DOCUMENT 5.2 (Part 2 of 2)
Environmental Statement – Chapters 11-16
National Grid (Richborough Connection Project) Order Regulation (5)(2)(a) Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 and TEN-E Regulation EU347/2013
Application Ref: EN020017 January 2016 Page intentionally blank
Richborough Connection Project Volume 5 5.2 Environmental Statement
National Grid National Grid House Warwick Technology Park Gallows Hill Warwick CV34 6DA
Final
January 2016
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Richborough Connection Project – Volume 5, Document 5.2
Document Control
Document Properties
Organisation Amec Foster Wheeler
Author Richborough EIA Project Team
Approved by Karen Wilson and Chris Chadwick, Amec Foster Wheeler
Title Environmental Statement
Document Reference 5.2
Version History
Date Version Status Description/Changes
04/01/16 1 Final 1st Issue
Richborough Connection Project – Volume 5, Document 5.2
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Richborough Connection Project – Volume 5, Document 5.2
Table of Contents – Part 2 of 2 (Chapters 11 to 16)
1. INTRODUCTION 1 1.1 General introduction 1 1.2 The applicant 1 1.3 The national transmission system 2 1.4 The need for new infrastructure and the Richborough Connection project 3 1.5 Overview of the proposed development 4 1.6 Planning Act 2008 and TEN-E Regulation EU 347/2013 5 1.7 The need for an Environmental Impact Assessment 5 1.8 Purpose of the Environmental Statement 6 1.9 Consultation and engagement 12 1.10 Structure of the Environmental Statement 14 1.11 Other DCO documents 14
2. NEED FOR THE PROPOSED DEVELOPMENT AND ALTERNATIVES CONSIDERED 15 2.1 The need for the proposed development 15 2.2 National Grid’s duties 18 2.3 National Grid’s project development process 18 2.4 Consideration of alternatives for the Richborough Connection project 20
3. DESCRIPTION OF THE PROPOSED DEVELOPMENT 55 3.1 Summary description 55 3.2 Construction programme 59 3.3 Proposed development site and surroundings 62 3.4 400kV overhead line construction 64 3.5 132kV overhead line diversion works 89 3.6 132kV overhead line dismantling 91 3.7 Project design evolution and mitigation 95 3.8 Construction Environmental Management Plan 96
4. PLANNING POLICY CONTEXT 101 4.1 Introduction 101 4.2 National Policy Statements 102 4.3 National planning policy and guidance 107 4.4 Development plans 108 4.5 Other Local Planning Authorities 109 4.6 Other legislative requirements 110
5. THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS 113 5.2 Environmental Impact Assessment terminology 114 5.3 Environmental Impact Assessment scoping and scheme evolution 115
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5.4 Project design and EIA scope evolution 127 5.5 Identification of baseline conditions 127 5.6 Assessment years 128 5.7 Overview of assessment methodology 129 5.8 Approach to cumulative effects 130
6. LANDSCAPE 145 6.1 Introduction 145 6.2 Policy and legislative context 146 6.3 Data gathering methodology 157 6.4 Environmental Impact Assessment consultation 159 6.5 Overall landscape baseline 165 6.6 Embedded environmental measures incorporated into the proposed development 197 6.7 Scope of the assessment 201 6.8 Assessment methodology 210 6.9 Assessment of effects: Landscape elements 216 6.10 Assessment of effects: Landscape character 227 6.11 Assessment of effects: Landscape designations 235 6.12 Assessment of effects: Wider study area – National designations 240 6.13 Conclusions of significance evaluation 242
7. VISUAL 247 7.1 Introduction 247 7.2 Policy and legislative context 248 7.3 Data gathering methodology 250 7.4 Environmental Impact Assessment consultation 252 7.5 Overall visual baseline 257 7.6 Embedded environmental measures incorporated into the proposed development 266 7.7 Scope of the assessment 269 7.8 Assessment methodology 276 7.9 Assessment of effects: Views within 1km 282 7.10 Assessment of effects: Views between 1 - 3km 322 7.11 Assessment of effects: Views beyond 3km 331 7.12 Conclusions of significance evaluation 335
8. HISTORIC ENVIRONMENT 355 8.1 Introduction 355 8.2 Policy and legislative context 355 8.3 Data gathering methodology 364 8.4 Environmental Impact Assessment consultation 365 8.5 Overall historic environment baseline 370 8.6 Embedded environmental measures incorporated into the proposed development 377 8.7 Scope of the assessment 379
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8.8 Assessment Methodology 386 8.9 Assessment of effects: Direct effects on Heritage Assets 391 8.10 Assessment of Effects: Change to setting of heritage assets 414 8.11 Assessment of Effects: Historic Landscape Character 449 8.12 Conclusions of Significance Evaluation 454
9. BIODIVERSITY 461 9.1 Introduction 461 9.2 Policy and legislative context 462 9.3 Data gathering methodology 469 9.4 Environmental Impact Assessment consultation 478 9.5 Overall biodiversity baseline 492 9.6 Embedded environmental measures incorporated into the proposed development 495 9.7 Scope of the assessment 505 9.8 Assessment methodology 517 9.9 Assessment of effects: Thanet Coast & Sandwich Bay SPA/Ramsar 521 9.10 Assessment of effects: Stodmarsh SPA/Ramsar 530 9.11 Assessment of effects: Stodmarsh SAC 537 9.12 Assessment of effects: Statutory sites West Blean and Thornden Woods SSSI 540 9.13 Assessment of effects: River Great Stour, Ashford to Fordwich Local Wildlife Site 544 9.14 Assessment of effects: Little Hall and Kemberland Woods and Pastures Local Wildlife Site 548 9.15 Assessment of effects: Chislet Marshes, Sarre Penn and Preston Marshes Local Wildlife Site 552 9.16 Assessment of effects: Ash Level and South Richborough Pasture Local Wildlife Site 558 9.17 Assessment of effects: Ancient woodland, veteran trees and lowland mixed deciduous woodland. 563 9.18 Assessment of effects: Hedgerows 569 9.19 Assessment of effects: Rivers 573 9.20 Assessment of effects: Ponds 577 9.21 Assessment of effects: Curlew (Non-breeding) 580 9.22 Assessment of effects: Lapwing (Non-breeding) 585 9.23 Assessment of effects: Dunlin (Non-breeding) 591 9.24 Assessment of effects: Marsh harrier (Breeding and Non-breeding) 597 9.25 Assessment of effects: Hobby (breeding) 601 9.26 Assessment of effects: Peregrine (Breeding and non-breeding) 604 9.27 Assessment of effects: Barn owl (Non-breeding and Breeding) 608 9.28 Assessment of effects: Cetti’s warbler (breeding) 611 9.29 Assessment of effects: Kingfisher (breeding) 613 9.30 Assessment of effects: Great crested newts 615 9.31 Assessment of effects: Reptiles 620 9.32 Assessment of effects: Badgers 624 9.33 Assessment of effects: Bat Assemblage 627 9.34 Assessment of effects: Dormouse 634
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9.35 Assessment of effects: Water vole and Otter 639 9.36 Assessment of effects: Terrestrial invertebrates 646 9.37 Assessment of effects: Invasive Plant Species 650 9.38 Conclusions of significance evaluation 652
10. TRAFFIC AND TRANSPORT 667 10.1 Introduction 667 10.2 Policy and legislative context 667 10.3 Data gathering methodology 672 10.4 Environmental Impact Assessment consultation 672 10.5 Overall traffic baseline 678 10.6 Embedded environmental measures incorporated into the proposed development 690 10.7 Scope of the assessment 695 10.8 Assessment methodology 698 10.9 Assessment of effects: Construction traffic (all vehicles) 706 10.10 Assessment of effects: Construction traffic (HGV flows) 713 10.11 Assessment of effects: Pedestrian delay (users of PRoW) 725 10.12 Conclusions of significance of evaluation 737
11. NOISE AND VIBRATION 743 11.1 Introduction 743 11.2 Policy and legislative context 743 11.3 Data gathering methodology 751 11.4 Environmental Impact Assessment consultation 753 11.5 Overall noise and vibration baseline 762 11.6 Embedded environmental measures incorporated into the proposed development 765 11.7 Part A Construction noise - Scope of the assessment 767 11.8 Assessment methodology - construction noise and vibration 771 11.9 Assessment of effects – construction noise 775 11.10 Assessment of effects - construction traffic noise 788 11.11 Assessment of effects – construction vibration 789 11.12 Conclusions of significance evaluation for construction noise 790 11.13 Part B Scope of the assessment – operational noise 792 11.14 Assessment methodology - operational noise 796 11.15 Assessment of effects – operational noise 801 11.16 Conclusions of significance evaluation for operational noise 807
12. AIR QUALITY 809 12.1 Introduction 809 12.2 Policy and legislative context 809 12.3 Data gathering methodology 815 12.4 Environmental Impact Assessment consultation 816 12.5 Overall air quality baseline 820
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12.6 Embedded environmental measures incorporated into the proposed development 822 12.7 Scope of the assessment 823
13. WATER ENVIRONMENT 827 13.1 Introduction 827 13.2 Policy and legislative context 827 13.3 Data gathering methodology 841 13.4 Environmental Impact Assessment consultation 844 13.5 Overall water environment baseline 850 13.6 Embedded environmental measures incorporated into the proposed development 866 13.7 Scope of the assessment 876 13.8 Assessment methodology 883 13.9 Assessment of effects on aquatic environment receptors 888 13.10 Assessment of effects on water resources receptors 896 13.11 Assessment of effects on flood risk receptors 899 13.12 Conclusions of significance evaluation 904
14. GEOLOGY, SOILS AND AGRICULTURE 911 14.1 Introduction 911 14.2 Policy and legislative context 912 14.3 Data gathering methodology 918 14.4 Environmental Impact Assessment consultation 920 14.5 Overall geology baseline 929 14.6 Overall soils and agricultural land baseline 934 14.7 Embedded environmental measures incorporated into the proposed development 938 14.8 Scope of the assessment 942 14.9 Assessment methodology 948 14.10 Assessment of effects: Pylons and access routes (ground instability effects) 954 14.11 Assessment of effects: Construction compound (ground instability effects) 955 14.12 Assessment of effects: Nearby buildings and structures (ground instability effects) 956 14.13 Assessment of effects: Mineral resources 957 14.14 Assessment of effects: Human health (soil contamination) 958 14.15 Assessment of effects: Human health (ground gas) 962 14.16 Assessment of effects: disturbance and loss of soil resources 963 14.17 Assessment of effects: temporary loss of agricultural land 965 14.18 Conclusions of significance evaluation 967
15. SOCIO-ECONOMICS AND RECREATION 971 15.1 Introduction 971 15.2 Policy and legislative context 971 15.3 Data gathering methodology 975 15.4 Environmental Impact Assessment consultation 976 15.5 Overall socio-economic baseline 983
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15.6 Embedded environmental measures incorporated into the proposed development 990 15.7 Scope of assessment 993 15.8 Assessment methodology 997 15.9 Assessment of effects: tourism 1001 15.10 Assessment of effects: Users of PRoW and cycle routes 1005 15.11 Assessment of effects: users of community infrastructure 1014 15.12 Assessment of effects: other businesses 1017 15.13 Assessment of effects – users (land owners and tenants) of agricultural land 1019 15.14 Assessment of effects – future land uses 1021 15.15 Assessment of effects: local and regional economies 1023 15.16 Conclusions of significance evaluation 1027
16. CUMULATIVE EFFECTS 1031 16.1 Introduction 1031 16.2 Environmental Impact Assessment consultation 1031 16.3 Methodology 1036 16.4 Assessment of Cumulative Effects: Landscape 1042 16.5 Assessment of Cumulative Effects: Visual effects 1060 16.6 Assessment of Cumulative Effects: Historic environment 1076 16.7 Assessment of Cumulative Effects: Biodiversity 1087 16.8 Assessment of Cumulative Effects: Traffic 1096 16.9 Assessment of Cumulative Effects: Noise 1100 16.10 Assessment of Cumulative Effects: Air quality 1109 16.11 Assessment of Cumulative Effects: Water environment 1109 16.12 Assessment of Cumulative Effects: Geology, Soils and Agriculture 1126 16.13 Assessment of Effects: Socio-economic and recreation 1135 16.14 Conclusions 1136
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FIGURES ARE CONTAINED IN VOLUME 5, DOCUMENT 5.3 AS SHOWN BELOW [unless otherwise stated in the text within this document]
Document Figure Number Figure Title Reference 5.3.1 Figure 1.1 Overview of the Proposed Development
The electricity system from generator to consumer Figure 1.2 [contained within this document – Volume 5.2, Page 3]
South east region existing high voltage transmission system 5.3.2 Figure 2.1a [contained within this document – Volume 5.2, Page 17]
Options considered in the 2013 Strategic Options Report Figure 2.1b [contained within this document – Volume 5.2, Page 22]
Figure 2.2 Route Corridor Study – North Corridor
Connection Options Report (May 2014) Alignment Options Figure 2.3 Overview
Section A Connection Options Report Alignment Options Figure 2.3a Overview
Section B Connection Options Report – Alignment Options Figure 2.3b Overview
Section C Connection Options Report – Alignment Options Figure 2.3c Overview
Section D Connection Options Report – Alignment Options Figure 2.3d Overview
Figure 2.4 Proposed Draft Route
Figure 2.5a to h Design Changes to the 400kV Route following S42 Consultation
5.3.3 Figure 3.1a to h The Proposed Development
Figure 3.2 Indicative Dimensions of Typical Poles and Pylons
Example of a 400kV Double Circuit Lattice Pylon Figure 3.3 [contained within this document – Volume 5.2, Page 65]
The Proposed Development (Sections A-D) Figure 3.4a to d [contained within this document – Volume 5.2, Pages 67, 69, 70 and 72]
Figure 3.5 Westbere Compound Area – Potential Arrangement
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Document Figure Number Figure Title Reference Figure 3.6 Richborough Compound Area – Potential Arrangement
Typical Bellmouth Design Figure 3.7 [contained within this document – Volume 5.2, Page75]
Figure 3.8 Typical Construction Haul Road and Raised Section
Typical Demarcation of Working Area Figure 3.9 [contained within this document – Volume 5.2, Page 78]
Figure 3.10 Culvert Construction Details
Figure 3.11 Typical Short Span Temporary Bridge Details
Figure 3.12 Typical Long Span Temporary Bridge Details
Figure 3.13a-v Arboricultural Impact Plan
Figure 3.14a to h Access Routes - Construction and Dismantling
Typical Pulling Sections with quipotential Zones Figure 3.15 [contained within this document – Volume 5.2, Page 84]
Figure 3.16a to h Access Routes - Maintenance
PX and PY Route Diversion Works (Stage by stage) at Monkton Figure 3.17 Marshes
5.3.4 No Figures
5.3.5 Figure 5.1a to d Location of Cumulative Developments
5.3.6 Figure 6.1a to d Landscape Designations
Figure 6.2 Kent Downs Area of Outstanding Natural Beauty
Figure 6.3a and b Local Landscape Character Areas
Figure 6.4 Topography
5.3.7 Figure 7.1 Zone of Theoretical Visual Influence - Bare Earth
Zone of Theoretical Visual Influence - taking account of Figure 7.2 Buildings and Woodland Screening
Figure 7.3 a-b Long Distance Recreational Footpath and Cycle Routes
Figure 7.4 a to g Visual Receptors within 1km of the Proposed Development
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Document Figure Number Figure Title Reference Representative Views within 1-3km of the Proposed Figure 7.5 a to e Development
Figure 7.6 Valued Views beyond 3km of the Proposed Development
Photographs of Existing Representative Views within 1-3km and Figure 7.7 Valued Views beyond 3km of the Proposed Development
Figure 7.8a to e Verified Photomontage Viewpoint Locations Plan
Figure 7.9.1 - Verified Photomontages Section A 7.9.10
Figure 7.9.11- Verified Photomontages Section B 7.9.18
Figure 7.9.19- Verified Photomontages Section C 7.9.25
Figure 7.9.26- Verified Photomontages Section D 7.9.32
Significance of Effects on Visual Receptors within 1km of the Figure 7.10 a to g Proposed Development -during construction
Significance of Effects on Representative Views within 1-3km of Figure 7.11 a to e the Proposed Development- during construction
Significance of Effects on Valued Views beyond 3km of the Figure 7.12 Proposed Development during construction
Significance of Effects on Visual Receptors within 1km of the Figure 7.13 a to g Proposed Development -during operation
Significance of Effects on Representative Views within 1 -3 km Figure 7.14 a to e of the Proposed Development - during operation
Significance of Effects on Valued Views beyond 3km of the Figure 7.15 Proposed Development -during operation.
5.3.8 Figure 8.1a to h Designated Heritage Assets
Figure 8.2a to g Non-designated Heritage Assets
5.3.9 Figure 9.1a to h Designated Features of Nature Conservation
Figure 9.2a to u Biodiversity : Extended Phase 1 Habitat Survey
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Document Figure Number Figure Title Reference 5.3.10 Figure 10.1 Highway Network Plan
Figure 10.2 Bus Routes Within East Kent
Figure 10.3 Cycle Routes Within East Kent
5.3.11 Figure 11.1 Construction and Operational Noise Monitoring locations
5.3.12 Figure 12.1 Air Quality Management Areas
Figure 12.2 Construction Dust Study Area
5.3.13 Figure 13.1 Water Environment Overview
Figure 13.2a to d Water Environment
Figure 13.3a to d Abstractions and Discharges
Figure 13.4a to d WFD and Water Quality
5.3.14 Figure 14.1a to d British Geological Survey Superficial Geology - Section A-D
British Geological Survey Bedrock Geology and Designated Figure 14.2a to d Geological Sites - Section A-D
Figure 14.3a to d Recorded landfills - Section A-D
Figure 14.4a to d Soil Associations (1km from Order limits) - Section A-D
Figure 14.5a to d Agricultural Land Classification (ALC) - Section A-D
5.3.15 Figure 15.1 Socio Economic Study Areas
Figure 15.2 Index of Multiple Deprivation
Figure 15.3a to d Public Rights of Way - Section A-D
Figure 15.4 Potentially Affected Businesses
Figure 15.5 Study Area ZTVI and Sensitive Businesses
5.3.16 No Figures
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Photos in Document 5.2
Photo 3.1 Typical aluminium, access road Page 76 Photo 3.2 Typical scaffold with netting and backstays Page 81 Photo 3.3 Pylon erection Page 83 Photo 3.4 Examples of a bird diverter Page 85 Photo 3.5 Lattice pylon dismantling Page 94 Photo 6.1 View from Patrixbourne at the edge of the North Downs AONB looking north Page 167 Photo 6.2 View south from the edge of Blean Woods Special Landscape Area which extends west from Canterbury showing the existing infrastructure and wirescape present in the landscape. Mayton Cottage on Heel Lane is visible towards the centre of the Photograph Page 172 Photo 6.3 View from within the Hoath Farmlands LCA looking towards Hersden Page 174 Photo 6.4 View from within the Wantsum Channel Area of High Landscape Value looking south towards the existing PX route on elevated ground Page 176 Photo 6.5 View of both the PX and PY routes running in parallel across the landscape in Section D Page 178 Photo 6.6 View towards Shelford Landfill (Viridor Waste Management site) on the northern edge of Canterbury Page 181 Photo 6.7 View from the edge of Tile Lodge conservation area looking south along Hoath Road with the PX route seen crossing the valley slope to the south east Page 184 Photo 6.8 View within the Chislet Marshes and Former Wantsum Channel Area of High Landscape Value Page 187 Photo 6.9 View from Richborough Castle Roman Fort looking north towards the PHA, PX and PY routes Page 189 Photo 6.10 View from Den Grove Woodland to the south of the PX route in Section A Page 193 Photo 6.11 View from Clangate Woodland looking south towards the PX route in Section B Page 194 Photo 7.1 Photograph taken from within the Stour Valley looking north west towards Broad Oak Page 258 Photo 7.2 Photograph taken from within the Sarre Penn Valley looking west Page 260 Photo 7.3 Photograph taken from the Saxon Shore Way (PRoW) looking east over the Chislet Marshes Page 261 Photo 7.4 Photograph taken adjacent the River Stour, close to Marsh Farm Water Treatment Works, looking east across the Ash Level Page 263 Photo 7.5 Photograph taken from Ramsgate esplanade, 4.4km from the proposed route, looking south west towards Richborough Page 276
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Insets in Document 5.2
Inset 11.1 Example CadnaA 400kV overhead line noise assessment model Page 802
Graphs in Document 5.2
Graph 15-1 Age distribution Page 986 Graph 15-2 Qualification level comparison Page 987 Graph 15-3 Employment Profile (installation of the 400kV overhead line connection – Average people per day by month) Page 1024 Graph 15-4 Employment profile (PX route removal – Average people per day by month) Page 1025
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APPENDICES ARE CONTAINED IN VOLUME 5, DOCUMENT 5.4
Document 5.4 Environmental Statement Appendices
5.4.1A 1A PINS Scoping Opinion (September 2014)
5.4.1B 1B Response to PINS Scoping Opinion
5.4.2A 2A Overview of Technology Options
5.4.2B 2B Figure Showing North and South Route Corridor Options
5.4.2C 2C Figure Showing North Corridor Sub-options
5.4.2D 2D Proposed South East Water Reservoir - Route Options Appraisal
5.4.3A 3A Pylon Information
5.4.3B 3B CONFIDENTIAL: Embedded Environmental Measures Schedule
3B CONFIDENTIAL: Embedded Environmental Measures Schedule (Confidential Information Removed)
5.4.3C 3C Construction Environmental Management Plan
5.4.3D 3D Outline Waste Management Plan
5.4.3E 3E CONFIDENTIAL: Biodiversity Mitigation Strategy
3E CONFIDENTIAL: Biodiversity Mitigation Strategy (Confidential Information Removed )
5.4.3F 3F Archaeological Mitigation Written Scheme of Investigation
5.4.3G 3G Construction Traffic Manangement Plan
5.4.3H 3H Public Rights of Way Management Plan
5.4.3I 3I Arboricultural Impact Assessment
5.4.3J 3J Indicative Construction Programme
5.4.4 No Appendices for this Chapter
5.4.5A 5A Certificate of Conformity
5.4.6A 6A Landscape Methodology
5.4.6B 6B Published Landscape Character Assessment Extracts
5.4.6C 6C Landscape Character Field Survey Sheet
5.4.6D 6D NBS Landscape Specification for Planting
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5.4.7A 7A Visual Methodology
5.4.7B 7B Holford Rules and Visual Amenity Principles
5.4.7C 7C Visual Impact Assessment Tables
5.4.7D 7D Method for the production of Verified Photomontages
5.4.8A 8A - Archaeological Desk-based Assessment
5.4.8B 8B - Gazetteer of Heritage Assets
5.4.8C 8C - Results of Step 1 Appraisal of Change to Setting
5.4.8D 8D - Summary Assessment of Direct Effects on Non-designated Heritage Assets
5.4.9A 9A Evaluation of Receptors
5.4.9B 9B Environmental Changes and Zones of Influence
5.4.9C 9C Justification for Defining Zones of Influence
5.4.9D 9D Glossary of Scientific Names
5.4.9E 9E Extended Phase 1 Habitat Survey Report
5.4.9F 9F Bat Survey Report
5.4.9G 9G CONFIDENTIAL: Badger Survey Report
5.4.9H 9H Dormice Survey Report
5.4.9I 9I Great Crested Newt Survey Report
5.4.9J 9J Hedgerow Survey Report
5.4.9K 9K Invertebrate Survey Report
5.4.9L 9L Reptile Survey Report
5.4.9M 9M Water Vole and Otter Survey Report
5.4.9N 9N Breeding Bird Survey Report
5.4.9O(i) 9O Non-Breeding Bird Survey Report 2012-2014
5.4.9O(ii) 9O Non-Breeding Bird Survey Report 2014-2015
5.4.9P 9P - Bird Collision Risk/Bird Flight Assessment
5.4.9Q 9Q CONFIDENTIAL: Ornithology - Schedule 1 Bird Report
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5.4.10A 10A Transport Assessment
5.4.11A 11A Construction Noise Calculations
5.4.11B 11B Night-time Background Noise Measurements
5.4.11C 11C Operational Noise Assessment
5.4.11D 11D Meteorological Office Average Rainfall Charts
5.4.11E 11E Overhead Line Noise Modelling
5.4.12A 12A Dust Risk Assessment
5.4.13A 13A Flood Risk Assessment
5.4.13B 13B Supporting Water Quality Baseline Information
5.4.14A 14A Land Contamination Desk Study
5.4.14B 14B Mineral Planning Report
5.4.14C 14C Soil Associations and Agricultural Land Classification
5.4.14D 14D Natural Geohazards
5.4.15A 15A Socio-economic Assessment Tables
5.4.16 No Appendices for this Chapter
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11. NOISE AND VIBRATION
11.1 Introduction 11.1.1 This chapter assesses the likely significant effects upon sensitive receptors of noise and vibration that are likely to be generated by the construction, operation and future decommissioning of the proposed development. 11.1.2 It also describes the assessment of potential audible noise effects resulting from the operation of the proposed development, notably due to corona discharge effects from overhead line conductors. 11.1.3 This chapter should be read in conjunction with the project description in Chapter 3. The effect of noise on sites of historic importance is considered in Chapter 8. The effect of noise on biodiversity is considered in Chapter 9. The effect of noise on socio-economic and recreational receptors is considered in Chapter 15. All these chapters are within this document. 11.1.4 Following a summary of relevant policy and legislation, the chapter outlines the data gathering methodology that was adopted as part of the noise assessment. This leads on to a description of the overall baseline conditions and the environmental measures that have been incorporated into the proposed development. 11.1.5 Due to the different approaches to the modelling and assessment of construction and operation noise effects, the remainder of this chapter has been subdivided into Part A Construction Noise (Sections 11.7 to 11.12 within this Chapter) and Part B Operational Noise (Sections 11.13 to 11.16 within this Chapter). Each Part presents the scope of the assessment, the assessment methodology and, for each receptor, an assessment of potential effects. Each Part concludes with a summary of the results of the assessment.
Limitations of the Environmental Statement Construction noise 11.1.6 The assessment in relation to noise effects from construction activities has taken into account the information on construction methods and construction plant available at the time of the assessment. Various environmental measures such as acoustic screening, selecting quieter plant and methods and restricting work hours at certain locations have been considered in the assessment. The selection of the most appropriate environmental measures will only be possible once the contractor has confirmed the exact working method and plant to be employed. Operational noise 11.1.7 Different individuals have varying perceptions, sensitivities and reactions to noise. The operational noise assessment does not take account of the sensitivity of specific individuals to noise as this is not possible to assess, instead it is based on documented community responses to noise.
11.2 Policy and legislative context 11.2.1 Table 11.1 lists the parts of the relevant planning policies which have been considered in assessing construction and operational noise and vibration effects. Relevant sections of the ES have been cross-referenced to the appropriate policy at Table 11.1, although reference should be made to the Planning Statement (Volume 7, Document 7.1) for the full policy assessment.
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Table 11.1 Policy issues considered in preparing the ES
Policy reference Policy issue
National planning EN-118 Requires the project to demonstrate good design, layout and landscape considerations to optimise noise policies mitigation.
This is provided in Section 2.4 within Chapter 2 of this document.
EN-1 Paragraph 5.11.4 requires that, where noise effects are likely to arise, the applicant should include: A description of the noise generating aspects of the development proposal leading to noise impacts including the identification of any distinctive tonal, impulsive or low frequency characteristics of the noise.
This is provided in paragraphs 11.13.8 to 11.13.12 within this Chapter.
EN-1 Paragraph 5.11.4 further requires: Identification of noise sensitive premises and noise sensitive areas that may be affected.
This is provided in paragraphs 11.13.1 to 11.13.5 and Table 11.27 within this Chapter and Appendix 11A within Volume 5, Document 5.4.11A.
EN-1 Paragraph 5.11.4 further requires a description of: The characteristics of the existing noise environment.
This is provided in Section 11.5 and Tables 11.5 and 11.6 within this Chapter and in Appendix 11B within Volume 5, Document 5.4.11B.
EN-1 Paragraph 5.11.4 further requires: A prediction of how the noise environment will change with the proposed development; In the shorter term such as during the construction period; In the longer term during the operating life of the infrastructure; At particular times of the day, evening and night as appropriate;
This is provided in Section 11.9 of this Chapter and in Appendix 11E within Volume 5, Document 5.4.11E.
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Policy reference Policy issue
EN-1 Paragraph 5.11.4 further requires: An assessment of the effect of predicted changes in the noise environment on any noise sensitive premises and noise sensitive area.
This is provided in Section 11.15 of this Chapter and in Appendix 11E within Volume 5, Document 5.4.11E.
EN-1 Paragraph 5.11.4 further requires details of: Measures to be employed in mitigating noise.
This is provided in Section 11.6 within this Chapter . In addition, construction noise and vibration effects will be managed through provisions in the CEMP Appendix 3C within Volume 5, Document 5.4.3C.
EN-1 Paragraph 5.11.6 states that operational noise, with respect to human receptors, should be assessed using the principles of the relevant British Standards and other guidance and for the prediction, assessment and management of construction noise, reference should be made to any relevant British Standards (such as BS5228).
The construction noise assessment has been carried out accordance with BS5228 as described in the assessment methodology in Section 11.8.
The method of operational noise assessment is provided in paragraphs 11.14.4 to 11.14.19 within this Chapter.
EN-1 As part of the decision-making process, EN-1 (Para. 5.11.9) refers to the Noise Policy Aims of the Noise Policy Statement for England (NPSE)142 (see below).
EN-519 Para. 2.9.2 recognises that “all high voltage transmission lines have the potential to generate noise under certain conditions.” In addition Para. 2.9.7 states that “audible noise effects can also arise from substation
142 Department for Environment, Food and Rural Affairs. Noise Policy Statement for England. London, March 2010.
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Policy reference Policy issue
equipment such as transformers, quadrature boosters and mechanically switched capacitors” and “noise may also arise from discharges on overhead line fittings such as spacers, insulators and clamps”.
EN-5 Para. 2.9.8 also sets out the requirements for an applicant’s audible noise assessment: “Standard methods of assessment and interpretation using the principles of the relevant British Standards are satisfactory for dry weather conditions, they are not appropriate for assessing noise during rain, which is when overhead line noise mostly occurs, and when the background noise itself will vary according to the intensity of the rain.”
Para. 2.9.9 continues “Therefore an alternative noise assessment method to deal with rain-induced noise is needed, such as the one developed by National Grid as described in report TR(T)94,1993143. This follows recommendations broadly outlined in ISO 1996144 (BS 7445:1991) and in that respect is consistent with BS4142:1997145 [superseded by BS4142:2014146].”
The method of assessment is detailed in paragraphs 11.14.4 to 11.14.19 within this Chapter.
EN-5 Requires the applicant to consider mitigation measures, specifically: The positioning of lines to help mitigate noise.
This is provided in Section 2.4 within Chapter 2 of this document.
EN-5 Requires the applicant to consider mitigation measures, specifically: The use of an appropriately sized conductor arrangement to minimise potential noise.
This is provided in Paragraph 3.4.1 within Chapter 3 of this document.
EN-5 Requires the applicant to consider mitigation measures, specifically: Quality assurance through manufacturing and transportation to avoid damage to overhead line conductors;
143 Technical Report TR(T)94, Issue 1, October 1993. A Method for Assessing the Community Response to Overhead Line Noise, National Grid. 144 The International Organisation for Standardisation ISO 1996 Parts 1 to 3 145 BS4142:1997 ‘Method for rating industrial noise affecting mixed residential and industrial areas’ British Standards Institution, 1997 146 BS4142: 2014 ‘Methods for rating and assessing industrial and commercial sound’. British Standards Institution, 2014.
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Policy reference Policy issue
This is provided in paragraph 11.6.2 within this Chapter.
EN-5 Requires the applicant to consider mitigation measures, specifically: Ensuring that conductors are kept clean and free of surface contaminants during installation.
This is provided in paragraph 11.6.2 within this Chapter.
EN-5 EN-5 does not refer specifically to construction noise.
NPPF36 Significant adverse impacts on health and the quality of life as a result of noise from new development should be avoided (Para. 123); other adverse impacts on health and quality of life arising from noise from new development should be reduced to a minimum. The NPPF does not contain assessment criteria, instead providing a series of policies, giving local authorities the flexibility in meeting the needs of local communities.
The NPPF (March 2012) is taken into account by Local Authorities when preparing their local and neighbourhood plans which form the basis for noise (including vibration) policies within an area.
The NPPF goes on to state in Paragraph 123 that “Planning policies and decisions should aim to: Avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; Mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through use of conditions; Recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land use since they were established, and Identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value”.
The NPPF document does not refer to any other documents regarding noise other than the NPSE.
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Policy reference Policy issue
Construction noise and vibration effects will be managed through provisions in the CEMP in Appendix 3C within Volume 5, Document 5.4.3C. In addition draft DCO Requirement 6 provides for a Noise and Vibration Management Plan (NVMP) to be prepared. The effects of operational noise are assessed in Section 11.15 of this Chapter.
NPSE, Defra Paragraph 1.7 states Defra’s Noise Policy Aims, which should: avoid significant adverse effects from noise, (March 2010) minimise adverse effects and where possible contribute to the improvement of health and quality of life.
The NPSE aims include the terms “significant adverse” and “adverse”. The World Health Organisation is currently applying the following established concepts from toxicology to noise impacts:
NOEL – No Observed Effect Level. This is the level below which no effect can be detected. In simple terms, below this level, there is no detectable effect on health and quality of life due to the noise. LOAEL – Lowest Observed Adverse Effect Level. This is the level above which adverse effects on health and quality of life can be detected.
The NPSE expands these terms leading to the concept of a Significant Observed Adverse Effect Level.
SOAEL – Significant Observed Adverse Effect Level. This is the level above which significant adverse effects on health and quality of life occur.
The NPSE goes on to state that it is not possible to have a single objective noise-based measure that defines SOAEL that will be applicable to all sources of noise in all situations. Consequently, the SOAEL is likely to be different for different noise sources, for different receptors and at different times.
Local planning CCC LP When granting planning permission for development which could potentially result in pollution, the Council will policies Policy C40 impose conditions or seek agreements to ensure subsequent mitigation measures are undertaken.
CCC DLP When granting planning permission for development which could potentially result in pollution, the Council will Policy QL12 impose conditions or seek agreements to ensure subsequent mitigation measures are undertaken.
TDC LP In setting a strong regeneration agenda for the area to meet the economic and social needs of local people, the 2006 No.13 Council is also keen to ensure that the environmental quality of the area is maintained and enhanced, both for local residents and visitors, and to encourage inward investment.
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Policy reference Policy issue
TDC DLP Development with potential to pollute will be permitted only where applicable statutory pollution controls and Policy SE01 siting will effectively and adequately minimise impact upon land use and the environment.
TDC DLP Development proposals that generate significant levels of noise must be accompanied by a scheme to mitigate Policy SE06 such effects, bearing in mind the nature of surrounding uses. Proposals that would have an unacceptable impact on noise-sensitive areas or uses will not be permitted.
DDC LP Sets out to minimise the effects of pollution by, or on, new development, but does not specifically refer to noise. 2002 No.7 and No.16
DDC CS Development which would result in the loss of, or adversely affect the character or appearance, of the Policy DM15 countryside will only be permitted if it is: i. In accordance with allocations made in Development Plan Documents; or ii. Justified by the needs of agriculture; or iii. Justified by a need to sustain the rural economy or a rural community; iv. It cannot be accommodated elsewhere; and v. It does not result in the loss of ecological habitats.
Provided that measures are incorporated to reduce, as far as practicable, any harmful effects on countryside character.
KCC Recognises that the protection and enhancement of the environment is the key to sustaining a high quality of Environment life in Kent. Policy
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11.2.2 Additionally, there are a number of separate guidance documents which contain advice on the assessment and control of noise with respect to various source and receptor types relevant to this assessment. These are summarised (along with other relevant guidance documents) in Table 11.2.
Table 11.2 Standards and guidance to be considered in preparing the ES
Guidance Document Summary
Construction noise
British Standard 5228: 2009 Provides recommendations for basic methods of noise +A1:2014 ‘Code of Practice control relating to construction and open sites where for Noise and Vibration work activities/operations generate significant noise Control on Construction and levels, including industry-specific guidance. Open Sites’ Part 1 – Noise
British Standard 5228: 2009 Provides recommendations for basic methods of +A1: 2014 ‘Code of Practice vibration control relating to construction and open sites for Noise and Vibration where work activities/operations generate significant Control on Construction and noise levels, including industry-specific guidance. Open Sites’ Part 2 – Vibration
Operational noise
BS8233:2014 Sound Presents ‘good’ and ‘reasonable’ design criteria for insulation and noise reduction internal noise levels in residential living rooms during for buildings147 the day, and in bedrooms at night.
BS4142:2014146 Method for Presents a method to assess the acceptability of the rating and assessing industrial levels of noise from a proposed new noise source. and commercial sound
World Health Organisation Presents guideline noise levels for community noise in Guidelines for Community specific residential environments e.g. outdoor living Noise (1999)148 areas, outside bedrooms.
World Health Organisation Considers the potential health effects of environmental Night Noise Guidelines for night noise, based on a review of available research Europe149 by a working group of experts.
Legislative requirements 11.2.3 Legislation on noise issues is primarily focussed on the control of noise emissions for example through statutory nuisance or the control of occupational exposure to noise. Key relevant legislation includes the following: Environmental Protection Act 1990 (as amended);
147 BS 8233:2014, Guidance on sound insulation and noise reduction for buildings, British Standards Institute. 148 World Health Organisation Guidelines for Community Noise, 1999 149 World Health Organization. Night Noise Guidelines for Europe. Copenhagen: World Health Organization.
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Noise Act 1996; and Control of Pollution Act 1974.
11.3 Data gathering methodology 11.3.1 A combination of desk-based and site-based survey techniques have been employed to derive baseline information, the objective being to identify and evaluate the potential noise effects on receptors arising from the construction and operation of the proposed development.
Desk study 11.3.2 The following information has been used in the assessment: Ordnance Survey mapping; topographical data; previous experience of similar developments on the 400kV electricity transmission network in England and Wales and on-site noise monitoring data. Construction noise 11.3.3 Sensitive receptors considered as part of the construction noise and vibration assessment have been identified from a review of online map and aerial photograph resources (https://maps.google.co.uk, www.magic.gov.uk and digital Ordnance Survey mapping) and Intergraph Geomedia mapping software. 11.3.4 Thirteen construction noise measurement points along the route were selected to be representative of residential receptors along the route and were agreed with the Environmental Health Officer (EHO) for the relevant Local Planning Authorities at a meeting at Canterbury City Council on 18 August 2014. The monitoring locations are shown in Figure 11.1 within Volume 5, Document 5.3.11. The locations were selected as being representative of the closest sensitive receptor locations for both the proposed 400kV overhead line and the existing 132kV PX route. Receptors were considered representative in terms of the nature of the surrounding environment and proximity to other noise sources such as roads and railway lines. Operational noise 11.3.5 A desk based assessment of sensitive receptors within each section of the proposed development has been undertaken by the use of aerial photography available from Google Maps and Intergraph Geomedia mapping software. 11.3.6 Fifteen operational noise measurement points along the proposed 400kV route were selected to be representiative of residential receptors along with the Nethergong Camping site and were agreed with the EHO for the relevant Local Planning Authorities via email consultation (04 July 2014). The monitoring locations are shown in Figure 11.1 within Volume 5, Document 5.3.11.
Survey work 11.3.7 Engagement has taken place with the EHOs of CCC, DDC, TDC and KCC to agree the construction and operational noise baseline monitoring locations (see Figure 11.1 within Volume 5, Document 5.3.11), duration of monitoring and number of monitoring visits.
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Construction noise 11.3.8 Baseline noise surveys (for use in the construction noise assessment) were carried out on 18 and 19 November 2014 during daytime hours, outside of peak traffic hours, between 0900 and 1600. Daytime baseline noise levels were monitored for 2 hours at each location during the daytime. The survey locations are numbered 1-13 on Figure 11.1 within Volume 5, Document 5.3.11. 11.3.9 Measurements were undertaken at a height of 1.5m and in free-field conditions i.e. greater than 3.5m from a reflective surface using a type 1 sound level meter (SLM) with preamplifier and microphone protected by foam windshield. 11.3.10 Weather conditions were suitable for noise surveys, with light winds (< 2m.s-1) on 18 November and calm conditions on 19 November 2014. 11.3.11 The calibration of the sound level meter was checked before and after the measurements using an acoustic calibrator, with any drift being noted. The equipment used has a calibration history that is traceable to a certified calibration institution. 11.3.12 The following instruments were used for the noise surveys: Rion NL32 Type 1 SLM Serial Number 00123728. Rion NL32 Type 1 SLM Serial Number 00903343. Rion NL32 Type 1 SLM Serial Number 01193048. Rion NL32 Type 1 SLM Serial Number 00451268. Rion NL52 Type 1 SLM Serial Number 00620868. Operational noise 11.3.13 For the operational noise assessment, night-time noise levels have been surveyed to determine the baseline situation. In the early hours of 16 July 2013, 23 September 2014, 18th February 2015 and 8th April 2015, attended 5-minute night-time spot measurements were taken at representative locations along the proposed 400kV route, to enable calculations to be undertaken. The night time noise baseline surveys are summarised in Appendix 11B within Volume 5, Document 5.4.11B. 11.3.14 The night-time background noise monitoring locations are shown on Figure 11.1 within Volume 5, Document 5.3.11 and are labelled as A-P to differentiate them from the daytime survey locations. Location F is not identified on the figure as it was found to be unsuitable for monitoring due to the lack of a safe place to carry out the noise measurments. 11.3.15 The measurements were all taken in the early hours of the morning, when weather conditions were fine, with little wind. They are considered representative of the likely quietest ambient background levels. 11.3.16 Measurements were undertaken at a height of 1.5m and in free-field conditions i.e. greater than 3.5m from a reflective surface using a type 1 SLM with preamplifier and microphone protected by foam windshield. 11.3.17 The calibration of the SLMs was checked before and after the measurements using an acoustic calibrator, with any drift being noted. The SLM conformed to BS EN
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61672-1:2003 Electroacoustics - Sound level meters150, and the calibrator conformed to BS EN 60942:2003 Electroacoustics - Sound calibrators151. The equipment used has a calibration history that is traceable to a certified calibration institution. 11.3.18 The following instruments were used for the night-time noise surveys: Bruel and Kjaer 2270 Type 1 SLM Serial Number 2664167; Bruel and Kjaer 2250 Type 1 SLM Serial Number 2506571; and Bruel and Kjaer 2250 Type 1 SLM Serial Number 3000223. 11.3.19 Confirmation has been received from UK Power Networks that their 132kV PX and PY routes were operational on all dates when background noise monitoring was undertaken.
11.4 Environmental Impact Assessment consultation
Environmental Impact Assessment scoping 11.4.1 In addition to comments derived from consultations, the Scoping Opinion for the Richborough Connection project was received from PINS and is included in Appendix 1A within Volume 5, Document 5.4.1A. The Secretary of State consulted on the Scoping Report and the responses received are included in summary below where relevant to Noise and Vibration. 11.4.2 Table 11.3 summarises how all consultee comments from non-statutory pre- application consultations and/or the Scoping Report have been addressed in the ES.
150 BS EN 61672-1:2013 ‘Electroacoustics - Sound level meters. Specifications’. British Standards Institution, 2001 151 BS EN 60942:2003 ‘Electroacoustics – Sound calibrators’. British Standards Institution, 2003
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Table 11.3 Consultee comments and responses to EIA scoping
Consultee Comments How addressed in this ES
Secretary of State The Secretary of State recommends that the Consultation has been carried out with the Environmental Health methodology and choice of noise receptors Department at CCC, DCC and TDC as indicated in Section 11.3 within should be agreed with the relevant this Chapter. The methodology and choice of noise receptors for the Environmental Health Department of the construction phase have been agreed with the relevant Environmental Council. Health Departments at a meeting at Canterbury City Council on 18 August 2014, and via email correspondence (04 July 2014) for the operational phase.
Secretary of State Information should be provided on the types of The construction noise assessment has identified the types of vehicles vehicles and plant to be used during the and plant to be used, as described in Appendix 11A within Volume 5, construction phase. Potential noise sources Document 5.4.11A. generated should be identified and assessed and information should be provided on the type, The assessment has considered the magnitude and duration of the magnitude, duration and extent of noise impacts associated with the construction of the new 400kV overhead line impacts. Where appropriate, measures should and the removal of the 132kV overhead line in Section 11.9 within this be provided to mitigate against noise impacts Chapter. and evidence should be provided to explain how and why they are effective. Embedded environmental measures have been proposed as and where required and these are set out in Section 11.9 within this Chapter. The measures are in accordance with recommended measures in BS5228.
