depend on the circumstances of the proposals as a matter of fact and degree. 110.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this case, the aim of the appeal proposals are to provide for an acceptable restoration of the former quarried areas to address issues of inadequate land stability, poor drainage conditions, the inability in its present or consented form to support viable agricultural after-use. The open, agricultural based restoration 28 CD13.4 https://www.gov.uk/planning-inspectorate 19

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this case, the aim of the appeal proposals are to provide for an acceptable restoration of the former quarried areas to address issues of inadequate land stability, poor drainage conditions, the inability in its present or consented form to support viable agricultural after-use. The open, agricultural based restoration 28 CD13.4 https://www.gov.uk/planning-inspectorate 19

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 scheme proposed is consistent with the restoration aims of the extant 1985 permission and is itself consistent with the objectives of including land within the Green Belt. 111. The short-term impacts (maximum 6 years) as a result of engineering operations, would be well contained visually. There would be no permanent buildings associated with the proposals and those that are proposed are small scale and purely ancillary and temporary in nature, to control the site operations for the duration of the restoration works. The temporary haul road would be provided with small scale bunds within an already relatively enclosed landscape that benefits from a considerable degree of existing natural screening. 112. The appeal site forms a relatively small and visually enclosed component of the wider Green Belt in the locality. The short-term operations would be visually enclosed and involve a phased form of infill and restoration. As such, the site would be progressively restored with no material impact on the overall openness of area during the temporary period of the operations. 113.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Furthermore, the proposed temporary operations are necessary and entirely reversible which enable the delivery of the restoration scheme which responds directly to the landscape character of this part of the North Downs National Landscape and would contribute to the wider objectives of the Green Belt by improving the rural landscape’s quality and protecting its openness. 114. As such, the proposal would maintain the long-term openness of the Green Belt and its permanence. There would be no adverse long-term impact on the Green Belt or its purposes. Consequently, the appeal proposal is not inappropriate development within the Green Belt. 115. I have no contrary evidence to suggest that the appeal site should otherwise be considered grey belt land within the context of paragraph 155 of the Framework. Given my findings above that the proposed development would not constitute inappropriate development within the Green Belt and would preserve its openness, it is not necessary for me to consider this matter further. For the same reason, the very special circumstances to justify allowing development within the Green Belt is also a matter that does not need to be addressed. 116.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Taking the above factors into account, the appeal proposals are both appropriate development and would maintain the openness of the Green Belt. Consequently, there would be no conflict with national Green Belt policy and correspondingly no conflict with Policy DM 4 of the KMWLP. Highway Safety and the efficient operation of the highway network 117. Neither reason for refusal of planning permission refers to highway safety or the effect of the proposed development on the efficient operation of the local highway network. Kent County Council, in the role of local highway authority, and National Highways, in their role as managers of the Strategic Road Network, raised no objections to the proposals subject to conditions being imposed. However, concerns were expressed in the Inquiry by interested parties regarding these matters. 118. The material required to achieve the proposed scheme would primarily originate from southeast London and would be delivered to the site by HGVs over a 5 to 6 https://www.gov.uk/planning-inspectorate 20

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 year period. To avoid traffic impacts on Westerham Town Centre a temporary haul road would be constructed between the A233 London Road and the B2024 Croydon Road involving the provision of a signalised crossing of Croydon Road to enable access from the haul road into the former quarry area. The proposed haul road would gain access from the existing A233 Beggars Lane/London Road roundabout junction (via an additional arm) before traversing over land within the ownership of the appellant, parallel to the M25, to join Croydon Road. 119. The planning application was accompanied by a Transport Statement29 (submitted as an Annex to the ES). This was updated in August 202230 and further updated in 2025 as part of the ES Addendum. The methodology for calculating travel demand assumes between 14 and 18 two-way HGV trips per peak hour. Assuming an 11-hour working day, this corresponds to a forecast of 150 – 200 daily of two-way lorry movements Monday to Friday. The calculation assumes that deliveries to the site would be evenly spread throughout the day. 120.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The trip distribution proposes that a maximum of 100 two-way HGV movements (50 inbound/outbound) would access and egress the haul road from the A25 (east), a maximum of 100 two-way HGV movements would access and egress from the A233 (north) with a maximum of 10 two-way HGV movements would access and egress directly into, and out of, the former quarry via the new access off Croydon Road (north) each day. The submitted evidence considers current Annual Average Daily Traffic flow (AADT), HGV two-way flows and compares the additional maximum HGV two-way flows that would be generated by the proposal on the three routes proposed to be used. 121. Amongst other data, the evidence shows that for the A25 East the proposal would result in an increase of 9.1% HGVs as a percentage of total traffic per day, an 8.8% increase for the A233 North and an 8.3% increase on Croydon Road. The evidence suggests that the 3 routes proposed to be used have a relatively low crash record.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The highway authority considers that these increases in HGV movements would not be so significant as to have a severe effect on highway safety and congestion, particularly as the ‘A’ roads are strategic routes that currently have up to 15,000 vehicles per day using them. 122. As part of the ES Addendum, an updated traffic survey was carried out in May 2025, based on 24-hour automatic traffic counts (ATC) at nine locations (the same as those surveyed in 2017), in order to gauge the robustness of the original data and the reliability of the associated assessment. The update survey indicates that weekday traffic flows have reduced for all the surveyed links, with average reductions ranging from 31% for the AM peak to 8% for the PM peak and 10% for the working day (07.00-18.00). Saturday flows (07.00-13.00) have increased on all but one of the surveyed links but none of these increases are greater than 10%. 123. I am satisfied that the data provided in the original Transport Statement, as supplemented by the 2022 update, remains robust. I recognise that any increase in HGV movements is likely to be a concern to the residents of the settlements through which such movements would occur.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision However, on the basis of the evidence provided in this appeal, and in the absence of any other compelling 29 CD3.12 30 CD4.6 https://www.gov.uk/planning-inspectorate 21

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision However, on the basis of the evidence provided in this appeal, and in the absence of any other compelling 29 CD3.12 30 CD4.6 https://www.gov.uk/planning-inspectorate 21

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 technical evidence, I have no reason to disagree with the views of the highway authority. 124. A number of planning conditions (Nos. 4, 27, 28 and 29) are proposed to control and monitor vehicular movements to ensure that the development is undertaken in accordance with the submitted transportation evidence. Subject to the imposition of these conditions, and in the absence of any other compelling technical evidence, I conclude that the proposal would not result in an unacceptable impact on highway safety, or that the residual cumulative impacts on the road network would be severe. Consequently, there would be no conflict with the provisions of paragraph 116 of the Framework and Policy DM 13 of the KMWLP. Effect on the special Interest of nearby heritage assets 125. Although the Council’s reasons for the refusal of planning permission does not identify any concerns regarding the impact of the proposed development on designated heritage assets, I am nevertheless required to have regard to the statutory duty to consider the effect of the proposal on such assets within the context of Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Although Historic England provided no comments and the Council’s Heritage Conservation Officer and Archaeological Officer raised no objections to the proposed development, I have had regard to the desirability of preserving or enhancing the designated heritage assets. 126. The Heritage Assessment31 identifies that there are no built designated or non- designated heritage assets located within the boundary of the appeal site. A 1.25km search area around the site was used to identify built heritage assets within the vicinity that might be affected by the proposed development. This identified heritage assets to include 59 listed buildings, including the Grade I listed Squerryes Court, 4 Grade II*s and 54 Grade IIs, Westerham Conservation Area and the Squerryes Court Registered Park and Garden. A number of non- designated built heritage assets, located within the Westerham Conservation Area were also identified. 127. The site visit confirmed the findings of the Assessment that in most cases, there is no intervisibility and no specific historical functional relationship between the site and the majority of these assets.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Given the intervening distance, topography, vegetation and/or buildings between the identified assets and the appeal site, in the majority of cases there is no potential for the assets’ significance to experience any perceptible change as a result of the proposed development. 128. However, the Assessment identifies that there are four heritage assets that have potential to be affected by the proposed development and which were further evaluated. These comprise the Westerham Conservation Area, the Squerryes Estate incorporating the Registered Park and Garden and associated buildings, Covers Farmhouse (Grade II) and Court Lodge (Grade II*). 129. The Westerham Conservation Area encompasses the historic core of the town and the principal road through the town along which ribbon development has occurred. The boundary extends to the north to include some development along London Road. The Assessment identifies that the Conservation Area has a 31 CD3.6 https://www.gov.uk/planning-inspectorate 22

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 varied setting with the immediate setting to the north and northeast, largely consisting of twentieth to twenty-first century residential and light industrial development. Beyond this development remain a small number of agricultural fields which are in turn bounded by the M25 which, although occupying lower ground, has an urbanising influence as a result of increased noise and light levels. The significance of the Westerham Conservation area is principally derived from the quality and variety of its historic buildings, as well as its composition and spatial form. 130. The former quarry itself shares no intervisibility with the Conservation Area, due to the intervening belts of woodland, built form and topography to the south and east. I concur with the findings of the Assessment that the former sand extraction activity site has eroded its contribution to the significance of the Conservation Area, with the historic functional association of agricultural activity now lost. 131. The proposed temporary haul road would be visually and aurally separated from the Conservation Area by the high density of intervening post-war residential development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Although it would partly erode the wider rural surroundings of the Conservation Area, this would not be legible from within, or immediately surrounding, the Conservation Area with these works occurring in close proximity to the M25 in an area that has already been eroded. As such these works would have no impact on the significance of the Conservation Area. 132. Given the lack of functional association and the lack of intervisibility, the appeal site currently does not make any contribution to the significance of the Conservation Area. Taking these factors into account, the proposal would have no material effect on the heritage significance of this asset. 133. Turning to Squerryes Court, this is identified as an exemplar illustration of the Queen Anne Style of architecture and lies adjacent to the A25 to the south-west edge of Westerham upon the north and east facing slopes of a greensand ridge. The house is entirely enclosed within its own Grade II Registered Park and Garden. 134. The appeal site is heavily screened by intervening vegetation, woodland and changes in topography. As such, it currently makes a neutral contribution to the significance of the Squerryes Court heritage assets.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The proposed development would have no impact on the significance of these assets. 135. Covers Farmhouse dates to at least the seventeenth century. Nineteenth century Ordnance Surveys show the farmhouse separated from a range of outbuildings to the north which are set in a courtyard plan and are suggested to have served an agricultural function. Its principal significance is identified as being derived from the architectural and historical interest embodied within its built fabric. Modern development and alteration that has occurred to the north of the farm and the use of the land as a quarry, coupled with the screening afforded by mature trees means that the asset’s setting makes a limited, and in part detrimental, contribution to the significance of the asset. 136. The appeal site currently makes a negative contribution to the significance of the asset, through the visual and aural intrusion caused by the extraction activity, and the loss of functional context once provided by the surrounding farmland. The proposed restoration of the appeal site to agricultural and ecological use would https://www.gov.uk/planning-inspectorate 23

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 provide an enhancement to the significance of the asset, by re-instating a more verdant, tranquil and rural setting to the north. 137. Court Lodge is a 15th century Grade II* hall house with 17th, 18th and 20th century alterations and additions located in a relatively isolated position north of the historic centre of Westerham. The assets significance is principally derived from the architectural and historic interest of its built fabric, which has high historic, evidential and aesthetic value. The asset’s immediate setting within private grounds contributes to the building’s aesthetic value. However, the asset’s wider, once tranquil and rural setting has been heavily eroded by 20th century development. These aspects of the asset’s setting are deemed to have a negative impact on the significance of the building, which is now largely divorced from its wider setting. 138. The construction of the M25 has already eroded much of the wider rural surroundings of the heritage asset. The haul road will likely lead to some increased levels of noise and vibration both during construction and when in use.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision However, I concur with the findings of the Assessment that this harm would be temporary and negligible, given the level of development that has already occurred in the area and the reduced contribution that setting to the north makes to the significance of the asset as a result. Consequently, the proposed haul road would likely cause a negligible level of less than substantial harm to Court Lodge. However, this harm would be temporary and reversible. I address the approach of balancing this harm against the public benefits, in accordance with Policy DM 5 of the KMWLP and the Framework, in the overall balance below. 139. I have also taken into account the concerns of interested parties regarding HGVs passing through Conservation Areas and in proximity of heritage assets on the journey to and from the proposed development. However, given my findings above regarding the likely increase in HGV movements on relevant highways that would be used in comparison to existing levels, I do not consider that there would be any substantive basis to suggest that this would likely cause harm to the significance of heritage assets.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Furthermore, the Council’s Heritage Conservation Officer considered these matters and raised no objection to the proposed development. Other matters Public safety associated with the current North Lake 140. It is clear from the evidence of Mr Warde, and from my own observations at the site visit, that the appeal site attracts trespassers who seek to swim in the North Lake or undertake other activities in the water and its shoreline, despite attempts to restrict access. Evidence was provided32 of the potential effects of cold water and the dangers of deep-water bodies, particularly where they are not safely designed or intended to be used for such purposes. Paragraph 102(a) of the Framework recognises that planning decisions should promote public safety and sets out that the safety of children and other vulnerable users in proximity to open water should be considered in assessing proposals for development. 141. I recognise that some former mineral workings are used for water-based recreation. In those cases, such use is usually an intended part of the design of 32 INQ09 and INQ10 and Proof of Evidence of Henry Warde https://www.gov.uk/planning-inspectorate 24

