8 week date Application No. Date of meeting Report No.

----------- GR/2009/0286 06.10.10

The Former Northfleet Cement Works, The Shore, Northfleet, Kent Redevelopment of land at Northfleet Works for a bulk aggregates import terminal handling up to 3 Mt per annum and associated infrastructure including reinstated rail access. Lafarge Cement UK Recommendation: That the Kent County Council be advised that the Borough Council raise NO OBJECTION to the principle of a bulk aggregates import terminal but requests that in the event of Kent County Council resolving to grant planning permission planning conditions and other satisfactory safeguards are imposed to control the use and limit the impact of the development in relation to potential harm to local amenity and in terms of traffic generated by the development using local highways. In particular it requests that the planning conditions set out in the recommendation of this report are imposed. In addition it supports the concerns of Dartford Borough Council and Kent Highway Services in seeking to limit the amount of material transported by road including a limitation on the number of vehicle movements and to ensure that alternative means of transport by rail and river are available upon the operation of the BAIT. It also requests that the responses of the other various consultees and local residents are carefully considered and taken into account in determining the application. 1. Introduction

This application for a bulk aggregates import terminal (BAIT) on part of the former Northfleet Cement Works site was originally submitted to the Kent County Council in March 2009. The application is for determination by Kent County Council as Minerals Planning Authority and not by the Borough Council. This Council is however a consultee and has been invited to comment on the application.

It was initially reported to the Board at the meeting on 2 September 2009 as an interim report for information of the Board and not for decision at that stage.

The Board also received at that meeting a separate report on a sister application for mixed use development (MUD) on the larger part of the cement works site which will be for the Borough Council to determine.

The Board resolved to defer consideration of both applications for a site inspection to take place. The site inspection took place on 16 September 2009 at 5.30pm. A similar visit was arranged for County Members on 6 October 2009 at 2.00pm. The Board did not receive a subsequent report of the site inspection as the purpose of the visit was primarily to view the diverse and extensive areas of the site. It included a mini bus tour of the site. The areas visited included Robins Creek, the former Bevan’s works, Lawn Road, the Britannia War Memorial, The Shore, the existing cement Import Terminal, the kilns, the tunnels in the Lawn Road spine, Vineyard Pit, Church Path Pit and Grove Road. Some papers from the site visit are nevertheless appended to this report.

Subsequent to the site visit the applicants have been appraising the scheme and proposals in the light of officer, consultee, local resident and Board Member comments and concerns. As a result some amendments to the application have been made and additional information provided and references to the amendments are set out in this report. In particular a set of updates was submitted in July 2010. Further consultations have been undertaken by Kent County Council on the updated information. Similarly the mixed use application (20090238) has been re-appraised in the light of officer, consultee, local resident and Board Member comments and concerns and a number of changes to the scheme have been made. A set of updates for the mixed use application was also submitted to the Borough Council in July 2010. Further publicity and consultations have been undertaken by the Borough Council and that application will be reported to the Board in due course.

The application description of the mixed use application has been revised and is as follows:-

Outline application for a mixed development and comprising up to 532 Homes, related car parking and landscaping (C3); up to 46,000 sq m Employment Floorspace, related car parking, servicing and landscaping (B1/B2/B8);

Mixed Use Neighbour Centre comprising mix of: up to 850 sq m retail/cafe/takeaway floor space (A1/A2/A3/A5); residential uses (C3); community centre (D1); up to 1,000 sq m clinic/health centre (D1) and related car parking and landscaping;

Riverside Food and Drink Uses comprising up to 500 sq m of pub or food and drink uses (A3/A4);

Public Open Space including riverside promenade, public park with equipped play areas and playing field with shared public/school use and wildlife corridors;

Fastrack Link to provide a segregated link across the site along with Fastrack stops;

Street and Footpath Network to provide access to development and maintain and enhance existing public rights of way, including a bridge link between Hive Lane and Factory Road;

Access Improvement to Grove Road/The Creek and The Shore/Crete Hall Road and associated highway improvements;

Supporting Services and Infrastructure including new utilities, enhanced flood defences and providing for access to cliffs and tunnels;

Ground re-grading to create efficient development and open space platforms and to raise land to address flood risk; and

Other Minor Works and development ancillary to the main proposals including the principle of relocating the Scout Hut within the site and the retention of tunnels and facing walls adjacent to Lawn Road. An additional planning application has also been submitted (20100612) to the Borough Council for its determination being an application for Listed Building Consent for the demolition and relocation of the war memorial; creation of open space and landscape setting and ancillary works.

2. Site Description

The application site of the bulk aggregates import terminal (BAIT) covers an area of 10.02ha. The application site is located on land within the former Northfleet Cement Works in the west section of what is known as Northfleet Embankment. The site is bounded by the River Thames to the north, dissected by the B2175 Northfleet High Street and bordered by the North Kent Railway Line to the south. To the east lies Kimberly Clarke tissue paper mill and to the west are Robin’s Creek and existing industrial areas. The whole of the Cement Works site is around 42.2 ha in size including land in Vineyard Pit and Church Path Pit.

Northfleet is the home of Portland Cement and bulk powders have been manufactured, imported, exported and packaged at Northfleet Works site for the last 150 years. Over the years the extraction of chalk and the resultant level changes has created a fragmented landscape with varying levels.

The works site can be split into four distinct areas:

• Church Path Pit – a former quarry lying between the B2175 and the

North Kent Line accessed by tunnel from the main works site, the western branch of this quarry is known as St Botolph’s Pit;

• Northfleet Works – the current site of the newer cement works laid out

on a level quarry floor between the B2175 and 42 Wharf on the River Thames;

• The former Bevan’s Works Site – the area to the west of Lawn Road

including the main site access and land rising up from the river front towards the existing residential community of Northfleet; formerly the site of Bevan’s Cement Works; and

• Vineyard Pit – a small quarry on what is the main road access into the

works lying between the B2175 Northfleet High Street and the North Kent Railway Line.

Bevan’s works dates from 1926 with significant upgrades in 1958 but itself was a wholesale replacement of the Knight, Bevan and Sturge works originally dating from the 1850’s but reconfigured in 1905. Church Path Pit and Vineyard Pit are 19th Century chalk quarries. Vineyard Pit until 2008 contained 2 large fuel oil tanks and an associated pump house which have now been removed as part of the decommissioning works. There is an electricity distribution area to the east of Church Path Pit but this is not within the application site. The southernmost part of Church Path Pit contains railway infrastructure associated with the Ebbsfleet International and domestic railway stations which are situated further to the south. Church Path Pit used to contain part of the ‘merry go round’ rail system from the Cement Works to Northfleet Station and Northfleet sidings.

There are two wharfs to the river frontage of the cement works - Bevans Wharf, a wooden structure located within the river, which in more recent years has been used only for the occasional import and export of bulk powders; and 42 Wharf, a working wharf, so named because of its 42 feet depth, which has been used for the import and export of cement bulk powder/cement clinker and the import of fuel, and is one of the best deep water wharfs in the South East Region with the potential for reinstated rail links. The waterfront to the River Thames is formed of man-made flood protection walls. Between 42 Wharf and the Shore, at the east end of the site, there is a small inlet which forms a beach at low water. Currently public access to the riverside is restricted with some limited public access available at the Shore adjacent to the east entrance to the Cement Works. The Cement Works was characterised by industrial utilitarian buildings of varying scales and heights with conveyors and silos. They were mostly steel structures clad in mineral compound sheeting. Some areas are devoid of buildings such as south of Bevans works site where much of the land is derelict apart from the existence of the Bevans chimney which dates from 1958. There is an existing 8 storey office building on the site (34m tall) which is located next to The Shore and alongside 42 Wharf. It was built in the Brutalist architectural style. The office building is still in

use and occupied in connection with the demolition works. The office building also accommodates on its roof the Port of London Authority (PLA) radar equipment which is vital in helping to facilitate the safety of navigation on the tidal River Thames. (Note: A planning application has been made (20090385) by the PLA for a 49m high tower to provide replacement navigation equipment. This would be sited to the east of the current office building).

In April 2008 the cement kilns ceased to operate, since then there has been on-going grinding of clinker; the cement works ceased operations in December 2008 and, is in the process of demolition on a staged basis. The demolition works includes the removal of the industrial buildings, the office building, the chimneys and Bevans wharf. The wharf is to be demolished as it is according to the applicants reaching a point where significant repair and upgrading would be required. The 106.4m high (350 ft) Bevans chimney built in 1958 which sat about 15m above the level of the main cement works was demolished by controlled explosion in February 2010. The two 170m (550ft) high chimneys within the former modern works were also demolished on 28 March 2010. The office building will be demolished at a later date. An element of cement based activity is still continuing in the form of the import and distribution of bulk powders via 42 Wharf following a planning permission granted in 2005 (The Cement Import Terminal).

The wider Northfleet Embankment is traditionally an area of heavy industry and employment including manufacturing, a tissue paper mill, aggregates import, a builder’s yard and vacant plots. The settlement of Northfleet lies to the south of the site. Land use here is predominately residential, with some commercial use comprising shops and services at The Hive. Lawn Road School is located immediately to the south of the main cement works site.

