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2565-01 / Proposed Extension to the Allington IWMF PEIR Main Report July 2020 11-i
CHAPTER 11.0 ECOLOGY AND NATURE CONSERVATION
11.0 ECOLOGY AND NATURE CONSERVATION ..................................................... 11-1
11.1 Introduction .......................................................................................................... 11-1
11.2 Methodology ........................................................................................................ 11-2
11.3 Baseline ............................................................................................................. 11-17
11.4 Assessment of Effects ....................................................................................... 11-29
11.5 Cumulative Effects ............................................................................................. 11-42
11.6 Mitigation ........................................................................................................... 11-45
11.7 Residual Effects and Conclusions ...................................................................... 11-46
APPENDICES (bound separately in Volume 3)
Appendix 11-1 ..................................................................... Preliminary Ecological Appraisal
Appendix 11-2 .......... Extended Phase 1 / UKHC Habitat Survey, and calculation of baseline
............................ ecological value in accordance with Biodiversity Metric 2.0;
Appendix 11-3 ......................................................................................... Invertebrate Survey
Appendix 11-4 ........................................................................ Reptile and Amphibian Survey
Appendix 11-5 ...................................................................................... Breeding Bird Survey
Appendix 11-6 ...................................................................................................... Bat Survey
Appendix 11-6 ............................ Assessment of Sensitivity of North Downs Woodlands SAC
Appendix 11-8 ..................................................................................................... HRA Report
Appendix 11-9 ................................................................................Stangate Baseline Report
Appendix 11-10 ........................ Stangate Ecological Enhancement Scheme - East and West
Appendix 11-11 ........................................ Stangate Ecological Enhancement Scheme - East
Appendix 11-12 ................................................................ Biodiversity Metric without HWRC
Appendix 11-13: .......................................... Biodiversity Metric 2.0 Calculation – with HWRC
Please note that a full list of acronyms is provided the contents to this PEIR and should be
referred to when reading this Chapter.
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11.0 ECOLOGY AND NATURE CONSERVATION
11.1 Introduction
Structure of Chapter
11.1.1 This Chapter considers the impacts of the Proposed Extension on flora and fauna,
in accordance with the requirements of the Infrastructure Planning (Environmental
Impact Assessment) Regulations 2017.
11.1.2 The legislative and policy context against which the Proposed Extension should be
considered is summarised below, followed by a summary of the consultation
responses that have been received prior to the preparation of this Chapter,
together with details of how they have been taken into consideration in the
preparation of this assessment. This is then followed by confirmation of the
reasonable worst-case parameters that have been used in the assessment of
effects. The Chapter then describes the background, scope and methodology of
the assessment; this is then followed by a description of habitats and fauna present
on the Site, including the occurrence of legally protected species, and invasive
alien species. The nature conservation interest of the Site and its surroundings is
then evaluated; any significant impacts upon interest features are assessed,
including indirect impacts on designated sites in the wider vicinity of the Proposed
Extension. Proposed mitigation and ecological enhancement measures are
outlined, with a summary of residual impacts following the implementation of
mitigation measures.
11.1.3 The Chapter is informed by the following ecological surveys and reports, which are
presented as Technical Appendices:
• Preliminary Ecological Appraisal (PEA), incorporating a data search to provide
contextual information (Appendix 11-1);
• Extended Phase 1 / UKHC Habitat Survey, and calculation of baseline
ecological value in accordance with Natural England’s Biodiversity Metric 2.0
(BM 2.0) (Appendix 11-2);
• Invertebrate Survey (Appendix 11-3);
• Reptile and Amphibian Survey (Appendix 11-4);
• Breeding Bird Survey (Appendix 11-5);
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• Bat Survey (Appendix 11-6);
• Assessment of sensitivity of North Downs Woodlands SAC (Appendix 11-7);
• HRA Report (Appendix 11-8);
• Stangate Baseline Report (Appendix 11-9);
• Stangate Ecological Enhancement Scheme – East and West (Appendix 11-
10);
• Stangate Ecological Enhancement Scheme - East (Appendix 11-11);
• Biodiversity Metric without HWRC (Appendix 11-12); and
• Biodiversity Metric 2.0 Calculation – with HWRC (Appendix 11-13).
Competence
11.1.4 This Chapter has been compiled by Kevin Barry Honour MSc MCIEEM, a Director
of Argus Ecology Ltd., who has over 27 years’ experience of ecological impact
assessment; this includes extensive experience of the assessment of energy
recovery and related facilities, including the ecological assessment of air quality
effects.
11.1.5 Argus Ecology Ltd. are a specialist ecological consultancy, established in 1991.
Employee expertise includes protected species survey and mitigation, habitat and
ornithological surveys. All ecological staff are Full Members of the Chartered
Institute of Ecology and Environmental Management (CIEEM).
11.2 Legislation, Policy and Guidance
European Conservation Legislation, Policy and Guidance
11.2.1 The Habitats Directive (92/43/EEC) provides for the establishment of protected
sites (Special Areas of Conservation (SAC)) as part of the Natura 2000 network, to
protect habitats and species of Community interest listed on Annex I and Annex II
respectively of the Directive. It also provides for strict protection of species of
Community interest listed in Annex IV(a) of the Directive (‘European Protected
Species’).
11.2.2 Article 6 (3) of the Habitats Directive provides for the protection of designated sites,
stating: “Any plan or project not directly connected with or necessary to the
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management of the site but likely to have a significant effect thereon, either
individually or in combination with other plans or projects, shall be subject to
appropriate assessment of its implications for the site in view of the site’s
conservation objectives. In the light of the conclusions of the assessment of the
implications for the site and subject to the provisions of paragraph 4, the competent
national authorities shall agree to the plan or project only after having ascertained
that it will not adversely affect the integrity of the site concerned and, if appropriate,
after having obtained the opinion of the general public.”
11.2.3 Article 12 of the Habitats Directive sets out the system of strict protection which
Member States are required to adopt for animal species listed on Annex IV(a).
Article 12(1)(b) prohibits: “deliberate disturbance of these species, particularly
during the period of breeding, rearing, hibernation and migration’; Article 12(1)(d)
prohibits ‘deterioration or destruction of breeding sites or resting places.”
11.2.4 Council Directive 2009/147/EC on the conservation of wild birds (the ‘Birds
Directive’) provides for the conservation and management of all wild bird species
naturally occurring in the European Union, their nests, eggs and habitats.
11.2.5 Article 2 of the Birds Directive provides for the maintenance of populations of wild
birds: “at a level which corresponds in particular to ecological, scientific and cultural
requirements, while taking account of economic and recreational requirements, or
to adapt the population of these species to that level.” Article 4(4) requires that
(outside of protected sites) member states: “should strive to avoid pollution or
deterioration of habitats.”
11.2.6 The Habitats and Birds Directives are implemented in England and Wales by the
Conservation of Habitats and Species Regulations 2017 (the ‘Habitats
Regulations’). Regulation 10 implements provisions in Article 4 of the Birds
Directive, requiring competent authorities to: “use all reasonable endeavours” to
“avoid any pollution or deterioration of habitats of wild birds.” Regulation 42
implements the system of strict protection applied to European Protected Species.
Regulation 63 addresses the requirements to undertake an appropriate
assessment of plans or projects which have a likely significant effect on European
conservation sites.
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11.2.7 The Conservation of Habitats and Species (Amendment) (EU Exit) Regulations
2019 were designed to enable the UK to continue to meet its international
commitments, such as the Berne and Bonn conventions, and ensure that
regulations transposing the EU Habitats and Wild Birds Directives are operable, by
making amendments to the Habitats Regulations and other instruments which
transpose the Directives into UK law. The purpose of the Directive was not to
introduce any changes to the level of site protection derived from EU law, or to
change the assessment process.
National Conservation Legislation, Policy and Guidance
11.2.8 The Wildlife and Countryside Act 1981 (as amended) provides the principal
legislation for designation of nationally important conservation sites and the
protection of species. Section 28 provides powers for the designation of Sites of
Special Scientific Interest (SSSIs), while subsequent amendments, including those
enacted by the Countryside and Rights of Way Act 2000 and the Natural
Environment and Rural Communities Act 2006, strengthen the protection of SSSIs.
11.2.9 Section 40 of the Natural Environment and Rural Communities Act 2006 (‘NERC
Act’) sets out the duty of public authorities to conserve biodiversity in the exercise
of their functions, through “having regard, so far as is consistent with the proper
exercise of their duties, to the purpose of conserving biodiversity”. Biodiversity
conservation is further defined as including the restoration or enhancement of a
population or habitat. Section 41 of the NERC Act requires the Secretary of State to
publish a list of species and habitats which are of principal importance for the
conservation of biodiversity in England (i.e. ‘priority species and habitats’), and to
take and promote the taking of “reasonably practicable” steps to further their
conservation.
11.2.10 As outlined in Chapter 3, the relevant NPS’s provide the primary basis for decisions
by the SoS on development consent applications for NSIPs. The requirements of
the NPS’s of most relevance to this Chapter of the PEIR are summarised below:
NPS EN-1, Overarching National Policy Statement for Energy
11.2.11 Section 5.3 Biodiversity and Geological Conservation states that: “Where the
development is subject to EIA the applicant should ensure that the ES
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[Environmental Statement] clearly sets out any effects on internationally, nationally
and locally designated sites of ecological or geological conservation importance, on
protected species and on habitats and other species identified as being of principal
importance for the conservation of biodiversity… The applicant should show how
the project has taken advantage of opportunities to conserve and enhance
biodiversity and geological conservation interests.”
11.2.12 The NPS document goes on to reiterate the Government’s biodiversity strategy
with its aim to ensure:
• “a halting, and if possible, a reversal, of declines in priority habitats and
species, with wild species and habitats as part of healthy, functioning
ecosystems; and
• the general acceptance of biodiversity’s essential role in enhancing the quality
of life, with its conservation becoming a natural consideration in all relevant
public, private and nongovernmental decisions and policies.”
11.2.13 The policy continues to say: “…development should aim to avoid significant harm
to biodiversity and geological conservation interests, including through mitigation
and consideration of reasonable alternatives… where significant harm cannot be
avoided, then appropriate compensation measures should be sought.”
11.2.14 Section 5.3.15 of the NPS EN-1 also refers to biodiversity within developments
stating: “Development proposals provide many opportunities for building-in
beneficial biodiversity or geological features as part of good design.”
11.2.15 With regards to Mitigation, section 5.3.18 states: “The applicant should include
appropriate mitigation measures as an integral part of the proposed development.
In particular, the applicant should demonstrate that:
• during construction, they will seek to ensure that activities will be confined to
the minimum areas required for the works;
• during construction and operation best practice will be followed to ensure that
risk of disturbance or damage to species or habitats is minimised, including as
a consequence of transport access arrangements;
• habitats will, where practicable, be restored after construction works have
finished; and
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• opportunities will be taken to enhance existing habitats and, where practicable,
to create new habitats of value within the site landscaping proposals.”
EN-3, Overarching National Policy Statement for Renewable Energy Infrastructure
11.2.16 Paragraph 2.4.2 of NPS EN-3 describes the criteria for good design for energy
infrastructure. It states that: “Proposals for renewable energy infrastructure should
demonstrate good design in respect of landscape and visual amenity, and in the
design of the project to mitigate impacts such as noise and effects on ecology.”