Secretary of State Noise impacts on human receptors should be The construction noise assessment has considered noise impacts on specifically addressed and particularly any human receptors and has considered potential noise impacts during the potential noise disturbance at night and other daytime and on weekdays and weekends in accordance with the unsocial hours such as weekends and public proposed construction hours of 07:00-19:00 on weekdays and 08:00- holidays. 17:00 on weekends. The operational noise assessment methodology takes account of the most onerous night time background noise level by using either 30dB as the baseline level or the measured background noise level (whichever is highest).
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Consultee Comments How addressed in this ES
Secretary of State The noise and vibration assessments should The construction noise assessment has considered noise impacts from take account of the traffic movements along construction vehicle movements on the public road network and on the access routes, especially during the construction access routes in Appendix 11A within Volume 5, Document 5.4.11A phase. The results from the noise and vibration and Section 11.9 of this Chapter. assessments will also provide information to inform the ecological assessment and there As and where required construction noise predictions have been provided should be cross references between these to inform the socio-economic and ecological assessments. chapters.
Secretary of State The ES should describe how noise and vibration Noise and vibration monitoring has been agreed with the relevant impacts will be monitored and how the need for Environmental Health Department, as and where required. This included additional mitigation will be determined and agreement on the monitoring locations, duration of monitoring and delivered. parameters to be measured.
CCC, DDC, Whilst the Councils understand that no Addressed in Sections 11.14 and 11.15 of this Chapter where further TDC, KCC significant adverse effects are expected from comments on daytime effects are provided. operation of the 400kV lines, given that noise associated with the operation of the new 400kV lines are anticipated to be greater than existing, clear data on this should be provided in order for any daytime effects to be properly understood, even if effects shown not to be significant.
CCC, DDC, Any perceptible impact on noise levels at nearby Addressed as a whole in Chapter 11 of this document. TDC, KCC noise sensitive receptors needs to be understood in order for a proper planning judgement to be made. The councils therefore request that this information is provided as part of the ES scope.
CCC, DDC, It is also understood that the T-Pylon design The T-Pylon is not being proposed for this project and as such is not TDC, KCC could have greater noise effects than a lattice considered in the noise assessment. pylon, so this should be properly considered.
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Consultee Comments How addressed in this ES
CCC, DDC, The Councils also want greater assurances and This is addressed in Section 11.15 of this Chapter. No significant effects TDC, KCC for it to be demonstrated in the ES that there will are expected due to the simultaneous operation of the existing 132kV and be no adverse cumulative impact during the proposed 400kV overhead lines. stage in which both the old 132kV and new 400kV lines are live, and this should be considered in the ES.
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Statutory Consultation 11.4.3 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed consultees and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising, inspection of documentation at selected locations and parish and town council briefings. 11.4.4 National Grid prepared a PEIR which was publicised at this consultation stage. National Grid sought feedback on the environmental information presented in that report. Feedback received during Statutory Consultation was considered by National Grid and incorporated where relevant in the design of the proposed development and its assessment and presentation in this ES. 11.4.5 A summary of the Statutory Consultation representations received (relevant to EIA) and National Grid’s responses are summarised at Volume 6, Document 6.1 (Consultation Report). A summary of the main Statutory Consultation representations received from prescribed and non-prescribed bodies in relation to the Noise and Vibration assessment are presented in Table 11.4 overleaf.
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Table 11.4 Consultee comments and responses to PEIR
Consultee Comments and considerations How addressed in this ES
CCC, TDC Addressing the Environmental Health Officers Construction Hours comments set out below regarding noise Construction hours will be 07:00-1900 on a weekday and 08:00-17:00 on assessment and mitigation, including working weekends and these have been assessed accordingly in the ES. hours: National Grid has signed a connection agreement with Nemo Link which - Monday to Friday: 07.30 to 18:00 hours requires the Richborough Connection project to be completed and - Saturday: 08:00 to 13.00 hours operational by Autumn 2018. Engineering design work and construction - Sunday/bank holidays No working phase programming has been undertaken, to take on board likely seasonal restrictions (adverse weather, ground conditions and ecological constraints In addition, it would be sensible to apply construction etc.) which will apply in some parts of the route. As a result of this there is a working hours and delivery times - to minimise the need to carry out construction activities outside of typical daytime hours, effect of the construction on the adjacent residents. including Saturday afternoons and Sundays in order to meet the connection With regards to deliveries to site, there should be no date. deliveries outside of the working hours: Further information is provided in Chapter 3 within this document.
The CEMP is in Appendix 3C within Volume 5, Document 5.4.3C. The The CEMP needs to be submitted for agreement embedded measures schedule in Appendix 3C (Document 5.4.3C) has and approval. been shown to the local authorities during the preparation of the ES.
Different day time working hours are referred to - in Working hours are provided in Chapter 3 within this document. some text and tables a 12 hours working day (07:00- 19:00) is mentioned, but in others, a 10 hour day is referenced. CCC would like a 10 hour working day (08:00-18:00) implemented.
Significance and Adversity: The approach taken to assess the impacts in terms Noise from construction activities, operational machinery, road traffic and of significance and adversity is correct, but there is overhead lines is by its very nature different. The construction noise and not enough justification of the significance criteria or operational noise significance criteria have been described in detail in this
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where the data has been referenced from. This Chapter (Section 11.8 for construction noise and Section 11.14 for needs to be clearly presented in the ES. operational noise).
For construction noise, the significance has been based on Annex E in BS5228. Being a British Standard, this is widely recognised as the approach for determining significance. Steps for applying Annex E are explained in Section 11.8 of this Chapter.
World Health Organisation (WHO) Guidelines and BS4142 have been used to derive significance criteria for use in the operational noise assessment.
Night-time Works Night time work is referred to as a possibility in areas Construction hours will be 07:00-19:00 on a weekday and 08:00-17:00 on where day time road closures may be an issue. It is weekends. Activities outside these hours could relate to traffic important in terms of minimising impact, especially if management, security patrols and installation/removal of netting from close to residential properties, that notice and proper scaffolding, which are not noisy activities. justification for any night time work is given. A four Draft DCO Requirement 7 defines these activities. week notice period, giving time to consider justification and any mitigation would be appropriate.
Maximum Noise Impacts All noise levels referred to are as averages. BS5228 does not provide for the predicting of L levels. Annex C of Maximum or impact noise levels do not appear to Amax BS5228 (database of noise levels for construction plant) provides L have been considered. The ES should address this. Aeq.T levels for static plant at 10m. There are no LAmax levels for static construction plant. BS5228 states there are no general empirical relationships between LAmax and LAeq, T.
Mitigation measures relating to construction noise impacts are set out in the Mitigation measures need to be more fully clarified CEMP in Appendix 3C within Volume 5, Document 5.4.3C. and considered in the ES. Embedded environmental measures relating to specific construction activities are described in Section 11.9 and in Appendix 3B (Document 5.4.3B). Embedded environmental measures for operational noise are described in Paragraphs 11.6.1 to 11.6.7. In addition a NVMP will be prepared under draft DCO Requirement 6.
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Consultee Comments and considerations How addressed in this ES
TDC TDC suggested that National Grid undertake a Background noise measurements were undertaken at Marsh Farm. The noise assessment at Marsh Farm because of its construction and operational noise assessment has considered Marsh close proximity to the proposed overhead line. Farm. Noise impacts have been predicted at Marsh Farm for all construction activities and predicted noise impacts are presented in Appendix 11A within Volume 5, Document 5.4.11A and for operational noise in Appendix 11E within Document 5.4.11E.
DDC From the submitted PEIR, it is evident that there is Cumulative noise effects of the operation of the existing 132kV and still much work to be completed in terms of proposed 400kV overhead lines are considered in Paragraphs 11.15.22 to TDC assessment of the effects of this project. For 11.15.27 of this Chapter and in Chapter 16 of this document. example, cumulative noise effects of both Cumulative noise effects of the operation of the new 400kV conductors; the new line and operational substation substation and converter station at Richborough are considered in Section noise have still to be fully assessed. In addition, the 11.16 of this Chapter and Chapter 16 of this document. operational effects of the overhead line is only Details of further noise modelling, taking account of site specific conditions based on preliminary information etc and needs are presented in Section 11.15 of this chapter and Appendix 11E within further modelling to take account of site specific Volume 5, Document 5.4.11E conditions. This is all to be reported more fully in the ES and in this respect it is difficult to make an informed decision of the full impact of the project at this stage.
CCC For both construction and operational noise, The classification of receptors is discussed in Section 11.14 of this Chapter. domestic dwellings have been classed as ‘Medium’ WHO Guidelines for Community Noise and BS4142 have been used to DDC in terms of sensitivity. Whist this is acceptable for derive significance criteria for use in the operational noise assessment. The day time construction noise, the classification for classification of residential receptors as ‘medium’ sensitivity is consistent TDC operational noise needs to be further explained and with the approach used for the Hinkley Point C Connection and Hinkley justified in the ES. Point C Nuclear Power Station DCO applications. The level of significance at this sensitivity takes account of guidance from the World Health Organisation. Therefore, when combined with the magnitude criteria, this is not detrimental to medium sensitivity (residential) receptors but provides additional protecton for vulnerable, high sensitivity receptors.
CCC The determination of individual receptor The highest noise levels generated by an overhead line generally occur sensitivities is to be looked at further in the ES and during rainfall, which is expected to occur for 5% of the time in the project DDC this will be very important. The PEIR suggests that area. Overhead line noise is not expected to occur continuously over a
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there are no receptors that would be classified as period of time. Further assessment is provided in Section 11.15 of this TDC ‘high sensitivity’ according to Table 11.16 and as Chapter. such the likely significance of effect at residential receptors within 100m of the route will be moderate and therefore these effects are not likely to be significant. Further justification for this needs to be given in the ES as potentially any noise in excess of 5dB above background noise levels could have an effect especially if occurring continuously over a period of time.
DDC There are some caravan sites along the route, e.g. The assessment has considered construction noise and operational noise to the north of Pluck’s Gutter. No mention is made impacts on caravan sites. The assessment indicates that construction noise of what steps will be taken to reduce the noise impacts will be negligible beyond 300m (Section 11.9 of this Chapter). The impact on such sites. This should be addressed in separation distance between works and Plucks Gutter (+800m) means that the ES. further assessment at this location was not required. A list of receptors considered in the operational noise assessment is provided in Table 11.27 of this Chapter and Appendix 11E within Volume 5, Document 5.4.11E; this list includes caravan sites. The caravan site to the north of Pluck’s Gutter is not included as the separation distance between the proposed 400kV route and this receptor is sufficiently large that further assessment at this location was not required.
CCC There are a number of residential receptors in our Addressed in detail in this chapter district (Table 11.20 and 11.21) in close proximity TDC to the proposed line/substation, so it’s imperative that any impact is fully assessed and justified.
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11.5 Overall noise and vibration baseline
Current baseline 11.5.1 The proposed development is located within a mixture of rural and suburban areas, which will have a correspondingly varied noise environment. 11.5.2 The existing noise climate along the proposed 400kV route is likely to be influenced by the following noise sources: road traffic - due to the local roads in proximity to the Order limits, baseline noise levels are likely to be particularly influenced by traffic noise; noise from fixed and mobile noise sources associated with industrial premises and agricultural activities adjacent to the proposed 400kV route; and railway noise – from the Ashford to Ramsgate railway line that runs parallel to much of the proposed 400kV overhead line and 132kV PX route. 11.5.3 While much of the proposed development is in a rural environment, measured noise levels close to sensitive receptors are considered typical of those likely to be influenced by nearby existing noise sources such as main roads and existing industrial/commercial facilities. Daytime noise and vibration baseline 11.5.4 Baseline noise monitoring (for use in the construction noise assessment) was carried out on 18 and 19 November 2014 as close to receptor locations as possible to ensure measurements were representative. Ten minute measurement intervals were used. Where monitoring was carried out close to roads, the measured LAeq levels have been adjusted for distance to the receptor location as indicated in Table 11.5. A full set of survey data is included in Appendix 11A within Volume 5, Document 5.4.11A. Noise monitoring locations are shown on Figure 11.1 within Volume 5, Document 5.3.11.
Table 11.5 Measured baseline noise levels (Construction Noise – Daytime))
Location Description Noise Level (dB A)1
LAeq(T) LAmax LAmin
Section A
1 Bricknor Close 47.7 76.0 38.5
2 Static caravans off Vauxhall Lane 59.4* 96.2 21.5
3 Property off Shalloak Road opposite Lynne Wood 58.7* 96.2 21.5
4 Bluebell Wood Park 62.5* 85.6 42.4
5 6 Mayton Lane, Broadoak 51.7 75.1 40.5
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Location Description Noise Level (dB A)1
LAeq(T) LAmax LAmin
6 Behind Popes Lane 55.9 89.7 34.8
Section B
7 Tile Lodge Farm 53.3 75.3 44.0
8 Houses adjacent to Nethergong Camping site. 57.5 81.2 41.1
9 Wall End Farm 69.5 88.4 34.9
Section C
10 Old Road (South East of Sarre) 50.2 87.9 33.4
11 Gore Street 55.5* 84.4 36.3
Section D
12 Sheriffs Court 57.12 88.5 38.8
13 Richborough Farm 48.8 72.6 29.9
1 LAeq,T is the equivalent sound pressure level - the steady sound level that, over a specified period of time, would produce the same energy equivalence as the fluctuating sound level actually occurring.
LAmax is the maximum A-weighted sound pressure level occurring within a specified time period.
LAmin is the minimum A-weighted sound pressure level occurring within a specified time period.
2 Noise levels have been adjusted for distance from measurement location to receptor location
11.5.5 No baseline vibration surveys have been carried out. There are no obvious sources of vibration other than possible vibration from train movements, which would only be likely to be significant in close proximity to the railway line. There is also a possibility that on occasions HGVs could generate some vibration within very close proximity to access routes, where there are notable irregularities in the road surface. Night-time noise baseline 11.5.6 The night time baseline noise surveys and measured night-time baseline noise levels 152 (measured as ambient background levels, LA90,5min) are summarised in Appendix 11B within Volume 5, Document 5.4.11B. Baseline noise levels were up to 47dB on the outskirts of Canterbury and as low as 21dB in the most rural locations along the proposed 400kV route. The chosen baseline noise levels at each monitoring
152 The majority of baseline noise measurements were undertaken before the publication of BS4142:2014.
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location are summarised in Table 11.6. The chosen baseline noise level is 30dB at all locations except at those locations where higher baseline levels were measured. Noise monitoring locations are shown on Figure 11.1 within Volume 5, Document 5.3.11.
Table 11.6 Chosen baseline noise levels (Operational Noise – Night time)
Location Description Noise Level (dB A)1
LA90
Section A
A Vauxhall Avenue 33
B Vauxhall Road 46
C Shalloak Road 33
D Hawe Lane 30
E Herne Bay Road 30
F Hoath Road n/m 2
Section B
G St Alban’s Road 30
H Sandpit Hill 30
Section C
I Island Road 30
J Island Road 30
K Sarre Court 30
L Gore Street 30
Section D
M Sherriffs Court Lane 30
N Station Approach 30
O Ebbsfleet Lane 34
P Marsh Farm Road 30
1 LA90,T is the A-Weighted noise level exceeded for 90% of measurement time interval (T). 2 n/m – No measurement. Location F was found to be unsuitable for monitoring due to the lack of a safe place to carry out the noise measurments.
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Future baseline 11.5.7 Road traffic is the dominant contributor to baseline noise levels; with two A-roads (the A28 and the A291) the most heavily trafficked in proximity to receptors along the proposed 400kV route. A review of Highways Agency data indicates that between 2009 and 2013, traffic flows on the A28 were relatively constant (+/- 2% change), whilst traffic flows on the A291 reduced by almost 10%. These changes would not be perceptible, and there are no apparent future changes in the area that would cause changes in road traffic volume, or other characteristics, that may result in significant long term changes in wide-scale ambient noise levels. Future baseline noise levels are therefore not expected to differ significantly from the baseline. The cumulative effects of traffic, especially with regards to the proposed Sturry Link Road are discussed in Chapter 16 within this document, and the effects are not expected to affect the assessment of operational noise.
11.6 Embedded environmental measures incorporated into the proposed development
Construction noise 11.6.1 The proposed development includes a range of embedded environmental measures (see Appendix 3B within Volume 5, Document 5.4.3B). Construction noise and vibration effects will be managed through provisions in the CEMP (see Appendix 3C within Volume 5, Document 5.4.3C) and delivered through Requirements 5 and 6 (including the NVMP) of the draft DCO (Volume 2, Document 2.1).
Operational noise 11.6.2 Noise from overhead lines cannot be practically mitigated once erected and operational. Mitigation such as the design and routeing of the overhead line are described in Section 2.4 within Chapter 2 of this document. Quality assurance through manufacturing and transportation will be undertaken to avoid damage to overhead line conductors which can increase potential noise effects. Care will be taken during installation to ensure that conductors will be kept clean and free of surface contaminants during stringing. This will minimise the risk of excessive dry noise on energisation of the proposed 400kV overhead line. 11.6.3 Under normal operating conditions pylon fittings, such as dampers, spacers, clamps and insulators are designed not to generate audible noise when in operation. 11.6.4 Pylon fittings, such as insulators, dampers, spacers and clamps are designed and procured in accordance with a series of National Grid Technical Specifications. The technical specifications define National Grid functional and performance requirements for new equipment associated with electricity transmission. 11.6.5 To be approved for use on the National Grid high voltage electricity transmission network, each fitting design must be Type Registered. Type registration comprises a series of tests on the fitting in question to ensure compliance with the relevant technical specification. These tests include performance requirements for corona inception and audible noise on all fittings along with wind tunnel testing of insulators for audible tones generated by Aeolian mechanisms. 11.6.6 Once a fitting has been type registered and approved for use, a number of further tests are also carried out post-manufacture in the form of Sample Testing. This
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ensures the fitting conforms to the specification in the type registration documentation. 11.6.7 The Technical Specification and Type Registration processes reduce the potential for audible noise and tones to occur from all types of fittings, including insulators. Where noise does occur it is likely to be localised and of short duration. If due to a fault, actions can be taken to rectify it. Where noise from fittings does occur which results in a complaint, appropriate actions can be taken to seek to remedy the cause of the noise, usually through cleaning or replacement of the relevant fitting. 11.6.8 Environmental measures relating to both construction and operational noise that have been incorporated into the proposed development are discussed in Table 11.7.
Table 11.7 Proposed embedded environmental measures
Potential Predicted Incorporated measure receptor changes and potential effects
Construction noise effects
Residents Temporary Several measures will be implemented as a within 300m increase in noise requirement of the CEMP (Appendix 3C) and a of from construction NVMP which will be prepared under draft DCO construction activities (fixed Requirement 6. Measures will include (but are activities and mobile plant not restricted to) the following. on site) Working hours restricted to core working hours (see Chapter 3 within this document), unless there are essential activities permitted under draft DCO Requirement 7. Restricting work hours to 0800 to 1800 (weekdays) and Saturday (0800 to 1300) at the closest locations where required to reduce noise to acceptable levels. Selection of quieter plant to comply with EU Directives and less intrusive methods. Use of acoustic screens and enclosures where required, in particular at pylons along the PX route close to housing and around the site compounds. Site hoarding with acoustic properties to be provided at Westbere compound. Strict maintenance of all plant and equipment. Adopt Best Practicable Means to mitigate and manage construction noise effects. Maintain access routes to prevent tyre generated noise and vibration. Noise and/or vibration monitoring where required and as agreed with the relevant LPA.
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Potential Predicted Incorporated measure receptor changes and potential effects
Operational noise effects
Residents Increases in Pylon fittings designed and procured in within noise from accordance with National Grid’s functional and approximately conductors both performance requirements. 300m of in dry and wet Compliance with performance requirements for proposed conditions. corona inception and audible noise on all fittings. 400kV route Wind tunnel testing of insulators for audible tones generated by Aeolian mechanisms. Testing to ensure each fitting type conforms to the specification. Conductor design to ensure operation below level at which conductor surface electric stress exceeds the inception level for corona discharge activity. Care taken during installation to ensure conductors kept clean and free of surface contaminants during stringing.
11.6.9 In the assessment presented below, environmental measures are proposed. These are used to demonstrate that it would be possible to achieve the required noise levels. However, other means to achieve such results are possible, such as choice of equipment or method of working, and these would be outlined in the NVMP under draft DCO Requirement 6.
11.7 Part A Construction noise - Scope of the assessment 11.7.1 Construction and operational noise effects have been assessed in separate Sections of this Chapter. This Section considers construction noise effects while operational noise effects are considered in Part B, Section 11.13.
Potential receptors 11.7.2 Construction works have the potential to generate noise and vibration at levels that may be disturbing to people and sensitive receptor locations. Construction noise and vibration effects are however of a temporary nature, occurring for the duration of the works at each work location. 11.7.3 The effects of noise on noise-sensitive receptors are varied and complicated, including interference with speech communication, disturbance of work or leisure activities, disturbance of sleep, annoyance and possible effects on mental and physical health. Some individuals will be more sensitive to noise than others. 11.7.4 Construction activity can result in varying degrees of ground vibration, depending on the equipment and method employed. Operation of construction equipment causes ground vibration which spreads through the ground and diminishes in strength with distance.
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11.7.5 Vibration may also have the potential to cause structural damage, although this is rare and would only occur where use of heavy machinery takes place in very close proximity to sensitive locations. 11.7.6 In terms of noise and vibration an environmental receptor is defined as any occupied premises used as a dwelling (including gardens), places of worship, educational establishments, hospitals or similar institution or any other property likely to be adversely affected by an increase in noise or vibration level. 11.7.7 For the construction noise and vibration assessment, receptors within 300m of construction works have been identified to assess the subsequent effect on receptors, of the proposed development. BS5228 2009 +A1 2014 Part 1 - Noise153 does not specify the study area to be considered; however, the greatest effects would occur within 100m of noise sources. As discussed below in paragraph 11.7.10 of this Chapter, the study area has extended to 300m from any construction works. 11.7.8 A desk study review of the Order limits has indicated that receptors likely to be affected by noise are residential in nature. Ecologically noise sensitive receptors have been considered in Chapter 9 of this document. 11.7.9 The receptor locations affected by noise will be different for various construction activities, depending on the location of the activity in relation to the receptor locations. The receptors affected by the various construction activities are listed in Appendix 11A within Volume 5, Document 5.4.11A.
Spatial and temporal scope 11.7.10 The spatial scope of the noise and vibration assessment includes all areas up to 300m from construction works. This is in accordance with BS5228 and using professional judgement. At distances over 300m noise predictions have to be treated with caution because of the increasing importance of meteorological effects. The predicted noise levels when undertaken in accordance with BS 5228 may be incorrect at distances greater than 300m. Annex F of BS5228 indicates that at distances over 300m noise predictions have to be treated with caution, especially where a soft ground correction factor has been applied, because of the increasing importance of meteorological effects. 11.7.11 Construction works will take place during the daytime from 07:00 to 1900 on weekdays and 08:00 to 17:00 on weekends and Bank holidays. Some work relating to traffic management and installation/removal of netting on scaffolding may take place at night at certain locations where it is essential not to disrupt traffic flows during the day. 11.7.12 The noise and vibration impacts will occur for the duration of the construction and dismantling works and the assessment has therefore considered the entire construction and dismantling phase. 11.7.13 This is a linear project and construction noise impacts will be transient in nature, with impacts occurring for a relatively short duration at specific receptor locations. Construction is expected to commence in 2017 and will be completed in 2021.
153 British Standards Institute (2014) BS5228 2009 +A1:2014 ‘Code of Practice for Noise and Vibration Control on Construction and Open Sites’ Part 1 - Noise
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Potentially significant construction effects 11.7.14 The potentially significant effects relating to the proposed development, which are subject to further assessment in this chapter (including inter-related and cumulative effects) are summarised below. Potential effects from construction activity noise on residential receptors (construction of the 400kV overhead line and dismantling of the 132kV PX route): Construction activity noise has the potential to cause disturbance where works take place in close proximity (generally within 100m) to receptors. The time of day that works take place also influences the significance of the noise. Dismantling of the 132kV PX route will take place in close proximity to certain receptors, in some cases as close as 10 to 15m, for example at Ulcombe Gardens, Broadoak Road and Halstead Road. Therefore further assessment of this effect is required. The construction of the 400kV overhead line will be completed before removal of the 132kV line, so there will not be any cumulative impact from these activities. Potential effects from noise from construction access routes on residential receptors (construction of the 400kV overhead line and dismantling of the 132kV PX route): Noise from traffic accessing the proposed development along access routes has the potential to have effects on residential receptors in close proximity to the access routes and therefore further assessment of this effect is required. Potential effects from construction vibration on residential receptors: Further assessment of potential vibration effects on residential receptors in the vicinity of pylon locations where piling is likely to take place is required. Inter-related effects 11.7.15 Noise and vibration from the construction phase of the proposed development could lead to effects on residential receptors, socio-economic receptors and protected species and habitats (biodiversity). Effects on Biodiversity have been considered in Chapter 9 and on socio-economic receptors in Chapter 15 (Socio-economics and recreation) both within this document). There will not be any inter-related effects between construction noise and other effects such as air quality or visual effects. Cumulative effects 11.7.16 There are several developments within the vicinity of the proposed development that would or are highly likely to coincide with the construction phase (see Chapter 16 within this document), such as the Discovery Park Biomass Plant, Thanet Solar Farm, Discovery Park Masterplan, the new substation and convertor station at Richborough as part of the Nemo Link project, Richborough Energy Park Peaking Plant, the development at Strategic Development Site SP3 Site 2: Sturry and Broad Oak and Sturry Link Road. 11.7.17 Where construction works for these developments takes place within close proximity (300m) to construction activities for the Richborough Connection, there is the potential for cumulative effects during the construction phase. It is envisaged that all of the other developments would adopt best practice mitigation measures to minimise noise and vibration. 11.7.18 Any traffic generated by other developments has been accounted for in the Traffic and Transport Assessment (Chapter 10 within this document). The cumulative
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traffic volumes for all developments have been considered in the traffic data considered in this assessment.
Scoped out effects 11.7.19 The Scoping Report and PEIR identified a number of effects to be scoped out, as desk-top studies and initial site work considered that they were unlikely to be significant and therefore not subject to further assessment. The issues identified to be scoped out are as follows. Potential noise effects on nearby residential receptors from night time works during construction/dismantling phases of the proposed development relating to putting up or removing nets on scaffolding and traffic management. These works are not expected to generate significant levels of noise as they will involve putting up or removing the nets between scaffolding either side of roads or railways, traffic management set up (workmen putting out cones/signs) and security patrols. Only works that are not possible within the core construction working hours (e.g. due to traffic disruption) will be carried out a night. For a full list of activities that may be required outside of the core construction working hours please refer to Requirement 7 of the draft DCO (Volume 2, Document 2.1, Schedule 3). The noise levels associated with these works are unlikely to exceed the threshold levels for night time noise. Therefore noise effects are unlikely to be significant and are scoped out of the assessment. Potential noise effects from construction traffic travelling along public roads on residential receptors in close proximity to construction access routes: DMRB Volume 11, Section 3, Part 7 (Highways Agency, 2011)154 sets out guidance and a methodology for assessing noise effects where there may be a change in road traffic flows. DMRB states that generally a 25% increase in flow is required for a 1dB(A) change in traffic noise levels, which would warrant further assessment. Traffic data provided in the traffic assessment (Chapter 10 of this document) indicates that construction traffic will not result in increases of 25% or more on the public road network and therefore an assessment in accordance with DMRB has been scoped-out of the assessment. The highest increases in road traffic on the public road network during construction, as reported in Chapter 10 is reported as a 7.8% increase on Gore Street and 7.3% on Sandpit Lane, which is well below the 25% threshold set out in DMRB. Potential cumulative noise effects from works associated with the dismantling of the 132kV PX route and the construction of the new 400kV overhead line: The 132kV PX route will only be removed once the 400kV overhead line is fully operational. Therefore these two elements of the proposed development will not occur at the same time and therefore noise effects in relation to this are scoped out of the assessment. Potential noise effects associated with the long-term maintenance of the 400kV overhead line: The overhead line would require routine inspections and occasional maintenance works, which are very unlikely to result in noise disturbance. Any noise emissions caused by daytime maintenance works would be slight and temporary. These works are unlikely to be significant and therefore have not been considered any further.
154 Department of Transport (2011) DMRB Volume 11, Section 3, Part 7
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11.8 Assessment methodology - construction noise and vibration
Methodology for prediction of effects Construction noise 11.8.1 BS 5228-1153 Annex E recommends the ABC method to establish construction noise limits for EIA. The ABC method involves rounding the existing ambient noise levels to the nearest 5dB for the appropriate time period (night, evening/weekends or day) and then comparing these levels to the total noise level, including construction noise. If the total noise level exceeds the existing rounded value, then a significant effect is deemed to have occurred. This method is explained further in the following paragraphs. 11.8.2 The relevant data from Table E.1 of Annex E in BS52283 shows example threshold values as reproduced below in Table 11.8.
Table 11.8 Significance evaluation: construction noise
Assessment category and Threshold level threshold value period Category A Category B Category C
Daytime (07.00 – 19.00) and 65 70 75 Saturday mornings(07.00 – 13.00)
Evenings (19.00 – 23.00) & 55 60 65 weekends (13.00 - 23.00) Saturdays and (07.00 – 23.00) Sundays
Night-time (23.00 – 07.00) 45 50 55
Weekends Evenings (19.00 – 23.00) & weekends (13.00 - 23.00) Saturdays and (07.00 – 23.00) Sundays
A) Category A: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are less than these values. B) Category B: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are the same as category A values. C) Category C: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are higher than category A values.
11.8.3 A significant effect has been deemed to occur if the total LAeq (equivalent noise level – see Volume 1, Document 1.5 for a glossary of all technical terms), including construction, exceeds the threshold level for the Category appropriate to the ambient noise level. 11.8.4 If the ambient noise level exceeds the threshold values given in the table (i.e. the ambient noise level is higher than the above values), then a significant effect is
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deemed to occur if the total LAeq noise level for the period increases by more than 3 dB due to construction activity. 11.8.5 The thresholds indicated in Table 11.8 would equate to a Lowest Observed Adverse Effects Level (LOAEL) represented by Category A levels and a Significant Observed Effects Level (SOAEL) for category C thresholds as defined in the NPSE. 11.8.6 The above criteria in Table 11.8 apply to residential receptors only. 11.8.7 BS5228153 Annex E also provides threshold trigger levels above which there is a responsibility on the developer to provide noise insulation or a scheme to facilitate temporary re-housing. This would involve finding alternate accommodation for affected residents at times when noise levels will be very high, regularly exceeding 85 dB(A) during the daytime. The standard suggests that noise insulation should be provided if the trigger levels shown in Table 11.9 are predicted to be exceeded for a period of ten or more days of working in any fifteen consecutive days, or for a total of days exceeding 40 in any six month period.
Table 11.9 Construction noise triggers for noise insulation and temporary re-housing
Day Relevant Averaging Noise insulation Temporary re- time period time T trigger level, dB housing trigger 1 LAeq,T level, dB LAeq,T
0700-0800 1 hour 70 80
0800-1800 10 hour 75 85 Monday 1800-1900 1 hour 70 80 to Friday 1900-2200 3 hour 65 75
2200-0700 1 hour 55 65
0700-0800 1 hour 70 80
0800-1300 5 hour 75 85
Saturday 1300-1400 1 hour 70 80
1400-2200 3 hour 65 75
2200-0700 1 hour 55 65
Sunday 0700-2100 1 hour 65 75 and Public 2100-0700 1 hour 55 65 Holidays
Note 1) Equivalent continuous A-weighted noise level predicted or measured at a point 1m in front of the most exposed windows or doors leading directly to a habitable room (living room or bedroom) in an eligible dwelling.
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11.8.8 Based on the limits in Table 11.8 and Table 11.9, the criteria for assessing the magnitude of construction noise effects are set out in Table 11.10.
Table 11.10 Magnitude of change for construction noise
Magnitude of Daytime (07:00 – 19:00) and Saturday afternoon (13:00 – effect Saturday mornings (08:00 – 17:00) and Sunday mornings 13:00) (08:00 – 17:00)
65 dB LAeq (3 hour for Saturday High >70dB LAeq (10 hour for weekday 13:00 to 17:00 and 1 hour for all and 5 hour for Saturday) other periods).
Between 65 to 70 dB LAeq (10 hour Between 55 and 65 dB LAeq (3 Medium for weekday and 5 hour for hour for Saturday 13:00 to 17:00 Saturday) and 1 hour for all other periods).
Between 55 to 65 dB LAeq (10 hour Between 45 and 55 dB LAeq (3 Low for weekday and 5 hour for hour for Saturday 13:00 to 17:00 Saturday) and 1 hour for all other periods).
Below 45 dB LAeq (3 hour for Negligible Below 55 dB LAeq (10 hour for Saturday 13:00 to 17:00 and 1 weekday and 5 hour for Saturday) hour for all other periods).
Below 40 dB LAeq (3 hour for No Effect Below 45 dB LAeq (10 hour and and Saturday 13:00 to 17:00 and 1 5 hour for Saturday)). hour for all other periods).
11.8.9 The sensitivities of receptors to construction noise and vibration are shown in Table 11.11.
Table 11.11 Sensitivity of receptors to construction noise and vibration
Sensitivity of Construction noise Construction vibration receptor
High Education, healthcare facility Listed buildings & non-earthwork Scheduled Monuments
Medium Residential Unreinforced or light framed structures
Low Area used primarily for leisure Residential or light commercial activities, including PRoW, sites buildings of historic or cultural importance.
Negligible All other areas such as those Reinforced or framed structures used primarily for agricultural or industrial purposes
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Construction traffic 11.8.10 Effects from construction traffic along public roads are scoped out of the assessment (see Section 11.6 of this Chapter). However given that there will be HGV traffic using the access routes to reach the working areas and that these are not existing roads an assessment of the noise levels from the HGVs using these routes has also been undertaken in accordance with BS5228153. The sensitivity and magnitude criteria used for this assessment is also outlined in Tables 11.10 and 11.11. Construction vibration 11.8.11 BS 5228-2155 Annex B provides guidance on effects of vibration levels on humans in terms of peak particle velocity (PPV). The guidance is based upon human response to vibration contained within British Standard 6472-1:2008156. This guidance has been used to assess construction vibration effects.
Significance evaluation criteria Construction activity and HGV noise 11.8.12 A combination of receptor sensitivity and magnitude of effect was used to determine the overall significance of the effect, as shown in Table 11.12.
Table 11.12 Significance criteria for construction activity and HGV noise effects
Significance Sensitivity of receptor of effect
Magnitude High Medium Low Negligible
High Major Major Moderate Minor
Medium Major Moderate Minor Negligible
Low Moderate Minor Negligible Negligible
Negligible Minor Negligible Negligible Negligible
No Effect Negligible Negligible Negligible Negligible
11.8.13 A significant effect is indicated where a receptor is of high or medium sensitivity and the magnitude of effect is high, and where the receptor is of high sensitivity and the magnitude of effect is medium. A significant effect would therefore occur where the overall significance is indicated as major (in bold text in Table 11.12 above). Major effects therefore are deemed to occur where magnitude of effects are high or medium and receptor sensitivity is high or medium. Considering the transient nature of the works and the fact that construction noise is temporary in duration, only effects of major significance have been determined as a significant effect.
155 British Standard 5228: 2009 + A1: 2014 ‘Code of Practice for Noise and Vibration Control on Construction and Open Sites’ Part 2 - Vibration 156 British Standard 6472-1:2008 ‘Guide to evaluation of human exposure to vibration in buildings. Vibration sources other than blasting.
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Construction vibration 11.8.14 Using the guidance provided in BS 5228-2155, a significance of effect in terms of PPV has been determined and is presented in Table 11.13.
Limits of Deviation 11.8.15 Construction noise predictions have been carried out considering the distance from proposed pylon locations to existing receptor locations. 11.8.16 If pylon locations were to change within the LoD, the predicted noise impacts on receptors would change. Where pylons move closer to receptors predicted noise levels would increase. A halving of the distance between receptors and construction locations would result in a 6dB increase in noise. The closest receptor to a pylon location is 69m for the caravan located near PC11. At this location, the LoD is 30m, but due to the need for the conductors (and their lateral swing during high winds) to remain within the LoD, pylon PC 11 could not move by this amount. For most pylon locations the separation distance to the closes receptors is such that slight shift in location within the LoD would not result in a significant increase in the predicted construction noise level.
Table 11.13 Significance evaluation: construction vibration
Vibration Effect Significance level
0.14 mm.s−1 Vibration might be just perceptible in the most sensitive situations for most vibration frequencies Neutral associated with construction. At lower frequencies, people are less sensitive to vibration.
0.3 mm.s−1 Vibration might be just perceptible in residential Slight Adverse environments.
1.0 mm.s−1 It is likely that vibration of this level in residential environments will cause complaint, but can be Moderate tolerated if prior warning and explanation has been Adverse given to residents.
10 mm.s−1 Vibration is likely to be intolerable for any more Major Adverse than a very brief exposure to this level.
11.9 Assessment of effects – construction noise
Baseline conditions Current baseline 11.9.1 Baseline surveys were carried out on 18 and 19 November 2014 and the measured levels are reported in Table 11.5. Future baseline 11.9.1 Baseline noise levels in the area are likely to remain similar to those currently experienced. Noise levels may increase slightly due to natural traffic growth (not
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associated with the proposed development). Generally a 25% increase in flow is required for a 1dB(A) change in traffic noise levels, therefore it is unlikely that there will be any noticeable change in noise levels to occur before completion of the Project and the current baseline is considered suitable for this assessment.
Assessment methodology 11.9.2 Based on the criteria in Table 11.8 and Table 11.9 the following thresholds in Table 11.14 have been set for considering construction noise effects.
Table 11.14 Threshold limit and trigger level for construction noise
Noise significance Noise limit dB Noise insulation Relevant time 2 threshold dB LAeq,T LAeq,T trigger level, dB period 1 LAeq,T
Daytime 65 70 75
Evening & Weekends (Saturday 1300- 55 60 65 1900 and Sunday 0700-1900)
Night-time 45 50 55
1. From BS5228 Annex E as described in Table 11.8 2. Based on BS5228 Annex E as described in Table 11.8 3. From BS5228 as per Table 11.9
11.9.3 Potential effects of noise on residential receptors have been assessed within 300m of construction and dismantling works and site compounds. This is based on indicative noise predictions that show noise levels would be within the lowest acceptable threshold level set out in Table 11.14 at 300m considering noise propagation with distance from source. The indicative predictions are based on considering the source noise level for the various construction activities and determining the distance at which the noise levels will be attenuated to meet the threshold levels in Table 11.14. The indicative predictions showing the distance at which the noise thresholds in Table 11.14 are met are set out in Table 11.15 and are based on the construction activities and construction plant to be used as set out in Table 11A.2 in Appendix 11A within Volume 5, Document 5.4.11A.
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Table 11.15 Distance from construction works at which threshold noise limits will be met
Activity <55dB <60dB <65dB <70dB
Distance (m)
≥300 ≥170 ≥100 ≥60
Construction Compounds
Site Preparation 48.0 52.9 57.5 62.0
Road Construction 50.8 55.7 60.3 64.8
Buildings 47.6 52.6 57.2 61.6
Bellmouths
Earthworks 46.2 51.2 55.8 60.2
Bellmouth Construction 49.8 54.7 59.3 63.8
Road Surfacing 48.5 53.4 58.0 62.5
Culverts
Excavation 46.2 51.2 55.8 60.2
Pipe Laying 38.2 43.2 47.8 52.2
Concrete Works 47.2 52.2 56.8 61.2
Scaffolding
Construction 48.4 53.3 58.0 62.4
Dismantling 48.4 53.3 58.0 62.4
Loading 40.2 45.2 49.8 54.2
Bridge Construction
Site Preparation 48.4 53.3 57.9 62.3
Concrete Works 49.4 54.4 59.0 63.4
Bridge Jacking 43.4 48.4 53.0 57.4
Overhead Line Construction
Pylon Construction
Ground Preparation 47.9 52.8 57.5 61.9
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Activity <55dB <60dB <65dB <70dB
Distance (m)
≥300 ≥170 ≥100 ≥60
Piled Foundations 54.9 59.8 64.4 68.8
Pylon Assembly 38.2 43.2 47.8 52.2
Pylon Installation 46.2 51.2 55.8 60.2
Conductor Installation 49.2 54.2 58.8 63.2
Overhead Line Decommissioning
Pylon Dismantling 48.8 53.7 58.3 62.7
Breaking up concrete 48.9 53.8 58.5 62.9
Rubble Dumping 48.5 53.4 58.0 62.4
Cutting Steel 49.4 54.4 59.0 63.4
11.9.4 In Table 11.15 it is indicated that at beyond 60m all construction activities will be within the daytime noise limit of 70dB(A). Embedded environmental measures such as providing acoustic screening would need to be implemented where receptors are closer than 60m to construction works to ensure that in the daytime the daytime noise limit is not exceeded. Acoustic screens would be placed as close to the noise source as possible and be of sufficient height so there is no clear line of sight between the receptor and the noise source so as to achieve a 10dB reduction in noise. BS5228- 1153 Annex F indicates a 10dB reduction where there is no clear line of site between plant and receptor as a result of the acoustic screen. 11.9.5 Within 170m from any construction works the noise limit of 60dB(A) for weekends (Saturday 13:00-19:00 and Sunday 07:00-19:00) would be exceeded. Where construction works are to take place within 170m of receptors, embedded mitigation measures such as providing acoustic screening or restricting work hours to daytime hours have been considered. 11.9.6 Noise management measures such as those outlined in Table 11.5 would ensure noise levels are within acceptable limits within 300m of any construction and dismantling works and therefore noise levels at receptors further afield would be within acceptable limits. 11.9.7 The method of assessing and calculating noise and vibration effects from construction and dismantling activities has been undertaken using the guidance contained in British Standard 5228 -1153 as outlined in Section 11.7 of this Chapter. 11.9.8 The construction and dismantling activity noise levels have been predicted with distance from source using the measured LAeq 1hr and the following formula as described in BS5228153:
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Kh = 20 * log10 (R/10) Where
Kh = the correction for propagation across hard ground R = the distance to the receptor location 10 = the distance in metres at which the sound pressure level from the plant has been measured, as recorded in the Tables in BS5228153. 11.9.9 Construction and dismantling noise levels have been predicted for varying distances from the Order limits, which represent the dwellings closest to the construction and dismantling works and therefore most likely to encounter high noise levels during the construction and dismantling phases. 11.9.10 The assessment has used the typical noise levels for the various items of plant when in use at a reference distance of 10m, as taken from tables within BS 5228153, as identified in Table 11A.1 in Appendix 11A within Volume 5, Document 5.4.11A). The sound pressure level for each noise source and the percentage of the working day (known as percentage on-time) that such plant normally operates enable a noise level to be calculated at an identified receptor. Construction plant would not normally operate continually throughout the working day. 11.9.11 Predicted daytime noise levels have been calculated based on the above information. The predictions have followed a cautious approach in that the worst- case assumption has been applied. In calculating the noise levels it has been assumed that the ground would be hard, and no attenuation has been included. The predicted noise levels have been presented as façade noise levels and in accordance with BS5228153 a +3dB correction has been applied to obtain the façade noise level. 11.9.12 Construction noise calculations have been included in Appendix 11A within Volume 5, Document 5.4.11A.
Predicted effects and their significance 11.9.13 The results of the assessment at all receptors are presented in Appendix 11A. Construction of 400kV route 11.9.14 The construction of the 400kV route will involve construction of access routes, bellmouths, culverts/temporary bridges and the overhead transmission line. The overhead transmission line requires construction of pylon bases, erecting pylons and stringing of the overhead conductor wires. Pylon construction 11.9.15 Predicted noise impacts for the construction of the pylons are detailed in Appendix 11A within Volume 5, Document 5.4.11A. In all instances the predicted noise levels without the implementation of environmental measures will be below the daytime noise limit of 70dB(A). Embedded environmental measures in the form of acoustic screening will be required at the locations set out in Table 11.16 to avoid exceedances of the 60dB(A) limit for the weekends (Saturday 13:00-19:00 and Sundays).