The main road access into the Northfleet Cement Works is privately owned and runs from a roundabout junction on A2260 Thames Way (also known as STDR 4) underneath the North Kent Railway Line and through Vineyard Pit before entering the site via a tunnel under Northfleet High Street. Other road linkages exist from Grove Road to the west and The Shore/Crete Hall Road to the east. There are a number of public footpaths that are located within and adjoining the application site - NU42 runs from High Street Northfleet along the length of Lawn Road in a northerly direction and into the works site before turning eastwards along the Shore to Granby Road; NU3 that runs in a northerly direction from Hive Lane towards the old Bevans Works and NU6 that runs from the Bevans Works to join Grove Road. Public Footpaths NU7 and NU8 cross at a high level over Church Path Pit but are not within the works site and NU4 adjoins the eastern side of the Cement Works site along Granby Road. Footpath NU7a on the other hand does run alongside part of the road access from Thames Way into Vineyard Pit and across towards Blue Lake where it links with footpath NU14 as well as running north to High Street Northfleet.

The application site for the aggregates depot comprises the more eastern section of the Northfleet Cement Works site.

The application site for the mixed use development comprises the western section of the Northfleet Cement Works site. It includes Grove Road at the western end of the Cement Works. It excludes Robins Creek also at the western end of the Cement Works where the Ebbsfleet River enters the River Thames. The outlet at Robins Creek is controlled via a sluice and vegetation has colonised the area around the creek. Robins Creek is principally in the ownership of the Environment Agency. It performs a floodwater storage function for the Ebbsfleet River where tide lock prevents discharge to the River Thames and comprises some mud flats and pioneer vegetation.

3. Planning History

The Northfleet Cement Works including the application site has a long history of industrial use. Cement manufacturing on the site of the present day Northfleet Works began in the 1850s with the construction of Bevans Works. This was reconstructed twice before elements of it were incorporated within the new Northfleet Works, constructed between 1969 and1970.

Served by road, rail and water, Northfleet Works on its opening was the largest cement works of its kind in the world. As built, rail traffic was intended to be 21 coal trains per week, bringing in 1 Mt/a of coal and 9 trains of gypsum inwards per week (250,000 t/a required). Cement production totalled 3.8 Mt/a of which 1.3 Mt/a cement was despatched by rail (about 18 trains per week) and the remainder by water for export and by road for UK consumption. The works had originally six rotary kilns but in the early 1980’s two of the kilns were removed to make way for a press plant.

Chalk to manufacture cement was quarried from Eastern Quarry and clay slurry was pumped under the River Thames from Ockendon Essex. In 2001 Blue Circle was taken over by Lafarge Cement.

The closure of Northfleet Cement Works, due to the exhaustion of its main raw material (chalk from Eastern Quarry) has been in the public domain for many years prior to occurring in April 2008. Planning policy dating back to 1994 has identified opportunities for elements of the Northfleet Works site to be redeveloped for other uses. Planning applications for Medway cement works at Holborough, as a replacement for Northfleet, were approved in 2001 following two public inquiries.

A Section 106 agreement required Lafarge, amongst other things, to cease activities at Northfleet and to work with the County and Borough Councils to formulate proposals for the redevelopment and use of the site by participating in Local Plan reviews and, specifically, by preparing Master Plans for the redevelopment of Northfleet Works.

The principle of closing and redeveloping Northfleet Cement Works has, therefore, been a fundamental plank in local and strategic land use planning for a decade and was specifically endorsed by the Government by allowing development of Green Belt land for Medway Cement Works in order, in part,

to release Northfleet Works for redevelopment as soon as possible, and by planning for that redevelopment through a legal obligation upon Lafarge.

The first element of this redevelopment was permitted in 2005 (GR/2005/0561) when planning permission was granted by the Borough Council for the construction of a Bulk Powders Import Terminal handling up to 1 million tonnes of bulk powders per annum with material imported across 42 Wharf. The Bulk Powder Import Terminal has been completed and is now operational. It lies at the east end of the works site adjacent to the application site.

In terms of specific historic features, within the site adjacent to the main office building on the waterfront is the Bevans war memorial. This commemorates those killed in World War I. The memorial is a Grade II listed building and is an important historic feature which is proposed to be relocated as part of the redevelopment to a more sensitive and appropriate setting. Detailed proposals for the relocation of the war memorial have been made as part of a separate listed building consent application to the Borough Council. The other Grade II listed building within the wider Northfleet Works site is the Port of London Authority owned Northfleet Lower Lighthouse located at the eastern end of 42 Wharf. This will remain in its present position and will retain its industrial setting.

Outside of the application site, but forming part of the overall context, lies a Conservation Area at The Hill, forming the historic core of Northfleet. Six listed buildings are located within the Conservation Area. These include the Grade I listed Parish Church of St Botolph, which is just to the east of Church Path Pit. The church dates from the 14th century and forms a focal point for a triangular open space at the historic core of the village which lies in an elevated position above the site. A further prominent listed building and local landmark is Sir Giles Gilbert Scott’s Roman Catholic Church of Our Lady of the Assumption.

Aspdin’s Kiln, to the south of Robin’s Creek, is a Scheduled Ancient Monument and the oldest surviving cement kiln in the world. The kiln is currently surrounded by employment development and is not visible from public vantage points. It is also not within the application site but is on land leased by Lafarge.

A full description of the historic context of the site is set out in the Cultural Heritage chapter of the Environmental Statement and in the subsequent supplementary report, Summary of Built Heritage Assessment.

4. Proposal

This application is for full planning permission for a Bulk Aggregates Import Terminal (BAIT).

The application is submitted to the Borough Council for consultation purposes and for comment only, as the determining authority is Kent County Council as the Minerals Planning Authority.

It has been submitted in parallel with (although separate to) a sister outline application for a mixed use development on another part of the cement works site which will be for the Borough Council to determine. The formal description of development is for redevelopment of land at Northfleet Works for a Bulk Aggregates Import Terminal handling up to 3 million tonnes per annum and associated infrastructure including: • Ship (bulk carriers and sand and gravel dredgers) and Barge

loading and unloading equipment including conveyor links across the Fastrack reservation;

• enclosed aggregate storage building and ancillary open storage;

• lorry loading;

• reinstated rail access and rail loading (including rail loading for

bulk powders);

• weighbridge and associated wheel wash and sheeting/un-sheeting areas;

• aggregates screening, crushing and washing plant;

• marine dredged sand and gravel processing plant;

• ancillary Ready Mixed Concrete plant;

• related lorry and car parking and landscaping;

• reservation of land for Fastrack link to provide a segregated link

across the site and associated landscaping;

• ground re-grading to provide an efficient development parcel;

• road access to provide continuity of access across the redevelopment of the Northfleet Works site;

• supporting services and infrastructure including new utilities,

enhanced flood defences, security fencing and providing for works to cliffs and tunnels; and

• other minor works and development ancillary to the main

proposals.

The application is accompanied by the following documentation:

Application Drawings Minerals Planning Statement Design and Access Statement

Environmental Statement covering the following topics:

• Transportation and Access • Air Quality • Noise and Vibration • Hydrology and Flood Risk including Flood Risk Assessment and • Drainage Strategy • Socio- Economic and Community • Landscape and Visual Impact • Geotechnics and Soil Contamination • Waste • Cultural Heritage • Ecology and Nature Conservation • Sustainability

Environmental Statement Non-Technical Summary Transport Assessment

Phasing and Implementation Strategy Land Stability Statement

Extent of the Site

The application site covers an area of 10.02ha. Explanation of the Proposals (as set out in original submission)

The proposals promote the use of 42 Wharf for the import of crushed rock and marine dredged sand and gravel for distribution onwards by road, rail and river for up to 3m tonnes per annum. 42 Wharf will also continue to be used for the import of bulk powders into the existing Bulk Powders Import Terminal which is now operational. It is anticipated that the majority will be crushed rock and the minority will be marine dredged aggregate in the proportions of around two to one. Of that 3m tonnes it is estimated that around 100,000 tonnes a year may be sold on as ready mixed concrete.

Crushed rock is unloaded from ships and transferred over the Fastrack link and reinstated rail link by conveyor. Enclosed storage will be provided for crushed rock within a ‘toast rack’ building with a capacity of around 300,000 tonnes. The toast rack structure will be constructed from pre-cast concrete sections. The ventilation of the cells will be carried out internally, to contain noise and dust. The storage building (and all ancillary buildings) will be clad with profiled metal. The final colour would be the subject of a planning condition but it is envisaged to be a neutral grey colour.

An enclosed screening plant to size aggregates is to be provided adjacent to the storage building connected by conveyors, along with an aggregate washing facility. Crushed rock is distributed from lorry loading points, a rail loading point or barge loading point on 42 Wharf each fed by conveyors.

There may some infrequent external storage and handling of crushed rock where required for operational reasons, for example if a ship needs to be unloaded if the internal storage is at capacity or if there are faults with the internal conveyor systems.

Sea dredged aggregates would also be unloaded from ships and transferred over the Fastrack link and reinstated rail link by conveyor. Sea dredged aggregates are to be stored externally. Stockpiles will contain up to around 9 tonnes of material and will be up to 16m in height. A screening plant is also provided. Sea dredged aggregates are to be distributed from lorry loading points fed by conveyors and can also be fed into the conveyor system feeding the rail and barge loading points.

A number of ancillary activities are also required at the terminal entrance including a weighbridge, gatehouse, wheel washing facilities and sheeting and un-sheeting areas. Within the site a one way road network is promoted, along with required lorry and visitor parking.

Connections to 42 Wharf are via conveyors over the Fastrack reservation and reinstated rail link. The conveyors will provide for ship unloading of crushed rock, and barge unloading of sand and gravel. Also a barge loading point is provided where exports from the terminal are to be sent up river to terminals with a lower draught. Conveyors feeding the Bulk Aggregates Import Terminal will be enclosed. New infrastructure on 42 Wharf will also take account of bulk powder unloading and loading machinery associated with the Bulk Powder Import Terminal.