National Planning Policy Framework
11.2.17 The National Planning Policy Framework (NPPF) for England sets out a number of
policies for conserving and enhancing the natural environment in Section 15
(paragraphs 170-183). Of particular relevance in the present context are the
following policies:
• 170: includes reference to the need to minimise risks to biodiversity and
promote net gains for biodiversity where possible, including establishing
coherent ecological networks (170 (d));
• 171: site protection should be commensurate with their status, and take a
strategic approach to maintaining and enhancing habitat networks;
• 175: addresses the conservation and enhancement of biodiversity in planning
applications;
• 177: the presumption in favour of sustainable development does not apply
when an Appropriate Assessment under the Habitats Regulations has
determined there will be an adverse effect on the integrity of a habitats site; and
• 180: includes policies to consider effects of pollution, including light pollution,
on the natural environment.
11.2.18 At the time of writing, the Environment Bill is currently passing through Parliament.
Amongst its most relevant provisions includes a strengthening of the duties under
Section 40 of the Natural Environment and Rural Communities Act 2006 to require
public authorities to enhance as well as conserve biodiversity. It will also introduce
a mandatory requirement for biodiversity net gain into the planning system1.
1 This currently only applies to planning applications determined under the Town and Country Planning Act 1990 and not DCO applications determined under the Planning Act 2008. However, it is clearly the direction of travel the Government are keen to promote for all development projects.
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11.3 Consultation
11.3.1 The proposed scope of this assessment was set out in the Scoping Report
submitted to the PINS in November 2019 (see Appendix 2.1). Scoping Opinion
was received from PINS in December 2019 as adopted by the SoS which
contained responses from Natural England (NE) and KCC.
11.3.2 Table 11-1 sets out a record of the scoping responses and consultations that have
been undertaken with PINS, officers at KCC and NE and explains how they have
been taken into account in the PEIR.
Table 11-1: Scoping Response – Ecological matters
Scoping Opinion issue Response
Planning Inspectorate comments (with ID from Table 4.4 of Aspect Based Scoping Tables)
ID 4.4.1: Scoping Request sought to scope out surveys for Water Vole, GCN and white-clawed crayfish. The Inspectorate considers that the ES should include an assessment of these matters where a likely significant effect will occur. The Applicant should make effort to agree the approach to the assessment with the relevant consultation bodies. Any agreements reached with the consultation bodies in relation to the assessment of these matters should be presented and evidenced in the ES
Water vole presence is assessed in protected species walkover survey (Appendix 11-2); GCN by eDNA sampling and a Habitat Suitability Assessment (Appendix 11-4). Potential effects on white-clawed crayfish have been considered following receipt of biological records and with reference to potential effects on water environment (Appendix 11-1; this Chapter). KCC were satisfied with the scope of surveys proposed (see below) and further consultations held with NE under their DAS have not raised any further issues with ecological scope
ID 4.4.2: In the absence of sufficient information to the contrary PINS state that effects of lighting on ecological receptors should be appropriately assessed
Presence of light-sensitive ecological receptors assessed through bat survey results and consideration of surrounding habitats. PEIR cross-referenced with Lighting Assessment (Appendix 5-2)
ID 4.4.3: PINS do not agree that the construction phase effects from increased emissions and deposition to ecological receptors can be scoped out.
The methodology for assessing construction phase effects on sensitive ecological receptors is described in Appendix 13-2 Based on the fact that no sensitive ecological receptors have been identified within 50m of the Proposed Extension (see Table 11.3 below) construction phase effects can be scoped out from detailed ecological assessment.
ID 4.4.4: In addition to local, national and international nature conservation designations, assessment should consider SINCs as well as local BAP.
The assessment considers locally designated sites (see Appendix 11-1) and BAP priority habitats and species (see Appendix 11-2).
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Scoping Opinion issue Response
ID 4.4.5: Details of further compensatory habitat needs to be provided to offset loss
The assessment has used the beta version of Biodiversity Metric 2.0 to quantify habitat loss, in addition to a qualitative assessment with reference to priority habitats and other features. The landscape scheme, coupled with avoidance and restoration of some higher value component features, has been designed to achieve partial compensation with a non-significant residual effect.
ID 4.4.6: All ecological survey work relied upon to inform the ecological assessment and the results, should be included either within the ES or appended to the ES. To aid the readers understanding, figures that depict survey locations, habitat coverage, and the locations of protected species, potential habitats should also be included within or appended to the ES
Supporting ecological survey reports are provided in Appendices 11-3 to 11-6, including appropriate figures.
ID 4.4.7: The ES should include details of all GCN surveys relied upon, either as part of the ecology chapter or as appendices. The Applicant should make effort to agree with relevant consultation bodies (notably Natural England) whether further GCN surveys are required
A Reptile and Amphibian survey report is provided (Appendix 11-4) which includes details of the GCN habitat suitability assessment, eDNA sampling, and the results of refugia surveys.
ID 4.4.8: Cumulative assessment. The Inspectorate recommends that guidance used for this assessment should be clearly set out and how it has been applied in the assessment of cumulative ecological effects and air quality effects on ecological receptors
Cumulative air quality effects are considered in Chapter 13 and Appendix 13-3. The HRA Report (Appendix 11-8) takes into account cumulative air quality effects on North Downs Woodlands SAC, following further consultation and advice from NE and KCC.
ID 4.4.9: List of baseline monitoring surveys omits reference to botanical, full ornithological, terrestrial, and marine invertebrates, and terrestrial and marine mammal surveys. Applicant should consider the need for these surveys.
Botanical, ornithological, terrestrial, and aquatic invertebrate surveys have been undertaken; protected species risk assessment incorporates a mammal survey (see Appendices 11-2 to 11-6). Marine fauna scoped out due to avoidance of risk to Medway MCZ through measures set out Chapter 12 (Water Quality and Drainage).
ID 4.4.10: The Scoping Report includes an intention for the ES to present ecological enhancement measures, if required, as part of the Proposed Development. The ES should clearly distinguish between the measures that are presented as mitigation in response to identified significant effects, and enhancement measures which the Applicant identifies as being in addition to the necessary mitigation measures. Mitigation measures, including any plans, should be sufficiently developed and secured through the DCO or other legal mechanism
The PEIR presents a series of ecological mitigation measures which are integrated into the construction methods and landscape design of the Proposed Extension. In addition, enhancement measures are proposed with respect to achieving BM 2.0 offsetting targets with a mixture of on-site and appropriately secured off-site mitigation (see Appendices 11-9 – 11-13)
ID 4.4.11: ES should state effects during construction and operation on the River Medway
The PEIR cross references the ecological impact assessment to the Water Quality and Drainage assessment (Chapter 12) in order to assess effects on River Medway / Medway Estuary.
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Scoping Opinion issue Response
Kent County Council comments (ecology)
KCC has reviewed the ecological information submitted within the Scoping Report and is satisfied with the range of surveys which are been carried out. All of this material must be included within the Environmental Statement (ES) when submitted
The PEIR includes reports of all ecological surveys undertaken as Technical Appendices to this document
The scoping report states that the following surveys/assessments are being undertaken: • Extended Phase 1 Habitat / Phase 2 Habitat Survey; • Environmental DNA (eDNA) sampling for Great Crested Newt (GCN) presence; • Breeding bird survey; • Freshwater invertebrate sampling;
• Butterfly/dragonfly transect; • Bat activity surveys/automated monitoring; • Reptile surveys; and • Protected species risk assessment.
All surveys proposed in the Scoping Report have been undertaken and are included as Technical Appendices.
The County Council is satisfied with the range of ecological surveys that are being carried out and advises that the results, as well as necessary mitigation strategies, are submitted with any planning application
Mitigation / compensation strategies are included in the PEIR where necessary.
It is advised that any potential impact of the proposed extension on features of nature conservation interest, as well as opportunities for habitat creation/ enhancement, will need to be included within the ES. Given that an area of botanically interesting grassland will be lost for the proposed development, details of the proposed compensation site (that will be surveyed prior to the production of an ES) must be submitted with the Development Consent Order (DCO) application.
Areas of higher quality grassland within the Site have been identified and mapped. Compensatory works including on-site soil transfer to the new landscape, will be included with the DCO application. Details of off-site compensatory habitat creation are included in the PEIR.
There are no designated sites for ecology in close enough proximity to incur direct impacts from the construction phase. However, there is the potential for effects to occur within the North Downs Woodlands Special Area of Conservation (SAC) to the north, should there be a change in air quality once the development is operational
The sensitivity of North Downs Woodlands SAC has been assessed by reference to Air Pollution Information Service (APIS) guidance, together with a site visit. Impacts have been modelled during the Stack Height Assessment process, and mitigation measures incorporated in the Project design to avoid exceedance of screening thresholds
The Scoping Report states that an air quality survey will be undertaken to assess the potential impact on the SAC. This information must be included within the ES, and the Environment Agency and Natural England should be consulted.
The PEIR includes an ecological interpretation of the Emissions Modelling Assessment, which addresses potential impacts to the SAC.
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Scoping Opinion issue Response
Natural England Comments
Natural England advises that the potential impact of the proposed extension upon features of nature conservation interest and opportunities for habitat creation/ enhancement should be included within this assessment in accordance with appropriate guidance on such matters. Guidelines for Ecological Impact Assessment (EcIA) have been developed by the Chartered Institute of Ecology and Environmental Management (CIEEM) and are available on their website
The assessment has been undertaken with reference to and in accordance with CIEEM guidance.
The ES should thoroughly assess the potential for the proposal to affect designated sites. European sites (e.g. designated Special Areas of Conservation and Special Protection Areas) fall within the scope of the Conservation of Habitats and Species Regulations 2017 (as amended). In addition, paragraph 176 of the National Planning Policy Framework requires that potential Special Protection Areas, possible Special Areas of Conservation, listed or proposed Ramsar sites, and any site identified as being necessary to compensate for adverse impacts on classified, potential, or possible SPAs, SACs and Ramsar sites be treated in the same way as classified sites
The assessment includes consideration of effects on all European sites within 10km of the Project
Under Regulation 63 of the Conservation of Habitats and Species Regulations 2017 (as amended) an appropriate assessment needs to be undertaken in respect of any plan or project which is (a) likely to have a significant effect on a European site (either alone or in combination with other plans or projects) and (b) not directly connected with or necessary to the management of the site
An HRA Report has been prepared to assess the effects of the Project on North Downs Woodlands SAC, including consideration of in-combination effects. Natural England have provided advice through their Discretionary Advice Service (DAS) on the assessment of effects on the SAC
The EIA will need to consider any impacts upon local wildlife and geological sites.
Details of local sites have been obtained from KMBRC and any impacts on them are considered have been assessed
The ES should assess the impact of all phases of the proposal on protected species (including, for example, great crested newts, reptiles, birds, water voles, badgers and bats). The area likely to be affected by the proposal should be thoroughly surveyed by competent ecologists at appropriate times of year for relevant species and the survey results, impact assessments and appropriate accompanying mitigation strategies included as part of the ES
A programme of protected species surveys has been undertaken at optimum times of year; assessment of impacts undertaken and mitigation strategies developed where appropriate
The ES should thoroughly assess the impact of the proposals on habitats and/or species listed as ‘Habitats and Species of Principal Importance’ within the England Biodiversity List
The assessment has included consideration of effects on habitats or species of principle importance for biodiversity conservation.
