West Sussex Minerals & Waste Development Framework Habitat Regulations Assessment – Appropriate Assessment of Sites
For Issue June 2011
Prepared for
West Sussex County Council West Sussex Minerals & Waste Development Framework
Revision Schedule
Appropriate Assessment Report June 2011
Rev Date Details Prepared by Reviewed by Approved by
01 November Draft for Graeme Down Dr James Riley Dr James Riley 2010 consultation Ecologist Principal Ecologist Principal Ecologist
02 June 2011 Incorporating Dr James Riley Natural Principal Ecologist England’s comments
URS/Scott Wilson Scott House Alençon Link This document has been prepared in accordance with the scope of Scott Wilson's Basingstoke appointment with its client and is subject to the terms of that appointment. Scott Wilson accepts no liability for any use of this document other than for the purposes for which it Hampshire was prepared and provided. No person other than the client may copy (in whole or in RG21 7PP part) use or rely on the contents of this document, without the prior written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion. Tel 01256 310200 Fax 01256 310201 © Scott Wilson Ltd 2010
www.urs-scottwilson.com
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Table of Contents
1 Introduction ...... 1 1.1 Legislation ...... 1 1.2 Scope and objectives ...... 2 2 Methodology ...... 4 2.1 Key principles ...... 4 2.2 Process ...... 4 2.3 Likely Significant Effects (LSE) ...... 5 2.4 Appropriate Assessment and Mitigation...... 6 2.5 Confirming other plans and projects that may act in combination...... 6 2.6 Physical scope of the assessment ...... 10 3 Pathways of impact...... 11 3.1 Introduction...... 11 3.2 Atmospheric pollution ...... 11 3.3 Water quality and flows ...... 20 3.4 Predation ...... 21 3.5 Disturbance ...... 22 3.6 Coastal Squeeze ...... 24 3.7 Direct landtake ...... 24 3.8 Screening distance summary ...... 26 4 Appropriate Assessment of Minerals Sites ...... 27 4.2 M/CH/1A (Woodmancote), M/CH/1B (Common Road West), M/CH/1C (Common Road East), M/CH/1D (Slades Field)...... 27 4.3 M/CH/7A (West Heath Common Extension) and M/CH/7B (East of West Heath Common)...... 28 4.4 M/CH/8A (Minsted West)...... 30 4.5 M/CH/10A – Duncton Common...... 31 4.6 M/CH/11 – Horncroft ...... 32 4.7 M/HO/2 – Chantry Lane Extension...... 32 4.8 M/MS/1 – Land Adjacent to West Hoathly Brickworks, M/MS/2 – Philpots Extension...... 33 4.9 Recommendations ...... 34 5 Minerals Sites Not Previously Screened ...... 36 5.2 M/HO/6B - Rudgwick East and M/HO/6A - Rudgwick West...... 36
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5.3 M/CH/8C - Severals West and M/CH/8D - Severals East ...... 36 6 Appropriate Assessment of Waste Sites ...... 38 6.2 W/AR/4 – Blue Prince Mushroom Site...... 38 6.3 W/CH/1B – Portfield, W/CH/1C – Fuel Depot, Bognor Road ...... 39 6.4 W/CH/4A – Land East of Tangmere Airfield, W/CH/4B – South East Corner of Tangmere Airfield, W/CH/4C – Woodhorn Farm...... 40 6.5 W/CH/5 – Bognor Common Stone Quarry ...... 42 6.6 W/CH/6 – Duncton Quarry ...... 43 6.7 W/HO/5 – Chantry Lane Sandpit...... 43 6.8 W/HO/9 – Land at North Farm ...... 44 6.9 W/HO/10 – Hampers Lane Engineering Works...... 45 6.10 W/MS/1 – Burleigh Oaks Farm...... 45 6.11 W/MS/2 - Freshfield Lane Brickworks ...... 46 6.12 Recommendations ...... 47 7 Conclusions of Appropriate Assessment ...... 49 7.2 Minerals and Waste Policy Options...... 49 Appendix 1 - ‘Tiering’ in Habitat Regulations Assessment...... 50 Appendix 2 - Background on European sites referenced in this document ...... 51 Appendix 3 – Minerals and Waste Sites Screened Out of HRA ...... 56
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1 Introduction
1.1 Legislation
1.1.1 The need for Habitat Regulations Assessment is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British law by the Conservation (Natural Habitats &c) Regulations 1994 (as amended in 2007). The ultimate aim of HRA is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates to habitats and species, not the European sites themselves, although the sites have a significant role in delivering favourable conservation status.
1.1.2 The Habitats Directive applies the precautionary principle to protected areas (Special Areas of Conservation, SACs and Special Protection Areas, SPAs, collectively known as European sites and which comprise the Natura 2000 pan-European network). Plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. Plans and projects may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead. In such cases, compensation would be necessary to ensure the overall integrity of the site network.
1.1.3 In order to ascertain whether or not site integrity will be affected, an HRA should be undertaken of the plan or project in question:
Box 1. The legislative basis for Appropriate Assessment
Habitats Directive 1992
Article 6 (3) states that:
“Any plan or project not directly connected with or necessary to the 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.”
Conservation of Habitats and Species Regulations 2010
“A competent authority, before deciding to … give any consent for a plan or project which is likely to have a significant effect on a European site … shall make an appropriate assessment of the implications for the site in view of that sites conservation objectives… The authority shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site”.
1.1.4 Over the years the phrase ‘Habitat Regulations Assessment’ (HRA) has come into wide currency to describe the overall process set out in the Conservation of Habitats and Species Regulations from screening through to IROPI. This has arisen in order to distinguish the process from the individual stage described in the law as an ‘appropriate assessment’. Throughout this report we use the term Habitat Regulations Assessment for the overall process and restrict the use of Appropriate Assessment to the specific stage of that name.
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1.2 Scope and objectives
1.2.1 The role of the Natura 2000 sites (SACs, SPAs, Ramsar) is to provide statutory protection for terrestrial and coastal sites that are of European and global importance as a result of habitats or species contained within them. Scott Wilson has been appointed by West Sussex County Council to assist in undertaking a Habitat Regulations Assessment (HRA) of the potential effects of the Minerals & Waste Development Framework (MWDF), on the Natura 2000 network.
1.2.2 The MWDF will supersede the West Sussex Minerals Local Plan and West Sussex Waste Local Plan (strategic planning framework for the protection of the environment, sustainable transport priorities, and the scale, pattern and location of minerals and waste development across West Sussex). The MWDF currently comprises a number of Background papers that detail potential policy and site options for minerals and waste development to 2026.
1.2.3 Formal preparation of the West Sussex Minerals and Waste Core Strategy has been suspended by the County Council due to uncertainties that have arisen in recent months. These include:
• the impact of the Government revoking the South East Plan, and the subsequent reinstatement of the plan; • possible changes to the planning system arising from the Decentralisation and Localism Bill; • the proposed national review of waste policy; and • the need for further discussions on joint working with the South Downs National Park Authority.
1.2.4 Nonetheless, the Council has indicated that preparation of a robust evidence base should continue in order to support future development of the MWDF, and this HRA report is being prepared as a key supporting document in this regard.
1.2.5 The purpose of this current document is to:
• Identify the European sites (Special Areas of Conservation , Special Protection Areas and Ramsar sites) that could potentially be affected by Strategic site allocations within the development document; • Research and set out details of their European interest features and the environmental conditions that are required to maintain the favourable conservation status of those features; • Explore the vulnerability of these European sites to potential impacts arising from the MWDF site allocations and if possible, screen out those European sites that on consideration are unlikely to be affected by the MWDF, based on current knowledge; • Where possible, identify those Strategic site allocations that may conflict with maintaining the favourable conservation of the European sites, based on current knowledge.
1.2.6 There are fourteen Special Areas of Conservation (SACs), Special Protection Areas (SPAs) or Ramsar sites that lie wholly or partly within West Sussex:
• Arun Valley SPA/Ramsar • Chichester and Langstone Harbours SPA/Ramsar
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• Duncton to Bignor Escarpment SAC • Ebernoe Common SAC • Kingley Vale SAC • Pagham Harbour SPA/Ramsar • Rook Clift SAC • Singleton and Cocking Tunnels SAC • Solent Maritime SAC • The Mens SAC • Wealden Heaths Phase 2 SPA Three SACs and one SPA lie outside of West Sussex, but are included in this HRA since it is considered that the West Sussex MWDF may generate pathways of impact (see Chapter 3) that could have adverse effects on these sites. These sites are: • Ashdown Forest SAC/SPA • East Hampshire Hangers SAC • Woolmer Forest SAC
1.2.7 Twenty-seven of the issues (encompassing 62 Options) have been screened in for Appropriate Assessment. The reason for this is that these are the policies that either promote or direct the scale and spatial distribution of minerals and waste development within West Sussex. They may be of particular relevance with regard to any unallocated (i.e. non-strategic) sites that come forward during the life of the MWDF in relation to criteria-based policies for determining appropriate waste/minerals sites. However, they cannot be meaningfully taken forward from the initial HRA screening stage until the actual wording of relevant policies is developed. This document therefore focussed on the allocated sites.
1.2.8 Chapter 2 explains the process by which the HRA process as a whole is being carried out. The screening (Likely Significant Effects) stage was the subject of an earlier report (March 2010). The current report builds on the findings of the screening report, taking into account responses from Natural England, who are the statutory consultees on HRAs, and seeks to examine in greater detail those site options that could not be screened out previously. This comprises the Appropriate Assessment stage of the HRA process. Chapter 3 explores the relevant pathways of impact and the criteria on which minerals and waste sites were screened in or out of assessment, and which are relevant to Appropriate Assessment. Chapter 4 presents a summary of the screening of each site option contained within the MWDF, for all sites where it was determined that Appropriate Assessment would be required. The Chapter then considers further the detailed Appropriate Assessment for each of these sites, exploring the need for and options for avoidance and mitigation. Chapter 5 then summarises the conclusions of HRA.
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2 Methodology
2.1 Key principles
2.1.1 This section sets out the basis of the methodology for the HRA. Scott Wilson has adhered to several key principles in developing the methodology – see Table 1.
Table 1 - Key principles underpinning the proposed methodology
Principle Rationale Use existing information We will use existing information to inform the assessment. This will include information gathered as part of the SA of the emerging MWDF and information held by Natural England, the Environment Agency and others. Consult with Natural We will ensure continued consultation with both Natural England and England, the Environment the Environment Agency for the duration of the assessment. We will Agency and other ensure that we utilise information held by them and others and take on stakeholders board their comments on the assessment process and findings. Ensure a proportionate We will ensure that the level of detail addressed in the assessment assessment reflects the level of detail in the MWDF (i.e. that the assessment is proportionate). With this in mind, the assessment will focus on information and impacts considered appropriate to the local level. Keep the process simple We will endeavour to keep the process as simple as possible while as possible ensuring an objective and rigorous assessment in compliance with the Habitats Directive and emerging best practice. Ensure a clear audit trail We will ensure that the AA process and findings are clearly documented in order to ensure a clearly discernible audit trail.
2.2 Process
2.2.1 The HRA is being carried out in the absence of formal Government guidance. Communities and Local Government released a consultation paper on Appropriate Assessment of Plans in 20061. As yet, no further formal guidance has emerged.
2.2.2 Experience with HRA of LDFs and RSSs suggests that 1) a European site based approach, and 2) avoidance / mitigation measures focused on the environmental conditions needed to maintain site integrity are in keeping with the spirit of the Habitats Directive. This has been the broad approach taken for almost all Regional Spatial Strategies and many HRAs for Local Development Frameworks.
2.2.3 Error! Reference source not found. below outlines the stages of HRA according to current draft CLG guidance. The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no significant adverse effects remain.
1 CLG (2006) Planning for the Protection of European Sites, Consultation Paper
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2.3 Likely Significant Effects (LSE)
2.3.1 The first stage of any Habitat Regulations Assessment (HRA Task 1) is a Likely Significant Effect (LSE) test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:
2.3.2 ”Is the Plan, either alone or in combination with other relevant projects and plans, likely to result in a significant effect upon European sites?”
2.3.3 The objective is to ‘screen out’ those plans and projects that can, without any detailed appraisal, be said to be unlikely to result in significant adverse effects upon European sites, usually because there is no mechanism for an adverse interaction with European sites.
2.3.4 In this case, the plan documents have been evaluated in detail within the context of existing knowledge of the various ways in which development can impact on European sites, accumulated from carrying out HRAs across the country at all geographical scales (from individual projects through to Regional Spatial Strategies). If it cannot be concluded with confidence that adverse effects are unlikely, we have deferred to the precautionary principle and assumed that they require investigation in the Appropriate Assessment.
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2.4 Appropriate Assessment and Mitigation
2.4.1 When a plan cannot be ‘screened out’ as being unlikely to lead to significant effects on European sites, it is necessary to progress to the later ‘Appropriate Assessment’ stage to explore the adverse effects and devise mitigation.
2.4.2 The steps involved are detailed in Box 2.
Box 2. The steps involved in the Appropriate Assessment exercise undertaken for the West Sussex MWDF
1. Explore the reasons for the European designation of these sites. 2. Explore the environmental conditions required to maintain the integrity of the selected sites and become familiar with the current trends in these environmental processes. 3. Gain a full understanding of the plan and its policies and consider each preferred option within the context of the environmental processes – would the preferred option lead to an impact on any identified process? 4. Decide if the identified impact is likely to lead to an adverse effect. 5. Identify other plans and projects that might affect these sites in combination with the Plan and decide whether there any adverse effects that might not result from the Plan in isolation will do so “in combination”. 6. Develop measures to avoid the effect entirely, or if not possible, to mitigate the impact sufficiently that its effect on the European site is rendered effectively inconsequential
2.4.3 The level of detail concerning developments that will be permitted under land use plans will never be sufficient to make a detailed quantification of adverse effects. Therefore, we have again taken a precautionary approach (in the absence of more precise data) assuming as the default position that if an adverse effect cannot be confidently ruled out, avoidance or mitigation measures must be provided. This is in line with CLG guidance that the level of detail of the assessment, whilst meeting the relevant requirements of the Habitats Regulations, should be ‘appropriate’ to the level of plan or project that it addresses (see Appendix 1 for a summary of this ‘tiering’ of assessment).
2.5 Confirming other plans and projects that may act in combination
2.5.1 It is neither practical nor necessary to assess the ‘in combination’ effects of the MWDF within the context of all other plans and projects within the South-East of England. In practice therefore, in combination assessment is only really of relevance when the plan would otherwise be screened out because its individual contribution is inconsequential. For the purposes of this assessment, we have determined that, due to the nature of the identified impacts, the key other plans and projects relate to the additional housing, commercial/industrial allocations, minerals and waste strategies and major infrastructure projects proposed for West Sussex and surrounding authorities over the lifetime of the Minerals and waste Development Framework policies.