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 the restoration scheme and often includes appropriate management and supervision. However, that is not the case with the appeal site which was not intended to be provided with any deepwater body and particularly one with steep slopes and unstable banks. 142. The evidence of Mr Warde is compelling in that there is a real concern that there is the potential for a fatality to occur given the current condition of the appeal site. The proposed development would resolve this issue by eliminating the risk posed by the current lake. I therefore attach significant weight to the public safety benefits that would be achieved by the appeal scheme. Noise and Vibration 143. Although the Council did not identify the impact of noise and vibration arising from the proposed development as a reason for the refusal of planning permission, concerns relating to these matters were raised by interested parties, particularly regarding the proximity of the haul road to the Churchill Primary School. The planning application was accompanied by a noise and vibration assessment33 and further information was provided as part of the ES Addendum34. 144.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The assessment included details of baseline noise monitoring, predictions of noise levels arising from the construction, use and removal of the temporary haul road, calculation of on-site operation and road traffic noise and an assessment of the predicted impact at noise sensitive receptors which included residential properties in the vicinity of the site and the school. The assessment demonstrates that noise levels would be generally maintained within the limits set out in the Planning Practice Guidance (PPG). 145. Noise levels associated with the initial construction of the access road from the A223 to the quarry are anticipated to remain below the proposed normal working limits at the surrounding properties, with the exception of Brickfield Cottages, during the period whilst the new access is constructed. The construction of the access would be a short-term operation and thus the higher 70 dB LAeq, 1 hour limit would be applicable at this property. However, such noise levels during the construction of the access would be acceptable in the context of the guidance provided in the PPG and therefore would not result in any significant adverse impacts. 146.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision With regard to the school during the construction of the access, the assessment demonstrates that noise levels would remain acceptable and unlikely to result in adverse impacts and that, where possible, works likely to generate high levels of noise, such as the construction of the bund adjacent to the school, would be carried out during school holidays or outside of lesson times. 147. The assessment demonstrates that noise levels associated with the general use of the access road by HGV traffic are anticipated to remain low and substantially below the proposed normal operating limit at the school and properties to the south of the access. Furthermore, the noise levels attributable to the vehicle movements along the access would be considerably below the existing ambient noise levels at these properties, which are principally attributable to traffic travelling along the M25. 33 CD4.4.3 34 CD4.4.4 https://www.gov.uk/planning-inspectorate 25

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 148. With regard to properties close to the former quarry itself, the assessment demonstrates that properties to the south and west of the quarry – Westwood Farm, Covers Farm and Bungalow – would remain below the proposed normal working limits throughout the proposed operations and therefore not result in any adverse noise impacts at these properties. Higher noise levels are anticipated at the properties to the east including Farleys Mill and neighbouring properties and Greencroft Farm. The assessment identifies that during works within 50m of the site boundary with these properties noise levels would potentially increase above the normal working limit however this would represent a small portion of the overall activities on the appeal site. On this basis it is considered unlikely that there would be a requirement for plant to operate within the area for more than a few weeks. Furthermore, to minimise any potential disturbance, works within 50m of the boundaries would be restricted to less than 8 weeks per year. 149. Consideration is also given to the changes in off-site traffic noise based on a change in traffic flows on roads surrounding the site.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The assessment indicates that the additional traffic accessing the proposed development would result in very small increases in road traffic noise levels on the surrounding road network. The assessment concludes that increases in road traffic noise levels would result in at worst a negligible impact upon residents of dwellings alongside the identified roads where vehicles associated with the development are likely to travel. Such levels would be substantially below those that would result in any significant adverse noise impacts. 150. The assessment was considered by the Council’s noise consultants who were satisfied that it is robust and suitably assesses the schemes potential effects on nearby noise sensitive properties. The consultants raised no objections to the proposed development provided suitable controls are secured by planning conditions. 151. Whilst I recognise that noise remains a concern for some interested parties, in the absence of any other compelling technical evidence to the contrary, I do not consider that there are any substantive reasons to dismiss the appeal on the grounds of noise impact.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Planning conditions can be imposed to provide noise limits and the submission of a noise management and monitoring plan. Subject to the imposition of such conditions (Nos. 32, 33 and 34) and on the basis of the evidence before me I am not persuaded that the proposal would likely give rise to unacceptable levels of noise. Consequently, there would be no conflict with the relevant provisions of Policy DM 11 of the KMWLP. Air Quality 152. The planning application was accompanied by an air quality assessment35 which was also considered in the ES Main Report36 and summarised in the Officer Report to Planning Committee. These consider the impacts of increased emissions arising from the additional traffic on local roads, including the A25 through Brasted and Sundridge, and the new haul road. 153. The ES Main Report identifies that the operational dust impact assessment has predicted Moderate Adverse impacts at the receptors closest to the quarry. However, the assessment has been founded on a worst-case approach; in 35 CD3.5 36 CD3.1 https://www.gov.uk/planning-inspectorate 26

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 addition, the works are expected to be completed within five years, and thus any effects would be temporary in nature. Assuming that best practice mitigation measures are employed to minimise the potential for off-site dust effects, the overall impacts are judged to be ‘not significant’. The potential for impacts upon human health at the worst-case receptor locations have been screened out and are ‘not significant’. 154. The impacts of increased emissions arising from the additional traffic on local roads (and the new haul road) were also assessed. Concentrations have been modelled for five worst-case receptors, representing existing properties where impacts are expected to be greatest. The ES Main Report identifies that concentrations of PM and PM (fine particulate matter) would remain below the 10 2.5 objectives at all existing receptors in 2018, with or without the proposed restoration. 155. Annual mean concentrations of nitrogen dioxide are predicted to exceed the objective at two receptors in Brasted, with or without the proposed development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision These exceedances are predicted within an Air Quality Management Area (AQMA), at locations where there has been recorded levels above the objective. Although moderate adverse impacts are predicted at these locations, the assessment is founded on a worst-case assumption that all the related traffic will travel along Brasted Road and is thus identified as likely to have overstated the impacts. 156. The ES Main Report concludes that the overall operational air quality effects of the proposed development are judged to be ‘not significant’. The proposals are identified as being consistent with all national and local policies and there are no air quality constraints to the scheme 157. The Council’s air quality advisors (Amey) acknowledges that exceedances have already been recorded within the AQMA and that the assessment has been carried out based on all traffic travelling through Brasted which would represent very much a worst-case scenario. The appeal scheme proposes that HGV traffic using the A25 through Brasted would be limited to 100 HGV movements per day (through a routing agreement).

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision As a result, traffic would be displaced onto the London Road (A233) north of the proposed haul road, but again modelling carried out assumed a worst-case scenario with all proposed traffic using this road to access the site and the impact was assessed as negligible. Given the above, Amey agree that the effects of the proposed vehicle movements on air quality are judged to be not significant in terms of the additional impacts. 158. The restoration works have the potential to create dust through site preparation, importation of fill material and materials handling across the site. The operational dust impacts assessment predicts ‘Moderate Adverse’ impacts at the receptors closest to the quarry, such as properties to the north of Farley Common. However, the assessment has been carried out on a worst-case scenario and any impacts would be temporary in nature. It identifies that If best practice mitigation measures are employed to minimise the potential for off-site dust effects, the overall impacts are judged to be ‘not significant’. Amey concur with this view subject to the imposition of a planning condition requiring dust management and monitoring (Condition No. 22). https://www.gov.uk/planning-inspectorate 27

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 159. Amey conclude that the effects of air quality have been assessed in a robust fashion that follows established and suggested methodologies and on that basis, there are no grounds to raise objections to the proposals in terms of the direct and indirect impacts on the wider area. 160. I recognise that the impact of the proposed development on air quality is a concern to interested parties and Sevenoaks District Council. However, I have taken into account the findings of the submitted air quality assessment which has been the subject of evaluation by independent consultants acting on behalf of the Council. In the absence of any compelling evidence to the contrary, I do not find that the proposed development would have a demonstrable detrimental effect on air quality of an extent to warrant the dismissal of this appeal on those grounds. Consequently, there would be no material conflict with the relevant provisions of Policy DM 11 of the KMWLP Other issues 161.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In addition to the matters considered above, I have also taken into account other concerns raised by interested parties regarding, amongst other matters, the potential effect of the proposed development on ecology, archaeology, groundwater and light pollution. Although the above matters have been carefully noted, they do not alter the main issues which have been identified as the basis for the determination of this appeal, particularly in circumstances where the Council has not objected to the appeal scheme for these other reasons. Planning Balance and Sustainable Development 162. I have found that the proposal would maintain the openness of the Green Belt. It cannot be regarded as constituting inappropriate development in the Green Belt. The proposal would deliver the long overdue restoration of the former quarry to an after use that is broadly commensurate with that required by the extant 1985 permission and would provide significant visual and landscape benefits in the medium to longer term. This would result in a landscape that would be consistent with the surrounding landscape character and would contribute to the enhancement of the landscape and scenic beauty of the National Landscape.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision These benefits are afforded significant weight. 163. The proposed development would result in a stable landform for the long term which would satisfactorily address the land instability problems within the site and any threat to adjoining land, including the potential risk to the M25. It would also ensure that the site can be satisfactorily sustainably drained and permanently remove the current potential flood risk associated the rising water levels in the North Lake. These benefits are also afforded significant weight. 164. I have also found that the proposed amount of fill importation is reasonable and necessary to achieve the objectives of the appeal proposals and secure the restoration of this former mineral working to a stable landform that would be suitable for agricultural use. It would utilise waste for a beneficial use to achieve the foregoing and constitute a recovery rather than a waste disposal operation. Furthermore, I have attached moderate weight to the consequential provision of continued inert CD&E waste disposal capacity in Kent over the Plan period of the KMWLP. https://www.gov.uk/planning-inspectorate 28

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 165. Subject to appropriate planning conditions, the proposed development would not, by reason of noise, dust or poor air quality, have a significant and demonstrable adverse effect on the amenity of the area or the living conditions and health of those living nearby or using educational facilities. In addition, I do not consider that it would have a significant adverse effect on the character or appearance of the site and the surrounding landscape of an extent to sustain the dismissal of this appeal on those grounds. Furthermore, no visual receptor would receive a significant adverse effect during the operational period of the proposed development of an extent that would be materially detrimental to living conditions. 166. I have attached significant weight to the public safety benefits that would be achieved by the elimination of the risks associated with swimming and other uses in the vicinity of the deep-water North Lake. The scheme would result in permanent enhancements to the PRoW network, which is a benefit that should be given some slight positive weight. 167.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The proposal would not result in an unacceptable impact on highway safety, nor would it cause a severe residual cumulative impact on the road network. 168. In terms of heritage, I have concluded above that the proposed haul road would likely cause a negligible level of less than substantial harm to the Court Lodge Heritage Asset. Section 66 of The Planning (Listed Buildings and Conservation Areas) Act 1990 requires the decision maker to pay special regard to the desirability of preserving listed buildings, their settings, and any architectural features they may possess. The Framework provides that great weight should be given to the conservation of designated assets, the more important the asset, the greater the weight should be. Considerable importance and weight should be given to this harm. 169. Paragraph 215 of the Framework sets out that where a development proposal will lead to less than substantial harm to the significance of a designated heritage assets, this harm should be weighed against the public benefits of the proposal.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision The low level of less than substantial harm that I have identified to the significance of the designated heritage asset is outweighed by the substantial public benefits that would be attributable to the restoration of the former quarry as identified above. The Council provided no reason for the refusal of planning permission on heritage grounds. 170. In the determination of this appeal have considered the Council’s position whether the restoration of the former quarry justifies the amount of fill proposed to be imported into the site. Whilst I recognise that there could be alternative schemes that may involve less, or more, fill importation, I am obliged to consider the planning merits of the scheme before me. In this case, I am unable to find any material harm with the provisions of the development plan of any extent that would justify the dismissal of this appeal or outweigh the benefits of the proposal. 171. Paragraph 11 of the Framework sets out that planning decisions should apply a presumption in favour of sustainable development and that for decision-taking this means approving development proposals that accord with an up-to-date development plan without delay.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this case, I have found that the appeal scheme would accord with the relevant provisions of the recently adopted KMWLP. There are significant benefits associated with the appeal scheme and on balance, having regard to the main issues and the other matters raised, that https://www.gov.uk/planning-inspectorate 29

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In this case, I have found that the appeal scheme would accord with the relevant provisions of the recently adopted KMWLP. There are significant benefits associated with the appeal scheme and on balance, having regard to the main issues and the other matters raised, that https://www.gov.uk/planning-inspectorate 29