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Additional consultation
11.3.3 Further consultation has been carried out with NE and KCC to discuss the scope
and results of ecological and air quality assessments.
11.3.4 Two videoconferencing meetings have been held with NE, including a member of
their local team and an air quality specialist. The primary purpose of these
consultations was to present the results of the air quality assessment as they
related to North Downs Woodlands Special Area of Conservation (SAC), take
advice on cumulative assessment, and confirm the acceptability of the approach
taken. The matters agreed with NE have been taken into account in the preparation
of this PEIR chapter and the associated appendices. It is the intention of the
Applicant to secure a formal Statement of Common Ground on these matters in
due course.
11.3.5 A videoconference meeting was held with KCC ecological and planning staff to
discuss the approach to biodiversity offsetting, including the off-site enhancement
proposals. The results of the initial Biodiversity Metric 2.0 spreadsheet calculations
were shared, and feedback was provided to them on the results of ecological
survey works.
11.4 Parameters Used for Assessment
11.4.1 The overall approach to the use of the Rochdale Envelope and the Parameters that
have been assumed for the assessment of likely significant environmental effects
arising from the Proposed Extension is set out in Chapter 5.0 of this PEIR. Those
parameters have been used, where relevant, to inform the assessments in each
topic specific chapter of this PEIR.
11.4.2 In order to provide a robust assessment, each topic specific chapter has been
prepared on a reasonable worst-case scenario for that given topic. This being the
worst-case scenario that could reasonably be expected to occur within each of the
parameters set. The reasonable worst-case scenario for each topic differs
depending upon the particular assessments being undertaken. However, all
assessments have been undertaken within the broadest reasonable parameters, to
ensure the assessment is precautionary in its approach.
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11.4.3 With respect to the ecological assessment, the reasonable worst-case scenario for
the Proposed Extension has been based upon the following assumptions:
• The permanent loss of habitat within the areas of built development /
impermeable areas on the Site - based upon the maximum extent of such
development on the works schedule. This excludes the temporary laydown area
in the construction phase which is to be included in the final landscape scheme.
• The temporary loss of all existing habitat within the areas identified on the
earthworks plan (see figures 5.8a – 5.8i).
• The retention of existing habitat on the areas unaffected by the proposed
earthworks.
• The ecological effects arising from other technical issues (for example, changes
in air quality, noise or hydrology) have also been taken into consideration and
the effects have been assessed based on outcome of the modelling undertaken
within each of the assessments. The assessments have also been prepared on
the basis of reasonable worst-case parameters.
11.4.4 The preferred route of the electrical connection from the Proposed Extension is
along the A20 utilising the existing carriageway and footpath. However, if that route
is not deemed feasible, use of the grid route for the Existing Station has also been
considered. The latter route does have greater potential to impact upon natural and
semi-natural habitat which would be disturbed during its construction. Whilst only
one route would be selected, the reasonable worst-case assumes that it could be
either and both options have been assessed.
11.5 Assessment Methodology
Assessment Methodology
11.5.1 Impact assessment methodology follows current Chartered Institute of Ecology and
Environmental Management guidelines (CIEEM, 20162, CIEEM, 20183). This is
based on:
• the identification of valued ecological resources;
• the characterisation of potential impacts as a consequence of the development;
2 CIEEM (2016). Guidelines for Ecological Impact Assessment in the UK and Ireland. Terrestrial, Freshwater and Coastal. Second Edition, January 2016 3 CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland. Terrestrial, Freshwater, Coastal and Marine. Version 1.1., September 2019.
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• an assessment of the likelihood of occurrence, duration, extent, magnitude,
frequency and reversibility; and
• an assessment of impact significance.
11.5.2 In order to assess the effects of a development on flora and fauna, it is first
necessary to identify the nature and geographical extent of likely impacts and
identify the component ecological interest features of the receiving environment.
This process identifies important ecological features which should be subject to
further assessment. These are features which are sufficiently important and
potentially affected by the project; CIEEM guidelines state “it is not necessary to
carry out detailed assessment of features that are sufficiently widespread,
unthreatened and resilient to project impacts and will remain viable and
sustainable.”
11.5.3 The identification of ecological effects also takes incorporated mitigation measures
into account. These comprise already committed measures, which the decision
maker can be confident would be included as part of the Proposed Extension; they
are described at the start of section 11.7 below.
11.5.4 The valuation of habitats and quantification of gains and losses as a consequence
of the Proposed Extension has been undertaken in accordance with the guidance
set out in Biodiversity Metric 2.04.
Scope of Assessment
Study Area
11.5.5 The study area used for identification of sensitive ecological receptors, survey and
assessment of effects has been undertaken in accordance with CIEEM guidance5.
This states that the scope and area that should be considered for study should be
based on the professional judgment of the ecologist, taking into account factors
such as the characteristics of the site subject to appraisal, its surroundings and the
nature of the changes proposed. For the purposes of assessing air quality impacts,
4 Crosher, I.A., Gold, S.B., Heaver, M.D., Heydon, M.A., Moore, L.D., Panks, S.A., Scott, S.C., Stone, D.A. & White, N.A. (2019). The Biodiversity Metric 2.0: auditing and accounting for biodiversity value. User guide (Beta Version, July 2019). Natural England Joint Publication JP029 5 CIEEM (2013). Guidelines for Preliminary Ecological Appraisal. Technical Guidance Series.
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screening distances determined by Environment Agency guidance and employed in
the Air Quality assessment (Chapter 13.0) have been used.
11.5.6 For the purposes of collating protected and priority species data, a 2km distance
from the Site boundary provides an appropriate study area, providing contextual
data on species which may occur on Site. This is also appropriate for UK-
designated statutory conservation sites, and non-statutory locally designated sites.
11.5.7 For air quality assessment purposes, a 2km radius from the emission source is
appropriate for assessing effects on nationally and locally important conservation
sites and ancient woodlands. For European (Natura 2000) sites, a 10km radius
from the emission source is used. With respect to construction phase dust
emissions, all sites within 50m of the Site boundary are considered.
11.5.8 With respect to ecological surveys, the study area is defined by the Site boundary
shown in Appendix 11-2, Figure A11.2.1. As the Site is bounded by major roads
and built development, it was not appropriate to include a wider buffer zone for
most surveys. The exception is bird surveys, where efforts were made to record
birds utilising land or airspace within 200m of the Site boundary.
Ecological Scoping Process
11.5.9 An initial desktop study was carried out to assess the ecological sensitivity of the
Site and its context, including the presence of statutory designated conservation
sites which could be regarded as sensitive receptors for air quality assessment.
11.5.10 A data search was commissioned from KMBRC for non-statutory designated sites,
protected and priority species records within a 3km radius of a point within the area
of the Proposed Extension. This captured all records within 2km of the Site
boundary.
11.5.11 In order to undertake ecological survey works during the optimum season, bird
survey work and great crested newt (GCN) eDNA sampling / habitat suitability
assessment commenced in spring 2019, in advance of the submission of the formal
Scoping Report.
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11.5.12 Based on the results of the initial site surveys and data searches, a programme of
ecological survey work was initiated and undertaken through the 2019 survey
season.
11.5.13 The following ecological surveys were undertaken; full details of methodology,
timings and personnel are provided in the relevant Technical Appendices:
• Extended Phase 1 Habitat Survey / UK Habitat Classification Survey;
• Great crested newt eDNA sampling and habitat suitability assessment;
• Aquatic and terrestrial invertebrate survey;
• Reptile and Amphibian survey;
• Breeding bird survey;
• Protected species walkover survey; and
• Bat activity surveys and assessment of roost potential.
11.5.14 All surveys were undertaken by appropriately qualified ecologists, during the
optimum field season in 2019.
11.5.15 In addition to ecological site surveys, North Downs Woodlands SAC was visited to
obtain further information on its potential vulnerability to air quality effects. Two
closed landfill sites were also visited in order to assess their potential to provide off-
site mitigation as part of the biodiversity offsetting process.
11.5.16 Information obtained from the data searches, site visit and initial field survey results
were summarised in the Ecology section of the Scoping Report submitted to PINS.
The outcome of the scoping exercise and the scoping responses received from
PINS, KCC and other statutory consultees, and how they have been taken into
account in this PEIR, is set out Section 11.3 above.
Assessment of Significance / Assessment Criteria
11.5.17 In the CIEEM (2018) guidelines a significant effect in ecological terms is defined as
an effect that: “either supports or undermines biodiversity conservation objectives
for important ecological features or for biodiversity in general.” In EIA terms, this is
an effect that is sufficiently important to require assessment and reporting so that
the decision maker is adequately informed of the environmental consequences of
permitting a project.
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11.5.18 In common with the approach taken elsewhere in this PEIR, CIEEM guidance does
not define particular levels of significance. However, a geographic scale at which
the effect is significant is applied where appropriate, in order to determine a
proportionate response in developing mitigation measures and help inform the
decision-making response to any residual effects.
11.5.19 Any significant ecological effects are subject, wherever feasible, to additional
mitigation measures, with the aim of avoidance, reduction or compensation. The
significance of residual effects is then re-assessed.
Assessment of air quality effects
11.5.20 The assessment of air quality effects on natural habitats has been undertaken as
an iterative process in collaboration with the Stack Height and Emissions Modelling
Assessments reported in Chapter 13.0 of this PEIR. This was undertaken in
accordance with IAQM (2019) guidance with regard to the respective roles of air
quality specialists and ecologists.
11.5.21 In accordance with IAQM guidance, air quality impacts on sensitive ecological
receptors in excess of screening thresholds would be subject to further ecological
assessment, normally presented in a Technical Appendix. In the case of the
Proposed Extension, incorporated mitigation measures have reduced the predicted
effects below screening thresholds, obviating the need for detailed ecological
interpretation. However, in accordance with case law in respect of incorporated
mitigation, a Habitats Regulations Assessment (HRA) Report (Appendix 11-8) has
been compiled, which addresses the issue of air quality effects on European
designated sites. Appendix 11-7 also incorporates the results of a survey of North
Downs Woodlands SAC, undertaken to improve the authors understanding of the
site’s condition and sensitivity to potential air quality effects.
Limitations
11.5.22 The surveys described in Appendices 11-1 – 11-7 were undertaken at appropriate
seasons for the relevant taxa and did not report any constraints which may have
affected the validity of the results. As with any ecological surveys, the use of a site
by fauna and the development of vegetation may change over time, sometimes
over short timescales.
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11.6 Baseline
Baseline Ecological Data
11.6.1 The following section summarises baseline ecological data relating to the Site and
its surroundings, which are set out in more detail in the Technical Appendices. See
Appendix 11-1 (PEA) for more details of the data search, including statutory and
locally designated sites, and protected and priority species recorded within a 2km
radius of the Proposed Extension. Appendix 11-2 provides further details of
habitats present on Site, and a valuation of baseline habitats in accordance with
Biodiversity Metric 2.0 and Appendices 11-3 – 11-7 provide more details of faunal
survey results.