Bulk out loading of aggregates to lorry and rail will take place via conveyor sand hoppers.

An ancillary ready mixed concrete plant is also proposed to the west of the storage building. This will have a degree of external storage of material associated with it and front end loaders will be used to sort and move aggregates to feed the ready mixed concrete plant. It is proposed that details of the ready mixed concrete plant and other ancillary buildings and infrastructure be provided as details pursuant to planning conditions. In order to mitigate any adverse impacts from the external storage of materials proposals include the use of discharge conveyors with telescopic chutes to minimise the open dropping of material, the use of fixed water sprays and a high standard of housekeeping on the site with the sweeping and watering of roads and the use of wheel washes for all vehicles.

Scale and Landscaping All buildings and associated conveyors and ancillary facilities are below 30m in height. The main storage building is 224m in length and 52m in width. The scale, height and appearance of the proposed Bulk Aggregates Import Terminal with its distinctive ‘cat slide’ sloped roofs is very similar in form and appearance to the existing Bulk Powder Import Terminal immediately to the east.

Landscaping proposals will be focussed upon the proposed Fastrack link being brought forward via the parallel mixed use planning application under

consideration by the Borough Council. Elsewhere within the site some elements of planting will be provided along with measures to enhance the ecological interest of the site such as exploiting the habitat potential of the reinstated rail sidings. This will be subject to further detailed design work and the applicants suggest that this could be the subject of a planning condition attached to any planning permission.

Access and Rail Connections

Access to the Bulk Aggregate Import Terminal is from the north west corner of the site, linking onto the proposed HGV access and ultimately to Vineyard Pit and Thames Way via the main works access. An alternative internal access route for Lafarge is proposed around the north side of the rail sidings to allow HGV access for Lafarge Cement UK to the Bulk Powder Import Terminal from the main works access. This private access route will also allow alternative HGV access from the Bulk Aggregates Import Terminal to the Shore/Crete Hall Road works access. This approach retains the integrity of the segregated Fastrack link across the site. Within the site a one way road network is proposed.

The reinstatement of the rail link to the works site via Northfleet sidings, Church Path Pit and the eastern tunnel under Northfleet forms part of proposals. The applicants advise that the reinstatement of much of this rail link is already permitted. Union Rail in the construction of the Channel Tunnel Rail Link removed much of the existing track serving the former merry go round rail system and has an obligation under the Channel Tunnel Rail Link Act to reinstate significant elements of the trackwork. These works do not require formal planning permission under the Town and Country Planning Act, and are likely to be undertaken in advance of the commencement of Channel Tunnel domestic services in December 2009.

Planning permission is therefore sought under this application only for those elements of rail that are not subject to reinstatement under the Channel Tunnel Rail Act. This includes the sidings within the main application site and the track within Church Path Pit in so far as it diverges from the previous alignment of the merry go round rail system. Lafarge Cement UK has all the required rights to use land at Northfleet Sidings for the reinstatement of the rail link.

The proposals reserve land for the Shore Fastrack link across 42 Wharf that forms part of the outline planning application for Mixed Use Development under consideration by this Council. The application boundaries also include land required for maintaining access to the main works access via Vineyard Pit and to access the Shore and Crete Hall Road. This is to maintain the road access via these links and to safeguard access throughout the redevelopment of the works site. No detailed drawings are provided for the access to Vineyard Pit and the precise route may vary within Lafarge’s landholding as redevelopment of the wider works progresses. The Transport Assessment includes indicative proposals for the improvement of access to the Shore/Crete Hall Road. Detailed proposals for site access will be approved as part of the sister outline application for Mixed Use Development and pursuant to planning conditions if permission is granted.

The application is supported by a full Transport Assessment that assesses scenarios for the split of traffic movements from the Bulk Aggregates Import Terminal between road, rail and river. Although a modal split of traffic of 40 per cent Road 40 per cent Rail and 20 per cent Barge has been tested; other splits of up to 100 per cent road are possible.

There is a need for the removal of the southern most part of the Lawn Road spine in order to accommodate the sidings on the site and the road access and this forms part of this planning application. The mixed use application proposes removing further elements of this chalk spine in conjunction with creating a proposed playing field. Other elements of groundworks will also be required in the south part of the site also.

The Bulk Aggregates Import Terminal will be securely fenced with 1.8m palisade fencing to provide security, and appropriate gates will be provided at the entrance. 2.4m high fencing will be provided to 42 Wharf to meet the port security requirements of the PLA, Customs, and police and immigration services. The design of fencing where it fronts the Shore Fastrack link will pay particular attention to promoting the environmental quality of this link and thus its attractiveness to pedestrian users.

Operational Aspects The proposed throughput of the Bulk Aggregates Import Terminal is up to 3mT per annum. This figure includes crushed rock, sand and gravel and ready mixed concrete.

A variety of sizes of ship will service 42 Wharf. 42 Wharf is 298m in length with a minimum water depth of 13m (42ft) at chart datum. Typically the size of ships within the range of between 6,000 and 40,000 deadweight tonnage (DWT) is anticipated but vessels up to 80,000 DWT could be accommodated. On average about one crushed rock boat per week and two to three dredgers are anticipated per week.

42 Wharf will be operational throughout the day and night, seven days a week due to the need to take account of the influence of tide times, weather and the need for quick turnaround.

Likewise, use of the reinstated rail link is required to be similarly unconstrained to take account of potential constraints in terms of the availability of train paths from Network Rail. Currently Northfleet Works receives and despatches road traffic at any time. The same arrangement is proposed to continue to apply to the operation of the proposed new Bulk Aggregates Import Terminal, although in reality relatively little night-time traffic is envisaged to be generated.

The applicants indicate that it is important to them that no time constraints are placed on the operation of the Bulk Aggregates Import Terminal given the need to receive imports at all times of the day and night throughout the year.

The number of permanent full time equivalent jobs associated with the development is for seven office workers, seven wharf workers and 67 lorry

drivers. There will be 18 other workers which include maintenance staff, barge staff and railway personnel. A full assessment of socio-economic impacts including employment during the construction phase are set out within the Environmental Statement. Conditions The applicants planning statement suggests a number of draft planning conditions that they indicate could be included in a planning permission. These are as follows:

1. Level of Development • The site and building hereby permitted shall be used as an import

terminal for the loading/unloading, storage and processing of aggregates, sands and gravels in accordance with the approved plans, and for no other purposes including any other purpose within classes B2 and B8 of the Town and Country Planning (Use Classes Order) 1987.

• Notwithstanding the provisions of Article 3 and Part 8 of the Town and

Country Planning (General Permitted Development) order 1995, as amended, no enlargement or alteration of the buildings, or additional plant and machinery beyond what is shown on the approved drawings shall be carried out without the prior written permission of the Minerals Planning Authority having been obtained.

• The terminal shall import not more than 3 million tonnes of aggregate,

sand and gravel per annum across 42 Wharf.

2. Environmental Matters

• A noise report showing that the rating level of the noise emitted from the development (other than noise from the exit or entry of road vehicles), shall be submitted for approval to the Minerals Planning Authority. The noise levels shall be determined at the points nearest to adjacent existing and proposed residential premises. The development shall not be occupied until approval of this report has been given by the Minerals Planning Authority.

• The commencement of the development shall not take place until a

satisfactory Code of Construction Practice is provided by the applicant and submitted for approval to the Minerals Planning Authority. This shall include but not be limited to:

• Hours of working limit including delivery times.

• Detailing best practical means for quiet working methods and

dust control.

• Providing a programme for the monitoring of noise and vibration during the construction of the development and a method for ensuring this information is made available to officers from the

Council. No building works shall commence until approval of this report has been given by the Minerals Planning Authority

• The development shall not commence until details of the lighting of the

site and buildings has been submitted to and approved by the Minerals Planning Authority; the development shall be carried out in accordance with the approved details.

• This development shall not come into operation until a satisfactory

dust management plan connected with the operation of the facility is provided by the applicant and submitted for approval to the Minerals Planning Authority. No operations shall commence on site until approval of this document has been given by the Minerals Planning Authority. This document shall include but not be limited to dust control measures covering:

• Internal roads

• Transfer to bulk storage

• Bulk storage and management of storage buildings

• Loading

• Monitoring

• No development approved by this permission shall be commenced

until a scheme for the disposal of foul and surface waters has been approved by and implemented to the reasonable satisfaction of the Minerals Planning Authority. The approved scheme shall be implemented prior to occupation.

• No sewerage or trade effluent (including vehicle wash or vehicle

steam cleaning effluent) shall be discharged to any surface water drainage system without appropriate treatment.

3. Design and Layout Matters • Prior to commencement of development details of the means of

enclosure of conveyors shall be submitted to and approved by the Minerals Planning Authority.

• Prior to commencement of development details of lorry and car

parking shall be submitted to and approved by the Minerals Planning Authority. Areas proposed for parking and turning shall be used for such purposes at all times when the premises are in use as a Bulk Aggregates Import Terminal.

• No part of the development hereby permitted shall obstruct or

interfere with the reserved Fastrack corridor running through the site. • A landscaping scheme shall be submitted to and be approved by or

on behalf of the Minerals Planning Authority before any works are commenced and such scheme shall be implemented to the

satisfaction of the Minerals Planning Authority. Such a scheme will include details of its consistency with the landscape scheme for the adjoining Mixed Use Development and Bulk Powders Import Terminal.

• External materials shall be submitted to and approved by the Minerals

Planning Authority. • Prior to the commencement of the development details of the means

of enclosure to the Bulk Aggregate Import Terminal and 42 Wharf shall be submitted to and approved by the Minerals Planning Authority.