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Table 11.16 Proposed environmental measures for 400kV overhead line construction
Pylon Work Ref No. Proposed environmental measures
PC1 Acoustic screening during piling works
Acoustic screening during piling works and around cable tensioning PC2 machines
Acoustic screening during site preparation, piling works and around PC3 cable tensioning machines
PC4 Acoustic screening during piling works
Acoustic screening during site preparation, piling works and around PC5 cable tensioning machines
PC8 Acoustic screening during piling works
Acoustic screening during piling works and around cable tensioning PC16 machines
PC21 Acoustic screening during piling works
PC26 Acoustic screening during piling works
PC35 Acoustic screening during piling works
PC41 Acoustic screening during piling works
11.9.16 By carrying out works at the locations indicated in Table 11.16 on a weekday during the daytime (07:00 to 18:00) and Saturday 08:00 to 13:00 and not carrying out works at weekends, the noise effects would be moderate adverse and not significant. Where works are required to be carried out over a weekend, acoustic screening could be used to mitigate noise impacts. Acoustic screening would be expected to reduce noise levels by 10dB and reduce the noise effect to moderate adverse at the locations in Table 11.16 which is assessed as not significant. Bellmouths 11.9.17 The construction of the bellmouths will, in a number of instances, take place close to residential properties. Predicted noise impacts for bellmouth construction are shown in Appendix 11A within Volume 5, Document 5.4.11A. With embedded mitigation in place in the form of acoustic screening, impacts associated with the construction of the bellmouths will not exceed the daytime noise limit of 70dB(A). Acoustic screening will reduce noise levels to below the 60dB(A) limit for weekends (Saturday 13:00-19:00 and Sundays). However where works take place in very close proximity to residential properties, as shown in Table 11.17 even with embedded environmental measures in the form of acoustic screening, noise levels exceed the 60dB(A) limit for weekend works. Additional measures in the form of restricting works hours to daytime hours will be required at these locations.
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Table 11.17 Proposed environmental measures for bellmouth construction
Work Ref No. Proposed environmental measures
BM02 Acoustic screening
BM03 Acoustic screening
BM04 Acoustic screening
BM05 Acoustic screening.
Acoustic screening. Restrict work hours to daytime hours Monday BM06 to Friday 0800 to1800 and Saturday 0800 to 1300
BM08 Acoustic screening.
Acoustic screening. Restrict work hours to daytime hours Monday BM09 to Friday 0800 to1800 and Saturday 0800 to 1300
Acoustic screening. Restrict work hours to daytime hours Monday BM10 to Friday 0800 to1800 and Saturday 0800 to 1300
Acoustic screening. Restrict work hours to daytime hours Monday BM11 to Friday 0800 to1800 and Saturday 0800 to 1300
Acoustic screening. Restrict work hours to daytime hours Monday BM12 to Friday 0800 to1800 and Saturday 0800 to 1300
BM14 Acoustic screening
BM15 Acoustic screening
Acoustic screening. Restrict work hours to daytime hours Monday BM16 to Friday 0800 to1800 and Saturday 0800 to 1300
BM17 Acoustic screening
Acoustic screening. Restrict work hours to daytime hours Monday BM18 to Friday 0800 to1800 and Saturday 0800 to 1300
BM21 Acoustic screening
11.9.18 Measures such as acoustic screening could be expected to reduce noise levels by 10dB, reducing the effects to moderate adverse for daytime works which would be not significant. 11.9.19 Where the 70dB(A) threshold is exceeded, acoustic screening would mean that noise levels still exceed the 60dB(A) limit for weekends and works at these locations should be limited to weekday daytime only. With such measures in place effects will be moderate adverse and not significant. Culverts 11.9.20 The predicted noise levels in Appendix 11A within Volume 5, Document 5.4.11A show noise levels from the construction of culverts without the implementation of
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environmental measures will not exceed the 70dB(A) noise limit for daytime and no embedded measures are required for daytime works on culverts. Embedded environmental measures in the form of acoustic screening will be required for the construction of the culverts at the locations in Table 11.18.
Table 11.18 Proposed environmental measures for culvert construction
Work Ref No. Proposed environmental measures
PC2-CR01 Acoustic screening
PC2-CR02 Acoustic screening
PC21-CR01 Acoustic screening
PX35-CR01 Acoustic screening
11.9.21 Use of acoustic screening where weekend works take place at the locations listed in Table 11.18 would be expected to reduce noise levels by 10dB(A) and reduce the effects to moderate adverse and not significant. Construction compounds 11.9.22 The compound at Richborough is distant from receptor locations and the noise impacts associated with the construction of the compounds will not exceed noise threshold values. The Westbere compound is located closer to receptor locations. Table 11.19 indicates that embedded mitigation in the form of acoustic barriers will be required at Westbere. Given the close proximity of the compound to residential receptors, compound setup would be restricted to daytime 08:00 to 18:00 on a weekday and 08:00 to 13:00 on a Saturday to keep noise impacts below the 70dB(A) weekday daytime noise limit. The assessment does however present a worst case by considering the distance between the compound site boundary and receptor locations. In reality much of the work at the compound will take place within the Order limits further away from receptor locations.
Table 11.19 Proposed environmental measures for compound construction
Work Ref No. Proposed environmental measures
Provide hoardings with acoustic features and restrict works to set Site compound - up the compound to daytime 0800 to 1800 on a weekday and 0800 Westbere to 1300 on a Saturday.
11.9.23 Mitigation measures such as acoustic screening could be expected to reduce noise levels by 10dB, reducing the effects to moderate adverse for daytime works. At the Westbere site compound the acoustic screening could be achieved by erecting acoustic hoardings around the site during setup of the compound.
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11.9.24 With environmental measures in place effects will be moderate adverse. The restriction on work hours at the compound refers to set up works only. Setting up the compound with site buildings closest to residential receptors and locating noise generating activities away from the site boundary would allow for use of the compound at weekends. Scaffolding for 400kV overhead line construction 11.9.25 Scaffolding will be required at locations along the overhead line to protect roads, trainlines, houses and other sensitive areas during construction. The noise associated with scaffolding works will not exceed the weekday daytime limit of 70dB and will therefore be of moderate significance at the locations indicated in Table 11.20. Embedded measures in the form of good practice and acoustic screening would mitigate noise levels to below the 60 dB(A) noise limit for weekends.
Table 11.20 Proposed environmental measures for scaffolding works for 400kV overhead line construction
Work Ref No. Proposed environmental measures
S1.1.1 Acoustic screening
S1.1.2 Acoustic screening
S2.1.1 Acoustic screening
S2.1.2 Acoustic screening
S3.1.1 Acoustic screening
S3.1.2 Acoustic screening
S4.1.1 Acoustic screening
S4.1.2 Acoustic screening
S8.1.1 Acoustic screening
S16.1.1 Acoustic screening
S16.1.2 Acoustic screening
11.9.26 Where weekend and evening scaffolding works take place at the receptor locations shown in Table 11.20, the unmitigated noise effects would be major adverse. 11.9.27 By carrying out works at the locations indicated in Table 11.20 on a weekday during the daytime the noise effects would be mitigated to moderate adverse. Where works are required to be carried out over a weekend, acoustic screening can be used to mitigate noise impacts. Acoustic screening would be expected to reduce noise levels by 10dB for certain scaffolding activities and reduce the noise effect to moderate adverse and not significant at the locations in Table 11.20. Restricting scaffolding works to daytime hours wold be the most effective mitigation to reduce
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the noise effect to moderate adverse and not significant at the locations in Table 11.20. Dismantling 132 kV overhead line 11.9.28 The removal of the 132kV overhead line will involve works close to residential receptors particularly in Canterbury. The works will involve use of breakers and steel cutters which have the potential to generate high noise levels. In Table 11.21 it is shown that embedded environmental measures during pylon removal in the form of acoustic screening will be required at a number of locations to ensure the noise levels do not exceed the daytime noise limit of 70dB at a number of locations. At certain locations works would need to be restricted to daytime hours as the weekend noise limit of 60dB(A) would be exceeded even with the acoustic screening.
Table 11.21 Proposed environmental measures for 132kV overhead line removal
Work Ref No. Proposed environmental measures
PX1 Acoustic screening
Acoustic screening. Restrict work hours to daytime weekdays 0800- PX2 1800 and Saturday 0800-1300
Acoustic screening. Restrict work hours to daytime weekdays 0800- PX3 1800 and Saturday 0800-1300
Acoustic screening. Restrict work hours to daytime weekdays 0800- PX4 1800 and Saturday 0800-1300
Acoustic screening. Restrict work hours to daytime weekdays 0800- PX5 1800 and Saturday 0800-1300
PX9 Acoustic screening
Acoustic screening. Restrict work hours to daytime weekdays 0800- PX10 1800 and Saturday 0800-1300
PX12 Acoustic screening
PX15 Acoustic screening
PX19 Acoustic screening
PX35 Acoustic screening
PX36 Acoustic screening
11.9.29 Environmental measures such as acoustic screening could be expected to reduce noise levels by 10dB, reducing the effects to moderate adverse and not significant for daytime works. 11.9.30 Where the 70 dB(A) threshold is exceeded, acoustic screening would mean that noise levels still exceed the 60dB(A) limit for weekends and works at these locations
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should be limited to weekday daytime only. With environmental measures in place effects would be moderate adverse and not significant. Scaffolding for 132 kV overhead line dismantling 11.9.31 Scaffolding works during the removal of the 132kV overhead line will also be located close to residential receptors in some instances. In Table 11.22 it is indicated that scaffolding works at SD10.1.1 take place close to Bluebell Woods and will require embedded environmental measures in the form of acoustic screening and restricting work hours to daytime only. 11.9.32 Scaffolding works at other locations along the 132kV overhead line route will require embedded environmental measures in the form of acoustic screening so as not to exceed the 60 dB(A) noise limit for weekends.
Table 11.22 Proposed environmental measures for scaffolding works on the 132kV line
Work Ref No. Proposed environmental measures
SD9.1.1 Acoustic screening
SD9.1.2 Acoustic screening
Acoustic screening. Restrict working hours to daytime 0800 to SD10.1.1 1800 on weekdays and 0800 to 1300 on Saturdays
Acoustic screening. Restrict working hours to daytime 0800 to 1800 SD10.1.2 on weekdays and 0800 to 1300 on Saturdays
SD13.1.1 Acoustic screening
SD13.1.2 Acoustic screening
SD19.1.1 Acoustic screening
SD19.1.2 Acoustic screening
SD35.1.1 Acoustic screening
SD35.1.2 Acoustic screening
SD35.1.3 Acoustic screening
SD36.1.1 Acoustic screening
SD36.1.2 Acoustic screening
11.9.33 Environmental measures such as acoustic screening could be expected to reduce noise levels by 10dB, reducing the effects to moderate adverse and not significant for daytime works. 11.9.34 Where the 70 dB(A) threshold is exceeded, acoustic screening would mean that noise levels still exceed the 60dB(A) limit for weekends and works at these locations
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should be limited to weekday daytime only. With environmental measures in place effects would be moderate adverse and not significant. Pylon (132kV) diversion works 11.9.35 The noise effects associated with pylon (132kV) diversion works are shown in Table 11.23. Construction noise from pylon diversion works will not exceed the 70dB(A) weekday daytime noise limit. Embedded environmental measures will however be required to avoid exceedances of the 60dB(A) weekend noise limit of 60dB(A).
Table 11.23 Proposed environmental for pylon diversion works
Work Ref No. Proposed environmental measures
PX08TB1 Acoustic screening
PX08TB2 Acoustic screening
PX08TB3 Acoustic screening
PX08TB4 Acoustic screening
PX08TA1 Acoustic screening
PX08TA2 Acoustic screening
PX08TA3 Acoustic screening
PX45TA1 Acoustic screening
PX45TA2 Acoustic screening
PX45TA3 Acoustic screening
PX45TA4 Acoustic screening
PX45TB1 Acoustic screening
PX45TB2 Acoustic screening
PX45TB3 Acoustic screening
PX45TB4 Acoustic screening
11.9.36 Works at the locations at indicated in Table 11.23 would require acoustic screening where weekend works are required and this would reduce the effect to moderate adverse and not significant. Construction of access routes 11.9.37 Access routes will be constructed to provide vehicle and equipment access to pylon and culvert locations and for erecting scaffolding. The noise associated with the construction of the access routes is shown in Table 11.24. The construction works have the potential to exceed the 70dB(A) daytime noise limit and the 60dB(A) weekend noise limit without mitigation. Embedded environmental measures in the
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form of acoustic screening and restricting work hours to daytime hours at a few has been implemented as shown in Table 11.24 and therefore noise impacts are indicated as moderate adverse and not significant.
Table 11.24 Proposed environmental measures for access route construction
Work Ref No. Proposed environmental measures
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM01 and Saturdays 0800 to 1300
BM03 to PC1 Acoustic screening
BM05 to PC2- Acoustic screening CR02
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM06 to PX5 and Saturdays 0800 to 1300
BM08 to PC4 Acoustic screening
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM09 to PC5 and Saturdays 0800 to 1300
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM10 and Saturdays 0800 to 1300
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM11 to PX9 and Saturdays 0800 to 1300
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM12 and Saturdays 0800 to 1300
BM13 to PC7 Acoustic screening
BM14 to PC9 Acoustic screening
BM15 to PC19 Acoustic screening
Acoustic screening. Restrict working hours to daytime 0800 to 1800 BM16 to PX12 and Saturdays 0800 to 1300
BM17 Acoustic screening
BM18 to PX13 Acoustic screening
BM21 to Acoustic screening PC10-CR01
BM22 to PX19 Acoustic screening
BM24 to Acoustic screening PC17-CR01
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Summary of construction noise effects 11.9.38 With environmental measures such as acoustic screening in place in the locations outlined above, none of the predicted noise levels shown in Appendix 11A within Volume 5, Document 5.4.11A exceed the thresholds for noise insulation shown in Table 11.9. Noise insulation also considers the duration of works and properties would qualify where the threshold in Table 11.9 is exceeded for 10 consecutive days in a period of 15 days or for 40 days in any 6 consecutive months. Overhead line construction works could take place at any location for up to 12 consecutive days. However, activities will be managed to ensure the noise insulation thresholds are not exceeded, and the temporal criteria for noise insulation will not be triggered. 11.9.39 None of the predicted noise levels shown in Appendix 11A exceed the temporary re-housing trigger level outlined in Table 11.9 and therefore there will be no requirement to provide alternative accommodation to local residents during the construction of the 400kV overhead line. Decommissioning effects (for the 400kV route) 11.9.40 The future decommissioning of the 400kV route would involve the use of similar plant to that used for the dismantling of the 132kV route and would include demolition of the pylon bases using a breaker and the cutting of steel. 11.9.41 The noise effects associated with decommissioning of the 400kV route indicate that the 70dB(A) daytime noise limit would not be exceeded. Where works take place over a weekend, there is a potential for the unmitigated noise levels to exceed the 60dB(A) weekend noise limit of 60dB(A). Embedded environmental measures in the form of acoustic screening would be adopted and the noise effects from decommissioning of the 400kV route are shown in Table 11.25.
Table 11.25 Proposed environmental measures for the 400kV overhead line decommissioning
Work Ref No. Proposed environmental measures
PC2 Acoustic screening
PC3 Acoustic screening
PC5 Acoustic screening
PC16 Acoustic screening
11.9.42 With embedded mitigation in place at the locations indicated in Table 11.25 the noise effects would be reduced to moderate adverse.
11.10 Assessment of effects - construction traffic noise
Assessment methodology 11.10.1 As indicated in Section 11.6 of this Chapter, construction traffic will not result in significant increases in traffic on the public road network and these effects have been
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scoped out. However, noise effects associated with construction and dismantling traffic movements on access routes have been assessed using BS5228-1153 which provides a calculation method for predicting noise from construction vehicles. The calculation method predicts an hourly noise level (LAeq, 1hr). The general expression for predicting the LAeq alongside an access route used by items of mobile plant is:
LAeq = LWA − 33 + 10log10 Q − 10log10 V − 10log10 d where:
LWA is the sound power level of the plant, in decibels (dB). Q is the number of vehicles per hour. V is the average vehicle speed, in kilometres per hour (km/h). d is the distance of receiving position from the centre of access road, in metres. 11.10.2 Access routes will be constructed between the bellmouths (created where an access route meets the public highway) and the pylon working areas. The calculation 153 method in BS5228-1 provides for prediction of 1 hour LAeq values. Traffic data have been provided as day peak flows. Daily traffic movements would be expected to be spread across the day.
Predicted effects and their significance 11.10.3 The predicted noise levels for construction traffic on access routes is shown in Table 11.5A in Appendix 11A within Volume 5, Document 5.4.11A. The predicted noise levels indicate that traffic noise levels (LAeq,1hr) will be below the 70 dB(A) daytime weekday noise limit at all locations. Only at one location, 9A Shalloak Road, will the traffic noise levels exceed the weekend noise limit of 60dB(A) due to the close proximity of the receptor to the access route from bellmouth BM11 to pylon PX9. 11.10.4 Environmental measures would include provision of an acoustic fence between the receptor location and the access route, which would be expected to reduce noise levels by 10dB to a moderate adverse effect. Alternatively, vehicle movements on this route could be restricted to daytime hours of 08.00 to 18.00 on a weekday and 08.00 to 13.00 on a Saturday.
11.11 Assessment of effects – construction vibration
Baseline conditions Current baseline conditions 11.11.1 No baseline vibration surveys have been carried out. There are no obvious sources of vibration other than from train movements in close proximity to the railway line. There is also a possibility that on occasions HGVs could generate some vibration within very close proximity to roads. Future baseline 11.11.2 Future baseline vibration levels would not be expected to increase. In the absence of the proposed development there would be some future traffic growth, but this would not be expected to increase baseline vibration levels.
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Assessment methodology 11.11.3 There are currently no British Standards that provide a methodology to predict levels of vibration from construction activities, other than that contained within BS5228-2155, which relates to percussive or vibratory piling only. 11.11.4 A qualitative assessment for the effect of vibration on the sensitive receptors was undertaken for the construction phase. There is sufficient empirical data available from other studies to provide for the qualitative assessment of construction vibration.
Predicted effects and their significance 11.11.5 Due to the complex relationship between the source of vibration, forcing frequency, the distance and geological characteristics between source and receiver and the construction of the receiving structure, it is difficult to predict the degree of vibration that may occur. 11.11.6 Most construction activities are not significant sources of ground-borne vibration. Activities such as earth-working, crane activities and concreting would produce relatively low levels of ground borne vibration. Piling activities could produce perceptible levels of vibration, depending on the method used. Piling will only be required for the construction of the new 400kV overhead line not the dismantling of the 132kV PX route. Proposed new pylon locations are generally located away from residential receptors, with the closest, Shalloak Road approximately 85m from pylon PC5. 11.11.7 It is assumed that receptors along the 400kV route are structurally sound and of negligible, low and medium sensitivity. Therefore based on the information outlined in BS 5228-2155 on typical levels of vibration associated with piling the significance of effect is minor adverse or negligible and therefore not significant.
11.12 Conclusions of significance evaluation for construction noise 11.12.1 The significance of adverse effects from construction noise, construction traffic noise and construction vibration is summarised in Table 11.26.
Table 11.26 Summary of significance of adverse construction noise and vibration effects
Receptor and Magnitude Sensitivity Significance3 Summary rationale effects of effect1 Value2
Residential Moderate Medium Not Significant Residential receptors receptors within (moderate) within close proximity 50m: of demolition of the Construction/ 132kV PX route dismantling (Ulcombe Gardens, activity noise Headcorn Drive, effects Bricknor Close and (including noise Bluebell Woods) are from site likely to experience compounds) high noise levels. Embedded mitigation in the form of acoustic
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Receptor and Magnitude Sensitivity Significance3 Summary rationale effects of effect1 Value2
screening and restricting work hours to daytime hours (weekday 0800 to 1800 and Saturday 0800 to 1300) at these locations will reduce noise levels to acceptable levels.
Residential Medium Medium Not significant Residential receptors receptors 50m to (moderate) within 50m to 120m of 120m: construction and Construction/ demolition works likely dismantling to experience noise activity noise levels above threshold effects criteria but the (including noise assessment has from site shown that with compounds) embedded mitigation in place these would not be significant.
Residential Low Medium Not significant Construction noise receptors (minor) levels beyond 120m beyond 120m: likely to be below Construction/ threshold criteria with dismantling embedded mitigation activity noise in place. effects (including noise from site compounds)
Residential Low Medium Not significant Construction traffic on receptors: (minor) access roads will Construction result in noise levels traffic noise below the threshold effects (from criteria at 10m from traffic on access the access routes. roads) Embedded mitigation in the form of acoustic screening is required at one receptor location (9 Shalloak Road). As all other receptors are more than 10m from access routes there will be no significant effects.
Residential There are no receptors within 20m of any piling location and receptors within therefore no significant effects are likely.
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Receptor and Magnitude Sensitivity Significance3 Summary rationale effects of effect1 Value2
20m: Construction vibration effects from piling
Residential Negligible Medium Not significant Significant vibration receptors (negligible) effects are unlikely as beyond 20m: the closest receptor is Construction 86m from the closest vibration effects piling location. from piling
Key/footnotes 1: 2: 3: High High Major Medium Medium Moderate Low Low Minor Negligible Negligible Negligible No Effect
Inter-related effects 11.12.2 Noise and vibration from the construction phase of the proposed development could lead to effects on residential receptors, socio-economic receptors and protected species and habitats. Effects on Biodiversity have been considered in Chapter 9 of this document and effects on socio-economic receptors have been considered in Chapter 15 of this document (Socio-economics and recreation). No inter-related effects are expected with other disciplines.
11.13 Part B Scope of the assessment – operational noise
Potential receptors 11.13.1 The zone of influence of noise from the proposed overhead line is likely to extend aproximately 300m from the proposed 400kV route centreline, depending on background noise levels. The effect of noise on sensitive receptors within aproximately 300m of the proposed 400kV route is assessed. A distance of aproximately 300m includes all high, medium and low magnitudes of effect. Receptor sensitivities are discussed in Paragraphs 11.14.2, 11.14.3 and Table 11.28 within this Chapter. 11.13.2 Medium sensitivity receptors with the potential to be affected by noise from the proposed development once fully commissioned and operational and which are assessed in this chapter comprise private residential properties along the proposed 400kV route. 11.13.3 Low and negligible sensitivity receptors with the potential to be affected by noise from the proposed development once fully commissioned and operational and which are assessed in this chapter comprise areas of public amenity and leisure, including campsites and PRoW. 11.13.4 There are no high sensitivity receptors, such as schools or healthcare facilities within the study area of operational 400kV overhead line noise.
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11.13.5 The receptor locations affected by operational noise are listed in Table 11.27 and discussed in detail in Section 11.15 of this Chapter. Additional detail is provided in Appendix 11E within Volume 5, Document 5.4.11E.
Table 11.27 Operational noise receptors
Receptor Ref. Receptor Name
01 251&253 Broad Oak Road
02 Vauxhall Avenue
03 Caravan Park off Vauxhall Road
04 4&6 Broad Oak Road
05A 10 Shalloak Road
05B 8 Shalloak Road
06 12 Shalloak Road
07 3 Shalloak Road
08 5 & 9 Shalloak Road and Dengrove Mobile Home Park
09 9a Shalloak Road
10 22, 24, 26, 28, 30, 32, 34, 36 & 44 Shalloak Road
11 52, 54, 56, 58, 60, 62, 64, 66, 68, 70, 72, 74, 76, 78 & 80 Shalloak Road
12 11 & 15 Shalloak Road
13 21, 29, 31 & Gower House Shalloak Road
14 55, 57 Shalloak Road, Golden Lion Public House, Godwin Farm House, 124, 122, 120, 118, 116 Sweechgate
15 Mayton Cottages
16 Nook Farm, The Green House, Dale View, Rusper Cottage, Towyn, 1, 5 & 6 Mayton Lane
17 Orchard Cottage & Little Orchard Barnet’s Lane
18 Brookside
19 Foxhill House, Lower Sweech Farm, Ranscombe and Lamberton House
20 Kemberland, Herne Bay Road
21 Caravan at Kemberland Farm (north of proposed 400kV route)
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Receptor Ref. Receptor Name
22 Hoades Court
23 Tile Lodge Cottages
24 3 & 4 Hoath Road and Woodfield
25 Tile Lodge Farm House
26 Chislet Park Farm Cottages
27 Chislet Park Oast
28 Owl Cottage
29 Nethergong Camping
30 Riverside House
31 Sarre Ferry Cottage
32 Marsh Farm
Potentially significant effects 11.13.6 The new 400kV overhead line would be operational from October 2018, whilst the proposed completion year for the construction phase of the proposed development (including removal of the PX route) is 2021. The potentially significant effects relating to the operation of the proposed development, which are subject to further assessment in this chapter, are summarised below: Potential effects on noise sensitive receptors from noise from conductors (the wires) under certain meteorological conditions (‘wet’ or ‘dry’ noise). Further assessment is provided within this chapter to identify whether the noise produced by the conductors will have a significant effect on noise sensitive receptors. (Further information on overhead line noise is given in paragraphs 11.13.8 – 11.13.12 of this Chapter). Potential effects on noise sensitive receptors from the impact of noise from the proposed 400kV and 132kV overhead lines when they are operational at the same time. Potential cumulative effects on noise sensitive receptors from the impact of noise from overhead line conductors in conjuction with noise from other developments proposed within the area of the Richborough Connection project. 11.13.7 Assessment of each of the following potential effects has led to the conclusion that they are not likely to be significant and hence have been scoped out of the assessment. Noise from ‘fittings’ is not likely to be significant and therefore this is scoped out of the assessment for the reasons outlined in paragraphs 11.6.3 – 11.6.7 of this Chapter. There would be no vibration effects during the operation of the overhead line and therefore this is scoped out of the assessment.
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Noise and vibration resulting from operational maintenance and inspections affecting residential properties, and other sensitive receptors is not likely to be significant and therefore this is scoped out of the assessment. The proposed development would be subject to annual foot patrol and infra red patrol using a helicopter. The infra red patrol would be undertaken at a height of 500ft and at a speed of approximately 50mph. This activity would have a low noise impact as it is undertaken at height, with no hovering near the pylons. Once every 6 to 10 years the overhead line would be subjected to a full condition assessment where the helicopter would hover at a height of 100 to 200 ft next to each pylon for a period of 10 minutes per pylon. In the unlikely event that intervention or maintenance is required then procedures are followed to gain access to carry out the required work within appropriate timescales. Given the lifespan of 40-60 years (insulators and fittings, and conductors), intervention for maintenance activity is unlikely to occur within the first 12-15 years of operation and hence would be extremely infrequent, and would be no more significant than the assessed construction activities at any given pylon location (see Part A of this Chapter). As future baseline conditions, and indeed assessment methodology, may have changed by the time any maintenance works are required, no further detailed assessment of noise and vibration effects of maintenance activities will be undertaken.
Overhead line operational noise 11.13.8 Conductor system noise is caused by corona discharge activity. Corona discharge occurs when the conductor surface electric stress exceeds the inception level for corona discharge activity, a level of around 17 to 20 kV/cm. Most transmission line conductors are designed to operate below this threshold, and so usually operate quietly in dry weather conditions. Small areas of surface contamination on conductors spoiling the otherwise smooth conductor surface are likely to cause a local enhancement of electric stress which may be sufficiently high to initiate localised discharge activity. At each discharge site a limited electrical breakdown of the air occurs. A portion of the energy associated with the corona process is released as acoustic energy which radiates into the air as sound pressure waves. 11.13.9 After a prolonged spell of dry weather without heavy rain to wash the conductors, contamination may accumulate sufficiently to result in increased noise. Under these circumstances the noise is referred to as 'dry noise'. During the next occurrence of heavy rain, these discharge sources are washed away and the line will resume its normal quieter operation. 11.13.10 The highest noise levels generated by an overhead line generally occur during rainfall. Water droplets may accumulate on the surface of the conductor and initiate multiple corona discharges. The number of droplets, and hence the noise level, will depend primarily on the rate of rainfall. Fog may also give rise to increased noise levels, although these levels are less than those during rain. Noise generated under these circumstances is referred to as 'wet noise'. However, some of the effect of this increased noise is masked by increased ambient noise due to rainfall (either directly due to raindrops falling on hard surfaces or nearby foliage, or indirectly due to increased vehicle tyre/road interaction noise on local wet roads). 11.13.11 Overhead line noise is therefore variable in nature, principally due to the effect of weather on the conductors. Historic anecdotal evidence received by National Grid
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over the years suggests that levels of audible noise from overhead lines can be higher in the first few months of operation as the conductors undergo a "weathering- in" process. The operational noise assessment is based on the effect of noise from “weathered in” conductors. 11.13.12 Under normal operating conditions pylon fittings, such as dampers, spacers, clamps and insulators are designed not to generate audible noise when in operation.
11.14 Assessment methodology - operational noise
Methodology for prediction of effects 11.14.1 Published and bespoke methodologies have been adopted for the assessment of the various elements relating to potential noise effects. These follow industry best practice to provide as robust an assessment of potential effects as possible, as described below. Sensitivity of receptors 11.14.2 Residential properties are assessed as being noise sensitive, although developments such as hospitals and schools also contain receptors that are potentially noise sensitive. It is therefore appropriate to determine sensitivity on a case by case basis at a local level. The World Heath Organisation (WHO) guidelines148 do offer some comment on degrees of sensitivity, identifying 'vulnerable subgroups' such as those suffering from particular medical conditions. Taking this into account, the sensitivity scale shown in Table 11.28 has been developed.
Table 11.28 Sensitivity of receptor - operational noise
Sensitivity of Receptor description receptor
High Such receptors include pupils in residential educational facilities and patients in healthcare facilities and are defined as a "vulnerable subgroup" with very high or continuous rates of occupancy. Receptors are categorised as high sensitivity where noise may be detrimental to vulnerable subgroups.
Medium Residential receptors. Receptors are categorised as medium sensitivity where noise may cause disturbance and a level of protection is required but a level of tolerance is expected.
Low Area used primarily for leisure activities including PRoW, sports facilities and sites of historic or cultural importance. Receptors are categorised as low sensitivity where noise may cause short duration effects in a recreational setting although particular high noise levels may cause a moderate effect.
Negligible All other areas such as those used primarily for industrial or agricultural purposes. Receptors are categorised as negligible sensitivity where noise is not expected to be detrimental.
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11.14.3 The classification of residential receptors as ‘medium’ sensitivity was used in the noise assessments for the recent Hinkley Point C Connection and Hinkley Point C Nuclear Power Station DCO applications. The level of significance at this sensitivity is set to corrolate with guidance levels, such as BS4142146, when determining the significance of effects. Therefore, this provides a robust assessment for medium sensitivity (residential) receptors and provides additional protecton for vulnerable, high sensitivity receptors. Magnitude of effect – noise predictions 11.14.4 The magnitude of effect is derived from noise predictions which are based on reasonable worst case assumptions. Therefore it would be inappropriate to conclude a high magnitude of effect simply because a certain threshold (e.g. the assessment level) is exceeded. The amount by which a threshold is exceeded, along with the duration of effect should also be taken into account. The apportionment of a magnitude rating has therefore taken this situation into account by applying professional judgement. 11.14.5 The magnitude of noise effects from conductors has been determined for this assessment in accordance with the method described in TR(T)94; an internal National Grid report, referenced in EN-5, describing a method to assess the potential effects of dry and rain-induced noise from new overhead lines. TR(T)94 does not set specific noise assessment criteria; instead it refers to BS4142 and the subjective response of communities and individuals to changes in noise levels. 11.14.6 To determine the change in noise level, the existing background noise level has to be determined. Based on the range of background noise levels measured at each monitoring location, professional judgement has been used to determine the representative background noise level at each receptor location, which has then fed into the noise assessment. A record of measured background noise levels can be found in Appendix 11B within Volume 5, Document 5.4.11B, and representative background noise levels used in the noise assessment can be found in Appendix 11E within Volume 5, Document 5.4.11E for each receptor. 11.14.7 A development specific methodology based on the principles of BS4142:2014 has been devised and used to assess overhead line noise occurring in dry weather conditions. A difference in the rating level (sound pressure level of the sound source + any penalty for tonality) at a receptor compared to background noise levels of +10dB or more is likely to be an indication of a significant adverse effect, whereas a difference of around +5dB is likely to be an indication of an adverse effect. The lower the rating level is relative to the measured background sound level, the less likely it is that the specific sound source will have an adverse effect or a significant adverse effect. Where the rating level of the sound source does not exceed the background sound level, this is an indication of the specific sound source having a low impact. 11.14.8 The methodology for assessing noise generated by overhead line conductors in wet weather conditions differs to the assessment methodology for dry weather conditions (due to the increase in background noise due to rainfall). The detailed methodology of TR(T)94 produces a weighted average increase in total sound pressure levels over a range of likely background noise levels due to rainfall, with the typical rainfall rates given the highest weighting. The greatest difference between noise levels with and without overhead line noise occur at rainfall rates of 1mm/hr. At this rainfall intensity, the TR(T)94 methodology adds a tonal penalty of 5dB to line noise to account for hum inception. The method assumes the rate of rainfall to be 1mm/hr, thereby representing a worst case assessment.
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11.14.9 BS4142:2014 has recently been published and specifies a 6dB penalty for tonal noise. As such an additional 1dB has been applied to the existing 5dB penalty bringing the assessment in line with current guidance. 11.14.10 The method for assessing overhead line noise is described in further detail in Appendix 11C within Volume 5, Document 5.4.11C. 11.14.11 The Met Office has provided National Grid with recent rainfall data. These data suggest that the 2001-2010 average annual rainfall rate ranges from 500 to 600mm of rain falling over <450 hours in the area of the proposed development. These figures indicate that wet weather conditions will occur for approximately 5% of the time in the proposed development area. 11.14.12 Examples of the Met Office rainfall charts are given in Appendix 11D within Volume 5, Document 5.4.11D. 11.14.13 Using the predicted sound emission rate in wet conditions (based on the TR(T)94 method assessing conductor type and configuration, and assuming a 1mm/hr intensity rainfall), and a typical background noise level during rain, adoption of the BS4142 methodology is considered appropriate, and is likely to produce a conservative assessment. 11.14.14 The predicted conductor sound power levels (wet and dry) from TR(T)94 has been used as input data into CadnaA. CadnaA uses the prediction methodology within ISO 9613 2: 1996157 to predict long-term equivalent continuous A-weighted sound pressure levels (LAeq) at the receptors being considered in the assessment. 11.14.15 The models assume downwind propagation, within +/- 45 degrees of direction connecting dominant source and receiver, and wind speeds between 1m/s and 5m/s at heights between 3m and 11m above the ground. 11.14.16 In order to assess the potential effects of noise during wet conditions, the measured background levels have been revised using the 'Miller Curves' presented in TR(T)94 which take account of the terrain/ground around the receptor being assessed, to produce a likely background noise level due to the effect of rainfall. These calculations assume a typical Miller Curve "Type 2"158, which estimates the sound levels due to rainfall as 41dB at a rainfall rate of 1mm/hr, and is considered to be a conservative estimate of the likely background noise due to rainfall over the whole proposed development area.
11.14.17 The model has estimated the free field LAeq sound levels at positions representative of the external façades of residential receptors. 11.14.18 The criteria for the magnitude of effect of operational noise are shown in Table 11.29.
157 The International Organisation for Standardisation ISO 9613 ‘Attenuation of sound during propagation outdoors’ Part 2: ‘General method of calculation’ (ISO, 1996) 158 Miller Curve ‘Type 2’ describes sound levels due to rainfall for “non-porous, hard, bare ground or pavement; falling raindrops splash on thin layers or puddles of collected water; or in or beside wooded area of deciduous trees without leaves or with small leaves; or in or besides wooded area of coniferous trees or evergreens having needles rather than leaves; or thin leafed ground cover or crop, such as hay, clover or grain”
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Table 11.29 Magnitude of operational effects
Magnitude of Operational noise – overhead line – dry and wet noise effect
High Predicted rating levels are 5dB or more above the higher of existing background noise levels or 30dB (background noise levels for wet noise assessment include noise levels due to rainfall)
Medium Predicted rating levels are between 5dB and 0dB above the higher of existing background noise levels or 30dB (background noise levels for wet noise assessment include noise levels due to rainfall)
Low Predicted rating levels are between 0dB and 5dB below the higher of existing background noise levels or 30dB (background noise levels for wet noise assessment include noise levels due to rainfall)
Negligible Predicted rating noise levels are between 5dB and 10dB below the higher of existing background noise levels or 30dB (background noise levels for wet noise assessment include noise levels due to rainfall)
No effect Predicted rating noise levels are 10dB or more below the higher of existing background noise levels or 30dB (background noise levels for wet noise assessment include noise levels due to rainfall)
11.14.19 The above criteria are based on the assessed levels during the quietest night-time hours, when people are likely to be sleeping. In addition, the levels assessed are free field calculations of external levels, and take no account of building attenuation effects to predict levels inside residential dwellings. As such, the above criteria are considered to be conservative and robust.
Significance evaluation methodology 11.14.20 The determination of significance of noise effects is based on: the sensitivity of a particular receptor (which depends on local circumstances and the type of receptor); the duration and frequency of occurrence of the noise effect, as well as the time of day or night at which it occurs; the magnitude of change in noise levels (which relates to existing background noise levels and predicted noise levels due to the proposed development); and the absolute noise level (i.e. the predicted future noise level) as it may either exceed or comply with relevant guideline noise limits, irrespective of the amount of change predicted.
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11.14.21 A combination of receptor sensitivity and magnitude of effect has been used to determine the overall significance of the effect, as shown in Table 11.30. Significant effects are highlighted in bold in Table 11.30.
Table 11.30 Significance criteria for operational noise effects
Sensitivity of receptor
Magnitude High Medium Low Negligible
High Major Major Moderate Minor Medium Major Moderate Minor Negligible Low Moderate Minor Negligible Negligible Negligible Minor Negligible Negligible Negligible No effect Negligible Negligible Negligible Negligible
11.14.22 In the context of the NPPF and NPSE it is not predicted that a Significant Observed Adverse Effect would occur due to noise from the overhead line. The SOAEL relates to noise which causes a change in behaviour and/or attitude for a prolonged period of time and has an impact on both health and quality of life. Based on the outputs of the CadnaA noise model, the predicted sound levels would be below those levels which have been shown to have an impact on health and quality of life. For the purpose of the DCO application, a significant effect has been assessed in terms of the effect on amenity, as opposed to effect on health and quality of life, as this is considered to be the most conservative approach to the assessment. A significant effect in relation to amenity is deemed to occur where a Major adverse effect is predicted.
Limits of Deviation 11.14.23 The assessment has considered the proposed development in the locations shown on the corresponding Figures (see Figures 3.1a-3.1d in Volume 5, Document 5.3.3). In addition, the assessment also considers the potential movement of pylon locations and conductors within the LoD. The LoD would provide a necessary and proportionate degree of flexibility as to the final alignment of the works. The LoD identify a maximum distance or measurement of variation within which these works must be constructed. The overhead line LoD are shown at Figures 3.1a-h. 11.14.24 Further detail as to the level of flexibility that would be afforded by the LoD and the assessment approach is provided in Chapter 3, paragraphs 3.1.7 to 3.1.16 of this document. The implication of the LoD is that some components of the proposed development may be closer or further away from existing receptors than assessed in Section 11.15 of this Chapter. 11.14.25 In practice, the implication of the LoD is that pylon structures and hence the centre line of the overhead line can move a maximum of 10m laterally, i.e. the noise sources can move a maximum of 10m closer to receptors, although there are sections of the proposed 400kV route where due to the proximity to residential receptors or other environmental features, the LoD has been reduced and this distance is less; details
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of these 'pinch points' can be found in Chapter 3, paragraphs 3.1.7 to 3.1.16 of this document). An assessment of the potential movement of the centreline to the maximum extent permitted by the LoD has been undertaken and where this leads to a change in significance of operational noise effect this has been detailed in paragraphs 11.15.28 and 11.15.30 of this Chapter.
11.15 Assessment of effects – operational noise
Predicted effects and their significance Conductor noise 11.15.1 Calculations of dry corona noise for the proposed overhead line conductors have been based on data from existing overhead lines, with appropriate correction factors for pylon design and conductor wire configurations. 11.15.2 The proposed conductor bundle comprises two conductors each 33.4mm in diameter and spaced 400mm apart. When strung on standard lattice pylons or low height lattice pylons, the modelled maximum surface electric stress will be in the range 16.3 to 16.7kV/cm, a level just below the inception level for corona discharge activity. This means for the majority of the time the line will operate quietly, however there will be conditions when noise due to corona discharge effects will occur. Medium sensitivity receptors 11.15.3 There are no high sensitivity receptors, such as schools or healthcare facilities, within the study area of operational 400kV overhead line noise. The assessment therefore considers medium sensitivity residential receptors. 11.15.4 The results of the analysis, including CadnaA noise propagation plots and predicted noise levels at nearby nosie sensitive receptors are shown in Tables 11E.3.6 and 11E.3.7 in Appendix 11E within Volume 5, Document 5.4.11E. Inset 11.1 overleaf shows an example of the CadnaA noise model of overhead line noise.
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Inset 11.1 Example CadnaA 400kV overhead line noise assessment model
11.15.5 The receptors where there may be a major or moderate significance of effect (i.e. operational noise with a magnitude of medium or high for receptors of medium sensitivity) were identified and are set out in Table 11.31.
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Table 11.31 Assessment of predicted Dry and Wet noise from overhead lines based on CadnaA noise propagation model
Receptor Receptor name Section Predicted Magnitude of effect Ref. Assessment Level, dB (including 6dB acoustic character correction)
Dry Wet Dry Wet
04 4&6 Broad Oak A -5 +2 Low Medium Road (Balmally Villas)
05A 10 Shalloak A -6 +0 Negligible Medium Road
07 3 Shalloak Road A -6 +1 Negligible Medium
21 Caravan at A -0 +5 Low Medium Kemberland Farm (north of proposed 400kV route)
25 Tile Lodge Farm B -4 +1 Low Medium House
11.15.6 The above predicted assessment levels are at locations representative of the external façades of properties. 11.15.7 For all other receptors considered in the noise modelling, the significance of effects are either low or negligible and so they are not significant, see Tables 11E.3.6 and 11E.3.7 in Appendix 11E within Volume 5, Document 5.4.11E. Dry conditions 11.15.8 During dry conditions, 400kV overhead line operational noise does not exceed low magnitude effects at any noise sensitive receptor. The receptors are classed as medium sensitivity receptors; the significance of effect is therefore, at worst, minor adverse, or negligible for dry conditions, which is not significant. 11.15.9 The above assessment is based on magnitudes of effect during night time periods when background noise levels are expected to be around their lowest level. Overhead line noise would not be expected to change throughout the day or night. As such, the significance is expected to be minor adverse to negligible during daytime periods at all noise sensitive receptors, which is not significant. 11.15.10 It should be noted that in dry conditions the highest predicted absolute noise level at a noise sensitive receptor along the proposed 400kV route is calculated as an LAeq of 25.3dB. This is at Receptor 2, the caravan park off Vauxhall Road. WHO Night Noise Guidelines give average Lnight,outside of 30dB as the level at which there is no
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observable effect. Levels of 30-40dB are observed to only give modest effects, Lnight,outside of 40dB is quoted as the Lowest Observable Adverse Effect Level (LOAEL). During daytime periods the LOAEL may be considered to be 50dB LAeq based on the guidance of WHO Guidelines for community noise and BS8233:2014. Against these criteria, the exercise of professional judgement leads to a conclusion that the significance of operational 400kV overhead line noise is minor adverse to negligible for night time and daytime periods at all noise sensitive receptors, which is not significant. Wet conditions 11.15.11 Results indicate that the magnitude of 400kV overhead line operational noise is low, negligible or would have no effect at the majority of receptors, other than those identified in Table 11.31. All receptors are of medium sensitivity and the significance of effect is therefore minor adverse, or negligible for wet conditions at all receptor locations other than those identified in Table 11.31 above, which is not significant. 11.15.12 During wet conditions the magnitude of 400kV overhead line operational noise is medium at 4&6 Broad Oak Road (Balmally Villas), 10 Shalloak Road, 3 Shalloak Road, the caravan at Kemberland Farm and Tile Lodge Farm House. All receptors are of medium sensitivity and the significance of effect is therefore moderate adverse but not significant. 11.15.13 The above assessment is based on magnitudes of effect during night time periods when background noise levels are expected to be around their lowest level. The significance of effect is expected to be minor adverse to negligible during daytime periods at all noise sensitive receptors, including those indentified in Table 11.31, which is not significant. 11.15.14 Rainfall data provided by the Met Office indicates that in this area, wet weather conditions and hence wet noise would be likely to occur around 5% of the year (2012 data). Dry conditions and hence dry noise would be likey to occur for around 95% of the year. Consequently for around 95% of the year the impact of overhead line noise would be at worst minor adverse to negligible. 11.15.15 The operational noise assessment is based on a ‘worse case’ scenario whereby wet noise is assumed to occur in the middle of the night when background noise levels are at their lowest and people are sleeping. In reality during the 5% of the year when wet noise effects can be expected to occur, as well as during the night, wet noise will occur during the daytime when background noise levels are likely to be higher and people are not sleeping. The wet noise assessment is a worst case assessment based on the impact at night and is therefore likely to over estimate the impact of wet noise that occurs during the daytime. Summary of effects 11.15.16 The assessment of the significance of effects due to opearational noise has concluded that: the significance of operational dry noise from 400kV lines is assessed as being minor adverse or negligible at all receptors, which is not significant; the significance of operational wet noise from 400kV overhead lines is assessed as being minor adverse or negligible at all receptors except 4&6 Broad Oak Road (Balmally Villas), 10 Shalloak Road, 3 Shalloak Road, the caravan at Kemberland Farm and Tile Lodge Farm House which are assessed as moderate adverse, although this is not significant.
