Covers Farm: Squerryes wants more time. No answers on haul road issue.

Squerryes wants yet more time on the quarry

Morants Promotions Ltd have asked Kent County Council Minerals and Waste Planning  and Planning for yet more time to carry out the “stabilisation/restoration” work at the Covers Farm quarry.  This is Planning Application KCC/SE/0223/2019.  Consultation on it has now been extended until 21st November 2019.

What is “Covers Farm”?

What is the ongoing  application, number  KCC/SE/0495/2018?

One kilometre to the west of Westerham there is a huge depleted sand quarry known as Covers Farm. The sand used to be extracted for tile-making.

In 1983 a planning condition required that, once depleted, the site should be restored to low quality agricultural land. This was to have been achieved simply by moving material around on site, with no importation of further material.

The pit is owned by the big local landowner, Squerryes Estate. Last year Squerryes took back the liability for the restoration of the site from the last company to have worked the pit, Redland Monier.

In 2018 Morants Promotions Ltd, a holding company for Squerryes Estate, submitted a planning application to Kent County Council Minerals and Waste for the “Stabilisation/ Restoration” of Covers Farm Quarry. Planning Application KCC/SE/0495/2018

This application is under ongoing consideration.

Squerryes’ plan involves importing 84,200 tipper trucks of inert waste along local roads and to the site over six years

More about the history of the application

On the site there is sand, bits of tiles and Gault Clay, a lot of this forming a saddle across the middle. Rainwater has accumulated in two lakes, one to the north, the other to the south. In 1983 Kent County Council made an order for the Covers Farm site to be restored to low quality agricultural land once exploitation was finished, simply by draining the excess water and by moving deposits about on site.

In 2017 Squerryes Estate took back the liability for the restoration from the last firm to have worked the pit, Redland Monier.

In the 2018 application to ‘stabilise’ the pit, number KCC/SE/0495/2018 Squerryes’ engineer claims that the walls of the northern lake are unstable. The Gault Clay that once capped the top of the north face has slid down the northern slopes. The engineer assumes that this clay is now lining the lake, preventing it from draining into the sand beneath. The engineer says that there is a risk of the lake overflowing from its the north-eastern rim, causing flooding in that area.

Squerryes’ engineer proposes to build huge dykes, called ‘bunds’, partly in the water, as you see in the upper part of the plan below, and then to slowly drain the displaced water to a second pond to the south and eventually into a sandy area also to the south of the site. The idea is that the land would be built up and contoured so that the surface water would drain into a central stream and flow southward. However the Technical Annex 6 on Flooding and Drainage in the 2018 application leaves many things in this process unclear.


Material on site would be insufficient to build these massive bunds. Squerryes’ engineer has come up with the figure of e 800,000 cubic metres or 84,200 tipper trucks of imported inert waste on local roads over 6 years as being necessary for this. But no-one can understand how he arrived at this figure.

We can be certain however that the importation of inert waste to the site would net Squerryes millions of pounds.

Map showing potential sources of the 800,000 m3 of inert landfill and the suggested routes for bringing them to the site. 66% from the Eltham area via the M25 Junction 5 through Sundridge and Brasted; 33% from North Bromley via Biggin Hill and Westerham Hill. Source: “Technical Annex 10 Transport”.


The ‘temporary’ road or ‘haul’ road

To spare Westerham High Street from all these lorries, Squerryes propose to build a single lane ‘temporary’ road (4m wide with passing places) between the BP garage roundabout and the Croydon Road just metres where the Croydon Road passes under the M25. Please see the map below.

Route of ‘temporary’ haul road in proposal to KCC for Covers Farm Restoration June 2017

Answers have not been forthcoming from Morants Promotions Ltd/Squerryes Estate

Why is Squerryes’ proposed haul road a big engineering concern? Why does Kent County Council still need answers from them?

The engineering consultancy Geo Amey have been asked to look at Squerryes’ application. An issue for them is the proximity of the proposed haul road to the M25 embankment near the Wolfe Garage and the potential danger from this. There would be 200 40-tonne truck movements along this temporary road each day. (See aerial view at top of page). This has nothing to with the alleged instability of the north face of the quarry – the BP garage is one kilometre to the east.

Answers have not been forthcoming from Morants Promotions Ltd/Squerryes Estate.

Highways England, the agency in charge of the M25, mention the tipper trucks’ risk in de-stabilising  the motorway embankment in the cutting beneath the road bridge leading to Biggin Hill.  Please read their letter below:

But Squerryes Estate  claims that it is the unstable quarry that poses the risk 

Squerryes’ engineer and a press release in December 2018 had suggested that the slope instability at the north of Covers Farm quarry could present a risk to the embankment of the M25. In fact Highways England have no concerns about the stability of embankment just to the north of Covers Farm. Evidence of this is contained in the response to an FOI request to Highways England (HE)
FOI Request Any identified risk to M25 westbound carriageway and hard shoulder at Westerham, Kent. (3)

Claim that Kent County Council consider the original Covers Farm plan “no longer fit for purpose”. It just ain’t true!

An inaccuracy in the 2018 Stabilisation and Restoration of Covers Farm Sandpit Main Report  Paragraph 5.5 reads as follows:
“… in discussions with KCC it was agreed that the original restoration scheme was no longer appropriate, since it would resolve neither the geotechnical nor drainage concerns, and would create a site that was not fit for purpose in terms of minimizing the risk to adjoining land.”

But please see the note of the telephone conversation between an elected Westerham Town Council officer and KCC Planning Officers in which they have no knowledge of KCC ever declaring that the original plan was no longer fit for purpose.
note of telephone conversation with adam tomszewski and andrea hopkins (2)

Are the 84,200 tipper trucks on local roads necessary? What is the evidence?

Why 84,200 tipper trucks if the Kent Order said, ‘Use the material on site’?
Given that this would amount to danger and disruption to road users and residents along the A25 and the A233, is all this haulage necessary?

In the Technical Annex 7 (the geotechnical report) the engineer has drawn on a theoretical material and data from other sites. There is no quantifiable scientific geological data taken from the Covers Farm site. Instead, the engineer has relied on visual inspection. Could what he observed be the result of weathering? Is the observed slippage something that’s happened in the past? Are the slopes now i fact stable?

Is there really a danger of the northern lake overflowing to the north-east?

The claim is that the lake is filling at the rate of 30,000 cubic metres per year. This would mean a 10% rise in the level each year. Is this feasible? Photograpghs of the water level in successive years and in successive decades suggest rather that it rises and falls.

What are other feasible options?

Could you drive a row of submerged piles to buttress the northern slope? Where failure of the slope next to Junction 6 of the M25 was observed, this was the chosen solution. A professional structural engineer has suggested that scaled down to the length of the northern face of Covers Farm would require 400 lorries and would take 9 months.

So why is the 800,000 cubic metre solution lasting 6 years the only solution considered?


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