Site Context
Statutory Designated Sites
11.6.2 The location of Natura 2000 (European designated sites) within a 10km radius is
tabulated below. These include three Special Areas of Conservation (SAC). There
are no Special Protection Areas (SPA) or Ramsar Sites within the 10km search
radius.
Table 11.2: Natura 2000 Sites within 10km of Proposed Extension
Site Status Distance (to nearest point)
Qualifying Features
North Downs Woodlands
SAC 2.7km NE Beech woodland
Yew woodland
Calcareous grassland
Peter’s Pit SAC 5km NW Great crested newt
Queendown Warren SAC 9.6km NE Calcareous grassland
11.6.3 Further details of qualifying features are given in Appendix 11-1. Appendix 11-7
provides more details on site condition and conservation objectives with respect to
the North Downs Woodland SAC.
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UK Statutory Designated Sites
11.6.4 There are two Sites of Special Scientific Interest (SSSIs), one Local Nature
Reserve (LNR) and one Marine Conservation Zone (MCZ) within the 2km study
area.
Table 11.3: UK Statutory Designated sites within 2km
Site and Designation Location (nearest) Features of Interest
Allington Quarry SSSI 0.37km SE Geological
Aylesford Old Pit SSSI 1.8km NW Geological
Ditton Quarry LNR 2.1km SW Calcareous grassland and scrub
Medway MCZ 0.30km NE Marine / estuarine habitats and geomorphological
features
Tentacled lagoon-worm
Smelt
11.6.5 Sites designated for geological interest only are not considered further in terms of
the ecological assessment. Further details of Ditton Quarry LNR and Medway MCZ
are given in Appendix 11-1.
Non-statutory Designated Sites and Ancient Woodlands
11.6.6 Information on non-statutory designated sites within 2km of the Proposed
Extension has been obtained from KMBRC; ancient woodland sites were identified
using Natural England’s Ancient Woodland Inventory v3.7 digital boundary data.
The following Local Wildlife Sites (LWS) and ancient semi-natural woodlands occur
within the search radius.
Table 11.4: Local Wildlife Sites and Ancient Woodlands within 2km
Site and Designation Location (nearest) Features of Interest
Lock Wood 0.7km NE Ancient woodland
Sandling Wood 1.8km E Ancient woodland
Dog Kennel Wood 1.4km SW Ancient woodland
Broke Wood 1.8km SW Ancient woodland
Fullingpits Wood 1.9km SW Ancient woodland
Aylesford Old Pit LWS 1.5km NW Calcareous grassland
Cuckoo Wood LWS 1.9km E Beech woodland
Blue Bell Hill Banks and Verges LWS 1.9km NE Calcareous grassland
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11.6.7 Further details of location and ecological interest features are given in Appendix
11-1; sensitivity to air quality effects is considered further in Appendix 11.7.
Protected Species Records
11.6.8 Records of European protected species obtained from KMBRC included great
crested newt (Triturus cristatus; GCN). The nearest records are over 1.1km from
the Site boundary at Aylesford to the NW, and M20 Junction 6 to the NE. They are
both separated from the Site by the River Medway and the major road network.
11.6.9 There was one otter (Lutra lutra) record from Maidstone, dating from 1987.
11.6.10 Bat records from the 2km search area included serotine (Eptesicus serotinus),
noctule (Nyctalus noctula), Leisler’s bat (Nyctalus leisleri), Daubenton’s bat (Myotis
daubentoni), Natterer’s bat (Myotis nattererii), whiskered bat (Myotis mystacinus),
common pipistrelle (Pipistrellus pipistrellus), soprano pipistrelle (Pipistrellus
pygmaeus) and brown long-eared bat (Plecotus auritus). The nearest known roost
location is approximately 220m south-west of the nearest Site boundary.
11.6.11 There were a number of records of UK protected species, protected under
Schedule 5 of the Wildlife and Countryside Act 1981. These included the three
commoner reptile species: grass snake (Natrix natrix), adder (Vipera berus) and
slow-worm (Anguis fragilis). One of the adder records was described as being from
Allington; this is only localised to a 1km grid reference, and dates from 1989.
11.6.12 Records of water vole (Arvicola amphibia) are mostly historic (20th century),
reflecting the population decline and range contraction of this species. More recent
records up to 2016 are located in the Aylesford area, north of the Site and
separated from it by the M20 and River Medway.
11.6.13 Records obtained from biological records centres cannot be considered as
comprehensive and were not relied upon to determine the scope of the survey
programme, without careful consideration of the likely risk of occurrence on or near
the Site.
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Priority Species Records
11.6.14 The KMBRC data returned a large number of priority species records in the 2km
study area, defined as those listed on Section 41 of the Natural Environment and
Rural Communities Act 2006. None of these were localised to the Site or
immediate surrounds. Further details are given in Appendix 11-1.
Other Species of Conservation Interest
11.6.15 A Nationally Scarce water beetle, Helophorus alternans, has a 2009 record from a
wetland in the western part of the Site.
Habitats and Vegetation
Local Ecological Context
11.6.16 The Site is located in the Medway Valley, around 300m from the River Medway at
its nearest (north-eastern) boundary.
11.6.17 The Site is relatively isolated from the surrounding landscape and other wildlife
habitats by industrial development, major road and rail infrastructure. It is bounded
to the east by the 20/20 Business Park; to the north by the M20; to the south by the
industrial estate access road and the Maidstone – London rail line; and to the
south-west and west by the A20 dual carriageway and A20 – M20 link road.
Habitats within Site
11.6.18 The Extended Phase 1 / NVC / UKHC habitat survey is described in detail in
Appendix 11-2 and illustrated in Figures A11.2.1 and A11.2.2 of that report. The
following provides a summary of the habitats and component species in the survey
area.
11.6.19 The eastern part of the survey area consists of the Existing Station and associated
infrastructure, including amenity grassland and an attenuation pond to the north
east, and flat area of bare aggregate, ephemeral – short perennial vegetation and
grassland with scattered scrub to the west. These features are enclosed within tall
bunds to the north, east and west, formed when the Existing Station was
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constructed. The bunds support a mix of scrub, young plantation woodland,
grassland, tall ruderal and ephemeral – short perennial habitats. Another bund to
the south is shorter in height, and densely wooded with immature plantation
woodland.
11.6.20 The western part of the survey area consists of a shallow bowl landform restored
from a former chalk quarry after landfilling, which retains a section of sparsely
vegetated exposed rock on the former quarry floor, adjoining a pond which acts as
a soakaway for drainage from the surrounding slopes and roof water from the
Existing Station. The quarry bowl mostly supports relatively species-poor neutral
grassland with scattered scrub, although there are areas of more diverse
grassland, particularly in the northern part of the bowl, including areas with locally
frequent pyramidal and bee orchids (Anacamptis pyramidalis, Ophrys apifera). The
upper parts of the bowl support patches of dense scrub, and there is an area of tall
ruderal vegetation on the northern slope.
Fauna
Freshwater Invertebrates
11.6.21 The existing pond was sampled using standard, timed methods, and samples
preserved for laboratory identification by a freshwater ecologist. The nationally
notable water beetle Helophorus alternans was not found in the sample. The
sample contained large numbers of bivalves, Diptera (true fly) larvae (including the
soldier-fly Stratiomys potamida) and water hog-louse (Asellus aquaticus). There
were also good numbers of Odonata (dragonfly and damselfly) larvae.
11.6.22 Diversity of the taxa identifiable to species level was low, with only 3 species of
Odonata, three Hemiptera (water bugs) and one Stratiomyidae (soldier-fly) species
recorded. No Priority Species, Nationally Scarce or notable species were recorded.
Terrestrial Invertebrates
11.6.23 18 species of butterfly were recorded; all were common and widespread species,
although three have experienced population declines and are listed as Section 41
Priority Species: wall (Lasimiomatta megera), small heath (Coenonympha
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pamphilus) and dingy skipper (Erynnis tages). One diurnal moth species recorded
in the surveys is also listed on Section 41: cinnabar moth (Tyria jacobaeae).
11.6.24 The invertebrate fauna is indicative of relatively new habitats. Most Lepidoptera
and Odonata were found in grassland habitats, with very few within the young
plantations or bunds that had been planted in the west of the Site or around the
bunds to the south and east. There were good numbers of Hymenoptera (bees and
wasps) within grassland habitats, but low species diversity.
Amphibians
11.6.25 Negative eDNA results have confirmed that neither the existing pond or the existing
surface water attenuation lagoon on the Site support great crested newts (GCN); in
addition, no amphibians were recorded under refugia in the course of reptile
surveys.
11.6.26 The M20 motorway and River Medway presents significant barriers between the
Site and the nearest known GCN breeding ponds over 1km to the north-east and
north-west.
Reptiles
11.6.27 No reptile species were found on the Site.
Breeding Birds
11.6.28 A total of 23 bird species were seen in the surveys, including 21 which were
thought to be at least possibly breeding on the Site. These were all common and
widespread species; species with the largest number of territories were blackbird
(Turdus merula: 20 territories), wren (Troglodytes troglodytes: 16) and blue tit
(Cyanistes caeruleus: 16).
11.6.29 Two Section 41 Priority Species were recorded; dunnock (Prunella modularis: 8
territories) and linnet (Carduelis cannabina: 1).
11.6.30 One protected species listed in Schedule 1 of the Wildlife and Countryside Act
1981 was recorded. An adult and juvenile peregrine falcon (Falco peregrinus) were
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present on the emission stack of the Existing Station. Although tall industrial
structures provide suitable nesting sites for this species, they were not recorded on
Site until after the breeding season and were not believed to have bred there.
Bats
11.6.31 Seven species of bats were recorded in the transect and automated monitoring
surveys: common pipistrelle, soprano pipistrelle, Myotis sp., noctule, Leisler’s bat,
serotine and brown long-eared bat. With the proviso that the Myotis recordings
could not be identified to species, these are all species recorded in the 2km data
search.
11.6.32 Transect surveys revealed relatively low levels of bat activity across the Site with
only common pipistrelle, soprano pipistrelle and noctules being detected in any
numbers. The Anabat detectors which were effectively detecting in two parts of the
Site for 46 days (92 days of data in total) detected a wider range of species, but
numbers of passes were still relatively lower than would have been expected for
the habitat.
11.6.33 Transect surveys did not detect any ‘hotspot’ areas of higher activity. Before the
survey it was expected that the pond in the western part of the Site might be a
focus of bat foraging activity, but activity levels were not noticeably elevated above
surrounding habitats. This may be due to the fringing willow scrub and emergent
vegetation, with limited flight paths over open water habitat.
11.6.34 There were very few features on Site which could provide potential roosting
opportunities for bats, with most trees in the surrounding plantations too young to
develop roost features. A taller hybrid black poplar tree near the site perimeter was
subject to a more detailed ground-level inspection and emergence survey, but no
evidence of use by bats was evident.
Other Fauna
11.6.35 A protected species walkover survey did not detect any signs of use by badger
(Meles meles); there were no signs of water vole or otter activity associated with
wetland / settlement pond habitats on Site.
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Invasive Species
11.6.36 No non-native invasive species listed on Schedule 9 of the Wildlife and Countryside
Act 1981 were recorded on or near the Site.
