RAGE 3 November 2025 response to SCC Ref 2021/0023

RESIDENTS AGAINST GRAVEL EXTRACTION - 3 November 2025 response to SCC Ref 2021/0023

The following is a slightly reformatted HTML version of the original docx file response.

Egham Residents’ Association, Stroude Residents’ Association, Thorpe Ward Residents’ Association,

Chairman: Dr Jocelyn Boxall Treasurer: Helen Garlick

                                                                    Residents Against Gravel Extraction  
                                                                    27 Manor Way  
                                                                    Egham  
                                                                    Surrey  
                                                                    TW20 9NQ  
                                                                    3 November 2025  

Ms S Saadeh Assistant Director for Planning and Development Planning PO Box 478 Reigate RH2 8EF

Dear Ms Saadeh

Your ref: SCC Ref 2021/0023 http://planning.surreycc.gov.uk/Planning/Display/SCC Ref 2021/0023

Location: Land at Whitehall Farm, Stroude Road, Egham, Surrey TW20 9UZ Proposal: Extraction of sand and gravel from land at Whitehall Farm together with the erection of processing plant and associated mineral infrastructure, the provision of a new access from Stroude Road, restoration involving the importation of inert materials to agriculture, parkland, wet grassland, reedbeds, and new woodland on a site of approximately 38 ha, and the temporary stopping up of footpath 64, and permanent diversion of footpath 39.

As Chairman of Residents Against Gravel Extraction, I would like to thank you for seeking to consult with parties in the area who may be affected by this proposal. I am writing a response to you about the latest amendment to the plan contained in Volume 4/1 Environmental Statement - Regulation 25 & Planning Application Reference SCC 2021/0023 Response dated August 2025, Appendix A and nine Environmental Statement addenda and new and revised phased working and restoration plans, concept restoration plan, tree protection plans and tree constraints plans and an aftercare and management plan. I would be grateful for the following observations and questions to be considered alongside our previous comments and questions, which still stand.

Concerns and questions about the impact of increased HGV traffic.

15/08/25 ES Reg 25 Response - Volume 4/1 T Addendum - Addendum Transport Assessment dated August 2025

The estimated increased volume of HGV traffic on an already busy highway on local roads is considerable. The table 3.3 on page 7 suggests an increase in ‘with-development’ HGV traffic is estimated to be 522 vehicles per weekday in the immediate, relatively small, area (based on establishing the actual number rather than a percentage increase and comparing baseline data and ‘with-development’ numbers – see the table below). This is in addition to ordinary HGV and other traffic and is a high number of extra vehicles.

The question is: How will the small roads, which include two mini-roundabouts and one small roundabout in close proximity to the motorway bridge and close to each other, accommodate these numbers, especially if other developments are simultaneously taking place nearby? This includes estates such as Maple Croft, whose access road is a few metres from the second mini-roundabout from the bridge on Thorpe Lea Road.

Forecast HGV Weekday Distribution in numbers of vehicles.

The estimated movement of HGV traffic for in-development seems only slightly different from the table provided in Table 7.7 p32 of the previous assessment dated 18/02/21 18/02/21 TA Appendix 7 - Transport Assessment - part 1 of 4 (report and plan 1) For example, the traffic estimate for B3376 Thorpe Lea Road had decreased by 86 and B388 Thorpe Lea Road by 20 perhaps due to some proposed developments being withdrawn but do the new figures do take into account the possible traffic from Maple Croft off Thorpe Lea Road which has 52 new homes – with possibly more than one vehicle per household? The information on the impact of the proposal on the highway in Impact upon Highway Operation, 3.16 p.8 states:

3.16 As per the TA [Traffic Assessment], it is expected that operational movements would be evenly distributed throughout each day; during peak operations, the proposed development is forecast to attract 15 HGV movements per hour between 08:00 and 16:30, reducing to 11 HGV movements per hour during 07:00-08:00 and 16:30-17:30.

This suggests that at peak times 15 vehicles per hour in addition to existing HGV traffic would be used during the operation. This equates to an extra 150 vehicles per day, (127.5 during peak times + 22 at non-peak) or 825 per week if working Monday to Friday 7 am to 5.30 pm and part of Saturday (5.5 working days at 10.5 hours per day; still a significant amount of additional traffic. The traffic assessment update suggests that there would be 146 in-development HGV movements per day (7.18, p.29).

Traffic carrying in-fill materials.

Whilst there has been a suggested preference for alternatives to in-fill which would cut down HGV movements (but only to some extent), the Traffic Assessment bases its information on in-fill traffic. The increased HGV traffic bringing in-fill equates to a significant increase of the number of lorry movements throughout the duration of the excavation of minerals (excluding the set-up year). For example, according to the proposal we are to expect transportation of 1,350,000 tonnes of inert fill materials to site. This means a typical HGV 8-wheel tipper lorry, which can carry 20 tonnes, needs to make 67,500 journeys to bring in-fill. Over the estimated 6-year period of 50 weeks of proposed in-fill truckloads, the amount of in-fill varies and is heavier towards the end – 200,000 tonnes per annum during extraction in early versions of the proposal rising to 350,000 tonnes per annum towards the end. Whichever way this is estimated for the traffic burden, these are very high figures for in-fill and the transport to bring it which will have an impact on the environment and the local residents.

We do not know what the predicted traffic flow is for the post-2028 period, 2028 being only one year into this proposed activity.

Set-up traffic on Whitehall Lane and its links to Stroude Road.