• Prior to the commencement of the development details of the

gatehouse/security lodge shall be submitted to and approved by the Minerals Planning Authority.

5. Application Updates Application Updates August 2009

A number of supplementary plans and information was submitted by the applicants to the Kent County Council in August 2009 and this additional information was forwarded to the Borough Council in mid September 2009 following the initial report to the Regulatory Board on 2 September 2009. This included, • A plan showing the relationship between groundworks in Vineyard

Pit and the North Kent Railway Line (in response to Network Rail’s consultation response).

• Information on rail connection feasibility.

• An update to the Transport Assessment to address concerns

raised by the Highways Agency, Kent Highways and Dartford Borough Council (including air quality issues).

• An update to the noise assessment.

• A Winter Bird Survey, to be read alongside the ecology and nature

conservation assessment of the Environment Statement.

• Information on proposed conveyors, similar aggregate unloading activities elsewhere, parking and office arrangements and sources and markets for crushed rock, sea-dredged aggregate and ready mix concrete.

• Responses of the applicants to the issues raised by consultees and

others to the original details; and

• Clarification on the planning status of the rail link and sidings.

Copies of the correspondence that accompanied the updates are appended to this report (Appendix 4). Application Updates July 2010 A number of updated plans and documents were more recently submitted to the Kent County Council in July 2010 as further supplements to the original documents. The only specific plan amendment to the BAIT proposal in the July 2010 updates is a minor amendment in the alignment of the proposed Fastrack link across 42 Wharf in order to avoid a water sump that exists on the site.

This amendment along with the design of the open space related to the proposed relocated War Memorial (which is the subject of a new and separate planning application to this Council) has required a minor amendment to the red line boundary of the sister Mixed Use Development application. However no updates are required to the red line boundary of the BAIT application.

The updates on the Mixed Use Development application include,

• the introduction of a potential health centre use within the

neighbourhood centre • the design of the Fastrack link where over the long term it is

unclear at present whether a fully segregated link will be required across the width of the entire site; and

• the retention and refurbishment of the majority of tunnels and

facing walls along the Lawn Road spine to create a heritage asset that reflects the cultural interest of the site and the cement industry.

As a result of these changes the quantum of residential development proposed on the mixed use development has accordingly increased from up to 510 residential units to up to 532 residential units The application updates in connection with the BAIT include, • Updated Application Drawings • A Planning Statement update

• A Design and Access Statement update

• A Phasing and Implementation Strategy Update

• An Environmental Statement (EIA) update

• A Transport Statement update.

Phasing Updates In respect of the timing and phasing of the development the applicants advise as follows: The mixed use application has been revisited to provide for a more consistent phasing of residential development commencing in 2012. This brings some land between College Road and Hive Lane forward for residential development in Phase II (2012-2014) as shown on updated plans and Phasing and Implementation Strategy. More fundamental shifts in phasing have occurred with respect to the Bulk Aggregates Import Terminal. The proposed Bulk Aggregates Import Terminal is intended as a long term development. At the submission of the planning application it was assumed that the Bulk Aggregates Import Terminal would be open and fully operational from 2012 (i.e. an annual throughput of 3 million tonnes of aggregates) to represent a ‘worst case’ scenario in assessments. There are a number of reasons why this is no longer a realistic assumption. A key reason is the economic recession – Lafarge expect the economic slow down to last throughout 2010 and beyond. Lafarge now predict a much slower build up in terms of the throughput of aggregates at the terminal during the early years. It is anticipated that the Bulk Aggregates Import Terminal could now open in 2015 rather than 2011. Overall – there is some uncertainty as to how the terminal will develop given the current economic position. Lafarge has now confirmed that the most likely phasing of development in terms of throughput of aggregates would be as follows: • Short Term – 0 to 7 years (2015 – 2022) – Throughput of up to 0.5

million tonnes per annum (mtpa) of predominantly sand and gravel with some ready mixed concrete.

• Medium term – 7 to 17 years (2022 – 2032) – Throughput of up to

1.25 mtpa of sand and gravel, crushed rock and ready mixed concrete; and

• Long Term – 17 to 27 years (2032+) – Throughput of up to 3.0

mtpa of all materials.

The reinstatement of the rail link was scheduled for 2013 in the original submission of the applications. Network Rail and Lafarge are working to a target for installation of the new physical connection by September/October 2011 with subsequent signalling commissioning during Q1 of 2012. However, this is only a target date and the provision of the rail link should not be a precondition of any planning permission for this development. Should there be a need for a condition to control the number of lorry trips to and from the terminal this should be based on limiting lorry trips in line with the numbers tested in the assessment that accompanies this application rather than requiring the provision or operation of the rail link by a certain date. An update to the Phasing and Implementation Strategy is provided to outline the updates to the timescales. As with the original submission, all

timescales are indicative and may be the subject to amendment in the light of the economic recession and other circumstances including: • The influence of the economy and speed of economic recovery; • The speed of regeneration in North West Kent generally; and

• The rate of development at Ebbsfleet Valley and Eastern Quarry.

The update to the Environmental Statement reviews the implications of the revised phasing on the development and concludes that there is no material change in the impacts identified.

Transport Updates In respect of updates concerning transport proposals the applicants advise as follows: Development proposals have not changed with regard to transport proposals. Supplementary information is provided in response to the revised phasing and in response to comments made by Kent Highway Services and the Highways Agency including information on the main access tunnels to the site. This material is not repeated within this statement. The additional material does not materially alter the proposals. In undertaking a stage one safety audit of the main access tunnel under Northfleet High Street (TU23) the possibility of single way shuttle working with a pedestrian footway through the main access tunnel is investigated. This application envisages that this tunnel will be retained for two-way vehicular traffic only. However, Lafarge Cement UK is happy that the detailed design and use of this tunnel remain open for further consideration by the relevant authorities. It is likely that this matter will be resolved at the reserved matters stage. Other Additional Information In response to a number of matters raised by Kent County Council as Minerals Planning Authority the applicants have provided the following additional information: External Storage of Crushed Rock The application proposed the open storage of sand and gravel. Open storage of crushed rock will only take place on an occasional basis for operational reasons, for example, following clearances of blockages or following the failure of equipment. LCUK is happy for this to be controlled by condition if required. In terms of the scenario presented of discharging an entire load of crushed rock to external storage, it is considered that this could not occur as insufficient space would be available.

Cladding of Buildings All elements of the toast rack store, screening and storage and washing plant are to be clad fully enclosed. Crushing The crushing plant is at the north end of the storage building. Crushing is included within the description of development and the manner in which material is fed is shown on the submitted process plan. Proximity of external storage to other development This matter has been fully assessed in the Environmental Assessment and is not seen as creating any adverse impacts. There are other examples where such storage exists in a similar proximity to non minerals development which do not create significant problems. Water from the Washing Plan and Fines/Silts A silt tank will be provided within the terminal area at ground level. It is proposed that this be fixed pursuant to a planning condition. Once sediment has settled water is reused in the washing process and some silts from marine dredged aggregates may be suitable for resale. Unexploded Ordnance In common with other plants a written incident plan will be adopted setting out the actions to be taken in the event of unexploded ordnance being brought ashore. This typically involves the stopping of all plant, evacuation of the site, calling in of the police force and then relevant measures to make any ordnance safe. This may involve the attendance of army specialists. Proposals for Other Terminals There are no proposals to close other terminals as a result of the current proposals. The terminal will in building up throughput over time respond to the anticipated reduction in contribution to mineral supplies from land won sources and the associated need for more terminal capacity. Means of Implementation As set out with regard to phasing it is anticipated that the sand and gravel activity will be the first elements of the scheme to be implemented. The implementation of the development will be in line with s56(1) of the Planning Act 19990 (as amended). In this context the implementation of the rail sidings on the main works site which form part of the application might well provide for a practical implementation of a permission. Potential for landscaping within the Terminal Area As set out in the original submission it is proposed that landscaping details for the Bulk Aggregates and adjacent Bulk Powders Import Terminal are

provided pursuant to condition. The additional plans submitted demonstrate the approach towards the Fastrack link across 42 Wharf. Impact of Conveyors on PLA Mast On the basis that the current radar on Blue Circle House has happily operated within proximity to conveyors associated with the cement works and given the Port of London Authority’s full knowledge of the proposed terminals, it is assumed that the proposed minerals conveyors will not have any adverse impacts on the operation of the Port of London Authority radar. Access to 42 Wharf Access across the fastrack link to 42 Wharf is shown on the submitted drawing. The Fastrack link will be delivered via the sister Mixed Use Development application. Employee Numbers Further to the discrepancy in the original submission I can confirm that the Bulk Aggregates Import Terminal will provide the following permanent full time equivalent jobs:

- Lorry Drivers – 67 in total with up to 40 based on the sites; - Office Workers – 7 - Other Staff – 25 (wharf workers, maintenance staff, railway

personnel).

Environmental Statement Update The EIA has been reviewed particularly in view of the revised development phasing, but also in respect of transportation and access, air quality, noise and vibration, hydrology and flood risk, Socio-economic and community, landscape and visual, geotechnics and soil contamination; waste, cultural heritage, ecology and nature conservation, cumulative effects and sustainability, in other words all of the topics that formed the scope of the original EIA. The EIA update concludes that there is no identified change to the potential residual effects as described in the 2009 EIA and that in general terms potential effects will occur at a later date spread over a longer period thereby giving rise to a lower peak and therefore a number of topics this is likely to be beneficial and may have an ameliorating effect.