Future Baseline
11.6.37 In the absence of the Proposed Extension, the buildings and activities associated
with the Existing Station would continue to operate in the eastern area of the Site.
Vegetation on the surrounding bunds would continue to mature. In the longer term
this would potentially provide more deadwood and crevice habitats suitable for bats
and other fauna, although this is dependent on future management.
11.6.38 The western part of the site, within the landfilled and restored former quarry, is
managed as a Nature Conservation Area under a Section 106 agreement. This is
due to be handed over to a management company, who are obliged to manage the
area in accordance with the Kent Biodiversity Action Plan, in order to achieve
ecological enhancement of the site.
11.6.39 Although the ecological assessment has concluded that it does not currently meet
Kent Local Wildlife Site selection criteria6, as habitats mature it is likely to acquire a
higher biodiversity interest.
11.6.40 However, increasing maturity of component habitats is not unequivocally positive;
species diversity may decline in grassland habitats if taller, more competitive
species such as false oat-grass (Arrhenatherum elatius) continue to increase in
abundance. Intermediate stages of woodland succession, where the canopy is at
scrub height, can support a higher breeding bird density than dense, even-aged
plantation woodland.
11.6.41 The future ecological baseline is clearly influenced by management, as
interventions such as mowing or grazing can serve to maintain grassland species
richness. However, the relative isolation of the Site from habitats in the surrounding
landscape will act as a brake on colonisation by less mobile flora and fauna and
may limit future species diversity.
6 Kent Wildlife Trust (2015). Local Wildlife Sites in Kent. Criteria for Selection and Delineation. Version 1.5, October 2015.
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mportant Ecological Features
Designated Sites
11.6.42 The European sites listed in Table 11.2 can be considered as ecological features
on an international scale of importance. Although none are within 2km of the Site,
they are particularly relevant with respect to the consideration of air quality impacts.
11.6.43 Ditton Quarry Local Nature Reserve (Table 11.3) can be considered as an
ecological feature of County-level importance.
11.6.44 The Local Wildlife Sites listed in Table 11.4 can be considered as ecological
features of County-level importance, designated in the context of quality standards
set across Kent by the Wildlife Trust and Kent Nature Partnership. All sites within
2km of the Site are relevant for consideration of air quality impacts; none are close
enough to be exposed to near-site effects such as noise, dust or human
disturbance.
11.6.45 Ancient woodland sites listed in Table 11.4 can be regarded as being of local to
County-level importance. In the context of EIA, because ancient woodland sites
cannot be restored or recreated in a realistic timescale, they are regarded as
‘critical natural capital’. The loss of ancient woodland cannot be effectively
mitigated by creation of new habitats.
Protected Species
11.6.46 In order to assess the level of value of protected species as important ecological
features, it is necessary to consider the following:
• the extent to which the Site contributes to the maintenance of their conservation
status in the wider area; and
• their level of legal protection, in order to address whether and how the
Proposed Extension could proceed in accordance with current legislation, and
assess whether any operations may require a Natural England disturbance
licence.
11.6.47 A total of seven European protected species have been recorded within the Site,
and one bird species with special protection under UK law.
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11.6.48 All bat species are protected through listing under Annex IVa of the EU Habitats
Directive, as implemented in England and Wales through Regulation 42 of the
Habitats Regulations 2017. Peregrine falcon has special protection through listing
in Schedule 1 of the Wildlife and Countryside Act 1981.
11.6.49 Although habitat quality is quite good for bats on the Site, foraging activity was
significantly lower than expected, most likely due to the proximity of major roads,
and the Site offers few opportunities for roosting. Bats can therefore be regarded
as being of no more than within-site importance as ecological interest features.
11.6.50 Peregrine falcon were only recorded after the end of the breeding season, with an
already-fledged juvenile and adult falcon recorded on the stack. Although the Site
was being used for resting and probably foraging, it cannot be regarded as being of
more than local importance for this species, as there was no evidence of
occupancy during the breeding season, and the Site represents only a small
proportion of likely home range.
11.6.51 All bird species are protected under the Wildlife and Countryside Act from
deliberate killing or injury, or destruction of nests, eggs or dependent young. The
Site’s avifauna cannot be regarded as being of more than within-site importance,
comprising moderate territory numbers of common and widespread species.
However, the legal protection afforded to birds means that mitigation measures will
be necessary to maintain legal compliance. The breeding bird assemblage is
therefore treated as an interest feature of local importance in the subsequent
impact assessment and mitigation proposals.
Priority Species
11.6.52 A number of Priority Species were recorded on the Site during the course of survey
work, including two breeding birds and four Lepidoptera species. Although subject
to significant past population declines, they remain common and widespread
species; there is no evidence of dependence on habitats within or adjoining the Site
and they cannot be regarded as important ecological features for the purposes of
the EIA.
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Priority Habitats
11.6.53 Appendix 11-2, Section 4.1 considered whether the Site supported any priority
habitats. Based on the extended Phase 1 & NVC surveys, the potential occurrence
of the following habitats was discussed:
• Lowland Mixed Deciduous Woodland;
• Lowland Meadows;
• Ponds;
• Reedbeds; and
• Open Mosaic Habitats on Previously Developed Land.
11.6.54 The evaluation concluded that only Lowland Mixed Deciduous Woodland priority
habitat occurred on Site, with other habitats not meeting the quality standards of
the published habitat descriptions.
11.6.55 Lowland Mixed Deciduous Woodland priority habitat is confined to a narrow strip
adjoining the M20. Appendix 11-2 explores how this is a small remnant of what
was previously a larger area of woodland which was fragmented by construction of
the M20. As a priority habitat, it can be considered an ecological interest feature of
local importance.
11.6.56 In the wider vicinity of the Site, the River Medway is an example of Rivers and
Streams Priority Habitat; it also supports a number of species of conservation
interest and contributes to the maintenance of ecological networks. It does not
have any statutory conservation designations upstream of the lower estuary but
can be regarded as an ecological feature of County level importance.
Other Important Ecological Features
11.6.57 Although not qualifying as a priority habitat, the relatively more species-rich areas
of grassland which support pyramidal orchid and bee orchid can be considered as
important ecological features of local importance. The complex of habitats
associated with the wetland area in the western part of the Site, including emergent
vegetation, aquatic vegetation, scrub and adjoining ephemeral – short perennial
vegetation can also be considered as a feature of local importance.
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Valuation of Baseline Habitats on Site
11.6.58 The value of baseline habitats has been calculated for the Site in accordance with
the BM 2.07. The basis for this calculation is set out in more detail in Appendix 11-
2. Current habitat baseline has been calculated at 239.15 biodiversity units. This
takes into account habitat condition, and encompasses the whole of the Site,
including vegetation around the Existing Station.
Summary of Important Ecological Features
11.6.59 Table 11.5 below summarises important ecological features which should be
considered in the assessment of ecological effects.
Table 11.5: Summary of Important Ecological Features
Feature Legal and policy status Level of importance
North Downs Woodlands SAC Articles 3 & 4, Habitats Directive; Habitats Regulations 2017; NPPF paras.
170-71 & 177.
International
Ditton Quarry LNR National Parks and Access to the Countryside Act 1949
County level
River Medway Water Framework Directive County level
Aylesford Old Pit LWS NPPF p. 171 County level
Cuckoo Wood LWS NPPF p. 171 County level
Blue Bell Hill Banks and Verges LWS
NPPF p. 171 County level
Lock Wood NPPF p. 171 Local
Sandling Wood NPPF p. 171 Local
Dog Kennel Wood NPPF p. 171 Local
Broke Wood NPPF p. 171 Local
Fullingpits Wood NPPF p. 171 Local
Lowland Mixed Deciduous Woodland
Section 41, Natural Environment & Rural Communities Act 2006
Local
Neutral grassland habitat (relatively species-rich areas with orchids)
NPPF p. 171 Local
Wetland habitats – pond, reedbed, willow scrub
NPPF p. 171 Local
7 Biodiversity Metric 2.0 – Calculation Tool Beta Test. December 2019 version
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Feature Legal and policy status Level of importance
Peregrine Falcon Schedule 1; Section 1.1, Wildlife and Countryside Act 1981
Local
Breeding bird assemblage Section 1, Wildlife and Countryside Act 1981
Within-site but legal protection
The HWRC Scenario
11.6.60 A separate planning application for a HWRC at the north-eastern edge of the Site
was submitted in December 2019 (application reference KCC/TM/0284/2019) and
is awaiting determination at the time of writing. As such, and as discussed in
more detail in Chapter 6.0, it is necessary for the ecological assessment to also
consider a second scenario, where the HWRC is implemented.
11.6.61 The HWRC would comprise:
• A new household waste recycling facility (the HWRC);
• A New access from Laverstoke Road;
• Re-engineering of existing perimeter earth bund;
• Loss of existing tree cover; and
• New native woodland planting.
11.6.62 The HWRC is being proposed on the existing bund that is located immediately to
the east of the Existing Station, separating and screening it from the 20/20
Business Park. In order to construct the HWRC, it would be necessary to carry out
ground re-modelling over a large section of the eastern bund (around 2.3ha in
total). This process would result in the loss of all the existing vegetation within the
affected area, with only a small amount being the subject of replacement through
a proposed landscape scheme (Figure 9.6b).
11.6.63 The earth excavated in the construction of the HWRC facility would be placed on
the bund located to the South of the Existing Station (see Figure 5.4e). This
currently supports a mosaic of grassland, scrub and tall ruderal vegetation, as well
as hard standing and sparsely vegetated areas. This area would be the subject of
a landscaping scheme which would include the creation of habitats of high nature
conservation value such as species-rich grassland and open mosaic habitats.
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11.6.64 As a consequence, the construction of the proposed HWRC would alter the
ecological baseline on the Site. With respect to the earthworks to the south of the
Existing Station, there is no significant difference in terms of habitat loss, since the
area would be utilised for material excavated as part of the construction of the
Existing Station (see Figures 5.8e - 5.8h). However, loss of vegetation on the
eastern bund represents an additional effect attributable to the HWRC.
11.6.65 As described in Chapter 5.0, the earthworks that would be carried out prior to the
construction of the Proposed Extension would need to accommodate the
additional material excavated to construct the HWRC. As such the height of the
proposed earthworks along the western perimeter of the Site would be 5m higher
in the HWRC Scenario (refer to Figures 5.4a-5.4f for an illustration of this).
Grid Connection
11.6.66 As set out in Chapter 5.0, the connection to the local electricity grid would be
undertaken by the District Network Operator (DNO) under their statutory powers
under the Electricity Act 1989. These works would be brought forward separately
by the DNO and as such do not fall to be consented under the DCO process.
Nonetheless, the Chapters of the PEIR have considered the likely environmental
impacts associated with the installation of the Grid Connection, because the
connection to the network is a critical requirement for the Proposed Extension to
recover energy.
11.6.67 The Existing Station is connected to the Maidstone Sub-Station via an
underground connection that runs east around the 20/20 Business Park and then
south through a variety of land-uses and suburban areas to the north of
Maidstone (Route A). The existing grid route is subject to a number of potential
environmental and physical constraints, which has led the Applicant to consider
whether an alternative route may be preferable (Route B). Accordingly, there are
two potential grid connection routes for the Proposed Extension, as follows:
• Route A: the grid route from the Existing Station, running through undeveloped
and suburban areas towards the northern edge of Maidstone;
• Route B: an alternative route that follows the A20, and roads passing through
Maidstone town centre.