The estimate of ‘in-development’ traffic excludes the number of HGV’s required for the 1-year set-up – we do not seem to have an estimated number of lorries for this phase which will use Whitehall Lane, (which is a lane rather than a road) presumably accessed via Stroude Road. This part of the plan will also significantly affect the residents of Whitehall Lane, Manor Way, Bosher’s Gardens, Crown Cottages, Milton Park Farm Cottages and others.

The question arises whether these calculations about the burden of traffic have been considered in the current Volume 4/1 response. To gain a realistic understanding of how many vehicles will be driving along the named roads each weekday, these additional factors will surely need to be taken into account.

Concerns About Water

15/08/25 ES Reg 25 Response - Volume 4/1 CA Addendum - Carbon Assessment dated March 2025 Redacted

The length of time that the site would be operational and its impact on the environment over time in terms of water consumption is of concern. The following comments and queries relate to information on pp.19-20 of the carbon assessment about the amount of water needed to undertake the extraction process. For example, the Carbon Assessment dated March 2025 suggests:

B7 Water Use

During the operational phase, water will be used for several key purposes. Approximately 400,000m3/year of water will be used for mineral processing, involving the wash, screen and separation of minerals as part of the extraction and processing activities. Water will also be required for welfare and office facilities on-site. This includes providing potable water for drinking, sanitation, and other daily needs of the staff. Table 5.10 summarises the carbon emissions from such water use. (15/08/25 ES Reg 25 Response - Volume 4/1 CA Addendum - Carbon Assessment dated March 2025 Redacted , p.19)

This amount is equivalent to a large lake per annum. The question is: Where will this water come from, and go to, in an already stretched environment which suffers both drought and flooding, both of which are set to increase? The environment of 2025 is considerably altered as a result of climate change and the future beyond 2028 needs to be taken into consideration as this date is only the proposed beginning of a lengthy process over many years involving water.

22/10/25 Affinity Water Response Redacted

The response by Affinity Water dated 22 October 2025 suggests that construction work ‘may exacerbate any existing pollution’. It also suggests that there would be an increased demand for supply in the area as a result of the development. The question here would be, how much stress would this activity place on existing supplies to the area? Also, how much, if any, pollution exists and how much more pollution would be caused by the proposed sand and gravel extraction and subsequent in-fill?

Water and residential properties near the proposed site.

During the summer of 2025 local residents were requested to consciously cut down on their consumption due to shortages.

Flooding Risks

The risk of flooding, particularly on the Egham Hill side of the proposed excavation pits continues to be a matter of concern in this area. The problem is elaborated in more detail by Egham Residents’ Association’s submission of comments.

15/08/25 ES Reg 25 Response - Volume 4/1 CA Addendum - Carbon Assessment dated March 2025 Redacted

The detail 5.3.22 on p. 20 outlining the long period of aftercare following in-filling at the site after its proposed activity to monitor emissions from fuel use is also of concern. The question for this part of the process, which extends decades beyond the mineral extraction itself, would be: What kind of emissions would these be and what impact will they have on the health of the local population? Why do the emissions need 25 years of monitoring?

Ongoing Concerns with PM2.5 emissions.

Along with other residents and residents’ associations, concerns about the fine particulate matter – PM2.5 particulates – generated by industrial processes, and the increased volume of HGV vehicles arriving at and leaving the proposed site continue.

Recent research into the effects of PM2.5s from industrial processes provides insight into this increasingly relevant issue and is especially relevant in terms of air quality. The research identifies an increase in strokes and heart conditions for those living near industrial sites.

Concerns about the plan and its proximity to existing and proposed dwellings less than 1 km from the site.

Another consideration regarding this proposal is its proximity to dwellings less than 1 km from the site. A simultaneous, ongoing proposal to build accommodation for 1,400 students at the bottom of Whitehall Lane on the site of the former Proctor and Gamble research laboratory will add a considerable amount of heavy traffic throughout construction and create demand for water. The site is currently being maintained whilst the owner, Royal Holloway, University of London, considers its future plans. Therefore, the proposal to extract sand and gravel needs to be considered in relation to other proposed activities in the area. Cemex’s plans still show the site as a ‘Research Laboratory’ and have not been updated to reflect the change of proposed use. We reiterate that a sand and mineral extraction site less than 1 km from this area would create noise and dust from 7 am until 5.30 pm 5.5 days a week over the suggested timeframe of 6 years (8 years overall including set-up) in close proximity to these proposed living conditions for students and support staff. In addition, building work – possibly commencing during the proposed sand and gravel extraction - would add a considerable amount of further traffic.

Concerns about the proposed time-frame of working the site and further works.

Another concern about the updates of this plan is that in addition to this proposal to work the Land at Whitehall Farm site for an estimated period of 8 years, there is a clear intention to work the Milton Park Farm site afterwards. This would extend the period of working considerably, potentially exposing local people to many more years of industrial activity, noise and pollution. What research has been done to estimate the cumulative impact of HGV traffic and environmental factors here?

Questions about government building targets and links to mineral extraction.

Finally, references to the government target of building 1.5 million new homes by 2029, and the need for minerals to support the development of these plans, need further detailed explanation and response to recent scepticism about whether this government target could realistically be achieved by then. By March 2025 the OBR (Office for Budget Responsibility) was highlighting that the government could not meet its target. In the light of this, the question arises about the actual need to extract minerals from the proposed site when stockpiles are already accrued. Thank you for taking the time to read the comments and questions on the proposal additions and amendments.

Yours sincerely

Jocelyn Boxall Chairman, Residents Against Gravel Extraction.