2.5.2 The Regional Spatial Strategy for the South East (2009)2 provides a good introduction to proposals for West Sussex as a whole, and surrounding counties. As of 6th July 2010, following
2 http://webarchive.nationalarchives.gov.uk/20100528142817/http://www.gos.gov.uk/gose/planning/regionalPlanning/815640/
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a letter from the Secretary of State for CLG, Regional Strategies was revoked, but has been temporarily reinstated since that time. However, guidance issued concurrently indicates that evidence that informed the preparation of Regional Strategies may still be a material consideration in development management decisions and for informing DPD production so the ultimate revocation of the RSS should not affect this report or assessment. Table 2 below outlines the plans and projects that have been identified as relevant to the pathways for effects upon European sites. These include those that are considered likely to influence:
• Surface water or groundwater dynamics or quality within the catchment of Solent Maritime SAC, Chichester and Langstone Harbours SPA/Ramsar, Pagham Harbour SPA/Ramsar, Arun Valley SPA/Ramsar, Woolmer Forest SAC, and Ashdown Forest SAC/SPA; • Traffic along roads passing through or close to Ashdown Forest SAC/SPA, Duncton to Bignor Escarpment SAC, Singleton and Cocking Tunnels SAC, The Mens SAC, Ebernoe Common SAC, Solent Maritime SAC, Chichester and Langstone Harbours SPA/Ramsar, Wealden Heaths Phase 2 SPA, and Woolmer Forest SAC; • Bird or bat disturbance at The Mens SAC, Singleton and Cocking Tunnels SAC, Ebernoe Common SAC, Chichester and Langstone Harbours SPA/Ramsar, Pagham Harbour SPA/Ramsar, Arun Valley SPA/Ramsar, Wealden Heaths Phase 2 SPA and Ashdown Forest SPA; • Coastal dynamics at Solent Maritime SAC, Chichester and Langstone Harbours SPA/Ramsar, and Pagham Harbour SPA/Ramsar; • Possible land take or disturbance to important areas for birds using areas outside of the SPAs/Ramsar sites at Chichester and Langstone Harbours SPA/Ramsar, and Pagham Harbour SPA/Ramsar; and • The overall increase in population and thus recreational pressure and disturbance on European sites within West Sussex and neighbouring authorities. Table 2 - Other Plans and Projects and Relevant Potential Impacts
Plan / Project Relevance
Sets out the regional housing, employment and other The South East Plan: Adopted development allocations for the entire South East of Regional Spatial Strategy (RSS) England. While it has now been revoked, it still provides a (2009) and associated Habitats useful summary of planned development across the Regulations Assessments region. East Solent Shoreline Management Development of strategies for coastal management and Plan (1997) protection. Potentially relevant in terms of the effects of coastal squeeze on European designated sites
Draft North Solent Shoreline Development of strategies for coastal management and Management Plan (2010) protection. Potentially relevant in terms of the effects of coastal squeeze on European designated sites
Chichester Harbour AONB Sets out the strategy for management of the harbour. Management Plan 2009-2014
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Plan / Project Relevance Shoreham Harbour Joint Area Will set out detail of spatial strategy in the Shoreham Action Plan Harbour area; relevant in that it provides detail of development plans
Sets out the spatial strategy for Chichester including Chichester LDF Core Strategy housing; relevant in that it provides detail of development (Strategic Growth Options, 2009) plans Sets out the spatial strategy for Arun including housing; Arun LDF Core Strategy (Options relevant in that it provides detail of development plans for Growth, 2009) Sets out the spatial strategy for Horsham including Horsham LDF Core Strategy housing; relevant in that it provides detail of development (Adopted, 2007) plans
Sets out detail of spatial strategy for Horsham including Horsham LDF Site Specific housing; relevant in that it provides detail of development Allocations DPD (2007) plans
Sets out the spatial strategy for Worthing including Worthing LDF Core Strategy housing; relevant in that it provides detail of development (Publication Version, 2010) plans
Sets out the spatial strategy for Crawley including Crawley LDF Core Strategy housing; relevant in that it provides detail of development (Adopted, 2007) plans
Sets out the spatial strategy for Mid-Sussex including Mid-Sussex LDF Core Strategy housing; relevant in that it provides detail of development (Pre-Submission Document, 2008) plans
Sets out the spatial strategy for Brighton and Hove Brighton and Hove Core Strategy including housing; relevant in that it provides detail of (Submission, 2010) development plans
Wealden LDF Core Strategy Sets out the spatial strategy for Wealden including (Spatial Development Options, housing; relevant in that it provides detail of development 2009) plans affecting Ashdown Forest SAC/SPA Sets out the spatial strategy for Havant including housing; Havant LDF Core Strategy relevant in that it provides detail of development plans (Submission, 2010) affecting Solent European Marine sites
Sets out the spatial strategy for East Hampshire including East Hampshire LDF Preferred housing; relevant in that it provides detail of development Policies (2009) plans affecting Wealden Heaths Phase 2 SPA and Woolmer Forest SAC
Hampshire Minerals and Waste Includes minerals and waste policies and locations Core Strategy (2007) East Sussex Minerals and waste Development Framework (Preferred Includes minerals and waste policies and locations Options, 2009)
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Plan / Project Relevance
Surrey Minerals Core Strategy and Primary Aggregates DPDs Includes minerals and waste policies and locations (Submission, 2010) and Waste Plan DPDs (Adopted, 2008)
Strategic framework for expansion of airport capacity in Aviation White Paper (2003) UK; relevant in that it defines airport growth and requires consideration for localised disturbance issues Onshore wind farms – operational Wind farms have potential to affect European sites during and in planning (as listed by British construction and operation Wind Energy Association) Sets out road schemes that could potentially affect traffic, Provisional West Sussex Local and therefore air quality, close to European designated Transport Plan (2011-2026) sites Set out transport schemes that could potentially affect Local transport Plans for traffic passing into and out of West Sussex, close to surrounding authorities European designated sites European site Management Plans Set out management strategies for designated sites (where available) Water Resource Management Define how demand for water resources will be met over Plans the lifetime of the MWDF Environment Agency Catchment Provide strategies to ensure water resource availability in Abstraction Management Strategies West Sussex and surrounding areas
Environment Agency Catchment Provide strategies to ensure flood risk management within Flood Management Plans West Sussex
Inform licensing strategies to prevent damage to Environment Agency Stage 3 and 4 European sites from adverse impacts of water resource Reviews of Consents depletion or reduction in water quality.
Provides strategies for water level management at Environment Agency Water Level Pulborough Brooks, Waltham Brooks, and Amberley Wild Management Plans Brooks
River Arun Tidal Abstraction Requires consideration of outcomes for water resources Scheme (Hardham) and water quality in relation to Arun Valley SPA/Ramsar
2.5.3 In addition to reviewing plans and projects that may interact with the West Sussex County Council MWDF, we will also make use of sources of information that provide information (but not plans) regarding European designated sites, including:
• Nature on the Map and its links to SSSI citations and the JNCC website (www.natureonthemap.org.uk); • The UK Air Pollution Information System (www.apis.ac.uk); and • Habitats Regulation Assessments of Local Development Framework Development Plan Documents where available
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2.6 Physical scope of the assessment
2.6.1 There is no pre-defined guidance that dictates the physical scope of a HRA of a Minerals and Waste Development Framework. Therefore, in considering the physical scope of the assessment, we were therefore guided primarily by the identified impact pathways rather than by arbitrary ‘zones’. However, it was considered advisable to ‘scope in’ all European sites in West Sussex for a first appraisal, plus those that lie close to the borders of the area. These have been listed in section 1.2.6 of this report and the interest features of all these sites are detailed in Appendix 2 along with the key environmental conditions necessary to maintain the integrity of the sites.
2.6.2 Outside of West Sussex, the following sites lie within a close distance, and are connected by potential pathways of impact, so that they are considered as part of this HRA:
• Ashdown Forest SAC/SPA (adjacent to West Sussex and East Sussex border); • East Hampshire Hangers SAC (in Hampshire, within 3km of West Sussex); and • Woolmer Forest SAC (in Hampshire, within 2km of West Sussex).
2.6.3 Information available from Natural England and the Joint Nature Conservation Committee provides a good introduction to the reasons for the designation of the European sites. This has been supplemented by information gained during consultation with the relevant agencies, notably Natural England and the Environment Agency. This information has informed the site descriptions in Appendix 2.
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3 Pathways of impact
3.1 Introduction
3.1.1 This section of the report summarises the various impact pathways that can link Minerals and waste development in West Sussex with European sites.
3.2 Atmospheric pollution
3.2.1 Current levels of understanding of air quality effects on semi-natural habitats are not adequate to allow a rigorous assessment of the likelihood of significant effects on the integrity of key European sites.
3.2.2 The National Expert Group on Trans-boundary Air Pollution (2001)3 concluded that:
• In 1997, critical loads for acidification were exceeded in 71% of UK ecosystems. This was expected to decline to 47% by 2010.
• Reductions in SO2 concentrations over the last three decades have virtually eliminated the direct impact of sulphur on vegetation. • By 2010, deposited nitrogen was expected to be the major contributor to acidification,
replacing the reductions in SO2. • Current nitrogen deposition is probably already changing species composition in many nutrient-poor habitats, and these changes may not readily be reversed. • The effects of nitrogen deposition are likely to remain significant beyond 2010. • Current ozone concentrations threaten crops and forest production nationally. The effects of ozone deposition are likely to remain significant beyond 2010. • Reduced inputs of acidity and nitrogen from the atmosphere may provide the conditions in which chemical and biological recovery from previous air pollution impacts can begin, but the timescales of these processes are very long relative to the timescales of reductions in emissions.
3.2.3 Grice et al4 5 do however suggest that air quality in the UK will improve significantly over the next 15 years due primarily to reduced emissions from road transport and power stations.
3.2.4 Waste sites (particularly incinerators and landfill sites) can contribute substantially to the atmospheric pollution load through emission of the following pollutants:
3 National Expert Group on Transboundary Air Pollution (2001) Transboundary Air Pollution: Acidification, Eutrophication and Ground-Level Ozone in the UK 4 Grice, S., T. Bush, J. Stedman, K. Vincent, A. Kent, J. Targa and M. Hobson (2006) Baseline Projections of Air Quality in the UK for the 2006 Review of the Air Quality Strategy, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland. 5 Grice, S., J. Stedman, T. Murrells and M. Hobson (2007) Updated Projections of Air Quality in the UK for Base Case and Additional Measures for the Air Quality Strategy for England, Scotland, Wales and Northern Ireland 2007, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland.
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• Methane (CH4) - Methane is produced when organic matter is broken down in the absence of oxygen and large quantities are produced by livestock, the spreading of animal manure and landfill sites. Waste treatment, including landfill, released nearly 22% of the UK's methane emissions in 2003, about 2% of all greenhouse gas emissions (in terms of carbon equivalents)6.
• Carbon Dioxide (CO2) - Carbon dioxide is one of the major combustion products from burning fossil fuels. It is also produced in certain non-combustion chemical reactions, for instance in the manufacture of cement. Carbon dioxide is a long-lived pollutant and will remain in the atmosphere for between 50 and 200 years. Carbon dioxide contributes to the greenhouse effect7. • Oxides of Nitrogen (NOx) - Oxides of nitrogen are formed during high temperature combustion processes from the oxidation of nitrogen in the air. The principal source of oxides of nitrogen is road traffic, which is responsible for approximately half the emissions in Europe8. NOx concentrations are therefore greatest in urban areas where traffic is heaviest. An increase in the deposition of nitrogen from the atmosphere to soils is generally regarded to lead to an increase in soil fertility, which can have a serious deleterious effect on the quality of semi-natural, nitrogen-limited terrestrial habitats. High NOx levels can also have directly toxic effects on plants.
• Ammonia (NH3) – This is probably the major source of nitrogen deposition to many wildlife sites, and is primarily agricultural in origin9, although it is also produced through some industrial process and by the composting of organic matter on waste sites.
• Sulphur dioxide (SO2) – this is an acidic gas that combines with water vapour in the atmosphere to produce acid rain. Both wet and dry depositions have been implicated in the damage and destruction of vegetation and in the degradation of soils and watercourses. Major SO2 problems now only tend to occur in cities in which coal is still widely used for domestic heating, in heavy industry and in power stations10.
• Low-level ozone (O3) – this is unlike the other pollutants mentioned, in that it is not emitted directly into the atmosphere, but is a secondary pollutant produced by a complex reaction 11 between nitrogen dioxide (NO2), hydrocarbons and sunlight . Unlike the other pollutants, it cannot therefore be directly related to increases in housing, traffic etc. Although peak levels of ozone are generally reducing, annual average levels are generally increasing. • Hydrogen chloride and hydrogen fluoride (HCl and HF) – Both of these chemicals are produced in small amounts as a result of certain energy from waste facilities, principally incineration. HF is the most phytotoxic of all air pollutants. It accumulates in very high concentrations in the margins of leaves. In sensitive species this may lead to distortion of the leaf shape, chlorosis (yellowing), red colouration and, in extreme cases, death of
6 Environment Agency website 7 UK Air Pollution Information System www.apis.ac.uk 8 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 9Institute of Grassland and Environmental Research http://www.iger.bbsrc.ac.uk/Ammonia_Inventory/sources.htm 10 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 11 UK Air Pollution Information System www.apis.co.uk
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tissues. HCl can also have local, direct, effects on plants, but there is little information available about dose-response relations12. • Dioxins - These are long-lived organic compounds, which form when chlorinated substances in the waste, such as PVC plastic, are burnt and accumulate in the human food chain. Dioxin emissions to air from incinerators are thought to have decreased significantly in recent years. Four sources account for 74% of the total air emissions. These are legal municipal waste incineration (26%), sinter plants (18%), residential wood combustion (boilers, stoves, fireplaces, 16%) and incineration of hospital waste (14%). The incineration of hazardous industrial waste contributes less than 1%.13 • Heavy metals – specifically Cadmium (Cd), which is a normal constituent of soil and water at low concentrations. The main sources of cadmium emissions are from waste incineration, and iron and steel manufacture14. Cadmium and other heavy metals are mainly present in the ash produced by incinerators, but some is released directly to atmosphere via the exhaust stack. Emissions of cadmium have declined substantially over recent years; this is mainly attributable to the decline in coal combustion to generate power. Environmentally, cadmium is dangerous because many plants and some animals absorb it easily and it becomes concentrated in tissues.
3.2.5 Migration of landfill gas outside the perimeter of landfill sites taking biodegradable waste can occur, but only where sites have been inadequately engineered. In such circumstances the gas will exclude oxygen from the soil and lead to the exposure and possible death of plants and soil fauna. Such effects are unlikely beyond a 0.5km radius15 in any case, but since they are a result of poor engineering design, and any current landfill sites will be required to conform to all modern authorisations, they are not considered further in this assessment.
3.2.6 For the following reasons, only NOx and ammonia are considered further as specific pollutants in this assessment:
• Despite the general association with nitrogen dioxide, ozone levels are not as high in urban areas (where high levels of nitrogen dioxide are emitted) as in rural areas. This is largely due to the long-range nature of this pollutant, which is sufficiently great that the source of emission and location of deposition often cross national boundaries. As such, low-level ozone can only be practically addressed at the national and international level. • Although methane and carbon dioxide are important greenhouse gases, it is not possible to relate quantities of these gases to particular effects on specific European sites. It is therefore not possible to consider these within the scope of this Appropriate Assessment other than by noting that increased emission of these chemicals will contribute at a global scale to accelerating rates of climate change. • Sulphur dioxide concentrations are overwhelmingly influenced (82% of emissions16) by the output of power stations and industrial processes that require the combustion of coal and oil.