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11.6.68 The potential grid routes are shown on Figure 4.1. This assessment will consider
the potentially significant environmental effects associated with construction /
decommissioning and operation of both routes on ecology.
11.7 Assessment of Effects
Incorporated Mitigation
Scheme Design
11.7.1 Mitigation measures incorporated into the design of the Proposed Extension are set
out in the Scheme Description (Chapter 5.0); measures relating to air quality are
set out in Chapter 13.0.
Measures to Avoid Effects on the Water Environment
11.7.2 Measures will be incorporated into the construction and operational phase of the
Proposed Extension to avoid effects on the water environment. These include
measures to address both water quantity (i.e. changes in runoff characteristics) and
water quality (i.e. avoidance of pollution). Additional mitigation measures are set
out in Chapter 12.0 and discussed in more detail below. These will have the effect
of avoiding or reducing risks to important ecological features such as the River
Medway.
Measures to Reduce Noise Disturbance
11.7.3 Measures to reduce noise generation during the construction and operational
phases of the Proposed Extension are outlined in Chapter 14.0 (Noise and
Vibration). Note that no noise-sensitive ecological receptors have been identified in
close proximity to the Site.
Measures to Maintain / Enhance Habitats on Site
11.7.4 The landscape design of the Proposed Extension has been developed as part of an
iterative process between the Project landscape architect and ecologist. The aim of
this process was to maximise the biodiversity value of retained and restored
habitats within the Site, while achieving the landscape design objectives set out in
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Chapter 10.0. The indicative Landscape Proposals are set out on Figure 9.6a
Illustrative Landscape Masterplan (without HWRC) and Figure 9.6b Illustrative
Landscape Masterplan with HWRC.
11.7.5 A total of over 15ha of habitats will be restored on Site, including broadleaved
plantation, neutral grassland, scrub, open mosaic habitat and a small orchard. A
further area of 7ha will be retained, situated to the north and north-east of the
Existing Station, and including most of the Lowland Mixed Deciduous Woodland
priority habitat.
11.7.6 In terms of Biodiversity Metric 2.0, retained, enhanced and created habitats within
the Site will have a value of 191.95 biodiversity units, including habitat creation in
the landscape design of 93.76 biodiversity units. Further details are provided in
Appendix 11-12.
11.7.7 In the HWRC scenario retained, enhanced and created habitats within the Site will
have a value of 181.71 biodiversity units, including habitat creation in the
landscape design of 102.27 units. This lower value is a consequence of the higher
weighting given to retention over restoration in the Biodiversity Metric 2.0
methodology and is a consequence of the additional habitat loss on the eastern
bund. Further details are provided in Appendix 11-13.
11.7.8 Both of the metric calculations have been included as Appendices 11.12 and
11.13. However, reference should be made to the source spreadsheets to explore
the basis for these calculations.
Measures to avoid Air Quality Effects
11.7.9 Mitigation of air quality effects has been developed through an iterative process
involving the Project air quality assessors and ecologists, after identification and
confirmation of sensitive ecological receptors and consideration of the results of the
Stack Height Assessment.
11.7.10 Incorporated mitigation measures involve an increase in the existing stack height
from 80m to 90m to aid dispersion, and combination of the emissions from the
Existing Station with the Proposed Extension into a single stack to increase
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buoyancy. These measures have the effect of reducing the process contribution of
the Proposed Extension to negligible levels at the North Downs Woodlands SAC;
this has implications for the Habitats Regulations Assessment (HRA) process
which are discussed in the Appendix 11-8.
Assessment of Construction Phase Effects - Existing Scenario
Potential Impacts
11.7.11 Key potential impacts during the construction phase of the Proposed Extension
include:
• Land-take for construction, with consequent loss of habitats and component
species in those parts of the Site which lie within the development footprint,
earthworks or construction laydown area;
• Potentially increased risk to water environment from loss of vegetation /
increase in runoff from bare surfaces, leakage of hydrocarbons from plant and
vehicles, and / or contamination from stored fuel or other materials; and
• Increased noise, lighting, vehicle movements and human activity as a
consequence of construction works, with potential disturbance of species using
proximal habitats.
Effects of Land-take
11.7.12 The need to carry out extensive earthmoving operations within the Site to
accommodate the Proposed Extension means that most vegetated habitats will be
lost. Calculations of volumes and the spatial extent of these earthworks are set out
elsewhere in this PEIR.
11.7.13 There will be some retention of habitats, including:
• An area in the central part of the northern bund surrounding the Existing
Station;
• An area in the far northern and north-eastern part of the Site adjoining the M20,
which includes Lowland Mixed Deciduous Woodland priority habitat;
• The main part of the wetland in the western part of the Site will be retained,
although its surroundings will be altered with steeper gradients;
• The small settlement pond adjoining the Existing Station, together with some
areas of amenity grassland around the buildings;
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• The eastern bund surrounding the Existing Station; and
• The southern slope of the wooded bund adjoining the access road on the
southern boundary of the Site.
11.7.14 A calculation has been made of the value of habitats lost in biodiversity units using
Biodiversity Metric 2.0. The principles of the assessment methodology and a
summary of the results of the calculations set out in Appendix 11-12. Based on the
anticipated extent of the proposed earthworks, this equates to a total of 162.85
habitat units (see Appendix 11-12, Table 1). This value does not provide a
qualitative evaluation of habitat loss, but does provide a numeric value in
‘biodiversity units’ against which the value of mitigation works can be measured.
11.7.15 Removal of plantation woodlands, scrub and tall vegetation (e.g. tall ruderal
habitats, bramble under-scrub) is likely to affect breeding birds if undertaken during
the breeding season; few species were recorded in the survey likely to breed in
open grassland habitats, although there are few areas which do not support
scattered scrub. Without appropriate mitigation measures to avoid killing or injury
there is a risk of contravening protected species legislation. There are no significant
risks to other legally protected species as a consequence of the site clearance
process.
Areas of relatively species-rich grassland containing orchid populations are also
within the earthworks footprint. The evaluation in Appendix 11-2 notes that these
areas do not qualify as Lowland Meadows Priority Habitat, although they contribute
to the Site’s overall biodiversity interest, and are identified as a feature of local
importance in Table 11.5. Mitigation proposals for these areas are set out in
section 11.9 below.
Risks to Water Environment
11.7.16 There is an increased potential for effects on the water environment during the
construction phase. The Proposed Extension does not involve working in close
proximity to existing watercourses, although its location around 300m from the
River Medway requires a precautionary approach to be taken to the management
of construction phase risks, both in relation to construction of the Proposed
Extension and associated earthworks.
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11.7.17 Additional mitigation measures are contained within the draft CEMP (Appendix 5-
4). These would help avoid risks of inadvertent pollution of watercourses during the
construction phase. It is intended that this would require approval through a DCO
Requirement prior to the commencement of development.
11.7.18 Retention of the pond area in the western part of the Site would preserve its
functionality as a groundwater-dependent terrestrial ecosystem (GWTE), although
its ecological value would be reduced through replacement of peripheral scrub and
ephemeral – short perennial vegetation of the quarry floor with more steeply graded
grassland slopes.
Increased Disturbance During Construction
11.7.19 The construction phase of the Proposed Extension has the risk of causing more
intensive disturbance of wildlife than its subsequent operational phase, although
individual disturbance events will generally be relative short in duration. Examples
include site clearance and earthmoving, and construction operations involving the
use of heavy equipment. Increased human activity, noise and the use of temporary
security lighting all have the potential to cause temporary disturbance of wildlife.
11.7.20 The Proposed Extension would be developed adjacent to the Existing Station, the
20/20 Business Park, and major road and rail infrastructure. The nearest habitats
which could be considered as sensitive receptors to construction phase
disturbance are the ancient woodland habitats adjoining the Medway. However,
these are separated from the Site by the M20 motorway, to which they are also in
close proximity to. Therefore, it is reasonable to concluded that on the basis of
these factors the Proposed Extension is unlikely to give rise to a significant effect
as a consequence of increased disturbance during the construction phase.
Assessment of Decommissioning Phase Effects – Existing Scenario
11.7.21 It is unclear at what point decommissioning and demolition of the Proposed
Extension would occur and what changes there would be in methods and approach
to decommissioning facilities in the intervening period. Notwithstanding, this could
be a part of the Project and so it is necessary to consider whether this would have
the potential to give rise to likely significant effects.
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11.7.22 Because of the uncertainty regarding the timing and approach to decommissioning,
for the purpose of this assessment, it has been assumed that similar techniques
and / or approaches would be used as the construction phase.
11.7.23 Whilst similar techniques would be used, the ecological impacts during the
decommissioning phase could differ from those experienced during the
construction phase. The construction phase would involve significant earthworks
which would result in the loss of retained habitat around the Existing Station. Whilst
decommissioning could relate to the extended Generating Station in its entirety, it is
likely that this would be limited to the buildings and hardstanding areas and the
landscape / biodiversity enhancement areas that are proposed in connection with
the Proposed Extension would be retained. In light of this, it is reasonable to
assume that the decommissioning effects on ecology would at worst be similar to
those experienced during the construction phase (none of which have been
identified as significant in EIA terms) and are, in all probability, likely to be less than
those predicted during construction.
Assessment of Construction / Decommissioning Effects - HWRC Scenario
11.7.24 In this scenario, the operational effects of the HWRC in terms of noise, vehicle
movements and human disturbance have the potential to act in a cumulative
manner with construction phase disturbance caused by the Proposed Extension.
This activity would be located close to the Site’s eastern boundary, where there is
already a high level of human disturbance from an adjoining distribution centre and
can be considered a low-sensitivity receptor. There will therefore be no significant
difference between construction-phase disturbance in this scenario.
11.7.25 The presence of the HWRC will not increase the construction-phase risk to the
water environment, as it would have its own systems to control and contain surface
water runoff and prevent pollution. These will be unaffected by development of the
Proposed Extension.
11.7.26 The deposition of excavated material in the western part of the Site from the
HWRC would produce a requirement to raise levels of earthworks relative to the
Proposed Extension, but will not significantly alter the spatial extent of disturbance,
or require significant changes to restoration proposals.
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11.7.27 A calculation has been made of the value of habitats lost in biodiversity units using
BM 2.0. The principles of the assessment methodology are set out in Appendix
11-2, and a summary of the results of the calculations set out in Appendix 11-13.
This takes into account the additional area of habitat loss within the development
footprint of the HWRC, and equates to a total of 180.36 habitat units. This
provides a slightly higher target for habitat creation and enhancement works when
compared to the total of 162.85 calculated for the Proposed Extension alone.
Assessment of Construction and Decommissioning Effects of Grid
Connection
11.7.28 As stated in Section 11.6 above, two potential grid connection routes are being
considered for the Proposed Extension (Route A and Route B). The route options
are illustrated on Figure 4.1. This section assesses the potential construction and
decommissioning phase impacts each route would have on ecology.
11.7.29 The existing grid connection route (Route A) passes through or close to some
areas of significant nature conservation interest. This can be illustrated by a
comparison of Figure 4.1 with Appendix 11.1, Figure A11.1.2.
