Campaign to Protect Rural England (CPRE) North East London have been active in trying to support developments at Risebridge and at other sites in North East London. Phil Butler recently produced this comprehensive report combining developments in North East London with our research elsewhere in the Country.

Andrew Rosindell, MP for Romford, being interviewed by Gareth Furby of BBC London News in the park adjacent to Risebridge Golf course, Romford; the bunding can be seen in the background (26.03.08)


Deferral of decisions is required on current LB Havering landraising applications and referral to the Environment Agency and Natural England pending the consultation and review of the rules governing licencing exemptions recently announced. There is a need for strong Supplementary Planning Documentation, including commensurate financial indemnity, to defend all open space from activities described below by EA Chairman Sir John Harmer as unscrupulous flouting of the landfill licence exemption for landscaping.
The selected justification [emphasis added in relevant places] has been compiled with the help of a network of directly affected residents groups. More evidence is available if needed.


Risebridge [Met: green belt] Golf Course
LPA granted permission to the Jack Barker Grp: for remodelling with 150,000 m3 [= 30,000 lorry movements] ‘topsoil’. When work started residents protested that the topsoil was in fact treated waste. Other issues included: a drainage lagoon and drainage channel had been filled in, high bunding, loss of privacy, interference with a footpath and destruction of a locally listed wildlife area. A proper EIA [Environmental Impact Assessment] was not submitted. A stop notice was issued and an amended application P1177.06 [for 134,000 m3 = 26,800 lorry movements] was approved. However residents complaints continue. Enforcement negotiations are ongoing while landraising continues. CPRE raised the issue with the Havering Wildlife Partnership and concerns have been raised with the LPA. Liability to prosecution under the Wildlife and Countryside Act was highlighted by Natural England [NE], the London Essex & Herts Amphibian and Reptile Trust [LEHART] and the London Mammal Group but has not been proceeded with to date.

Hornchurch Country Park [Met: green belt]
Current planning application P2028.07 by Ingebourne Valley Co: for 5-6 years loss of access and amenity on an area of 46 ha to facilitate deposition of an unspecified volume of treated waste [based on the min: figures in the application this equates to 200 lorry movements/day or 264,000 over 5 years, and approx: 2million tonnes of waste; i.e. 10 times the Risebridge GC operation] on a long-remediated former landfill site that has been safe for full public access for some four decades, has flourishing tree and floral grassland and is part of the designated Ingrebourne river borough/GLA Green Corridor, Green Arc, Green Grid, LOOP and Connect2 plans. The site has heritage and WWII archaeological value as a Battle of Britain airfield. The stated purpose is to recreate former grass runways but effectively the country park will be turned back into a very large unlicenced landfill site. No proper EIA submitted, only a quote of the UK Wildlife Trusts general statement of support for restoration of hazardous sites with inert landfill linked to an unjustified assumption of poor existing ecological value and consequential poor ecological restoration commitment. CPRE have formally objected, pointing out the flimsy excuse for profitable waste disposal and have raised the issue with HWP.

Maylands Golf Course [Met: green belt]
A previous 2006 planning application by the owners P2157.06 for 390,000 m3 on an area of 21 ha for a nine hole extension over a regionally listed wildlife/scenic area, part of the designated Ingrebourne river borough/ GLA Green Corridor, Green Arc, Green Grid, LOOP [London Outer Orbital Path] and Connect2 plans, was published after destruction of habitat had begun. CPRE formal objection and discussion at HWP of wildlife and landscape issues resulted in a stop notice and application withdrawal. CPRE also objected to the current re-application P2061.07 for 350,000 m3 = 70,000 lorry movements over five years [2.6 times the Risebridge GC works] quotes the UK Wildlife Trusts general statement of support for restoration landfill of hazardous sites linked to an obviously flawed ES [Environmental Statement-not the required EIA] and a consequentially poor ecological restoration commitment. NGO representatives on HWP have taken up this case formally with the LPA.

Whalebone Lane Nth Proposed Golf Course [Met: green belt]
Current application to expand a driving range to a full course on 47 ha of Crown farmland [dissected by by the LB Havering/LB Barking & Dagenham boundary] by importing 648,430 m3 of construction waste = 129,686 lorry movements at 100 lorry movements per day over three [or more?] years [4.8 times the Risebridge GC works]. The Environmental Statement is considered to be inadequate. There is an issue about future return to agricultural use. CPRE have formally objected to both LPAs involved and raised the issue with HWP.