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 the benefits of the scheme would outweigh any adverse impacts likely to be associated with it. Furthermore, I have found that the amount of inert fill proposed to be imported into the site to deliver the proposed restoration scheme would be reasonably necessary. 172. The appeal scheme would accord with the recently adopted development plan taken as a whole and material considerations do not indicate that the appeal should be determined other than in accordance with the development plan. Therefore, having had regard to the economic, social and environmental implications of the scheme, it would amount to sustainable development under the terms of the Framework taken as a whole. Consequently, there would be no conflict with the provisions of Policy CSW 1 of the KMWLP. Conditions 173. I have considered the proposed planning conditions, including a number of pre- commencement conditions, that have been provided by the Council. I have considered these against the advice given in paragraph 57 of the Framework and the guidance contained in the section on ‘Use of Planning Conditions’ in the PPG.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Where necessary I have amended them in the interests of clarity, precision, conciseness or enforceability. 174. Condition No. 1 provides the time limit for the commencement of the development, being no later than 5 years from the date of the permission. The main parties agree that such extended period is necessary to enable the Appellant to prepare the submission of the necessary environmental permit, which the parties suggest that there is currently in excess of one year determination period and thereby minimising the need to seek a fresh planning application. Such approach is reasonable and, as such, the 5-year commencement provisions set out in the condition are necessary. 175. A condition (No. 2) restricting the development to a period of 6 years from commencement is necessary to ensure that the site is restored within the parameters of the time period set out in the application and accompanying ES. I have imposed a condition (No. 3) relating to the approved plans in the interests of certainty. 176.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In the interests of highway safety, the free flow of traffic on the surrounding highway network, and to ensure restoration of the haul road, conditions are necessary requiring the submission of design and construction details of the haul road, measures to prevent the deposition of mud and material on the public highway during construction, ensuring that no importation of fill occurs until the haul road has been completed, the provision of pre-commencement highway condition surveys, restrictions on the number of vehicle movements and access and egress locations, and the submission and implementation of a Traffic Management Plan (Nos. 4, 5, 7, 27, 28 and 29). 177. Also, in the interests of highway safety, the protection of the living conditions of the occupants of nearby properties and the protection of the water environment and ecological interests, a condition is necessary to provide for the submission and implementation of a construction environmental management plan (No. 6). 178. In order to ensure that development does not prejudice the integrity of the M25 Motorway, a condition is necessary requiring the submission of a monitoring https://www.gov.uk/planning-inspectorate 30

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Appeal Decision APP/W2275/W/25/3358947 strategy and emergency action plan (No. 8). Conditions are also necessary requiring the submission of the detailed design of the surface water drainage system and the subsequent verification of the installed system to ensure that the development does not exacerbate the risk of on/off site flooding (Nos. 9 and 44). 179. A number of conditions (Nos. 10, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 40 and 41) are necessary relating to the operation of the site and management of the importation and deposition of the inert fill to ensure the geotechnical integrity of the site, soils management, phasing details, ensuring that only inert fill is imported, measures to deal with any contaminated material imported to the site or encountered on the site, stockpiling height limitations, and the storage of fuels, oils and chemicals. These conditions are necessary to provide control over the infill operations, protect the environment and ensure the progressive working and restoration of the site. 180.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision In order to investigate and record any archaeological interest in the vicinity of the haul road, a condition is necessary requiring the submission and implementation of a scheme of archaeological investigation and recording (No. 11). 181. In the interests of protecting the living conditions of the occupants of nearby properties, conditions are necessary requiring the submission and implementation of a dust management plan, imposition of noise limits and noise management and monitoring, hours of operation and external lighting details (Nos. 22, 30, 31, 32, 33 and 34). Conditions requiring the submission and implementation of details of landscaping, aftercare, measures to ensure the protection of retained trees and the submission of details of the restoration of the haul road are also necessary to protect the character and appearance of the area (Nos. 23, 37, 38, 42 and 45). 182.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Appeal Decision Conditions are also necessary, in the interests of the protection and enhancement of ecology, nature conservation and biodiversity, requiring the submission of an Ecological Mitigation and Habitat Creation Plan, protection of trees during the bird nesting season and the submission and implementation of a Landscape and Ecological Management Plan (Nos. 24, 25, 35 and 36). 183. In order to ensure the safety of the users of the public footpath network during the development and ensure the reinstatement of public right of way SR338, conditions are necessary requiring the submission and implementation of a Public Rights of Way Management Plan and details of the reinstatement works (Nos. 26 and 39). 184. The submission of geotechnical verification during and on completion of the development is necessary to ensure the integrity of the slopes and the proper restoration of the site (No. 43). Conclusion 185. There are no other considerations of such weight as to warrant a decision other than in accordance with the aforementioned development plan policies and the Framework. Consequently, for the above reasons, based on the evidence before me and all other matters raised, I conclude that the appeal should be allowed.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington INSPECTOR https://www.gov.uk/planning-inspectorate 31

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington INSPECTOR https://www.gov.uk/planning-inspectorate 31

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 ANNEX A - APPEARANCES FOR THE APPELLANT: Richard Kimblin KC Instructed by Steven Fidgett Counsel for the Appellant Director, Union4 Planning Ltd He called Mr Matthew Franklin BA, MA Technical Director, PJA Mr Stuart Accleton Operations Director, Erith Mr Steven Wilson MSc, BEng, CEng, Technical Director, MICE, CEnv, CSci, CWEM, MCIWEM, FGS Environmental Protection Group Mr Robert Rummey BArch (Hons) Edin, Principal Rummey Design RIBA, DipLA, CMLI, FRSA Mr Henry Warde Owner Squerryes Estate Mr Steven Fidgett BSc (Hons), DipTP(Dist), Director, Union4 Planning Ltd MRTPI FOR KENT COUNTY COUNCIL Charles Streeten Instructed by Sarah Bonser Counsel for the County Planning Authority Head of Planning and Highways Legal team Assisted by Jeffrey Chu (Pupil) They called Michael Ashley MGeol (Hons), MSc, FGS Lead Senior Engineer, Amey Douglas Lewis BSc (Hons), PhD, CWEM Technical Director, Amey PIEMA Adrian Lynham BA (Hons), DipTP, MSc, Director, Continuplan MRTPI INTERESTED PARTIES: Councillor Nigel Williams Kent County Council Councillor Michelle Algar Sevenoaks District Council Councillor Nick Robson Westbury Town Council Jenny Cowan Keep Westerham Green Jonathan Lord Westbury Town Council

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 32 Appeal Decision APP/W2275/W/25/3358947 ANNEX B LIST OF DOCUMENTS SUBMITTED DURING THE INQUIRY

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 ANNEX B LIST OF DOCUMENTS SUBMITTED DURING THE INQUIRY | Inquiry Document (INQ) | Description of Document | | --- | --- | | INQ 1 | Accompanied site visit itinerary plan | | INQ 2 | Revised Inquiry Programme dated 30 May 2025 | | INQ 3 | Appellant’s Opening Statement | | INQ 4 | Council’s Opening Statement | | INQ 5 | Transcript of Statement read by Councillor Michelle Alger | | INQ 6 | Transcript of Statement read by Councillor Nick Robson | | INQ 7 | Letter of Representation dated 26 May 2026 containing notification of intended works by Thames Water to replace a water pipe on Main Road, Biggin Hill with works programmed to last until up to September 2027 | | INQ8 | Note from Council relating to soil requirement and distribution | | INQ 9 | Extract from BBC Website regarding high number of accidental drownings | | INQ 10 | Document from National Water Safety Forum regarding water- related fatalities in 2024 | | INQ 11 | Agreed Plans List | | INQ 12 | Tracked Change Version of agreed/disagreed planning conditions | | INQ 13 | Clean copy version of agreed/disagreed planning conditions | | INQ14 | Google Earth screenshot showing appeal site and settlements of Westerham and Oxted |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | Inquiry Document (INQ) | Description of Document | | --- | --- | | INQ 15 | Note from Appellant regarding restoration soil requirement for approved northern quarry restoration | | INQ 16 | Transcript of Statement read by Jenny Cowan | | INQ 17 | Redhill Aerodrome Court of Appeal Judgement [2014] EWCA Civ 1386 | | INQ 18 | Council’s closing submissions | | INQ 19 | Appellant’s closing submissions | | INQ 20 | Abfall – Judgement | | INQ 21 | Abfall – opinion | https://www.gov.uk/planning-inspectorate 33 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | INQ 22 | Construction (Design and Management) Regulations 2015 (CDM) – Regulation 9 | | --- | --- | | INQ 23 | CDM – Regulation 26 | | INQ 24 | DB Symmetry Judgement | | INQ 25 | Derbyshire Dales District Council Judgement | | INQ 26 | Gladman Developments Ltd v Canterbury City Council Judgement | | INQ 27 | Gluck v SSHCLG Judgement | | INQ 28 | Hawkey Judgement | | INQ 29 | Langley Park Scholl for Girls Governing Body v Bromley LBC Judgement | | INQ 30 | Grand Duchy of Luxembourg Judgement | | INQ 31 | Mansell v Tonbridge and Malling Borough Council Judgement | | INQ 32 | Murfitt v Secretary of State for the Environment Judgement | | INQ 33 | New Earth Solutions (West) Ltd v Environment Agency Judgement | | INQ 34 | Phides Estates (Overseas) Ltd v SSCLG Judgement | | INQ 35 | Tarmac Aggregates Ltd v SS for Environment, Food and Rural Affairs Judgement | | INQ 36 | Tesco Stores Ltd v Dundee City Council Judgement | | INQ 37 | Test Valley Borough Council v Fiske Judgement | | INQ 38 | Trusthouse Forte Hotels Ltd. v SS for The Environment Judgement | | INQ 39 | Waste Framework Directive | | INQ 40 | Extract from Appellant’s Closing Submissions containing Footnote 16 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington ANNEX C LIST OF DOCUMENTS REQUESTED BY THE INSPECTOR AND SUBMITTED AFTER THE CLOSE OF THE ORAL SESSIONS OF THE INQUIRY | INQ 41 | Final agreed schedule of planning conditions | | --- | --- | https://www.gov.uk/planning-inspectorate 34 Appeal Decision APP/W2275/W/25/3358947 ANNEX D CORE DOCUMENTS (CD)

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 ANNEX D CORE DOCUMENTS (CD)