6. Development Plan

The Development Plan comprises:-

• The Gravesham Local Plan First Review (1994) • Saved Policies of the Local Plan First Review (1994)

There are a number of other un-adopted planning documents (e.g. The Gravesham Local Plan Second Review) which are of some relevance and are a material consideration, together with national planning advice and guidance (PPG’s/PPS’s) and the emerging policies in the Local Development Framework. On 6 July 2010 the Secretary of State announced the revocation of Regional Strategies with immediate effect. As a result the South East Plan and the policies therein are no longer a material consideration. However when this planning application was originally submitted in March 2009 it should be noted that the South East Plan was part of the adopted development plan. It should also be noted that the Kent and Medway Structure Plan which was approved on 6 July 2006 and was part of the adopted development plan at the time of the submission of the original application ceased to have effect as a development plan on 6 July 2009.

Local Planning Guidance

Gravesham Local Plan First Review (1994)

The Gravesham Local Plan First Review was adopted in November 1994. The Gravesham Local Plan still remains as the adopted local planning document and the written statement and proposals map will continue to have effect as the development plan pending the preparation of the Local Development Framework (LDF). A substantial number of policies of the Gravesham Local Plan First Review have been saved by a Direction dated 25 September 2007 of the Secretary of State under paragraph 1 (3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004.

In the Gravesham Local Plan First Review Proposals Map the area of the Northfleet Cement Works on the east side of the site including all the land within the application for the bulk aggregates import terminal is shown as an existing industrial area (policy E1) and also subject to Channel Tunnel Safeguarding under policy T14. Policy E1 is a saved policy.

Policy E1 is as follows:- Policy E1: Existing Industrial Areas

In the existing industrial areas shown on the Proposals Map, the Borough Council will give priority to the need for employment. In these areas, proposals which will generate additional employment of all types, whether industrial or not, will normally be permitted except where such proposals would be in conflict with Policy S1. All proposals will be expected to take into account the requirements relating to design, environmental protection and parking set out elsewhere in this Written Statement.

Part of the mixed application site, mainly the site of the old Bevans cement works, is also shown as being within an existing industrial area and subject to policy E1.

The western area of the mixed use site is shown as being subject to Area Policy AP13. This states:- Policy AP13: Grove Road and College Road

In the area shown on the Proposals Map, the Borough Council will not oppose in principle partial redevelopment for a commercial or mixed development, provided this is consistent with the amenity of adjacent residential properties and results in a substantial improvement in the environment of the area. The Borough Council will seek the preparation of a planning brief.

The area immediately north of The Hive between College Road and Hive Lane is shown as being subject to policies PLT1 and M1, being a site for additional open space and for restoration of derelict land. These policies are as follows:-

Proposal PLT1: Additional Open Space including Public Open Space and/or Playing Fields The following additional areas of land are identified on the Proposals Map for open space purposes, including public open space and/or playing fields:- (i) Land north of Thames Way, Northfleet 9.2 ha (ii) South of Riverview Park 0.5 ha (iii) Third Avenue, Northfleet (part)* min. 0.4 ha (iv) College Road, Northfleet 1.9 ha (v) Waterton Avenue, Gravesend 1.3 ha (vi) Wombwell Hall (Phase 1), Northfleet* 0.4 ha (vii) Campbell Road Chalk Pit, Gravesend 1.48 ha (viii) Dover Road Pit, Northfleet (after restoration) 0.78 ha (ix) Bat and Ball Ground, Trafalgar Road, Gravesend 2.4 ha (x) Ordnance Road, Gravesend 0.76 ha and as part of the development of major sites at:- (xi) West of Wrotham Road, Gravesend* 9.2 ha (xii) North East Gravesend*

Undetermined

Policy M1: Restoration of Derelict Land

In seeking derelict land grants, the Borough Council will concentrate its efforts (where necessary in conjunction with other agencies or private developers) on schemes which will reclaim and bring into use sites within the Borough, particularly where this would increase employment and on schemes which would result in significant environmental improvements. In considering proposals the Borough Council will have regard to the protection of the wildlife value of derelict sites.

The following sites, as indicated on the Proposals Map, are considered to be the priorities for concerted action to create employment or recreational facilities, using derelict land grants as necessary:-

(i) Land at College Road, Northfleet (ii) Land at Grove Road, Northfleet (iii) Thames and Medway Canal (See Proposal PLT3) (iv) The former Gravesend West Railway Line (See Proposal

PLT2) (v) Pit south of Dover Road, Northfleet (vi) Campbell Road Pit, Northfleet

The following policy in the Local Plan First Review is relevant to the consideration of the aggregates application. Policy R1: Commercial River Frontage Policy

In the commercial riverside, as shown on the Proposals Map, the Borough Council will have a preference for development adjacent to the river which requires a riverside location and makes use of the river as a means of transport. Any new buildings will need to be set back sufficiently from the water's edge, to enable access to be achieved to the river for wharfage purposes. Where appropriate and consistent with safety, a public riverside walkway or riverside access will be expected.

Other general policies relevant to the development are: Policy TC1: Design of New Developments Policy TC10: Landscaping Policy T1: Impact of Development on the Highway Network Policy T2: Channelling Traffic onto the Primary and District Distributor Network Policy T3: Development not well related to the Primary and District Distributor Network Policy T5: New Accesses onto Highway Network Policy P3: Vehicle Parking Standards

Gravesham Local Plan Second Review 2000 The Draft Gravesham Local Plan Second Review Deposit Version 2000 (Draft Local Plan Second Review) has been adopted by the Borough Council for development control purposes but in view of the provisions of the Planning and Compulsory Purchase Act 2004, it is not being progressed any further. Nevertheless, it remains a material consideration. It is acknowledged that the policies are of limited weight but that the weight which can be attached to its policies is greater where the policies are consistent with Government guidance and with policies of the adopted Local Plan First Review.

The following Local Plan Second Review policies are particularly relevant to this application.

Policy MDS3 Northfleet Cement Works/Land East of Grove Road

In the event of the Northfleet Cement Works becoming available for redevelopment, the Borough Council will support proposals for a mixed use scheme, to include Land East of Grove Road, which comprises some or all of the following elements:-

i. a range of employment uses, including port-related,

manufacturing and distribution;

ii. residential development; and

iii. a major sports facility.

A planning brief should precede any planning application(s), such proposals to be accompanied by a comprehensive Master Plan for the area. The following issues would need to be addressed:-

iv. nature, location and mix of land uses; v. height, layout, density and tenure of residential development;

vi. land contamination – remediation measures;

vii. possible rail connection to North Kent Line via Church Path

Pit/St. Botolph’s Pit;

viii. highway links and traffic generation, including any off-site highway improvements;

ix. need for and potential to provide major sports facility;

x. provision of open space and landscaping;

xi. access to riverside; and

xii. links to surrounding community.

All proposals will be subject to Policies T1 (Location of Development), H9 (Affordable Housing), LT3 (Green Grid) and SC1 (Social and Community Infrastructure).

Other relevant policies in the Gravesham Local Plan Second Review are; Policy E4: New Employment Areas, Policy TR3: Public Access to the Riverside, Policy BE12: Design of New Development, Extensions and Alterations, Policy T1: Location of Development, Policy T12: New Accesses on Highway and Public Transport Network, Policy T14: Freight, Policy T16: Car Parking Standards, Policy NE23: Tidal Flood Risk Area, Policy NE15: Contaminated Land and Landfill Sites, and Policy NE16: Air Quality.

Local Development Framework The Council is in the process of preparing a Local Development Framework (LDF) for the Borough since 2005. Progress to date on this document has focussed on the Statement of Community Involvement (SCI), which was adopted in March 2007 and the Core Strategy. The Local Development Scheme (LDS), which sets out the programme for taking forward the LDF, was reviewed in order to address deficiencies in the evidence base and the changes introduced by PPS12 and the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008. The revised LDS was approved by GOSE on 16 January 2009.

A number of public consultation exercises have been carried out to identify the key issues and priorities for consideration in the Core Strategy. In the Core Strategy Key Issues and Options Consultation Document 2007, it was stated in relation to Northfleet Cement Works, Delivering the Major Development sites – the main focus of sustainable development in Gravesham. Leaving aside Gravesend Town Centre, which will in itself be a focus of regeneration activity, the main mixed use sites are Ebbsfleet, Northfleet Embankment (east and west) and Canal Basin/North East Gravesend. The emerging South East Plan designates Kent Thameside as a major growth area, thereby taking forward strategic planning policy already established in Regional Guidance (RPG9 and 9a) and the Kent and Medway Structure Plan. The challenge is therefore is to deliver that growth in a way that is sustainable and responds to local context.

Of particular concern are identifying those major sites which can accommodate the proposed level of development set out in the emerging South East Plan; ensuring that existing neighbourhoods are made more sustainable; and that new and existing areas are knitted together to create a new structure for the Borough that works and meets the needs of the local community.

Beyond this, the growth planned for Kent Thameside set out in the emerging South East Plan is based upon Ebbsfleet performing an important role as an international and domestic transport node on the new Channel Tunnel Rail Link and as a new commercial centre with employment opportunities driving forward the economic regeneration of the sub-region.

Constraints on development limit choices for accommodating the major new development. Beyond this, higher level policy documents already identify the broad areas deemed appropriate for regeneration whilst others already benefit from planning permission. As such, many of the major development sites are largely ‘givens’ and include:-

Ebbsfleet (station and development).