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During daytime periods the significance of effects are likely to be minor adverse or negligible at all noise sensitive receptors, which is not significant. Low and negligible sensitivity receptors 11.15.17 The route of the proposed 400kV overhead line is in the vicinity of or crosses a number of areas used primarily for leisure activities, such as PRoW and a camp site, as well as several sites designated for nature conservation, industrial and agricultural land. 11.15.18 The magnitude of effect due to overhead line noise may be medium or high during particularly quiet or wet periods in areas close to or under the 400kV overhead lines, although the effect will dissipate quickly with increased distance. 11.15.19 The duration of exposure of these receptors to overhead line noise is likely to be limited to short durations, which will typically occur during daytime hours. Areas such as PRoW and sites designated for nature conservation are less likely to be used during periods of rainfall when the highest noise levels generated by the overhead line are likely to occur. Furthermore, during daytime periods when the above areas are likely to be used, background noise levels are expected to be higher. 11.15.20 Campsites, including Nethergong Camping are deemed to be of low sensitivity as the effects of overhead line noise on thesite’s users are transient. The operational noise levels at Nethergong Camping are assessed as negligible during dry conditions and low adverse during wet conditions. Absolute noise levels during dry conditions are predicted to be 18.7dBA. This level is well below guideline levels for suitable sleeping conditions as decribed in BS8233. 11.15.21 The exercise of professional judgement therefore concludes that the effects on low and negligible sensitivity receptors are expected to be minor adverse or negligible and are therefore not significant. Simultaneous operation of existing 132kV overhead line and proposed 400kV overhead line 11.15.22 There will be a period of time when the existing 132kV overhead line and the proposed 400kV overhead line operate simultaneously. 11.15.23 The route layouts of the existing 132kV overhead line and the proposed 400kV overhead have been reviewed as part of this assessment. 11.15.24 132kV overhead lines typically operate at low electrical stresses and are therefore considered to be practically quiet. 11.15.25 The worst case spatial scope for a moderate effect from the proposed 400kV overhead line is approximately 29m for dry conditions and approximately 102m for wet conditions in the area of the existing 132kV line, during quiet night time periods. 11.15.26 The potential for significant noise effects due to the simultaneous operation of the existing 132kV and proposed 400kV overhead lines is extremely low given the following factors: The low noise levels generated (well below the level considered to represent the respective day/night Lowest Observed Adverse Effect Level); The relative separation distances and/or absence of noise sensitive receptors; and
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The variability in corona discharge or other sound generating properties and meteorological conditions required to cause such conditions. 11.15.27 Given the above factors and the conservative assessment approach adopted in this Chapter, the potential noise effect is considered to be negligible. Potential variation of significance of operational effects 11.15.28 Table 11.32 shows the receptors where a change in lateral overhead line route within the LoD would result in an increase of significance from overhead line noise into the moderate adverse or major adverse category.
Table 11.32 Summary of potential increase in significance of effect to moderate adverse or major adverse within LoD
Ref. Receptor Condition Increase in Increase in Movement (Dry/Wet) significance significance required from: to: to trigger change
05B 8 Shalloak Road Wet Minor Moderate 5m Adverse Adverse towards receptor
21 Caravan at Dry Minor Moderate 2m Kemberland Farm Adverse Adverse towards (north of proposed receptor 400kV route)
21 Caravan at Wet Moderate Major 5m Kemberland Farm Adverse Adverse towards (north of proposed receptor 400kV route)
11.15.29 Should the proposed 400kV overhead line route move 5m closer to 8 Shalloak Road during wet conditions, or 2m closer to Caravan 1 at Kemberland Farm during dry conditions, the magnitude of 400kV overhead line operational noise would be medium at these locations. The receptors are of medium sensitivity and the significance of effect would therefore be moderate adverse but not significant. 11.15.30 Should the proposed 400kV overhead line route move 5m closer to Caravan 1 at Kemberland Farm during wet conditions, the magnitude of 400kV overhead line operational noise would be high at this location. The receptor is of medium sensitivity and the significance of effect would therefore be major adverse, which would be significant. This receptor has temporary planning permission for residential use until January 2016. Climate change effects 11.15.31 Data from the Met Office159 shows a stable/slightly decreasing trend in rainfall rates over the last 100 years. Based on this trend in rainfall, wet noise generation by the
159 Jenkins, G.J., Perry, M.C., and Prior, M.J. 2008. The Climate of the United Kingdom and Recent Trends. Met Office Hadley Centre, Exeter, UK.
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overhead lines is not expected to be worse than assessed over the lifespan of the proposed development.
11.16 Conclusions of significance evaluation for operational noise
The significance of identified effects 11.16.1 The assessment of operational noise from the proposed 400kV overhead line indicates that the magnitudes of effect are predicted to be ‘low’, ‘negligible’ or of ‘no effect’ for all dwellings further than approximately 120m from the proposed 400kV route centre-line. Only dwellings within approximately 120m of the proposed 400kV route centreline may potentially experience a ‘medium’ magnitude of effect, due to operational noise, depending on the respective background noise in the area. There are no ‘high magnitude’ effects at residential receptors predicted other than at Caravan 1, Kemberland Farm where a high magnitude of effect is predicted if the proposed 400kV route centreline moves 5m closer to the receptor within the LoD. 11.16.2 An assessment of medium magnitude of effect is derived where a rating level (for dry noise or wet noise) of between 0dB and 5dB above background is predicted. An assessment of high magnitude of effect is derived where a rating level (for dry noise or wet noise) 5dB or more above background is predicted. Table 11.33 summarises the significance of effects of operational noise.
Table 11.33 Summary of significance of effects
Receptor and Magnitude Sensitivity Significance Summary effects of effect rationale
400kV Overhead Medium Medium Moderate Absolute noise Line noise – wet adverse levels due to conditions – at overhead line residential noise are low. locations: Balmally Wet noise Villas, 4 & 6 Broad conditions are Oak Road Broad likely to occur Oak Lodge Farm, for less than 5% 10 Shalloak Road, of the time. 3 Shalloak Road, the caravan at Kemberland Farm to the north of the proposed 400kV route and Tile Lodge Farm House
11.16.3 The assessment of the significance of effects due to operational noise has concluded that: operational dry noise from the proposed 400kV overhead line is assessed as being not significant at all receptors;
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operational wet noise from the proposed 400kV overhead line is assessed as being not significant at all receptors except at Caravan 1, Kemberland Farm where a significant effect is predicted if the proposed 400kV route centreline moves 5m closer to the receptor within the LoD; and during daytime periods the significance of effects are likely to be not significant at all noise sensitive receptors.
Inter-related effects 11.16.4 Noise and vibration is considered in Chapter 8 (Historic Environment) of this document in relation to the effect on sites of historic importance. Operational noise is unlikely to have a significant effect on sites of historic importance. 11.16.5 Noise and vibration is considered in Chapter 9 (Biodiversity) of this document in relation to the effect on fauna. Operational noise is unlikely to have a significant effect on sensitive species. 11.16.6 Noise and vibration is considered in Chapter 15 (Socio-economics and recreation) of this document. An amenity effects assessment has been undertaken which considers effects arising as a result of the inter-relationship of other environmental effects which together could affect the amenity value of receptors during construction, operation and decommissioning. The assessment has considered likely effects on the amenity of various receptors including: visitor attractions, PRoW, recreational routes, tourism accommodation and recreational areas; and local communities and community facilities (including health, education and community gathering).
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12. AIR QUALITY
12.1 Introduction 12.1.1 This chapter of the ES is a shortened chapter (as explained in Chapter 5 of this document) which reports on why the proposed development will have no likely significant effects on air quality such that this topic has been scoped out of the assessment following an initial assessment stage. 12.1.2 Following a summary of relevant policy and legislation, the chapter outlines the data gathering methodology and a description of the overall baseline conditions. Subsequent sections of the chapter describe the consultation which has taken place, the environmental measures incorporated into the proposed development and the scope of the assessment undertaken. The chapter should be read in the context of the project description in Chapter 3 of this document and in conjunction with Appendix 12A within Volume 5, Document 5.4.12A.
Scope of the Environmental Statement 12.1.3 In relation to air quality, all effects have subsequently been scoped out of the assessment. Initially, it was not possible to scope out vehicle emission effects until traffic data had been reviewed. Following receipt of the data, the construction vehicle numbers were compared against criteria and subsequently screened out. In terms of construction dust emissions, best practice guidance states that, providing appropriate environmental measures are adopted, there should not be significant effects as a result of construction dust. Appropriate environmental measures were determined following the completion of a dust risk assessment, and were incorporated into the design of the proposed development, therefore ensuring there would be no significant construction dust effects. The subsequent sections of this Chapter explain the reasons why such effects are scoped out. This chapter is structured in accordance with the approach set out in Chapter 5 of this document. As all effects are scoped-out there is no detailed assessment section in this chapter.
12.2 Policy and legislative context 12.2.1 This assessment has been undertaken in accordance with current legislation, along with national and local plans and policies.
Policy context 12.2.2 Chapter 4 of this document provides the overall policy context to the proposed development.Table 12.1 summarises the policy issues relevant to the air quality assessment, that have been considered in preparing this chapter. Relevant Sections of the ES have been cross-referenced to the appropriate policy at Table 12.1, although reference should be made to the Planning Statement (Volume 7, Document 7.1) for the full policy assessment.
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Table 12.1 Air quality policy issues considered in preparing the ES
Policy type Policy Policy issue reference
National planning EN-118 Part 5 of the NPS EN-1 contains policy and guidance on generic impacts, including air quality. Section 5.2 policies of EN-1 sets out the factors that an air quality assessment should consider. These include: any significant air emissions, their mitigation and any residual effects distinguishing between the project stages and taking account of any significant emissions from any road traffic generated by the project; the predicted absolute emission levels of the proposed project, after mitigation methods have been applied; existing air quality levels and the relative change in air quality from existing levels; and any potential eutrophication impacts.
All aspects of the proposed development have been considered in terms of emissions to air (Section 12.7 of this Chapter), environmental measures have been identified (Section 12.6 of this Chapter and Appendix 12A in Volume 5, Document 5.4.12A), residual effects discussed (Section 12.7) and baseline air quality conditions have been defined (Section 12.5). Due to the nature of the proposed development, there is not considered to be potential for any eutrophication impacts.
NPPF19 At Paragraph 109, the principle relating to air quality states that “the planning system should contribute to and enhance the natural and local environment by...preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability.” In addition, Paragraph 124 outlines that "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan."
All aspects of the proposed development have been considered in terms of air quality impacts (Section 12.7 of this Chapter). Baseline air quality concentrations in relation to EU limit values and air quality national objectives, and presence of air quality management areas have been considered in Section 12.5 of this Chapter.
Local planning policies CCC LP Policy C39, a saved policy of the Local Plan, states: “development that could directly or indirectly result in Policy C39 additional air pollutants and worsening levels of air quality within the area surrounding the development
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Policy type Policy Policy issue reference
site will not be permitted unless mitigation measures are agreed and fully implemented as part of the proposal.”
All aspects of the proposed development have been considered in terms of emissions to air (Section 12.7), and environmental measures have been recommended where required and incorporated into the CEMP (Section 12.6 of this Chapter and Appendix 12A in Volume 5, Document 5.4.12A).
CCC DLP The City Council will expect all development proposals to be of high quality design and will assess Draft Local proposals against the impact of noise, dust and vibration from the development or neighbouring uses Plan including polluting elements such as noise, air and light. Policy DBE3 All aspects of the proposed development have been considered in terms of emissions to air. See Section 12.7 and Section 12.6 of this Chapter and Appendix 12A in Volume 5, Document 5.4.12A.
CCC DLP When granting planning permission for development which could potentially result in pollution, the Council Policy will impose conditions or seek agreements to ensure subsequent mitigation measures are undertaken. QL12 All aspects of the proposed development have been considered in terms of emissions to air (Section 12.7), and environmental measures have been recommended where required and incorporated into the CEMP (Section 12.6 of this Chapter and Appendix 12A in Volume 5, Document 5.4.12A).
TDC LP Policy EP5, a saved policy of the Local Plan states that: “proposals for new development that would result Policy EP5 in the national air quality objectives being exceeded will not be permitted. Development proposals that might lead to such an exceedence, or to a significant deterioration in local air quality resulting in unacceptable effects on human health, local amenity or the natural environment, will require the submission of an air quality assessment, which should address: the existing background levels of air quality, the cumulative effect of further emissions and the feasibility of any measures of mitigation that would prevent the national air quality objectives being exceeded, or would reduce the extent of air quality deterioration.”
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Policy type Policy Policy issue reference
All aspects of the proposed development have been considered in terms of emissions to air (Section 12.7), and environmental measures have been recommended where required and incorporated into the CEMP (Section 12.6 of this Chapter and Appendix 12A in Volume 5, Document 5.4.12A). Residual effects are discussed (Section 12.7) and baseline air quality conditions have been defined (Section 12.5).
TDC DLP All major development schemes should promote a shift to the use of sustainable low emission transport to Policy minimise the impact of vehicle emissions on air quality, particularly within the designated Urban Air Quality SE05 Management Area. Development will be located where it is accessible to support the use of public transport, walking and cycling. Development proposals that might lead to a significant deterioration in air quality or an exceedence of air quality national objectives or to a worsening of air quality within the urban Air Quality Management Area will require the submission of an Air Quality Assessment.
This assessment considers the potential air quality impacts as a result of the proposed development (Section 12.7 of this Chapter). Baseline air quality concentrations in relation to air quality national objectives and presence of air quality management areas have been considered (Section 12.5).
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Legislative requirements European legislation 12.2.3 EU Framework Directive 96/62/EC on ambient air quality assessment and management came into force in November 1996 and had to be implemented by Member States by May 1998. The Directive aims to protect human health and the environment by avoiding, reducing or preventing harmful concentrations of air pollutants. As a Framework Directive, it requires the Commission to propose ‘Daughter’ Directives setting air quality objectives, limit values and alert thresholds, as well as guidance on the monitoring of individual pollutants. 12.2.4 The European Commission worked together with Clean Air For Europe (CAFE) to produce and publish a new European Directive in 2008 (Directive 2008/50/EC). It merges and replaces the majority of previous EU air quality legislation and incorporates the fourth Daughter Directive. Key changes included a new air quality objective for particulate matter smaller than 2.5µm (micrometres) in aerodynamic diameter (PM2.5). The objective includes a limit value and exposure reduction target. Member States had until 2010 to transpose the new directive into domestic law. National Air Quality Strategy 12.2.5 Part IV of the Environment Act (1995) requires the UK Government to produce a national Air Quality Strategy (AQS) which contains standards, objectives and measures for improving ambient air quality. Air pollution can seriously affect people's health and also the environment. The AQS sets out maximum ambient concentrations that are not to be exceeded either without exception or only with a permitted number of exceedences over a specified timescale. 12.2.6 The latest version of the AQS for England, Scotland, Wales and Northern Ireland was published in 2007160. It made no major changes to the objectives set out in the 2000 strategy or its addendum. National legislation 12.2.7 The ambient air quality standards and objectives are presented in Table 12.2. These are given statutory backing in England through the Air Quality Regulations 2000 and the Air Quality (Amendment) Regulations 2002. The Air Quality Standard Regulations 2010 transposed the requirements of the European Union Directives 2008/50/EC and 2004/107/EC on ambient air quality. The AQS objectives/EU Limit Values applicable to this assessment are presented in Table 12.2.
160 Department for the Environment, Food and Rural Affairs (2007) The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, Department for the Environment, Food and Rural Affairs
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Table 12.2 Relevant Air Quality Objectives/EU Limit Values
Air Quality Objectives EU Limit Values Pollutant Concentration Averaging Compliance Concentration Compliance period date date
3 3 NO2 200μg/m 1-hour mean 31 December 200μg/m (18 1 January (Nitrogen (not to be 2005 exceedences) 2010 Dioxide) exceeded more than 18 times per year)
40μg/m3 annual mean 31 December 40 μg/m3 1 January 2005 2010
3 3 PM10 50μg/m 24-hour mean 31 December 50μg/m (35 1 January (Particulate (not to be 2004 exceedences) 2005 matter <10 exceeded more microns in than 35 times size) per year)
40μg/m3 annual mean 31 December 40μg/m3 1 January 2004 2005 NOx 30μg/m3 annual mean 31 December 30μg/m3 19 July 2001 (Oxides of 2000 Nitrogen)*
*For the protection of vegetation and ecosystems
12.2.8 Local authorities have no legal requirement to comply with AQS objectives; they are however required to demonstrate best efforts to work towards achieving AQS objectives in order to meet statutory EU limit values. 12.2.9 Under the Local Air Quality Management (LAQM) regime, local authorities have a duty to undertake periodic reviews of local air quality against the AQS objectives/limit values. Where a local authority's review and assessment of local air quality indicates that AQS objectives/limit values are not expected to be achieved, local authorities are required to designate an Air Quality Management Area (AQMA). 12.2.10 The main requirements with respect to dust control from industrial or trade premises not regulated under the Environmental Permitting (England and Wales) Regulations 2010 and subsequent amendments, such as construction sites, are provided in section 79 of Part III of the Environmental Protection Act 1990. The Act defines statutory nuisance as, inter alia: “(d) any dust, steam, smell or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance; and (e) any accumulation or deposit which is prejudicial to health or a nuisance.”
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12.3 Data gathering methodology
Desk study 12.3.1 A desk study was undertaken to obtain information relating to baseline air quality conditions in the vicinity of the proposed development; this comprised the administrative areas of CCC, TDC and DDC. Desk study information has been taken from the following sources: CCC161, TDC162 and DDC163 LAQM reports; Department for Environment, Food and Rural Affairs (Defra) LAQM website164; Kent Air website165; and MAGIC website166. 12.3.2 A review of Ordnance Survey mapping and aerial photography available via GoogleEarth was also undertaken in order to identify sensitive receptor locations in and around the Order limits, within the study areas as discussed in Section 12.7 of this Chapter. 12.3.3 Guidance outlined in the following documents was also used to inform the baseline information gathering and is referenced where applicable as part of the impact assessment process: Institute of Air Quality Management’s (IAQM) Guidance on the Assessment of Dust from Demolition and Construction167; The Highways Agency’s Design Manual for Roads and Bridges (DMRB)168; Kent and Medway Air Quality Partnership Air Quality and Planning Technical Guidance169; and Environmental Protection UK (EPUK) Guidance: Development Control: Planning for Air Quality (2010 Update)170 has been updated since the production of the PEIR. The updated guidance document by the EPUK and IAQM Land-Use
161 Ricardo-AEA. Kent-Air website. Available from: http://www.kentair.org.uk/library?view=la (Accessed 28 Jul 2015) 162 Thanet District Council. Thanet District Council website. Available from: http://thanet.gov.uk/search/?q=air+quality (Accessed 20 Oct 2015) 163 Dover District Council. Dover District Council website. Available from http://www.dover.gov.uk/Environment/Environmental-Health/Air-Quality/Home.aspx (Accessed 28 Jul 2015) 164 Defra. Defra website. Available from http://laqm.defra.gov.uk/ (Accessed 28 Jul 2015) 165 Ricardo-AEA. Kent Air website. Available from http://www.kentair.org.uk/data/ (Accessed 28 Jul 2015) 166 Natural England. MAGIC website. Available from http://www.magic.gov.uk/ (Accessed 28 Jul 2015) 167 The Institute of Air Quality Management (2014) Guidance on the Assessment of Dust from Demolition and Construction 168 Highways Agency (2007), Design Manual for Roads and Bridges Volume 11, Section 3, Part 1, HA207/07
169 Kent and Medway Council (2011) Kent and Medway Air Quality Partnership Air Quality and Planning Technical Guidance
170 Environmental Protection UK (2010) Development Control: Planning for Air Quality (2010 update)
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Planning and Development Control: Planning for Air Quality171 has therefore been used to inform the assessment.
Survey work 12.3.4 As set out in the PEIR, the results of the desk study did not identify the need for any specific survey work, therefore no survey work has been undertaken for this assessment.
12.4 Environmental Impact Assessment consultation
Environmental Impact Assessment scoping 12.4.1 The Scoping Opinion for the Richborough Connection project has been received from PINS (see Appendix 1A in Volume 5, Document 5.4.1A). The Secretary of State consulted on the Scoping Report12 and the responses received are included in summary below where relevant to air quality. 12.4.2 Table 12.3 summarises how all consultee comments upon the Scoping Report have been addressed in the ES.
Table 12.3 Consultee comments and responses to EIA scoping
Consultee Comments How addressed in this ES
Secretary Adverse change to air Any changes in air quality have been of State quality should be considered, and following screening assessed in relation to assessments have subsequently been compliance with European scoped out. Baseline air quality air quality limit values and concentrations in relation to European air AQMAs. quality limit values and location of AQMAs have been considered in Section 12.5 of this Chapter.
Secretary The site lies within a The effect of the project on sensitive of State sensitive area that receptors (including designated wildlife includes national and sites) has been considered for both the European-designated construction and operational phases. Whilst wildlife sites. The impacts effects have been subsequently scoped out, on these and other the designated sites were considered when ecological receptors undertaking the dust risk assessment in should therefore be order to determine appropriate dust carefully assessed. mitigation measures (Appendix 12A) in Volume 5, Document 5.4.12A). Chapter 9 of this document details effects on ecological receptors.
Secretary The assessment should A dust risk assessment has been of State consider potential effects undertaken in accordance with Best
171 Environmental Protection UK and Institute of Air Quality Management (2015) Land-Use Planning and Development Control: Planning for Air Quality
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Consultee Comments How addressed in this ES
from increases in airborne Practice Guidance (Appendix 12A in pollution including fugitive Volume 5, Document 5.4.12A), which dust during site considers a variety of receptors including preparation, construction footpaths. Following the dust risk and dismantling works. assessment, appropriate mitigation Such emissions both on measures have been recommended site and off site should be (Appendix 12A), based on the risk rating of considered, including the site. These measures are derived from along access roads, local the Institute of Air Quality Management’s footpaths and other Best Practice Guidance for Construction PRoW. The need for Dust. appropriate mitigation and monitoring measures The methodology was outlined in the PEIR, should also be considered. and no subsequent comments were The applicant should received regarding the methodology. agree these with relevant consultees.
Secretary The baseline described in Potential air quality effects from the of State the Scoping Report is proposed development have been scoped based on Defra predictions out. Monitoring data from all local of background pollutants authorities have been collated and and that no site specific reviewed, and used, together with the Defra surveys are proposed. As background maps, to inform the Baseline this data is predicted Section (Section 12.5 of this Chapter). rather than factual and covers 1km by 1km grid Given that potential air quality effects as a squares it cannot be result of the project have been scoped out, considered truly and following review of existing air quality representative of local monitoring data, air quality monitoring in the conditions from which vicinity of the project was not considered potential impacts can be necessary. accurately assessed. This could affect the need and The methodology was outlined in the PEIR, adequacy of any mitigation and no subsequent comments were measures required. The received regarding the methodology. applicant is therefore encouraged to consult with each local authority regarding the validity of this data and the need for additional baseline monitoring.
Natural The assessment should All aspects of the proposed development England take account of the risks of have been considered in terms of emissions air pollution and how these to air (Section 12.7), and environmental can be managed or measures have been recommended where reduced. required and incorporated into the CEMP (Section 12.6 and Appendix 12A, Volume 5, Document 5.4.12A).
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Consultee Comments How addressed in this ES
Public Assessments should Any changes in air quality have been Health include appropriate considered, and subsequently scoped out, England screening assessments following screening assessments (Section and 12.7). Modelling was therefore not required. modelling where All phases of the proposed development necessary, should have been considered. Baseline air quality consider all potential concentrations in relation to European air pollutants associated with quality limit values and location of AQMAs the development for the have been considered in Section 12.5 of construction, operational, this Chapter. and decommissioning phases, should consider fugitive emissions, should include estimates of background levels, should consider cumulative impacts, should consider exsiting monitoring data, should compare concentrations with Air Qualilty Objectives, should consider sensitive receptors.
Public The assessment should This assessment considers the potential air Health consider impacts on quality impacts as a result of the proposed England existing areas of poor air development, as outlined in Section 12.7. quality (such as air quality Baseline air quality concentrations in management areas). relation to air quality national objectives and Modelling should use presence of air quality management areas appropriate meteorological have been considered (Section 12.5). data and should consider Modelling was not required. local topography.
CCC, TDC, The adequacy of existing Existing local authority monitoring data were DDC and air quality data should be used, and effects subsequently scoped out KCC agreed with the EHOs and following screening assessments. undertake monitoring if Monitoring was therefore not deemed required. necessary.
Statutory Consultation 12.4.3 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed consultees and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising, inspection of documentation at selected locations and parish and town council briefings. 12.4.4 National Grid prepared a PEIR which was publicised at this consultation stage. National Grid sought feedback on the environmental information presented in that report. Feedback received during Statutory Consultation was considered by National
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Grid and incorporated, where relevant, in the design of the proposed development and its assessment and the presentation of that assessment in this ES. 12.4.5 A summary of the Statutory Consultation representations received and National Grid’s responses are presented at Volume 6, Document 6.1 (Consultation Report). A summary of the main consultee responses received in relation to the air quality assessment are presented in the Table 12.4 below.
Table 12.4 Consultee comments and responses to PEIR
Consultee Comments and How addressed in this ES considerations
Public One respondent expressed The potential air quality impact of Consultation concern about air pollution the proposed development has Respondent arising both during been considered for both the construction and once the construction and operational connection is built. phases, and measures have been proposed where necessary to ensure there would be no significant air quality effects as a result of the proposed development.
Canterbury City Although no air quality The risk of dust impacts has been Council objectives will be exceeded, assessed in accordance with best there is the likelihood of practice guidance (the IAQM nuisance dust from fugitive Guidance on the Assessment of emissions from the site during Dust from Demolition and both the demolition and Construction167). Appropriate construction phases. There mitigation measures have been are adjacent residential and incorporated into the proposed work premises so it will be development to ensure there are no important to ensure that they significant air quality impacts are not impacted by this and (Appendix 12A in Volume 5, that appropriate best practice Document 5.4.12A). These measures and mitigation measures are outlined in the CEMP measures are put in place to (Appendix 3C in Volume 5, minimise these effects. These Document 5.4.3C) and Appendix details should be included in 3B in Volume 5, Document the Site Management Plan. 5.4.3B.
Natural Removal of the 132kV line is The risk of dust impacts has been England welcomed, this should be assessed in accordance with best conducted in such a way so practice guidance (the IAQM as to avoid impact on trees Guidance on the Assessment of and the ground flora of the Dust from Demolition and site and the timing of removal Construction167). Appropriate should avoid sensitive environmental measures have been periods such as bird incorporated into the proposed breeding/nesting and development to ensure there are no sensitive times for bat usage, significant air quality impacts and consideration of noise, (Appendix 12A in Volume 5, vibration and dust should be Document 5.4.12A). These assessed. measures are outlined in the CEMP (Appendix 3C in Volume 5, Document 5.4.3C) and Appendix
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Consultee Comments and How addressed in this ES considerations
Further avoidance and 3B in Volume 5, Document potential mitigation measures 5.4.3B. regarding potential impacts particularly on bird interest features will need to take into account the reasons for designations and the life cycle of the species and how they may be affected, timing of any works will be critical, and consideration of noise, vibration and dust should be assessed.
12.5 Overall air quality baseline
Current baseline Section A – Stour Valley 12.5.1 Section A is located within the administrative area of CCC. The main source of air pollution in the district is road traffic emissions from major roads161. CCC has designated one AQMA due to exceedences of the NO2 annual mean air quality objective164. The AQMA covers parts of the city centre and the main roads coming into it, and is approximately 290m south west of the Order limits, at its closest point (refer to Figure 12.1, in Volume 5, Document 5.3.12 for location of AQMA). 12.5.2 CCC undertakes both passive and automatic air quality monitoring within its district. However, the closest monitoring location is approximately 350m from the Order limits165, along a main road (Sturry Road) within the AQMA, and is therefore not considered representative of the area where the proposed development will take place. 12.5.3 Predictions of background pollutant concentrations on a 1km by 1km grid basis have been produced by Defra for the entire UK to assist Local Authorities in their Review and Assessment of air quality. Air quality background maps for 2015 for the area encompassing the Order limits have been downloaded from the Defra website164. These indicate that, in Section A, background NO2 concentrations are well below the annual NO2 air quality objective of 40µg/m³, with the highest background concentration being 13.9µg/m³ (at grid square 616500, 159500). PM10 concentrations are well below the annual PM10 air quality objective (40µg/m³) in the vicinity of the Order limits; with the highest background PM10 concentration being 16.8µg/m³ (at grid square 616500, 162500). NOx concentrations are also well below the annual NOx air quality objective (30µg/m³) in the vicinity of the site; with the highest background NOx concentration being 18.6µg/m³ (at grid square 616500, 159500). Section B – Sarre Penn Valley 12.5.4 Section B is also located within the CCC administrative area and is just under 4km north east of the AQMA, at its closest point164.
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12.5.5 No air quality monitoring is undertaken in the vicinity of Section B165. 12.5.6 Air quality background maps164 for 2015 for the area encompassing the site boundary indicate that, in Section B, background NO2 concentrations are well below the annual NO2 air quality objective (40µg/m³), with the highest background concentration being 11.9µg/m³ (at grid square 621500, 162500). PM10 concentrations are well below the annual PM10 air quality objective (40µg/m³) in the vicinity of the Order limits; with the highest background PM10 concentration being 17.5µg/m³ (at grid square 620500, 163500). NOx concentrations are also well below the annual NOx air quality objective (30µg/m³) in the vicinity of the site; with the highest background NOx concentration being 16.0µg/m³ (at grid square 621500, 162500). Section C – Chislet Marshes 12.5.7 Section C is located within the administrative areas of CCC, DDC and TDC. 12.5.8 The main source of air pollution in all three districts is road traffic emissions from major roads. Shipping emissions are also a contributor to air pollution in Dover; however, due to its distance from the proposed Order limits, this would not be applicable to Section C161. 12.5.9 The closest AQMA to Section C is approximately 4km to the north east, in Thanet. The AQMA covers a number of urban areas within Thanet, and has been declared due to exceedences of the NO2 annual mean air quality objective. 12.5.10 Canterbury City Council (CCC), DDC and TDC undertake both passive and automatic air quality monitoring. However, no air quality monitoring is undertaken in the vicinity of Section C165. 12.5.11 Air quality background maps164 for 2015 for the area encompassing the Order limits indicate that, in Section C, background NO2 concentrations are well below the annual NO2 air quality objective (40µg/m³), with the highest background concentration being 11.1µg/m³ (at grid square 627500, 165500). PM10 concentrations are well below the annual PM10 air quality objective (40µg/m³) in the vicinity of the Order limits; with the highest background PM10 concentration being 17.9µg/m³ (at grid square 626500, 164500). NOx concentrations are also well below the annual NOx air quality objective (30µg/m³) in the vicinity of the Order limits; with the highest background NOx concentration being 14.9µg/m³ (at grid square 627500, 165500). Section D – Ash Level 12.5.12 Section D is located within the administrative areas of DDC and TDC. 12.5.13 The closest AQMA to Section D is that covering the urban areas of Thanet. The closest point of the AQMA to Section D is just under 2km to the north east164. 12.5.14 No air quality monitoring is undertaken in the vicinity of Section D165. 12.5.15 Air quality background maps164 for 2015 for the area encompassing the Order limits indicate that, in Section D, background NO2 concentrations are well below the annual NO2 air quality objective (40µg/m³), with the highest background concentration being 12.1µg/m³ (at grid square 633500, 162500). PM10 concentrations are well below the annual PM10 air quality objective (40µg/m³) in the vicinity of the Order limits; with the highest background PM10 concentration being 17.0µg/m³ (at grid square 633500, 160500). NOx concentrations are also well below the annual NOx air quality objective (30µg/m³) in the vicinity of the Order limits; with the highest background NOx concentration being 16.1µg/m³ (at grid square 633500, 162500).
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Future baseline 12.5.16 The main contributor to air pollution within the Order limits is traffic emissions. Emissions (per vehicle) have generally decreased over time due to new technology, increasingly stringent emission regulations and cleaner fuel formulations. However, in recent years, the progressive Euro standards for diesel vehicles have not delivered the anticipated improvements in nitrogen oxide emissions, resulting in little/no 172 reduction in roadside NO2 concentrations . 12.5.17 Euro 6 emission standards came into force in 2013 for Heavy Duty Vehicles (HDVs) and came into force for cars and vans in September 2015. It is anticipated that there will be an improvement in emissions from Euro 6/VI vehicles (particularly diesel vehicles), this may therefore result in an improvement in air quality concentrations over time. 12.5.18 Consented developments in the surrounding area (as summarised in Table 5.2 of this document) may increase traffic flows in the vicinity of the proposed development. This may therefore result in an increase in air quality concentrations (namely NO2 / NOx and PM10). However, as baseline air quality concentrations are well below their respective objectives, this should not be an issue. 12.5.19 In addition, construction of the consented developments may result in a temporary increase in particulate concentrations as a result of fugitive dust emissions during construction works. 12.5.20 In summary, whilst there is uncertainty regarding future baseline air quality concentrations, it is anticipated that concentrations will remain below the respective air quality objectives due to the current air quality concentrations being well below the objectives.
12.6 Embedded environmental measures incorporated into the proposed development 12.6.1 The proposed development includes a range of embedded environmental measures (see Appendix 3B within Volume 5, Document 5.4.3B). Table 12.5 details the environmental measures which have been incorporated into the CEMP (see Appendix 3C, Volume 5, Document 5.4.3C) relating to air quality.
Table 12.5 Proposed embedded environmental measures
Potential Predicted changes and Incorporated measure receptor potential effects
Human and Air quality effects during Measures which have been incorporated ecological the construction phase into the CEMP following the dust risk receptors as a result of dust assessment (detailed in Appendix 12A in located along emissions from Volume 5, Document 5.4.12A) are set the route and demolition, earthworks, out in Appendices 3B and 3C in Volume close to the construction and 5, Documents 5.4.3B and 5.4.3C. trackout. Measures include (but are not limited to):
172 Defra. Defra website. Available from http://uk- air.defra.gov.uk/assets/documents/reports/cat05/1108251149_110718_AQ0724_Final_report.pdf (Accessed 20 Oct 2014)
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Potential Predicted changes and Incorporated measure receptor potential effects
construction plan site layout so that machinery and access roads dust causing activities are located away from receptors, as far as is possible; no bonfires and burning of waste materials; and ensure vehicles entering and leaving sites are covered to prevent escape of materials during transport.
Appendix 12A details all embedded environmental measures.
12.7 Scope of the assessment 12.7.1 The following air quality effects have been considered in the assessment, and discussed in further detail overleaf: construction phase: effects as a result of dust emissions from demolition, earthworks, construction and trackout; construction phase: effects as a result of vehicle emissions; and operational phase: effects as a result of vehicle emissions.
Potential receptors 12.7.2 All receptors within the respective study areas could be affected by the proposed development, these include: Human receptors within 350m of the Order limits; ecological receptors within 50m of the Order limits and human or ecological receptors within 50m of the routes used by construction vehicles on the public highway, up to 500m from the site entrance(s)167 (that is, the access(es) used to access the construction works from the public highway as shown Figure 12.2, in Volume 5, Document 5.3.12). Potential receptors include (but are not limited to): properties to the north east of Canterbury, Marsh Farm and properties within Sarre. Potential ecological receptors include West Blean and Thornden Woods SSSI and Sandwich Bay to Hacklinge Marsh SSSI. These receptors could be affected by dust during the construction phase. It should be noted that the guidance refers to the sensitivity of an area, which is dependent on the number and type of receptors present, therefore receptors have not been assessed individually, as detailed in Appendix 12A, Volume 5, Document 5.4.12A. Human and ecological receptors within 200m of roads experiencing a change in traffic flows, as a result of the project168. Potential receptors include (but are not limited to): properties to the north east of Canterbury, Marsh Farm and properties within Sarre. Potential ecological receptors include East Blean Woods SSSI, West Blean and Thornden Woods SSSI and Sandwich Bay to Hacklinge Marsh SSSI. These receptors could be affected by vehicle emissions during the construction and operational phase.
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Spatial and temporal scope 12.7.3 The spatial scope of the air quality assessment includes all areas where air quality effects could extend. For the construction dust, this is an area within 350m of the Order limits, and within 50m of the routes used by construction vehicles on the public highway, up to 500m from the site entrances. Effects from construction dust could last for the duration of the construction phase, dependent on the construction activities, although effects would be transient. The study area for vehicular emissions is an area 200m of roads experiencing a change in traffic flows as a result of the Project. Vehicular emissions may occur during the construction and operational phase of the Project.
Potentially significant effects 12.7.4 Initial assessment of each of the potential effects has led to the conclusion that they would not be significant and hence do not require further assessment, as detailed below. Effects on air quality of emissions from construction traffic 12.7.5 The EPUK170 guidance and the DMRB168 stipulate criteria in relation to when vehicle emissions from construction traffic should be considered as part of an assessment. A change in Heavy Duty Vehicles (HDV) of more than 200 per day for a year or more would require an assessment to determine the effects. Review of the predicted construction movements detailed in Chapter 10 of this Chapter indicates that predicted daily HDVs (two-way movements) on all access roads would be below 200 per day, even during peak construction times (see Table 12.6). 12.7.6 The EPUK guidance has recently been updated. The latest EPUK and IAQM guidance171 does not include criteria for construction vehicles, but does include criteria relating to the operation of a proposed development. The criteria recommends an air quality assessment should be undertaken when there is a change in HDV flows of more than 25 annual average daily flows within or adjacent to an AQMA, or more than 100 annual average daily flows elsewhere. As indicated in Table 12.6, all average HDV flows are below 25, with the exception of Ramsgate Road and Gore Street, which have average flows of 26 HDVs per day. As neither of these roads are within an AQMA, and are below 100 annual average daily flows, further assessment is not required in accordance with the updated guidance. It must also be noted that the criteria are overly cautious, as they relate to the operation of a development rather than temporary construction traffic. 12.7.7 In light of the above, construction vehicle emissions have not been considered further in the assessment.
Table 12.6 Daily HGV two-way movements for the construction phase*
Road Name Bellmouth Average Peak
SECTION A
Broad Oak Road BM05 - BM07 + BM08 -12 8 65
Broad Oak Road BM02 8 27
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Road Name Bellmouth Average Peak
BM02, BM03 - BM04, Vauxhaul Road BM05-BM07 & BM08- 10 68 BM12
Shalloak Road BM08 - BM12 6 40
Herne Bay Road BM16 - BM19 & BM21 5 40
Hoath Road BM22, BM23-24 8 104
SECTION B
Bredlands Lane BM22, BM23 - BM24 8 104
Sandpit Lane BM28 - BM29 12 41
SECTION C
BM 1-12, BM22-24 (one- A28 Island Road way), BM28-29, BM30, 21 118 BM31 & BM32
A253 Ramsgate BM33 (BM34, BM35, 26 132 Road BM36, 37)
BM37 (BM34, BM35, Gore street 26 132 BM36)
SECTION D
A256 Ramsgate BM38, BM41-BM42 1 2 Road
Richborough BM41 0 0 Road
A256 Ramsgate BM42 0 0 Road
*Based on construction vehicles operating Monday to Saturday, as a worst case, as construction may also take place on a Sunday. This would result in a reduction of the daily flows presented here, as they have been derived from weekly flows) Effects on air quality of emissions from operational traffic 12.7.8 Once constructed, traffic movements would be limited to a small number of light vehicle movements to allow for foot patrol inspections (followed by helicopter inspection if required, approximately every 6 years), subsequent infrequent repairs and routine maintenance works on all aspects of the development. The number of vehicles that triggers the need for an air quality assessment, in accordance with the IAQM and EPUK guidance171 is greater than 100 annual average daily traffic (AADT) movements in sensitive areas such as AQMAs and 500 AADT movements elsewhere. These thresholds would not be exceeded during the operational phase of the project. Therefore vehicle emission effects for the operational phase have been scoped out of the assessment.
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Effects on air quality of emissions from construction works 12.7.9 In terms of construction dust, the IAQM guidance167 stipulates a construction dust risk assessment should be undertaken where there is: a “human receptor within 350m of the boundary of the site; an ecological receptor within 50m of the boundary of the site; or either a human or ecological receptor within 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s)”. As there are both human and ecological receptors within the study area stipulated within the IAQM construction dust guidance (see Figure 12.1 in Volume 5, Document 5.3.12), a dust risk assessment has been undertaken, as detailed in Appendix 12A in Volume 5, Document 5.4.12A. This has identified that without measures to mitigate dust, the risk of dust effects is at most medium. The risk assessment is used to define appropriate measures to mitigate any dust effects to ensure there would be no significant air quality effects. As appropriate measures have been incorporated into the project (Table 12.5 and Appendix 12A), there would be no significant air quality effects as a result of construction works. Inter-related effects 12.7.10 During construction, there is potential for inter-related effects as a result of dust emissions (for example there could be visual, noise, traffic and dust effects upon the same receptor). However, as best practice measures have been incorporated into the project (Table 12.5 and Appendix 12A in Volume 5, Document 5.4.12A), there would be no significant air quality effects as a result of construction dust. Additionally, baseline PM10 concentrations are well below the air quality objective. It is therefore considered that there would be no significant inter-related effects as a result of construction dust. 12.7.11 There would be no significant inter-related effects as a result of vehicle emissions given the vehicle numbers anticipated during the construction and operational phases and the low background concentrations.
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13. WATER ENVIRONMENT
13.1 Introduction 13.1.1 This chapter of the ES assesses the likely significant effects of the proposed development with respect to the water environment. It considers potential effects on surface water, groundwater and flood risk receptors. It should be read with reference to the project description in Chapter 3 within this document, and to those chapters where effects that are related to the water environment are assessed, namely Chapter 9, Chapter 14, and Chapter 15, all within this document. 13.1.2 Following a summary of relevant policy and legislation, the chapter outlines the data gathering methodology that was adopted as part of the water environment assessment. This leads on to a description of the overall baseline conditions, the environmental measures that have been incorporated into the scheme, the scope of the assessment, the assessment methodology and, for each receptor, an assessment of potential effects. The chapter concludes with a summary of the results of the assessment, including consideration of inter-related and cumulative effects. This chapter is partly based on the information provided in the Flood Risk Assessment (FRA), included in Appendix 13A within Volume 5, Document 5.4.13A.
13.2 Policy and legislative context
Policy context 13.2.1 The assessment has been informed by consideration of policies, both national and local, that have relevance to the water environment, as presented in Table 13.1. Relevant sections of the ES have been cross-referenced to the appropriate policy at Table 13.1, although reference should be made to the Planning Statement (Volume 7, Document 7.1) for the full policy assessment.
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Table 13.1 Policy issues considered in preparing the ES
Policy reference Policy issue
National planning EN-118 EN-1 identifies requirements to assess the potential impacts of energy projects on flood risk (Section 5.7), policies and water quality and water resources (Section 5.15), including consideration of climate change effects over the proposed development lifetime (Section 4.8).