12 ERM. 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council 13 Chlorine Online Information Resource website http://www.eurochlor.org/upload/documents/document57.pdf 14 National Atmospheric Emissions Inventory www.aeat.co.uk/netcen/airqual/naei/annreport/annrep96/sect6_3.htm 15 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf 16 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php
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None of these activities will be associated with developments under the Minerals and Waste Development Framework and indeed the use of Energy from Waste technology will reduce
reliance on conventional power stations and therefore contribute to a reduction in SO2 emissions. • There is an enormous range in sensitivity to hydrogen chloride and hydrogen fluoride between species, and there are no commonly available critical levels for avoidance of visible injury to vegetation. Coupled with the fact that quantities emitted by incinerators will typically result in ground-level concentrations lower than the concentration that will harm vegetation17, these chemicals are not considered further in this assessment. • As with ozone, the distance from emission to deposition of dioxins can be many hundreds of miles, potentially crossing trans-national boundaries, and is dependent upon meteorological conditions. Most importantly, amounts of dioxins formed in incinerators do not depend on chlorine levels, but primarily on the design and operating temperatures of the facility18. It is therefore not possible to consider dioxin emissions in detail within this assessment. However, it is important to note that dioxins are only emitted by incineration and that incinerators are required by law to control their dioxin emissions below set thresholds.
3.2.7 Since ammonia is of relevance to European sites primarily through its effect upon nitrogen deposition, it is not considered independently of nitrogen deposition in this assessment. Since NOx can be directly toxic to plants, it is considered separately from its influence on nitrogen deposition in this assessment.
3.2.8 Eutrophication of sensitive habitats through atmospheric deposition is a widely acknowledged phenomenon, although it is extremely difficult to measure as its effects are often hidden by changes in local nutrients (i.e. via direct fertilisation) or changes in grazing pressure.
3.2.9 In well-managed sites, the effects of eutrophication may be to some extent counteracted through an increase in grazing pressure. Bobbink et al.19 suggest that sites with low intensity management may have lower critical thresholds than those in higher levels of management. Reintroducing grazing into ungrazed or under-grazed sites can help to counteract changes in vegetation due to nitrogen deposition; however increasing grazing on sites that are already well-grazed may have a direct adverse impact on the plants for which the site was designated. Moreover, the droppings of grazing animals will themselves contribute to nutrient enrichment, which must be taken into consideration to ensure that the presence of the livestock themselves does not negate the purpose of intensifying the management.
3.2.10 Furthermore, air pollution can act synergistically with insufficient grazing to exacerbate management problems and lead to a coarser species-poor sward. A changing climate (i.e. rising temperatures and reduced summer rainfall) is further exacerbating the situation by putting sensitive habitats and species under increasing stress, in turn reducing their competitive ability and increasing susceptibility to pathogens.
17 ERM. January 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council 18 Chlorine Online Information Resource website. http://www.eurochlor.org/upload/documents/document57.pdf 19 Bobbink, Ashmore, Braun, Fluckiger and Vanden Wyngaert. 2002. Work on critical loads for natural and semi- natural systems (“Empirical nitrogen critical loads for natural and semi-natural ecosystems 2002 update”)
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Oxides of nitrogen and nitrogen deposition
3.2.11 The most acute impacts of NOx take place close to where they are emitted, but individual sources of pollution will also contribute to an increase in the general background levels of pollutants at a wider scale, as small amounts of NOx and other pollutants from the pollution source are dispersed more widely by the prevailing winds.
3.2.12 The main sources of NOx in the UK are20:
• Road and other transport (approximately 47%; greater in urban areas); • Public power generation using fossil fuels (22%). • Combustion in industrial processes21 (14%). • Domestic and commercial sources (4%), e.g. commercial boilers in schools, hospitals etc.
3.2.13 Therefore, when considering the ecologically relevant impacts of the Minerals and Waste Development Framework, by far the largest contribution to NOx will generally be made by the associated road traffic.
3.2.14 The following air pollution limit value applies for the protection of vegetation and ecosystems from NOx:
• World Health Organisation 30 μgm-3 annual average; EU Air Quality Framework Directive 30 μgm-3 annual average away from areas close to main roads, built up areas or major industrial sites; Natural England policy in agreement with the Environment Agency in their Review of Consents process is that the 30 μgm-3 threshold should apply to all designated sites, due to the sensitivity of the habitats within the sites.
Transport exhaust emissions
3.2.15 In an appropriate assessment of potential impacts of proposed waste facility sites in Surrey, a dispersion model was used to quantify the effects of emissions from operational vehicles travelling to and from a theoretical incinerator. It was shown that at distances greater than 55 metres from the kerbside, ground level concentrations of NOx represent less than 1% of the critical level22. Inevitably however, the distance to which the pollutants will disperse depends upon the parameters of the model and prevailing meteorological conditions. Moreover, it is clear from other research that there is no such thing as a ‘typical’ waste site.
• The actual scale of heavy vehicle movement associated with waste facilities is entirely dependent upon both the type and scale of the facility, neither of which can be prescribed by the Waste Development Framework except at the broadest scale. It is therefore impossible to give meaningful “typical” values for waste sites. A review of a number of waste schemes23 identified that: • A Household Waste Recycling Centre may have very small numbers of heavy vehicle movements (4 per day) but can have a very large number of car movements associated with
20 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 21 Combustion of coal and oil, some refinery processes and the production of sulphuric acid and other chemicals 22 1% being the level defined in the EU Habitats Directive Handbook at which emissions are not likely to have a significant effect alone or in combination, irrespective of background levels 23 ERM. January 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council
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the general public bringing waste to the site – 150 cars per day at the site considered in the cited example; • Thermal Treatment and Energy from Waste facilities will generally have a much greater number of heavy vehicle movements (perhaps 100 to 200 per day) due to their generally large size, but will also have a much smaller number of cars travelling to the site, as they do not accept waste from the general public and are heavily automated; • Most other forms of waste treatment (including landfill) fall between these two extremes depending as much upon their size as their type; • The situation can become considerably more complex if various forms of waste treatment facility are co-located on the same site. The ERM (2007) study gathered data from one site that combined a Waste Transfer Station with a Household Waste Recycling Centre, which as a result showed both higher numbers of HGV traffic (66 per day) and public car traffic (up to 1,000 per day at peak times of the year) than either form of waste facility might be expected to attract individually.
3.2.16 It is clear from the above that the situation regarding vehicular exhaust emissions associated with waste treatment sites is considerably more complex than it might appear at face value. The only general conclusion that can be safely drawn is that all new waste sites are likely to result in a local increase in vehicle movements and that this increase may be greater where multiple types of waste treatment facility are provided in the same location. It is also true that the distance vehicles travel may be as important as the numbers or type of vehicle in contributing to deteriorating atmospheric deposition of European sites, if the route leads the traffic within close proximity of multiple European sites.
3.2.17 According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant” 24.
Figure 1 – Traffic contribution to concentrations of pollutants at different distances from a road (Source: DfT)
3.2.18 Given the difficulties in accurately determining and modelling likely scales of vehicle usage on sites for which all parameters must necessarily at this stage be wholly theoretical, it seems more in line with the precautionary principle to utilise the more cautious 200 m figure, rather than smaller figures that may have been derived from site-specific theoretical models.
24 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf
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3.2.19 This is therefore the distance that has been used throughout this report in order to determine whether European sites are likely to be significantly affected by development under the MWDF. There are eleven European sites within the scope of this assessment that lie within 200m of a main road that could serve as a transport route for waste or minerals traffic:
• Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC lie within 200m of the A27 (within Hampshire); • The Mens SAC lies within 200m of the A272 for a considerable distance. • Ebernoe Common SAC lies within 200m of the A283 for a short distance. • Singleton and Cocking Tunnels SAC lies within 200m of the A286 for a considerable distance. • Ashdown Forest SAC/SPA lies within 200m of the A22 and A275 (in East Sussex) for a considerable distance. • Duncton and Bignor Escarpment SAC lies within 200m of the A285 for a short distance. • Wealden Heaths Phase II SPA is bisected by the A3 (in Hampshire) for a considerable distance. • Woolmer Forest SAC lies within 200m of the A3 (in Hampshire) for a considerable distance.
3.2.20 The issue of cumulative vehicle exhaust emissions is clearly a collective one and no single minerals or waste site can be identified as being ‘responsible’. As such, the approach we have taken is to assume that air quality issues arising from vehicle exhaust emissions are relevant to the MWDF options covering the whole county, and not to individual waste or minerals sites.
Energy from Waste
3.2.21 While traffic makes the largest overall contribution to NOx, some individual point sources can also result in substantial increases in the local NOx concentration. Of those point sources associated with waste treatment, thermal treatment / Energy from Waste facilities25 have the potential to emit the greatest amounts, as any form of thermal treatment involves the emission of exhaust gases.
• For the purposes of this assessment we have not tried to model the emissions of a particular form of thermal treatment in order to estimate possible NOx emissions, for the following reasons: • It is not known at this stage which sites will support a thermal treatment facility or the scale of such a facility; • Incineration (mass burn) is currently the only thermal treatment technology that can be accurately modelled. Use of this technology can emit large quantities of NOx, but the NOx emissions of any form of incinerator, and their distances to deposition, are entirely dependent upon specific parameters of the facility (e.g. stack height). Since any incinerator modelled for this HRA would at this stage be based on entirely hypothetical parameters, the resulting model may in fact bear little relation to actual emissions from an incinerator at a given location;
25 Energy from Waste (or Waste to Energy) refers to those types of thermal treatment that incorporate energy recovery technology.
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• More importantly, while incineration is currently the most common form of Energy from Waste technology, the international drive to reduce pollutant emissions has resulted in the development of numerous alternative technologies (such as pyrolysis or gasification), which produce relatively little NOx26 27. At this stage it is unknown which technology will be utilised at the chosen site as this cannot be specified by the Minerals and Waste Development Framework. However, given that the Minerals and Waste Development Framework covers the period until 2026, it is possible that the form of technology adopted for the chosen site will involve gasification, pyrolysis or similar technology, rather than mass burn. Any modelling based upon conventional incineration technology would therefore be potentially unrepresentative.
3.2.22 Therefore, we have concluded that detailed modelling should await greater certainty about the nature of the proposed facility. This may therefore be more logically undertaken as part of the project-level Appropriate Assessment for any Energy from Waste Facility as the Minerals and Waste Development Framework will not identify a specific site for EfW but only a range of sites that are of sufficient size to be suitable for larger facilities (which would include EfW).
3.2.23 The Environment Agency guidance on screening point-source pollution emitters for more detailed assessment28 lists the presence of a SSSI or Natura 2000 site within 10km as one of the indicators that detailed assessment (i.e. dispersion-modelling) may be required for a planning application/IPCC consent. The implication of this is that the emissions of a point- source can normally be considered effectively inconsequential on sites located more than 10km distant. While this would not apply to major emitters such as large power stations, refineries and steel works, it would apply to smaller ones such as thermal waste treatment facilities.
3.2.24 For this HRA, we have therefore used the 10km figure as a basis on which to screen sites in and out of assessment regarding their possible use as a location for an Energy from Waste facility. If sites that may be suitable for EfW are located within 10km of a European site, they have been screened in for further consideration.
Landfill
3.2.25 A non-inert landfill gas flare (or utilisation engine) will produce an emission of exhaust gases such as sulphur dioxide, NOx, unburnt hydrocarbons, carbon monoxide and hydrogen chloride. However, the volume of exhaust gases is likely to be small in comparison to other combustion facilities and at a distance of >1km from the European site may well be inconsequential29. We have therefore used the 1km figure throughout this report as a basis on which to screen landfill sites in or out of assessment with regard to air quality issues.
26 “For a given secondary material, emission levels of SOx, NOx, and particulates from gasification systems are reduced significantly compared to incineration systems… Data for repowering of coal-fired electric utilities with IGCC technology has shown that emissions of SOx, NOx, and particulates are reduced by one to two orders of magnitude” Radian International LLC. 2000 A Comparison of Gasification and Incineration of Hazardous Wastes. Report produced for US Department of Energy National Energy Technology Laboratory. http://www.netl.doe.gov/publications/others/techrpts/igcc_wp.pdf 27 Some manufacturers of gasification technology claim the potential to reduce NOx emissions to <10 ppm. “The SOx, NOx, mercury, volatile metals, and particle emissions from a Solena IPGCC plant constitute a small fraction of those emissions from a … incinerator waste-to-energy plant.” Solena Group website www.solenagroup.com/html/images/fuelflexible.pdf 28 Environment Agency. 2003. Integrated Pollution Prevention and Control - Environmental Assessment and Appraisal of BAT. Horizontal Guidance Note IPPC H1 29 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance. http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf
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Other types of waste facility
3.2.26 Atmospheric emissions of NOx from other types of facility are negligible. For example, anaerobic digestion30 does result in the generation of biogas but not NOx. The emissions to the air are well controlled; some emissions may arise from biogas under positive pressure in the tank, but under normal operating conditions biogas is not released direct to air31. Equally, waste transfer stations32 and mechanical biological treatment33 plant can incorporate a number of different processes in a variety of combinations and can be built for various purposes, but air emissions and health impacts are most likely to be linked to traffic movements. In general therefore, the view has been taken in this report that waste sites other than landfill and Energy from Waste facilities are unlikely to have a significant air quality effect on European sites (other than through associated vehicle exhaust emissions).
Plant pathogen emissions
3.2.27 Some composting sites can result in the production of plant pathogens, which if released into the environment can result in adverse effects on vegetation within European sites located close to the facility. In previous work in Sussex we have agreed with Natural England a screening distance of 1km to be applied to such facilities. No composting sites will be situated within 1km of any European sites in West Sussex so this issue is not considered further.
Quarries and minerals sites
3.2.28 Atmospheric pollutants generated by minerals sites are more straightforward than with waste sites and generally resolve themselves into dust and traffic exhaust emissions. Vehicle exhaust emissions have already been discussed. Effects of dust will depend on the prevailing wind direction and the transport distance is related to particle size; large particles (>30um) will mostly deposit within 100m of the source, intermediate particles (10-30um) are likely to travel up to 200 - 500m. Smaller particles (<10um) can travel up to 1km from the source34. Dust size and chemical composition is important as smaller particles can enter or block stomata and thus interfere with gas exchange, while sufficient coverage may prevent light penetration to the chloroplasts. In prolonged cases, death can result.
3.2.29 Dust impacts will be considered further in this assessment, but cannot be quantified beyond the broad potential distances identified above for different particle sizes. For the purposes of HRA, those minerals sites that lie more than 500m from a European site have been ‘screened out’ as being unlikely to contribute significant dust impacts even without special mitigation such as ‘wetting’. For the purposes of this document we have not considered the impact of small particles (i.e. PM10) up to 1km from source since the effects of PM10 and tolerance limits for wildlife are often unknown and therefore cannot be readily assessed.
30 The biological treatment of biodegradable organic waste in the absence of oxygen, utilising microbial activity to break down the waste in a controlled environment 31 Defra. 2004. Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes. Defra Publication, London, UK 32 In which waste is transported from waste producers (industry, commerce and the general public) to be treated, recycled and/or disposed 33 A generic term for an integration of several processes commonly found in other waste management technologies, such as Materials Recovery Facilities, sorting and composting plant 34 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf
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Diffuse air pollution
3.2.30 In addition to the contribution to local air quality issues, development can also contribute cumulatively to an overall deterioration in background air quality across an entire region. In July 2006, when this issue was raised by Runnymede District Council in the South East, Natural England advised that their Local Development Framework ‘can only be concerned with locally emitted and short range locally acting pollutants’ 35 as this is the only scale which falls within a local authority remit. It is understood that this guidance was not intended to set a precedent, but it inevitably does so since (as far as we are aware) it is the only formal guidance that has been issued to a Local Authority from any Natural England office on this issue.
3.2.31 In the light of this and our own knowledge and experience, it is considered reasonable to conclude that diffuse pan-authority air quality impacts are the responsibility of National Government, both since they relate to the overall quantum of development within a region or country (over which individual counties have little control), and since this issue is best addressed at the highest pan-authority level. Diffuse air quality issues will not therefore be considered further within this HRA.