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD1 | | Planning Application Plans and Documents | | | | --- | --- | --- | --- | --- | | | | | | | | | | Application Plans | | | | | | | | | | CD1.1 | 1325/L/1 v1 - Site Location Plan (Colour A3) | | | 14.06.2018 | | CD1.2 | 1325/SC/1 v.2- Site Context Plan Colour A3 | | | 12.09.2018 | | CD1.3 | 1325/A/1 v.4 - Application Plan (Colour A3) | | | 12.09. 2018 | | CD1.4 | 1325/CO/1 v.4 - Composite Operations Plan (Colour A3) | | | 07.09.2018 | | CD1.5 | 1325/PO/1 v.6 - Progressive Operations Plan (Colour A3) | | | 12.09.2018 | | CD1.6 | 1325/CS/1 v.1- Illustrative Cross Sections (As existing) | | | 17.09.2018 | | CD1.7 | 1325/S/3 v.5. Site Plan (As existing) (A3 Colour) | | | 13.02. 2020 | | CD1.8 | 1325/R/3 v.8 - Restoration Plan (marked as received 6 April 2023) A3 | | | 14.02.2023 | | CD1.9 | 1325/AR/1 v.10 - Illustrative Route of Internal Access Road (west) (Date received 13 May 2021) (A3 Colour) | | | 13.05.2021 | | CD1.10 | 1325/AR/2 v.9 - Illustrative Route of Internal Access Road (East) (date received 13 May 2021) A3 Colour | | | 13.04.2021 | | CD1.11 | 1325/CR/1 v.5 - Croydon Road Crossing and Compound details (date received 13 May 2021) A3 Colour | | | 13.04.2021 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD1 | | Planning Application Plans and Documents | | | | --- | --- | --- | --- | --- | | CD1.12 | Illustrative Cross sections showing restored landform Reference 1325/CS/2. V.2 dated. (marked as received 6 April 2023) A3 Colour | | | 14.02.23 | | CD1.13 | 1325/AR/1 v.9 - Illustrative Route of Internal Access Road (West) (A3 Colour) | | | 31.05.2019 | | CD1.14 | 1325/AR/2 v.8. - Illustrative Route of Internal Access Road (East) (A3 Colour) | | | 31.05.2019 | | CD1.15 | 1325/CR/1 v.4 - Croydon Road and Crossing Compound details (A3 Colour) | | | 31.05.2019 | | | Application Documents | | | | | CD1.16 | Application Forms and Certificates (Agent D.K Symes Associates) | | | 3.10.2018 | | CD1.17 | Application Cover Letter (Reference DSK/yw/1325) | | | 3 October 2018 | | CD1.18 | Planning Statement – prepared by D.K Symes Associates | | | October 2018 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 35 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | CD2 | | Other Application Supporting Documents and | | | | --- | --- | --- | --- | --- | | | | Plans | | | | | | Supporting Documents | | | | | | | | | | CD2.1 | Slope Stability Assessment GB Card (April 2018) – referred to as draft (Marked as registered 19 November 2018) | | | GB324-SSA- APR-2018- DRAFT | | CD2.2 | Supporting Statement – Further information on Stability. DK Symes Associates | | | December 2019 | | CD2.3 | GB Card Alternative 0ptions Restoration GB324- AOR-DEC-2020 | | | December 2020 | | CD2.4 | Transport Statement | | | August 2022 | | CD2.5 | Surface Water Drainage Strategy – prepared by GB Card Partners (March 2023) GB324-SWDS-MAR-2023- REV2 (Marked as received 6 April 2023) | | | March 2023 | | CD2.6 | Ecological Impact Assessment – prepared by Ecosa (Final Document) (Marked as received 6 April 2023) | | | 23 March 2023 | | | | Other Background Plans | | | | | | | | | | CD2.7 | Composite Plan (Plan 1325/CP/1 v1) A3 Black and White (Former Restoration Plan 346/4) | | | | | CD2.8 | Earthwork Volume Analysis Proposed Final Levels. Drawing 0233.604. (Marked Received 6 April 2023) A1 Black and White | | | August 2018 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD2 | | Other Application Supporting Documents and | | | | --- | --- | --- | --- | --- | | CD2.9 | Earthwork Volume Analysis Cut and Fill Contours. Drawing 0233.606) (Marked as received 6 April 2023) A1 Colour | | | February 2018. | | CD2.10 | Potential Sources of Infill Material with Proposed site access routes to Site 1325/SZ/1 v.1 (A-E) (Received 18 February 2020) | | | August 2018 | | CD2.11 | Cut and Fill Volumes General Arrangement Plan. Drawing GB-324-001. 7 March 2023 A1 Colour | | | 7 March 2023 | | CD2.12 | Cut and Fill Volume Sections GB-324-004. (marked as received 6 April 2023) | | | 7 March 2023. | | CD2.13 | Restoration Plan (Plan 1.346.4). A3 Colour (Former Restoration Plan 346/4) | | | June 1981 | | CD2.14 | Restoration Proposals (Plan 2.37927b). A3. (Former Restoration Plan Redlands Roof tiles 1983) | | | August 1983 | | CD2.15 | Scoping Request (D.K Symes Associates) | | | May 2017 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD3 | | Environmental Statement Documents | | | | --- | --- | --- | --- | --- | | | | | | | | CD3.1 | Environmental Statement Main Report- prepared by Peter Radmall Associates (September 2018) | | | | | CD3.2 | Environmental Statement Volume 1: Non-technical Summary (September 2018); | | | | | CD3.3 | Environmental Statement: Technical Annex 1: Scoping Opinion | | | | https://www.gov.uk/planning-inspectorate 36 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | CD3.4 | Environmental Statement: Technical Annex 2: Application Drawings | | | --- | --- | --- | | CD3.5 | Environmental Statement: Technical Annex 3: Air Quality | | | CD3.6 | Environmental Statement: Technical Annex 4: Cultural Heritage Desk Based Assessment (CGMs) | | | CD3.7 | Environmental Statement: Technical Annex 5: Ecology. Ecological Impact Assessment (September 2018) | | | CD3.8 | Environmental Statement: Technical Annex 6: Flood risk and Drainage. Flood Risk Assessment & Surface Water Drainage Strategy. GB Card & Partners. | GB324- FRA&SWDS- SEPT-2018- REV1 September 2018 | | CD3.9 | Environmental Statement: Technical Annex 7: Ground Conditions (Phase 1 Desk Study and Preliminary Engineering Assessment) | GB324-P1DS- PEA-SEPT- 2018-REV5 September 2018 | | CD3.10 | Environmental Statement: Technical Annex 8: Landscape and Visual Impact. Landscape and Visual Impact Assessment (LVIA). Rummey Environmental | September 2018 | | CD3.11 | Environmental Statement: Technical Annex 9: Noise and Vibration (Plans only). | | | CD3.12 | Environmental Statement: Technical Annex 10: Transport. Transport Statement prepared by PJA | August 2018 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD4 | | Environmental Statement Addenda and | | | | --- | --- | --- | --- | --- | | | | Statements of Conformity | | | | CD4.1 | Statement of ES Compliance | | | 11 December 2019 | | CD4.1.1 | Appendix 1 – Geotec & Geo Enviro Interpretative Report GB324-GGIR-DEC-2019 | | | December 2019 | | CD4.1.2 | Appendix 2 – Ecology Technical Note | | | 9.12.2019 | | CD4.1.3 | Appendix 3 – Draft Outline Ecological Mitigation Plan | | | May 2019 | | CD4.1.4 | Appendix 4- Proposed Routing Agreement | | | 29.04.2019 | | CD4.1.5 | Appendix 5 – TS Missing figures 1) 13-2 Site location 2) 13-3 Public RoW 3) 13-1 Road Links 4) TEMPRO outputs | | | | | CD4.2 | Environmental Statement Addendum. (Marked as received 13 January 2021) | | | January 2021 | | CD4.3 | Environmental Statement (Statement on Conformity) (Marked as received 6 April 2023) | | | March 2023 | | CD4.4 | Environmental Statement (letter - Statement on Conformity) | | | 21 March 2024 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 37 Appeal Decision APP/W2275/W/25/3358947 | CD4.4.1 | Appended to ES letter – Green Belt Assessment (March 2024) | | | --- | --- | --- | | CD4.4.2 | Appended to ES letter –GB Card Technical Note 6 | | | CD4.4.3 | Appended to ES letter –ES Noise Chapter. ES Chapter 12 Noise and Vibration chapter prepared by LF Acoustics Ltd (Marked as received 29 April 2024) | | | CD4.4.4 | Appended to ES letter- Letter from L.F Acoustics | 1 March 2024 | | CD4.5 | ES Addendum with Tracked Changes | May 2025 | | CD4.6 | ES Addendum Final | May 2025 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD4.4.1 | Appended to ES letter – Green Belt Assessment (March 2024) | | | --- | --- | --- | | CD4.4.2 | Appended to ES letter –GB Card Technical Note 6 | | | CD4.4.3 | Appended to ES letter –ES Noise Chapter. ES Chapter 12 Noise and Vibration chapter prepared by LF Acoustics Ltd (Marked as received 29 April 2024) | | | CD4.4.4 | Appended to ES letter- Letter from L.F Acoustics | 1 March 2024 | | CD4.5 | ES Addendum with Tracked Changes | May 2025 | | CD4.6 | ES Addendum Final | May 2025 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD5 | | Consultation Responses | | | | --- | --- | --- | --- | --- | | | | | | | | CD5.1 | Sevenoaks District Council – including Sevenoaks District Council (Aboricultural & Landscape Officer) | | | | | CD5.2.1 | Westerham Town Council responses (All Objections) | | | 22.12.2018 | | CD5.2.2 | Westerham Town Council Letter | | | 02.05.2019 | | CD5.2.3 | Westerham Town Council (including transport and geotec review | | | February 2020 | | CD5.2.4 | Westerham Town Council response | | | April 2020 | | CD5.2.5 | Westerham Town Council response RPS traffic review addendum | | | 05.05.2020 | | CD5.2.6 | Westerham Town Council response | | | 18.02.2022 | | CD5.2.7 | Westerham Town Council response | | | August 2022 | | CD5.2.8 | Westerham Town Council response | | | June 2023 | | CD5.2.9 | Westerham Town Council response | | | 25 April 2024 | | CD5.2.10 | Westerham Town Council response | | | 23 May 2024 | | CD5.3 | Sundridge with Ide Hill Parish Council (Objection) | | | | | CD5.4 | Brasted Parish Council (Objection) | | | | | CD5.5 | Riverhead Parish Council (Objection) | | | | | CD5.6 | Chevening Parish Council (Objection) | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD5 | | Consultation Responses | | | | --- | --- | --- | --- | --- | | CD5.7 | Surrey County Council (No objection) | | | | | CD5.8 | Tandridge District Council (No objection) | | | | | CD5.9 | Warlingham Parish Council (Objection) | | | | | CD5.10 | Tatsfield Parish Council (Objection) | | | | | CD5.11 | Chelsham and Farleigh Parish Council (Objection) | | | | | CD5.12 | London Borough of Bromley Council (Objection) | | | | | CD5.13 | Croydon Council (No Comment) | | | | | CD5.14 | National Highways England (NH) (No Objection) | | | | | CD5.15 | Environment Agency (EA) (No Objection) | | | | | CD5.16 | Natural England (NE) (No Objection) | | | | | CD5.17 | Historic England (HE) (No comments) | | | | | CD5.18 | UK Health Security Agency (UKHSA) (formerly Public Health England) (No comment) | | | | | CD5.19 | Campaign to Protect Rural England (CPRE) Protect Kent (Objection) | | | | | CD5.20 | Kent Wildlife Trust (KWT) | | | | | CD5.21 | Kent Downs Area of Outstanding Natural Beauty (AONB) Unit (No Objection) | | | | | CD5.22 | Surrey Hills AONB Team (No objection) | | | | | CD5.23 | Thames Water (No comments) | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 38 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD5.24 | Kent County Council Highways and Transportation | 30.04.02024 | | --- | --- | --- | | CD5.25 | KCC Geotechnical (Amey) Ground Engineering Review | 16.03.2020 | | CD5.26 | Amey June Meeting follow up report – scope - Ground water, slope stability and design | 21.07.2020 | | CD5.27 | Amey Response to Questions 22.02.21 | 18.03.2021 | | CD5.28 | Amey – Technical note – Response to Questions 02.02.2022 Rev B | | | CD5.29 | Amey – Technical Note – Rev A | 28.02.2022 | | CD5.30 | Amey letter - Landscape | 23.08.2022 | | CD5.31 | Amey letter – Air Quality | 08.09.2022 | | CD5.32 | Amey -Technical note to questions 13.01.2023 Rev B | | | CD5.33 | Amey – Technical Note Position Statement | 16.06.2023 | | CD5.34 | Amey – Technical Note – Geotechnical | 31.07.2023 | | CD5.35 | Amey – Technical Note- Drainage Report 4 Revision 1 | 22.09.2023 | | CD5.36 | Amey Technical Note – Geotechnical Summary | 14.11.2023 | | CD5.37 | Amey – Technical Note – Drainage Report 4 Revision 2 | 17.11.2023 | | CD5.38 | Amey – Technical Note – Geotechnical Response | 24.04.2024 | | CD5.39 | Amey – Landscape Response | 10.05.2024 | | CD5.40 | Amey- Drainage Response | 10.05.2024 | | CD5.41 | KCC- Public Rights of Way (No Objection) | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD5.24 | Kent County Council Highways and Transportation | 30.04.02024 | | --- | --- | --- | | CD5.42 | KCC - County Heritage Conservation Officer (CO) (No objection) | | | CD5.43 | KCC Ecological Advice Service (EAS) response | | | CD5.44 | KCC Flood and Water Management (F&M) (No Objection) | | | CD5.45 | KCC Policy Response | | | CD5.46 | County Archaeological Officer (CAO) (No objection) | | | CD5.47 | Kent County Council’s Air Quality & Odour Consultants (Amey-AQ) - Final response | | | CD5.48 | Kent County Council’s Noise Consultants (Amey – Noise) - Final response | | | CD5.49 | Kent County Council’s Landscape Consultants (Amey- Landscape) - Final response | | | CD5.50 | Letter from Councillor Sandra Robinson | 27.05.2024 | | CD5.51 | Keep Westerham Green Letter | | | CD5.52 | Letter from Westerham Society | | | CD5.53 | Letter from Claire Coutino MP | 26.05.2021 | | CD5.54 | Letter from Oxted and Limpsfield Residents Group | 06.02.2020 | | CD5.55 | Letter from Woldingham Association | 16.02.2020 | | CD5.56 | Letter from Laura Trott MP | 16.06.2020 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD5.24 | Kent County Council Highways and Transportation | 30.04.02024 | | --- | --- | --- | | CD5.58 | Statement on behalf of Community Stakeholders presented by Local KCC Member Nick Chard to the Planning Applications Committee Site Visit, October 2021 | | | CD6 | | Development Plan | | | | --- | --- | --- | --- | --- | | | | | | | https://www.gov.uk/planning-inspectorate 39 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | CD6.1 | Kent Minerals and Waste Local Plan (KMWLP) 2013- 2039 (Approved for Adoption at Committee on 13 March 2025) | Adoption date 24.04.2025 | | --- | --- | --- | | CD6.2 | Kent Minerals Site Plan | Adopted 2020 | | CD6.3 | Sevenoaks Core Strategy | Adopted February 2011 | | CD6.4 | Sevenoaks Allocations and Development Management Plan (ADMP) | Adopted February 2015 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD6.1 | Kent Minerals and Waste Local Plan (KMWLP) 2013- 2039 (Approved for Adoption at Committee on 13 March 2025) | Adoption date 24.04.2025 | | --- | --- | --- | | CD6.2 | Kent Minerals Site Plan | Adopted 2020 | | CD6.3 | Sevenoaks Core Strategy | Adopted February 2011 | | CD6.4 | Sevenoaks Allocations and Development Management Plan (ADMP) | Adopted February 2015 | | CD7 | | Supplementary Planning Guidance and | | | | --- | --- | --- | --- | --- | | | | Documents (SPGs/ SPDs) Other Relevant | | | | | | Guidance and Background Documents | | | | CD7.1 | Kent Downs National Landscape: Landscape Character Assessment 2020 | | | | | CD7.2 | Kent Downs National Landscape Management Plan 2021-2026 | | | | | CD7.3 | Westerham Conservation Area Appraisal Dec 2023 | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD7 | | Supplementary Planning Guidance and | | | | --- | --- | --- | --- | --- | | | | Documents (SPGs/ SPDs) Other Relevant | | | | | | Guidance and Background Documents | | | | CD7.1 | Kent Downs National Landscape: Landscape Character Assessment 2020 | | | | | CD7.2 | Kent Downs National Landscape Management Plan 2021-2026 | | | | | CD7.3 | Westerham Conservation Area Appraisal Dec 2023 | | | | | CD8 | | Development Plan Evidence Base | | | | --- | --- | --- | --- | --- | | | | | | | | CD8.1 | Kent Waste Needs Assessment 2022 Update Construction, Demolition & Excavation Waste Management Requirements in Kent | | | | | CD8.2 | Inspectors Report into the Kent Minerals and Waste Local Plan | | | | | CD8.3 | Kent Minerals and Waste Local Plan 2013-2030 | | | | | CD8.4 | Kent County Council Local Aggregate Assessment 2023 | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD8 | | Development Plan Evidence Base | | | | --- | --- | --- | --- | --- | | | | | | | | CD8.1 | Kent Waste Needs Assessment 2022 Update Construction, Demolition & Excavation Waste Management Requirements in Kent | | | | | CD8.2 | Inspectors Report into the Kent Minerals and Waste Local Plan | | | | | CD8.3 | Kent Minerals and Waste Local Plan 2013-2030 | | | | | CD8.4 | Kent County Council Local Aggregate Assessment 2023 | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD9 | | Appellant’s Appeal Documents | | | | --- | --- | --- | --- | --- | | | | | | | | CD9.1 | Appeal Form (completed by Union4 Planning) | | | 14.01.2025 | | CD9.2 | Appeal Cover Letter (completed byUnion4 Planning) | | | 14.01.2025 | | CD9.3 | Appeal Notice (Annexe 2A) and covering letter (prepared by Union4 Planning | | | 14.01.2025 | | CD9.4 | Statement of Case prepared by Steve Fidgett (Union4 Planning) | | | 14.01.2025 | | CD9.5 | Draft Statement of Common Ground (SoGC) (Issued with the Appeal submission) | | | 14.01.2025 | | CD9.6 | Draft list of Core Documents (Version issued with the Appeal) | | | | | CD9.7 | Appeal Site Notice | | | 22.04.2025 | | CD9.8 | Letter from Union4 Planning – Response to PINs Regulation 25 request | | | 09.04.2025 | | CD9.9 | CMC note of Behalf of the Appellant | | | 27 March 2025 | | CD9.10 | Proof of Evidence -Slope Stability, Drainage and Restoration (Environmental Protection Group) Evidence prepared by Steven Wilson | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 40 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | CD9.10.S | Summary Proof Mr Steven Wilson | | | --- | --- | --- | | CD9.11 | Proof of Evidence – Planning Balance (Union4) - Evidence prepared by Steven Fidgett | | | CD9.11.S | Summary Proof Mr Steven Fidgett | | | CD9.12 | Proof of Evidence – Availability of Inert Restoration Fill. Evidence prepared by Stuart Accleton | | | CD9.13 | Proof of Evidence- Landscape and Visual Impact. Evidence prepared by Robert Rummey | | | CD9.13.S | Summary Proof Mr Robert Rummey | | | CD9.14 | Proof of Evidence – Transport Evidence prepared by Matthew Franklin | | | CD9.14.S | Summary Proof Transport | | | CD9.15 | Proof of Evidence – Stewardship Evidence of Mr Henry Warde | | | CD9.16 | LVIA Updated Addendum | | | CD9.17 | Rebuttal Proof of Evidence by Steven Wilson | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD10 | | Kent County Council Appeal Documents | | | | --- | --- | --- | --- | --- | | | | | | | | CD10.1 | Planning Committee Report (SE/18/3435 (KCC/SE/0495/2018) | | | | | CD10.2 | Decision Notice SE/18/3435 (SE/1165) | | | Issued 17.07. 2024 | | CD10.3 | Minutes of Planning Committee dated 15 July 2024 | | | | | CD10.4 | List of consultees notified of the appeal | | | | | CD10.5 | Appeal Questionnaire | | | 10.02.2025 | | CD10.6 | Statement of Case | | | 10.03.2025 | | CD10.7 | List of Consultees Notified of Appeal | | | | | CD10.8 | Suggested Draft planning conditions (KCC02) | | | March 2025 | | | Proof(s) of Evidence | | | | | CD10.9 | Proof of Evidence Adrian Lynham | | | | | CD10.10 | Proof of Evidence Dr Doug Lewis | | | | | CD10.11 | Proof of Evidence Michael Ashley | | | | | CD10.12 | Summary Report Covers Quarry – Alternative Restoration Plan CO04300759 / LSCP-001 / P01 | | | 28 April 2025 | | CD10.13 | Rebuttal Proof of Evidence Adrian Lynham | | | | | CD10.14 | Rebuttal Proof of Evidence Michael Ashley | | | | | CD10.15 | Rebuttal Proof of Evidence Dr Doug Lewis | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD11 | | Other Appeal/ Inquiry Representations | | | | --- | --- | --- | --- | --- | | | | | | | | CD11.1 | Interested Party Representation | | | | | CD11.2 | Councillor Robinson Representation | | | 10 March 2025 | | CD11.3 | Keep Westerham Green Representation | | | | | CD11.4 | Interested Party Representation | | | | | CD11.5 | Westerham Town Council Representation | | | | | CD12 | | Other Appeal Documents | | | | --- | --- | --- | --- | --- | | | | | | | https://www.gov.uk/planning-inspectorate 41 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | CD12.1 | Appellant start letter | 03.02.2025 | | --- | --- | --- | | CD12.2 | LPA Start Letter | 03.02.2025 | | CD12.3 | Case Management Conference (CMC) Invitation | 13.03.2025 | | CD12.4 | Case Management Conference (CMC) Agenda | 13.03.2025 | | CD12.5 | Case Management Conference (CMC) Pre- conference note | 13.03.2025 | | CD12.6 | Letter from PINs -Regulation 25 of the EIA Regulations | 27.03.2025 | | CD12.7 | Case Management Conference (CMC) Summary note of CMC held on 27.03.2025 | Received 2.3.2025 | | CD12.8 | Statement of Common Ground (agreed between KCC as Local Planning Authority and Morants Promotions Ltd as appellant). Issued to PINS 17.04.2025 | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD12.1 | Appellant start letter | 03.02.2025 | | --- | --- | --- | | CD12.2 | LPA Start Letter | 03.02.2025 | | CD12.3 | Case Management Conference (CMC) Invitation | 13.03.2025 | | CD12.4 | Case Management Conference (CMC) Agenda | 13.03.2025 | | CD12.5 | Case Management Conference (CMC) Pre- conference note | 13.03.2025 | | CD12.6 | Letter from PINs -Regulation 25 of the EIA Regulations | 27.03.2025 | | CD12.7 | Case Management Conference (CMC) Summary note of CMC held on 27.03.2025 | Received 2.3.2025 | | CD12.8 | Statement of Common Ground (agreed between KCC as Local Planning Authority and Morants Promotions Ltd as appellant). Issued to PINS 17.04.2025 | | | CD13 | | Relevant Judgements and Appeals | | | | --- | --- | --- | --- | --- | | | | | | | | CD13.1 | R (Lee Valley Regional Park Authority) v Epping Forest DC and Valley Grown Nurseries Ltd 2016 | | | | | CD13.2 | Turner v SSCLG 2016 | | | | | CD13.3 | Europa Oil and Gas Ltd v Secretary of State for Communities and Local Government [2013] | | | | | CD13.4 | Supreme Court Judgement Samuel Smith Old Brewery (Tadcaster) and others) (Respondents) v North Yorkshire County Council (Appellant) | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD13 | | Relevant Judgements and Appeals | | | | --- | --- | --- | --- | --- | | | | | | | | CD13.1 | R (Lee Valley Regional Park Authority) v Epping Forest DC and Valley Grown Nurseries Ltd 2016 | | | | | CD13.2 | Turner v SSCLG 2016 | | | | | CD13.3 | Europa Oil and Gas Ltd v Secretary of State for Communities and Local Government [2013] | | | | | CD13.4 | Supreme Court Judgement Samuel Smith Old Brewery (Tadcaster) and others) (Respondents) v North Yorkshire County Council (Appellant) | | | | | CD14 | | Planning History | | | | --- | --- | --- | --- | --- | | | | | | | | CD14.1 | Permission 83/01511 | | | | | CD14.1.1 | Restoration proposals (83/01511) | | | | | CD14.2 | Permission 75/01088 | | | | | CD14.3 | Permission SE/02/2255 | | | | | CD14.4 | Permission SE/14/1680 | | | | | CD14.5 | Permission SE/15/3215 | | | | | CD14.6 | Permission SE/17/3215 | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | CD14 | | Planning History | | | | --- | --- | --- | --- | --- | | | | | | | | CD14.1 | Permission 83/01511 | | | | | CD14.1.1 | Restoration proposals (83/01511) | | | | | CD14.2 | Permission 75/01088 | | | | | CD14.3 | Permission SE/02/2255 | | | | | CD14.4 | Permission SE/14/1680 | | | | | CD14.5 | Permission SE/15/3215 | | | | | CD14.6 | Permission SE/17/3215 | | | | OTHER INQUIRY DOCUMENTS (ID)