Northfleet Embankment east and west (major opportunities for mixed housing, employment, retail, leisure and other uses together with enhanced transport facilities). Canal Basin/North East Gravesend (major development under way and fresh opportunities being explored). Christianfields/Southfields (separate redevelopment schemes in south Gravesend). Swanscombe Peninsula (area where the potential has yet to be fully explored).

However, whilst the broad development areas have already been defined, the character, mix and distribution of development on individual sites have still to be decided. This will be influenced by a range of factors, including physical constraints, the status of the land (i.e. whether it is brownfield or greenfield land), flood risk, water capacity and transport infrastructure.

In addition, there are a number of significant development projects that are already underway. These include:- • Completion of Channel Tunnel Rail Link Phase 2 – Autumn 2007. • Ebbsfleet International and Domestic Station – opening 2007 with

domestic services from 2009, including trains from Gravesend. • Ebbsfleet Development, as set out in the outline planning consent. • A2 widening

The primary objective of the LDF is to deliver a sustainable pattern, mix and form of development within the Borough of Gravesham which meets the needs of the local community through to 2026 but does not compromise the ability of future generations to meet their own needs. The major development sites are largely “givens” and the main issues are therefore about the way in which these sites are developed and how they are integrated into the wider urban fabric. With regard to Northfleet Embankment, this is an extensive area (87 hectares, extending 2.5 kilometres) on Thames Waterfront, close to Ebbsfleet International Station. SEEDA, with the assistance of with funding from the Department of Communities and Local Government, has assembled key parcels of land for redevelopment and a range of new, mixed uses are proposed, including office, residential and leisure development, as well as new public open space and a riverside walk/cycle way. It is also proposed that FASTRACK will run through the area.

There are three key areas: Northfleet Embankment East, West and Industrial Core. Northfleet Embankment East contains the SEEDA land ownerships and will be progressed most rapidly. A planning application is suspected in the Autumn, which will include, amongst other elements, up to 1,800 dwellings in

a range of types, sizes, densities and tenures, up to 25,000 square metres of employment uses a mixed use centre and a new primary school.

Northfleet Embankment West is predominantly in the ownership of Lafarge Cement UK. The opportunity to redevelop the site will occur following the closure of the existing Northfleet Cement Works in 2008, although Lafarge are proposing to retain land to include an aggregates terminal based around 42 Wharf and rail access alongside the new cement import terminal. A Master plan for this area is in the course of preparation by David Lock Associates.

The Industrial Core comprises the new cement facility and the existing and newly rebuilt Kimberly-Clark facility. The reinstatement of rail freight is actively being pursued for this area. Apart from the housing mix and employment land uses, the key issues are what social, community and leisure/open space facilities are to be provided and where these are best located, height of buildings, highway access and pedestrian links to the existing surrounding communities and the riverside. In the responses to the Key Issues Leaflet (March 2005) the Core Strategy Key Issues and Options Consultation Document indicates that in respect of Northfleet Embankment there was widespread support for regenerating the area for mixed use development (housing, employment, leisure and open space), whilst making the riverside more accessible and securing environmental improvements. There were varying degrees of support for particular types of development, especially industry and employment, whilst safeguarding existing uses and leisure, recreation and tourism, including river-related uses. A significant but lesser number of responses also advocated a wider range of housing, including affordable and key worker accommodation and a combination of housing and employment uses.

A number of people also saw the possibility of improving the road network and links to the Town Centre and A2 and also expressed support for Fastrack. In Responses to the Future of Gravesham Leaflet and Exhibition (March 2006) the Core Strategy Key Issues and Options Consultation Document indicates that in respect of Northfleet Embankment in response to the questions posed, there was a large majority favouring residential-led mixed use development and in agreement with the retention of existing employment and the proposed location of housing. There was strong support for confining leisure provision to housing areas and for improved access to the riverside. A number of people also wanted new indoor leisure facilities to be provided. More recently a draft Core Strategy and Development Management Policies development Plan Document (Regulation 25 document - Issues and Options) was considered by the Council’s Cabinet in December 2009 who approved the document for the purposes of public consultation. A six week consultation period was undertaken between 28 January and 11 March 2010 to enable residents, local businesses and stakeholders to have their say in the future planning for the Borough.

It is anticipated that this will be examined by an independent Inspector appointed by the Planning Inspectorate in 2011 for adoption in 2012.

Core Strategy Policies The most relevant core strategy policies are, Core Strategy Policy 1: Spatial Strategy and Settlement Hierarchy Core Strategy Policy 2: Urban Area Core Strategy Policy 5: Development and Design Principles Core Strategy Policy 10: Economy and Employment Core Strategy Policy 15: Transport Core Strategy Policy 16: Strategic Sites

Core Strategy Policy 16: Strategic Sites indicates in relation to Land at Northfleet Embankment West: An approximate dwelling requirement (from the SHLAA) of 910 units. The approximate employment development requirement is 850m² (A1) and 46,500m² (B1, B2, B8) The approximate other development requirement is 180m² (D2) The accompanying table (Table 8) of strategic sites indicates in relation to Land at Northfleet Embankment West: Objectives for the Site To provide a sustainable neighbourhood with local employment opportunities that conserves and incorporates local heritage. The development should be well integrated, accessible and linked to surrounding residential areas, other key employment locations, local and international transport hubs, Gravesend Town Centre, the River Thames and provide green corridors for recreation and wildlife.

Enabling Infrastructure Requirements

Addressing land contamination and floodrisk, land raising, improving highways access and utilities infrastructure, preserving local heritage and archaeology. Site Specific Requirements • The securing and timing of affordable housing • Open space, play space and play equipment • Any required improvements to highways and public transport arising

from the development • Providing public art and conserving local heritage • A healthcare contribution • An education contribution • A community safety contribution • Provision of community facilities • Provision of and improvements to walking, cycling and public realm

including delivering the Thames Path

Lead Delivery Organisations LaFarge, other businesses located at Northfleet Embankment, SEEDA, HCA and Gravesham Borough Council Sources of Funding

LaFarge, SEEDA and HCA Development Management Policies The most relevant development management policies are, Development Management Policy 3: Protecting Amenity Development Management Policy 4: Design Development Management Policy 14: Maintaining Employment Capacity Development Management Policy 15: New Employment Development Management Policy 30: Assessment Criteria for Transport Proposals Development Management Policy 31: Transport assessments and Travel Plans Development Management Policy 32: Transport Network and Accesses Development Management Policy 33: Vehicle Parking Standards

Development Management Policy 14: Maintaining Employment Capacity states: The Council will seek to sustain and enhance employment capacity (land, floorspace, and/or jobs) in line with the approach set out in the following table and by: 1. Safeguarding existing employment floorspace throughout the

Borough by protecting against changes of use to non-commercial uses. Development that improves the quality and quantity of existing provision will be encouraged.

2. Employment sites identified on the Proposals Map will be

retained and enhanced.

3 Employment floorspace identified in employments sites at (ii) which is suitable for small and medium-sized enterprises (SMEs) in terms of its type, size and affordability will be protected.

Planning applications for alternative uses on sites with an existing employment use, or on sites that were last used for employment uses, will normally be resisted unless the applicant can provide robust and credible evidence that the site has been actively marketed unsuccessfully for its existing permitted employment use for a period of 12 months, or that there are other exceptional planning reasons that would justify a change from employment use. Developers seeking to develop employment sites for alternative uses will be required to prove to the satisfaction of the local planning authority that the wider social

and environmental benefits of a change of use outweigh the economic cost associated with the loss of employment land.

The accompanying Table (Table 9) setting out the policy approach to Employment Sites in the Borough indicates in respect of Northfleet Cement Works Northfleet as a development site as follows: Evaluation Former cement works currently in process of demolition, with new cement import facility constructed and operational. Also includes deep-water wharfage, vacant quarry sites; and good road connection via Thames Way to A2. Also potential to reconnect site to heavy rail. EA Flood Zone 3A + Northfleet Industrial Air Quality Management Area.

Policy Approach to the Site Support retention of cement imports and other river related uses of main part of former factory site using a safeguarded 42 Wharf. Support also accorded redevelopment of western part of the site + Church Path Pit and Vineyard Pits to B1/B2/B8 uses, subject to scheme protecting residential amenity of adjoining areas through mitigation and use of buffer zones. Reason for the Approach Redevelopment of cement works site affords an important opportunity to reconfigure land uses in this area and diversify economy so as not to be overly dependant on Ebbsfleet office type jobs. Provided schemes that come forward are sensitive to context, juxtaposition of larger scale industrial/ employment uses/river-related uses would be acceptable.

Other Planning Policy Documents There are a number of planning policies and documents that are of specific relevance to this proposal for an aggregates import terminal. These include: Government advice in Minerals Planning Statement One: Planning and Minerals (2006)

Kent Minerals and Waste Development Scheme: 15 May 2009 This Minerals and Waste Development Scheme sets out the County Council’s programme for the preparation of Development Plan Documents during the period 2009-2012. Under this programme the County Council will prepare:

• Minerals and Waste Core Strategy DPD • Mineral Sites DPD • Waste Management Sites DPD

Kent Minerals Local Plan: Construction Aggregates (adopted December 1993; covers period to 2006)

This contains a number of saved policies beyond 27 September 2007 including CA1, CA2, and CA3. Policy CA1 (Access Considerations) states, When considering potential locations for wharves and rail depots to receive aggregates, the county council will normally require that they (i) have no undue impact upon road safety and road congestion;

(ii) avoid residential areas; and

(iii) in the case of wharves are capable of linking to the rail network.