3.3 Water quality and flows
3.3.1 The quality of the water that feeds European sites is an important determinant of the nature of their habitats and the species they support. Poor water quality can have a range of environmental impacts:
• At high levels, toxic chemicals and metals can result in immediate death of aquatic life, and can have detrimental effects even at lower levels, including increased vulnerability to disease and changes in wildlife behaviour. • Eutrophication, the enrichment of plant nutrients in water, increases plant growth and consequently results in oxygen depletion. Algal blooms, which commonly result from eutrophication, increase turbidity and decrease light penetration. The decomposition of organic wastes that often accompanies eutrophication deoxygenates water further, augmenting the oxygen depleting effects of eutrophication. In the marine environment, nitrogen is the limiting plant nutrient and so eutrophication is associated with discharges containing available nitrogen. • Some pesticides, industrial chemicals, and components of sewage effluent are suspected to interfere with the functioning of the endocrine system, possibly having negative effects on the reproduction and development of aquatic life.
3.3.2 Water quality may be adversely affected by waste sites through:
• Pollution through water runoff from hard surfaces carrying oils, heavy metals and/or de-icing compounds. While these effects can be dispersed throughout the downstream water catchment, they will be most visibly manifested within tens of metres to a few hundred metres of the site36; and
35 English Nature (16 May 2006) letter to Runnymede Borough Council, ‘Conservation (Natural Habitats &c.) Regulations 1994, Runnymede Borough Council Local Development Framework’. 36 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance. http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf
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• Discharges of leachate from landfill sites can add ammonia, other nutrients and chemical pollutants to surface water bodies. Leachate can also penetrate groundwater. Leachate can escape from landfill sites by leakage through a barrier / containment system, ‘break out through a cap, or overtopping containment.
3.3.3 There are several ways in which quarrying / mining can affect water quality/resources:
• Quarries and mines that are below the water table will require dewatering on a regular basis. Dewatering37 can lead to a reduction in the water table and “draw down” from hydraulically linked groundwater dependent habitats (including streams and rivers); • The physical presence of a new quarry in the unsaturated zone (i.e. above the water table) can increase the possibility of aquifer contamination and result in a direct reduction in temporary groundwater storage capacity; • If the water that is pumped from a quarry as a result of dewatering has a high proportion of clays and suspended particles, or is contaminated with metals, it can reduce water quality within those watercourses that receive the water; and • Backfilling a dormant quarry with overburden or imported fill may cause changes to groundwater levels, quality and flow paths in adjoining areas.
3.3.4 In or near West Sussex there are four European sites that have a particular hydrological sensitivity (with the exception of Arun Valley, this is essentially associated with maintaining high quality flows of freshwater into the estuarine sites):
• Solent Maritime SAC • Chichester and Langstone Harbours SPA/Ramsar; • Pagham Harbour SPA/Ramsar; and • Arun Valley SPA/Ramsar Woolmer Forest SAC and Ashdown Forest SAC also contain habitat features that are sensitive to changes in water resources and water quality.
3.4 Predation
3.4.1 In addition to disturbance due to activities taking place on site, landfill sites can attract large numbers of gulls and corvids (members of the crow family) and rats, which can disturb and prey on the young of bird species for which Special Protection Areas and/or Ramsar sites have been designated. In the case of West Sussex, this is of relevance to the following sites, which were designated at least in part for their populations of breeding birds:
• Chichester & Langstone Harbours SPA and Ramsar site; • Pagham Harbour SPA/Ramsar; • Ashdown Forest SPA; and • Wealden Heaths SPA
37 Dewatering is most commonly carried out by intermittent pumping from a sump located in the deepest part of the quarry, to keep pace with the inflow of groundwater.
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3.4.2 Environment Agency and Scottish Environmental Protection Agency guidance indicate that 5km is the limit within which gull predation associated with landfill sites may be an issue for designated sites with breeding birds (particularly ground nesting species). As such, for this report, landfill site locations have been screened in for further assessment if they lie within 5km of the sites listed in 3.4.1.
3.5 Disturbance
3.5.1 Waste sites can share many noise and visual disturbance issues (e.g. heavy vehicle movements and loud machinery) with other industrial operations. Birds are the faunal group that is most often considered in relation to disturbance, largely as this is the group on which disturbance impacts have been most studied.
3.5.2 Concern regarding the effects of disturbance on birds stems from the fact that they are expending energy unnecessarily and the time they spend responding to disturbance is time that is not spent feeding38. Disturbance therefore risks increasing energetic output while reducing energetic input, which can adversely affect the ‘condition’ and ultimately survival of the birds In addition, displacement of birds from one feeding site to others can increase the pressure on the resources available within the remaining sites, as they have to sustain a greater number of birds.39 Moreover, the more time a breeding bird spends disturbed from its nest, the more its eggs are likely to cool and the more vulnerable they are to predators.
3.5.3 Human activity can affect birds either directly (e.g. through causing them to flee) or indirectly (e.g. through damaging their habitat). The most obvious direct effect is that of immediate mortality such as death by shooting, but human activity can also lead to behavioural changes (e.g. alterations in feeding behaviour, avoidance of certain areas etc.) and physiological changes (e.g. an increase in heart rate) that, although less noticeable, may ultimately result in major population-level effects by altering the balance between immigration/birth and emigration/death.40
3.5.4 The degree of impact that varying levels of noise will have on different species of bird is poorly understood except that a number of studies have found that an increase in traffic levels on roads does lead to a reduction in the bird abundance within adjacent hedgerows - Reijnen et al (1995) examined the distribution of 43 passerine species (i.e. ‘songbirds’), of which 60% had a lower density closer to the roadside than further away. By controlling vehicle usage they also found that the density generally was lower along busier roads than quieter roads41.
3.5.5 Activity will often result in a flight response (flying, diving, swimming or running) from the animal that is being disturbed. This carries an energetic cost that requires a greater food intake. Relatively little detailed research has been conducted concerning the energetic cost to wildlife of disturbance, but such evidence as exists indicates a significant negative effect.
38 Riddington, R. et al. 1996. The impact of disturbance on the behaviour and energy budgets of Brent geese. Bird Study 43:269-279 39 Gill, J.A., Sutherland, W.J. & Norris, K. 1998. The consequences of human disturbance for estuarine birds. RSPB Conservation Review 12: 67-72 40 Riley, J. 2003. Review of Recreational Disturbance Research on Selected Wildlife in Scotland. Scottish Natural Heritage. 41 Reijnen, R. et al. 1995. The effects of car traffic on breeding bird populations in woodland. III. Reduction of density in relation to the proximity of main roads. Journal of Applied Ecology 32: 187-202
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3.5.6 Quarrying and mining share many noise and visual disturbance issues (e.g. heavy vehicle movements and loud machinery) with other industrial operations; however, quarrying can also result in disturbance through the controlled blasting of rock in order to extract it for processing. This can result in ground vibration that can be perceived a considerable distance from the point of blasting. In addition, the shockwaves will travel through the air (known as overpressure) and, if the blasting takes place near water, the shockwaves can be perceived at even greater distances.
3.5.7 Disturbing activities are on a continuum. The most disturbing activities are likely to be those that involve irregular, infrequent, unpredictable loud noise events, movement or vibration of long duration. Birds are least likely to be disturbed by activities that involve regular, frequent, predictable, quiet patterns of sound or movement or minimal vibration. The further any activity is from the birds, the less likely it is to result in disturbance.
3.5.8 The factors that influence a species response to a disturbance are numerous, but the three key factors are species sensitivity, proximity of disturbance sources and timing/duration of the potentially disturbing activity.
Sensitivity of species (birds)
3.5.9 The distance at which a species takes flight when approached by a disturbing stimulus is known as the ‘tolerance distance’ (also called the ‘escape flight distance’) and differs between species to the same stimulus and within a species to different stimuli. No data could be sourced on the tolerance distances of birds in response to waste or minerals sites specifically, although the regular mechanized noise that is associated with minerals and waste sites is likely to be less disturbing that the presence of visible human activity in areas in which the birds are not used to observing such activity.
3.5.10 Five European sites in or near West Sussex have been designated at least in part for their bird interest:
• Chichester and Langstone Harbours SPA/Ramsar; • Pagham Harbour SPA/European Marine site/Ramsar; • Wealden Heaths Phase 2 SPA; • Ashdown Forest SPA; and • Arun Valley SPA/Ramsar
3.5.11 The following SACs were designated at least in part for the presence of maternity or hibernation roosts of bat species, which are also vulnerable to disturbance:
• Singleton and Cocking Tunnels SAC; • The Mens SAC; and • Ebernoe Common SAC.
3.5.12 For the purposes of HRA we have used the precautionary distance of 1km as a basis on which to screen minerals and waste sites in or out of consideration with regard to the potential for disturbance (i.e. noise and visual) impacts.
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3.6 Coastal Squeeze
3.6.1 Rising sea levels can be expected to cause intertidal habitats (principally saltmarsh and mudflats) to migrate landwards. However, in built-up areas, such landward retreat is often rendered impossible due the presence of the sea wall and other flood defences.
3.6.2 In addition, development frequently takes place immediately behind the sea wall, so that the flood defences cannot be moved landwards to accommodate managed retreat of threatened habitats. The net result of this is that the quantity of saltmarsh and mudflat adjacent to built-up areas will progressively decrease as sea levels rise. This process is known as ‘coastal squeeze’. In areas where sediment availability is reduced, the 'squeeze' also includes an increasingly steep beach profile and foreshortening of the seaward zones.
3.6.3 Minerals and waste sites can contribute to coastal squeeze as much as any other development by restricting opportunities for managing realignment. This impact is relevant to sections of the Essex coastline, which are designated as SAC, SPA and Ramsar sites. Additionally, minerals sites located near habitats where a balance of saline and fresh water is critical have the potential to affect flows through processes such as dewatering, leading to impacts such as reduced freshwater flows to estuaries and saline intrusion.
3.6.4 The Shoreline Management Plan for North Solent is currently out for consultation. An HRA of the draft plan42 indicated that for Chichester and Langstone Harbours there would be a combination of ‘Hold the Line’, ‘Managed Realignment’ and ‘Adaptive Management.’ Hold the Line will have no effect on habitats behind the defences, whilst managed realignment was likely to “have a significant detrimental effect resulting in loss of designated terrestrial habitats including coastal grazing marsh, saline lagoons and grasslands.” With regard to Pagham Harbour, a Managed Realignment Scheme is being developed by the Environment Agency for Medmerry to provide for the retention of coastal habitat. Conclusions for the Solent Maritime SAC were that No Active Intervention policies are likely to have “a significant detrimental effect on habitats on both sides of defences through either coastal squeeze resulting from redundant defences or saline intrusion of habitats previously protected by defences.”
3.6.5 The following sites in West Sussex are currently suffering from, or potentially threatened by coastal squeeze, saline intrusion or altered coastal processes:
• Solent Maritime SAC; • Chichester and Langstone Harbours SPA/Ramsar; and • Pagham Harbour SPA/Ramsar.
3.6.6 At present there are no minerals or waste sites under consideration in the MWDF that could lead to likely significant effects on the European designated sites listed in 3.6.5 through coastal squeeze, saline intrusion or altered coastal processes. Therefore, these processes are not considered further in this report.
3.7 Direct landtake
3.7.1 Issues of direct landtake from terrestrial European sites generally relate to existing permissions (often associated with mineral extraction) that were granted prior to the designation of the site
42 http://www.northsolentsmp.co.uk/media/adobe/o/2/Appendix_J_-_Appropriate_Assessment_(draft).pdf
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and which have not yet reached completion. In some cases, the process of mineral extraction can be partly responsible for creating the interest of the European site in the first place. This is partly the case with Dungeness SAC and Dungeness to Pett Level SPA and Ramsar site in East Sussex where former mineral workings now form important lagoon habitat. At this stage we have not identified any European sites that may be subject to direct landtake as a result of minerals operations in West Sussex.
3.7.2 In addition to direct landtake from European sites, those sites which are designated for highly mobile species can also be adversely affected by loss of habitat (or in the case of bats disruption of commuting routes) outside the SAC boundary itself. In West Sussex, this applies principally to Ebernoe Common SAC and The Mens SAC.
3.7.3 Ebernoe Common is an exceptional site for both barbastelle and Bechstein bats. Most of what is known about the foraging behaviour of barbastelle bats has been derived by studies carried out over the past ten years, and the studies are able to give detailed information on flight lines surrounding Ebernoe Common of the barbastelle bat:
• Greenaway, F. (2004) Advice for the management of flightlines and foraging habitats of the barbastelle bat Barbastellus barbastellus. English Nature Research Report, Number 657. • Greenaway, F. (2008) Barbastelle bats in the Sussex West Weald 1997 - 2008
3.7.4 The Mens SAC is also important for its barbastelle populations and radio-tracking studies have been undertaken to identify core foraging areas. These reports have identified that:
• The barbastelles of The Mens SAC forage to the east of the SAC, principally on the floodplain of the river Arun from close to Horsham in the north to Parham in the south. They also cross to the Adur floodplain. In some cases the bats travelled up to 7km to visit foraging areas; • The barbastelles at Ebernoe Common SAC had flightlines that followed watercourses, particularly the river Kird, and woodland cover for distances of typically 5km. Flightlines outside the SAC are particularly to the south (the Petworth and Tillington area) but also to the west, north and east.
3.7.5 There has been less study of the Bechstein bat populations. However, those radio-tracking projects which have been implemented for the species have established that the tracked individuals generally remained within approximately 1.5 km of their roosts43. These distances do fit with those identified from radio-tracking of Bechstein’s that has been undertaken at Ebernoe Common SAC from 2001, which identified that the maximum distance travelled by a tagged Bechstein's bat to its foraging area was 1,407m, with the average 735.7m44.
43 Cited in: Schofield H & Morris C. 2000. ‘Ranging Behaviour and Habitat Preferences of Female Bechstein’s Bats in Summer’. Vincent Wildlife Trust 44 Fitzsimmons P, Hill D, Greenaway F. 2002. Patterns of habitat use by female Bechstein’s bats (Myotis bechsteinii) from a maternity colony in a British woodland
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3.8 Screening distance summary
3.8.1 The table below summarises the screening distances used for each source of impact.
Table 3 – Screening distances used for each source of impact
Pathway Screening distance
Air quality – Energy from Waste 10km from European site
5km from The Mens SAC or 7km from Ebernoe Common SAC with regard to barbastelles (1.5km for Bechstein bats on Ebernoe Direct landtake Common SAC) and suitable habitat for foraging barbastelles and Bechstein’s present on site Gull/corvid predation (non-inert 5km from European site supporting sensitive ground-nesting landfill only) breeding species (e.g. terns) Air quality – landfill gas flares 1km from European site Air quality – plant pathogens 1km from European site (composting only) 1km from European site supporting disturbance sensitive Disturbance (noise/visual) species/populations Air quality - dust 500m from European site Air quality – vehicle exhaust 200m from European site emissions Water quality and flows No standard distance – use Source/Pathway/Receptor approach
Coastal squeeze No standard distance – evaluate on case by case basis
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4 Appropriate Assessment of Minerals Sites
4.1.1 This chapter considers each minerals site that was identified as requiring Appropriate Assessment following initial screening (the screened out sites are summarised in Appendix 3). The geographical relationship between European designated sites and proposed minerals sites is shown on Figure 3a that accompanies this report. Sites are grouped together where the potential impact pathways and European sites identified in the HRA screening report are identical. The outcome of the screening assessment (which was the subject of a separate report) is summarised first and then an Appropriate Assessment is undertaken.