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington OTHER INQUIRY DOCUMENTS (ID) | ID1 | | Other correspondence including Technical | | | | --- | --- | --- | --- | --- | | | | Responses during the application | | | | | | | | | | ID1.1 | Agents Cover letter (for additional information) 12 December 2019 | | | | | ID1.2 | Note regarding Restoration Soils – From Erith (marked as received 1 October 2021) | | | 30-09-21 | | ID1.3 | Technical Note on Slope Stability from GB Card (ref: GBC/GB/324) | | | 12 March 2020 | | ID1.4 | GB Card Technical Note on Phase 2 Review by Amey Consulting date 16 March 2020. | | | 23 July 2020 | https://www.gov.uk/planning-inspectorate 42 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID1.5 | Response to Point 4 of the Redacted Objection relating to the Traffic light Chart (marked as received 16 March 2021) | 15 March 2021 | | --- | --- | --- | | ID1.6 | Email from Agent (D.K Symes Associates) to KCC | 18 February 2020 | | ID1.7 | Letter from Henry Warde setting out response to objections (Marked as received 21 March 2021) | 19 March 2021 | | ID1.8 | Letter from GB Card. Technical Note TN03.– response to Letter from Environment Agency (17th February 2021) | 8 March 2021 | | ID1.9 | Letter from GB Card. Technical Note TN04– response to Letter from Environment Agency -17th February 2021. | 16 March 2021 | | ID1.10 | Email from Agent in respect of Noise Assessment | 5 July 2023 | | ID1.11 | Letter from ECOSA in response to biodiversity / KWT Comments | 3 August 2023 | | ID1.12 | GB Card Technical Note TN05– response to reports prepared by Amey Consulting 14th December 2023 | 01 February 2024 | | ID1.13 | DSKA draft email to KCC | 12 February 2020 | | ID1.14 | GB Card Letter Soakaway Investigation Report | 19 December 2017 | | ID1.15 | GB Card Preliminary Haul Road Stability Assessment GB324-PHRSA-270718 | | | ID1.16 | GB Card RAMs for Ground Investigations | July 2019 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID1.5 | Response to Point 4 of the Redacted Objection relating to the Traffic light Chart (marked as received 16 March 2021) | 15 March 2021 | | --- | --- | --- | | ID1.17 | GB Card Report on Drainage Investigation | July 2019 | | ID1.18 | GB Card Letter- Temporary Access Road - Letter Statement of Intent | 14 February 2019 | | ID1.19 | GB Card Specifications for Soakaway Test | May 2022 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID1.5 | Response to Point 4 of the Redacted Objection relating to the Traffic light Chart (marked as received 16 March 2021) | 15 March 2021 | | --- | --- | --- | | ID1.17 | GB Card Report on Drainage Investigation | July 2019 | | ID1.18 | GB Card Letter- Temporary Access Road - Letter Statement of Intent | 14 February 2019 | | ID1.19 | GB Card Specifications for Soakaway Test | May 2022 | | ID2 | | Other Relevant Appellant Documents | | | | --- | --- | --- | --- | --- | | | | | | | | ID2.1 | GC Card Slope Monitoring Report | | | April 2018 | | ID2.2 | GC Card Slope Monitoring Report | | | December 2018 | | ID2.3 | GC Card Slope Monitoring Report | | | April 2019 | | ID2.4 | Union4 Planning Letter – Technical Note: Fill Volume Required | | | 24 June 2024 | | ID2.5 | Covers Quarry, Review of Proposed Restoration (Restoration (Environmental Protection Group) Prepared by Steve Wilson | | | 20 December 2024 V.2 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID2 | | Other Relevant Appellant Documents | | | | --- | --- | --- | --- | --- | | | | | | | | ID2.1 | GC Card Slope Monitoring Report | | | April 2018 | | ID2.2 | GC Card Slope Monitoring Report | | | December 2018 | | ID2.3 | GC Card Slope Monitoring Report | | | April 2019 | | ID2.4 | Union4 Planning Letter – Technical Note: Fill Volume Required | | | 24 June 2024 | | ID2.5 | Covers Quarry, Review of Proposed Restoration (Restoration (Environmental Protection Group) Prepared by Steve Wilson | | | 20 December 2024 V.2 | https://www.gov.uk/planning-inspectorate 43 Appeal Decision APP/W2275/W/25/3358947

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 | ID3 | | Other National Planning Policy, Guidance and | | | | --- | --- | --- | --- | --- | | | | Statements | | | | ID3.1 | National Planning Policy for Waste (NPPW) | | | October 2014 | | ID3.2 | Our Waste, Our Resources: A Strategy for England | | | 2018 | | ID3.3 | Waste Management Plan for England (WMPE) | | | 2021 | | ID3.4 | The Circular Economy Package Policy Statement | | | 2020 | | ID3.5 | A Green Future: Our 25 Year Plan to Improve the Environment | | | 2018 |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID3 | | Other National Planning Policy, Guidance and | | | | --- | --- | --- | --- | --- | | | | Statements | | | | ID3.1 | National Planning Policy for Waste (NPPW) | | | October 2014 | | ID3.2 | Our Waste, Our Resources: A Strategy for England | | | 2018 | | ID3.3 | Waste Management Plan for England (WMPE) | | | 2021 | | ID3.4 | The Circular Economy Package Policy Statement | | | 2020 | | ID3.5 | A Green Future: Our 25 Year Plan to Improve the Environment | | | 2018 | | ID4 | | | | Other Consultation Responses | | | | | | --- | --- | --- | --- | --- | --- | --- | --- | --- | | | | | | | | | | | | | | | | Residents Groups | | | | | | | | | Keep Westerham Green | | | | | | | | | | Westerham Society | | | | | | | | | | Woldingham Association and Oxted & Limpsfield Residents Association | | | | | | | | | | | Members/ Councillors/MP | | | | | | | | | | | | | | | | | | | local County Member for Sevenoaks West, Mr Nick Chard | | | | | | | | | | Laura Trott, MP for Sevenoaks and Swanley | | | | | | | | | | Claire Coutinho, MP for East Surrey | | | | | |