Policy CA2 (Primary Policy Constraints) states, Wharves or depots to receive aggregates will not normally be permitted outside of existing port, industrial or railway operational areas and of the locations identified in Policy CA4. Special circumstances will have to be demonstrated to justify exceptions to this policy. Policy CA3 (Local Considerations) states, When considering proposed wharves or depots to receive aggregates the County Council will normally require that: (i) the proposal does not adversely affect local features of identified importance or their setting; and/or that site specific protection policies in a local plan or areas otherwise identified as of conservation significance (e.g. conservation areas) are not compromised (ii) the operation can be carried out consistent with the requirements of policies CA16 to CA23 (iii) the proposal is not unduly obtrusive in the landscape

7. Reason for Report

Major development proposal and the application has been the subject of a previous report.

8. Consultations and Publicity Consultations and publicity on this application was originally undertaken by Kent County Council with nearly 1000 organisations and local residents notified as well as a notice in the newspaper and site notices. It will be for Kent County Council to analyse and consider all the responses received.

An appendix was included in the previous report listing the representations the County Council had received and this Council’s own summary of the responses. This is attached to this report as Appendix 1 The Borough Council additionally carried out its own consultations with other Council Departments. The comments of Regulatory Services to the original proposals are also appended as Appendix 2.

Additional consultations have been carried out by KCC in respect of the application updates and this Council’s summary of new responses is included as Appendix 3. Further internal consultations have been carried out by the Borough Council in relation to the application updates and the following responses have been received. Regulatory Services (Environmental Health), GBC The effect of the update in respect of the BAIT application does not change things greatly in terms of this Services interests.

The planning statement update advises

3.7 The transport modelling informed the modelling of air quality and noise within the Environmental Statement. In the same way given that the revised description of development remains within the thresholds employed within the transport modelling, the Environmental Assessment remains robust for the updated description of development.

It is understood that KCC will use their consultants to check the robustness of this statement but provided this remains true nothing further needs to be added by this Service.

It is also advised that,

3.17 The reinstatement of the rail link was scheduled for 2013 in the original submission of the applications. Network Rail and Lafarge are working to a target for installation of the new physical connection by September/October 2011 with subsequent signalling commissioning during Q1 of 2012. However, this is only a target date and the provision of the rail link should not be a precondition of any planning permission for this development.

The report then advises that, …any condition should be based on limiting lorry trips in line with the numbers tested in the assessment.

This is considered appropriate.

It is noted that there is a proposal for open storage of sand and gravel but that open storage of crushed rock will only take place on an occasional basis for operational reasons e.g. following clearances of blockages or following failure of equipment. A condition covering this is appropriate. There are a number of issues relating to dust control that are relevant to this site. Rather than

have these all put in individually it is considered more manageable and efficient if a requirement is placed on the applicant to provide a written dust control policy to be reviewed by the LPA yearly.

It is welcomed that all elements of the toast rack store, screening and storage and washing plant are to be clad and fully enclosed.

The report advises re:

Proximity of external storage to other development 3.27 This matter has been fully assessed in the Environmental Assessment and is not seen as creating any adverse impacts. There are other examples where such storage exists in a similar proximity to non minerals development which do not create significant problems.

Again it is understood that KCC will use their consultants to check the robustness of this statement but provided this remains true nothing further needs to be added by this Service.

Finally this Service notes the information provided by Peter Brett Associates which reviews the environmental impact assessment (EIA) following revision of the proposed development phasing. This advises that it is likely that the development of the BAIT is to be moved back which will have the effect of delaying the full impact of the BAIT and the following statements are made with regard to Air Quality:

The Environmental Statement predicted the combined impact of the proposed aggregates terminal and the mixed use development is a small increase in annual nitrogen dioxide and PM10 concentrations at a few receptors as a result of the development traffic. This impact is now predicted to occur a number of years later. No material change to assessed effects.

And noise:

A number of noise impacts were identified due to traffic and rail activity generated by the aggregates terminal, including ‘adverse –minor’ to ‘adverse – moderate’ impacts affecting a limited number of properties overlooking Church Path Pit. These impacts originally assigned to 2012 will now not occur until 2022 and will not reach full magnitude until 2032. As background noise may have increased between 2022 and 2032, it is possible that a lower noise impact will be experienced at the residential properties than predicted in the Environmental Statement for a future year following completion of the development (now 2032). The effect of the proposed phasing changes will be to delay the occurrence of previously identified noise impacts and potentially ameliorate their severity.

No further comment is considered necessary on these statements by this Service but the previous comments and suggested conditions/controls still apply.

9. Service Manager (Development Control) Comments

Introduction and Scope of the Planning Assessment This planning application is for full planning permission for a bulk aggregates import terminal on an area of approximately a quarter of the existing Northfleet Cement Works site. It will be located on part of the site of what was the main works site (the newer works built in 1970) and now currently being decommissioned. It will sit alongside the now operational Cement Import terminal at the eastern end of the works site which was granted planning permission by the Borough Council in 2005. The application being a minerals development is for determination by the Minerals Planning Authority, Kent County Council, and not by the Borough Council. This Council is however a consultee and is invited to comment on the application. It will be for the Kent County Council to analyse and decide on the appropriateness of the site for the proposals and they will review the proposals in the context of minerals planning policy and guidance and the strategic importance and need for such a facility. It is for the Borough Council to advise on how the proposals will fit within the local context and of any local concerns. Relationship with the Mixed Use Application The aggregates import terminal would be directly adjacent to the mixed use development site to the west and which is the subject of a separate planning application (20090238) for determination by this Authority and which will be separately reported to the Board in due course. The mixed use development is only an outline planning application and therefore the actual disposition of uses is not known or firmly fixed at this stage. However the illustrative master plan proposals indicate that immediately adjoining the site of the proposed BAIT new industrial units (B2/B8) would be located and not residential development, thereby providing a buffer to the proposed residential development further to the west. It is therefore considered that the proposed BAIT would reasonably fit with the emerging proposals for the Mixed Use Development on the remainder of the former Northfleet Cement Works site. Planning Policy Issues

Saved policies from the adopted Gravesham Local Plan First Review (1994) show the site as an existing industrial area (policy E1) over-washed by Channel Tunnel Rail Link safeguarding (policy T14). The commercial river frontage policy (R1) also applies. Subject to a consideration of environmental constraints etc, the use of part of the site for aggregates import would appear to be consistent with these policies because it generates employment (whether industrial or not) and makes use of the river as a means of transport.

Whilst the Gravesham Local Plan Second Review Deposit Version (2000) did not proceed to adoption, the policies therein are a material planning consideration although the weight which may be accorded them is limited. In this instance, policies MDS3 (Major Development Site: Northfleet Cement Works/Land East of Grove Road); E4 (New Employment Areas); H1 (New Housing Sites); LT3 (Development of Green Grid sites); T5 (Channel Tunnel Rail Link Safeguarding); NE23 (Tidal Flood Risk Area) and TR3/4 (Thames River Frontage) apply. Once again, the proposal for aggregates import on this site is not inconsistent with these policies.

The proposal would also appear to have a good fit with saved policies CA1, CA2, and CA3 of the Kent Construction Aggregates Local Plan. Whilst the site is not specifically identified as a potential aggregates import site, it is an existing industrial operational area with wharfage and (subject to detailed consideration through the planning process) capable of meeting the other criteria set out in the policies. Environmental Impacts The site has previously been used for many years as a cement works operating on a 24 hour basis without the extent of planning controls and safeguards that would normally be imposed. The current proposals whilst acceptable in principle in environmental terms, bearing in mind the past uses of the site over many years for cement manufacture, will nevertheless have some impact on local amenity in terms of noise and air quality including railway noise and other impacts including additional traffic generated by the development. Certain safeguards would therefore be sought in the event of the Kent County Council resolving to grant planning permission. The comments from Regulatory Services (Appendix 2 to this report) as originally made in response to the consultation process last year set out in detail the issues and concerns in terms of noise and vibration effects, lighting impacts, contamination, air quality and vermin control. Further comments in response to the updated information are also set out in this report (section 8). A number of planning conditions are recommended in the comments made and these are set out in the recommendation in this report. The Board will note, as referred to earlier in the report under the proposals section that it is proposed to reinstate the freight railway link between the North Kent Railway Line and the cement works site through Church Path Pit via the eastern most tunnel to provide rail access to the Bulk Aggregates Import Terminal. The actual reinstatement of the track is already effectively permitted as Union Rail Link removed much of the existing rail system and has an obligation under the CTRL Act to reinstate significant elements of the trackwork. These works do not require formal planning permission under the Town and Country Planning Act. The track will not go back entirely in

the same location that was formerly used due to the previously unacceptable tight curvature that was in place in Church Path Pit. The rail works that do require planning permission in this application are however the sidings within the Cement Works site and where the track does diverge from the previous alignment. However irrespective of whether some works are permitted development the applicant will need to comply with best practicable means to ensure the track is ‘state of the art’ and designed to prevent any unnecessary noise/ground borne vibration. A planning condition is recommended to deal with measures and mitigation to reduce noise and vibration from rail use. The applicants have indicated that they would have concern, if permission were to be granted for the BAIT, that the implementation of the rail link was a pre-condition of any permission. They have also expressed concern at any limitations on modal split – the number of movements by either road, rail or water although they would expect a limit on numbers of lorry trips. Other matters considered necessary to be limited or controlled through planning conditions by Regulatory Services include: • a general control on noise, vibration and dust through a

comprehensive Code of Construction Practice • mitigation/maintenance of the rail track

• a limitation on barge loading/unloading operations to only take

place during the normal working hours

• measures to minimise noise impacts of plant, machinery and other equipment

• a detailed noise report to be submitted showing the rating level of

noise emitted from the built development and designed so as not to exceed background noise levels by more than 3dB