4.1.2 Any quarry extension could lead to drawdown from dewatering operations. It is an issue that is too detailed and site-specific to be considered in depth at this level (as the impacts are entirely linked not only to the location of sites but to their relation to the water table and the volume/rate and timing of de-watering operations which will only be known once an application is made). However, all quarry operators should be aware of this possible issue.
4.2 M/CH/1A (Woodmancote), M/CH/1B (Common Road West), M/CH/1C (Common Road East), M/CH/1D (Slades Field) Summary of screening
Site Site name Location Mineral Status HRA Screening (green= screened out, amber number =screened in for Appropriate Assessment) on Figure 3a 27 Woodmancote Chichester Sharp sand Inactive These four sites all lie approximately 3km from and gravel (part of site Kingley Vale SAC, Solent Maritime SAC and, (concreting has been Chichester and Langstone Harbours SPA/Ramsar. aggregate) worked) There is no scope for adverse impacts on Kingley 4 Common Road Chichester Sharp sand Inactive Vale SAC. However it is assumed quarry traffic will West and gravel (not yet use the A27 which lies within 200m of Solent worked) Maritime SAC and Chichester and Langstone 3 Common Road Chichester Sharp sand Inactive Harbours SPA/Ramsar. East and gravel (not yet (concreting worked) Although brent geese (for which the SPA/Ramsar is aggregate) designated) use land immediately adjacent to the A27 as a high tide roost this land is already subject 22 Slades Field Chichester Sharp sand Inactive to considerable vehicle movements and it is and gravel (not yet unlikely that additional traffic from the working of (concreting worked) this minerals site would significantly alter the aggregate) disturbance to which the geese are exposed.
The possibility of adverse effects due to exhaust emissions requires investigation and should be informed by estimates of the likely increase in vehicle movements on the A27 as a result of the minerals and waste development covered in the Core Strategy.
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Appropriate Assessment
4.2.1 The screening exercise identified that air quality was a pathway requiring consideration with regard to these proposed minerals sites due to the potential for increased minerals traffic movements within 200m of European designated sites. However, within West Sussex the Solent Maritime SAC and Chichester and Langstone Harbours SPA/Ramsar do not lie within 200m of the A27 on which vehicle movements are almost certain to occur. The closest distance between the A27 and the SAC/SPA/Ramsar sites is found at the head of Fishbourne Channel, which lies 450m from the road.
4.2.2 The background papers to the MWDF indicate that “no information on the forecast of…minerals imported or exported into West Sussex is available,” although the adopted Hampshire Minerals and Waste Core Strategy does not identify any need for importation of sand and gravel from West Sussex. However, discussions between the Council and Natural England have identified that a precautionary approach should be taken and it should not be assumed based on this that there is no likelihood of minerals traffic using the A27 to transport minerals through Hampshire, where the road does pass within 200m of designated sites.
4.2.3 It is therefore concluded that these proposed minerals sites will not have adverse effects on air quality at any European designated sites within Sussex, but that the transport assessments for these minerals sites should take into account any impacts on sites in Hampshire if there will be a significant increase in vehicle movements on the A27.
4.3 M/CH/7A (West Heath Common Extension) and M/CH/7B (East of West Heath Common) Summary of screening
Site Site name Location Mineral Status HRA Screening (green= screened out, amber number on =screened in for Appropriate Assessment) Figure 3a 23 West Heath Chichester Soft sand Inactive Common (building (not yet These two sites lie approximately 6km from Wealden Extension sand) worked) Heaths Phase II SPA and East Hampshire Hangers SAC.
Assuming quarry traffic uses the A3 via A272, there is potential for an impact pathway via traffic emissions to the Wealden Heaths Phase II SPA so this site has been screened in for further consideration.
Furthermore both sites lies adjacent to a watercourse 21 East of West Chichester Soft sand Inactive that drains to the river Rother and ultimately into the Heath (building (not yet Arun Valley SPA/Ramsar. There is therefore a Common sand) worked) potential pathway for sediment to impact this European site.
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Appropriate Assessment
4.3.1 The screening exercise identified that air quality was a pathway requiring consideration with regard to these proposed minerals sites, due to potential for increased traffic volumes within 200m of European designated sites. However, the only possible impacts on the Wealden Heaths Phase 2 SPA or Woolmer Forest SAC would arise from traffic movements on the A3 in Hampshire. The background papers to the MWDF indicate that “no information on the forecast of…minerals imported or exported into West Sussex is available,” although the adopted Hampshire Minerals and Waste Core Strategy does not identify any need for importation of sand and gravel from West Sussex. However, discussions between the Council and Natural England have identified that a precautionary approach should be taken and it should not be assumed based on this that there is no likelihood of minerals traffic using the A3.
4.3.2 Based on current information there is no reason to conclude that these proposed minerals sites will have adverse effects on air quality at any European designated sites but transport assessments undertaken for this site should take into account any impacts on Wealden Heaths Phase 2 SPA or Woolmer Forest SAC if there will be a significant increase in vehicle movements on the A3 within 200m of those sites.
4.3.3 The screening process identified the potential for impacts on the Arun Valley SPA/Ramsar through reduced water quality as a result of sediment deposition. However, these sites lie almost 25km from the Arun Valley SPA/Ramsar, such that any increase in sediment that might arise from dewatering associated with this minerals site would be subject to such a scale of dilution that its effect on the SPA/Ramsar site would be negligible, particularly since the main channel of the River Arun does not form part of the SPA/Ramsar site. Moreover, it is assumed that sediment loading in watercourses near the site will be controlled by conditions since it is an offence to pollute surface watercourses irrespective of whether they drain to a European site or not.
4.3.4 It can therefore be concluded that there are adequate safeguards in place to ensure that the proposed minerals sites will not have adverse effects on water quality at any European designated sites.
4.3.5 It is understood that M/CH/7A (West Heath Common Extension) has recently been granted planning permission and it can therefore be assumed that any issues relating to European sites were considered and resolved.
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4.4 M/CH/8A (Minsted West) Summary of screening
Site Site Location Mineral Status HRA Screening (green= screened out, amber =screened in number on name for Appropriate Assessment) Figure 3a 16 Minsted Chichester Soft Inactive West sand (not yet This site lies approximately 6km from Singleton and Cocking worked) Tunnel SAC. There is no scope for adverse impacts on this European site.
However, the site does lie adjacent to a watercourse that drains to the river Rother and ultimately into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment impacts so this site has been screened in for further consideration.
Appropriate Assessment
4.4.1 The proposed minerals site is approximately 200m from a stream that flows 2-3km into the River Rother. The Rother at this point is 15-20km from the Arun Valley SPA/Ramsar site (the Rother feeds into the River Arun). As such any increase in sediment that might arise from dewatering associated with this minerals site would be subject to such a scale of dilution that its effect on the SPA/Ramsar site would be negligible, particularly since the main channel of the River Arun does not form part of the SPA/Ramsar site. Moreover, it is assumed that sediment loading in watercourses near the site will be controlled by conditions since it is an offence to pollute surface watercourses irrespective of whether they drain to a European site or not.
4.4.2 It can therefore be concluded that there are adequate safeguards in place to ensure that minerals site CH/8A will not adverse effects on the Arun Valley SPA/Ramsar through reduced water quality.
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4.5 M/CH/10A – Duncton Common Summary of screening
Site Site Location Mineral Status HRA Screening (green= screened out, amber number name =screened in for Appropriate Assessment) on Figure 3a 7 Duncton Chichester Soft sand Inactive Common (concrete and (not yet This site lies approximately 2.3km from Duncton to Bignor building worked) Escarpment SAC. However, there is no pathway sand) connecting this site to the SAC.
The site also lies approximately 8km from the Mens SAC and 9km from Ebernoe Common SAC. Whilst the site contains large amounts of woodland it lies outside of the key foraging distance of Barbastelle and Bechstein bats from these European sites and therefore is not screened in for this pathway of impact.
A watercourse adjacent to the site drains into River Rother and into Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment to impact this European site.
Appropriate Assessment
4.5.1 The proposed minerals site includes a stream that flows 1km into the River Rother. The Rother at this point is approximately 9km from the Arun Valley SPA/Ramsar site (the Rother feeds into the Arun before this point). As such any increase in sediment that might arise from dewatering associated with this minerals site would be subject to such a scale of dilution that its effect on the SPA/Ramsar site would be negligible, particularly since the main channel of the River Arun does not form part of the SPA/Ramsar site. Moreover, it is assumed that sediment loading in watercourses near the site will be controlled by conditions in any case since it is an offence to pollute surface watercourses irrespective of whether they drain to a European site or not.
4.5.2 It can therefore be concluded that adequate safeguards are in place to ensure that minerals site CH/10A will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water quality.
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4.6 M/CH/11 – Horncroft Summary of screening
Site number Site Location Mineral Status HRA Screening (green= screened out, amber =screened on Figure 3a name in for Appropriate Assessment) 11 Horncroft Chichester Soft Inactive (not This site lies approximately 7km from Arun Valley sand yet worked) SPA/Ramsar via water courses (2.5km directly) and 3km from Duncton to Bignor Escarpment SAC.
A watercourse running through to the site drains into River Rother and into Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment to impact this European site.
Appropriate Assessment
4.6.1 The proposed minerals site includes a stream that flows 1km into the River Rother. The Rother at this point is approximately 6km from the Arun Valley SPA/Ramsar site (the Rother feeds into the Arun before this point). As such any increase in sediment that might arise from dewatering associated with this minerals site would be subject to such a scale of dilution that its effect on the SPA/Ramsar site would be negligible, particularly since the main channel of the River Arun does not form part of the SPA/Ramsar site. Moreover, it is assumed that sediment loading in watercourses near the site will be controlled by conditions since it is an offence to pollute surface watercourses irrespective of whether they drain to a European site or not.
4.6.2 It can therefore be concluded that adequate measures are in place to ensure that minerals site CH/10A will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water quality.
4.7 M/HO/2 – Chantry Lane Extension Summary of screening
Site Site name Location Mineral Status HRA Screening (green= screened out, amber =screened number on in for Appropriate Assessment) Figure 3a 2 Chantry Horsham Soft Inactive This site lies approximately 5km from Arun Valley Lane sand (not yet SPA/Ramsar. A watercourse adjacent to the site drains into Extension worked) River Stor and into this European site. There is therefore a potential pathway for sediment to impact this European site.
4.7.1 The River Stor flows from adjacent to this site into the Arun Valley SPA/Ramsar some 5-6km distant. On route the River passes the settlement of Storrington and two treatment works. Input of water from the River Stor onto the SPA/Ramsar is only permitted through opening of sluice gates in very dry conditions as an ‘emergency measure,’ as the water quality within the River Stor is already poor. It is therefore clear that flows from the River Stor are not essential for the continued maintenance of the integrity of the SPA/Ramsar site.
4.7.2 It can therefore be concluded that minerals site HO/2 will not have an adverse effect on the Arun Valley SPA/Ramsar through reduced water flows or quality.
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4.8 M/MS/1 – Land Adjacent to West Hoathly Brickworks, M/MS/2 – Philpots Extension Summary of screening
Site Site name Location Mineral Status HRA Screening (green= screened out, number amber =screened in for Appropriate on Figure Assessment) 3a 13 Land Adjacent Mid- Wadhurst clay Inactive This site lies approximately 2km from to West Sussex (not yet Ashdown Forest SPA/SAC. It is assumed that Hoathly worked) site traffic will use the A22 which bisects this Brickworks SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site. 17 Philpots Mid- Architectural/building Inactive This site lies approximately 2km from Extension Sussex sandstone (not yet Ashdown Forest SPA/SAC. It is assumed that worked) site traffic will use the A22 which bisects this SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site.
Appropriate Assessment
Air quality
4.8.1 Although site traffic from these two sites could use the A22 south-bound, it is not necessarily the optimal route for transport of minerals for use within West Sussex, where transport via the M23 past Crawley may be more efficient. At this stage there is no certainty over which routes would be used.
4.8.2 Air Quality at Ashdown Forest SAC/SPA adjacent to the A22 according to the Site Relevant Critical Load available on APIS is 15.7 kg/N/ha/yr (as at 19th August for grid reference TQ419313) and the minimum critical load for the habitat present, wet and dry heathland, is 10 kg/N/ha/yr. Although Ashdown Forest is currently identified as being at risk from eutrophication this relates to agricultural runoff rather than atmospheric deposition.
4.8.3 Background levels of nitrogen deposition are above the critical load. Since the critical load will already be exceeded without additional traffic arising from minerals development in West Sussex (and since this must be considered within the context of additional nitrogen inputs from agricultural runoff) it cannot be concluded that, in the absence of mitigation, minerals and waste traffic using the A22 would not contribute to an overall ‘in combination’ adverse effect on the heathland interest features of the SAC (and therefore on those SPA interest features which depend upon heathland habitat) when considered ‘in combination’ with the additional traffic which the A22 will take as a result of 11,000 new homes to be delivered under the Wealden District Core Strategy and within the context of existing agricultural runoff. Additionally, policies within the emerging East Sussex and Brighton & Hove WMDF may result in minerals traffic past this SAC/SPA.
4.8.4 Therefore, at this stage, it is not possible to conclude that these minerals sites will not have an adverse effect on Ashdown Forest SAC/SPA when considered ‘in combination’ with other projects and plans. Further safeguards will therefore be required.
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Disturbance of SPA birds
4.8.5 Traffic increases on the A22 would have the potential to disturb bird species for which the SPA is designated. The findings of a recent visitor survey45 confirm that Ashdown Forest is a well used resource with a local (as opposed to tourist) catchment area of up to 13km. From the survey, annual visits to the Forest are estimated at around 1.35 million, which the study concluded, may well be a distinctly conservative estimate. The study found that 87% of these visits were made by motorised vehicle.
4.8.6 Although various studies have indicated that nightjars, Dartford warblers, and woodlarks, are all sensitive to disturbance, studies have tended to focus on recreational pressure rather than traffic-related disturbance. Given that access points to the SPA (i.e. car parks) are already a known focus for activity, it is reasonable to assume that any avoidance behaviour by these species will already be occurring as a result of recreational access. The effects of noise on bird species tend to operate on a continuum, such that unpredictable, loud noises would be expected to have greatest impact. Given that the A22 is already heavily used by traffic, including commercial heavy goods vehicles it is reasonable to conclude that any increased usage by minerals traffic from sites MS/1 and MS/2 will not result in significant additional noise compared to background levels and thus disturbance to birds for which the SPA is designated.
4.8.7 It can therefore be concluded that these minerals sites will not have any likely significant effects on any European designated sites through disturbance.
4.9 Recommendations
4.9.1 It can be seen that only two minerals sites (M/MS/1 – Land Adjacent to West Hoathly Brickworks and M/MS/2 – Philpots Extension) cannot be ruled out with regard to potential adverse effects on European sites, although a precautionary approach is also taken following the advice of Natural England, with regard to sites M/CH/1A (Woodmancote), M/CH/1B (Common Road West), M/CH/1C (Common Road East), M/CH/1D (Slades Field), M/CH/7A (West Heath Common Extension) and M/CH/7B (East of West Heath Common). This is a precautionary judgment and any effect will only be triggered when the minerals site is considered ‘in combination’ with other projects and plans. If it is intended to service M/MS/1 via the A22, or sites M/CH/1A, M/CH/1B, M/CH/1B or M/CH/1D will result in significant export of minerals along the A27 into Hampshire, or sites M/CH/7A and M/CH/7B will result in significant increase in vehicle movements within 200m of Wealden Heaths Phase 2 or Woolmer Forest SAC in Hampshire then it will be necessary for the site operator to demonstrate that either:
• The increase in vehicle movements on the A22 through Ashdown Forest SAC as a result of these minerals developments will amount to less than 200 Heavy Duty Vehicles/day46; or • The increase in vehicle movements will result in an increase in nitrogen deposition at the roadside within Ashdown Forest SAC amounting to less than 1% of the critical load47 for the most sensitive habitat within the site (i.e. an increase of less than 0.1 kgN/ha/yr); or
45 UE Associates (2009). Visitor Access Patterns on Ashdown Forest. 46 The Design Manual for Roads and Bridges (Volume 11, Section 3, Part 1) regarding air quality environmental impact assessment from roads indicates that if the increase in traffic will amount to less than 200 HDV movements per day the development can be scoped out of further assessment. 47 1% of the critical load being the criterion that the Environment Agency uses to determine when the contribution of a particular source of pollution will be effectively inconsequential even when considered ‘in combination’ with other projects and plans
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• If the increase in deposition will be greater than 1% of the critical load further assessment is undertaken to demonstrate that there will be no adverse affect on the integrity of the designated site.