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington | ID4 | | | | Other Consultation Responses | | | | | | --- | --- | --- | --- | --- | --- | --- | --- | --- | | | | | | | | | | | | | | | | Residents Groups | | | | | | | | | Keep Westerham Green | | | | | | | | | | Westerham Society | | | | | | | | | | Woldingham Association and Oxted & Limpsfield Residents Association | | | | | | | | | | | Members/ Councillors/MP | | | | | | | | | | | | | | | | | | | local County Member for Sevenoaks West, Mr Nick Chard | | | | | | | | | | Laura Trott, MP for Sevenoaks and Swanley | | | | | | | | | | Claire Coutinho, MP for East Surrey | | | | | | https://www.gov.uk/planning-inspectorate 44

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington https://www.gov.uk/planning-inspectorate 44

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 ANNEX E SCHEDULE OF CONDITIONS Implementation and Approved Plans 1) The development hereby permitted shall begin not later than five years from the date of this decision. Written notification of the date of commencement shall be provided to the County Planning Authority within 7 days of such commencement. For the purposes of this condition, commencement shall include any works to construct the haul road. 2) The development to which this permission relates shall be completed and the site be restored, including delivery of the landscape scheme and the removal and restoration of the haul road, site compound, treatment area, all plant, machinery, structures, buildings, lighting, hard standing, and stockpiled materials not provided for in the approved restoration scheme, no later than six years from the date of commencement. 3) The development to which this permission relates shall be carried out and completed in all respects in accordance with the details set out in the following drawings and as required in the conditions set out in this decision: a. 1325/L/1 v1 – Site Plan; b. 1225/SC/1 v2 – Site Context Plan; c. 1325/A/1 v4 – Application Plan; d.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 1325/S/3 v5 Site Plan (As existing); e. 1325/CR/1 v5 – Croydon Road Crossing and Compound details; f. 1325/CO/1 v4 – Composite Operations Plan; g. 1325/PO/1 v6 – Progressive operations Plan; h. 1325/CS/1 v1 – Illustrative Cross Sections (As existing); i. 1325/CS/2 V2 – Illustrative Cross Sections (Showing Restored Landform); j. 1325/AR/1 v10 – Illustrative Route of Internal Access Road (West); k. 1325/AR/2 v9 – Illustrative Route of Internal Access Road (East); l. 1325/R/3 v8 – Restoration Plan dated 14 February 2023; m. GB-324-001 Rev. 0 Cut & Fill Volumes General Arrangement Exg Topo 0m dated 7 March 2023; and n. GB-324-004 Rev 0 Cut & Fill Volumes Sections Exg Topo 0m dated 7 March 2023. Temporary Haul Road 4) Prior to construction of the haul road details of the design shall be submitted and approved in writing by the County Planning Authority. The design information submitted shall include: https://www.gov.uk/planning-inspectorate 45

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 a. Details of the full route and alignment of the proposed haul road (from the Beggers Lane roundabout to Croydon Road and then from Croydon Road to the Treatment Area) in accordance with the principles established by drawings 1325/AR/1 v10 – Illustrative Route of Internal Access Road (West); 1325/AR/2 v9 – Illustrative Route of Internal Access Road (East); 1325/CR/1 v5 – Croydon Road Crossing and Compound details; and 1325/CO/1 v4 – Composite Operations Plan; b. Details of the signalised Croydon Road crossing, including details of the highway layout, measures to prevent vehicles leaving the site and traveling southwards into Westerham, road markings, signage, details of associated fencing and gates, the provision of site lines to the access points and associated vegetation clearance, as shown on drawings 1325/AR/1 v10 – Illustrative Route of Internal Access Road (West) and 1325/CR/1 v5 – Croydon Road Crossing and Compound details; c.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of the revised layout of Beggars Lane roundabout access, including details of the highway layout, road markings, signage, details of associated fencing and gates (set back from the public highway to allow a HGV to move off the roundabout before reaching the gates), the provision of site lines and associated vegetation clearance, as shown on drawing 1325/AR/2 v9 – Illustrative Route of Internal Access Road (East); d. Construction drawings and specifications for the haul road, including the method of construction, details of the access and egress points from the public highway, details of volume and type of construction materials, details of the surface treatment(s), details of road widths and passing bays, drainage and surface water management provisions; e. Technical information on the construction method, including design calculations, to demonstrated that the haul road would be engineered such that it would not compromise the integrity of the M25; f.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington A method statement covering the management and protection of soils, including a soil resource plan identifying areas of topsoil and subsoil to be stripped, including depths and volumes; details of the method of soil stripping ensuring separation of topsoil and subsoil, a handling protocol to avoid damage, compaction and contamination, including arrangements to ensure that soils shall only be stripped, handled, stored or replaced when in a dry and friable condition; g. Bund construction details to provide screening of the haul road and compound in accordance with the principles shown in drawings 1325/AR/1 v10 – Illustrative Route of Internal Access Road (West); 1325/AR/2 v9 – Illustrative Route of Internal Access Road (East); 1325/CR/1 v5 – Croydon Road Crossing and Compound details, including location, height and dimensions, separate storage of top and sub soils, the intended profiles of the bunds and how they relate to the adjacent landform and any other landscape feature (such as woodland), stability measures, grass seeding to protect the resource, an implementation and maintenance regime, and measures for monitoring and maintaining soil quality during storage; https://www.gov.uk/planning-inspectorate 46

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 h. Measures to ensure mud and debris are not deposited on the public highway during construction (both in relation to the Beggers Lane roundabout and Croydon Road; and i. Details of a monitoring and maintenance regime for the haul road to ensure it remains fit for purpose for the duration of the development, including measures to ensure a smooth surface to minimise noise and dust associated with vehicle movements (particularly when vehicles are empty). The haul road shall be constructed in accordance with the details approved and shall thereafter be maintained to the approved standard for the duration of the development. If the applicant or contractor wishes to make a change to the approved design during the design /or construction phase, details of the change shall be submitted for the prior written approval of the County Planning Authority. The haul road shall be removed and the land restored within the timeframes provided for by condition 2 above and in accordance with a scheme submitted pursuant to condition 45.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 5) Except for the purpose of constructing the haul road, no importation of infill material shall take place until the haul road, as approved pursuant to condition 4 above, is completed in full in accordance with the details approved. 6) Prior to the commencement of the development hereby permitted, a Construction Environmental Management Plan (CEMP), covering both the construction and operational phases of the development, shall be submitted to and approved in writing by the County Planning Authority. The CEMP shall include: a. Construction Traffic Management Plan for the delivery of the haul road – including: i. Routing of construction and delivery vehicles to/from site. ii. Site access arrangements and controls. iii. Parking and turning areas for construction and delivery vehicles and site personnel. iv. Timing of deliveries, avoiding network and school peaks where possible. v. Implementation of temporary traffic management and signage, including posting signs to alert drivers of the potential presence of the public, especially before the crossing at Croydon Road and where Public Right of Way SR338 intersects with the access road. b.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of the implementation, decommissioning, and restoration of any temporary construction compound required specifically for the construction of the haul road; c. Details of the temporary welfare facilities to be provided on-site, as well as the measures to be implemented during construction to ensure no discharges to the environment. d. Appropriate pollution prevention measures to be implemented during construction to stop contaminated runoff, pollution, soils, silt or debris https://www.gov.uk/planning-inspectorate 47

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of the implementation, decommissioning, and restoration of any temporary construction compound required specifically for the construction of the haul road; c. Details of the temporary welfare facilities to be provided on-site, as well as the measures to be implemented during construction to ensure no discharges to the environment. d. Appropriate pollution prevention measures to be implemented during construction to stop contaminated runoff, pollution, soils, silt or debris https://www.gov.uk/planning-inspectorate 47

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 resulting from construction operations from entering nearby surface water drainage networks. e. The mitigation measures to be incorporated from the Ecological Mitigation and Habitat Creation Plan (EMHCP) required by condition 24 below, including measures to ensure protected/ priority species and habitats identified on site are protected during both construction of the haul road and the operational phase of the development. f. Arrangements to accommodate the archaeological watching brief required pursuant to condition 11; g. A scheme to ensure there is no deposit of mud and/or debris on the public highway, from vehicles leaving the site at both the crossing on Croydon Road and at the access onto the Beggers Lane roundabout. The scheme shall address: i. Details of the location, design and capacity of wheel and chassis cleaning measures to be employed during the operational phase (including a wheel wash system incorporating a closed-loop water management system to prevent contaminated runoff, provision of mechanical wheel spinners, shakers, and/or wheel baths as necessary). ii.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Daily inspection and maintenance of internal access roads, equipment and the public highway at the entrances to the site to ensure cleanliness and effectiveness of the measures; iii. A record to be maintained and made available to the County Planning Authority on request of any identified problem or complaint and details of the measures deployed to address the matter; iv. Deployment of a mechanically propelled road sweeper to clean internal haul roads and the site access points as required; v. Site management arrangements to ensure all vehicles exiting the site shall pass through the approved system(s); vi. Details of the reporting arrangements to demonstrate that the approved facilities and measures shall be maintained in full working order and used throughout the operational life of the development. vii. Details of the implementation, maintenance, and review mechanisms for these arrangements to ensure that no mud and debris is deposited on the public highway throughout the life of the development. h. All loaded open-backed vehicles entering the site shall be sheeted or otherwise enclosed. i.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Noise management plan during construction of the haul road, including the mitigation and monitoring measures set out in update to the Noise and Vibration Chapter of the Environmental Statement (Ref: ES r1.4 260424) received 29 April 2024, including undertaking the construction of the bunds and other noisy activity close to the school outside of normal school hours; https://www.gov.uk/planning-inspectorate 48

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Noise management plan during construction of the haul road, including the mitigation and monitoring measures set out in update to the Noise and Vibration Chapter of the Environmental Statement (Ref: ES r1.4 260424) received 29 April 2024, including undertaking the construction of the bunds and other noisy activity close to the school outside of normal school hours; https://www.gov.uk/planning-inspectorate 48

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 Once approved, the CEMP shall be implemented as approved both during the construction of the haul road and for the life of the development. 7) Prior to the commencement of the development hereby permitted, a pre- commencement highway condition report for Beggars Lane from the A25 up to and including the Beggars Lane Roundabout (Junction with London Road) shall be carried out and submitted to the County Planning Authority. Infilling and Restoration 8) Prior to the commencement of the development, a Monitoring Strategy and Emergency Action Plan demonstrating that all operations proposed on site will maintain the integrity and functionality of the M25 strategic network shall be submitted and approved in writing by the County Planning Authority. The report shall include: a. An Instrumentation and Monitoring Strategy with agreed trigger levels both during and post completion of the restoration works; b. Reporting procedures; and c. Preparation of an Emergency Action Plan with agreed actions in case of trigger breaches. Once approved, the Monitoring Strategy and Emergency Action Plan shall be implemented as approved and maintained during the life of the development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Surface water drainage 9) Prior to the commencement of the development hereby permitted, a detailed surface water drainage scheme for the site shall be submitted to and approved in writing by the County Planning Authority in general accordance with the approved plans, and shall demonstrate that the surface water generated by this development (for all rainfall durations and intensities up to and including the climate change adjusted critical 100 year storm) can be accommodated and disposed of within the curtilage of the site without increase to flood risk on or off- site. The drainage scheme shall include: a. Design details of the additional infiltration basin proposed adjoining the Southern Lake; b. Details to control and manage the proposed infiltration to ground, including any silt or pollutants, demonstrating that the development would result in no pollution risk to controlled waters and/or any unacceptable risk to ground stability; c. Details of control measures to manage surface water run-off on site; d. Details of the proposed measures to manage water quality; e. Details of the timing of such works, including in the context of each phase of the development; and f.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of appropriate ongoing operational, maintenance and management regime for the proposed scheme both during and following completion of the development. https://www.gov.uk/planning-inspectorate 49