Wennington Rd Rainham [Met: green belt] proposed bund along N side of railway
No information given on purpose or volume of imported material for a long bund on wetland adjacent to the Rainham Marshes SSSI [best estimate based on applicant’s sketch is about 8000 m3 = 1600 lorry movements]. The water table, drainage, landscape and wildlife are likely to be adversely affected. CPRE have formally objected and RSPB have raised the issue with the EA and NE. A ward councillor has called in the application to ensure determination by regulatory services committee rather than under delegated powers without consideration of the above issues.


With the greatest respect to all applicants, the experience of both residents and LPAs following granting of planning permission involving landraising at far too many sites is that watertight conditions covering delivery of all proposed benefits and adherence to all specifications are essential e.g:
3D presentation of actual planned works for public consultations, not artistic impressions,
finished landscape quality,
full environmental impact assessment,
archaeological and historical assessments,
community benefits,
floodlighting issues,
scheduled lorry movements and routes,
dust and mud controls,
highway damage,
maximum use of ‘cut and cover’ design to minimise imported material,
quality and quantity of imported materials,
planned placement of materials,
monitoring arrangements,
return to agriculture as/when required,
possession of all permits and licences before the start of any work,
protection of the permanent open space and/or green belt character and status of the site,
financial indemnity commensurate with the frequently experienced, foreseeable risks e.g:
the need for, and cost of, monitoring, enforcement, legal challenges and removal of imported material should the applicant or a contractual successor default following enforcement of agreed conditions.
Full Environmental Impact Assessments are essential in these cases. LPAs have powers to review an ES and require full EIA on sites of 1ha or more and to ensure that proposals are amended in line with European Directive 97/11/EC, Town & Countryside Act Regulations 1999 S4, and Circular 02/99.

Sent: Thursday, March 13, 2008 5:32 PM
Subject: House of Commons Landraising PQs

Andrew Rosindell (Romford) (Con): What his policy is on the use of waste as part of the landscaping of new developments; and if he will make a statement. [193649]
The Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs (Joan Ruddock):
The Government encourage the reduction, reuse, recycling and recovery of waste wherever possible. As a way of encouraging recovery, suitable waste can be used in landscaping developments under exemptions from waste management licensing, administered by the Environment Agency.
Andrew Rosindell:
I thank the Minister for her reply, but has she had an opportunity to examine the situation at the Risebridge golf course in my constituency, where hundreds of thousands of tonnes of waste have been dumped under the guise of landfill, to the great benefit of the company running the golf course? Will she come to see the destruction that that is causing to the local environment, and take immediate action to prevent this scam from happening elsewhere in the country? Basildon is another example of where it is now happening. Will the Government take immediate action to resolve that devastation of the environment?
Joan Ruddock:
I have indeed taken the trouble to examine the case that the hon. Gentleman raises, as well as that raised by my hon. Friend the Member for Basildon (Angela E. Smith) in respect of the Basildon golf course. The Environment Agency has permitted the use of the material on the site, but having heard the hon. Gentleman's case, I have drawn the issue further to the attention of the agency. It tells me that it visited on 28 February, and will visit again on 20 March. Because of the concerns that he and other Members have raised, a review of exemptions from permitting will take place. A consultation will be carried out this summer, and the revised exemptions could be introduced at the earliest in October next year. That will be done, and we are concerned. Where waste can be used in low-risk operations, that should be done for recovery. Where there are possible scams, however, permitting will be needed. That will be the subject of the consultation.