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5 Minerals Sites Not Previously Screened
5.1.1 Four minerals sites have been brought forward for consideration since the original screening exercise was undertaken. These are therefore subject to a short screening appraisal below.
5.2 M/HO/6B - Rudgwick East and M/HO/6A - Rudgwick West Summary of screening
Site Site name Location Mineral Status HRA Screening (green= screened out, amber =screened in for number on Appropriate Assessment) Figure 3a 28 Rudgwick Horsham TBC TBC West These sites do not lie within 10km of any European designated site, and are not connected by any pathways of impact. Therefore 29 Rudgwick Horsham TBC TBC there is no potential for adverse effects on European sites. East
5.3 M/CH/8C - Severals West and M/CH/8D - Severals East Summary of screening
Site Site Location Mineral Status HRA Screening (green= screened out, amber =screened in for number on name Appropriate Assessment) Figure 3a 30 Severals Chichester TBC TBC These sites lie approximately 6km from Singleton and Cocking West Tunnel SAC. There is no scope for adverse impacts on this European site. 31 Severals Chichester TBC TBC East However, the sites do include a watercourse that drains to the river Rother and ultimately into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment impacts so this site has been screened in for further consideration.
Appropriate Assessment
5.3.1 The proposed minerals sites include a stream that flows 500m (CH/8C) and 2km (CH/8D) into the River Rother. However, the Rother at this point is 15-20km from the Arun Valley SPA/Ramsar site (the Rother feeds into the Arun before this point). It should be noted that the main channel of the River Arun does not form part of the SPA/Ramsar. As such any increase in sediment that might arise from dewatering associated with this minerals site would be subject to such a scale of dilution that its effect on the SPA/Ramsar site would be negligible, particularly since the main channel of the River Arun does not form part of the SPA/Ramsar site. Moreover, it is assumed that sediment loading in watercourses near the site will be controlled by conditions since it is an offence to pollute surface watercourses irrespective of whether they drain to a European site or not.
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5.3.2 It can therefore be concluded that minerals sites CH/8C and CH/8D will not have any likely significant effects on the Arun Valley SPA/Ramsar through reduced water flows or quality.
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6 Appropriate Assessment of Waste Sites
6.1.1 The following chapter considers each waste site that was identified as requiring Appropriate Assessment following initial screening (the screened out sites are summarised in Appendix 3). The geographical relationship between European designated sites and proposed waste sites is shown on Figure 3b that accompanies this report.
6.1.2 Sites are grouped together where the potential impact pathways and European sites identified in the HRA screening report are identical. The outcome of the screening assessment (which was the subject of a separate report) is summarised first and then an Appropriate Assessment is undertaken.
6.2 W/AR/4 – Blue Prince Mushroom Site
Screening Outcomes
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in for number Facility Appropriate Assessment) on Figure 3b 1 Blue Prince Arun Built waste This site lies approximately 8km from Arun Valley SPA/Ramsar Mushroom facility or and 10km from Duncton to Bignor Escarpment SAC. Site composting This site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of two European sites, it is considered that it should be screened in for further consideration on this basis. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out.
6.2.1 Dependent on the type and size of facility an Energy from Waste plant could lead to adverse effects on European designated sites up to 10km from source through reduced air quality. The Arun Valley SPA/Ramsar currently does not exceed its site critical levels for nitrogen deposition or NOx, as measured using APIS (accessed 19th August 2010, for grazing marsh habitat at TQ037133). According to APIS the critical load for the principal habitat (grazing marsh) is 20-30 kgN/ha/yr, while deposition is currently (2010) 15 kgN/ha/yr. It is unlikely that a single Energy from Waste facility would lead to a 33% increase in deposition when considered in isolation but it is not possible at this stage to rule out such an increase when the facility is considered ‘in combination’ with other projects and plans, particularly the increased traffic due to an additional 65,000 dwellings recommended to be delivered across West Sussex by 2026 (South East Plan, 2009)48 and any other EfW facilities delivered on suitable sites identified in the Minerals & Waste DPD.
6.2.2 The proposed waste facility also lies to the south-east of Duncton to Bignor Escarpment SAC, and is on the limit of the 10km distance over which the potential for adverse effects requires assessment. The woodland habitat currently experiences 29.0 kg N/ha/year deposition (as at 19th August 2010 at SU989132), which exceeds the critical load (10 kg/N/yr) for woodland habitats by almost three times. Housing figures published in the South East Plan (2009)
48 The South East Plan has since been revoked – however, in the absence of alternative data on housing numbers at this point (November 2010) we have assumed that the numbers set out in the South East Plan are a reasonable precautionary maximum to use, although actual numbers could be lower
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indicated that over 65,000 new dwellings were likely to be delivered between 2006 and 2026 within West Sussex, alongside new employment opportunities. Although the South East Plan itself has now been revoked, the planned housing levels are still broadly accurate.
6.2.3 It is therefore not possible at this point to state that no adverse effects will occur, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward. If the site use is determined to be composting rather than Energy from Waste, then it will be possible to screen out site AR/4 as having no likely significant effects on European designated sites.
6.3 W/CH/1B – Portfield, W/CH/1C – Fuel Depot, Bognor Road Summary of screening
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in for number Facility Appropriate Assessment) on Figure 3b 30 Portfield Chichester Built waste These sites lie approximately 7km from Pagham Harbour facility, inert SPA/European Marine Site/Ramsar, 6km from Chichester and landfill or inert Langstone Harbours SPA/Ramsar, 8km from Singleton and recycling Cocking Tunnels SAC, 6km from Solent Maritime SAC and 8km from Kingley Vale SAC. 13 Fuel Chichester Built waste Depot, facility These sites are considered potentially suitable for an Energy from Bognor Waste facility and, since it lies within 10km of five European sites, it Road is considered that it should be screened in for further consideration on this basis. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out.
Appropriate Assessment
6.3.1 Dependent on the type and size of facility, an Energy from Waste site could lead to adverse effects on European designated sites up to 10km from source through reduced air quality. Current deposition of nitrogen on Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC (data at SU838041 on 19th August 2010) indicates that the rate is 12.6kg/ha/year, well within the acceptable limits of 30-40kg/ha/year for saltmarsh habitats. It is considered sufficiently unlikely that an Energy from Waste facility would lead to the very large (over 200%) increase in deposition which would be required to exceed the critical load even when considered ‘in combination’ with other projects and plans that no adverse effects on Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC are expected to result.
6.3.2 According to the Site Relevant Critical Load on APIS, the interest features at Pagham Harbour which is potentially sensitive to nitrogen deposition are the little tern and common tern, since an increase in tall vegetation (which might result from eutrophication) could make their nesting habitat less suitable. Current deposition at Pagham Harbour is 7.8 kgN/ha/yr while the minimum critical load for the most sensitive habitat used by these species (according to APIS) is 10 kgN/ha/yr. As such, a 28% increase in deposition would be required in order to lead to an exceedence. This is considered unlikely to result from an EfW situated 7km away, even when
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considered ‘in combination’ with other projects and plans. However, we have recommended that the project level HRA (which is required in line with EA policy for any emitter situated within 10km of a European site) should consider this issue in further detail.
6.3.3 Singleton and Cocking Tunnels SAC is also within 10km of these proposed waste sites, but the site is insensitive to reduce air quality. The site is adjacent to the A286, but the location of sites CH/1B and CH/1C means that it is unlikely that significant additional traffic would use this road past the SAC. The hibernation roosts of bats for which the SAC is designated would therefore not be subject to any adverse effects through disturbance or reduced air quality.
6.3.4 Kingley Vale SAC is also within 10km of these proposed waste sites and does contain habitats that are sensitive to reduced air quality. APIS data for this site (19th August 2010 at SU824100) indicate that the level of nitrogen deposition is currently 13.3 kg/ha/year, within acceptable limits for chalk grassland (15kg/ha/year). There is no available measurement for yew- dominated woodland, but figures for oak woodland are provided – at 26.3 kg/ha/year this value exceeds the critical load for a woodland habitat.
6.3.5 It is therefore not possible at this point to state that no adverse effects will occur on Kingsley Vale SAC, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward.
6.4 W/CH/4A – Land East of Tangmere Airfield, W/CH/4B – South East Corner of Tangmere Airfield, W/CH/4C – Woodhorn Farm Summary of screening
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in number Facility for Appropriate Assessment) on Figure 3b 21 Land East of Chichester Built waste These sites lie approximately 7km from Pagham Harbour Tangmere facility SPA/European Marine Site/Ramsar, 6km from Chichester and Airfield Langstone Harbours SPA/Ramsar, 8km from Singleton and Cocking Tunnels SAC, 6km from Solent Maritime SAC, 8km 34 South East Chichester Built waste from Kingley Vale SAC and 9 km from Duncton to Bignor Corner of facility or Escarpment SAC. Tangmere composting Airfield These sites are considered potentially suitable for an Energy 36 Woodhorn Chichester Built waste from Waste facility and, since it lies within 10km of five Farm facility European sites, it is considered that it should be screened in for further consideration on this basis. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out.
Appropriate Assessment
6.4.1 Current deposition of nitrogen on Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC (data at SU838041 on 19th August 2010) indicates that the rate is 12.6kg/ha/year, well within the acceptable limits of 30-40kg/ha/year for saltmarsh habitats. It is considered sufficiently unlikely that an Energy from Waste facility would lead to the very large (over 200%) increase in deposition which would be required to exceed the critical load even
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when considered ‘in combination’ with other projects and plans that no adverse effects on Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC are expected to result.
6.4.2 According to the Site Relevant Critical Load on APIS, the interest features at Pagham Harbour which is potentially sensitive to nitrogen deposition are the little tern and common tern, since an increase in tall vegetation (which might result from eutrophication) could make their nesting habitat less suitable. Current deposition at Pagham Harbour is 7.8 kgN/ha/yr while the minimum critical load for the most sensitive habitat used by these species (according to APIS) is 10 kgN/ha/yr. As such, a 28% increase in deposition would be required in order to lead to an exceedence. This is considered unlikely to result from an EfW situated 7km away, even when considered ‘in combination’ with other projects and plans. However, we have recommended that the project level HRA (which is required in line with EA policy for any emitter situated within 10km of a European site) should consider this issue in further detail.
6.4.3 Singleton and Cocking Tunnels SAC is also within 10km of these proposed waste sites, but the site is insensitive to reduce air quality. The site is adjacent to the A286, but the location of sites CH/1B and CH/1C means that it is unlikely that significant additional traffic would use this road past the SAC. The hibernation roosts of bats for which the SAC is designated would therefore not be subject to any adverse effects through disturbance or reduced air quality.
6.4.4 Kingley Vale SAC is also within 10km of these proposed waste sites and does contain habitats that are sensitive to reduced air quality. APIS data for this site (19th August 2010 at SU824100) indicate that the level of nitrogen deposition is currently 13.3 kg/ha/year, within acceptable limits for chalk grassland (15kg/ha/year). There is no available measurement for yew- dominated woodland, but figures for oak woodland are provided – at 26.3 kg/ha/year this value exceeds the critical load for a woodland habitat.
6.4.5 Duncton to Bignor Escarpment SAC is also within 10km of these proposed waste sites and does contain habitats that are sensitive to reduced air quality. The woodland habitat currently experiences 29.0 kg N/ha/year deposition (as at 19th August 2010 at SU989132), which exceeds the critical load (10 kg/N/yr) for woodland habitats by almost three times. Over 65,000 new dwellings are recommended for delivery between 2006 and 2026 within West Sussex (South East Plan, 2009), alongside new employment opportunities. However, although the SAC lies 10km north-east of the proposed facilities, and thus subject to the prevailing winds, it is on the farther side of a scarp slope from the potential Energy from Waste facilities. Therefore the risk of adverse effects is reduced.
6.4.6 It is therefore not possible at this point to state that no adverse effects will occur on Kingsley Vale SAC or Duncton to Bignor Escarpment SAC, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward.
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6.5 W/CH/5 – Bognor Common Stone Quarry Summary of screening
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in for number on Facility Appropriate Assessment) Figure 3b 2 Bognor Chichester Inert This site lies approximately 5km from Ebernoe Common SAC, 500m Common landfill from The Mens SAC, 6km to Arun Valley SPA and 7km Duncton to Stone Quarry Bignor Escarpment SAC.
This site is considered for inert landfill. As such and given the distances involved the initial screen determined that there were no pathways linking this site with European sites. However, given the ascertained proximity to The Mens SAC the site requires some further consideration.
Appropriate Assessment
6.5.1 Studies carried out to model the foraging habits of barbastelle bats for which The Mens SAC and Ebernoe Common SAC are partly designated (see section 3.7.4) have identified that they forage to the east of The Mens SAC, rather than to the west in the vicinity of the proposed waste site. Barbastelle bats from the Ebernoe Common colony do forage around the Petworth area which is within 500m of site W/CH/5. However, this site, consisting as it does of an existing quarry void, does not itself present suitable foraging habitat for barbastelle bats from either SAC (since the site lies more than 1.5km from Ebernoe Common SAC it is thus outside the typical foraging/commuting distances for the Bechstein bat population).
6.5.2 There will inevitably be some level of noise associated with landfilling operations, although landfilling activity will be essentially confined to the limits of the existing quarry such that the actual quarry faces will themselves act as a noise barrier. Moreover:
• Currently mapped barbastelle roosts within The Mens SAC are greater than 500m from the proposed waste site; and • Barbastelle bats have been known to be present since at least 2001, during which time quarrying operations have taken place.
6.5.3 However, the effect of noise on roosting bats is not well studied. In the absence of definitive information of the tolerance of barbastelle bats and given the importance of the population at The Mens SAC, it is not possible to conclude with certainty that no adverse effects on roosting bats would occur. Further safeguards therefore need to be incorporated into the Minerals & Waste DPD and data establishing no adverse effect would need to be supplied to Natural England as part of any consenting process for extensions to this site.
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6.6 W/CH/6 – Duncton Quarry Screening summary
Site Site Location Type of HRA Screening (green= screened out, amber =screened in for number on name Facility Appropriate Assessment) Figure 3b 10 Duncton Chichester Inert Although this site was originally screened out, further investigation has Quarry landfill identified that this site lies within 150m of Duncton to Bignor Escarpment SAC. This is sufficiently close that air quality impacts on the SAC from vehicle exhaust emissions may result. Further consideration is therefore required.
Appropriate Assessment
6.6.1 Exhaust emissions associated with vehicle movements within the quarry itself may be effectively screened from the SAC due to the quarry faces themselves. However, road access to this proposed waste site will be from the A285 to the east which is adjacent to the SAC. Therefore there exists a possibility that any increase in vehicle movements as a result of the waste site will result in reduced air quality at the SAC. Although an attempt has been made to source any investigations of air quality impacts that may have been associated with current quarrying activities, none have been obtained.