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of appropriate ongoing operational, maintenance and management regime for the proposed scheme both during and following completion of the development. https://www.gov.uk/planning-inspectorate 49 Appeal Decision APP/W2275/W/25/3358947 The surface water drainage scheme shall be implemented and maintained in accordance with the approved details. Working and Phasing 10) Prior to the importation of any infill materials, save for the haul road, a detailed working and phasing scheme shall be submitted and approved in writing by the County Planning Authority. Such scheme shall include: a. Details of the phases of working, including drawings and supporting information describing the operations to take place in each phase of the development; b. Details of the engineering of the berms to create the cells within the northern lake; c. A scheme for the progressive dewatering of the northern lake, including measures to control surface water runoff to ensure there is no increased risk of surface water flooding and measures to protect water quality; d. Details of the subsequent filling of each of the cells, including measures to ensure that only suitable granular infill material is deposited below the waterline; e.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Final details of the site compound in accordance with the principles shown on drawing 1325/CR/1 v5 – Croydon Road Crossing and Compound details, including details of all buildings, plant and equipment, surface treatment, car parking, external lighting, fuel storage and refueling area; f. Details of the treatment area shown on drawing 1325/CO/1 v4 – Composite Operations Plan, including a layout plan. The details shall include all operations proposed to take place in this area (such as any material handling, screening, storage, quarantine area for unsuitable fill material, and separate arrangements for topsoil production), details of the formation of the area (including the method of construction and the prior infill of the area within the footprint of the lake); g. Details of a notice board to be erected at the site entrance(s) providing details of the site operator, including contact daytime details for the company, the site manager and/or site office and an emergency contact outside normal working hours; h. Details of any new fencing and boundary treatment not covered by the details approved by condition 4 or condition 26; i.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Other than soil management approved in connection with the haul road, a method statement covering the management and protection of any other soils and overburden on the site, including a soil resource plan identifying areas of topsoil and subsoil to be stripped, including depths and volumes; details of the method of soil stripping ensuring separation of topsoil and subsoil, a handling protocol to avoid damage, compaction and contamination, including arrangements to ensure that soils shall only be stripped, handled, stored or replaced when in a dry and friable condition; https://www.gov.uk/planning-inspectorate 50

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Other than soil management approved in connection with the haul road, a method statement covering the management and protection of any other soils and overburden on the site, including a soil resource plan identifying areas of topsoil and subsoil to be stripped, including depths and volumes; details of the method of soil stripping ensuring separation of topsoil and subsoil, a handling protocol to avoid damage, compaction and contamination, including arrangements to ensure that soils shall only be stripped, handled, stored or replaced when in a dry and friable condition; https://www.gov.uk/planning-inspectorate 50

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 j. Other than the bund creation approved in connection with the haul road, details of any other bund construction proposed on site, including location, height and dimensions, separation of top and sub soils, the intended profiles of the bunds and how they relate to the adjacent landform and any other landscape feature (such as woodland), stability measures, vegetation cover, and measures for monitoring and maintaining soil quality during storage; and k. A timetable for the implementation and delivery of the phases of work describe above. Thereafter, the working and phasing scheme shall be implemented in accordance with the approved details. Archaeology 11) Prior to the commencement of any preliminary groundworks associated with the haul road, details of an archaeological watching brief shall be submitted to and approved in writing by the County Planning Authority. The watching brief shall be implemented as approved by an archaeologist agreed by the County Planning Authority so that the soil stripping and any excavations along the haul road are observed and any items of interest and finds are recorded and reported in accordance with the approved watching brief.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Materials Handling 12) The volume of inert fill material imported to site shall not exceed 800,000m3 or that necessary to achieve the permitted site contours, whichever is the lesser. 13) Only inert materials shall be imported to the site. 14) Prior to the establishment of the treatment area shown on drawing 1325/CO/1 v4 – Composite Operations Plan and other than materials required for the construction of the haul road, only clean inert granular material shall be imported to the site. 15) Prior to commencement of infilling hereby permitted, a detailed Topsoil Production and Management Scheme shall be submitted for the written approval of the County Planning Authority. The Topsoil Production and Management Scheme shall include: a. Details of the origin, composition, and quality of materials to be used for topsoil production, including any imported materials; b. Description of the process for blending subsoil, compost, or other organic materials to create a suitable topsoil medium, including evidence that the topsoil would meet the requirements of BS 3882:2015 (Specification for Topsoil); c. Measures to ensure the material is free from contaminants, invasive species, and construction waste; d.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Methodology for handling and storing soils to prevent degradation, including: • Minimising multiple handling; • Avoiding handling in wet conditions; • Use of temporary bunds with appropriate seeding to prevent erosion; https://www.gov.uk/planning-inspectorate 51

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Methodology for handling and storing soils to prevent degradation, including: • Minimising multiple handling; • Avoiding handling in wet conditions; • Use of temporary bunds with appropriate seeding to prevent erosion; https://www.gov.uk/planning-inspectorate 51

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 e. Depths and methods for spreading topsoil across the restoration area; f. Measures to ensure even distribution and integration with subsoil layers; g. Use of appropriate machinery to avoid compaction; h. Details of soil improvement (e.g. fertilisation, decompaction) where necessary; The approved scheme shall be implemented in full and maintained throughout the restoration and aftercare phases of the development. 16) With the exception of materials imported to construct the haul road, all material imported to the site shall either be placed directly within the infill area, or be deposited, inspected and/or stored, within the treatment area shown on drawings 1325/PO/1 v6 Progressive Operations Plan and 1325/CO/1 v4 Composite Operations Plan, prior to placement. No other locations within the site shall be used for this purpose. 17) No stockpiles of any material on the site shall exceed 3m in height above the existing ground level. 18) Any materials received on site that do not meet the criteria as inert infill material shall be quarantined and removed from the site as soon as practicable, and no later than within 48 hours of receipt.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 19) No crushing of any material shall take place on site. 20) Other than contaminated material which is not suitable for use in infilling or restoration, no materials shall be exported from the site. 21) If contamination not previously identified is found to be present at the site during development then no further development shall take place within the relevant phase or part thereof until a remediation strategy has been submitted to and approved in writing by the County Planning Authority detailing how this contamination will be dealt with. The remediation strategy shall be implemented as approved. Dust management 22) Prior to the commencement of the development hereby permitted a Dust Management and Monitoring Plan shall be submitted to and approved in writing by the County Planning Authority. The Dust Management and Monitoring Plan shall include (amongst other matters): a. A plan of dust generating activities and the closest sensitive receptors; b. Details of dust controls and mitigation proposed, including the measures set out in Chapter 6 of the Environmental Statement (dated July 2018); c.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of a dust monitoring scheme to be implemented on site and along the length of the haul road, including regular monitoring and inspections (including along the boundaries with the closest sensitive receptors and adjoining primary school), details of the frequency of inspections (adjusted according to dust risk), provisions for targeted quantitative dust sampling surveys during dry whether conditions at sensitive locations (linked to the https://www.gov.uk/planning-inspectorate 52

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of a dust monitoring scheme to be implemented on site and along the length of the haul road, including regular monitoring and inspections (including along the boundaries with the closest sensitive receptors and adjoining primary school), details of the frequency of inspections (adjusted according to dust risk), provisions for targeted quantitative dust sampling surveys during dry whether conditions at sensitive locations (linked to the https://www.gov.uk/planning-inspectorate 52

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 phases of the development), details of additional safeguarding measures to be taken where a specific dust problem is identified; d. Additional safeguarding measures to be implemented during dry and/or windy weather conditions and/or where a specific dust problem is identified by the monitoring scheme; e. Details of a site complaints procedure, including arrangements to be put in place to record and address any dust complaints or other similar concerns raised by the local community, and details of proposed engagement with the local community (including the Westerham Town Council and Churchill Primary School) regarding the development and the measures to be put in place to safeguard local amenities; and f. A mechanism to review and update the management and monitoring plan. Thereafter, the Dust Management and Monitoring Plan shall be implemented as approved and the measures approved maintained for the life of the development. Landscaping and Planting 23) Prior to the commencement of the development hereby permitted a detailed landscaping and planting scheme shall be submitted for written approval to the County Planning Authority. The scheme shall include: a.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Final details of the proposed planting of native trees, woodland, hedgerows, shrubs, and seeding of wildflowers and grass; b. Details of the species mix, density, method of planting and protection measures; c. Detailed profiling of all ponds and flood retention areas, including aquatic and marginal wetland planting; d. Planting required by the Ecological Mitigation and Habitat Creation Plan; e. Reinstatement of any hedgerows removed shall be replaced with a like for like species planted in double staggered rows 500mm wide at 300mm spacings; f. Protection measure for existing woodland planting and trees through a tree constraints plan in accordance with BS5837 indicating any trees to be removed and those to be retained and including details of root protection areas, warning signage and fencing details. Within the fenced off protection areas the existing ground level shall neither be raised nor lowered, no material, temporary buildings, plant, machinery or surface soil shall be placed or stored and no herbicides shall be used; g. Details of measures to be taken to ensure that wide or tall loads, or plant with booms, jibs and counterweights can operate without coming into contact with any trees to be retained; h.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Phasing plan for delivery of the proposed planting; and i. Details of an interim maintenance plan for any early planting that takes place during the operational phase, with the long-term management and https://www.gov.uk/planning-inspectorate 53

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Phasing plan for delivery of the proposed planting; and i. Details of an interim maintenance plan for any early planting that takes place during the operational phase, with the long-term management and https://www.gov.uk/planning-inspectorate 53

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 maintenance to be addressed by the Landscape and Ecological Management Plan (LEMP) required by condition below. The landscaping and planting scheme shall be implemented in accordance with the approved specifications, with planting carried out according to the phasing plan. Ecology 24) No works shall commence until an Ecological Mitigation and Habitat Creation Plan (EMHCP), has been submitted to and approved in writing by the County Planning Authority addressing: a. Updated preliminary ecological appraisal and recommended species surveys; b. Mitigation for protected and notable species; c. Protection of retained habitats; d. Creation / enhancement of semi-natural habitats to buffer Westerham Woods SSSI, compensate for loss of habitats, provide receptor site habitat and enhance the site’s biodiversity; and e. Interim management of the habitats on the site (subject to submission of Landscape Ecological Management Plan (LEMP)). The EMHCP shall be informed as necessary by updated ecological surveys and shall include the following: i. Purpose and conservation objectives for the proposed works; ii. Review of site potential and constraints; iii.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Detailed design(s) and/or working method(s) to achieve objectives in part (i) above; iv. Extent and locations of proposed mitigation, management and habitat creation on appropriate scale maps and plans, including detailed designs for the receptor site / ecological area; v. Preparation of a work schedule for mitigation and details of timings, including a link to the phases of development; vi. Prescriptions for habitat establishment and initial management actions; vii. Persons responsible for implementing the works; The EMHCP shall be implemented as approved. 25) Prior to the commencement of the development hereby permitted details of the measures to protect Westerham Woods SSSI and Devil of Kent Wood (root protection zones, stand-offs, bunding and protective fencing) from indirect impacts arising from the proposal shall be submitted to the County Planning Authority for written approval and thereafter be implemented as approved. https://www.gov.uk/planning-inspectorate 54

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 Public Rights of Way 26) Prior to the commencement of the development hereby permitted, a Public Rights of Way Management Plan shall be submitted and approved in writing by the County Planning Authority. The Management Plan shall include: a. Measures to protect footpath SR338 and members of the public using the route from operations at the site; b. A plan including details of the temporary fence to be erected along the length of PROW SR338 where it crosses the site; c. Design details for fencing to be maintained in place for the duration of the development, no less than 1.5 metres in height and appropriate to segregate pedestrians using the route from the operational areas (the design of the fencing should take into account the sensitive nature of the surrounding landscape); d. Any necessary signage, associated infrastructure, surfacing and measures to protect users of the rights of way, particularly around the point the footpath crosses the proposed haul road; e. Details of the timing of implementation of the PROW Management Plan, including delivery of associated fencing, signage or other measures. f.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Arrangements for the removal of the fencing proposed along the route and reinstatement of the land in accordance with the landscape scheme required pursuant to this permission. The approved PROW Management Plan associated fencing, signage or other measures shall be implemented and installed on site prior to the importation of infill material or as otherwise agreed in the approved details and maintained for the life of the development, to be removed in accordance with the approved details as part of the final restoration of the quarry. Highway and transportation matters 27) No more than 200 two-way HGV movements (100 in / 100 out) associated with the development hereby permitted shall enter or leave the site in any one day Monday to Friday. No more than a maximum of 100 two-way HGV movements (50 in / 50 out) shall enter or leave the site on Saturdays between 0800 – 1300 hours. There shall be no HGV movements after 1300 hours on Saturday, or on Sundays or Bank / Public Holidays. 28) Prior to the commencement of the development hereby permitted, a detailed Traffic Management Plan shall be submitted and approved in writing by the County Planning Authority.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington The plan shall include the following requirements based on the overall number of HGV movements approved by condition 27 above: a. Details of a system to record the number of vehicles delivering infill material to the site each day, including a record of the type of vehicle and the date and time of each vehicle entering the site; https://www.gov.uk/planning-inspectorate 55

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington The plan shall include the following requirements based on the overall number of HGV movements approved by condition 27 above: a. Details of a system to record the number of vehicles delivering infill material to the site each day, including a record of the type of vehicle and the date and time of each vehicle entering the site; https://www.gov.uk/planning-inspectorate 55