Jack Barker golf course operations
Research by Basildon campaign

The Jack Barker Golf’ website shows that it currently runs 12 golf courses: Risebridge (Romford, RM1 4DG); Chirk (Wrexham LL14 5AD), Delapre (Northampton NN4 7DU), Goldenhill (Stoke on Trent ST6 5SS), Greenway Hall (Bagnall, Stoke on Trent ST9 9LJ), Hucknall ( Nottingham NG15 7TA), Keele (ST5 5AB), Mansfield (NG18 3PJ), Nottingham (NG6 8LF), Rother Valley (Sheffield, S26 5PQ), Tamworth (B77 4EG), Wavendon (Milton Keynes MK17 8DA).
There is some evidence that each golf course is managed by a separate company rather than directly by Jack Barker Golf. For example, Chirk Golf Course appears to be run by Chirk Golf Course Limited, 15 – 21 Victoria Road, Bletchley, MK2 2NG, and Goldenhill Golf Course appears to be managed by Golf Course Management (Elesmore) Limited of Tattenhoe Lane, Bletchley, MK3 7RB. A new company, Basildon Golf Centre Limited, was set up to run Basildon Golf course.
The 12 courses seem to vary greatly in their locations, their features and in the extent to which Jack Barker Golf has sought to ‘improve’ them through the importation of inert waste and in other ways. For example, I could find no evidence of proposed ‘improvements’ at Chirk. However, there has been controversy over proposed improvements at Risebridge, Delapre, Goldenhill, Rother Valley and Wavendon. In addition, plans at Keele were significantly changed after consultation with the County Council, and the same County Council has objected to plans at Tamworth. Plans for a completely new course (at Streathill Buckinghamshire) were rejected. The issue of the volume of waste to be used for improvements and/or its impact on the environment features throughout and has led to the rejection of plans at Rother Valley, Stearthill, Tamworth and Wavendon, and to the modification of plans at Keele. Work that was allowed to proceed has been the subject of complaints at Risebridge, Goldenhills, Greenway Hall (Bagnall) and Delapre.
Goldenhills Golf Course, Stoke on Trent, Staffordshire:
A question about this development was asked in the House of Commons on 15 November 2001
Ms Joan Walley (Stoke-on-Trent, North): In respect of landfill sites, my right hon. Friend is right to emphasise the importance of planning decisions. Can he give a progress report on the work that he has been able to do with the Environment Agency to ensure that golf courses are not using loopholes in planning legislation inadvertently to set up landfill sites when developing golf courses? In my constituency, at Bagnall and Goldenhill, we have real fears that we will end up with waste disposal sites when what we have at the moment are golf courses (Hansard).

Stearthill Farm Bucks

‘Church bells were sounded after villagers learned a controversial scheme for a golf course has been blocked. In a decision this week, a planning inspector rejected the applicant’s appeal over the plan, on grounds the Little Horwood scheme was against waste policies and would have harmed the rural landscape. The Jack Barker Group, which owns Wavendon Golf Club in Milton Keynes, had proposed to build a 27-hole course with a driving range at Stearthill Farm. The scheme would have seen a landraising operation carried out involving the dumping of almost a million tonnes of recycled building waste by lorries over a three-year period. Protests were voiced by villagers concerned about the use of building waste and any potential noise or pollution, and there was also opposition from parish councillors.’


Natural England:

Dear Phil Butler, our enquiries desk has passed me your emails on the above issue. This does seem to highlight a need for more effective planning and regulation enforcement. As a national specialist I cannot comment on the individual cases but where issues relating to the loss of biodiversty, landscape quality and recreational greenspace occur in the future then this is something Natural England might comment on and engage in on a case by case basis.

Jonathan Price Senior Specialist - Planning Policy Team (Planning, Transport and Local Government) Natural England Northminster House Peterborough PE1 1UA Tel +44(0)1733 455210 Fax +44(0)1733 568834 mobile 07876230140 email

English Heritage
Reply states: not satisfied with the required Archaeological survey for Whalebone Lane GC application. [David Divers 0207 973 3000]

Environment Agency
Dear Mr Butler,
Enquiry regarding A Questionable Landfill Practice
Thank you for your enquiry. Please note that for the sites planning permission is issued by the relevant local authority which determines the final contours and thus the quantity of material which can be accepted at the site. Any queries/concerns regarding this matter should be re-directed towards the relevant local planning authority.
Exempt Activities:
Activities described at the sites listed below would or do have a waste exemption and not a waste management licence.
- Risebridge Golf Course
- Maylands Fields
- Maylands Golf Course
- Hornchurch Country Park
Again, the local authorities have the primary powers to determine where waste sites, including exempt sites, are allowed to be located. The Environment Agency's responsibility is to ensure that waste is recovered without endangering human health and without using processes or methods which could harm the environment and in particular without:
i) risk to water, air, soil, plants or animals; or
ii) causing nuisance through noise or odours; or
iii) adversely affecting the countryside or places of special interest.
Whilst we are aware that "landscaping" projects are taken advantage of by unscrupulous operators we have been working at a national level with DEFRA to revise the exemption system. The Environment Agency takes abuse of the waste exemption system very seriously and investigates abuse of the system as and when we become aware. If I can be of any further help, please contact me.
Our ref: NE15552_SS Date: 19 December 2007
Yours sincerely Sandra Stormer External Relations Officer
Direct dial 01707 632302 Direct fax 01707 632 610
Direct email