6.6.2 The woodland habitat currently experiences 29.0 kg N/ha/year deposition (as at 19th August 2010 at SU989132), which exceeds the critical load (10 kg/N/yr) for woodland habitats by almost three times. Any traffic generated by the landfill site must be considered in combination with a probable increase in traffic movements on the A285 over the plan period associated with the delivery of over 65,000 recommended new dwellings within West Sussex (South East Plan, 2009), alongside new employment opportunities.
6.6.3 At this stage it is therefore not possible to conclude with certainty that landfill operations at this quarry will not lead to adverse effects on the SAC through air quality impacts, when considered in combination with the other increases in traffic on the A285 that are likely to occur over the operational life of the quarry. Further safeguards are therefore required for the Minerals & Waste DPD.
6.7 W/HO/5 – Chantry Lane Sandpit Summary of screening
Site number Site name Location Type of HRA Screening (green= screened out, amber =screened in for on Figure 3b Facility Appropriate Assessment) 7 Chantry Horsham Inert This site lies approximately 5km from Arun Valley SPA/Ramsar. Lane Sand landfill Pit The site lies adjacent to a watercourse that drains to the river Stor and into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for discharged leachate to impact this European site.
This site is considered for inert landfill. As such and given the distances involved there are no other pathways linking this site with European sites.
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Appropriate Assessment
6.7.1 This site lies adjacent to the proposed minerals site M/HO/2.
6.7.2 The River Stor runs from adjacent to this site into the Arun Valley SPA/Ramsar some 5-6km distant. On route the River passes the settlement of Storrington and two treatment works.
6.7.3 Input of water from the River Stor onto the SPA/Ramsar is only permitted through opening of sluice gates in very dry conditions as an ‘emergency measure,’ as the water quality within the River Stor is poor. Therefore any leachate that may enter the River Stor will generally not result in a subsequent adverse effect on the SPA/Ramsar.
6.7.4 It can therefore be concluded that waste site HO/5 will not have any likely significant effects on the Arun Valley SPA/Ramsar through reduced water quality.
6.8 W/HO/9 – Land at North Farm Summary of screening
Site Site Location Type of HRA Screening (green= screened out, amber =screened in for number on name Facility Appropriate Assessment) Figure 3b 20 Land at Horsham Built This site lies approximately 8km from Arun Valley SPA/Ramsar. North waste Farm facility The site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis.
Appropriate Assessment
6.8.1 Dependent on the type and size of facility an Energy from Waste plant could lead to adverse effects on European designated sites up to 10km from source through reduced air quality. The Arun Valley SPA/Ramsar currently does not exceed its site critical levels for nitrogen deposition or NOx, as measured using APIS (accessed 19th August 2010, for grazing marsh habitat at TQ037133). According to APIS the critical load for the principal habitat (grazing marsh) is 20-30 kgN/ha/yr, while deposition is currently (2010) 15 kgN/ha/yr. It is unlikely that a single Energy from Waste facility would lead to a 33% increase in deposition when considered in isolation, particularly since the proposed site lies south-east of the SPA, while the prevailing wind is west/south west. However, it is not possible at this stage to absolutely rule out such an increase when the facility is considered ‘in combination’ with other projects and plans, particularly the increased traffic due to an additional 65,000 dwellings recommended to be delivered across West Sussex by 2026 (South East Plan, 2009) and any other EfW facilities delivered on suitable sites identified in the Minerals & Waste DPD.
6.8.2 It is therefore not possible at this point to state that no adverse effects will occur, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward.
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6.9 W/HO/10 – Hampers Lane Engineering Works Summary of screening
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in for number Facility Appropriate Assessment) on Figure 3b 15 Hampers Lane Horsham Built waste This site lies approximately 6km from Arun Valley SPA/Ramsar. Engineering facility or Works inert The site is considered potentially suitable for an Energy from recycling Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis.
Appropriate Assessment
6.9.1 Dependent on the type and size of facility an Energy from Waste plant could lead to adverse effects on European designated sites up to 10km from source through reduced air quality. The Arun Valley SPA/Ramsar currently does not exceed its site critical levels for nitrogen deposition or NOx, as measured using APIS (accessed 19th August 2010, for grazing marsh habitat at TQ037133). According to APIS the critical load for the principal habitat (grazing marsh) is 20-30 kgN/ha/yr, while deposition is currently (2010) 15 kgN/ha/yr. It is unlikely that a single Energy from Waste facility would lead to a 33% increase in deposition when considered in isolation, particularly since the proposed site lies south-east of the SPA, while the prevailing wind is west/south west. However, it is not possible at this stage to absolutely rule out such an increase when the facility is considered ‘in combination’ with other projects and plans, particularly the increased traffic due to an additional 65,000 dwellings recommended to be delivered across West Sussex by 2026 (South East Plan, 2009) and any other EfW facilities delivered on suitable sites identified in the Minerals & Waste DPD.
6.9.2 It is therefore not possible at this point to state that no adverse effects will occur, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward.
6.10 W/MS/1 – Burleigh Oaks Farm Summary of screening
Site Site Location Type of HRA Screening (green= screened out, amber =screened in for number on name Facility Appropriate Assessment) Figure 3b 6 Burleigh Mid- Built This site lies approximately 6km from Ashdown Forest SPA/SAC. Oaks Sussex waste Farm facility This site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis.
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Appropriate Assessment
6.10.1 Air Quality at the centre point of Ashdown Forest SAC/SPA according to the Site Relevant Critical Load available on APIS is 11.5 kg/N/ha/yr (as at 19th August) compared to a minimum critical load for the habitat present, wet and dry heathland, of 10 kg/N/ha/yr.
6.10.2 The proposed built waste facility would be located to the north-west of Ashdown Forest, and there is thus reduced potential for air quality impacts as this avoids the prevailing wind direction (south/south-west). Background levels of nitrogen deposition are above the critical load. Since the critical load will already be exceeded without additional traffic arising from minerals and waste development in West Sussex (and since this must be considered within the context of additional nitrogen inputs from agricultural runoff) it cannot be concluded that an EfW facility at this site would not have an overall ‘in combination’ adverse effect on the heathland interest features of the SAC (and therefore on those SPA interest features which depend upon heathland habitat) when considered alongside the additional traffic which the A22 will take as a result of 11,000 new homes to be delivered under the Wealden District Core Strategy and within the context of existing agricultural runoff. Additionally policies within the emerging East Sussex and Brighton & Hove WMDF may result in minerals traffic past this SAC/SPA.
6.10.3 It is therefore not possible at this point to state that no adverse effects will occur, particularly when considered ‘in combination’ with other projects and plans. Therefore the MWDF will need to ensure that this site is subject to a more detailed assessment if an EfW plant does come forward.
6.11 W/MS/2 - Freshfield Lane Brickworks Summary of Screening
Site Site name Location Type of HRA Screening (green= screened out, amber =screened in for number on Facility Appropriate Assessment) Figure 3b 12 Freshfield Mid- Inert This site lies approximately 4km from Ashdown Forest SPA/SAC. It is Lane Sussex landfill assumed that site traffic will use the A275 Road which bisects this Brickworks SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site.
Although the site lies within 5km of Ashdown Forest SPA it is identified for potential inert landfill rather than putrescible waste and is therefore unlikely to attract gulls and corvids. As such it is considered that it can be screened out as not representing a predation risk to the ground- nesting birds of the SPA.
Appropriate Assessment
6.11.1 The screening exercise identified that air quality was a pathway requiring consideration with regard to this proposed waste site, due to potential for increased traffic volumes within 200m of European designated sites. Air Quality at Ashdown Forest SAC/SPA adjacent to the A275 according to the Site Relevant Critical Load available on APIS is 15.7 kg/N/ha/yr (as at 19th August for grid reference TQ415304) and the minimum critical load for the habitat present, wet and dry heathland, is 10 kg/N/ha/yr.
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6.11.2 Although traffic associated with this site could use the A275 north-bound, through the forest, it is not an optimal route for transport from elsewhere within West Sussex, where transport via the M23 past Crawley or from the direction of Hayward’s Heath, would be more efficient. The background papers to the MWDF indicate that “no information on the forecast of…minerals imported or exported into West Sussex is available,” but the adopted Hampshire Minerals and Waste Core Strategy does not identify any need for movement of waste to/from West Sussex and nor do the currently emerging proposals for the East Sussex Minerals & Waste Core Strategy. However, Natural England in their initial consultation response on this HRA commented that a precautionary approach should be taken towards this site.
6.11.3 Following discussion with Natural England we have concluded that at this point it is not possible to be certain that significant effects on Ashdown Forest SAC/SPA will not occur as a result of site W/MS/2, Additional precautions are therefore required for inclusion within the MWDF.
6.12 Recommendations Energy from Waste
6.12.1 If it is intended to bring forward any Energy from Waste facilities on the suitable waste sites identified in this report (W/MS/1 – Burleigh Oaks Farm, W/HO/10 – Hampers Lane Engineering Works, W/HO/9 – Land at North Farm, W/CH/4a – Land East of Tangmere Airfield, W/CH/4b – South East Corner of Tangmere Airfield, W/CH/4c – Woodhorn Farm, W/CH/1b - Portfield, W/CH/1c – Fuel Depot, Bognor Road, W/AR/4 – Blue Prince Mushroom Site) then it will be necessary for the applicant to demonstrate that either:
• The facility will lead to an increase in nitrogen deposition within all European sites that lie within 10km that constitutes less than 1% of the critical load49 for the most sensitive habitat within the site; or • If the increase in deposition will be greater than 1% of the critical load it will nonetheless be sufficiently small that no adverse effect on the interest features and integrity of the European site will result.
Site W/CH/5 – Bognor Common Stone Quarry
6.12.2 In order for site CH/5 to be approved for inert landfill, the MWDF should require any applicant to demonstrate that there will be no adverse impacts on The Mens SAC or Ebernoe Common SAC or that any adverse effects can be adequately mitigated, with a particular focus on noise disturbance of the bat populations that may forage in woodland around the boundaries of the site. In order to do so, a project-level Appropriate Assessment (and consultation with Natural England) will be required. This may involve introduction of regular monitoring (frequency, duration and details to be agreed with the local authority and Natural England) to ensure that the effectiveness of any control measures that are introduced is evaluated and additional/alternative measures deployed as necessary. Unless the assessment can satisfactorily demonstrate that current levels of noise on site will not increase (either in frequency or levels) above the current baseline, or that any increase will not have an adverse effect, permission should be refused.
49 1% of the critical load being the criterion that the Environment Agency uses to determine when the contribution of a particular source of pollution will be effectively inconsequential even when considered ‘in combination’ with other projects and plans
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Site W/CH/6 – Duncton Quarry and Site W/MS/2 – Freshfield Lane Brickworks
6.12.3 In order for site W/CH/6 (Duncton Quarry) and W/MS/2 (Freshfield Lane Brickworks) to be approved for inert landfill the MWDF should require any applicant to demonstrate that the landfill site (either traffic or other operations) will not lead to an adverse effect on the integrity of Duncton to Bignor Escarpment SAC and Ashdown Forest SAC/SPA, respectively, through demonstrating that:
• The increase in vehicle movements within 200m of the European site as a result of these developments will amount to less than 200 Heavy Duty Vehicles/day50; or • The increase in vehicle movements will result in an increase in nitrogen deposition at the roadside, amounting to less than 1% of the critical load51 for the most sensitive habitat within the site; or • If the increase in deposition will be greater than 1% of the critical load further assessment is undertaken to demonstrate that there will be no adverse affect on the integrity of the designated site.
6.12.4 Since both European sites are already subject to nitrogen deposition far in excess of the critical load for the habitat it would not be sufficient to demonstrate that vehicle movements/emissions will be no greater than the current baseline.
50 The Design Manual for Roads and Bridges (Volume 11, Section 3, Part 1) regarding air quality environmental impact assessment from roads indicates that if the increase in traffic will amount to less than 200 HDV movements per day the development can be scoped out of further assessment. 51 1% of the critical load being the criterion that the Environment Agency uses to determine when the contribution of a particular source of pollution will be effectively inconsequential even when considered ‘in combination’ with other projects and plans
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7 Conclusions of Appropriate Assessment
7.1.1 If the Council is able to incorporate the suggested measures into the evolving MWDF then it will be possible to conclude that the MWDF met the requirements of the Habitats Directive regarding their impacts on European sites in that all site allocations can either be concluded not to have an adverse effect on European sites or will have additional tests placed upon them that will need to be met before development can proceed.
7.2 Minerals and Waste Policy Options
7.2.1 Twenty-seven of the issues (encompassing 62 Options) have been screened in for Appropriate Assessment. The reason for this is that these are the policies that either promote or direct the scale and spatial distribution of minerals and waste development within West Sussex. They may be of particular relevance with regard to any unallocated (i.e. non-strategic) sites that come forward during the life of the MWDF in relation to criteria-based policies for determining appropriate waste/minerals sites. However, they cannot be meaningfully taken forward from the initial HRA screening stage until the actual wording of relevant policies is developed. As such, the next key step will be to assess the preferred option text and/or draft policies.
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Appendix 1 - ‘Tiering’ in Habitat Regulations Assessment
Planning Policy Statements AA
Increasing Sub-Regional Strategies AA specificity in terms of evidence base, impact evaluation, mitigation, consideration of Minerals and waste AA alternatives etc. Development Frameworks
Individual projects/planning applications AA
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Appendix 2 - Background on European sites referenced in this document
Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Kingley Vale 208.05 • Yew-dominated • Maintenance of grazing SAC woodland • The long-term conservation of the yew forest • Dry grasslands and requires the maintenance of nurse scrub habitat scrublands on chalk or and the regulation of numbers of resident deer. limestone • Minimal air pollution – nitrogen deposition may cause reduction in diversity, sulphur deposition can cause acidification • Absence of direct fertilisation • The site is vulnerable to spray-drift (i.e. eutrophication) from surrounding intensive arable land. • Low recreational pressure. Rook Clift SAC 10.82 • Mixed woodland on • Appropriate woodland management base-rich soils • Deer grazing needs to be controlled associated with rocky • Planting inside the woodland needs to be tightly slopes controlled. Duncton to 214.47 • Mixed woodland on • Minimal atmospheric pollution - may increase Bignor base-rich soils the susceptibility of beech trees to disease Escarpment associated with rocky • Appropriate woodland management SAC slopes Singleton and 2.45 • Hibernating barbastelle • Absence of disturbance. Tunnel entrances are Cocking bat covered by bat grill to prevent disturbance. Tunnels SAC • Hibernating Bechstein’s • Barbastelles require a constant humidity around bat their roosts; any manipulation of the shrub layer must be carefully considered. The Mens SAC 203.28 • Beech forests on acid • Appropriate woodland management. soil • Low recreational pressure (because • Barbastelle bat management is minimum intervention and Bridleway degradation by horse riding is a recurring threat) • Minimal air pollution - may increase the susceptibility of beech trees to disease and alter epiphytic communities. • Barbastelles require a constant humidity around their roosts; any manipulation of the shrub layer must be carefully considered.