Assessments of the effects of the proposed development on the aquatic environment (which includes water quality), water resources and flood risk are included in sections 13.9, 13.10 and 13.11 of this Chapter, respectively. A FRA is included in Appendix 13A, Volume 5, Document 5.4.13A. The future baseline, accounting for climate change is presented in section 13.5.
EN-1 Paragraph 5.7.4 of EN-1 states that “applications for energy projects of 1 hectare or greater in Flood Zone 1 in England…and all proposals for energy projects located in Flood Zones 2 and 3 in England…should be accompanied by a flood risk assessment (FRA).”
A FRA is included in Appendix 13A, Volume 5, Document 5.4.13A.
EN-1 Section 5.7.4. states that “The minimum requirements for FRAs are that they should:
be proportionate to the risk and appropriate to the scale, nature and location of the project;
consider the risk of flooding arising from the project in addition to the risk of flooding to the project;
take the impacts of climate change into account, clearly stating the development lifetime over which the assessment has been made;
be undertaken by competent people, as early as possible in the process of preparing the proposal;
consider both the potential adverse and beneficial effects of flood risk management infrastructure, including raised defences, flow channels, flood storage areas and other artificial features, together with the consequences of their failure;
consider the vulnerability of those using the site, including arrangements for safe access;
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Policy reference Policy issue
consider and quantify the different types of flooding (whether from natural and human sources and including joint and cumulative effects) and identify flood risk reduction measures, so that assessments are fit for the purpose of the decisions being made;
consider the effects of a range of flooding events including extreme events on people, property, the natural and historic environment and river and coastal processes; include the assessment of the remaining (known as ‘residual’) risk after risk reduction measures have been taken into account and demonstrate that this is acceptable for the particular project;
consider how the ability of water to soak into the ground may change with development, along with how the proposed layout of the project may affect drainage systems;
consider if there is a need to be safe and remain operational during a worst case flood event over the development’s lifetime; be supported by appropriate data and information, including historical information on previous events.”
An assessment of the effects on flood risk receptors is included in Section 13.11 of this Chapter. A FRA is included in Appendix 13A, Volume 5, Document 5.4.13A. Section 6 of the CEMP (Appendix 3C, Volume 5.4.3C) include flood risk management (mitigation) measures.
EN-1 Paragraph 5.7.7 states that “Applicants for projects which may be affected by, or may add to, flood risk should arrange pre-application discussions with the EA, and, where relevant, other bodies such as Internal Drainage Boards, sewerage undertakers, navigation authorities, highways authorities and reservoir owners and operators.
Such discussions should identify the likelihood and possible extent and nature of the flood risk, help scope the FRA, and identify the information that will be required by the IPC to reach a decision on the application when it is submitted.”
An overview of the discussions and consultation with the EA, the IDB and other relevant bodies is provided in section 13.4 of this Chapter
EN-1 Paragraph 5.7.9 outlines that the Examining Authority where relevant should be satisfied that:
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Policy reference Policy issue
“the application is supported by an appropriate FRA;
the Sequential Test has been applied as part of site selection;
a sequential approach has been applied at the site level to minimise risk by directing the most vulnerable uses to areas of lowest flood risk;
the proposal is in line with any relevant national and local flood risk management strategy;
priority has been given to the use of sustainable drainage systems (SuDs);
in flood risk areas the project is appropriately flood resilient and resistant, including safe access and escape routes where required, and that any residual risk can be safely managed over the lifetime of the development.”
The DCO is accompanied by a FRA in Appendix 13A, Volume 5, Document 5.4.13A. Details to support the application of the Sequential Test are provided in Section 2.2 of the FRA. The sequential approach is discussed in Table 2.1, and sections 2.2 and 5.6 of the FRA. National policies are discussed in Section 2.2 of the FRA. Local policies are discussed in Section 2.3 of the FRA. SuDS drainage measures have been set out in Table 6.1 of the FRA, 13.10 of this Chapter and in the CEMP (Volume 5.4 Appendix 3C). The resilience of the development to flooding is discussed in Section 5.2 of the FRA. Flood risk management measures, including access and egress and the management of residual risks through the lifetime of the development are discussed in Section 6 of the FRA, as well as in the CEMP (Volume 5.4.3C, Appendix 3C).
EN-1 Paragraph 5.7.10 outlines that the Examining Authority will “… need to be satisfied that the proposed drainage system complies with any National Standards published by Ministers under Paragraph 5(1) of Schedule 3 to the Flood and Water Management Act 2010.”
Schedule 3 of the Flood and Water Management Act 2010 relates to sustainable drainage. The Government have decided not to implement Schedule 3, and not to publish any National Standards. Instead, sustainable drainage will be delivered through the planning system, supported by Non-
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Policy reference Policy issue
statutory Technical Standards for Sustainable Drainage Practice Guidance173, which was issued by the Local Authority SuDS Officer Organisation in September 2015.
EN-1 Paragraph 5.7.18 outlines that “To satisfactorily manage flood risk, arrangements are required to manage surface water and the impact of the natural water cycle on people and property.”
This is described in section 6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
EN-1 Paragraphs 5.7.20 – 5.7.21 requires that “Site layout and surface water drainage systems should cope with events that exceed the design capacity of the system, so that excess water can be safely stored on or conveyed from the site without adverse impacts.
The surface water drainage arrangements for any project should be such that the volumes and peak flow rates of surface water leaving the site are no greater than the rates prior to the proposed project, unless specific off-site arrangements are made and result in the same net effect.”
The preparation of a Drainage Management Plan (DMP) is listed in the draft DCO Requirements, to be produced following DCO approval, and referenced in the CEMP. This will include site drainage strategies for the compounds at Westbere and Richborough, as set out in section 6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A)
EN-1 Paragraphs 5.2.23 – 5.2.25 outline that “Opportunities should be taken to lower flood risk by reducing the built footprint of previously developed sites and using SuDS.
Essential energy infrastructure which has to be located in flood risk areas should be designed to remain operational when floods occur.
In addition, any energy projects proposed in Flood Zone 3b the Functional Floodplain (where water has to flow or be stored in times of flood), or Zone C2 in Wales, should only be permitted if the development will not result in a net loss of floodplain storage, and will not impede water flows.
173 Local Authority SuDS Officer Organisation, 2015. Non-statutory Technical Standards for Sustainable Drainage – Practice Guidance. http://www.lasoo.org.uk/non-statutory- technical-standards-for-sustainable-drainage
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Policy reference Policy issue
Flood Warning and evacuation plans should be in place for those areas at an identified risk of flooding.
The applicant should take advice from the emergency services when producing an evacuation plan for a manned energy project as part of the FRA.
Any emergency planning documents, flood warning and evacuation procedures that are required should be identified in the FRA.”
This is described in section 6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
EN-1 Paragraph 5.15.2 requires that “Where the project is likely to have effects on the water environment, the applicant should undertake an assessment of the existing status of, and impacts of the proposed project on, water quality, water resources and physical characteristics of the water environment as part of the ES or equivalent.”
This is described in sections 13.9 – 13.11 of this chapter and the FRA at Appendix 5.4.13A.
EN-1 Paragraph 5.15.2 requires that “The ES should in particular describe the existing quality of waters affected by the proposed project and the impacts of the proposed project on water quality, noting any relevant existing discharges, proposed new discharges and proposed changes to discharges.”
This is described in section 13.5 of this Chapter.
EN-1 Paragraph 5.15.3 requires that “The ES should in particular describe existing water resources affected by the proposed project and the impacts of the proposed project on water resources, noting any relevant existing abstraction rates, proposed new abstraction rates and proposed changes to abstraction rates (including any impact on or use of mains supplies and reference to Catchment Abstraction Management Strategies).
The ES should in particular describe existing physical characteristics of the water environment (including quantity and dynamics of flow) affected by the proposed project and any impact of physical modifications to these characteristics.
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Policy reference Policy issue
The ES should in particular describe any impacts of the proposed project on water bodies or protected areas under the Water Framework Directive and source protection zones (SPZs) around potable groundwater abstractions.”
This is described in section 13.5 of this Chapter.
EN-1 Paragraph 5.15.6 outlines that “The IPC should satisfy itself that a proposal has regard to the River Basin Management Plans and meets the requirements of the Water Framework Directive (including Article 4.7) and its daughter directives, including those on priority substances and groundwater.”
This is included in section 13.2 of this Chapter.
EN-1 Paragraph 5.15.8 outlines that “The IPC should consider whether mitigation measures are needed over and above any which may form part of the project application. (See sections 4.2 and 5.1.) A construction management plan may help codify mitigation at that stage.”
This is described in section 13.6 of this Chapter.
EN-1 Paragraph 5.15.9 outlines that “The risk of impacts on the water environment can be reduced through careful design to facilitate adherence to good pollution control practice. For example, designated areas for storage and unloading, with appropriate drainage facilities, should be clearly marked.” This is described in section 13.12 of this Chapter and outlined in the CEMP at Appendix 3C (Document 5.4.3C).
EN-1 Paragraph 5.15.10 outlines that “The impact on local water resources can be minimised through planning and design for the efficient use of water, including water recycling.”
This is described in section 13.12 of this Chapter and outlined in the CEMP at Appendix 3C.
EN-519 EN-5 restates the requirements of EN-1 which necessitates that due consideration and assessment is given to the effects of future climate change on flood risk to electricity transmission infrastructure (Section 2.4).
This is described in section 4.6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
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Policy reference Policy issue
EN-5 Paragraph 2.4.1 requires that “Applicants should set out to what extent the proposed development is expected to be vulnerable, and, as appropriate, how it would be resilient to: flooding, particularly for substations that are vital for the electricity transmission and distribution network; effects of wind and storms on overhead lines; higher average temperatures leading to increased transmission losses; and earth movement or subsidence caused by flooding or drought (for underground cables).”
The FRA (Appendix 13A, Volume 5, Document 5.4.13A) addresses the issue of resilience to flooding. The resilience of pylon design to other aspects of climate change, such as wind and storms and higher temperatures, is addressed in National Grid’s published Climate Adaptation Report174.
EN-5 Paragraph 2.4.2 states that “Section 4.8 of EN-1 advises that the resilience of the project to climate change should be assessed in the Environmental Statement (ES) accompanying an application. For example, future increased risk of flooding would be covered in any FRA (see section 5.7 in EN-1).”
The future baseline for the water environment is set out in section 13.5 of this Chapter, and considered in sections 13.7, 13.9, 13.10 and 13.11 of this Chapter. It is also discussed in the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
NPPF36 NPPF requires flood risk should be avoided wherever possible through the use of a sequential approach to locating new development in areas of low risk (Paragraph 100). It also requires that new development should not increase the risk of flooding elsewhere, and provides guidance on management and mitigation of flood risk for new developments, including the use of sustainable drainage systems (SuDs, Paragraph 103). National Planning Practice Guidance (NPPG) provides additional detail supporting the NPPF, such as the requirements for a site specific FRA, land use flood vulnerability classifications and climate change allowances.
In addition, Paragraph 109 requires the planning system to prevent new development from contributing to, or being adversely affected by unacceptable risk of water pollution.
All of the requirements relating to flood risk are addressed in the FRA (Appendix 13A, Volume 5, Document 5.4.13A): sequential approach (section 5.7), risk of flooding elsewhere (sections 5 and 6),
174 National Grid Electricity Transmission plc, 2010. Climate Change Adaption Report, September 2010.
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Policy reference Policy issue
management and mitigation (section 6), SuDS (section 6.1), land use vulnerability classifications (section 3.3) and climate change (section 4.6).
An assessment of the effects of the proposed development on the aquatic environment and water resources, including water quality/pollution, are included in sections 13.9 and 13.10 of this Chapter.
MPS The Marine Policy Statement175 (MPS) is the national framework for preparing Marine Plans and taking decisions affecting the marine environment. This is of relevance to the proposed development because the Order limits traverse the tidal reach of the River Stour. Whilst, for NSIPs such as the proposed development, the application must be decided in accordance with the relevant NPS, decisions must also have regard to the MPS.
Planning policy relating to the MPS is discussed in section 13.2.7 of this Chapter.
Local planning CCC LP Requires an appropriate assessment (of flood risk or drainage) to accompany a planning application where policies Policy C31 development is proposed in an area at risk of flooding or increased surface water run-off. The assessment should include the requirement for a contribution towards new flood defences or mitigation measures. Measures identified to mitigate effects shall be installed and maintained at the developer’s own expense.
The DCO is accompanied by a FRA (Appendix 13A, Volume 5, Document 5.4.13A). Flood risk management measures are set out in section 6 of the FRA.
CCC DLP All development proposals within the areas at risk of flooding or increased surface water run-off shall be Policy CC4 subject to a FRA and/or drainage impact assessment, where relevant. This assessment shall be in accordance with the Council’s Drainage Impact Guidance Note and Strategic Flood Risk Assessment, including the requirement for a contribution towards any necessary new flood defence or mitigation measures.
The DCO is accompanied by a FRA (Appendix 13A, Volume 5, Document 5.4.13A). Flood risk management measures are set out in section 6 of the FRA.
175 HM Government, 2011. UK Marine Policy Statement. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69322/pb3654-marine-policy-statement- 110316.pdf
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Policy reference Policy issue
CCC DLP On sites that have not been previously developed within the Environment Agency’s Zones 2 and 3, no new Policy CC5 development will be permitted unless an exceptional justification can be demonstrated through the Sequential and Exception Tests. Extensions to existing property and change of use must meet the requirements of flood risk assessments.
The Sequential and Exception Tests are discussed in sections 2.2, 5.6 and 5.8 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
CCC DLP All developments should aim to achieve greenfield run-off rates and ensure that surface water run-off is Policy CC11 managed as close to its source as possible using the following hierarchy: a. Discharge into the ground b. Discharge to a surface water body c. Discharge to a surface water sewer d. Discharge to a combined sewer
Measures relating to surface water run-off, the adherence to greenfield run-off rates and discharge locations are discussed in section 6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A) and section 13.6 and 13.11 of this Chapter.
CCC DLP New development should incorporate well designed mitigation measures to ensure that the water Policy CC12 environment does not deteriorate, both during construction and during the lifetime of the development.
Environmental measures relating to the water environment are set out in section 13.6 of this Chapter.
TDC LP Allocates the former Richborough power station site for redevelopment, noting that any proposals should be weighed against protection of the river corridor, protection of water quality and flood risk (Paragraph 13.89).
There are no formal saved policies relevant to the proposed development relating to the water environment in the plan.
Environmental measures to protect the river corridor, water quality and flood risk are set out in Section 13.6 of this Chapter.
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Policy reference Policy issue
TDC DLP The Sequential Test and Exception Test as set out in the NPPF will be applied to applications for Policy CC01 development within identified flood risk areas. Development proposals in these areas will need a flood risk assessment to be carried out by the developer.
The DCO is accompanied by a FRA (Appendix 13A, Volume 5, Document 5.4.13A). The Sequential and Exception Tests are discussed in sections 2.2, 5.6 and 5.8 of the FRA.
TDC DLP New development will be expected to manage surface water resulting from the development, incorporating Policy CC02 SuDS wherever possible. SuDS design should be considered as an integral part of the masterplanning and design process for new development.
Environmental measures to manage surface water, including the requirement for SuDS, are set out in section 13.6 of this Chapter and section 6 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
TDC DLP Development with the potential to pollute will be permitted only where applicable statutory pollution controls Policy SE01 and siting will effectively and adequately minimise impact upon land use and the environment, including the release of pollutants to water.
Environmental measures that will minimise the impact of the development on the water environment are set out in section 13.6 of this Chapter. Assessments of the effects on the aquatic environment and water resources are included in sections 13.9 and 13.10 of this Chapter.
TDC DLP Proposals for development within the Groundwater Source Protection Zones identified on Map 19 (inc. in Policy SE4 Draft Local Plan) will only be permitted if there is no risk of contamination to groundwater sources.
An assessment of the potential effect of the development on groundwater resources is included in section 13.10 of this Chapter.
DDC LP Chapter 6 ‘Water Environment’ and the plan’s overall aims seek to “contain, reduce and, if possible, prevent water pollution”; “direct development away from areas liable to flooding”; and “wherever possible, protect and enhance the nature conservation, landscape and amenity value of the District’s water environment”.
Policy DM16 requires that the water environment is suitably protected to avoid harm to the landscape character of the area.
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Policy reference Policy issue
Environmental measures that will minimise the effect of the development on the water environment are set out in section 13.6 of this Chapter. Assessments of the effects on the aquatic environment, water resources and flood risk are included in sections 13.9, 13.10 and 13.11 of this Chapter.
KCC Local Policy 3 (areas with a low local flood risk which are being managed effectively) applies to the majority of the Flood Risk Order limits: Management Strategy “Policy 3 – Flooding in these areas will be monitored and problems will be dealt with reactively by the (2013)183 appropriate risk management authority”.
Policy 1 (areas with complex local flood problems) applies to a small section of the Order limits at Canterbury:
“Policy 1 – The flood risks in these areas will be investigated by KCC as a priority”.
Policies of KCC relating to their management of local flood risks are set out in the FRA (Appendix 13A, Volume 5, Document 5.4.13A).
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13.2.2 A number of other organisations with responsibility for management and regulation of the water environment have produced plans and strategies that are of relevance to this assessment. These are: The Environment Agency (EA); The River Stour (Kent) Internal Drainage Board (IDB); Kent County Council (KCC); South East Water (SEW); and The Marine Management Organisation (MMO). 13.2.3 The EA is the lead statutory body with responsibility for protection of the fluvial water environment (upstream of the mean high water spring limit). It is also responsible for flood defence and drainage for Main Rivers176 and estuarine and coastal areas, and is the designated ‘competent authority’ with responsibility for delivering the objectives of the Water Framework Directive (WFD). The EA has produced regional management plans and policies for the water environment relevant to this assessment, including the following: River Stour Catchment Flood Management Plan, December 2009177; Water Level Management Plan (WLMP) for Stodmarsh and Sandwich Bay to Hacklinge Marshes (SSSI)178; South East River Basin Management Plan, December 2009179; and Stour Abstraction Licensing Strategy, February 2013180. 13.2.4 The River Stour (Kent) IDB is responsible for managing drainage of agricultural land in the Chislet and Minster Marshes and the Ash Level. Consequently, their Policy Statement on Flood Protection and Water Level Management181 is of relevance to this assessment, as are a number of their byelaws that relate to management of the drainage network. 13.2.5 KCC is the Lead Local Flood Authority for the area (as defined by the Flood and Water Management Act, 2010), and as such is responsible for managing flood risk from ‘local’ sources of flooding, which include surface run-off, groundwater and Ordinary Watercourses182, other than those Ordinary Watercourses located within
176 Main River is a statutory designation which is usually applied to larger watercourses. 177 Environment Agency, 2009. River Stour Catchment Flood Management Plan; Summary Report. Environment Agency, Guidbourne House, Worthing, December 2009. 178 It is understood that this WLMP has been produced although a copy has not been obtained. The information provided on water level management by the EA and IDB via the consultation process described in Section 13.4 is considered sufficient for the purposes of this ES. 179 Environment Agency, 2009. River Basin Management Plan South East River Basin District. Environment Agency, Rio House, Bristol. December 2009. 180 Environment Agency, 2013. Stour Abstraction Licensing Strategy. Ref LIT 2048, Environment Agency, Horizon House, Bristol, February 2013. 181 River Stour (Kent) Internal Drainage Board. Policy statement on flood protection and water level management. (Online). Available from: http://www.riverstouridb.org.uk/policy.php (Accessed 23 June 2014). 182 ‘Ordinary Watercourse’ means any river, stream, ditch, drain, cut, dike/dyke, sluice, sewer (other than a public sewer) and passage through which water flows and which does not form part of a designated Main River..
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IDB areas, which remain the responsibility of the IDB. KCC’s strategy for managing flooding from local sources is set out in their Local Flood Risk Management Strategy (June 2013)183. The local planning authorities along the length of the Order limits have also produced Strategic Flood Risk Assessments (SFRAs)184 to support the development of their respective Local Plans, and these have also been reviewed as part of the water environment assessment. 13.2.6 SEW set out their plans to secure water supplies from 2015 to 2040 in their Water Resource Management Plan (WRMP). In order to meet a forecast demand shortfall, the plan outlines a proposed new reservoir at Broad Oak with an intake from the River Stour to be completed between 2030 and 2035. 13.2.7 The MMO is responsible for licensing activities that affect tidal waters up to the mean high water spring limit. The MMO is developing ‘Marine Plans’ for the future development of the marine environment, similar to those developed by local planning authorities on land. A total of ten Marine Plans covering all the seas around England are expected to be in place by 2021. The proposed development is located in the South East inshore area185, for which no plan is currently available. As a consequence, there are no local MMO policies that can be applied to this assessment.
Legislative requirements 13.2.8 Legislation relevant to the assessment of potential effects on the water environment includes the following: The European Union (EU) Water Framework Directive (2000/60/EC) (WFD), as enacted into domestic law by the Water Environment (Water Framework Directive) (England and Wales) Regulations 2003; Flood and Water Management Act 2010; River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England and Wales) Directions 2010; The EU Floods Directive (2007/60/EC), as enacted into domestic law by the Flood Risk Regulations 2009; Priority Substances Directive (2008/105/EC), as enacted into domestic law by the 2010 Directions listed above; Water Act 2003; Land Drainage Act 1991; Environment Act 1995; Water Resources Act, 1991;
183 Kent County Council, 2013. Local Flood Risk Management Strategy, June 2013. 184 Canterbury City Council, undated. Strategic Flood Risk Assessment – non-technical summary. Thanet District Council, 2009. Strategic Flood Risk Assessment, April 2009. Dover District Council, 2007. Strategic Flood Risk Assessment, September 2007. 185 Marine Management Organisation, 2014. Marine plan areas in England. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/325688/marine_plan_areas.pdfhttps://www.go v.uk/government/uploads/system/uploads/attachment_data/file/325688/marine_plan_areas.pdf
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Environmental Protection Act 1990; and Control of Pollution Act 1974.
Guidance 13.2.9 A range of general good practice advice and technical guidance is of relevance to this assessment, including the following: Environment Agency Pollution Prevention Guidance notes (PPG)186; Construction Industry Research & Information Association Report C697: The Sustainable Drainage Systems (SuDS) manual187; Construction Industry Research & Information Association Report C698: Site handbook for the construction of SuDS188; Construction Industry Research & Information Association Report C532: Control of water pollution from construction sites189; Construction Industry Research & Information Association Report C648: Control of water pollution from linear construction projects – technical guidance190; Construction Industry Research & Information Association Report C649: Control of water pollution from linear construction projects – site guide191; and Construction Industry Research & Information Association Report C692: Environmental good practice on site (third edition)192.
13.3 Data gathering methodology
Desk study 13.3.1 A comprehensive data gathering exercise has been undertaken in the preparation of this chapter of the ES. The most up-to-date information and mapping available on publicly accessible websites was initially used to determine a broad understanding of the current conditions along the route and in the immediate surrounding area. 13.3.2 The general study area for the purposes of desk study was taken to extend to a distance of approximately 100m from the proposed Order limits and additionally included any parts of the surface water catchments (as defined by the EA’s WFD
186 Environment Agency. Pollution Prevention Guidance (PPG). (Online) Available from https://www.gov.uk/government/collections/pollution-prevention-guidance-ppg (Accessed 22 Oct 2014). 187 Construction Industry Research & Information Association (CIRIA), 2007. The SuDS Manual. Report C697, CIRIA, London. 188 Construction Industry Research & Information Association (CIRIA), 2007. Site handbook for the construction of SuDS. Report C698, CIRIA, London. 189 Construction Industry Research & Information Association (CIRIA), 2001. Control of water pollution from construction sites; Guidance for consultants and contractors. Report C532, CIRIA, London. 190 Construction Industry Research & Information Association (CIRIA), 2006. Control of water pollution from linear construction projects – technical guidance. Report C648, CIRIA, London. 191 Construction Industry Research & Information Association (CIRIA), 2006. Control of water pollution from linear construction projects - site guide. Report C649, CIRIA, London. 192 Construction Industry Research & Information Association (CIRIA), 2010. Environmental good practice on site (third edition). Report C692, CIRIA, London.
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Cycle 2 water body boundaries) downstream of the proposed Order limits. It is appropriate to consider all downstream locations given their hydraulic connectivity (and therefore existence of potential ‘pathways’ for change) with the proposed development. Further baseline information with regard the WFD is provided in the water quality section of this chapter below. 13.3.3 Due to the limited possible interactions between the proposed development and upstream areas, these have generally not been assessed. The flood risk study area extends to the boundaries of the existing EA flood models to the north, south and east, thus extending further than WFD water body boundaries across the floodplain (upstream catchment inflows are incorporated into the models). 13.3.4 Following initial desk study, relevant organisations were approached to undertake direct consultations and to request specific data of direct relevance to the assessment. This is discussed further in Section 13.4. 13.3.5 The data and sources of information collected are listed in Table 13.2 below.
Table 13.2 Water environment – sources of information
Data type Sources of information
Topography Ordnance Survey mapping 1:50,000 and 1:10,000 scales
Rainfall Flood Estimation Handbook CD-ROM 3 (Centre for Ecology and Hydrology, 2009)193
Evapotranspiration Adams et al., 2008194
Hydrology EA ‘What’s in your backyard’ website195 River Stour Abstraction Licensing Strategy180 National River Flow Archive: http://www.ceh.ac.uk/data/nrfa/index.html EA flow data196
Flood risk197 EA ‘What’s in your backyard’ website195 Environment Agency Flood Model Reports and Outputs (including model mapping outputs)198
193 Centre for Ecology & Hydrology, 2009. Flood Estimation Handbook (FEH) CD-ROM (v3). Centre for Ecology & Hydrology, Wallingford, Oxon. 194 Adams et al. (2008). B Adams (editor), Contributors: K Baxter, D Buckley, J Cunningham, P Hopson, B Ó Dochartaigh, M Packman, V Robinson, R Sage, P Smedley, P Shaw, P Waring, G Warren, S Watson, 2008. The Chalk aquifer of the North Downs. Research Report RR/08/02, British Geological Survey, Keyworth, Nottingham. 195 EA ‘What’s in your backyard’ website online interactive maps (http://maps.environment-agency.gov.uk/wiyby/) 196 Daily flow data for the Calcott and Horton gauging stations, together with multiple spot gauging, acquired via EA data request. 197 Further local surface water management plans and district scale SFRAs are reported and taken into account within the FRA (Appendix 13A within Volume 5, Document 5.4.13A). 198 JBA (2013). Great Stour Flood Risk Mapping Study Final Report. 2011s5615 - River Stour Modelling and Mapping (v2 March 2013) JBA (2010). EA Southern, Lower Stour Areas Benefitting from Defences and Hazard Mapping Study. Final Report, June 2010. 2009s0416 - Lower Stour ABD Hazard Mapping Study Modelling Report_v5.6 and associated mapping.
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Data type Sources of information
EA flood spatial mapping, including flood zone and flood risk maps, flood defence details and historical flood extents Isle of Grain to South Foreland Shoreline Management Plan (SMP10)199 River Stour Catchment Flood Management Plan179 Kent County Council Preliminary Flood Risk Assessment200 Kent Mineral and Waste Development Framework Strategic Flood Risk Assessment (SFRA)201
Water quality Environment Agency water quality monitoring data202 South East River Basin Management Plan177 Local Catchment Improvement Partnership (CIP) reports and Water body Improvement Plans (WIPs)203 EA consented discharge data203 EA ‘What’s in your backyard’ website195
Groundwater EA groundwater level monitoring borehole locations203 EA Source Protection Zones203 EA ‘What’s in your backyard’ website195 South East River Basin Management Plan177
Water abstractions Environment Agency Abstraction licence details203 EA ‘What’s in your backyard’ website195 River Stour Abstraction Licensing Strategy180
Water Resource River Stour Abstraction Licensing Strategy180 Availability
Project description See Chapter 3, previous environmental considerations undertaken for Strategic Options Report (SOR) and Route Corridor Study (RCS) are outlined in Chapter 2.
Survey work 13.3.6 A walkover of the area in and around the Order limits was undertaken by members of the water environment project team on 26-28 August 2014.
JBA (2012). Model Update-Lower Stour ABD and Hazard Mapping Study (2010); Model Addendum, March 2012. 2011s5490 Lower Stour Addendum Report Final 199 Halcrow 2010. Isle of Grain to South Foreland SMP Review 2010. Halcrow Group Limited, Swindon 2010. 200 Kent County Council (2011). Preliminary Flood Risk Assessment, Final, September 2011. Available online at: http://www.kent.gov.uk/about-the-council/strategies-and-policies/environment-waste-and-planning-policies/flooding-and- drainage-policies/preliminary-flood-risk-assesment#http://www.kent.gov.uk/about-the-council/strategies-and- policies/environment-waste-and-planning-policies/flooding-and-drainage-policies/preliminary-flood-risk-assesment# 201 Kent County Council (2012). Kent Mineral and Waste Development Framework Strategic Flood Risk Assessment, May 2012. Available online at https://shareweb.kent.gov.uk/Documents/Forms/AllItems.aspx?RootFolder=%2fDocuments%2fenvironment%2dand%2dpla nning%2fplanning%2dand%2dland%2duse%2fPreferred%20Options%20consultation%20%2d%20May%202012&FolderCT ID=0x01200019B0E8F7AFBFA541BB6297103765733A (accessed 17/09/14). 202 Including WFD related chemical and biological monitoring data, and historical GQA data, acquired via EA data request. 203 Via EA data request.
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13.3.7 The results of the desk based assessment and the walkover survey did not identify the requirement for any specific survey work with respect to the water environment. This approach was discussed and confirmed through consultations with the EA (as discussed and agreed at a meeting with the EA on 22 September 2014204).
13.4 Environmental Impact Assessment consultation
Environmental Impact Assessment scoping 13.4.1 A request for a Scoping Opinion for the Richborough Connection project was submitted in August 2014, and the Scoping Opinion Report was received from PINS on 18 September 2014 and is included in Appendix 1A within Volume 5, Document 5.4.1A. The Secretary of State has consulted on the Scoping Report and the responses received are summarised below in Table 13.3 where relevant to the water environment.
Table 13.3 Consultee comments and responses to EIA scoping
Consultee Comments How addressed in this ES
Secretary of Agrees that the following Pollution effects on Sandwich Bay State water environment issues SAC and flood risk effects on third can be scoped out: party receptors during the operational phase remain scoped out of the pollution impacts on assessment and are not considered Thanet Coast and further, as discussed in Section 1.1 Sandwich Bay Special within this Chapter. Area of Conservation (SAC); Water quality effects arising from the water quality receptors presence of infrastrucuture and during the operational routine inspection and maintenance phase; activities during the operational phase food risk receptors during also remain scoped out and are not the operational phase; considered further, as discussed in and Section 1.1 within this Chapter. agricultural drainage However water quality effects (notwithstanding the associated with more substantial potential relationship with infrequent refurbishment works during the FRA). the operational phase are scoped-in and are considered in the Section 13.8 within this Chapter.
The potential for the proposed development to disrupt agricultural drainage, leading to changes in run- off rates and flood hazard is considered in the FRA (Appendix 13A within Volume 5, Document
204 Meeting minutes for meeting held with the EA and IDB on Monday 22 September 2014. Ref: L34829/EAMM40/RSIDBMM41.
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Consultee Comments How addressed in this ES
5.4.13A) and in Section 13.8 within this Chapter.
Notes that the impact of the Effects on surface watercourses project on the extensive within and around the Order limits network of drainage ditches have been assessed on the basis of and watercourses in low-lying identification of ‘aquatic environment’ areas of the Order limits receptors at WFD river waterbody needs to be addressed in full, scale, as discussed in Sections 13.7 including an assessment of and 13.8 within this Chapter. climate change. All sources of flooding are considered A FRA is required, which in the FRA (Appendix 13A within should cover tidal, as well as Volume 5, Document 5.4.13A), pluvial and fluvial impacts. including tidal flooding. Effects on third party flood risk receptors are also summarised in Section 13.8 within this Chapter.
Potential impacts on the Effects of the proposed development public water supply and on water resources receptors are sewer networks should be considered in Section 13.8 within this addressed. Chapter. However, no public water supply receptors have been identified as being at risk from the proposed development. Local impacts on water distribution and sewer networks have not been assessed as part of the EIA205. As set out in Section 2.13 of the CEMP, utilities, and requirement for relocation will be assessed by the construction contractor as part of the detailed design process after the DCO has been granted.
Environment A FRA will be required. An FRA has been prepared Agency (EA) Acknowledgement that (Appendix 13A within Volume 5, construction design process Document 5.4.13A), in which will take account flood risk to embedded environmental measures inform the location and for temporary infrastructure have been design of temporary specified, also summarised in Table infrastructure. 13.10 within this Chapter.
Flood Defence Consent FDC applications will be made outside (FDC) will be required for of the DCO application process, most works within 8/15m of any likely following approval, once detailed Main River or flood defence designs for works likely to affect main structure and early rivers have been prepared. discussions are Nevertheless discussions have taken
205 Utility checks have been undertaken and discussions commenced with relevant bodies, including Southern Water and South East Water. Consideration of existing utilities would be undertaken by the Contractor post-DCO.
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Consultee Comments How addressed in this ES
recommended. place on FDC requirements Circumstances under which throughout the EIA process, including FDC will be required were at meetings on 22/09/2014204 (EA and advised. Advised that works IDB), 17/04/2015206 (EA), and liable to affect Ordinary 13/10/2015207 (EA, IDB and KCC), Watercourses will be subject and email liaison with the IDB on to Land Drainage Consent 17/04/15 and 21/05/2015. Detailed (LDC) from the River Stour designs for watercourse crossings will IDB or KCC. take account of the embedded environmental measures for watercourse water quality, conveyance capacity and morphology identified in Section 13.6 within this Chapter.
A number of issues were Not considered further in this chapter. raised related to habitats and species, which are addressed in Chapter 9 within this document.
Kent County Highlighted the need to liaise Ongoing consultation with SEW has Council with SEW re: the potential informed the development of an (KCC) Broad Oak Reservoir and alignment for the overhead line that pipeline. would avoid the proposed reservoir footprint. This has not been considered further in the ES, as no planning application has yet been submitted for this development.
Satisfied with the proposed See response to EA comment on scope of the ES from a flood requirements for FDCs and LDCs. risk perspective. Noted location of the site within the River Stour (Kent) IDB area. Provided advice on consenting requirements for works in or near watercourses in line with that provided by the EA.
Marine The potential for potentially Clear span bridges will be used for the Management contaminated sediment two temporary crossings of the tidal Organisation associated with temporary River Stour, which will not result in (MMO) bridge structures to impact on any disturbance of bed sediments in the marine environment the tidal watercourse. On this basis, should be assessed in the there is not expected to be any scope ES. for effects of this nature, and this issue has been scoped-out from further consideration.
206 Meeting minutes for meeting held with the EA on 17 April 2015. Ref: 34829/EA MM 96. 207 Meeting minutes for meeting held with the EA, IDB and KCC on 13 October 2015. Ref: EA MM192.
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Consultee Comments How addressed in this ES
Other effects of the proposed development on the water quality and morphology of the tidal River Stour (Kent) WFD waterbody will be considered in Section 13.8 within this Chapter.
Further comments on the Not considered further in this chapter. scope of the assessment in relation to marine and intertidal ecology and commercial fishery receptors were made, and are discussed in Chapter 9 within this document.
Natural Agreed that potential Potential water environment effects on England pollution impacts on Thanet coastal water bodies and associated (NE) Coast and Sandwich Bay designated sites have been scoped- SAC were unlikely to be an out and are not assessed further in issue, given distance and this chapter. interest features of the site208.
Did not agree that potential The potential for effects on water effects on Stodmarsh SAC quality in Stodmarsh SAC is assessed arising from waterborne in this chapter in Section 13.8 within pollution from the proposed this Chapter. development could be scoped out, given its hydrological links to the proposed development and its greater freshwater interest.
Thanet If river transport is required River transport does not form part of District during the construction or the development proposals, and Council operational stages, the consequently this issue has been (TDC) effects on the water scoped out from further consideration. environment and in particular pollution risks should be fully considered.
Statutory Consultation 13.4.2 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed bodies and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising, inspection of documentation at selected locations and parish and town council briefings.
208 It should be noted that Natural England’s view on this matter changed from Scoping to PEIR stage.
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13.4.3 National Grid prepared and publicised a PEIR in February 2015 and sought feedback on the environmental information presented in that report. Feedback received during the Statutory Consultation was considered by National Grid and incorporated where relevant in the design of the proposed development and its assessment and presentation in this ES. 13.4.4 For the water environment, the PEIR included a preliminary EIA and a draft FRA. 13.4.5 A summary of the Statutory Consultation representations received (relevant to EIA) and National Grid’s responses are summarised in Volume 6 (Consultation Report). A summary of the main prescribed and non-prescribed bodies representations received in relation to the water environment assessment are presented in Table 13.4 below.
Table 13.4 Prescribed consultee comments and responses to the water environment assessment in the PEIR
Consultee Comments and How addressed in this ES considerations
Environment The EA noted that it had no Refer to Table 13.3 Agency (EA) additional comments to make and referred back to its previous responses to the Scoping Report (02/09/2014) and SOR (27/12/2012)
Kent County Kent County Council noted The findings of the FRA (Appendix Council (KCC) that they had no objection to 13A within Volume 5, Document the proposed development on 5.4.13A) provide the basis for the flood risk grounds, but would assessment of the effects of the review the final FRA in due proposed development on flood risk course. receptors presented in Section 13.8 within this Chapter.
Its response provides an As noted in Table 13.3, the overview of requirements for principles of consenting for works in consenting for works in or near or near watercourses have been watercourses that is consistent discussed and agreed during with that received from the EA correspondence and a meeting held in their Scoping Response, as on 13/10/2015, based on the outlined in Table 13.3. application of the embedded environmental measures for watercourse water quality, conveyance capacity and morphology identified in Section 13.6 within this Chapter.
Marine The MMO makes similar As noted in Table 13.3 clear span Management comments as made in their bridges will be used for the two Organisation scoping response with regard temporary crossings of the tidal (MMO) to potential impact of River Stour, which will not result in temporary bridge structures on any disturbance of bed sediments in three sets of receptors: the tidal watercourse. On this basis,
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local fish resources; there is not expected to be any intertidal and subtidal scope for effects of this nature, and marine ecology; and this issue has been scoped-out from the marine environment further consideration. (in the context of release of potentially contaminated sediment).
The MMO agreed that residual Other effects of the proposed effects on receptors are likely development on the water quality to be low, but that these and morphology of the tidal River should be identified and Stour (Kent) WFD waterbody will be assessed in the context of considered in Section 13.8 within these receptors in the ES. this Chapter.
Suggested conditions for the Effects on marine fisheries and Deemed Marine Licence were ecology are considered in Chapter enclosed with the response. 9 within this document.
Natural With regard to Stodmarsh The Stodmarsh England (NE) SSSI / SPA / SAC / Ramsar SSSI/SPA/SAC/Ramsar site is not in and Sandwich Bay and direct hydrological connectivity with Hacklinge Marshes SSSI, the Order limits. The other Sandwich Bay and Thanet designated sites are located at least Coast SPA / Ramsar and 5km downstream, other than under Sandwich Bay SAC, the ES the rare circumstances that the should consider the potential Stonar Cut flood gates are open impact on these sites in during flood events, under which relation to pollution that could scenario dilution capacity would be result from project construction very large. activities and be transmitted to the sites via hydrological Embedded environmental measures pathways. to minimise the risk of pollution to watercourses in the vicinity of construction activities are identified in Section 13.6 within this Chapter.
An assessment of the potential effects of pollution arising from construction activities on downstream designated sites is presented in Section 13.8 within this Chapter.
Woodland Raised concerns about Measures are identified to mitigate Trust impacts on ancient woodland, the effects of vegetation removal including run-off and water and ground disturbance associated quality effects. with construction phase activities in Section 13.6 within this Chapter. Further specific measures to minimise effects on ancient
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woodlands (woodland will be coppiced where possible) and to compensate for the loss of felled trees are presented in the AIA (Appendix 3I, within Volume 5, Document 5.4.3I).
The effects of construction activites, including vegetation clearance and tree felling, on water quality and run- off is considered in Section 13.8 with this Chapter. Operational phase effects on the water environment due to the loss of woodland cover are scoped out from further assessment, as no significant effects are predicted due to the measures proposed in the AIA (Appendix 3I, within Volume 5, Document 5.4.3I).
Non-statutory consultation 13.4.6 In addition to the responses received to the formal consultation exercises summarised above, the project team has continued to engage with consultees regarding the water environment throughout the EIA process via meetings and written correspondence. Reference is made to relevant meeting minutes and correspondence as appropriate throughout this chapter. Key meetings with prescribed consultees were held on 29 April 2014 (EA and IDB), 12 September 2014 (MMO), 22 September 2014 (EA and IDB), 17 April 2015 (EA), 13 October 2015 (EA, IDB and KCC), and 6 November 2015 (MMO).
13.5 Overall water environment baseline
Current baseline Topography 13.5.1 The Order limits extend from Canterbury North 400kV/132kV Substation in the west to the former Richborough power station site in the east. Starting from the western end, Section A starts in the valley of the River Great Stour before crossing over a broad watershed into the valley of the Sarre Penn watercourse to the north. The Order limits then extend eastwards along the Sarre Penn Valley (Section B) into the low lying, intensively drained areas of Chislet and Minster Marshes and Ash Level (Sections C and D). Ordnance Survey (OS) mapping indicates that the topography of the area is relatively subdued, with elevations varying between approximately 50 metres above Ordnance Datum (mAOD) at the watershed between the Stour and Sarre Penn valleys around Broad Oak (NGR TR163614) down to around 3mAOD on the marshes to the east of Upstreet (NGR TR225635).