11.7.30 After leaving the Site and passing under the Maidstone – Strood rail line, the route
runs parallel to a tidal reach of the River Medway, which lies within the Medway
MCZ. It then passes close to the boundary of an ancient woodland, Lock Wood,
before a directionally-drilled crossing of the River Medway upstream of the tidal
limit and MCZ.
11.7.31 Continuing to the east of the A229, the route passes close to Cuckoo Wood LWS
and ancient woodland, although separated from it by a minor road (Sandling Lane).
After continuing within and adjacent to public highways, the route then passes
through the southern edge of Heath Wood, a woodland located to the south-west of
M20 junction 7. The section of woodland on the southern boundary is classed as a
Plantation on Ancient Woodland (PAWS) site.
11.7.32 The route then turns south, across the A249 and through Upper Fullingpits Wood;
this is not on the Ancient Woodland Register, although the nearby Lower Fullingpits
Wood to the east is classed as ancient semi-natural woodland. The remainder of
the route continues on a generally southerly trajectory through urban areas to the
grid connection at Maidstone 132/33kV Substation.
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11.7.33 As well as the sites of known ecological interest, the route passes through public
open spaces and parkland either side of the River Medway (Allington Open Space
and a recreation ground at Dickens Road), as well as open space with mature trees
within the Invicta Park complex.
11.7.34 It is understood that a new grid connection along the existing Route A would
require a new route separated by up to 6m from the existing cable duct. It would
not be possible to use the existing duct and may therefore not be possible to avoid
nearby features of ecological value.
11.7.35 Route B reaches the Substation through urban areas of Allington and Maidstone. It
crosses the River Medway on an existing road bridge and does not pass close to
any features of known ecological interest. It is located either within road surfaces,
verges or paths, and avoids any areas of woodland or other semi-natural
vegetation. There are some street trees within road verges along parts of the route
which may justify protection or avoidance measures, but do not constitute
significant ecological constraints.
11.7.36 In light of the foregoing, Route B can be regarded as a preferred option in
ecological terms, as it avoids any features which may have any biodiversity
interest.
Decommissioning of Grid Connection
11.7.37 At the end of its operational life, it is anticipated that the ducting for the Grid
Connection would be left in situ, such that there would be no decommissioning
works and therefore no potential significant effects upon ecological interest features
adjoining the route.
Assessment of Operational Phase Effects – Existing Scenario
Potential Impacts
11.7.38 Key potential impacts during the operational phase of the Proposed Development
include:
• Potential air quality effects of emissions on sensitive ecological receptors,
including statutory designated sites;
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• Potential near-site effects of noise, human disturbance and lighting.
Air Quality Effects
11.7.39 The following provides a summary of the key impacts in relation to Environment
Agency or IAQM screening thresholds8.
11.7.40 In all cases, the Proposed Extension results in an increase in nitrogen and acid
deposition rates of less than 1% of the relevant Critical Load for the most sensitive
habitat present, relative to the existing baseline.
11.7.41 At North Downs Woodland SAC, the process contribution (PC) to nitrogen
deposition is predicted to be a maximum of 0.8% of the lower Critical Load for the
most sensitive woodland plant community present. The PC to acid deposition is
0.5% of the relevant Critical Load, and ammonia levels are predicted to increase by
0.8% of the relevant Critical Level.
11.7.42 At ancient woodlands and Local Wildlife Sites, the process contribution to nitrogen
deposition is predicted to be between 0.1 and 0.3% of the lower Critical Load for
the most sensitive habitat present; the PC for acid deposition is predicted between
0.1 and 0.6% of Critical Load. Lock Wood ancient woodland has a predicted
reduction in PC of -0.8% with respect to nitrogen deposition, and -2.1% with
respect to acid deposition.
11.7.43 The ecological effects of emissions to air are addressed in more detail in Appendix
11-6, based on the Emissions Modelling Report produced by Fichtner Consulting
Engineers (Appendix 13-3). In addition to the above impacts, and following
consultation with Natural England, in-combination effects of nitrogen deposition in
North Downs Woodlands SAC are also considered in the Habitats Regulations
Assessment Report Appendix 11-7.
8 Holman et al (2019). A guide to the assessment of air quality impacts on designated nature conservation sites – version 1.0, Institute of Air Quality Management, London. www.iaqm.co.uk/text/guidance/airquality-impacts-on-nature-sites-2019.pdf
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Potential Effects of Noise, Human Disturbance and Lighting
11.7.44 As noted in the assessment of effects during the construction phase, there are few
important ecological features around the Site which could be regarded as
particularly noise sensitive.
11.7.45 The increase in operational phase traffic movements within and around the Site
compared to the current baseline is relatively low (see Chapter 15.0), and does not
significantly alter the likelihood of disturbance of adjoining habitats.
11.7.46 There are few receptors of high sensitivity to increased light levels in the vicinity of
the Proposed Extension, as evidenced by data from the bat survey. The Existing
Station is illuminated, and lighting on the adjoining motorway and dual carriageway
road network means that any increase in lighting will be incremental in extent,
rather than introducing lighting into a previously dark natural environment.
Effect Significance
11.7.47 The table below combines the identification of important ecological features,
including their geographic scale of importance, with the potential impacts and their
predicted effects set out above. It uses these to assess the effect on the
conservation status of species, and the integrity of any sites or component habitats
thereof, in order to identify whether any ecological effects can be considered to be
significant in EIA terms.
11.7.48 With respect to designated sites in the defined Study Area of the Proposed
Extension, no ecologically significant construction phase effects are predicted.
Additional mitigation measures set out in the Water Quality and Drainage section
and incorporated in the CEMP will ensure avoidance of any risks on the River
Medway and Medway MCZ and ensure that there are no significant effects.
11.7.49 With the implementation of incorporated mitigation measures, operational phase air
quality effects on designated sites are all predicted to be negligible in magnitude
(i.e. below Environment Agency or IAQM screening thresholds). The design and
operation of surface water attenuation features will ensure continuing avoidance of
risk to the River Medway and Medway MCZ.
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Table 11.6: Effect Significance
Interest feature Scale of
importance Effects
Effect significance / effect on site integrity or conservation status
Off-Site Interest Features: Construction / Decommissioning Phases
River Medway / Medway MCZ County /
national level
Risk of effects reduced to negligible level or avoided by measures set out in
Water Quality and Drainage chapter and CEMP
No predicted effects
All other sites International –
local
Can be screened out from further assessment – all more than 50m from Site boundary and with no predicted
effect pathway
No predicted effects
Off-Site Interest Features: Operational Phase
North Downs Woodlands SAC
International
With incorporated mitigation, inconsequential (de minimis) increase in nitrogen deposition rates, alone and in-combination with road traffic effects
No effect on site integrity
Ditton Quarry LNR
County level
Air quality effects all below screening
thresholds No other predicted effects
No significant harm
River Medway / Medway MCZ
County / National level
Design of surface water attenuation features avoids risk of effects on water
environment No predicted effects
Aylesford Old Pit LWS County level
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Cuckoo Wood LWS County level
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Blue Bell Hill Banks and Verges LWS County level
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Lock Wood Local
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Sandling Wood
Local
Air quality effects all below screening thresholds; small magnitude reduction in acid deposition rates (minor positive
magnitude) No other predicted effects
No predicted effects
Dog Kennel Wood Local
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Broke Wood Local
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
Fullingpits Wood Local
Air quality effects all below screening thresholds
No other predicted effects No predicted effects
On Site Interest Features: Construction Phase
Lowland Mixed Deciduous Woodland
Local Proximal disturbance impacts of
earthmoving Minor negative effect, not significant in EIA terms
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Interest feature Scale of
importance Effects
Effect significance / effect on site integrity or conservation status
Neutral grassland habitat (relatively species-rich areas with orchids)
Local Loss of feature
Minor negative effect at local scale, requires
additional mitigation not significant in EIA terms
Wetland habitats – pond, reedbed, willow scrub
Local Partial loss / disturbance of feature
with groundwater-dependent habitats retained
Minor negative effect at local scale, not significant
in EIA terms
Peregrine Falcon Local (legal protection)
None predicted Not significant
Breeding bird assemblage Within-site
(legal protection)
Possible damage or destruction of nests, eggs and dependent young during site clearance operations
No significant effect on local population / will require mitigation to maintain legislative
compliance
On-site Interest Features: Operational Phase
Lowland Mixed Deciduous Woodland
Local Adjoining planting in new landscape design will increase effective area of
woodland as it matures
Minor positive, not significant
Neutral grassland habitat Local
New grassland habitats will develop, species composition and diversity
depending on management
Minor positive effect, greater with mitigation
Wetland habitats – pond, reedbed, willow scrub
Within-site Parts of feature retained, including
open water / emergent vegetation, but constrained by adjoining steep slopes
Not significant
Peregrine Falcon Local
No significant change from current baseline
Not significant
Breeding bird assemblage Within-site
Likely to see recovery in breeding density (within 5 years) as restored
habitats mature Not significant
Grid Connection
11.7.50 As noted previously, the electrical grid connection would comprise an underground
cable. Accordingly, during the operational phase, it would not have any potential to
give rise to significant effects on ecology.
Assessment of Operational Phase Effects - HWRC Scenario
11.7.51 The HWRC would result in an increase in noise and human disturbance in the
vicinity of the Existing Station, through development of the eastern bund. This will
be proportionately more disturbing to birds and other wildlife using the Site than
either the Existing Station or the Proposed Extension, because of the greater
frequency of outdoor human activity, vehicle movements and noise associated with
disposal of household waste. In contrast, despite movement of HGVs to and from
the Tipping Hall, in normal operation an energy recovery facility usually
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experiences relatively little outdoor human activity. However, as noted in the
context of construction-phase disturbance, this activity would be located close to
the Site’s eastern boundary, where there is already a high level of human
disturbance from an adjoining distribution centre. It will not significantly affect the
ability of wildlife to colonise and utilise the restored landscape around the Proposed
Extension, which is separated from the HWRC by the Existing Station. It will not
therefore result in a significant difference in the significance of operational phase
ecological effects.
11.8 Cumulative Effects
11.8.1 As described in Chapter 6, the cumulative assessments undertaken within each
chapter of this PEIR has been carried out by considering which scenario (i.e.
development of the Proposed Extension with or without the HWRC) would give rise
to the ‘worst-case’ for the assessment of that environmental topic. Once that has
been established, it has then been assessed on that basis in conjunction with the
cumulative schemes set out below. Where the two scenarios give rise to different
worst-case effects, two cumulative scenarios are assessed separately.
11.8.2 For the purposes of the assessment of potentially significant effects on ecology, it
has been judged that the ‘HWRC Scenario’ would represent the worst case. This is
on the basis of a slightly greater effect volume of traffic generation. This relates
principally to the ecological effects of emissions to air, which have been modelled
in Appendix 13-4. It must be noted that even with slightly greater effects these
would still not be significant in EIA terms.
11.8.3 The approach to the cumulative assessment is discussed in Chapter 6.0. All six
identified developments are for residential use; three benefit from planning
permission (not yet implemented), whilst the planning applications for the other
three have not yet been determined. The schemes are listed below, and their
locations are shown on Figure 6.1.