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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Ebernoe 133.94 • Atlantic acidophilous • Appropriate management. Common beech forests with Ilex • Minimal atmospheric pollution - may increase SAC and sometimes also the susceptibility of beech trees to disease and Taxus in the shrublayer alter epiphytic communities.Absence of • Barbastelle bat disturbance. • Bechstein’s bat • In a wider context, bats require good connectivity of landscape features to allow foraging and commuting. • Both bat species have close association with woodland. Areas of undesignated woodland adjacent to SAC may be of most importance to population • Barbastelles require a constant humidity around their roosts; any manipulation of the shrub layer must be carefully considered. Solent 11325.09 • Estuaries • Sufficient space between the site and Maritime SAC • Cord grass swards development to allow for managed retreat of • Atlantic salt meadows intertidal habitats and avoid coastal squeeze. • Subtidal sandbanks • No dredging or land-claim of coastal habitats. • Intertidal mudflats and • Unpolluted water and high oxygenation. sandflats • Absence of nutrient enrichment. • Lagoons • Absence of non-native species. • Annual vegetation of • Maintenance of freshwater inputs. drift lines • Balance of saline and non-saline conditions. • Coastal shingle • Maintenance of grazing vegetation outside the reach of waves • Glasswort and other annuals colonising mud and sand • Shifting dunes with marram • Desmoulin’s whorl snail
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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Chichester and 5810.03 • Internationally important • Sufficient space between the site and Langstone wintering populations of development to allow for managed retreat of Harbours Brent goose, shelduck, intertidal habitats and avoid coastal squeeze. SPA/Ramsar pintail, shoveler, red- • Unpolluted water. breasted merganser, • Absence of nutrient enrichment of water. ringed plover, grey • Minimal recreational and other disturbance plover, dunlin, bar-tailed • Absence of non-native species e.g. from godwit, curlew, shipping activity. redshank and breeding • Maintenance of appropriate hydrological population of little tern regime, e.g. freshwater flows at heads of • Over winter the area channels are important for birds to preen, drink regularly supports and feed. 93230 waterfowl (5 year • Short grasslands surrounding the site are peak mean 01/04/1998) essential to maintaining interest features as • Internationally important they are now the key foraging resource for population of wintering Brent goose. waterfowl (Ramsar) • Internationally important populations of ringed plover, black-tailed godwit, common redshank, dark-bellied brent goose, common shelduck, grey plover, dunlin, little tern (Ramsar) Pagham 636.68 • Internationally important • Sufficient space between the site and Harbour wintering populations of development to allow for managed retreat of SPA/European ruff and pintail intertidal habitats and avoid coastal squeeze. Marine • Internationally important • Unpolluted water. Site/Ramsar breeding population of • Minimal recreational and other disturbance little tern • Absence of nutrient enrichment of water. • Absence of non-native species. • Maintenance of appropriate hydrological regime. • Maintenance of isolated, open, non-vegetated sand and shingle beaches and spits for nesting. • Maintenance of suitable feeding areas in estuarine habitats and inland grazing marshes • Maintenance of suitable feeding areas with winter wheat/grass close to Pagham Harbour
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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Arun Valley 528.62 • Supports nationally • Appropriate grazing management SPA/Ramsar important wintering • Sympathetic management of lowland wet population of 27241 grassland/grazing marsh (including water level waterfowl (5 year peak management). mean 30/06/1999) • Minimal disturbance including tundra swan • Management of the hydrology of the area • The Arun Valley important. For example, the impact of water consists of three abstraction, river maintenance, and ensuring component Sites of that winter flooding can continue as part of the Special Scientific existing management of the site. Interest. • The neutral wet grassland • Ditches support rich aquatic flora and invertebrate fauna. • The area is of outstanding ornithological importance notably for wintering wildfowl and breeding waders. Ashdown 3207.08 • Wet heathland with • Minimal air pollution (nitrogen deposition can Forest SPA cross-leaved heath cause compositional changes over time) SAC/SPA 2729 SAC • Dry heaths • Use of grazing management to prevent • Great crested newts succession • Nationally important • Balanced hydrological regime to maintain wet breeding populations of heath. nightjar and Dartford • Minimal recreational disturbance warbler • Absence of urbanisation • Suitable foraging and refuge habitat within 500m of the pond. • Relatively unpolluted water of roughly neutral pH. • Some ponds deep enough to retain water throughout February to August at least one year in every three. • In a wider context, great crested newts require good connectivity of landscape features (ponds, hedges etc) as they often live as metapopulations in a number of ponds. Wealden 2053.83 • Nationally important • Maintenance of grazing and other traditional Heaths Phase breeding populations of management practices. 2 SPA nightjar, woodlark and • Unfragmented habitat Dartford warbler • Minimal recreational pressure and a low incidence of wildfires.
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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Woolmer 666.68 • Acid peat-stained lakes • Maintenance of grazing and other traditional Forest SAC and ponds management practices. • Dry heaths • Unfragmented habitat • Depressions on peat • Minimal recreational pressure and a low substrates incidence of wildfires. • Wet heathland with • Minimal nutrient enrichment cross-leaved heath • Minimal air pollution – nitrogen deposition may • Very wet mires often cause reduction in diversity, sulphur deposition identified by an unstable can cause acidification ‘quaking’ surface East 569.68 • Dry grasslands and • Low nutrient runoff from surrounding land - Hampshire scrublands on chalk or being steep and narrow, the Hanger woodlands Hangers SAC limestone, including are vulnerable to nutrient run-off leading to important orchid sites eutrophication. • Beech forests on neutral • Maintenance of grazing to rich soils • Controlled off-track recreational activity (i.e. • Mixed woodland on trampling) base-rich soils • Minimal air pollution – nitrogen deposition may associated with rocky cause reduction in diversity, sulphur deposition slopes can cause acidification • Dry grasslands or • Absence of direct fertilisation scrublands on chalk or • Well-drained soils limestone • Yew-dominated woodland • Early gentian
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Appendix 3 – Minerals and Waste Sites Screened Out of HRA
Minerals Sites
Site Site name Location Mineral Status HRA Screening (green= screened out, amber number =screened in for Appropriate Assessment) on Figure 3a 6 Densworth Chichester Sharp sand Inactive This site lies approximately 2km from Kingley Vale North and gravel (not yet SAC. However, there is no scope for adverse worked) impacts on that SAC and no pathway connecting with any other European sites.
24 West Stoke Chichester Sharp sand Inactive This site lies approximately 2km from Kingley Vale Road East and gravel (not yet SAC. However, there is no scope for adverse worked) impacts on that SAC and no pathway connecting with any other European sites.
25 West Stoke Chichester Sharp sand Inactive This site lies approximately 2km from Kingley Vale Road West and gravel (not yet SAC. However, there is no scope for adverse worked) impacts on that SAC and no pathway connecting with any other European sites.
12 Huntersrace Chichester Sharp sand Inactive This site lies approximately 2km from Kingley Vale Land North and gravel (not yet SAC. However, there is no scope for adverse worked) impacts on that SAC and no pathway connecting with any other European sites.
14 Land at Chichester Sharp sand Inactive This site lies approximately 7km from Solent Redvins and gravel (not yet Maritime SAC and Chichester and Langstone worked) Harbours SPA/Ramsar. There is no scope for adverse impacts on this site and no pathway connecting with any other European sites. 8 Land Adjacent Chichester Sharp sand Inactive This site lies approximately 4km from Solent to Valdoe and gravel (not yet Maritime SAC and Chichester and Langstone Quarry (East worked) Harbours SPA/Ramsar, and Kingley Vale SAC. Lavant) There is no scope for adverse impacts on these or any other European sites.
5 Copse Farm Chichester Sharp sand Inactive This site lies approximately 4km from Solent and gravel (not yet Maritime SAC and Chichester and Langstone (concreting worked) Harbours SPA/Ramsar, and Kingley Vale SAC. aggregate) There is no scope for adverse impacts on these or any other European sites.
18 Shopwyke Chichester Sharp sand Inactive This site lies approximately 4km from Solent North and gravel (not yet Maritime SAC and Chichester and Langstone (concreting worked) Harbours SPA/Ramsar, and Kingley Vale SAC. aggregate) There is no scope for adverse impacts on these or any other European sites.
19 Shopwyke Chichester Sharp sand Inactive This site lies approximately 4km from Solent
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Site Site name Location Mineral Status HRA Screening (green= screened out, amber number =screened in for Appropriate Assessment) on Figure 3a South and gravel (not yet Maritime SAC and Chichester and Langstone (concreting worked) Harbours SPA/Ramsar, and Kingley Vale SAC. aggregate) There is no scope for adverse impacts on these or any other European sites.
15 Madams Green Chichester Sharp sand Inactive This site lies approximately 4km from Solent Farm West and gravel (not yet Maritime SAC and Chichester and Langstone (concreting worked) Harbours SPA/Ramsar, and Kingley Vale SAC. aggregate) There is no scope for adverse impacts on these or any other European sites.
26 Withies Farm Chichester Sharp sand Inactive This site lies approximately 4km from Solent West and gravel (not yet Maritime SAC and Chichester and Langstone worked) Harbours SPA/Ramsar, and Kingley Vale SAC. There is no scope for adverse impacts on these or any other European sites.
1 Brick Kiln Farm Chichester Sharp sand Inactive This site lies approximately 4km from Solent and gravel (not yet Maritime SAC and Chichester and Langstone (concreting worked) Harbours SPA/Ramsar, and Kingley Vale SAC. aggregate) There is no scope for adverse impacts on these or any other European sites.
10 Hawkhurst Chichester Soft sand Inactive This site lies approximately 7km from Duncton to Farm (building and (not yet Bignor Escarpment SAC, Rook Clift SAC, and coarse sand) worked) Kingley Vale SAC. There is no scope for adverse impacts on these European sites. The site is also approximately 2.5km from Singleton and Cocking Tunnel SAC. It is assumed that site traffic will use A285 road which runs perpendicular to the tunnels. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels. 9 Ham Farm Horsham Soft Sand Inactive No European site within 10km of this site. There is (not yet no scope for pathways connecting any European worked) sites. 20 Shoreham Horsham Chalk for the Dormant No European site within 10km of this site. There is Cement Works manufacture of no scope for pathways connecting any European cement sites. 28 Rudgwick West Horsham TBC TBC This site does not lie within 10km of any European designated site, and is not connected by any pathways of impact. Therefore there is no potential for adverse effects under HRA. 29 Rudgwick East Horsham TBC TBC This site does not lie within 10km of any European designated site, and is not connected by any pathways of impact. Therefore there is no potential for adverse effects under HRA.
Waste Sites
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Site Site Authority Type of HRA screening (green = screened out, amber = number (name/address) facility screened in for Appropriate Assessment) on Figure 3b 32 Shoreham Harbour Adur Built waste No European site within 10km of this site. There is no facility scope for pathways connecting any European sites. 33 Slindon Bottom Pit Arun Inert landfill This site lies approximately 9km from Arun Valley SPA/Ramsar, 5km from Duncton to Bignor Escarpment SAC and 9.4km from Singleton and Cocking Tunnels SAC. This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 37 Site Adjacent to Arun Built waste No European site within 10km of this site. There is no Sewage Works, facility scope for pathways connecting any European sites. Ford 11 Ford Airfield Arun Built waste No European site within 10km of this site. There is no facility scope for pathways connecting any European sites. 16 Hobbs Barn Arun Built waste No European site within 10km of this site. There is no facility or scope for pathways connecting any European sites. composting 23 Land South of Chichester Composting This site lies approximately 7km from Pagham Harbour Strettington Flyover SPA/European Marine Site/Ramsar, 6km from Chichester and Langstone Harbours SPA/Ramsar, 8km from Singleton and Cocking Tunnels SAC, 6km from Solent Maritime SAC and 8km from Kingley Vale SAC.
This site is considered for open air composting. As such and given the distances involved there are no pathways linking this site with European sites. 29 Pendean Chichester Inert landfill This site lies approximately 8km from Duncton to Bignor Escarpment SAC, 3km from Singleton and Cocking Tunnels SAC, 7km from Rook Clift SAC, 9km from Kingley Vale SAC and 10km from Ebernoe Common SAC.
It is assumed that site traffic will use A286 road which runs perpendicular to Singleton & Cocking Tunnels SAC. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels.
This site is considered for inert landfill. As such and given the distances involved there are no other pathways linking this site with European sites. 3 Boxgrove Gravel Pit Chichester Inert landfill This site lies approximately 9km from Pagham Harbour SPA/European Marine Site/Ramsar, 9km from Chichester and Langstone Harbours SPA/Ramsar, 7km from Singleton and Cocking Tunnels SAC, 9km from Solent Maritime SAC and 7km from Duncton to Bignor Escarpment SAC.
This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 28 Old Lime Works Chichester Inert recycling This site lies approximately 8km from Duncton to Bignor
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Site Site Authority Type of HRA screening (green = screened out, amber = number (name/address) facility screened in for Appropriate Assessment) on Figure 3b Escarpment SAC, 1km from Singleton and Cocking Tunnels SAC, 6km from Kingley Vale SAC and 6km from Rook Clift SAC.
It is assumed that site traffic will use A286 road which runs perpendicular to Singleton & Cocking Tunnels SAC. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels.
This site is considered for inert recyling. As such and given the distances involved there are no other pathways linking this site with European sites. 8 Cocking Chalkpit Chichester Inert landfill This site lies approximately 7.5km from Duncton to Bignor Escarpment SAC, 1km from Singleton and Cocking Tunnels SAC, 6.1km from Kingley Vale SAC and 6km from Rook Clift SAC.
It is assumed that site traffic will use A286 road which runs perpendicular to Singleton & Cocking Tunnels SAC. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels.
This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 31 Shoreham Cement Horsham Built waste No European site within 10km of this site. There is no Works facility scope for pathways connecting any European sites. 27 Nowhurst Business Horsham Built waste No European site within 10km of this site. There is no Centre facility or inert scope for pathways connecting any European sites. recycling 5 Brookhurst Wood Horsham Built waste No European site within 10km of this site. There is no facility or non- scope for pathways connecting any European sites. inert landfill 24 Langhurstwood Horsham Non-inert No European site within 10km of this site. There is no Brickworks landfill scope for pathways connecting any European sites. 25 Laybrook Horsham Non-inert This site lies approximately 6km from Arun Valley SAC Brickworks landfill and 10km from The Mens SAC. This site is considered for non-inert landfill. Given the designation of the closest sites and the distances involved there are no pathways linking this site with European sites 35 Star Road Trading Horsham Built waste No European site within 10km of this site. There is no Estate facility scope for pathways connecting any European sites. 14 Golding Barn Horsham Inert landfill No European site within 10km of this site. There is no scope for pathways connecting any European sites. 4 Broadbridge farm Horsham Composting This site lies approximately 8km from Arun Valley SPA/Ramsar. This site is considered for open air composting. As such and given the distances involved
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Site Site Authority Type of HRA screening (green = screened out, amber = number (name/address) facility screened in for Appropriate Assessment) on Figure 3b there are no other pathways linking this site with European sites. 22 Land Rear of Mid Built waste No European site within 10km of this site. There is no Ricebridge Industrial Sussex facility scope for pathways connecting any European sites. Estate 19 Land at Hickstead Mid Built waste No European site within 10km of this site. There is no Sussex facility scope for pathways connecting any European sites. 17 Land Adjacent to Mid Built waste No European site within 10km of this site. There is no Sewage Works, Sussex facility scope for pathways connecting any European sites. Cuckfield 18 Land Adjacent to Mid Built waste No European site within 10km of this site. There is no Goddards Green Sussex facility scope for pathways connecting any European sites. WWTW 26 Newtimber Chalk Pit Mid Inert waste No European site within 10km of this site. There is no Sussex recycling scope for pathways connecting any European sites. 9 Decoy Farm, East Worthing Built waste No European site within 10km of this site. There is no Worthing facility scope for pathways connecting any European sites.
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