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Geology, soils and land use 13.5.2 Please refer to Chapter 14 within this document for a description of the geology, soils and land use in and around the Order limits. Climate 13.5.3 Standard annual average rainfall estimates for the period 1961-1990 (SAAR61-90) were taken from the Flood Estimation Handbook (FEH) CD-ROM 3209). These demonstrate that average annual rainfall in the area exhibits an east to west gradient, varying from approximately 650mm at the western end of the route around Canterbury to less than 600mm at the eastern end around Richborough. This is considerably lower than the English annual average (1981-2010) of 855mm210, demonstrating that rainfall in the vicinity of the route is relatively low. 13.5.4 Data presented in Adams et al (2008)194 suggest that the average annual potential evapotranspiration in the area is approximately 550mm, with nearly 80% of this occurring between April and September. Actual evapotranspiration depends largely on vegetation and crop type, but, on average, is probably about 25% less than potential values194. 13.5.5 This difference between average annual rainfall and actual evapotranspiration is referred to as hydrologically effective rainfall (i.e. that portion of rainfall that contributes to aquifer recharge and river flow). The figures presented above suggest that annual average hydrologically effective rainfall along the route varies between 180 and 240mm. Surface hydrology 13.5.6 An overview of the water environment, including the location of principal watercourses, is provided in Figure 13.1 within Volume 5, Document 5.3.13. Smaller scale mapping, including smaller watercourses, is provided in Figures 13.2a to 13.2d within Volume 5, Document 5.3.13. Watercourses that could be affected by the proposed development include the River Great Stour/Stour211, the Sarre Penn, the Wantsum Channel212 and the extensive network of drainage ditches found in the Chislet, Monkton and Minster Marshes and Ash Level. 13.5.7 Consultations with the EA regarding management of their pumping stations, and a site walkover have confirmed that the Sarre Penn (Figure 13.2b) drains to the Wantsum Channel, which normally drains north to the North Sea via a tidal outfall east of Reculver (Figure 13.1), although there is also provision for the Wantsum Channel to discharge to the River Great Stour via Mile End pumping station (Figure 13.2c). 13.5.8 Throughout Section A and most of Section B, the Sarre Penn is a semi-natural stream running through a well defined valley feature. The upper Sarre Penn valley in Section A is the site of the South East Water’s proposed Broad Oak Reservoir (see Chapter 5, Table 5.3 within this document) and consequently there is a long-term flow
209 Centre for Ecology & Hydrology, 2009. Flood Estimation Handbook (FEH) CD-ROM (v3). Centre for Ecology & Hydrology, Wallingford, Oxon 210 UK Met Office. Met Office: Rainfall, sunshine and temperature time-series (Online) Available from: http://www.metoffice.gov.uk/climate/uk/actualmonthly/ (accessed May 2014). 211 This river is known as the Great Stour upstream of the confluence with the Little Stour at Pluck’s Gutter (NGR TR268634), and simply as the Stour downstream of this. 212 Also referred to as the River Wantsum
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measurement site at Calcott (NGR TR173624, Figure 13.2a). At Calcott the watercourse passes Longshaw Fishery, a series of four off-line lakes (Figure 13.2a). Downstream of Chislet, towards the lower end of Section B, the watercourse changes character; becoming enclosed within embankments with low-lying land to both sides that form Chislet Marshes (Figure 13.2b and 13.2c). Moving into Section C, the Sarre Penn flows into the Wantsum Channel just to the west of the village of Sarre (Figure 13.2c). 13.5.9 The Chislet Marshes (located to the north of the proposed route in Section C) are intensively drained and used primarily for arable agriculture. The water regime of the marshes is controlled by demand which varies with the seasons; in the winter the levels are kept low to protect against flooding; in the summer, large quantities of water are required for irrigation180. The water regime is augmented by the presence of Mile End pumping station (Figure 13.2c) which can transfer water from the Great Stour into the marsh. There are no permanent flow gauging stations within the marsh although there are many water level measurement sites which are used for internal management of the marsh180. 13.5.10 The River Great Stour is tidal downstream of Fordwich, approximately 1.5km east of Canterbury North 400/132kV Substation (normal tidal limit at TR175599 taken from Ordnance Survey mapping, as indicated in Figure 13.2a). However, in practice the Westbere Lakes (Figure 13.2a and 13.2b) act as a series of balancing ponds for tidal effects, and therefore there is very little tidal influence upstream of this point (NGR TR195605). Further downstream, the EA has confirmed that the main Great Stour/ Stour channel is isolated from the marsh and level drainage systems by sluices and control structures and thus only the main river is tidal under normal conditions. 13.5.11 The Monkton and Minster Marshes (Figures 13.2c and 13.2d) are located on the low lying, reclaimed land to the north of the River Stour, east of Sarre (Sections C and D). This land is intensively farmed for arable crops. The Monkton and Minster Streams (Figures 13.2c and 13.2d) drain the marshes to the north of the River Stour. There is a gravity outfall near Weatherlees Hill wastewater treatment works (WWTW) and a pumping station adjacent to Minster WWTW (Figure 13.2d). 13.5.12 The Ash Level (Section D, Figure 13.2d) is located to the south of the River Stour and is similar in character to the marshes to the north; albeit areas of the Ash Level are less intensively farmed and are more widely utilised for grazing. The Ash Level is drained predominantly by the Richborough Stream (Figure 13.2d) and the main Ash Level Pumping Station is in the west at Plucks Gutter (Figures 13.2c and 13.2d). There is a gravity outfall in the east near Richborough Farm (Figure 13.2d), however it has been noted by the EA that there is often not any flow through this outfall. 13.5.13 Water levels in the dense drainage networks of the Chislet and Minster Marshes and Ash Level are managed for agricultural and nature conservation purposes by the River Stour (Kent) IDB in conjunction with the EA, who owns and operates the pumping station assets. Levels are maintained by a number of sluices and pumping stations, which serve to hydraulically isolate the freshwater ditches from the tidal River Stour and manipulate levels (primarily for the benefit of agriculture). 13.5.14 The EA has confirmed that all their pumping stations are fully automated to maintain levels as per the regime described above. These pumps are not considered to be flood defence assets and are therefore not included within the EA’s Lower Stour flood model198.
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13.5.15 The furthest downstream flow gauge on the River Great Stour is located at Horton, just upstream of Canterbury (NGR TR115553). Summary data from this and the Calcott gauge on the Sarre Penn are presented in Table 13.5.
Table 13.5 Summary of river flows*
Gauge Gauge Water- NGR Catch Mean Q101 Q952 BFI3 Period ref. name course -ment flow (m3/s) (m3/s) of area (m3/s) record (km2)
40011 Horton Great TR 345 3.16 6.06 1.03 0.69 1964- Stour 115 2013 553
40027 Calcott Sarre TR 19.4 0.09 0.24 0.001 0.31 1975- Penn 173 2013 624
*Source: National River Flow Archive (http://www.ceh.ac.uk/data/nrfa/index.html) 1 Q10: the flow that is equalled or exceeded 10% of the time – an index of high flow 2 Q95: the flow that is equalled or exceeded 95% of the time – an index of low flow 3 BFI: baseflow index, the proportion of the total river flow that is derived from gradual release from groundwater storage, as opposed to rapid surface or near-surface run-off
13.5.16 These data demonstrate that the River Stour drains a substantial catchment upstream of Canterbury, with a relatively high baseflow index (BFI) indicating a substantial baseflow component derived from the North Downs Chalk aquifer, in addition to surface run-off from the Weald Clay areas in its headwaters. By comparison, flows derived from the small catchment of the Sarre Penn are very small. A relatively low BFI is indicative of the fact that this catchment is largely underlain by low permeability London Clay. Flood risk 13.5.17 The EA’s Flood Zone mapping provides an indication of the likelihood of flooding from fluvial and tidal sources, with Flood Zones 1 (less than 0.1% Annual Exceedance Probability (AEP) of flooding in any one year), 2 (between 0.1% and 1% (fluvial) or 0.5% (tidal) AEP), and 3 (equal to or greater than 1% (fluvial) or 0.5% (tidal) AEP) indicating a low, medium and high likelihood of flooding from rivers and the sea respectively213. Flood Zone extents are shown in Figure 5 of the FRA (Appendix 13A, Volume 5, Document 5.4.13A). The historic flood map, showing the recorded extent of historic floods in the area is provided in FRA Figure 6 and the EA’s updated ‘Flood Map for Surface Water’, showing surface water flood extents is presented as FRA Figure 7. 13.5.18 Table 13.6 summarises the percentage of each section of the Order limits that is located within Flood Zones 2 and 3.
213 Refer to Planning Practice Guidance on Flood Risk and Coastal Change, Table 1 for detailed Flood Zone definitions: http://planningguidance.planningportal.gov.uk/blog/guidance/flood-risk-and-coastal-change/flood-zone-and-flood-risk- tables/table-1-flood-zones/
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Table 13.6 Percentage of Order limits within each EA Flood Zone
Section Catchment description Principal Percentage of Order limits source of in Flood Zone (%) flood risk 1 2 3
A Great Stour upstream of Fluvial 87% 2% 11% Fordwich and upstream end of Sarre Penn valley
B Sarre Penn valley to Fluvial 54% 16%1 30% Upstreet
C Stour north floodplain, Tidal and 48% 5% 47% Wantsum Channel, fluvial Chislet and Minister Marshes
D Stour south floodplain; Tidal and 34% 35% 31% Ash Level fluvial
Overall 55% 16% 29%
Notes: 1) The downstream part of Section B, between Chislet Business Park and Upstreet is at risk of tidal flooding during an extreme event (Flood Zone 2).
13.5.19 In the western half of the Order limits (Sections A and B) the principal source of flooding risk is from fluvial sources, such as the River Great Stour and the Sarre Penn. Furthermore, areas of Flood Zones 2 and 3 are limited, and confined to the valley floor areas in the immediate vicinity of the principal watercourses. This compares to the eastern end of the route (Sections C and D), for which widespread areas are at risk due to a combination of fluvial and tidal sources in the low-lying marshes and levels. 13.5.20 Most of the marshes and levels of the lower Great Stour Valley are separated from the main River Stour by an extensive network of embankments. Some of these, including the Abbot’s, Monk’s and Sarre Walls, are historical structures associated with drainage and land reclaimation works that date back to the Middle Ages. Some of them are mapped as formally maintained flood defences on the EA’s online flood mapping, reproduced in Figure 5 of the FRA (Appendix 13A within Volume 5, Document 5.4.13A), while others are not. For example, some of Abbot’s Wall is indicated as a flood defence in the EA’s mapping (FRA Figure 5f), whereas further downstream it is not (FRA Figure 5g). Monks Wall and Sarre Wall are also not shown as flood defences. 13.5.21 The EA confirmed (see Annex 13A.2 of the FRA, Appendix 13A within Volume 5, Document 5.4.13A) that only formal flood defences on the banks for the River Stour are represented on their Flood Map and that, in many places, the banks of the Stour have been built up by channel maintenance activities and to facilitate land drainage for agriculture, rather than for flood defence. 13.5.22 It is worth noting that the upper catchment of the Wantsum Channel (the southern end) is contiguous with the floodplain of the River Stour. This is a consequence of
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the minimal topographical changes across this area, and the fact that the flow in the Wantsum Channel is artificially managed via pumping stations and maintained channels. 13.5.23 Flood risk assessment Figure 5 also shows areas benefitting from flood defences across Chislet, Monkton and Minster Marshes and Ash Level within Sections C and D of the Order limits. These are areas that benefit from flood defences from tidal flooding, which themselves could be located closer to the coast, and were determined by comparing modelled flood results for defended and undefended scenarios. There are no areas benefitting from defences in Sections A and B of the Order limits. 13.5.24 The EA holds two flood models for the River Great Stour/ Stour between Canterbury and Sandwich, as follows: i. an upper model, which was developed in 2012 and includes the fluvial reach of the Great Stour between Canterbury and Fordwich; and ii. a lower model, which was originally developed in 2010 (and updated in 2012 to better represent the flood defences around Sandwich), covering the tidal reach from Fordwich to Sandwich and including some representation of the IDB drainage networks on the adjacent marshes and levels. 13.5.25 There is no EA modelling covering the Sarre Penn within the Order limits in Sections A and B. 13.5.26 In this assessment, EA flood zones, which are based upon both modelled and historic flood information have been used to define the baseline flood risk extent. However flood model information has been used when necessary to provide greater understanding of flood levels and depths in areas of specific concern, for example with respect to examining the impacts of the proposed River Stour bridge crossings in flood conveyance and storage. 13.5.27 The EA’s updated Flood Map for Surface Water (uFMfSW) is shown in FRA Figure 7 (Appendix 13A within Volume 5, Document 5.4.13A). The uFMfSW defines areas at very low (less than 0.1%), low (between 0.1% and 1%), medium (between 1% and 3.3%) and high (greater than 3.3%) risk of surface water flooding. Generally this mapping does not show any significant additional flood risk from surface water flooding, since surface water flood extents appear to be generally coincident with the channel network along the route. What it does provide is indicative flood extents for the smaller watercourses and minor tributaries that drain to the River Stour and Sarre Penn that are not shown in the main EA Flood Zone maps. 13.5.28 The EA’s on-line mapping also provides flood extents associated with the failure of reservoirs of capacity of greater than 25,000m3. The mapping indicates no risk associated with this potential source of flooding along the route. No other potential sources of flooding from artificial sources have been identified. Consequently, artificial sources of flooding have not been considered further in this assessment. 13.5.29 Shallow groundwater is likely to be encountered in many areas along the proposed overhead line route, including in the Stour valley near Canterbury at the eastern end of Section A, in the floor of the Sarre Penn valley along Section B, and throughout the low-lying areas of the Chislet, Monkton and Minster Marshes and Ash Level in Sections C and D. Throughout Sections C and D, the low permeability of superficial deposits means that a shallow perched water table is present because of impeded drainage, which is controlled by the dense network of sub-surface field drains and
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field-edge drainage ditches found in these areas. As a consequence of this, although some groundwater is likely to be encountered during excavations, this is unlikely to be in significant quantities. 13.5.30 Elsewhere, British Geological Society (BGS) Groundwater Flooding Susceptibility data as supplied by Envirocheck214 shows that there are relatively few locations within the Order limits where groundwater flooding could be possible. Most notably, these include an area in the Stour valley to the east of Canterbury North 400kV/132kV Substation where subsurface structures could be susceptible to groundwater flooding, and the floor of the Sarre Penn valley as far as Upstreet which could be susceptible to surface flooding from groundwater sources. Groundwater 13.5.31 The Order limits predominantly overlies the East Kent Tertiaries WFD groundwater body, including all of Sections C and D, the western end of Section A in the Great Stour Valley at Canterbury, and the eastern end of Section B in the Sarre Penn valley near Upstreet. This groundwater body comprises deposits of the Harwich Formation, Lambeth Group and Thanet Beds Formation, all classified by the EA as Secondary A aquifers215, with the Thanet Beds predominating in and around the Order limits. 13.5.32 The London Clay, which underlies most of the western part of the Order limits (most of Sections A and B), is classified by the EA as a non-aquifer and does not form part of any WFD groundwater body. 13.5.33 The outcrop of the Thanet Chalk (which is classified as a Principal Aquifer216) is situated to the north of the Order limits east of Sarre, and the edge of the outcrop overlaps with the Order limits in the vicinity of Sarre (within Section C, NGR TR256650) as indicated by the boundary of the associated WFD groundwater body i.e. the ‘Kent Isle of Thanet Chalk’. In addition, the Chalk is present at depth below the overlying Thanet Formation, which may be relatively thin in some places along Sections C and D of the route. 13.5.34 It is likely that groundwater within the Tertiary deposits will interact with surface waters which flow across the groundwater body. For example it is likely that they will provide some seasonal inflow and they are known (as confirmed by the EA203) to be in hydraulic continuity with the marshes at the lower end of the Great Stour catchment. The Stour Abstraction Licensing Strategy (EA, 2013217) reports that the chalk has a strong influence on flows in the River Stour, with a significant proportion of the flow downstream of Wye (which is upstream of Canterbury) contributed by base flows, and the river is less responsive to rainfall peaks compared to further upstream.
214 Landmark Information Group (2014). Envirocheck Information Report, June 2014. 215 Secondary aquifers are permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers. Secondary A aquifers are generally the permeable layer aquifers formerly classified as minor aquifers (as distinct from Secondary B aquifers which may be associated with fissures within lower permeability layers for example). 216 Principal Aquifers are layers of rock or drift deposits that have high intergranular and/or fracture permeability - meaning they usually provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. In most cases, principal aquifers are aquifers previously designated as major aquifer. 217 Environment Agency (2013). Stour Abstraction Licensing Strategy, February 2013. A licensing strategy to manage water resources sustainably. Environment Agency, Horizon House, Bristol.
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13.5.35 In addition, the EA classifies the alluvium found in the floor of the Great Stour Valley near Canterbury (western end of Section A) and along the Sarre Penn Valley (Section B) as a Secondary A Aquifer215. All other drift types found in the vicinity of the route are considered to be non-aquifers. 13.5.36 Groundwater vulnerability is classified by the EA as Secondary Aquifer (previously Minor Aquifer) High status218 in the area of alluvial deposits within the Stour Valley. Elsewhere, in the vicinity of the Stour, where head deposits overlie the bedrock, the EA classifies groundwater vulnerability as being of Secondary Aquifer (previously Minor Aquifer) Intermediate status218. 13.5.37 The vast majority of the Order limits lie outside of any groundwater Source Protection Zones (SPZs). The exception being two short sections of existing access road in the northern part of Section D, as shown in Figure 13.3 within Volume 5, Document 5.3.13. The ends of these existing access routes are within the total catchment and outer zone (sub-surface only) of an SPZ associated with a public water supply abstraction from the Thanet Chalk near Minster, which is approximately 1.5km219 from the nearest edge of the Order limits. 13.5.38 There are a futher two SPZs in the general vicinity of the Order limits, as indicated in Figure 13.3b. Both are located close to the boundary between Sections A and B of the Order limits. The first is a small SPZ located near to Hersden, to the north of the Westbere Lakes. With the exception of two small inner zones located approximately 650m to the south of the Order limits, this SPZ relates to subsurface activity only; no parts of the inner or outer zones intersect with the Order limits. The second is a small SPZ at Millbank, which is approximately 1km to the north of the Order limits at its nearest point (Figure 13.3b). Abstractions 13.5.39 There are few licensed groundwater abstractions in the immediate vicinity of the Order limits (see Figure 13.3 within Volume 5, Document 5.3.13 which presents licensed abstractions and discharges). A relatively large (annual average maximum licensed volume of 5.1Ml/d) mineral washing groundwater abstraction licence is associated with the mineral workings at Westbere which is over 900m south of the Order limits. Major groundwater abstractions (including public water supply abstractions) from the Thanet Chalk are located to the north of Section D (the nearest of which are over 1.4km away, as indicated in Figure 13.3d). The remaining groundwater abstractions in the vicinity of the Order limits are very small in comparison, at 126 Sturry Road (annual average maximum licensed volume of 0.14 Ml/d, approximately 350m to the south of the Order limits), Ebbsfleet Farm (annual average maximum licensed volume of 0.03 Ml/d, approximately 750m to the north of the Order limits), Laundry Road Industrial Estate (annual average maximum licensed volume of 0.17 Ml/d, approximately 2.2km to the north of the Order limits. 13.5.40 A large number of licensed surface water abstractions, largely associated with spray irrigation (and winter storage), are drawn from the ditch networks in the freshwater marshes in the vicinity of Order limits Sections C and D. The spray irrigation demand varies depending upon the rainfall experienced within the summer months and the type of crop being grown. There is a large difference between the licensed value and that actually used180. Most of these licensed abstractions are located to the south of
218 High, Intermediate and Low denote soil leaching potential as defined by the National Soil Resources Institute 219 The EA do not provide grid references for public water supply abstractions for security reasons.
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the proposed route, e.g. on the Richborough Stream that crosses the Ash Level, and only six abstraction licences are located coincident with or within 100m of the Order limits. All six of these licences are for spray irrigation purposes. The EA and the IDB manage the freshwater marshes as a level-dependent environment through the use of sluices and pumps. Water abstraction from the marshes is supplemented through the EA’s ‘marsh feeding scheme’ (transfer of water via Mile End pumping station) from the tidal reaches of the River Great Stour) and new abstraction is restricted to the winter period and subject to local flow or level conditions. 13.5.41 The three local authorities (CCC, TDC and DDC) within which the route will pass were consulted to obtain their records of private water supplies in the study area. Each advised that there are no known private (i.e. unlicensed) water supplies in the vicinity of the route220, 221 and 222. Discharges 13.5.42 A large number of licensed discharges are present within the study area, most of which are associated with small sewage discharges from domestic properties. A total of 12 licensed discharges are located coincident with or within 100m of the Order limits, which are of the following type: four water company sewage discharges; three non water company sewage discharges; three waste site discharges for site drainage/surface water; one retail filling station discharge for site drainage; and one agricultural discharge for site drainage. 13.5.43 Three out of the six consented water company discharges are associated with final effluent discharge at WWTWs, as follows: Canterbury WWTW (permit number W00532, dry weather flow (DWF) of 20,176m3/d) which discharges to the River Great Stour within Section A (NGR TR167598, located near to Pylon PC3 in Figure 13.2a); Minster WWTW (permit number W00559, DWF 1,000m3/d) which discharges to the tidal River Stour within Section C at Marsh Farm (NGR TR310629, shown in Figure 13.2d); and Weatherlees Hill WWTW (permit number A00623, DWF 21,435m3/d) which also discharges to the tidal Stour at the extreme eastern end of the proposed Order limits (NGR TR328624, as shown in Figure 13.2d). 13.5.44 The remaining three water company discharges are for intermittent storm water overflows from the Canterbury and Minster WWTW, and from a wastewater pumping station at Chislet Business Park (NGR TR208630).
220 Email correspondence between Richard Wells (Amec Foster Wheeler) and Claire Hawken (Deputy Elections Manager and Freedom of Information/Data Protection Co-Ordinator for Canterbury City Council. 221 Email correspondence between Richard Wells (Amec Foster Wheeler) and Amanda Berry (Environmental Health Officer for Thanet District Council) on 2/10/2014. 222 Email correspondence between Richard Wells (Amec Foster Wheeler) and Glenn (Specialist Customer Advisor, EK Services for Dover District Council on 2/10/2014.
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Water quality 13.5.45 Since 2009, the EA’s General Quality Assessment (GQA)223 of surface water quality has been replaced by the WFD status classification approach. The River Stour, surrounding watercourses and underlying groundwater aquifers are located in the EA’s South East River Basin District. 13.5.46 The South East River Basin Management Plan (RBMP)179 divides surface water catchments and groundwater aquifers into discrete water bodies. A fundamental requirement of the WFD is to attain ‘good’ status within each defined water body and to ensure that deterioration in the status is prevented. 13.5.47 For surface waters there are two separate classifications for water bodies: i.e. ecological; and chemical. For a surface water body to be in overall 'good' status both ecological and chemical status must be at least 'good'. Ecological status is recorded on a scale high, good, moderate, poor and bad and is evaluated on the basis of environmental quality standards (EQSs) for biological, physico-chemical and hydromorphological elements. Chemical status is recorded as good or fail, and is evaluated on the basis of meeting EQSs for specific priority substances or priority hazardous substances, such as pesticides and heavy metals. To date, EQSs for WFD in England and Wales are specified in the WFD Directions 2010224, although it should be noted that these are due to be superseded by revised standards in late 2015. 13.5.48 Whilst good ecological status is defined as a slight variation from undisturbed natural conditions in natural water bodies, artificial and heavily modified water bodies (AWBs and HMWBs) are unable to achieve natural conditions. Instead, AWBs and HMWBs have a target to achieve good ecological potential (GEP), which recognises their important uses, whilst making sure ecology is protected as far as possible. The ecological potential for AWBs and HMWBs is also measured on the scale high, good, moderate, poor and bad. The chemical status of these water bodies is measured in the same way as for natural water bodies. 13.5.49 For groundwater bodies, good status has a quantitative and a chemical component. Together these provide a single final classification: good or poor status. Quantitative status is evaluated on the basis of overall aquifer water balance, impacts of abstraction on dependent surface waters or wetlands and potential for saline intrusion. Chemical status is evaluated on the basis of evidence for impacts of poor water quality on dependent surface waters or wetlands or deterioration of the quality of groundwater used for potable supply. 13.5.50 Since the publication of the first RBMP in 2009225, some of the associated Cycle 1 water bodies have undergone revision to their boundaries, names and associated management by the EA. These changes were undertaken to make them more logical management units, better reflecting the hydrological catchments of this part of the RBMP area, and also on account of an unrepresentative sampling point in Cycle 1226.
223 GQA data is available for the area of the River Stour for the period 1990 – 2009; however is deemed to be superseded by WFD water quality data and is not presented herein. 224 The River Basin Districts Typology, Standards and Groundwater threshold values (Water Framework Directive) (England and Wales) Directions 2010. 225 A draft ‘Cycle 2’ South East RBMP for the period 2015-2021 has been subject to public consultation, which is now closed. The final Cycle 2 RBMP is due for publication before the end of 2015. 226 Data request consultations August 2014.
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In addition to boundary changes, new water bodies have been added for Cycle 2 (post 2015) management and reporting. 13.5.51 EA data227 provide details regarding these recent updates, including data up to 2013 where available, which thus supersedes the information reported in the Cycle 1 RBMP. 13.5.52 Those WFD water bodies that may potentially be affected by the proposed project, based on Cycle 2 water bodies, are listed in Table 13.7 and presented on Figure 13.4 within Volume 5, Document 5.3.13. These have mostly been identified on the basis of their direct hydrological connectivity with the proposed Order limits, i.e. where any part of their catchment area coincides with the potential development area. However, in addition, a number of lake water bodies have been included, which are situated in the floodplain of the Great Stour downstream of Section A of the Order limits around Canterbury North 400/132kV Substation. Table 13.7 also indicates the water body type, overall status or potential, and a summary of those elements of the overall status assessment that do not meet the requirements of good status or potential. These reflect assessments based on 2013 water quality data where available. In some cases while the EA provided an overall 2013 water body status, information on the reason for failure to meet good status or potential – the ‘driver’ for the status – is not available. In these cases, where available, the 2009 ‘driver’ and supporting information is used, however it is recognised that these may change as the Cycle 2 update is completed by the EA. 13.5.53 It can be seen from Table 13.7 that none of the water bodies intersecting, or downstream of the order limits are currently at good status or potential. For surface water bodies, failures to achieve good status or potential appear to be largely related to nutrient enrichment and issues of physical modification, which in turn affect flow dynamics and fish populations. This is consistent with the intensive agricultural land- use and the heavily-modified nature of drainage networks found along the route and supported by EA descriptions/explanations presented in the relevant Water Body Improvement Plan (WBIP)228. The EA has identified229 that results from 2013 monitoring show a general decline in status across the Stour area compared to previous years but this is considered to be a reflection of improved knowledge rather than actual deterioration in quality. Further commentary on WFD status and baseline water quality is provided in Appendix 13B (Document 5.4.13B).
227 EA data request received July 2014. Supplemented by data from EA Catchment Explorer, http://environment.data.gov.uk/catchment-planning/, accessed 04/09/15. 228 Environment Agency 2014. Sarre Penn & River Wantsum Water Body Improvement Plan (WIP). 229 Environment Agency 2014. Great Stour between A2 and West Stourmouth Water Body Improvement Plan (WIP).
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Table 13.7 WFD Water bodies in potential direct or indirect connectivity with the proposed development (based on Cycle 1, 2013 data)
Water body Water body type Current overall Supporting elements at (designation status/potential less than good reason) status/potential
Great Stour HMWB river Moderate potential Fish, phosphate, between A2 and (wider phytobenthos1, West Stourmouth environment) macrophytes2 and current absence of required mitigation measures3
Sarre Penn and HMWB river Bad potential Fish, phosphate and, River Wantsum (land drainage) current absence of required mitigation measures3
Monkton and HMWB river Moderate potential No available information Minster Marshes (land drainage)
Ash Level HMWB river Moderate potential No available information (land drainage)
Stour (Kent) HMWB Poor potential Phytoplankton, dissolved Transitional inorganic nitrogen, (flood protection) phosphate, specific pollutants, current absence of required mitigation measures3
Fordwich Lakes AWB lake Poor potential Phytoplankton, total phosphorus, dissolved oxygen
Westbere Lakes AWB lake Poor potential Phytoplankton, total phosphorus
Fordwich Lake AWB lake Poor potential Phytoplankton, total East phosphorus
Great Puckstone AWB lake Moderate potential Phytoplankton, total phosphorus
Stodmarsh AWB lake Poor potential Phytoplankton, total Nature Reserve phosphorus Pool
East Kent Groundwater Poor status Effects on surface waters Tertiaries groundwater test
Kent Isle of Groundwater Poor status Effects on surface waters Thanet Chalk groundwater test, water balance test, chemical status
1: Phytobenthos – microscopic plants that live attached to substrates such as rock/stone or large plants.
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Water body Water body type Current overall Supporting elements at (designation status/potential less than good reason) status/potential
2: Macrophytes – emergent, submergent or floating aquatic plants. 3: Mitigation measures may be considered to be those environmental improvements that would assist the WFD water body to achieve good potential.
Statutory designated sites for nature conservation 13.5.54 Designated sites are discussed in Chapter 9 within this document. Those sites with a water dependence that could be potentially impacted are listed below. Flows in the River Stour and associated watercourses partially support a range of valuable water dependent ecosystems, which are protected by a range of statutory international and national designations, including SSSIs, SACs, SPAs, National Nature Reserves (NNRs) and sites covered by the Ramsar Convention. A summary of those sites with a key water dependence and potential hydrological connectivity with the proposed scheme is presented in Table 13.8. Further details are provided in Chapter 9 within this document, including their location in Figure 9.1a-h within Volume 5, Document 5.3.9.
Table 13.8 Summary of water dependent designated sites with potential hydrological connectivity to the Order limits
Designated site Water dependence Hydrological connectivity
Sandwich Bay to Contains a range of habitats Connectivity at distance. Hacklinge with water dependence Connected via River Stour, Marshes SSSI including mudflats, saltmarsh approximately 5km downstream of and freshwater grazing the Order limits under normal marsh. Relict fen vegetation conditions, but only 275m around the dykes of the downstream if the Stonar Cut flood inland farmland includes fen gates are open. plants that are now scarce in One SSSI unit is located outside Kent. Considerable but adjacent to the north of the ornithological interest which Order limits (near Weatherlees Hill is indirectly dependent on WWTW), however drainage is not water dependent (and dune) connected. habitats.
Sandwich Bay & Water dependent habitats Connectivity at distance. Pegwell Bay support important waders Direct connectivity via River Stour- National Nature and wildfowl populations. site located approximately 13km Reserve (NNR) downstream of the Order limits (or 2.4km if the Stonar Cut flood gates are open).
Thanet Coast & Some water dependent Connectivity at distance. Sandwich Bay habitats (maritime grassland, Direct connectivity via River Stour- SPA / Ramsar Site saltmarsh and grazing site located approximately 5km (& Sandwich Bay marsh) support this coastal downstream of the Order limits (or SAC) Ramsar site (primary interest
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Designated site Water dependence Hydrological connectivity
features include wader 275m if the Stonar Cut flood gates species, migratory birds and are open). wetland invertebrates).
Stodmarsh SSSI / Wetland supporting a range Connectivity at distance. SPA / SAC / NNR of water dependent habitats, Connected via River Stour >1.5km Ramsar Site which in turn support notable downstream of the Order limits at breeding and wintering Canterbury (NNR boundary >6km habitat for notable bird downstream). species. In addition the site No direct connectivity at nearest supports national rare point (400m): land within Order wetland invertebrates and limits at this location drains plant species. northwards towards the Sarre Penn, rather than southwards towards Stodmarsh.
Non-statutory designated sites for nature conservation Local Wildlife Sites 13.5.55 There are a number of Local Wildlife Sites (LWSs) intersecting or close to the Order limits, as identified by the Kent and Medway Biodiversity Partnership Steering Group, including the following sites with a water dependence: River Great Stour, Ashford to Fordwich LWS; Chislet Marshes, Sarre Penn and Preston Marshes LWS; Woods and Grassland Minster Marshes LWS (250m outside of the Order limits); and Ash Level & South Richborough Pasture LWS. 13.5.56 LWSs have no specific protection in law but nonetheless represent areas which are important for the conservation of wildlife230. See Chapter 9 within this document for further details in relation to LWSs. Biodiversity Opportunity Areas 13.5.57 Biodiversity Opportunity Areas (BOAs) can be seen as a spatial reflection of the Kent Biodiversity Action Plan (BAP). They indicate where the delivery of Kent BAP targets should be focused in order to secure the maximum biodiversity benefits231. The BOA maps also show where the greatest gains can be made from habitat enhancement, restoration and recreation, as these areas offer the best opportunities for establishing large habitat areas and/or networks or wildlife habitats. 13.5.58 The majority of the study area lies within one of the following two BOAs: Lower Stour Wetlands BOA; or The Blean BOA.
230 Kent Wildlife Trust (2012). What are Local Wildlife Sites - KWT leaflet, May 2012. 231 Kent Biodiversity Partnership (2014). Website: http://www.kentbap.org.uk/kent-boas/ (accessed 23/10/2014).
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13.5.59 The Lower Stour Wetlands BOA has direct water dependence. Chapter 9 within this document outlines that the BOAs within the Order limits are comprised of priority habitats, designated and non-designated sites which have been scoped in and taken forward for further assessment as receptors. BOAs are therefore not considered as receptors in their own right and are scoped out from further assessment (Appendix 9A within Volume 5, Document 5.4.9A).
Future baseline Climate change 13.5.60 The predicted future baseline water environment may change as a result of climate change. It is predicted that winters will become generally wetter and summers generally drier as a result of climate change. This is demonstrated in Table 13.9, which provides estimates from UK Climate Projections (UKCP09) of likely change in temperature and rainfall, under a range of emissions scenarios. Changes in rainfall and temperature will result in changes to the magnitude and distribution of river flows and groundwater recharge and subsequently the water resources available for use and for the water environment.
Table 13.9 Potential changes in the climate for south east England (medium emissions scenario) anticipated for the 2020s, 2050s and 2080s
Parameter 2020s* 2050s* 2080s*
Changes to winter mean 1.3 2.2 3.0 temperature ºC
Changes to summer mean 1.6 2.8 3.9 temperature ºC
Changes to winter mean 6 16 22 precipitation %
Changes to summer mean -8 -19 -23 precipitation %
* Central estimates Source: http://ukclimateprojections.metoffice.gov.uk/ 21942
13.5.61 It is also likely that the frequency and magnitude of flood events could change as a result of climate change effects on storm rainfall intensity, high river flows and sea levels. Consideration of climate change effects on flood risk over the lifetime of the proposed development are assessed within the FRA (Appendix 13A within Volume 5, Document 5.4.13A). Land use change 13.5.62 Changing land use can affect the permeability of the ground, which can affect surface water run-off and aquifer recharge. Given the low lying nature of the majority of the route, the intensively drained marsh land type and the desire to maintain and enhance the existing marsh habitats, as prescribed by the BOAs and LWSs for
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example, it is unlikely that the run-off regime will change significantly in and around the Order limits over the lifetime of the development. 13.5.63 The Stour Catchment Flood Management Plan177 identifies the following flood risk management policy for the Lower Stour area (which the Plan deems to be at low to moderate flood risk): Take action with others to store water or manage run-off in locations that provide overall flood risk reduction or environmental benefits. 13.5.64 Thus over the operational lifetime of the proposed development there may be reintroduction or expansion of wetland habitats within the marshes, in response to flood management planning. Any such change would seek to reduce potential climate change effects on, for example, the Stodmarsh SAC and would effectively work to broadly maintain the existing run-off and flood risk character of the lower Stour. Proposed South East Water reservoir 13.5.65 As discussed in Section 4.6 of this document, SEW’s WRMP contains outline details of the proposed Broad Oak Reservoir. 13.5.66 The proposed reservoir will significantly alter the hydrology of the Sarre Penn catchment immediately upstream of the Richborough Connection project. The maximum extent of the proposed reservoir has been considered during the development of the route for the Richborough Connection and discussions with SEW are ongoing. 13.5.67 The construction phase of the Richborough Connection project is anticipated to start in July 2017 and to be completed by June 2021 (including the dismantling of the 132kV PX route and removal of all non-permanent infrastructure). The assessment within this ES assumes that there will be no overlap with the construction phase of the proposed Broad Oak reservoir, which is SEW’s preferred option for securing increasing water supply capacity in the area in the future as stated in their WRMP, but which has no current status in the land use planning system. 13.5.68 The WRMP indicates that the reservoir would not be operational until 2033. Further detail on the proposed programme was provided by SEW at the public meeting in Broad Oak on 24 September 2015, where it was indicated that pre-application consultation on the proposals would occur in 2023, leading to a planning application being submitted around 2025, which would allow construction to commence around 2029. Mitigation works for the reservoir may be progressed in advance of the main construction works commencing, but it is expected that this would be subsequent to planning approval being granted, which is expected in 2025 at the earliest. Potential cumulative effects have therefore been scoped-out from this assessment on the basis that the construction phases of the Richborough Connection project and Broad Oak Reservoir projects will not coincide (see Table 5.3 of this document). Once construction is completed for the Richborough Connection, it is anticipated that the presence of the 400kV overhead line would form part of the baseline for assessment of effects in the EIA for the proposed Broad Oak Reservoir as and when the planning application for this scheme is brought forward. WFD change 13.5.69 Given the current ‘less than good’ ecological status/potential of all the RBMP water bodies along the route, it is anticipated that future status will improve, ultimately to one of good status/potential, as required by the WFD. As well as ensuring that there is no deterioration in current status, the development should also ensure that there
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are no effects that would preclude or hinder the improvement in status to Good in the future.
13.6 Embedded environmental measures incorporated into the proposed development 13.6.1 The proposed development includes a range of embedded environmental measures (see Appendix 3B, Volume 5, Document 5.4.3B). As a consequence, the potential effects of the development are subsequently evaluated with these ‘embedded’ measures in place232. The rationale for the inclusion of specific environmental measures in the design of the proposed development, and in the management of construction and dismantling programmes, with respect to the water environment is summarised in Table 13.10. Unless specified otherwise, all of the embedded environmental measures set out in Table 13.10 will be detailed and delivered through the CEMP (Appendix 3C within Volume 5, Document 5.4.3C), which will be secured through a DCO Requirement (draft Requirement 5).
232 These measures are proposed to be secured through the DCO and therefore the assessment has been completed for a mitigated scheme.
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Table 13.10 Proposed embedded environmental measures
Potential receptor Predicted changes and Incorporated measure type* potential effects
Aquatic environment Change in water quality via General receptor e.g. WFD generation of sediment laden All EA Pollution Prevention Guidance (PPGs) will be followed on-site to avoid pollution, water body or water run-off as a result of with particular emphasis being placed on adherence to PPG5, ‘Works and maintenance in dependent construction activities, e.g. or near water’ and PPG6 ‘Working at Construction and Demolition Sites’. designated site temporary access route and pylon foundation construction As set out in the CEMP, the contractor will undertake daily inspections, which will include activities or via accidental monitoring conformance with the CEMP. Immediate action including, if necessary discharge of concrete or fuels ‘stopping a job’, will be taken should any incidents or non-conformance with the CEMP be etc, resulting in potential found during inspection. This will ensure that the measures taken to protect the water deterioration in status of environment are effective. receptor WFD water body or designated site. Stand-off from watercourses Where possible, works within 8m (15m where navigable) of watercourse banktops will be avoided to minimise the number of Flood Defence (or Land Drainage) Consents required. An absolute minimum 3m stand-off distance from all watercourses/ waterbodies will be applied (with the exception of crossings and where existing field access routes that are already located adjacent to watercourses are to be utilised). This stand-off distance increases to 5m where ecological environmental measures are required.
Consents Flood Defence Consent/Land Drainage Consent will be obtained from the EA, IDB and KCC for all works within 8m of a Main River banktop (EA), 15m where tidal (EA), 8m for IDB watercourses (IDB) and where works are proposed between the banktops of all other watercourses233 (KCC). Formal Flood Defence (or Land Drainage) Consent applications will need to demonstrate measures are in place to protect water quality and to minimise
233 Kent County Council advised during the 13/10/2015 consultation meeting that they do not have byelaws in place (as the EA and IDB do) that requires consent for works outside of the banktop of Ordinary Watercourses outside of IDB areas. Consequently, clear span designs (banktop to banktop) that do not require works within the watercourse itself will not require land drainage consent. Land drainage consent for non-IDB Ordinary Watercourses is only required where in-channel works (i.e. between banktops) is to occur.
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Potential receptor Predicted changes and Incorporated measure type* potential effects
effects on watercourse morphology and conveyance, in order to ensure compliance with WFD objectives.
Culverts and bridges Culvert design will be chosen to minimise in-channel disturbance of bed and banks. Installation of culverts will be made in a dry channel (isolated from the channel flow) with overpumping of water made as necessary. Clear span bridges will be used for those watercourses too wide or deep to be crossed using culverts, for example, the two proposed crossings of the River Stour, and for crossings of larger drainage channels, including Sarre Penn, Severnscore Dike, West Monkton Stream, East Monkton Steam, Minster Stream and the River Wantsum.
Access routes and site compounds Access routes and works areas (including site compounds and pylon working areas) will be designed to be semi-permeable to allow infiltration (with the exception of fuel storage areas in the construction compounds, which will be underlain by low permeable material in order to ensure that any pollution incidents associated with spillages/leakages are contained).
Run-off will generally not be drained via a piped or open channel drainage system, but will instead be allowed to infiltrate. Infiltration trenches will be used to promote infiltration of locally displaced run-off where required. Further measures such as silt fencing will be installed to prevent run-off from disturbed areas from reaching watercourses where appropriate. Environmental measures will be provided in-situ in small scale measures in preference to larger regional systems.
Soil stockpiles Soil stockpiles will be located at least 8m from all watercourses (15m from the Stour on account of EA access requirements). Where stockpiles run parallel to watercourses, the stockpiles will be located on the opposite side of the access route. Temporary soakaway ditches (as above) will be installed where required to capture and treat sediment-laden run-off from soil stockpiles; with ditches installed adjacent to those stockpiles that are deemed to present a potential risk of run-off to water features. Silt fences may also be
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Potential receptor Predicted changes and Incorporated measure type* potential effects
installed adjacent to soil stockpiles or at the Order limits boundary where watercourses are in close proximity or downslope. The surface of stockpiled soils will be smoothed with excavators to reduce potential for run-off generation. With the exception of stockpiles with a lifetime of less than 3 months, all stockpiles will be seeded to encourage stabilisation of topsoil.
Groundwater dewatering discharges No silty water to be discharged directly into any watercourse. Groundwater dewatered from excavations (e.g. pylon foundation excavations) will be discharged to adjacent grassed/vegetated agricultural land, away from watercourses as far as possible. Where there remains the potential for this water to run-off into nearby surface water features, additional control measures will be put in place, which may include surrounding the discharge area (grassed/vegetated agricultural land) with sediment fencing or passing the silt-laden water through a Siltbuster® or similar. If infiltration is not possible, and discharge to a watercourse is required, this will be subject to a permit from the EA and will be proactively managed to meet the permit conditions. Further details regarding discharge consents are provided in the CEMP.
Site compounds Prior to the utilisation of any existing piped drainage systems, the contractor would investigate the suitability of such systems and replace elements and install additional measures, such as oil interceptors, where required. As part of the DMP (discussed below) detailed drainage strategies will be prepared for each compound, utilising SuDS principles173 for any areas requiring new drainage system. SuDS measures may include attenuation storage; infiltration trenches/soakaways. Discharge of site drainage to Controlled Waters may be subject to Environmental Permit from the EA. Any discharge to sewer wll be subject to permit from the water company.
Drainage Management Plan Further details of construction phase drainage management measures will be developed by the appointed contractors after the DCO has been granted, and will be presented in a DMP. The DMP will be submitted to and approved by the relevant planning authority prior to commencement of construction.
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Potential receptor Predicted changes and Incorporated measure type* potential effects
CEMP The requirement for all of the measures above will be detailed and secured in the CEMP, which will be a DCO Requirement. Further details regarding the process for obtaining discharge consents and the procedures for the management of consents are provided in the CEMP (Appendix 3C in Volume 5, Document 5.4.3C).
Aquatic environment Changes in morphology and Stand-off from watercourses receptor e.g. WFD flow conveyance as a result of Ensuring minimum stand-off distances between works and watercourses, except where water body or water increased sediment inputs or watercourse crossings are required, as noted above234. dependent direct watercourse designated site disturbance, resulting in Watercourse crossings potential deterioration in status Ensuring culverts and watercourse crossings are designed to minimise morphological and of receptor WFD water body or conveyance effects234. designated site. EA PPGs Ensuring construction of watercourse crossings adheres to best practice guidance for works in or near watercourses234.
Consents Applications for consent will need to demonstrate that proposals would not compromise WFD objectives.
Groundwater dewatering discharges If discharges to watercourses are at rates that could cause erosion to bed or banks, appropriate erosion control measures would be incorporated.
Aquatic environment Potential change to surface Pylon foundations receptor e.g. WFD water quality affected by Suitably corrosion and pH resistant concrete formulas will be utilised for pylon foundations. water body or water chemical leaching of concrete This will be specified in the CEMP.
234 All works within 8m of a main river bank-top (15m for a tidally influenced watercourse) will be undertaken with formal written Flood Defence Consent from the EA. All culverts or in- channel works for ordinary watercourses will be undertaken with the consent of the either Kent County Council or the River Stour (Kent) IDB.
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Potential receptor Predicted changes and Incorporated measure type* potential effects dependent footings (subsurface corrosion EA PPGs designated site of concrete), mobilisation of Compulsory adherence to standard EA PPGs and good practice with regards pollution contaminants from prevention will be delivered via the CEMP. contaminated soil, or accidental spillage of Site compounds pollutants (e.g. fuel or oil). Site drainage infrastructure from the site laydown compounds (Westbere and Richborough) would be designed such that it passes through a hydrocarbon interceptor and any discharge of this run-off water off-site will likely be subject to Environmental Permit to discharge as authorised by the EA
Contaminated land Where the contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) indicates that historical land contamination is likely, testing of the relevant material would be undertaken to assess the risk, as discussed in sections 14.9 and 14.13 of Chapter 14 of this document, and further measures taken as appropriate. Where a risk of contamination has been identified, intrusive investigations would be undertaken and suitable measures implemented prior to construction works and soil stockpile creation commencing. Requirement 13 of the DCO would secure the implementation of suitable measures to protect controlled waters from potentially contaminative ground conditions. The installation of run-off control measures and ensuring that stockpiles are located an appropriate distance away from watercourses, as discussed above, would further minimise the risk of contaminants arising from the excavation of contaminated land from reaching watercourses.