11.8.4 The following projects are considered in the assessment of cumulative effects:
• Springfield Road, Maidstone – 295no. residential units;
• Somerfield Distribution Centre, Aylesford – 92 no. residential units;
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• Land W of Hermitage Road / E of Quarry Wood Industrial Estate, Aylesford –
total of 99no. residential units including assisted living spaces;
• Springfield Library, Maidstone – 170 no. residential units;
• Land S of London Rd. / E of Hermitage Lane, Aylesford – 840 no. residential
units and associated services;
• Land SW of London Rd. / W of Castor Park, Allington – 106 no. residential
units.
11.8.5 With the exception of traffic generation, there are no potential effects of the above
developments which could operate in combination with the Proposed Extension.
None adjoin the Site or are ecologically linked to it, so habitat losses associated
with them would not act in a cumulative manner through severance of ecological
networks. The Proposed Extension will not give rise to additional recreational
pressure on sensitive sites, so cannot act in a cumulative manner with residential
developments. Aside from traffic, none of the above developments include sources
of emissions to air.
11.8.6 Cumulative effects of road traffic generation for the above are considered in
Chapter 13.0 (air quality) Emissions modelling has concluded that there will be no
significant cumulative effects as a consequence of traffic and point source
emissions from the Proposed Extension in combination with the above
developments.
Other Cumulative Effects - North Downs Woodland SAC
11.8.7 The Emissions Modelling report (Appendix 13-3) considers a range of plans and
projects which may result in road traffic-related air quality impacts on North Downs
Woodland SAC.
11.8.8 A Habitats Regulations Assessment (HRA) Report assesses the implications of
these cumulative effects for the integrity of the SAC, with the conclusion that there
is no exceedance of Environment Agency or IAQM screening thresholds, and in-
combination effects can be considered negligible in EIA terms, and inconsequential
or de minimis in HRA terms.
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11.9 Additional Mitigation
Mitigation for Construction Phase Effects on Water Environment
11.9.1 Additional mitigation measures to avoid effects on the water environment are set
out in Section 12.8 of the Water Quality and Drainage chapter of the PEIR.
Measures can be summarised as:
• Provision of a CEMP;
• Conformity of construction works to ADAS Technical Note on Workmanship
and Materials for Drainage Schemes (1995);
• Earth moving operation would be undertaken in accordance with BS6031:2009
Code of Practice for Earthworks;
• Conformity with DEFRA guidance in the Construction Code of Practice for the
Sustainable Use of Soils on Construction Site (2009);
• Good practice guidance on erosion and pollution control would be followed, e.g.
CIRIA Environmental Good Practice on Site (C692) and Control of Water
Pollution from Construction Sites (C532);
• Avoid the storage of plant / machinery fuel or material (including soil stockpiles)
alongside watercourses unless unavoidable. Construction works should be
programmed as far as is practicable to minimise soil handling and temporary
soil storage; and
• Spillage prevention and remediation measures including designated refuelling
areas, bunded and locked tanks, and spill kits.
Mitigation for Construction Phase Effects on Grassland Habitats
11.9.2 The boundaries of areas of relatively species-rich grassland containing orchid or
broomrape (Orobanche minor) populations identified in the extended Phase 1
Habitat Survey will be plotted using a sub-metre mapping grade GIS.
11.9.3 Soils from these areas will be stripped and re-spread as part of the progressive
restoration of the Site. Because of the phasing of the earthmoving works, it will be
possible to strip and spread these soils in one operation, minimising handling and
avoiding storage. This will serve to avoid any loss of seed viability, and minimising
loss of viability of vegetative propagules in the upper soil horizons.
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11.9.4 Soils from these areas will, wherever possible, be reserved for areas to be
managed as grassland in the new landscape design, rather than woodland.
11.9.5 A draft CEMP has been prepared in support of this PEIR and is contained within
Appendix 5-4, this sets out the approach to earthworks movements generally and
in terms of the specific requirements for the retention of orchids.
Avoidance of Construction Phase effects on Proximal Habitats
11.9.6 A site perimeter fence would be erected during earthworks to ensure that proximal
habitats which lie outside the development footprint are appropriately protected.
This will include, in particular, the area of Lowland Mixed Deciduous Woodland
Priority Habitat located on the northern / north-eastern boundary of the Site.
Construction Phase Mitigation for Breeding Birds
11.9.7 Site clearance of scrub vegetation and other tall cover will not be undertaken within
the bird breeding season (March – end August), if necessary, bringing forward such
advance works in advance of the main construction period.
11.10 Residual Effects
11.10.1 The table below summarises the residual construction phase ecological effects of
the Proposed Extension following implementation of mitigation measures. Note
that there are no differences in significance between the Proposed Extension and
the HWRC scenario. This excludes effects which have been avoided by
incorporated mitigation measures and focusses on those identified in Table 11.6.
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Table 11.7: Residual effects – construction phase
Interest feature
Scale of Importance
Predicted Effect
Significance of Effect; Pre-mitigation
Mitigation Residual Significance of Effect
Medway MCZ / River Medway
National / County level
Pollution risk
Negligible (see Table 12.9)
Operational control and monitoring measures in CEMP
Negligible
Lowland Mixed Deciduous Woodland
Local Physical disturbance
Minor negative, not significant in EIA terms
Fencing and avoidance measures
Negligible
Neutral grassland (orchid-rich areas)
Local Loss of feature
Minor negative, local scale
Preservation of surface soils
Minor negative, becoming negligible
Wetland habitats
Local Loss of marginal habitats
Minor negative, not significant in EIA terms
Limitation of damage to core wetland through measures in CEMP
Minor negative, nto significant in EIA terms
Breeding bird assemblage
Within-site
Disturbance / damage to nests and young
Negligible, but legal protection requires mitigation
Clearance of suitable breeding habitat outside nesting season
Negligible
11.10.2 The table below considers residual operational phase effects.
Table 11.8: Residual effects – operational phase
Interest feature
Scale of Importance
Predicted Effect
Significance of Effect; Pre-mitigation
Mitigation Residual Significance of Effect
North Downs Woodlands SAC
International Air quality effects
Negligible (with incorporated mitigation)
No additional mitigation necessary
Negligible
Medway MCZ / River Medway
National / County level
Pollution risk
Negligible (see Table 12.10)
Surface water drainage strategy
Negligible
11.11 Compensation for Construction Phase Habitat Loss
11.11.1 The Construction of the Proposed Extension to the Allington IWMF would result in
the loss of an area to the west of the Existing Station, that currently comprises the
restored former Allington Quarry. This land is identified within the existing Allington
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S106 agreement (dated 13th November 2017) as a NCA. The NCA does not have
any statutory or non-statutory designation and does not met the Kent Selection
Criteria for a LWS.
11.11.2 The NCA would be lost in its entirety during the construction phase of the Proposed
Extension and, following completion of construction, the land that remains to the
west of the Proposed Extension would be restored providing ecological, landscape
and amenity benefit (See Figures 9.6a and 9.6b).
11.11.3 Habitat loss associated with the construction of the Proposed Extension has been
identified within this Chapter of the PEIR and it has been concluded that, taking into
account the proposed mitigation measures (soils handling and placement,
avoidance of effects on priority habitats and partial restoration) the works would
result in an effect of minor significance at a local scale of importance and are not
significant in EIA terms. Whilst an adverse effect, additional ecological measures
are not required to compensate for the loss.
11.11.4 Notwithstanding, following discussion with KCC, the Applicant chose to develop a
strategy that would aim to off-set the loss of biodiversity arising from the
development of the Proposed Extension by means of on-site mitigation and off-site
compensatory habitat enhancement (see Appendix 11-9). Biodiversity Metric 2.0
provides a tool to quantify the value of this enhancement, set against the value of
habitats lost.
11.11.5 The Applicant has identified an area of land within the same local authority
(TMBC), which is under their ownership and control, where enhancement
measures could be undertaken to compensate for the loss on the Allington Site.
That site is the former Stangate landfill, which is located near Borough Green,
Kent. Details of the proposed enhancement measures are set out in the Stangate
East / West and Stangate East Ecological Management Plans, contained within
Appendices 11-10 and 11-11.
11.11.6 Biodiversity Metric 2.0 has been used to calculate the net gain from the Proposed
Development (see Appendix 11-2 for further details). The Metric calculation has
confirmed that the Stangate East / West Ecological Management Plan could deliver
a net gain of up to 56.69% (52.41% in the HWRC Scenario) and that the Stangate
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East Ecological Management Plan could deliver a net gain of up to 9.99% (5.71%
in the HWRC Scenario)
11.12 Summary
11.12.1 The Proposed Extension will result in the development of land at Allington IWMF
currently subject to a Section 106 Agreement and managed as a Nature
Conservation Area. Following ecological surveys, the nature conservation value of
this area has been evaluated, together with habitats around the Existing Station
which make up the Site. The conclusion of this assessment is that it would not
currently meet Kent Local Wildlife Site criteria, although it does contain features
with some biodiversity interest. These include areas of grassland supporting
populations of locally common orchid species, and a remnant area of longer-
established woodland adjoining the M20 motorway.
11.12.2 Ecological surveys have found relatively low levels of bat activity on the Site;
surveys for great crested newts, reptiles and other protected species produced
negative results. The invertebrate fauna comprises relatively mobile species,
typically occurring in relatively immature habitats. These results have been
interpreted as arising from the isolation of habitats by transport infrastructure and
industrial development and by the Site’s history of disturbance.
11.12.3 Mitigation measures are planned to protect woodland and provide partial protection
to wetland habitats during construction, and to identify areas of soils supporting
areas of relatively species-rich grassland. These soils will be utilised in the
restoration of new grassland habitats in the Site’s landscape design.
11.12.4 With respect to off-site habitats, North Downs Woodlands SAC has been identified
as a sensitive receptor of high nature conservation importance with respect to
emissions to air. Mitigation measures have been incorporated into the design of the
Proposed Extension to ensure that dispersion and deposition of key pollutants
remains below Environment Agency and IAQM screening thresholds, alone and in
combination with other plans and projects. Consequently, no effects on the
integrity of European and internationally designated conservation sites are
predicted as a consequence of the Proposed Extension.
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11.12.5 The River Medway, including the Medway MCZ in the tidal reaches of the river, has
been identified as a sensitive receptor for water quality impacts. Mitigation
measures during construction, operation and decommissioning of the Proposed
Extension are set out in the Water Quality and Drainage section (Chapter 12.0).
These will have the effect of avoiding any risk to the water environment or reducing
risk to a level which can be considered negligible.
11.12.6 The HWRC scenario will result in an additional impact on habitats to the east of the
Existing Station, but does not change the significance of ecological effects, or
impose any significant constraints on proposed mitigation measures.
11.12.7 The assessment indicates that the Proposed Extension would not have a
significant residual effect on important ecological features, subject to the
implementation of mitigation measures. It is also possible to achieve biodiversity
net gain in excess of 10% of baseline values through the implementation of off-site
habitat enhancement works at the former Stangate landfill site.
11.12.8 The proposal complies with policy NPS EN-1 in avoiding significant harm to
ecological resources, including through the incorporation of mitigation measures
into the design of the Proposed Extension. Opportunities will be taken to create
new habitats of value within the Site’s restored landscape.