Adverse effects of bunding
Delapre GC,
With regard to the "Reduction of noise" heading; at Delapre GC, Northampton, the bund on the Public parkland runs parallel to London Road (a main route into/out of the town centre from M1 junction 15). Residents of the properties on the opposite side of the road to the parkland report perceive an increase in traffic noise caused by the bund reflecting this back at their properties. It is more noticeable in summer when windows are open.
In terms of the "Security" heading; the bund has not stopped stolen cars being driven onto the parkland and burnt out - the Police Safer Community Team achieved that! - but until the police strategy paid off, stolen cars could be driven on the parkland for extended periods because the bund reflected the sound back into the parkland, with residents on London Road unable to hear them and so not telephoning the police to report the incidents as they would ordinarily have done.
Best regards, Paul Varnsverry

I entirely concur with your experience, that’s exactly what Mayden tried here at Risebrdge GC, we are on the main A12 out of London, we now have the yobs standing on top of the bunds looking directly into our bedrooms, and of course getting up to all types of anti-social activities, and yes we are still getting the burnt out cars, plus as with you the noise from the A12 now appears to be magnified
Kind regards Ian James

Blunts Farm [Epping Forest District Council]

Working independently to try and stop the landfilling of this green belt site a group of residents formed an action group Theydon Bois & Abridge Action Group [TBAG] in June 2005. We were galvanised at this time by a new planning application for a tennis academy. Due to pressure on the LPA, and by providing evidence to the Environment Agency we put a stop to the landfilling of this site. The Environment Agency withdrew the developers waste exemption licence and the LPA issued Enforcement Notices (for the second time, they were not issued the first time round).
We have had several meetings with our local MP Eleanor Laing and she invited the Chairman of the Environment Agency Sir John Harman to visit the site, he described the developers as 'unscrupulous’ and commented that "By flouting the conditions of the exemption for landscaping, this unscrupulous operator has been able to bring tens of thousands of tons of waste onto the site and may have made up to £20m by doing so. I wouldn't want to see the operator get away with this abuse without suffering substantial financial loss."
We have lobbied Tony Blair, Ed Milliband and The Major of London. TBAG remain opposed to the methodology of landfill for golf course construction and will help others in any way that we can to get this appalling abuse of our environment stopped, nationally. We look forward to meeting you on Tuesday 25th March. John Toplis, a member of a residents group fighting an application to landfill a golf course in Basildon, will also be joining us, as will two members of our local Rural Preservation Society.

Note: Golfers statements of dissatisfaction with landraising activities are on file.


Golf Course receivership
Mr Lloyd Skinner bought North Weald Golf Club Epping Essex from the receivers in 2004. He has stated publicly that the course is running at a loss and requires landfill revenue to survive.
[letter on file PB]. There are some 27 golf courses easily accessible from Havering, Barking and Dagenham. A number are believed to be in, or on the verge of, financial difficulties on the evidence of applications for large scale, profitable landraising. This strongly suggests that applications for new or extended courses must fail the test of need for otherwise appropriate green belt leisure facilities:

Chingford Golf Club,
Royal Epping Forest Golf Club, Wanstead Golf Club,
West Essex Golf Club, Abridge Golf & Country Club, Bentley Golf & CC, Blakes Golf Club Chigwell Golf Club, Fairlop Waters Golf Club, Ilford Golf Club, Loughton Golf Club,
Maylands Golf Club, North Weald Golf Club, Risebridge Golf Centre, Romford Golf Club,
South Essex Golf Centre, Theydon Bois Golf Club, Top Meadow Golf Club and Hotel,
Thorndon Park Golf Club, Upminster Golf Club, Warley Park Golf Club,
Weald Park Hotel Golf and Country Club, Woodford Golf Club,
Woolston Manor Golf and Country Club, Stapleford Abbots Golf Club, Priors Golf Club,
Friars Golf Club.


Stafford Castle Golf Club Staffordshire

"The County Council has provided advice on a number of similar proposals to that proposed at Stafford Castle. For example, following discussions about a similar proposal at Keele Golf Centre (ref: 01/00685/FUL) the total quantity of proposed imported materials was reduced from 30,000 cubic metres to 15,000 cubic metres. This reduction was achieved by the applicant re-assessing and designing the proposals so as to create as many of the course features and landforms as possible through ‘cut and fill’ operations rather than direct importation. The final development was successful in both achieving its intend purpose and objectives and in this case, the County Council was satisfied that the importation operations were ‘incidental to the development proposals’ and therefore had no objections to this being considered as a ‘district matter".