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 b. Details of a routeing plan, including the distribution of the movements across the highway network [i.e., a maximum of 100 two-way HGV movements (50 inbound / 50 outbound) along the A25 (east), a maximum of 100 two-way HGV movements (50 inbound / 50 outbound) along the A233 (north), and a maximum of 10 two-way HGV movements (5 inbound / 5 outbound) along Croydon Road (north) each day]; c. All HGVs to be fitted with GPS trackers and the routeing data to be recorded and monitored and made available to the County Planning Authority in a useable electronic format upon request; d. A maximum of 9 two-way HGV movements per hour during peak hours and 12 two-way HGV movements per hour at other times during the working day along the A25 (east) and a maximum of 9 two-way HGV movements per hour during peak hours and 12 two-way HGV movements per hour at other times during the working day along the A233 (north) and a maximum of 5 two-way HGV movements per hour along Croydon Road (north). For the purposes of this clause peak hours are defined as 07:30 to 9:00 and 17:00 to 18:30 hours Monday to Friday; e.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of an internal system of management to actively monitor the routing of HGVs to ensure compliance with the relevant controls and mechanisms, including arrangements to suspend movements from a particular direction where the approved limit has been reached in anyone day; f. Measures to be taken to ensure that HGVs attending the site via Croydon Road only turn right into the site and left out of it, travelling to and from the north, and that no HGVs associated with the development travel through Westerham Town. g. Details of a scheme to secure a 10mph speed limit for all vehicles travelling along the haul road or on site, including details of signage to be erected and measures to ensure compliance with the speed limit. h. Measure to ensure all drivers and site personnel are aware of the above requirements and mechanisms to secure compliance if necessary. Thereafter, the Traffic Management Plan shall be implemented as approved and maintained for the life of the development.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 29) No vehicles importing infill material shall access the site other than via the access points to the temporary haul road proposed off Beggers Lane roundabout or off Croydon Road as shown on drawings 1325/AR/1 v.10 Illustrative Route of Internal Access Road (west) and 1325/AR/2 v.9 Illustrative Route of Internal Access Road (east). Hours of operation 30) No operations shall take place on the site except between 0700 – 1800 hours Mondays to Fridays and 0730 – 1300 hours on Saturdays. No operations shall take place on Sundays or Bank or Public Holidays. https://www.gov.uk/planning-inspectorate 56

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 29) No vehicles importing infill material shall access the site other than via the access points to the temporary haul road proposed off Beggers Lane roundabout or off Croydon Road as shown on drawings 1325/AR/1 v.10 Illustrative Route of Internal Access Road (west) and 1325/AR/2 v.9 Illustrative Route of Internal Access Road (east). Hours of operation 30) No operations shall take place on the site except between 0700 – 1800 hours Mondays to Fridays and 0730 – 1300 hours on Saturdays. No operations shall take place on Sundays or Bank or Public Holidays. https://www.gov.uk/planning-inspectorate 56

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 Lighting 31) No external lighting shall be installed on the site without the prior written approval of the County Planning Authority. Where external lighting is required within the site compound or elsewhere on site, the details submitted for approval shall include the height and location of all luminaires, the direction of lighting, luminosity, light spread, power source, and hours of proposed use. Unless otherwise approved within the above scheme, all external lighting shall be switched off outside of the approved operational hours. Thereafter, any external lighting installed on site shall be implemented in accordance with the approved details. Noise 32) Except for the temporary operations outlined in condition 32 below, noise levels arising from normal operations at the site, including the importation and deposit of inert materials, shall not exceed 55dB(A) LAeq 1 hour (free field) measured at any noise sensitive property, except for at Covers Farm and Bungalow where the limit shall not exceed 50dB(A) LAeq 1 hour (free field).

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington 33) During any temporary operations, such as construction and removal of the haul road, soil stripping and bund creation, noise levels shall not exceed 70dB(A) LAeq 1 hour (free field) measured at any noise sensitive property for more than 8 weeks per year. 34) Prior to commencement of the development hereby permitted a Noise Management and Monitoring Plan shall be submitted to and approved in writing by the County Planning Authority. The Plan shall include (amongst other matters): a. A plan detailing the 50 metre buffer zone between the normal site operations and boundaries with Covers Farm and Bungalow and Farley Mill and neighbouring properties; b. Measures to reduce the noise impact of the development (including that associated with the construction and removal of the haul road, plant and machinery operating on site and HGV movements along the haul road); c. No plant or machinery shall be operated on site unless fitted and operated with effective noise suppression equipment; d. No tonal reversing alarms shall be used by operational vehicles, plant and machinery based on site; e.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington A scheme of noise monitoring in accordance with the principles recommended in the Mitigation and Monitoring section of the update to the Noise And Vibration Chapter of the Environmental Statement (Ref: ES r1.4 260424) received 29 April 2024, including regular monitoring to enable the site operator to demonstrate compliance with the approved noise limits, including monitoring locations, monitoring protocols and submission of monitoring results; f. A scheme to record the date, time, and location of all work taking place within 50 metre buffer zone identified in (a) above to enable the site operator to demonstrate work has not taken place within the buffer zone for more than 8 weeks in a year; https://www.gov.uk/planning-inspectorate 57

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 g. Details of noise complaints procedure, including arrangements to record and address any complaints received; h. Measures to be implemented if the results indicate an exceedance of the noise limit attributable to site operations, including measures to be taken to reduce noise levels; and i. Provision for continual updates, including the identification of the timescale and frequency of such updates, until working and restoration are completed. Thereafter, the Noise Management and Monitoring Plan shall be implemented as approved and the measures approved maintained for the life of the development. Ecology 35) Any trees agreed with the County Planning Authority to be removed shall only be removed outside of the bird nesting season (1st March – 31st August). 36) A Landscape and Ecological Management Plan (LEMP) based on the Landscaping and Planting Scheme and Ecological Mitigation and Habitat Creation Plan required pursuant to conditions 23 and 24, shall be submitted to and approved in writing by the County Planning Authority within 2 years of the date of implementation of the planning permission hereby approved. The content of the LEMP shall include the following: a.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Description and evaluation of features to be managed; b. Ecological trends and constraints on site that might influence management; c. Aims and objectives of management (including habitat creation and enhancement, as well as landscape mitigation); d. Appropriate management proposals and options for achieving aims and objectives; e. Prescriptions for management actions, together with plan(s) of management areas; f. Preparation of a work schedule (including an annual work plan capable of being rolled forward for a period not less than five-years from completion of the restoration scheme); g. Details of the organisation(s) responsible for the implementation of the plan and how they will be funded; h. Ongoing species and habitat monitoring in relation to ecological mitigation and enhancements; and i. Timetable for management plan review informed by ongoing monitoring. The approved plan shall be implemented and maintained for the period agreed in accordance with the approved details, work schedules and timetables.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Landscape Planting 37) All planting and seeding detailed in the approved landscaping and planting plan shall be carried out in the first planting and seeding season (in accordance with https://www.gov.uk/planning-inspectorate 58

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Landscape Planting 37) All planting and seeding detailed in the approved landscaping and planting plan shall be carried out in the first planting and seeding season (in accordance with https://www.gov.uk/planning-inspectorate 58

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 approved phasing plan) and any trees or plants which within a period of five years from planting die, are removed or become seriously damaged or diseased shall be replaced in the next planting season with others of similar size and species. 38) No trees or shrubs, which are to be retained on the site, shall be damaged or uprooted, felled, topped, lopped or interfered with in any manner without the prior written approval of the County Planning Authority. Public Right of Way 39) No later than 12 months prior to the completion of the importation of materials or 5 years from the commencement of development, whichever is sooner, a scheme for the reinstatement of the public right of way SR338 shall be submitted to and approved in writing by the County Planning Authority. The scheme shall include: a. A plan showing the proposed alignment of the reinstated route, which shall follow the original legal line unless otherwise agreed. b. Confirmation of the width of the path to be reinstated, consistent with its recorded status and historic use. c. Details of the proposed surface materials, construction method, and drainage to ensure the path is suitable for its designated use (as a footpath).

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington d. Measures to ensure the surface is durable, safe, and accessible in all weather conditions. e. Provision of appropriate signage and waymarking to clearly identify the route for users. f. Measures to ensure the reinstated route is accessible to all users, including those with limited mobility, where appropriate. g. A timetable for the reinstatement of the route, to be completed no later than the timeframe allowed under condition 2 above. h. Provisions for the inspection and maintenance of the reinstated route for a period of 12 months post-completion to ensure it remains in a satisfactory condition. The approved scheme shall be implemented in full and the public right of way shall be made available for public use in accordance with the approved details and timetable. Site Management 40) The terms of this planning permission and any scheme or details, including variations approved pursuant thereto, shall be made known to any person(s) given responsibility for the management or control of operations. Access to all the aforementioned details must be maintained in the operator's site office at all times during the operational life of the site.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Storage 41) All oils, fuels, and chemicals shall be stored in accordance with the Control of Pollution (Oil Storage) (England) Regulations 2001. Storage containers shall be located on impervious bases and surrounded by bunds with a capacity of not less https://www.gov.uk/planning-inspectorate 59

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Storage 41) All oils, fuels, and chemicals shall be stored in accordance with the Control of Pollution (Oil Storage) (England) Regulations 2001. Storage containers shall be located on impervious bases and surrounded by bunds with a capacity of not less https://www.gov.uk/planning-inspectorate 59

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 than 110% of the largest container within the site compound shown on drawing 1325/CR/1 v5 – Croydon Road Crossing and Compound details. All valves and dispensing mechanisms shall be within the bunded area and locked when not in use. Spill kits shall be available at all storage locations and staff shall be trained in their use. Aftercare Scheme 42) No later than 12 months prior to the completion of the importation of materials or within 5 years of commencement of development, an Aftercare Scheme for the site shall be submitted to and approved in writing by the County Planning Authority. The scheme shall outline the steps to be taken to bring the land to the required standard for agricultural use and shall cover a period of not less than five years from the date of completion of restoration. The scheme should cover the aftercare requirements for both the quarry site and the restored haul road and shall link back to the approved Topsoil Production and Management Scheme. The Aftercare Scheme shall include: a. Land Management Objectives: A statement of the intended agricultural afteruse and the steps necessary to achieve this use; b.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Soil Management: Details of soil replacement, cultivation, drainage, irrigation, and soil conditioning measures, including: i. Soil handling methods and timing to avoid compaction and degradation; ii. Depths and types of soils to be replaced; c. Agricultural Operations: A schedule of operations including: i. Cultivation, reseeding, fertiliser application, weed control, and grazing or cutting regimes; d. Monitoring and Reporting: i. Annual aftercare meetings with the County Planning Authority to review progress and agree actions for the coming year; ii. Submission of annual progress report on an agreed date each year detailing works undertaken, the outcomes achieved and the actions for the coming year; e. Remedial Measures: Provisions for implementing additional measures if the land fails to meet the required agricultural standard. The approved Aftercare Scheme shall be implemented in full unless otherwise agreed in writing with the County Planning Authority. Verification of geotechnical considerations 43) Every 12 months from the date of commencement, an annual geotechnical progress report shall be submitted to the County Planning Authority. The report shall demonstrate: a.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of the work completed over the last year including details of volumes and type of infill material imported; https://www.gov.uk/planning-inspectorate 60

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Details of the work completed over the last year including details of volumes and type of infill material imported; https://www.gov.uk/planning-inspectorate 60

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 b. Observations taken on site, including photographic evidence of the work completed; c. A summary of the infill volumes, the locations, placement, levels and geographical limits; d. An updated topographic survey of the infill and restoration work; e. An assessment of compliance with design parameters and stability criteria; f. Provisions for implementing remedial works in the event that monitoring identifies instability, excessive settlement, or other geotechnical risks. g. Actions and recommendations for the coming 12 months; A final geotechnical verification report shall be submitted to the County Planning Authority within 1 month of completion of infilling of the development which shall include a confirmation of the work completed, including a final topographic survey for the site as restored, and an assessment of long-term slope stability. No part of the site shall be released from restoration obligations until the County Planning Authority has confirmed in writing that the geotechnical verification requirements have been satisfactorily met.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Verification of surface water drainage 44) At least 12 months prior to the anticipated completion of restoration of the site (or five years from the date of commencement of the development, whichever is the earlier, a Verification Report demonstrating the successful construction and completion of the approved surface water drainage system shall be submitted for the written approval of the County Planning Authority. The Report shall be carried out by a suitably qualified person and should include information and evidence (including photographs) demonstrating: a. The scheme delivered on site accords with the approved details and plans; b. The modelled operation of the drainage system, such that flood risk, is appropriately managed; c. Details of the earthworks; d. Details and locations of inlets, outlets, and control structures; e. Extent of planting; ecological features; f. Details of materials 61tilized in construction including subsoil, topsoil, aggregate and membrane liners; g. Full as built drawings; topographical survey of ‘as constructed’ features; and h. Details of an operation and maintenance manual for the drainage scheme as constructed.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Restoration of haul road 45) No later than 12 months prior to the completion of the importation of materials or year 5 of the importation, whichever is sooner, a detailed scheme for covering the https://www.gov.uk/planning-inspectorate 61

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Restoration of haul road 45) No later than 12 months prior to the completion of the importation of materials or year 5 of the importation, whichever is sooner, a detailed scheme for covering the https://www.gov.uk/planning-inspectorate 61

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Appeal Decision APP/W2275/W/25/3358947 removal and reinstatement of the haul road shall be submitted for the prior written approval of the County Planning Authority. The scheme shall include: a. Details of a scheme to remove and fully restore the haul road and surrounding land to its former condition (being agricultural land), including removal of any materials not required to restore the land, placement of soils; b. Details of a scheme to remove the Croydon Road crossing point, including the removal of associated infrastructure (including traffic lights, gates, hardstanding) and the reinstatement and any repairs necessary to the public highway (in accordance with the s278 agreement) and the reinstatement of the hedgerows and highway verges; and c. Details of a scheme to remove the access and crossing point onto the roundabout with A233 London Road/Beggers Lane, including the removal of associated infrastructure (including traffic lights, gates, hardstanding) and the reinstatement and any repairs necessary to the public highway (in accordance with the s278 agreement) and the reinstatement of the hedgerows and highway verges.

Covers Quarry, Westerham , Kent, TN16 2ER — Kent County Council — Stephen Normington Thereafter, the above restoration scheme shall be completed in full as approved before the cessation of the timescales set out in condition 2 above. END OF CONDITIONS https://www.gov.uk/planning-inspectorate 62