Fuel and oil storage All oil and diesel storage facilities will be at least 10m from any watercourse and at least 50m from any borehole or well
Water resources Potential change to Pylon foundations receptor e.g. WFD groundwater quality affected Suitably corrosion and pH resistant concrete formulas will be utilised for pylon foundations. groundwater body by chemical leaching of concrete footings (subsurface EA PPGs corrosion of concrete),
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Potential receptor Predicted changes and Incorporated measure type* potential effects
mobilisation of contaminants Compulsory adherence to standard EA PPGs and good practice with regards pollution from contaminated soil, or prevention will be delivered via the CEMP. accidental spillage of pollutants (e.g. fuel or oil). Site compounds Site drainage infrastructure from the site laydown compounds (at Westbere and Richborough) will be designed such that it passes through a hydrocarbon interceptor and any discharge of this run-off water off-site will likely be subject to Environmental Permit to discharge as authorised by the EA
Contaminated land As discussed previously, where the contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) indicates that contamination is likely, testing of the relevant material would be undertaken to assess the risk, as discussed in sections 14.9 and 14.13 of Chapter 14 of this document, and further measures taken as appropriate. Intrusive investigations would be undertaken prior to construction works commencing in those areas in which potential contamination has been identified in the desk study (Appendix 14A within Volume 5, Document 5.4.14A) to ensure that suitable measures are put in place ahead of soil stockpile creation.
Fuel and oil storage All oil and diesel storage facilities will be at least 10m from any watercourse and at least 50m from any borehole or well
Water resources Potential change to water See measures listed above re: silt and accidental release of pollutants in context of receptor e.g. quality of a water supply aquatic environment receptors. licensed abstraction resource (e.g. local private or private water water supply) which may affect supply the viability of an abstraction (e.g. for agricultural purposes).
Water resources Disruption of horizontal flows, Land drains receptor e.g. e.g. disruption to field drains, As discussed in the Geology, Soils and Agriculture chapter (Chapter 14 within this licensed abstraction during excavations. document), works to mitigate any impacts to agricultural field drainage have been
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Potential receptor Predicted changes and Incorporated measure type* potential effects or private water identified. For example, where field drains are excavated/encountered, measures will supply include local re-routing works, installation of lateral drains to allow new subsurface crossing of drain flow paths beneath access routes for example (if applicable) or reinforcement above drains to protect from crushing/collapse.
Flood risk receptor Change to local flood risk as a Access routes result of compartmentalisation Access routes (and working areas) in the floodplain are to be as close to ground level as of the floodplain. possible (a slight raise surface is often required to allow for drainage). Trackway will be used where possible. Cross drainage would be provided as necessary at topographic low points.
Soil stockpiles 20m breaks in soil stockpiles will be ensured at no greater than 80m intervals. Stockpile gaps will be located at topographic low points to preserve existing flow paths. Where stockpiles are placed on either side of the access routes, the gaps should coincide. These measures will reduce the potential magnitude of this effect.
Flood risk receptor Change to local flood risk as a Structures in the floodplain result of loss of floodplain At specific locations, in the vicinity of identified receptors, no raised structures, such as storage and/or change in raised access routes, working areas and associated topsoil stockpiles, will be located floodplain flow conveyance within the floodplain. Access routes and working areas will be ‘at grade’ and any associated stockpiles will be located outside of the floodplain. Locations include the upper section of the River Great Stour valley in Canterbury, and in Sarre Penn valley the vicinity of Tile Lodge Farm and Nethergong Farm
Flood risk receptor Changes to flow conveyance Watercourse crossings as a result of new or modified All installed structures will be sized to maintain existing flow conveyance.234. watercourse crossings, leading Clear span bridges for those watercourses too wide or deep to be crossed using culverts. to increased flood risk to No multiple pipes for culverts would be permitted. Culverts would have concrete bedding people, property and to prevent settling of the culvert and resultant loss of flow capacity. infrastructure.
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Potential receptor Predicted changes and Incorporated measure type* potential effects
Main River crossings Long clear span bridges for the temporary River Stour crossings, the soffits of which have been set on the basis of navigational requirements, which far exceed the requirements for flooding, i.e. well in excess of both the fluvial 1% AEP plus climate change and tidal 0.5% AEP plus climate change modelled design levels plus a 600mm freeboard. All installed structures will be sized to avoid any constraints to channel cross section. Detailed design will require approval from EA via Flood Defence Consent (Main Rivers), or from IDB/KCC via Land Drainage Consent (Ordinary Watercourses). These measures will reduce the potential magnitude of this effect.
Flood risk receptor Changes to run-off rates Ground cover resulting from ground Access routes and working areas to be constructed of material at least as permeable as disturbance and creation of the topsoil removed (e.g stone/crush gravel), where practicable, unless temporary impermeable surfaces, leading trackway is utilised to minimise the loss of floodplain storage, where additional drainage to increased flood risk to measures will be provided, such as infiltration trenches. people, property and infrastructure. Drainage No formal (piped or open channel) systems to be constructed (other than the land drains discussed previously). Run-off from access routes and working areas to be allowed to infiltrate wherever possible.
Drainage Management Plan Further details of construction phase drainage management measures will be developed by the appointed contractors after the DCO has been granted, and will be presented in a DMP. The DMP will be submitted to and approved by the relevant planning authority prior to commencement of construction.
Site compounds As part of the DMP, detailed drainage strategies will be prepared for each compound, utilising SuDS principles for any areas requiring new drainage system. Drainage from areas not served by existing drainage systems will be designed in accordance with SuDS principles and at pre-development rates. SuDS measures may include attenuation storage; infiltration trenches/soakaways.
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Potential receptor Predicted changes and Incorporated measure type* potential effects
Reinstatement All access route and working area construction material to be removed at the end of construction/demolition and reinstated with the topsoil stockpiles (to a level slightly above natural ground level to allow for settlement).
Dewatering activities Dewatering will cease if a Flood Alert or Flood Warning has been issued by the EA for an area downstream.
These measures will reduce the potential magnitude of this effect.
* Receptor types are introduced in the Potential receptors section below.
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13.7 Scope of the assessment
Potential receptors 13.7.1 Three types of receptors have been identified with respect to this water environment assessment: i. aquatic environment receptors; ii. water resources receptors; and iii. people, property and infrastructure at risk of flooding. 13.7.2 Each of these broad receptor types are discussed in this section. Aquatic environment receptors 13.7.3 The aquatic environment receptor type represents a range of potential species, interactions and pathways that may be affected by the proposed development. Potential effects on specific species (including fish) and aquatic and riparian biodiversity are assessed within the biodiversity assessment (Chapter 9 within this document), which should be read in conjunction with this assessment. Within this Water Environment chapter it is important to have cognisance of the requirements of the WFD, in order that potential effects are presented in the context of the water management and regulatory framework that is employed by the EA. Therefore, water quality and hydromorphology effects on aquatic environment receptors are considered in the context of WFD water body status within this chapter of the ES. 13.7.4 Water quality and hydromorphology are important elements in the characterisation of surface water bodies under the WFD. There are other elements of WFD characterisation (predominantly biology elements) such as macroinvertebrates and diatoms which are not assessed directly within this assessment, or the biodiversity assessment presented in Chapter 9 within this document. This approach is appropriate given that any changes in WFD biology elements (macroinvertebrates etc) would be an indirect result of changes to the water quality or the hydromorphology of a water feature. The characterisation of ecological potential for HMWBs and AWBs does not utilise hydromorphology as a supporting element and therefore in these instances, the only pathway for aquatic environment effects is via changes to water quality (although potential effects on hydromorphology are considered for all surface watercourses in the study area). 13.7.5 Specific consideration has been given to those designated nature conservation sites with a water dependence in the vicinity of the proposed development, as identified via the baseline assessment (Table 13.8). These have been identified as distinct aquatic environment receptors where there appears to be hydrological connectivity between the Order limits and the designated site. Water resources receptors 13.7.6 Water resources receptors include both surface and groundwater resources. Consideration of surface water resources will ensure a consideration of the rights of local water users, primarily abstractors within this assessment (navigation interests are assessed within Chapter 15 of this document). Potential derogation of these rights, as a result of the proposed development could occur either as a result of adverse changes to water quantity (e.g. reduced river flows or groundwater levels which could affect the yield of a water resource) or adverse changes to water quality
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(e.g. deterioration in water quality which may render a water resource unusable or increase treatment costs). The EA use WFD water bodies as the basic unit for assessment in their Abstraction Licensing Strategies180 and therefore spatial scale is consistent between the aquatic environment and water resources receptors. It would be impractical to evaluate the potential for effects on each of the many small scale agricultural abstractions individually. Consideration of groundwater resources will ensure any potential changes in WFD groundwater body quantitative and qualitative status are assessed (in the context of water resources effects i.e. separate to any consideration of WFD aquatic environments effects - as above). Flood risk receptors 13.7.7 Flood risk receptors are defined within this assessment as people, property and infrastructure that could be at risk of flooding. A parallel FRA has been undertaken for the proposed development which has helped to define the baseline flood risk across the study area (Appendix 13A within Volume 5, Document 5.4.13A). Where a flood risk to an identified receptor exists within the baseline environment it is important that this assessment recognises the potential change in risk arising from the proposed development.
Spatial and temporal scope Spatial scope for aquatic environment and water resources receptors 13.7.8 As noted above, the basic receptor unit for the assessment of effects on the aquatic environment and water resources is the WFD water body. Therefore the spatial scope of the assessment for direct effects on these receptors will be the catchment areas of all waterbodies that coincide with the Order limits. This includes river, transitional and groundwater water bodies, as identified in Table 13.7. 13.7.9 A large number of small surface watercourses that are too small to be designated as WFD water bodies in their own right traverse the Order limits. These are not considered as receptors in their own right; rather they are considered as part of the assessment of effects on the WFD water body in whose catchment they are located. 13.7.10 There is no pathway for direct effects on lake water bodies, as there are no water bodies of this type with catchment areas that coincide with the Order limits. However, there are a number of lake water bodies in the floodplain of the River Great Stour downstream of Fordwich, which are also listed in Table 13.7. The River Great Stour provides a potential pathway for indirect effects between those areas of the Order limits in the Great Stour valley at the western end of Section A and these features. Whilst the likelihood of significant effects on these water bodies is considered to be low, they are retained in the assessment as a precautionary measure. 13.7.11 Coastal water bodies are excluded from the assessment on the grounds that there is no pathway for direct effects arising from the proposed development on these water bodies. Furthermore, the potential for indirect effects on coastal water bodies arising from transmission of effects from the Order limits via the intervening transitional water body (i.e. the tidal River Stour) is considered to be negligible. This assessment is based on a consideration of the relative sizes of the transitional and adjacent coastal water bodies, and the magnitude of dilution that any indirect effect would be subject to. 13.7.12 In addition to WFD water bodies, all water-dependent statutory designated sites downstream, or downgradient of the Order limits are considered as potential water ecosystem receptors in their own right, as identified in Table 13.8.
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Spatial scope for flood risk receptors 13.7.13 Individual properties whose risk of flooding could be changed by the proposed development have been identified as flood risk receptors for this assessment. Properties were identified as potential flood risk receptors on the basis of a GIS- based screening exercise that considered the proximity of the Order limits and their location with respect to Flood Zones. This exercise is reported in Appendix A of the FRA (Appendix 13A within Volume 5, Document 5.4.13A). Potential receptors from this preliminary screening exercise were then subject to detailed assessment in the FRA, the key points of which are paraphrased in this chapter. 13.7.14 It should be noted that only flood risk effects on third party receptors are reported in the ES. Aspects of the development itself that are at risk of flooding are assessed in the FRA. Temporal scope 13.7.15 The temporal scope of this assessment covers the construction, operational and decommissioning phases of the proposed development. Effects on hydrology and flood risk will principally be associated with the construction phase. Once constructed, operational phase effects are expected to be more limited. These could occur either as a consequence of the presence of the infrastructure or as a consequence of operation and maintenance activities. Decommissioning effects would effectively be similar to construction phase effects, albeit of a lower magnitude and set against the future baseline.
Potentially significant effects Construction 13.7.16 The greatest potential for significant effects on the water environment arising from proposed development is likely to occur during the construction phase (i.e. comprising the construction of the new 400kV line and the dismantling of the existing 132kV PX line). These could arise from a range of construction related activities, including ground disturbance and soil stockpiling arising from the creation of access routes, working areas, laydown compounds and pylon foundation excavations, the installation of new or upgraded watercourse crossings; accidental spillage or release of polluting substances; and site drainage and excavation dewatering works. Effects that could be significant in the absence of effective environmental measures, include the following: Potential effects on the water quality of aquatic environment receptors arising from inflow of sediment-laden run-off from areas of disturbed ground or the accidental release of pollutants as a result of construction works. Potential effects on the hydromorphology and sediment transport regime of aquatic environment receptors. These could arise directly, as a consequence of works in or near watercourses (e.g. installation or removal of bridges or culverts), or indirectly as a result of changes in flow regime, or inputs of suspended sediments arising from ground disturbance or site drainage/ excavation dewatering works. The potential effects noted above for surface water aquatic environment receptors could also have implications for surface water resource availability. In addition, potential effects on groundwater resource receptors, both in terms of quantity (e.g. dewatering and disruption of flow pathways) and quality (e.g.
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accidental spillage of pollutants), could arise from construction activities, most notably from the construction of pylon foundations. Chemical leaching of concrete footings could also affect the quality of water resources. Potential effects on watercourse flow conveyance arising from the presence of temporary or permanent watercourse crossings. This has the potential to affect the morphology of aquatic environment receptors and to increase the risk of flooding to flood risk receptors. Potential effects on flood risk to on or off-site third party receptors as a result of changes in land cover (and thus run-off rates and volumes) and increases on ground elevations to create temporary access routes, working areas and associated topsoil stockpiles, and temporary embankments for the larger watercourse crossings, some of which will be located in the floodplain and could result in a reduction in floodplain storage volumes and/or change in floodplain flow conveyance. 13.7.17 In practice, the embedded environmental measures listed in Table 13.10 will be sufficient to ensure no significant effects will arise on water environment receptors during the construction phase. Operations 13.7.18 Once construction activities are complete, temporary access routes, working areas and watercourse crossings will be removed and affected areas reinstated to their previous condition. As a consequence, operational phase effects on the water environment are expected to be much more limited than those occurring during construction, and are unlikely to be significant. Neverthless, effects could arise either as a consequence of the presence of the infrastructure or as a consequence of operation and maintenance activities. 13.7.19 Effects arising from the presence of infrastructure could include the impedance of sub-surface flow pathways arising from disrupted drainage in the vicinity of the pylon foundations, reduced watercourse conveyance and watercourse morphology. However, any such effects would be localised in nature, and could be effectively mitigated through incorporation of appropriate design measures during construction, such as diversion of field drainage networks around pylon foundations, as discussed further in Chapter 14 within this document, and best practice design for watercourse crossings, as listed in Table 13.10. 13.7.20 Provided access is taken via existing routes, routine inspection and maintenance are not expected to give rise to significant effects on the water environment, on the grounds that there will be minimal disturbance to surface soils or watercourses. 13.7.21 However, refurbishment activities may involve the use of heavy plant and the need to construct further temporary access routes, which may include watercourse crossings. There may therefore be scope for similar effects to arise on water environment receptors as during the construction phase. However, these are likely to be more localised, and would not involve excavation works to the same degree as during construction. Given these factors, and assuming similar implementation of the construction best practice environmental measures listed in Table 13.10, no significant water environment effects are expected to arise from refurbishment activities. In conclusion, the potential for adverse effects during the operational phase have been scoped out, other than routine maintenance which would be the same as for construction but of a lesser scale.
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Decommissioning 13.7.22 Future decommissioning phase effects are likely to be similar to construction phase effects, albeit against a future baseline of potentially higher sensitivity of receptors (improvements in WFD status), and greater flood hazard as a result of climate change. There would be the requirement to construct access routes, including watercourse crossings, working areas and laydown compounds. However, the extent of excavation required would be more limited as generally only the upper 1.5m of the pylon foundations would be removed, leaving the remainder in situ. This would significantly reduce the requirement for drainage and dewatering activities, compared to the construction phase. Given this, and assuming implementation of the embedded environmental measures listed in Table 13.10, no significant water environment effects are expected to arise from decommissioning activities. Decommissioning works would require comprehensive re-assessment at the time based on best available information, and under prevailing planning regime at the time prior to commencement of works. Inter-related effects 13.7.23 Inter-related effects have been considered in this assessment, i.e. where effects in one environmental area could give rise to effects in others. The greatest potential for water envrionment effects that are inter-related with other topics is considered to be with geology, soils and agriculture, and with biodiversity. Potential effects on surface soils and agricultural underdrainage arising from construction activities, which are assessed in Chapter 14 within this document could give rise of to effects on water environment receptors which are assessed in this chapter. Conversely, effects on the water quality and hydromorphology of aquatic environment receptors as reported in this chapter could give rise to effects on specific aquatic protected habitats and species, which are considered in Chapter 9 within this document. Inter-related effects are considered in Section 13.12 of this Chapter. Cumulative effects 13.7.24 As noted above, the greatest scope for significant water environment effects arising from the Richborough Connection project is during the construction phase. As a consequence, the greatest scope for cumulative effects also arises if the construction phase of other projects that are co-located in the same catchments coincides with that of the Richborough Connection. Table 5.2 outlines those major developments which either have gained planning consent or are at the pre-application stage and which could proceed to construction in parallel with the Richborough Connection. All of these projects are located in the same surface water catchments as the Richborough Connection Order limits. Therefore, there is scope for cumulative effects to arise, although these are unlikely to be significant if the other projects adopt construction best practice measures and incorporate appropriate drainage design as required by the planning and permitting regimes. Cumulative effects are discussed in more detail in Chapter 16 of this document. Scoped out effects 13.7.25 The Scoping Report and PEIR identified a number of effects to be scoped out; desk- top studies and walkover surveys indicated that they were unlikely to be significant and therefore were not subject to further assessment. These were discussed and agreed through scoping and subsequent meetings, and restated during the consultation meeting with the EA, IDB and KCC on 13 October 2015. The issues identified to be scoped out are listed overleaf.
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Construction Potential effects on aquifer recharge (water resources receptors) through alteration of surface permeability via installation of access routes, construction compounds etc. The embedded environmental measures, which include provision for semi-permeable hardstanding surfaces with lateral drainage to promote infiltration, together with consideration of the small surface area relative to the size of aquifer recharge areas, determines that the magnitude of this potential effect is negligible and effects are not likely to be significant. Potential effects on the water environment, and particularly aquatic environment receptors as a result of direct physical disturbance of ponds. No ponds will be lost, either temporarily or permanently, and the embedded environmental measures discussed in Chapter 9 within this document, such as temporary fences to prevent trampling of bankside vegetation during construction works, ensure that a stand-off is provided that will prevent any impact from occurring. Potential effects on the water environment due to demarcation and isolation of working areas at some locations by the installation of temporary fencing. These works are scoped out of this assessment given that any associated ground disturbance will be minimal, and that this activity will have negligible potential to affect the water environment as a consequence. These activities are similar to agricultural fencing that is commonplace throughout the study area. Potential effects on the water environment associated with all scaffolding operations. Ground disturbance associated with these operations would be minimal and minimum stand-off distances from watercourses would be observed. There would be therefore be minimal interaction with the water environment from this element of the works. Potential effects on the River Stour from the use of a boat during construction. There may be some temporary and very limited requirement for use of a boat to pass an initial pilot wire across the river, ahead of stringing works; no permanent docking at the bankside would be required. Given the short time scale of this activity, the fact that the watercourse is already used for navigation, and the expectation that no disturbance of bed sediments or bank sides would result, the activity is scoped out of any further assessment. There is no proposed use of the river for construction traffic or delivery of construction materials. Potential effects on the River Stour arising from the installation of temporary emergency mooring buoys in the vicinity of sections of the River Stour that would be temporarily closed to navigation during construction. Mooring buoys have been designed to avoid impact on the watercourse and channel bed. No posts would be driven into the bed; buoys would be attached via mooring chains connected to a post driven into the bank. Temporary mooring buoys would be removed once the necessary construction works are complete. Potential effects on the River Stour arising from shading caused by the proposed temporary crossings over the River Stour. As agreed with the MMO during the consultation meeting held on 6 November 2015, based on the relatively narrow widths (single lane) of the proposed crossings, with the soffit set 4.0m above the mean high water spring (MHWS), as the sun moved throughout the day, very little, if any, of the watercourse would suffer from excessive shading.
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Potential effects on the water environment from steelwork delivery, pylon erection, construction and presence of equipotential zones, stringing and pulling operations and erection of lattice pylons following foundation installation during construction. These specific activities would have no interaction with the water environment and are scoped out of further consideration. Operations Water quality effects arising from the presence of overhead line infrastructure on aquatic environment and water resources receptors. Suitably corrosion and pH resistant concrete formulas will be utilised for pylon foundations. Concrete is often used in the environment and in areas in contact with water (e.g. bridges, culverts) without any impacts on water quality. Water quantity and hydromorphology effects arising from the presence of overhead line infrastructure. All pylons will have been located a minimum distance away from surface watercourses, and agricultural underdrainage networks will have been diverted around pylon foundations. There will therefore be negligible impact arising from the presence of the pylons on water flows, levels and watercourse morphology. Potential effects on the water environment arising from a permanent reduction in vegetation cover (in turn impacting run-off rates and quality). As discussed in the AIA (Appendix 3I, within Volume 5, Document 5.4.3I), trees would be coppiced, pollarded or pruned where possible to enable construction and operational clearances, as opposed to complete felling. Where working areas or tree condition requires complete felling, replacement planting would be provided at a ratio of 1:1 by area for wooded groups (replacing the same area lost) and 1:4 for individual trees (four trees for every one lost). Hedges will be replaced at a rate of 1:1 by length. Thus, in terms of run-off rates, the long term impact during the operational phase will be negligible. Further details, including the principles of the replacement planting are described in the AIA. Effects arising from the presence of overhead line infrastructure on flood risk receptors. The only potential operational effect of the development on flood risk would be via the displacement effect that positioning pylons in the floodplain might have on flood levels and extents. However, since the volume of water displaced by these structures would be minimal in comparison with overall flood volumes, any effect is considered to be not significant. Operational phase flood risk has therefore been scoped out of the EIA, which is an approach supported by the EA during consultation meetings235. All water environment effects associated with routine inspection and maintenance activities. These activities would result in minimal disturbance of surface soils or watercourses. Best practice measures in line with EA PPGs would be incorporated into operational procedures to ensure that the risk of accidental release of pollutants into the water environment is minimised. There would be no impact from these activities on third party flood risk receptors, although flood risk to personnel carrying out maintenance activities during the operational phase is still considered as part of the FRA (Appendix 13A within Volume 5, Document 5.4.13A).
235 Approach discussed during consultation meeting held on the 22 September 2014.
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Potential effects on the ability of SEW to deliver their planned Broad Oak Reservoir. There is anticipated to be no overlap in the construction periods of the two developments and the operational phase of the Richborough Connections project is not anticipated to have any adverse effects on the water environment. Consequently this has been scoped-out of the Cumulative Assessment. As noted in Paragraph 13.5.68, construction of the Richborough Connection project is expected to be complete before a planning application for Broad Oak Reservoir is submitted. Consequently, it is anticipated that the presence of the 400kV overhead line will form part of the baseline for the EIA for the reservoir scheme. Decommissioning 13.7.26 It is envisaged that those activites and potential effects that are scoped out of the construction phase can also be scoped out for the future decommissioning phase.
13.8 Assessment methodology
Methodology for prediction of effects 13.8.1 There is no standard assessment methodology employed for surface water EIA in the UK. Potential effects will therefore be assessed using an approach consistent with that advocated by the Institute of Environmental Management and Assessment236, as set out below.
Significance evaluation methodology 13.8.2 The assessment of effects will be carried out such that the significance of effects is evaluated as a product of the value/sensitivity of the receptor, and the magnitude of change in the relevant parameter (i.e. water quality or quantity, watercourse morphology or flood risk) arising from the proposed development, assuming relevant embedded environmental measures identified are implemented. The environmental measures incorporated into the proposed development presented in Table 13.10 are assumed to apply before the assessment of significance. Receptor sensitivity 13.8.3 Table 13.11 provides a summary of the methodology used to classify the value or sensitivity of water environment receptors that may be subject to potential effects. This is based on an assessment of a number of criteria. For aquatic environment receptors: ̶ the spatial scale and type of the receptor water feature; ̶ the WFD ecological status or potential; and ̶ the presence of international or national nature conservations designations (where designations relate specifically to water dependent habitats or interest features). For water resources receptors: ̶ utilisation of receptor for potable public or private water supply;
236 Institute of Environmental Management and Assessment, 2011: The State of Environmental Impact Assessments in the UK.
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̶ current water availability status as defined by EA catchment abstraction management strategy; and ̶ quantitative and qualitative status of WFD groundwater body. For flood risk receptors: ̶ sensitivity to flooding, principally as defined by the flood risk vulnerability classification in the Planning Practice Guidance that accompanies the NPPF (DCLG, 2012237).
Table 13.11 Summary of sensitivity (or value) of water features
Value/ Criteria Examples Sensitivity
Very High Aquatic environment Surface WFD water body at high status. receptor: feature with a very high yield, quality Conditions supporting sites with international and rarity with little conservation designations (SACs, SPAs, potential for substitution. Ramsar sites), where the designation is based specifically on aquatic features.
Water resources Surface water catchment or groundwater receptor supporting SPZ for regionally important public water human health and supplies. economic activity at a regional scale.
Flood risk receptor: land NPPF examples which include: use type defined as essential transport links; ‘Essential Infrastructure’ essential utility infrastructure (which has and ‘Highly Vulnerable’ to be located in a flood risk area for operational reasons) including power to flood risk. stations, grid and primary substations and water treatment works that need to remain operational in times of flood; police stations, ambulance stations, fire stations; basement dwellings; and permanent caravans/mobile homes.
High Aquatic environment Conditions supporting sites with national receptor: feature with a conservation designations (e.g. SSSI) where high yield, quality or the designation is based specifically on aquatic features. rarity with a limited
potential for substitution. Receptor water body: all relevant WFD supporting elements* at least good status/potential.
237 Department for Communities and Local Government. Planning Practice Guidance website, accessed 30/07/2015. http://planningguidance.planningportal.gov.uk/
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Value/ Criteria Examples Sensitivity
Water resources Surface water catchment or groundwater receptor supporting SPZ for local public water supplies. human health and Water bodies supporting licensed non public economic activity at a water supply abstractions which are large local scale. relative to available resource or where raw water quality is a critical issue, e.g. industrial process water.
Flood risk receptor: land NPPF examples which include: use type defined as hospitals; ‘More Vulnerable’ to residential institutions e.g. prisons and flood risk. hotels; dwelling houses, nightclubs, hostels; hazardous waste landfill and waste management facilities; and short-let caravan and camping sites.
Medium Aquatic environment Sites with local conservation designations receptor: feature with a where the designation is based specifically moderate yield, quality on aquatic features.
and rarity with some Receptor water body: all relevant WFD potential for substitution. elements* at least moderate status/potential.
Water resources Water bodies supporting licensed non public supporting human health water supply abstractions which small and economic activity at relative to available resource, or where raw water quality is not critical, e.g. cooling household/individual water, spray irrigation. business scale. Water bodies supporting un-licensed potable surface water abstractions, e.g. private domestic water supplies.
Flood risk receptor: land NPPF examples which include: use type defined as buildings used for shops, financial, ‘Less Vulnerable’ to professional and other services; flood risk. sewage treatment works (if adequate measures to control pollution and manage sewage during flooding events are in place); minerals working and processing; and land and buildings used for agriculture and forestry.
Low Aquatic environment Receptor water body: relevant WFD receptor: commonplace elements* at less than moderate feature with low yield or status/potential.
quality with good Small watercourses not classified as a WFD potential for substitution. river water body.
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Value/ Criteria Examples Sensitivity
Water resources do not Un-licensed non-potable abstractions, e.g. support human health, livestock supplies. and of only limited economic benefit.
Flood risk receptor: land NPPF examples which include: use type defined as flood control infrastructure; ‘Water-compatible docks, marinas and wharves; development’ or amenity open space; and undeveloped from a sewage transmission infrastructure and pumping stations flood risk point of view.
*For the purposes of this assessment, ‘relevant WFD elements’ are taken to mean: • all biological quality elements e.g. fish, invertebrates etc.; • all physico-chemical quality elements e.g. dissolved oxygen, phosphate etc.; and • hydromorphological supporting elements. The definition of ‘relevant WFD elements’ (given the lack of potential for the project to influence these substances) excludes: • Priority Hazardous Substances; • Priority Substances; and • Specific Pollutants.
Magnitude of change 13.8.4 The magnitude of change acting on water environment receptors is independent of the sensitivity of the feature. This is a largely qualitative assessment, which relies on professional judgement, although it may be informed by quantitative information and analysis where data are available and where appropriate. Table 13.12 provides examples of how various magnitudes of change will be determined with respect to water features.
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Table 13.12 Examples of water environment magnitude of change
Magnitude Criteria Examples of negative change
High Results in major Aquatic environment: deterioration in flow/ level change to feature, of regime, morphology or water quality, leading to sufficient magnitude sustained, permanent or long-term breach of to affect its environmental thresholds (e.g. relevant SSSI use/integrity. conservation objectives (COs), or WFD boundary class Environmental Quality Standard (EQS)).
Water resources: complete loss of resource or severely reduced resource availability to other water users.
Flood risk: major change in level or extent at receptor location.
Medium Results in noticeable Aquatic environment: deterioration in flow/ level change to feature, of regime, morphology or water quality, leading to sufficient magnitude periodic, short-term and reversible breaches of to affect its EQSs. use/integrity in some circumstances. Water resources: moderate reduction in resource availability and/or quality, which may compromise the ability of water users to exercise licensed rights on a temporary basis or for limited periods.
Flood risk: moderate change in level or extent at receptor location.
Low Results in minor Aquatic environment: measurable reduction in change to feature, flow/ level regime, morphology or water quality, with insufficient but with limited consequences in terms of COs or magnitude to affect water body status (i.e. no breaches of EQSs). its use/integrity in most circumstances. Water resources: minor reduction in resource availability and/or quality, but unlikely to affect the ability of water users to exercise licensed rights.
Flood risk: small, but measurable change in level or extent at receptor location.
Negligible Results in little or no Aquatic environment: no measurable deterioration change to feature, in flow/ level regime, morphology or water quality, with insufficient and no consequences in terms of COs or WFD magnitude to affect status. its use/integrity. Water resources: no measurable change in resource availability or quality and no change in ability of water users to exercise licensed rights.
Flood risk: any change to level or extent at receptor location within range of uncertainty in estimate.
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13.8.5 The significance of effects is derived by considering both the sensitivity of the feature and the magnitude of change, as summarised in Table 13.13. Effects can be ‘Beneficial’, ‘Adverse’ or ‘Neutral’.
Table 13.13 Derivation of significance of potential effects
Magnitude Sensitivity of receptor of change
Very High High Medium Low
High Significant Significant Significant Not Significant
Medium Significant Significant Not Significant Not Significant
Low Significant Not Significant Not Significant Not Significant
Negligible Not Significant Not Significant Not Significant Not Significant
13.9 Assessment of effects on aquatic environment receptors
Predicted effects and their significance Receptors 13.9.1 The baseline sensitivity of aquatic environment receptors differs depending on which phase of the proposed development is being assessed. For example, on the basis of the relatively short construction phase of the Richborough Connection project (approximately four years compared to the seven year RBMP reporting cycle for example), construction/dismantling related effects from the proposed development have been considered against the current baseline water environment. However, the future baseline for aquatic environment receptors against which operational and decommissioning effects would be assessed assumes that good status would be achieved, in line with WFD objectives, as discussed in Paragraph 13.5.69 of this Chapter. 13.9.2 Further consideration of the ecological sites identified in Table 13.8 has been undertaken in order to determine, in the context of local topography and hydrological catchments for example, whether there is any discernible direct pathway to these sites from the proposed development. Where these sites are located at distance downstream of the Order limits, it is assumed that measures to avoid significant effects at the directly affected receptor upstream of the ecological site, together with dilution effects with distance downstream are sufficient to avoid significant effects at the ecological site. For example, the nearest designated site downstream of the proposed development is the Stodmarsh SSSI/SAC/SPA/NNR/Ramsar Site (hereafter referred to as ‘Stodmarsh SSSI’). This is located 1.5km downstream on the River Great Stour, which itself is a receptor. The River Great Stour provides the pathway to Stodmarsh SSSI and therefore it follows that protection of the River Great Stour by appropriate environmental management measures, together with the dilution effects that would naturally occur with increased distance downstream from the development, will avoid the propagation of any significant effects further
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downstream. Thus, the designated sites at distance from the Order limits, summarised in Table 13.8, are not presented as receptors in their own right. 13.9.3 For the purposes of this assessment, it has been assumed that there is hydrological continuity between the River Great Stour and the various WFD lake water bodies in the reach downstream of Fordwich. The River Great Stour therefore offers a potential pathway for effects from Section A of the Order limits near Canterbury North Substation to these water bodies, as noted in Paragraph 13.7.10 of this Chapter. However, the same principle applies for these water bodies as for the downstream designated sites discussed above: the protection of the River Great Stour by implementing appropriate environmental measures as part of the proposed development together with downstream dilution effects will avoid the propagation of significant effects to the lakes water bodies and thus they are not included as receptors in their own right in this assessment. 13.9.4 The baseline characterisation confirmed that a large proportion of the study area is covered by LWSs. If LWSs were considered to be Water Environment receptors in their own right then they would (on account of their regulatory status) be assigned an equivalent or lower sensitivity than contiguous WFD water body receptors. The LWSs are predominantly concerned with water related habitat and therefore the environmental measures implemented to protect associated WFD water bodies will also mitigate any significant effects on LWSs. LWSs are therefore not considered any further in the assessment. 13.9.5 The Lower Stour Wetlands BOA was identified within the baseline characterisation as a BOA with water dependence. Preliminary consideration of the BOA in the context of the other identified receptors, indicates that the environmental measures implemented to avoid effects on other more (spatially) specific aquatic environment receptors will also mitigate any significant effects on BOAs. The proposed development will not increase the fragmentation of wildlife habitats across the BOA or neutralise significant opportunities for habitat restoration or recreation which are given (within the BOA Statement) as primary considerations to potential development. BOAs are thus not considered any further in the assessment. 13.9.6 Table 13.14 summarises the receptors taken forward in this assessment, all of which are WFD water bodies. The sensitivity of each receptor has been determined in accordance with Table 13.11.
Table 13.14 Identified potential receptors and associated value/sensitivity – aquatic environment
Receptor Sensitivity Rationale
Great Stour Medium Moderate WFD Potential; large main river between A2 and (construction watercourse with capacity to accommodate West Stourmouth phase) water quality effects (typical construction WFD water body. related water quality changes). (GB107040019743)
Great Stour High (operational/ Large main river watercourse with capacity between A2 and decommissioning to accommodate water quality effects, West Stourmouth phases) although assumed future Good WFD WFD water body. Potential. (GB107040019743)
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Receptor Sensitivity Rationale
Sarre Penn and Medium Bad WFD Potential; capacity to River Wantsum (construction accommodate water quality effects (typical WFD water body phase) construction related water quality changes). (GB107040019620)
Sarre Penn and High (operational/ Assumed future Good WFD Potential, River Wantsum decommissioning although likely to have some capacity to WFD water body phases) accommodate water quality effects. (GB107040019620)
Monkton and Medium Moderate WFD Potential; predominantly Minster Marshes (construction agricultural, level dependent ditches with WFD water body phase) large capacity to accommodate water (GB107040019621) quality effects (typical construction related water quality changes).
Monkton and High (operational/ Assumed future Good WFD Potential, albeit Minster Marshes decommissioning still likely to have some capacity to WFD water body phases) accommodate water quality effects. (GB107040019621)
Ash Level WFD Medium Moderate WFD Potential; predominantly water body (construction agricultural, level dependent ditches with (GB107040019600) phase) large capacity to accommodate water quality effects (typical construction related water quality changes).
Ash Level WFD High (operational/ Assumed future Good WFD Potential, albeit water body decommissioning still likely to have some capacity to (GB107040019600) phases) accommodate water quality effects.
Stour (Kent) WFD Medium Moderate WFD Potential; large main river, water body (construction tidally influenced watercourse with large (GB520704004700) phase) capacity to accommodate water quality effects (typical construction related water quality changes).
Stour (Kent) WFD High (operational/ Assumed future Good WFD Potential, albeit water body decommissioning still likely to have considerable capacity to (GB520704004700) phases) accommodate water quality effects.
Assessment 13.9.7 The proposed development has the potential to generate sediment-laden run-off, which could, in the absence of appropriate environmental measures and design measures, adversely affect aquatic environment (or water resources receptors). Activities that have been identified that could potentially produce sediment-laden run- off include: construction and removal of temporary access routes (including topsoil stripping) and other working areas (e.g. crane pads, temporary laydown compounds, pylon working areas and bellmouths); run-off from installed access routes, temporary laydown compounds and working areas (e.g. crane pads and pylon working areas);
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direct sediment disturbance from in-channel or riparian works (limited to culvert and bridge installations); trial pit and pylon foundation excavations (construction of 400kV foundations and dismantling of the PX route foundations) including discharge of dewatered excavation water; excavations associated with undergrounding several short sections of 11kV and 33kV cables; disturbance associated with piling activities; stockpiling of soils; and land drainage works (for example rerouting sections of existing land drains intersected by pylon locations, and installation of new complete sections of land drain where reconnection to existing drains is not possible). 13.9.8 There is potential for these sediment generating activities to affect all surface water aquatic environment and water resources receptors. 13.9.9 The determined significance of suspended sediment-related effects is considered precautionary, given that the surface watercourses across the study area will experience a large baseline variation in suspended sediment concentrations due to prevailing agricultural practices (as supported by the monitored suspended sediment concentrations reported in Section 1.2 of Appendix 13B (Document 5.4.13B) and site visit observations). The predominant arable land-use across the study area is routinely turned over during ploughing activities, harrowing etc (as evidenced at the time of the walkover survey). These baseline activities create extensive loose, bare soil surfaces on an annual basis and are likely to generate run-off characterised by very high concentrations of suspended sediments. 13.9.10 With due consideration of the existing potential for agricultural activities to generate high concentrations of suspended sediments under baseline conditions, the numerous project specific environmental measures (as set out in Table 13.10 and discussed further below) will effectively reduce the potential magnitude of change acting on the receptors listed in Table 13.14 to either Low or Negligible. 13.9.11 All EA PPGs will be followed on-site to avoid pollution, with particular emphasis being placed on adherence to PPG5, ‘Works and maintenance in or near water’ and PPG6 ‘Working at Construction and Demolition Sites’. A monitoring schedule will be implemented by the contractor to ensure that the measures taken to protect the water environment are effective. This would include daily inspections. Immediate action including, if necessary ‘stopping a job’, will be taken should any incidents or non- conformance with the CEMP (Appendix 3C within Volume 5, Document 5.4.3C) be found during inspection. 13.9.12 Where possible works within 8m (15m where navigable) of watercourse banktops will be avoided to minimise the number of Flood Defence (or Land Drainage) Consents required. An absolute minimum 3m stand-off distance from all watercourses/ waterbodies will be applied (with the exception of crossings and where existing field access routes that are already located adjacent to watercourses are to be utilised). This stand-off distance increases to 5m where ecological environmental measures are required (see the Embedded Environmental Measures Schedule in Appendix 3B within Volume 5, Document 5.4.3B).
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13.9.13 Flood Defence Consent/Land Drainage Consent will be obtained from the EA, IDB and/or KCC for all works within 8m of a Main River banktop (EA), 15m where tidal (EA), 8m for IDB watercourses (IDB) and where in-channel works are proposed between the banktops of all other watercourses238(KCC). Formal Flood Defence (or Land Drainage) Consent will include pollution prevention measures as appropriate. Applications for consent will need to demonstrate that proposals would not compromise WFD objectives. 13.9.14 Culverts will be designed to minimise in-channel disturbance of bed and banks, which could produce sediment disturbance. The specific culvert design is dependent upon the dimensions of the watercourse, for example bed width, in order to allow appropriate conveyance of flood flows. Larger watercourses (generally those ditches with a top width greater than or equal to 5m, or with a bed width greater than or equal to 3.5m), will be bridged as opposed to culverted, together with those watercourses for which in-channel works should be avoided for ecological reasons. 13.9.15 Clear span bridges will be used for those watercourses too wide or deep to be crossed using culverts, for example the two proposed crossings of the River Stour, and for crossings of larger drainage channels, including Sarre Penn, Severnscore Dike, West Monkton Stream, East Monkton Steam, Minster Stream and the River Wantsum. 13.9.16 Culvert design will be chosen to minimise in-channel disturbance of bed and banks. Installation of culverts will be made in a dry channel (isolated from the channel flow) with overpumping of water made as necessary. Overpumping requirements will be minimal in many of the IDB controlled ditches, on account of a lack of significant flow. Given the isolation of construction works, as far as reasonably practicable, from the wider watercourse, during installation of culverts, it is likely that any disturbance related suspended sediment concentrations would be within the normal range that would be expected within these lowland, agricultural ditches. 13.9.17 The bridge type to be utilised for the temporary crossings over the main River Stour (Mabey Universal type or similar), and crossings of wider IDB drainage channels, has been chosen in order to avoid in-channel disturbance. Bridge foundations would be set back from the bank edge and the bridge structure will be lifted onto the foundations, thus removing the necessity for any in-channel works. The bridge height (soffit height) will meet or exceed the height of adjacent bridges on the River Stour to ensure that navigation interests are not affected. Where (on account of an assessment of the ground surface and slope for example) it is determined that bridge foundation works (shallow excavations, plant movements etc) pose a risk of generating sediment-laden run-off, silt fencing will be installed around the works location, prior to heavy plant or excavation works. 13.9.18 Access routes and works areas (including laydown compounds and pylon working areas) will be designed to be constructed using semi-permeable aggregate, which will allow infiltration of a large proportion of rainfall and thus reduce run-off volumes (with the exception of fuel storage areas in the construction compounds, which will be underlain by low impermeable material in order to ensure that any pollution incidents associated with spillages/leakages are contained). Run-off will generally
238 Kent County Council advised during the 13/10/2015 consultation meeting that thay do not have byelaws in place (as the EA and IDB do) that requires consent for works outside of the banktop of Ordinary Watercourses outside of IDB areas. Consequently, clear span designs (banktop to banktop) that do not require works within the watercourse itself will not require land drainage consent. Land drainage consent for non-IDB Ordinary Watercourses is only required where in-channel works (i.e. between banktops) is to occur.