Tamworth GC Amington, Staffordshire

Staffordshire CC advice: "I refer to your letter dated 8 August 2007 which accompanied details on the above proposal. An extension of time to respond to the consultation has previously been agreed until 14 September 2007 as confirmed in your email dated 31 August 2007. The comments and observations made below are made in respect of the County Council’s responsibilities as the Waste Planning Authority only. It is understood that additional comments and advice may have been sought directly from the County Council’s Environment & Countryside Unit and Highways Development Control Unit. Any subsequent comments/issues raised by either of these sections should supplement the comments made in this letter and be taken into account in consideration of the above application.
The application seeks full planning permission for the redevelopment of the existing clubhouse, construction of a new 2 tier floodlit driving range and maintenance shed and various engineering and landscaping works in order to reconfigure and improve the existing course layout. In addition to the building works it is proposed to import approximately 150,000m3 of inert materials which would be used to construct elevated tee areas and landscape mounding surrounding the course, driving range and between fairways. The landscape mounding is proposed to improve course playability, protect users of public footpaths and to shield the driving range and maintenance shed. Mounding proposed around the perimeter of the course/site is proposed to protect neighbouring land from trespass onto and off the site and to screen views of the adjacent industrial buildings (pages 18 & 19 of the Supporting Statement). Based upon the information contained within the Transport Statement submitted in support of the application (paragraph 4.1.1 on page 6) it is anticipated that the works would take approximately 3 years to complete.
Annex A of PPS10 states "that in respect of applications which are properly to be decided by the district planning authority but which involve the use of large amounts of engineering fill for such purposes as levelling or landscaping of sites or construction of bunds and embankments, it may be appropriate for the district planning authority to question the applicant about the purpose of the development".
Policy 10 of the Waste Local Plan reflects the advice in PPS10 and sets out the criteria against which this type of proposal should be considered. One such criterion identified in Policy 10 is to ensure that the amounts of waste deposited are the minimum necessary for intended purpose. As a result, a key issue to be considered in assessing this application is whether the importation of waste materials is essentially financing the proposed development and consequently the key driver behind the proposals or is the proposed amount of fill reasonable and the minimum necessary for achieving the proposed development? In considering the application your Council will need to be satisfied that the quantity of waste proposed is the minimum necessary for the intended purpose and satisfied that the applicant has addressed each of the issues raised in these policies.
Particular issues which must be considered are:

1. Is there a need for soils to be imported at all? Has the applicant looked seriously at alternative methods to importation such as ‘cut and fill’ (i.e. on its own or combined with importation in order to reduce the total quantities of imported material)? Page 12 of the Supporting Statement states that the design of the course has evolved following initial discussions with several departments/sections at Tamworth Borough Council during the tender process. Is the Borough Council satisfied that all possible ‘alternatives’ to the importation of waste been considered?
2. Has the applicant provided a precise breakdown of the quantities of waste to be involved in each proposed area of work? This information will be helpful in checking that the quantities of material quoted are correct and is helpful for monitoring operations should permission be granted.
3. Are the amounts of waste the minimum necessary? (WLP Policy 10)
4. Are the proposals comprehensive, detailed and achievable? (WLP Policy 10)

5. Do the material planning benefits outweigh any planning objections or potential harm (i.e. noise and disruption during operations, dust, heavy traffic movements, duration of operations, landscape impacts etc)? (WLP Policy 10)
Although it is accepted that the importation of waste materials can be common practice for the creation of new golf course features we are concerned that 150,000m3 of material is an extremely significant quantity of material. By way of comparison Poplars Landfill Site receives between 300-500,000 tonnes of waste per annum.
In light of the comments above, we would strongly recommend that should your Council be minded to determine this application, then you should be satisfied that the amount of material required is the 'minimum necessary' for the works proposed and that all possible alternatives to the importation of the amount of waste proposed have been properly considered. By addressing the issues/questions raised above, you should be able to ensure that the quantities of waste proposed are appropriate for the proposal and that the development, if permitted, can be adequately monitored and controlled.
Should your Council decide to subsequently approve the above development it is recommended that conditions should be imposed to address the following issues/matters.
• Quality and type of waste to be deposited (i.e. soils and uncontaminated inert excavation and construction wastes/materials)
• Quantity of waste imported/deposited and the keeping of records on the tonnages delivered
• Access and limitations on the number of HCV movements (further advice should be sought from the County Highways DC Team)
• Details of the vehicle/road cleaning to be implemented before work commences
• Hours of working
• Details of the proposed methods of dust suppression
• Detailed plan showing the final levels and contours of the tipped materials and topsoils
• Duration of tipping operations
• A scheme to be submitted for the progressive construction of the works (including the marking out of the areas for disposal and required heights)
• Details of the proposed methods for the stripping, storage and replacement of soils and requirement that no soils are exported off the site.