• a lighting report to be submitted

• waste storage facilities to be provided

• the submission of a contaminated land assessment

• management and mitigation of traffic for air quality reasons

• a limitation on the number of barge and train movements per

week/day

• mitigation measures in relation to the use of conveyor belts

• enclosing of stockpiles and screening within buildings to ensure there is no impact from fugitive dust or from PM10 emissions during demolition, construction or operation

• open storage of crushed rock to take place only on an occasional

basis for operational reasons

• submission of a written dust control policy to be reviewed annually

• cladding and enclosing of the toast rack, store screening and storage and washing plant

• the mitigation measures in the Environmental Statement

concerning the moving of aggregates and likely dust to be implemented

• vermin control to be implemented during demolition and

construction phases. Other Impacts

The Board will note from the other consultation responses in relation to traffic impacts in particular in the responses from both Dartford Borough Council and Kent Highways Services the concerns at the impact on the highway network arising from HGV movements associated with the BAIT. It is recommended in those responses to the County Council that controls are placed on the number of HGV movements from the BAIT that HGV routing is imposed and that suitable contributions are also sought to the strategic transport infrastructure programme. Officers of this Council would support the mitigation being sought by Kent Highways Services and Dartford Borough Council in reducing the highway impact of the development. Phasing The Board will note that one of the main updates to the proposals since the application was first submitted is in respect of the phasing with the BAIT not being open until 2015 rather than 2011 as originally suggested. It is stated that it is now intended as a long term development and a key reason is the economic recession. However in addition the Board is advised that proposals are likely to come forward at an earlier stage (late 2010) to use the land on a temporary basis for up to five years for the Crossrail project for a tunnelling logistics facility. This will comprise receiving and processing of excavated material from Crossrail tunnels, casting tunnel segments and delivery of tunnel segments. The site will be required for approximately five years. A public exhibition of the Crossrail proposal is being held at Lawn Road School on Tuesday 5 October. If a planning application is subsequently submitted this will also be for determination by Kent County Council.

Conclusion In considering all the information and assessing the various responses to the consultation and publicity process it is concluded that there is no objection to the principle of a bulk aggregates import terminal on the former Northfleet Cement Works site in planning terms subject to a number of controls and conditions to mitigate the potential environmental and other impacts. In the analysis of the planning issues and the subsequent recommendation consideration has been given to the Human Rights Act and it is concluded that any breaches or interference to individual human rights are reasonable and fair.

Planning Application GR/2009/0286 RECOMMENDATION That the Kent County Council be advised that the Borough Council raise NO OBJECTION to the principle of a bulk aggregates import terminal but requests that in the event of Kent County Council resolving to grant planning permission planning conditions and other satisfactory safeguards are imposed to control the use and limit the impact of the development in relation to potential harm to local amenity and in terms of traffic generated by the development using local highways. In particular it requests that the planning conditions set out in the recommendation of this report are imposed.

In addition it supports the concerns of Dartford Borough Council and Kent Highway Services in seeking to limit the amount of material transported by road including a limitation on the number of vehicle movements and to ensure that alternative means of transport by rail and river are available upon the operation of the BAIT. It also requests that the responses of the other various consultees and local residents are carefully considered and taken into account in determining the application.

Suggested planning conditions: 1. No development shall take place until a comprehensive Code of

Construction Practice has been submitted to and approved in writing by the County Planning Authority. The Code shall address the matters set out in paragraph 3.8 of the Environmental Statement Volume 1 – Text (dated March 2009) and include the mitigation measures set out in the following paragraphs of the Environmental Statement:

• Paragraph 7.6. relating to air quality; • Paragraph 8.6 relating to noise and vibration; • Paragraph 12.6 relating to geotechnics and soil contamination; • Paragraph 13.6 relating to waste

The Code shall be implemented as approved unless otherwise agreed beforehand in writing by the County Planning Authority.

2. Measures/mitigation (including ongoing maintenance) to reduce

squeal and vibration from rail use (if not covered by above) and use of audible warnings (i.e. horns) to be submitted for approval. Reference shall be made to the design measures that have been put in place on the railway to mitigate adverse noise/vibration effects as detailed in a separately prepared report produced by Robert Skene Consulting (RSC) including in ES Appendix D3.

3. Hours of use condition that only allows ship, barge and rail loading,

unloading and shipment within normal working hours (to be defined).

4. Measures to minimise noise impacts of plant, machinery and other

equipment (e.g. resilient noise dampening surfaces, etc) to be submitted for approval.

5. A noise report showing that the rating level of the noise emitted from

the built development (other than noise from the exit or entry of road vehicles), shall not exceed the existing background noise level by more than 3dB shall be submitted for approval to the County Planning Authority. The noise levels shall be determined at the points nearest to adjacent existing and proposed residential premises. The measurements and assessments shall be made according to BS4142:1997. No building works shall commence until approval of this report has been given by the County Planning Authority.

6. No lighting to be installed until a suitable written report has been

submitted to the County Planning Authority providing sufficient information as to what extent surrounding existing and approved light sensitive properties are to be affected by the lighting of the bulk aggregate import terminal and associated transport routes, demonstrating best practice and detailing what works are to be carried out to minimise light disturbance. The development shall not be lit until approval of the report is received from the County Planning Authority and all measures included in the approved plan have been put into place.

7. Storage facilities to be provided shall be of sufficient capacity having

regard to the quantity of waste produced and the frequency of waste collection. All waste shall be removed from site on a regular basis by a licensed waste carrier and disposed of at a licensed waste disposal site.

8. No development approved by this permission shall be commenced

prior to a contaminated land assessment (in accordance with the CLEA guidelines and CLR 11 methodology) and associated remedial strategy, together with a timetable of works, being submitted to the County Planning Authority for approval.

a) The contaminated land assessment shall include a desk study to

be submitted to the County Planning Authority for approval. The desk study shall detail the history of the site uses and if necessary propose a site investigation strategy based on the relevant information discovered by the desk study. The strategy shall be approved by the County Planning Authority prior to investigations commencing on site.

b) The site investigation, including relevant soil, soil gas, surface

and groundwater sampling, shall be carried out by a suitably qualified and accredited consultant/contractor in accordance with a Quality Assured sampling and analysis methodology.

c) A site investigation report detailing all investigative works and

sampling on site, together with the results of analysis, risk assessment to any receptors and a proposed remediation strategy shall be submitted to the County Planning Authority.

The County Planning Authority shall approve such remedial works as required prior to any remediation commencing on site. The works shall be of such a nature so as to render harmless the identified contamination given the proposed end-use of the site and surrounding environment including any controlled waters.

d) Approved remediation works shall be carried out in full on site

under a quality assurance scheme to demonstrate compliance with the proposed methodology and best practice guidance. If during any works contamination is encountered which has not previously been identified then the additional contamination shall be fully assessed and an appropriate remediation scheme agreed with the County Planning Authority.

e) Upon completion of the works, this condition shall not be

discharged until a closure report has been submitted to and approved by the County Planning Authority. The closure report shall include details of the proposed remediation works and the quality assurance certificates to show that the works have been carried out in full in accordance with the approved methodology. Details of any post remediation sampling and analysis to show the site has reached the required clean-up criteria shall be included in the closure report together with the necessary documentation detailing what waste materials have been removed from the site.

f) Where applicable, a monitoring and maintenance scheme to

include monitoring the long-term effectiveness of the proposed remediation over an agreed period of time, and the provision of reports on the same, must be prepared and approved in writing by the County Planning Authority.

Following completion of the measures identified in that scheme, and when the remediation objectives have been achieved, reports that demonstrate the effectiveness of the monitoring and maintenance carried out must be produced and submitted to the County Planning Authority.

9. A scheme for management and mitigation of traffic due to concentrations of nitrogen dioxide and PM10 (particularly as the levels of nitrogen dioxide in the area are only marginally below the objective are receptors along the B2175 through Northfleet and as additional traffic may cause the annual mean objective to be exceeded in some locations triggering the declaration of an Air Quality Management Area) to be submitted for approval.

10. No more than four ship/barge deliveries per week, a limit on barge

exports and no more than four train movements per day without the prior approval of the County Planning Authority having been obtained.

11. Full details of mitigation measures during operation of the bulk

aggregates import terminal shall be submitted to the County Planning Authority before commencement of the development; such measures

shall include the use of covered conveyor belts, fully enclosed stockpiles, and placing the screening within a building.

12. Details shall be submitted for approval by the County Planning

Authority of measures to address any impact on fugitive dust and PM10 emissions during demolition, construction or operation of the bulk aggregates import terminal.

13. Open storage of crushed rock for operational reasons shall only take

place on the site with the prior written agreement of the County Planning Authority.

14. A written dust control policy shall be submitted for the approval of the

County Planning Authority before commencement of the development; the agreed policy shall be reviewed annually.

15. The toast rack building (for the storage of crushed rock), the screening

store, and the storage and washing plant shall be fully clad and enclosed before the aggregates terminal herby permitted is first brought into use.

16. The mitigation measures in section 7.6 of the Environmental

Statement to address concerns about fine particulates/dust associated with the unloading of the aggregates from the ships/barges and movement to and from stockpiles shall be implemented before the bulk aggregates import terminal is brought into use.

17. Vermin control during demolition and construction phases shall be

implemented in accordance with details to be first submitted to and approved in writing by the County Planning Authority; such details shall include implementation of a strict baiting regime during all phases from demolition to operation and consideration of appropriate landscaping to avoid providing the ideal habitat for rats.