Please note that the County Council would be happy to provide further advice and guidance on the wording/appropriateness of any draft conditions, which the Borough Council may subsequently produce.
Under the powers delegated to the Director of Development Services this letter confirms that the County Council as the waste planning authority OBJECTS to the proposals as the quantities of inert materials proposed to be imported as part of the development are of a scale similar to that of a very large waste disposal operation and therefore could potentially be contrary to the advice in PPS10 and Policy 10 of the adopted Waste Local Plan. If the Borough Council is minded to approve the application it is recommended that it clarifies with the applicant the waste issues outlined above and secures proper and adequate conditions relating to the waste matters outlined.
Yours faithfully, Richard Higgs Corporate Director (Development Services)

Wavendon Golf Course Milton Keynes

Excerpt from the case officer report: "When this application was originally submitted, in August 2005, the proposal included additional landscape mounding of the golf course. Officers took the view that, because of the amount of material that would be imported to create the additional mounding, the creation of the mounding should be treated as a waste disposal application rather than a minor engineering application.
Officers therefore requested further information from the applicants, together with the appropriate (much larger) planning application fee that should accompany an application for waste disposal.
The applicants disagreed with the officers’ view and eventually appealed to the Planning Inspectorate against the failure of the Council to issue a decision in relation to the application.
The Inspector supported the officers’ position on the fee and declared the application was invalid.
However, because the application was found to be invalid the Inspector made no decision on the application.
Following the Inspector’s finding in July last year, further discussions have taken place between the applicants and officers. As a result of very significant concerns expressed by officers about the mounding the applicants have withdrawn that element from the current application and the submitted fee is sufficient for the application as amended to be now determined by the authority. RECOMMENDATION
It is recommended that planning permission be granted subject to conditions relating to materials, landscaping, floodlighting and car parking.
Report author / case officer – Jeremy Lee 01908 252316"

Phil Butler for CPRE NE London Group

Update Thursday 3rd April 2008
This evening Phil Butler spoke at a 'planning meeting' in the London Borough of Havering at which permission was sought for the importation of 390,000 cubic metres of landfill. Phil subsequently reported:

After a lengthy debate the reg:services committee tonight unanimously deferred the application for further investigation of; possible reduction of imported material, drainage, lorry movements and access. There seemed to be the beginnings of awareness of the financial dynamics of the landfill business that can be built on next time. NGO comments were fairly well verbally covered by the planners. Regrettably there was no evidence of concern about upholding the policies protecting SMIs. Thanks to everyone who made very useful written inputs. These will now need to be repeated of course when the application is reconsidered. Getting key issues across to all councillors whether or not they sit on the committee is vital. We need at least one councillor to volunteer to support our case next time [and on the even bigger and even more contentious HX CP and Whalebone Lane applications.

Phil also issued the following Press Release:

CPRE statement to LB Havering Regulatory Services Committee on 03.04.2008
Maylands Golf Course planning application
Phil Butler said:
Important matters are not fully covered in the officer’s report.
The rules covering landfill licence exemptions are subject to review following parliamentary questions by Andrew Rosindell about damaging operations like this one.
PPS 10 advises local authorities to question applicants thoroughly about the purpose and need for large land-raising applications because income from importing landfill plus landfill tax exemption, not landscaping, turns out to be the primary purpose of far too many applications of this kind.
This application should follow PPS17 and Royal and
Ancient guidelines on the conservation of existing ecology and landscape. This means it should be based on the repositioning of existing soils to minimise imported material but this option has not been considered.
300,000 cubic metres of landfill is more than twice the agreed quantity for Risebridge golf course. It won’t be all topsoil but mainly construction waste including non-inert metal and plastic,
The Risebridge experience clearly shows that Environment Agency monitoring will not control the quantity, quality and planned placement of imported material, or protect the wildlife. It’s the Council that has to deal with costly enforcement and legal action.
This site of metropolitan importance for wildlife and landscape is protected from damage by policies in the London Plan, PPG2, PPS10, PPS17 and DC58. Massive damage by massive landfilling should not be allowed.
Please uphold the policies and refuse the application. Thankyou

On his way to the top! Andrew Rosindell scales a bund at Risebridge