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not be drained via a piped or open channel drainage system, but will instead be allowed to infiltrate. Infiltration trenches will be used to promote infiltration of locally displaced run-off where required. Further measures such as silt fencing will be installed to prevent run-off from disturbed areas from reaching watercourses where appropriate. Such measures will be provided in-situ in small scale measures in preference to larger regional systems (to be assessed by the contractor during construction). 13.9.19 Dependent upon the foundation type that is chosen at each pylon location, there may be a requirement to carry out piling. From the point of view of sediment disturbance, piling works generally represent less disturbance (and generation of sediment-laden run-off) than alternative excavation-based foundation installation methods. 13.9.20 Generally, stockpiled soils will be stored adjacent to the working areas (the exception being where stockpiles are to be avoided in the floodplain). Soil stockpiles will be located at least 8m from all watercourses (15m from the Stour on account of EA access requirements) in order to reduce the likelihood of sediment-laden water entering nearby ditches and watercourses. Where stockpiles run parallel to watercourses, the stockpiles would be located on the opposite side of the access route. The surface of stockpiled soils will be smoothed with excavators to reduce potential for run-off generation. With the exception of stockpiles with a lifetime of less than 3 months, all stockpiles will be seeded to encourage stabilisation of topsoil. 13.9.21 Temporary soakaway ditches (as above) will be installed where required to capture and treat sediment-laden run-off from soil stockpiles; with ditches installed adjacent to those stockpiles that are deemed to present a potential risk of run-off to water features. Silt fences may also be installed adjacent to soil stockpiles where watercourses are in close proximity or downslope. 13.9.22 Where the contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) indicates that historical land contamination is likely, testing of the relevant material would be undertaken to to assess the risk, as discussed in sections 14.9 and 14.13 of Chapter 14 of this document, and further measures taken as appropriate. Where a risk of contamination has been identified, intrusive investigations would be undertaken and suitable measures implemented prior to construction works and soil stockpile creation commencing. Requirement 13 of the DCO would secure the implementation of suitable measures to protect controlled waters from potentially contaminative ground conditions. The installation of erosion control measures and ensuring that stockpiles are located away from watercourses, as discussed above, would further minimise the risk of contaminants arising from the excavation of contaminated land from reaching watercourses. 13.9.23 Across the predominantly low-lying Order limits, where the water table is assumed in most locations to be shallow, there is likely to be some degree of excavation required below the water table. This is likely to be the case for the construction of the foundations for the new 400kV route, and perhaps for the removal of the existing foundations of the PX route to be dismantled and any associated site investigation trial pits. Therefore it is anticipated that some degree of short-term excavation dewatering will be required. This water could contain elevated concentrations of suspended sediment. 13.9.24 Silty water will not be discharged directly to any watercourse. Site-specific measures will be developed for the appropriate discharge of this water. It is anticipated that in most instances (on account of the small volumes that will be encountered) water will
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be discharged to adjacent grassed/vegetated agricultural land, away from watercourses, as far as possible, where it will be allowed to infiltrate. 13.9.25 Where there remains the potential for this water to run-off into nearby surface water features, additional control measures will be put in place, which may include surrounding the discharge area with sediment fencing or passing the silt-laden water through a Siltbuster® or similar. Despite the temporary nature of individual discharges (assumed less than 3 months) and the measures described here (designed to prevent pollution of surface watercourses), an Environmental Permit from the EA, in relation to the discharge activity, will likely be required as a result of the LWS present across much of the Order limits. The proposed method and permitting requirements relating to dewatering discharge has been, and continues to be, consulted upon with the EA. Permitting of discharges will be addressed outside of the DCO process, as agreed with the EA during consultation meetings, most recently on 13 October 2015. 13.9.26 Details of construction phase drainage management measures will be developed by the appointed contractors after the DCO has been granted, and will be presented in a DMP. The DMP will be submitted to and approved by the relevant planning authorities.. 13.9.27 As part of the DMP, detailed drainage strategies will be prepared for each site compound (Westbere and Richborough), utilising SuDS principles for any areas requiring new drainage system. SuDS measures may include attenuation storage; infiltration trenches/soakaways. Existing drainage infrastructure is not thought to exist at either the Westbere or Richborough compound; prior to the utilisation of any existing piped drainage systems, if identified, the contractor will investigate the suitability of such systems and replace elements as necessary. Additional measures, such as oil interceptors, will be installed where required. Discharge of site drainage to Controlled Waters may be subject to Environmental Permit from the EA. Any discharge to sewer will be subject to permit from the water company and dealt with by the site contractors. 13.9.28 Any potential increases in sediment laden run-off could also result in increased silt deposition within the watercourse network affecting the hydro-geomorphology of the watercourse. Those measures described above to limit sediment laden run-off will also prevent any resultant sediment deposition and changes to watercourse morphology. 13.9.29 The proposed development has the potential to further affect water quality conditions and therefore aquatic environment receptors (and water resources receptors) within associated water features via accidental discharge of concrete or fuels, via activities including: pouring of concrete on-site, in relation to for example pylon foundations or culvert bed works; and refuelling of heavy plant. 13.9.30 Compulsory adherence to the requirements of the EA PPGs and good practice with regards pollution prevention will be delivered via the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). Particular emphasis will be placed on adherence to PPG5, ‘Works and maintenance in or near water’ and PPG6, ‘Working at Construction and Demolition Sites’. For example, all concrete pours will be contained within shuttering or dry excavations (with geotextile) and pre-cast concrete will be utilised where possible. Where use of pre-cast concrete is not possible, ready mix
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concrete will be used, as opposed to mixing occurring on-site. Suitably corrosion and pH resistant concrete formulas will be utilised for pylon foundations. Another example is provided by the fuel storage tanks at the compounds. Any fuel storage tanks within the compounds would be double-skinned/bunded. The fuel tank would be used to fill mobile bowsers, which, in turn, would be used to transport fuel around the Order limits to fuel equipment. Any re-fuelling/filling of bowsers would be carried out in accordance with the contractor’s method statement. This will likely include the use of “plant nappies” (impermeable sheets or absorbent pads) with spill kits available. Any equipment parked-up or left overnight will have a spill tray left underneath. Such adherence to the EA’s PPGs will minimise the magnitude of any change associated with the construction works. 13.9.31 The measures set out above with respect to drainage at laydown compounds will reduce the potential magnitude of any concrete or fuel spillages, particularly the installation of an oil interceptor into any piped drainage system. In addition, all oil and diesel storage facilities will be at least 10m from any watercourse and at least 50m from any borehole or well 13.9.32 Planned maintenance works of vehicles will be conducted within the designated site compounds, as per PPG guidelines, additional measures will be implemented as required (e.g. drip trays). 13.9.33 The installation of culverts and bridges within / over watercourses represents additional physical modification to surface watercourses which would make any target of introducing hydro-geomorphological diversity and achievement of corresponding WFD environmental measures more difficult. However, all WFD receptors are already classified as HMWBs and are highly channelised and altered watercourses (managed, straightened and dredged drainage ditches) with many existing culverts already in place. The presence of additional structures is not likely to represent any adverse effect, especially given the temporary nature of the structures which will be in place for less than one WFD cycle. Many of the proposed culverts will be upgrades to existing culverts and will represent an improvement to potential flow conveyance relative to the current baseline. The greatest influence on the WFD status in these ditches is not likely to be the presence of existing or proposed temporary culverts, but rather factors such as lack of flow, shallow water depths, tidal influence, nutrient inputs and sediment run-off from agriculture. As such, the magnitude of change arising from the proposed culverts, which are themselves temporary, is considered to be low. 13.9.34 Although temporary culverts will be used at the majority of locations, clear span bridges (also temporary) are proposed at numerous locations, such as the larger watercourse crossings, including the two crossings over the River Stour, Sarre Penn, Severnscore Dike, West Monkton Stream, East Monkton Steam, Minster Stream and the River Wantsum, as well as those crossings for which ecological environmental measures are proposed (such as where water voles and shining –ram’s-horn snails are present). The use of clear span bridges will minimise the magnitude of change with respect to morphological impacts. 13.9.35 The magnitude of change from all identified potential effects on aquatic environment receptors, taking account of environmental measures is either low or negligible. Consideration of the sensitivity of all aquatic environment receptors (medium to High) in combination with the potential magnitude of change acting upon them, finds that the significance of effects on aquatic environment receptors is, in all instances, not significant. As a consequence of this evaluation, it is also concluded that the
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Richborough Connection project will not result in any deterioration of WFD Status or Potential for receptor water bodies, nor will it prejudice future achievement of WFD objectives.
13.10 Assessment of effects on water resources receptors
Predicted effects and their significance Receptors 13.10.1 Water resources receptors are listed in Table 13.15. The sensitivity of these receptors has been identified in accordance with the criteria outlined in Table 13.11.
Table 13.15 Identified potential receptors and associated value/sensitivity – water resources
Receptor Sensitivity Rationale
Great Stour between Medium Not used for public water supply abstraction. Large A2 and West main river has potential to accommodate limited Stourmouth WFD changes in water quality (e.g. short-term periods of increased suspended sediment concentrations). water body No private water supplies. (GB107040019743)
Sarre Penn and Medium No licensed public water supply abstraction; some River Wantsum WFD licensed agricultural abstraction. No private water water body supplies. Predominantly within level dependent (GB107040019620) ‘green line boundary’ of the local EA abstraction strategy (new abstraction licences limited to winter period with additional conditions) i.e. taken to be indicative of being sensitive to future water resources (quantitative) change. Likely that receptor has lower sensitivity with regards water quality effects on water resources.
Monkton and Minster Medium No public water supply abstraction; some licensed Marshes WFD water agricultural abstraction. No private water supplies. body Predominantly within level dependent ‘green line (GB107040019621) boundary’ of the local EA abstraction strategy (new abstraction licences limited to winter period with additional conditions) i.e. taken to be indicative of being sensitive to future water resources (quantitative) change. Likely that receptor has lower sensitivity with regards water quality effects on water resources.
Ash Level WFD Medium No public water supply abstraction; some licensed water body agricultural abstraction. No private water supplies. (GB107040019600) Predominantly within level dependent ‘green line boundary’ of the local EA abstraction strategy (new abstraction licences limited to winter period with additional conditions) i.e. taken to be indicative of being sensitive to future water resources
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Receptor Sensitivity Rationale
(quantitative) change. Likely that receptor has lower sensitivity with regards water quality effects on water resources.
Stour (Kent) WFD Low Not used for public water supply abstraction. No water body specific strategy for the tidal stretch180. Based on (GB520704004700) upstream assessment point it is considered likely that there is potential to accommodate new abstraction volumes. Tidally influenced river with baseline water quality regime that exhibits a range of conditions and thus has potential to accommodate change (e.g. accommodate some variation in suspended sediment concentrations). No private water supplies.
East Kent Tertiaries Medium Secondary aquifer. GW water body may have WFD groundwater interactions with overlying surface waters, however body these are also (currently) at less than good status, (GB40702G501600) therefore no uplift in the groundwater sensitivity is deemed necessary.
Kent Isle of Thanet Very High Principal aquifer used for public water supply. Chalk WFD Precautionary assignment of high sensitivity, given groundwater body the licensing ‘presumption against’ new licences180 (GB40701G500100) and potential for any groundwater pollution to affect outcropping Chalk aquifer.
Assessment 13.10.2 Those scheme activities with the potential to affect water resources receptors via potential changes to the water quality of surface watercourses (potential for increases in sediment laden run-off for example), together with the design measures associated with these, are presented in the aquatic environment receptors section above. The potential for ground contamination to affect water quality is also presented in the aquatic environment receptors section above and discussed further under inter- related effects in section 13.12 of this Chapter. Other potential effects could arise as a result of changes in groundwater levels and groundwater flow pathways as a result of temporary excavation dewatering and subsurface development, and contamination of groundwater encountered in excavations. These are discussed further below. 13.10.3 Changes in groundwater levels as a result of dewatering would be highly localised and for a limited period of time. The locations in which dewatering is most likely to be required will be at those pylons located in valley floor of the Stour valley near Canterbury and in the Sarre Penn valley, and particularly throughout the Chislet and Minster Marshes and Ash Level. In the marshes and levels, the permeability of the underlying superficial deposits (within which the perched groundwater would need to be dewatered) is generally low, and it is likely that dewatering volumes will be low and impacts on groundwater levels and flow directions will be negligible. 13.10.4 The alluvium in the valley floor in the Stour valley near Canterbury and along the Sarre Penn valley is itself classified as a Secondary A aquifer, and may be in
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hydraulic continuity with the underlying East Kent Tertiaries WFD groundwater body. This, together with evidence from BGS Groundwater Flooding Susceptibility mapping, suggests that more significant dewatering volumes may be required to keep excavations dry during construction in these areas. However, given that these alluvial aquifers are limited in extent, and the temporary nature of the works, any change in groundwater levels and flows would still be highly localised and for a limited period of time. 13.10.5 In terms of the existing groundwater flow environment, the presence of extensive networks of existing land drains and field-edge drainage ditches have the effect of artificially lowering the water table across much of the Order limits. These maintain surface conditions in a relatively dry state, with the water table equating approximately to the water level in the network of adjacent ditches. Interuption of the existing land drainage network would therefore result in a localised impact on water levels. Field observations of outflow pipes suggest the depth of subsurface drains to be generally greater than 1m depth and therefore they are unlikely to be encountered during shallow excavations associated with access route construction, for example. Where subsurface drains are encountered during excavation, local measures will be put in place, as discussed further in Chapter 14 within this document, to ensure that horizontal flows are not disrupted. These measures will include local re-routing works, installation of lateral drains to allow new subsurface crossing of drain flow paths beneath access routes for example (if applicable) or reinforcement above drains to protect from crushing/collapse. 13.10.6 Changes in groundwater flows as a result of subsurface infrastructure, such as pylon foundations (including piles) and longitudinal excavations associated with the 11kV and 33kV undergrounding cable sections, which could impede flows and/or establish new preferential pathways respectively is considered to be low. Preferential groundwater pathways associated with such longitudinal excavations are unlikely to become established on account of shallow groundwater flows being dominated by the existing land drainage system, which will be supplemented by rerouting and/or installation of new land drains wherever necessary. Furthermore, only relatively short sections of underground cables are required, associated with the smaller 11kV and 33kV lines. Furthermore, trenches will be backfilled and compacted which will minimise the potential for such pathways to establish. 13.10.7 Consideration of potential changes in groundwater levels and flow pathways as a result of temporary excavation dewatering and subsurface development finds that any changes will be localised and of insufficient magnitude to affect the use or integrity of water resources receptors, and is therefore determined to be of negligible magnitude. 13.10.8 Given that groundwater is anticipated to be encountered within excavations, there is the potential to affect the water quality status of the groundwater resource, thus having an adverse effect on the water resources receptor. This will be addressed through adherence to standard working practices, such as the appropriate use of concrete within excavations (shuttering where necessary, no submerged workings and appropriate, quick drying concrete formulas used in all locations). Furthermore, suitably corrosion and pH resistant concrete formulas will be utilised for pylon foundations. Further measures will be implemented to reduce the likelihood of accidental release of polluting substances such as oil or fuel through accidental spillage or leakage, and to contain any release should it occur, as discussed in Section 13.9 of this Chapter. These measures will ensure that any potential changes
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to the water quality of groundwater receptors arising from the proposed development will not affect their use or integrity and are therefore of negligible magnitude. 13.10.9 The local authorities and the EA have been consulted regarding the presence of PWS and they have confirmed that there are no private water supplies in the vicinity of the Order limits. 13.10.10 The assessment of these potential effects takes account of the presence of the most sensitive receptor (sensitivity of very high) previously identified i.e. the Kent Isle of Thanet Chalk WFD groundwater body, even though the Chalk only outcrops over a very small area of the Order limits. Even under this most sensitive scenario of very high, because the magnitude of potential change to groundwater receptors has been identified in all instances to be negligible, the significance is assessed to be not significant.
13.11 Assessment of effects on flood risk receptors
Predicted effects and their significance Receptors 13.11.1 Table 13.16 lists the receptors taken forward in the assessment. Potential receptors have been grouped on the basis of land use vulnerability class. With particular reference to potential off-site third party receptors, property and infrastructure were identified on the basis of a GIS-based screening exercise that considered the proximity of the Order limits, their location with respect to Flood Zones and professional judgement on the potential for hydrological connectivity, as discussed in Appendix C of the FRA (Appendix 13A within Volume 5, Document 5.4.13A). The sensitivity of these receptors has been identified in accordance with the criteria outlined in Table 13.11.
Table 13.16 Identified potential receptors and associated value/sensitivity – flood risk
Receptor group Receptor Sensitivity Rationale example
Essential Infrastructure Substation Very High See individual fluvial and tidal within or on the edge of flood risk receptors* presented Flood Zone 2 or 3 within the FRA (Appendix 13A within Volume 5, Document 5.4.13A)
Highly vulnerable N/A Very High None identified in relation to development within or on this development. the edge of Flood Zone 2 or 3
More vulnerable Residential High See individual fluvial and tidal development within or on development flood risk receptors* presented the edge of Flood Zone 2 within the FRA (Appendix 13A or 3
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Receptor group Receptor Sensitivity Rationale example
within Volume 5, Document 5.4.13A)
Less vulnerable Industrial/ Medium See individual fluvial and tidal development within or on agricultural flood risk receptors* presented the edge of Flood Zone 2 area within the FRA (Appendix 13A within Volume 5, Document or 3 5.4.13A)
Water compatible Nature Low See individual fluvial and tidal development within or on Reserve flood risk receptors* presented the edge of Flood Zone 2 within the FRA (Appendix 13A within Volume 5, Document or 3 5.4.13A)
* Defined on basis of proximity to proposed development and EA flood zones and using professional judgement. For example, if a property is located in Flood Zone 1 but is very close to Flood Zone 2 or 3 and to a proposed construction access route, it has been identified as a potential receptor. However if a property is located close to an access route, stockpile or pylon, but well within Flood Zone 1 and not within a surface or groundwater flood risk area then it has not been identified as a potential receptor.
Assessment 13.11.2 The magnitude of the potential effect on flood risk receptors as described in Table 13.12 is defined in terms of change to the flood risk to the receptor arising from the development. Three potential mechanisms have been identified that have the potential to have an effect on receptors that are at risk of fluvial or tidal flooding and these are considered in turn below: loss of floodplain storage and/or change in floodplain flow conveyance ; compartmentalisation of the floodplain; and change in watercourse flow conveyance. 13.11.3 An assessment of the potential of these mechanisms to cause changes in flood risk to receptors in the vicinity of the proposed development is presented below. Further details on specific receptors for example are provided in the FRA (Appendix 13A within Volume 5, Document 5.4.13A). Loss of floodplain storage and/or change in floodplain flow conveyance 13.11.4 The development of raised structures, such as raised access routes, working areas and associated topsoil stockpiles, in the floodplain during construction works could lead to a loss of floodplain storage and/or change in floodplain flow conveyance. In order to reduce the effect, raised structures will be kept to a minimum. The construction of temporary access routes on embankments will be avoided, although their elevation will generally be slightly above surrounding ground surface (anticipated to be between 50mm and 300mm) to facilitate drainage of surface run- off, and may need to be slightly higher in some places to even out local topographic variations. The soil that is stripped back to allow construction of access routes and crane pads will be stored in embankments alongside these features. The construction of these raised features will be phased according to programme
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requirements, and they will only cover a very small portion of the total Order limits at any one time as a consequence. 13.11.5 In addition to access routes, working areas and stockpiles, embankments will also be required in the floodplain for the temporary bridges over the River Stour (to elevate the road to the height of the bridge itself, which will be raised 4m above the MHWS for navigational purposes). 13.11.6 As set out in the FRA (Appendix 13A within Volume 5, Document 5.4.13A), it has been estimated that the presence of such raised structures in the floodplain during the construction phase will result in flood water level increases in the region of centimetres. Although such an increase is small, it would represent an increase in risk where there are receptors nearby that could be impacted. For the most part, other than agricultural land, there are few receptors that could be impacted. However, where specific receptors, such as residential properties, have been identified in the FRA as potentially being at increased risk, additional environmental measures have been specified at these locations. These will be detailed and delivered through the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). 13.11.7 The additional measures are as follows: at specific locations, in the vicinity of identified receptors, no raised structures, such as raised access routes, working areas and associated topsoil stockpiles, will be located within the floodplain. Access routes and working area will be ‘at grade’ and any associated stockpiles will be located outside of the floodplain. Locations include the upper section of the Great Stour valley in Canterbury, and in the vicinity of Tile Lodge Farm and Nethergong. Trakway could be used in order to avoid both any raise and any associated stockpiles. Such environmental measures will ensure no adverse impact to third party receptors as a result of the development. Compartmentalisation of the floodplain 13.11.8 The presence of the proposed construction phase infrastructure within the floodplain (the raised structures discussed above) has the potential to compartmentalise the floodplain, or in other words affect the conveyance or movement of flood waters across the floodplain, and thus affect flood extent and depths at the local scale. 13.11.9 This effect would only occur where the flood depths are equal to or less than raised features such as access routes and soil stockpiles; once flood depths exceed the raised features water would flow over the top, reducing their impact. 13.11.10 The walkover survey of the proposed development area found that local topographical features, in particular field edge and ditch edge embankments and the network of existing agricultural tracks, are raised above the surrounding ground level to a height broadly equivalent to that of the proposed access routes and soil stockpiles. Furthermore, it was observed that the dense network of drainage ditches were likely to provide the main pathways by which floodwaters will spread across the low-lying marsh and level areas. Consequently, the additional tracks and soil storage mounds are unlikely to represent significant additional impediment to the movement of floodwater in these areas, and the specification of appropriately sized culverts at ditch crossing points will ensure that the conveyance capacity of the ditch network is maintained. Nevertheless, embedded environmental measures have been recommended (set out in Table 13.10) to further reduce the potential for this effect to, by way of ensuring that there are 20m gaps in soil stockpile embankments at no greater than 80m intervals, and through providing cross-drainage beneath raised sections of access routes. The gaps would be located at existing topographic low
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points so as to maintain existing flow paths wherever possible, and where stockpiles are located on both sides of access routes, the gaps should coincide. These measures will be detailed and delivered through the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). 13.11.11 As a consequence, in most areas of the Order limits, it is considered that there would be a negligible change in flood risk due to floodplain compartmentalisation. 13.11.12 The potential for floodplain compartmentalisation was also considered as part of the third party assessment undertaken in the FRA (Appendix 13A within Volume 5, Document 5.4.13A). As discussed above, where specific receptors, such as residential properties, have been identified as potentially being at increased risk, additional environmental measures have been specified. These measures (as set out for loss of floodplain storage) will ensure no adverse impact to third party receptors as a result of the development. Change in watercourse flow conveyance 13.11.13 If not appropriately designed, the ninety-seven new and upgraded watercourse crossings that are required for construction access have the potential to adversely affect flow conveyance within the affected watercourses and therefore to influence flood depths. 13.11.14 This is unlikely to be a significant issue for drainage ditches within the marshes and levels of the lower Stour valley, since the flat topography and the presence of numerous flow and level control structures mean that flow velocities in the drainage ditch networks are generally very low, as indicated by results from the EA’s Lower Stour modelling study. Nevertheless, new and upgraded culverts for smaller ditches will be designed to fit existing channel dimensions, and have at least the capacity of the previous ones. To minimise the risk of blockage, multiple pipes would not be used. Culverts would have concrete bedding to prevent settling of the culvert and resultant loss of flow capacity. These measures would thereby ensure that flow conveyance is maintained or enhanced relative to current conditions. 13.11.15 Clear span bridges will be used for larger drainage ditches. Locations already identified for temporary clear span bridges include crossings over the Sarre Penn, Severnscore Dike, West Monkton Stream, East Monkton Steam, Minster Stream and the Wantsum Channel. 13.11.16 As discussed in Section 13.9 of this Chapter, the two temporary crossings of the River Great Stour will also be provided by way of clear span bridges. In order to mitigate against flow conveyance effects in the river, it was necessary to set bridge soffit levels at least 600mm above the predicted 0.5% AEP combined fluvial and tidal flood level. In defining this flood level a 2070 climate change scenario allowance was allowed, which is deemed a conservative approach in this instance given that the temporary bridges will only be in place for a short period of time (anticipated to be 31 months for the temporary bridge near Minster, and 38 months for the temporary bridge near Richborough, according to the Construction Programme). For the two proposed River Stour bridge crossings this dictated minimum soffit levels of 2.98m AOD for the upstream bridge between Minster Marshes and Ash Level and 3.38m AOD for the downstream bridge at Richborough. The derivation of these minimum soffit levels are detailed in the FRA (Appendix 13A within Volume 5, Document 5.4.13A). Ultimately, however, bridge soffit levels have been determined on the basis of navigational requirements, which far exceed those required for flood risk
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conveyance, further removing any potential for adverse effects of flow conveyance in the River Stour. Soffit heights have been set at 4m above MHWS. 13.11.17 Each temporary watercourse crossing design will be subject to approval from the appropriate consenting authority, in the form of Flood Defence or Land Drainage Consents, prior to the commencement of its construction. The consenting authority is the EA for all Main Rivers; the IDB for Ordinary Watercourses within their District; and KCC for Ordinary Watercourses elsewhere (such as the upper Sarre Penn valley). 13.11.18 Direct disturbance of watercourses or deposition of sediment arising from construction activities in watercourses could also reduce flow conveyance and potentially increase flood risk. However, as noted in Section 13.9 of this Chapter, a range of construction phase embedded environmental measures have been specified in the ES to control silt-laden run-off from working areas and minimise direct channel disturbance. 13.11.19 Given the detailed consideration being given to watercourse crossing design and the implementation of embedded environmental measures to minimise effects on watercourses during construction, it is concluded that the proposed development is unlikely to increase flood risk through effects to watercourse conveyance; these measures will reduce the potential magnitude of this effect to negligible. Overall evaluation of changes to fluvial and tidal flood risk 13.11.20 The above issues and measures regarding the potential mechanisms for affecting fluvial and/ or tidal flood hazard have been considered with specific reference to the location and site-specific nature of individual flood risk receptors within presented in Appendix C of the FRA (Appendix 3C within Volume 5, Document 5.4.3C). It was concluded in the FRA that although several third party developments lie within close proximity to the Order limits, the embedded environmental measures proposed would ensure no increase in risk to any receptor. Therefore it is concluded that the tidal and fluvial flood hazard will not be increased elsewhere as a result of the development. 13.11.21 On the basis that the FRA has concluded that the flood risk to the development is acceptable, without increasing flood risk to any potential receptors elsewhere, the potential effects on fluvial and tidal flood risk receptors are determined to be not significant. Surface water 13.11.22 Potential effects on flood risk receptors associated with an increase in hardstanding areas (affecting surface water run-off rates), have been considered in the context of the EA’s surface water flood risk maps (including in the FRA included in Appendix 13A within Volume 5, Document 5.4.13A). The proposed development is not likely to increase the rate of surface run-off on the grounds of the embedded environmental measures integral to the proposed development. With the exception of existing areas of impermeable surfaces and areas used to store fuel storage tanks, which will need to be underlain by impermeable hardstanding to mitigate against the risk of leakage, all access routes and hardstanding will be designed to be semi-permeable to allow infiltration. Where practicable, access routes and working areas are to be constructed of material at least as permeable as the topsoil removed (e.g stone/crush gravel), unless temporary Trakway is utilised to minimise the loss of floodplain storage, where additional drainage will be provided, such as infiltration trenches. No formal (piped or open channel) systems would be constructed; run-off from access
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routes and working areas to be allowed to infiltrate wherever possible. For example, where an increase in surface water run-off could occur, shallow infiltration trenches could be installed parallel to temporary construction infrastructure (as discussed above with relevance to measures to address sediment laden run-off ) which will allow any run-off to be captured, treated and allowed to discharge to ground. 13.11.23 Furthermore, the measures noted above to mitigate against the risk of floodplain compartmentalisation, ensuring that there are 20m gaps in soil stockpile embankments at no greater than 80m intervals, with gaps at topographic low points and providing cross-drainage beneath raised sections of access routes, will also ensure that surface run-off pathways are not significantly disrupted by temporary construction access infrastructure. 13.11.24 Further details of construction phase drainage management measures will be developed by the appointed contractors after the DCO has been granted, and will be presented in a DMP. The DMP will be submitted to and approved by the relevant planning authority prior to commencement of construction. In addition, detailed drainage strategies will be prepared for each compound, utilising SuDS principles for any areas requiring new drainage system. Drainage from areas not served by existing drainage systems towill be designed in accordance with SuDS principles and at pre-development rates. SuDS measures may include attenuation storage; infiltration trenches/soakaways. 13.11.25 All access route and working area construction material to be removed at the end of construction/demolition and reinstated with the topsoil stockpiles (to a level slightly above natural ground level to allow for settlement). 13.11.26 Dewatering of excavations could be another source of additional ‘surface water’ from the construction works. Therefore, dewatering will cease if a Flood Alert or Flood Warning has been issued by the EA for an area downstream. 13.11.27 It is concluded that the proposed development, with the specified design and environmental measures in place, all of which will be detailed and delivered through the CEMP (Appendix 3C within Volume 5, Document 5.4.3C), will not result in increases in the rate of surface run-off and therefore all potential effects in relation to surface water flood risk would be not significant.
13.12 Conclusions of significance evaluation 13.12.1 Table 13.17 presents a summary of the assessment. All potential effects, after consideration of proposed development design and specific embedded environmental measures have been found to be not significant.
Table 13.17 Summary of significance of adverse effects for the construction phase
Receptor Magnitude Receptor Significance Summary rationale and effects of change1 sensitivity2 of effect
Aquatic Low High (most Not Potential for measurable environment sensitive) significant reduction in quality, but of and surface limited duration, within water baseline fluctuation of resource suspended sediment
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Receptor Magnitude Receptor Significance Summary rationale and effects of change1 sensitivity2 of effect
receptors: concentrations (particularly Increase in considering routine sediment agricultural ploughing laden run-off activities across much of the area) and negligible consequences in terms of WFD water body status. The implementation of the numerous embedded environmental measures summarised in Table 13.10 would ensure the low magnitude of change.
Aquatic Negligible High (most Not Adherence to EA PPGs and environment sensitive) significant construction best practice. and water All concrete pours will be resource made in exposed, receptors: dewatered (as necessary) Change in excavations i.e. no water quality submerged concrete pours. via Laydown compound accidental measures to avoid discharge of contaminated run-off, such polluting as bunded fuel storage substances tanks within areas of (concrete, impermeable hardstanding. fuel, lubricants)
Aquatic Negligible High (most Not Management measures environment sensitive) significant designed to prevent silt- receptors: laden run-off. Dry working Changes in for culvert installation morphology procedures on ditches. Use and flow of clear span bridges for conveyance larger watercourse as a result of crossings, including the increased River Stour. sediment inputs or direct watercourse disturbance
Aquatic Low High (most Not Appropriate watercourse environment sensitive) significant crossing design to be receptors: secured through EA, IDB Physical and KCC consents. Clear modification span bridges to be used on to channel River Stour crossings, and affecting on larger ditches if
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Receptor Magnitude Receptor Significance Summary rationale and effects of change1 sensitivity2 of effect
WFD hydro- appropriate. Some geomorpholo upgraded culverts will gical constitute an improvement assessment to baseline flow conveyance (HMWB potential. consideration s)
Groundwater Negligible Very High Not Construction phase resources (most significant dewatering effects receptors: sensitive temporary and localised. Change in GW Permanent changes to flow water table receptor) pathways as a result of level and pylon foundations unlikely flow because of small size of pathways as these structures. a result of Appropriate compacting subsurface backfill of cable trenches in development undergrounded sections of the 11kV and 33kV lines. Maintenance/protection of agricultural subsurface drainage pathways (land drains).
Groundwater Negligible Very High Not Adherence to EA PPGs and resources (most significant construction best practice. receptors: sensitive All concrete pours will be Potential to GW made in exposed, affect the receptor) dewatered (as necessary) quality status excavations i.e. no of submerged concrete pours. groundwater Laydown compound resource measures to avoid contaminated run-off, such as bunded fuel storage tanks within areas of impermeable hardstanding.
Tidal and Negligible Very high Not No significant reduction in fluvial flood (most significant floodplain storage or risk sensitive) conveyance as a receptors: consequence of temporary Increase in infrastructure in the flood risk due floodplain. Cross-drains in to tracks and gaps in soil construction storage bunds to maintain activities in floodplain connectivity. the floodplain Watercourse crossings designed to maintain watercourse conveyance. Clear span bridges for the two Stour crossings with
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Receptor Magnitude Receptor Significance Summary rationale and effects of change1 sensitivity2 of effect
soffits in excess of the 0.5% AEP plus climate change flood level plus freeboard.
Surface Negligible Very High Not Ground surface cover will water flood (most significant be of semi-permeable risk sensitive) aggregate to promote receptors: infiltration, with additional Increase in infiltration trenches where flood risk due required. Cross-drains in run-off from tracks and gaps in soil construction storage bunds to maintain areas overland flow pathways. Drainage Strategies will subsequently be prepared in accordance with SuDS principals for the laydown compounds, which will ensure no increase in run- off as a result of the development.
Key 1. 2. /footnotes: High Very high As defined in Table 13.13 Medium High Low Medium Negligible Low (refer to (refer Table Table 13.10) 13.12
Inter-related effects 13.12.2 Key inter-relationships exist between the freshwater, marine geological, and socio- economic environments. Specifically this covers freshwater dependent habitats and species (Chapter 9 within this document), marine dependent habitats species (Chapter 9 within this document), leaching of ground contaminants to controlled waters (Chapter 14 within this document), and navigation, recreational and commercial fisheres (Chapter 15 within this document). 13.12.3 Based on the assessment of construction, operation and decommissioning above, the potential for inter-related effects on the water environment is greatest during the construction phase. Freshwater dependent habitats and species 13.12.4 In terms of the ecology associated with watercourses, the embedded environmental measures already set out in section 13.6 of this Chapter will ensure that there will be no changes to the water quality due to sediment/chemical entrained run-off (from construction), or morphology changes, such as at the watercourse crossings, i.e. any
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changes are considered to be not significant. For example, the EA’s PPGs will be followed for works adjacent to water dependent habitats and watercourse crossings have been designed to not reduce channel conveyance. On the basis that no significant effects have been identified on the freshwater aquatic environment, no other water environment related effects (or embedded environmental measures) have been identified that could impact upon freshwater dependent habitats and species receptors; it is concluded that there will be no significant inter-related effects arising from effects on the water environment. Marine dependent habitats and species 13.12.5 With respect to marine physical processes (including water quality and ecology), any impacts were scoped out of this assessment on the basis of no significant effects on the freshwater environment which would be the pathway required from the water environment within the Order limits and the marine environment. In fact, even in the absence of the embedded environmental measures proposed to reduce, avoid or compensate for any freshwater effects, with due consideration of the very large dilution capacity of the estuary, it would be unlikely that a change in water quality in the marine environment would occur. On this basis, it is concluded that there will be no significant inter-related effects on the marine environment arising from effects on the water environment. Leaching of ground contaminants to controlled waters 13.12.6 In terms of potential geological effects, these specifically relate to the potential for contamination already present within the ground to be mobilised (to a greater extent than would occur in the absence of the development) into the water environment and affecting the aquatic environment and/or water resources of ‘controlled waters’239. 13.12.7 Given the rural nature of the vast majority of the order limits, the likelihood of encountering contamination is considered to be low in most areas, as identified in the contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A). 13.12.8 As discussed previously, the presence of embedded environmental measures to protect the aquatic environment and water resources from sediment laden run-off and spillages, such as interceptor drains, infiltration trechnes, silt fences (and ensuring that stockpiles are located an appropriate distance away from watercourses), would minimise the risk of any unidentified contaminants (not identified by the desk study and intrusive investigation and subject to additional measures) from reaching surface water bodies. 13.12.9 With respect to groundwater, given that infiltration is already possible across the vast majority of the order limits, the excavation and stockpiling of such ground should not result in a significant variation in the mobilisation potential of any contaminants that are present within excavated material; the risk to groundwater should remain unchanged. The greatest potential would be where ground previously covered with hardstanding was uncovered, such as areas where hardstanding is to be removed. 13.12.10 Where the contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) indicates that historical land contamination is likely, such as existing developed areas (including areas currectly covered in hardstanding), testing of the relevant material would be undertaken to assess the risk, as discussed in sections 14.9 and 14.13 of Chapter 14 of this document. Areas of potential contamination
239 Controlled waters are defined in Section 104 of the Water Resources Act 1991. http://www.legislation.gov.uk/ukpga/1991/57/section/104
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to be investigated are indicated in Figure 14A.1 within Volume 5, Document 5.4.14A, and include a backfilled former quarry at pylon PC2, Shelford Quarry landfill at pylon PX6, Hersden Tip landfill at pylon PX23, Westbere compound site (Hersden- Westbere landfill), the access route to pylon PC4 (Broad Oak Lodge Farm landfill), and the access route to the Richborough compound (various landfills). 13.12.11 As discussed in Chapter 14 of this document, intrusive investigation of these areas would be undertaken prior to commencement of ground works. In addition to human health receptors discussed in Chapter 14 of this document, the investigation would include an assessment of the risk to controlled waters, as discussed in the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). Suitable measures to protect controlled waters would be taken as appropriate, to be determined upon assessment of the investigation data. Necessary measures would be implemented in advance or upon commencement of ground works and soil stockpile creation as necessary. Measures that could be taken to address the risk of contaminants leaching into these controlled waters could include removal of the contaminated material off-site or the placement of an impermeable cover (sheeting) over the affected stockpiles to reduce the risk of contaminants being mobilised/leached in the first place. 13.12.12 The requirement to provide a written scheme to deal with the ground conditions that could cause significant harm to persons or pollution of controlled waters or the environment would be secured through Requirement 13 of the draft DCO (see Volume 2, Document 2.1). Requirement 13 of the draft DCO requires that no stage of the authorised development may commence until the written scheme has been submitted to and approved by the relevant planning authority, after consultation with the EA. This scheme should also include measures to protect groundwater from the mobilisation of contamination in the event that piling is required, as set out in section 14.10 of Chapter 14 of this document. On the basis of the embedded environmental measures already incorporated into the development, and the further assessment and measures to be implemented as a result of the future assessment as necessary, it is concluded that there will be no significant inter-related effects on the water environment as a result of leaching of contaminants to controlled waters. Socio-economics and recreation 13.12.13 In terms of socio-economics and recreation, the key potential interaction with respect to the water environment will be with navigation along the River Stour. As discussed previously, the two crossing points over the River Stour will both be temporary clear span bridges. These have been designed such that the soffits will be at a sufficient elevation to allow navigation to continue throughout the construction works. On the basis that no significant effects have been identified on the freshwater environment, no other water environment related effects (or embedded environmental measures) have been identified that could impact upon socio-economic and recreational receptors; it is concluded that there will be no significant inter-related effects arising from effects on the water environment.
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14. GEOLOGY, SOILS AND AGRICULTURE
14.1 Introduction 14.1.1 The proposed development has the potential to affect the geology, soils and agricultural land within the Order limits during the construction, operational and decommissioning phases. This chapter assesses these potential effects and should be read in conjunction with Chapter 3 within this document. Following a summary of the relevant policy and legislation, the current environmental baseline is defined. The environmental measures which have been incorporated into the project design are described, followed by an assessment of the significance of effects resulting from the proposed development. 14.1.2 This chapter considers the potential effects of the project on land use in general (due to a change to non-agricultural use), as well as effects on soil resources (due to the proposed works affecting the quality of the land) and agricultural drainage systems. Potential socio-economic effects associated with loss of agricultural land and disruption of agricultural activities, including farm business, are considered in Chapter 15 within this document. 14.1.3 This chapter assesses potential effects associated with land contamination, insofar as these relate to human health and ground gas. Any consequential effects of contamination on receptors outside the scope of this chapter (namely surface water, groundwater and ecosystems) are discussed as ‘inter-related’ effects in Section 14.18 of this Chapter, with reference to Chapter 9 and Chapter 13 within this document. 14.1.4 The quantification and classification of waste soils, disposal options and other information relating to waste will be determined as part of the detailed construction design. The chemical composition of soil arisings will be determined by a combination of targeted pre-construction ground investigation and construction phase compliance testing. It is anticipated that soil arisings will primarily be retained on site for re-use to backfill excavations required for the removal of the foundations of the existing 132kV PX infrastructure and for soft landscaping, as explained in the Outline Waste Management Plan (Appendix 3D within Volume 5, Document 5.4.3D). Soils will be re-used under a Materials Management Plan (MMP), which will be submitted to the Environment Agency in advance of construction commencing. Any excess soils requiring off-site disposal would generally be expected to be non-hazardous waste, due to their anticipated nature. Any soil arisings identified to be affected by contamination will be recovered or disposed of in accordance with the procedures described in Section 4.3 of the Outline Waste Management Plan (Appendix 3D) and in the CEMP Appendix 3C within Volume 5, Document 5.4.3C, including off-site disposal if necessary.
Limitations of this Environmental Statement 14.1.5 This ES has been prepared in advance of intrusive ground investigation, with the exception of very limited preliminary investigations (2 cable percussion boreholes and 5 trial pits). Further intrusive ground investigation will be undertaken prior to construction where required. The general scope of this investigation, and how it will be secured through the requirements of the DCO, are described subsequently in this chapter. This approach (i.e. intrusive investigation post-consent) has been informed by the findings of a land contamination desk study Appendix 14A within Volume 5,
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Document 5.4.14A, which concludes that, based on reasonable worst case circumstances, the potential contamination risks associated with the project range from low to moderate and that there is a high degree of confidence that any effects can be mitigated by a range of commonly adopted good practice measures, without the need for specialist or bespoke mitigation. This chapter identifies the general scope of good practice environmental measures that are likely to be adopted, and the process by which these will be delivered following confirmatory ground investigation prior to construction. 14.1.6 Full technical appraisals regarding potential ground instability effects on new project infrastructure form part of the detailed engineering design process, so are yet to be completed. The assessments in this chapter consider the likely ground conditions and the probability that effects can be mitigated/avoided by detailed engineering design using standard solutions (e.g. piled foundations), as required to ensure the constructability and operability of the proposed new infrastructure.
14.2 Policy and legislative context
Policy context 14.2.1 Chapter 4 within this document provides the overall policy context with respect to the proposed development. The relevant policies for the assessment of geology, soils and agriculture are summarised in Table 14.1. Relevant sections of the ES have been cross-referenced to the appropriate policy at Table 14.1, although reference should be made to the Planning Statement (Volume 7, Document 7.1) for the full policy assessment.
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Table 14.1 Geology, soils and agriculture policy issues considered in preparing the ES
Policy reference Policy issue
Geology
National planning EN-118 Paragraph 5.10.8 states that “for developments on previously developed land applicants should ensure that policies they have considered the risk posed by land contamination”. Paragraph 4.10.3 advises that effects should be considered on the assumption that other relevant pollution control and environmental regimes will be properly applied and enforced by the relevant regulator, and should seek to complement rather than duplicate these.
The potential land contamination effects associated with the proposed development are assessed in Sections 14.14 and 14.15 of this Chapter.
Paragraph 5.10.9 highlights the need to consider minerals safeguarding issues, stating that “applicants should safeguard any mineral resources on the proposed site as far as possible, taking into account the long-term potential of the land use after any future decommissioning has taken place”.
The potential minerals sterilisation effects associated with the proposed development are assessed in Section 14.13 of this Chapter.
Paragraph 5.3.3 states that “the applicant should ensure that the ES clearly sets out any effects on internationally, nationally and locally designated sites of [ecological or] geological conservation importance”. The potential for the proposed development to affect geological conservation receptors has been scoped out of the assessment, as described in Section 14.8 of this Chapter.
Paragraph 2.2.6 identifies the duty of transmission licence holders, in formulating proposals for new infrastructure, to have regard to the preservation of geological features of special interest and “do what [they] reasonably can to mitigate any effect which the proposals would have”.
EN-519 The potential for the proposed development to affect geological conservation receptors has been scoped out of the assessment, as described in Section 14.8 of this Chapter.
NPPF36 Section 11 of the National Planning Policy Framework (NPPF), Paragraph 109 states that the planning system should aim to protect geological conservation interests and remediate / improve land affected by
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Policy reference Policy issue
contamination and instability. “The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes, geological conservation interests and soils; preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.”
The potential land contamination effects associated with the proposed development are assessed in Sections 14.14 and 14.15 of this Chapter. The potential ground instability effects associated with the proposed development are assessed in Sections 14.10, 14.11 and 14.12 of this Chapter.
Paragraph 121 advises that planning decisions should ensure that “the site is suitable for its new use taking account of ground conditions and land instability”. Paragraphs 143 and 144 advise that Local Planning Authorities should define Minerals Safeguarding Areas MSA) and Mineral Consultation Areas (MCA), stating that they should “not normally permit other development proposals in MSAs where they might constrain potential future use for these purposes”.
The potential minerals sterilisation effects associated with the proposed development are assessed in Section 14.13 of this Chapter.
Local Planning Policy CCC Policy C40 of CCC Adopted Local Plan (2006) specifies that the City Council will impose conditions or seek Adopted agreements to ensure that mitigation measures are undertaken when assessing proposed developments Local Plan that could potentially result in pollution. This is reflected in Policy QL12 of the CCC Draft Local Plan (2014). (2006) and Policies LB6 and LB7 of CCC Draft Local Plan (2014) relate to the protection of designated geological sites. Draft Local Policy LB6 states that planning permission will not be granted where the proposals would harm SSSI, other Plan (2014) than in exceptional circumstances where detailed assessment and compensation measures are provided. Policy LB7 states that development that is likely to have an adverse impact on Regionally Important Geological Sites (RIGS) will only be permitted if the justification for the proposals clearly outweighs any harm to the intrinsic conservation and/or scientific value of the RIGS.
TDC Saved Policy EP2 of TDC Adopted Local Plan (2006) specifies the requirement for development proposals Adopted on/near landfill sites to demonstrate that risks associated with ground gas are adequately mitigated. Local Plan Saved Policy NC3 of TDC Adopted Local Plan (2006) specifies that development that would be damaging to
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Policy reference Policy issue
(2006) and nature conservation sites (including those of geological importance) will not be permitted, expect under Draft Local exceptional circumstances and with appropriate mitigation. Saved Policy NC6 states that “development Plan to which would result in the loss or obstruction of geological features of importance for study and research 2031 – purposes will not be permitted.” The requirements of these policies are reflected in Policies GI02 and SP25 Preferred of TDC Draft Local Plan to 2031 – Preferred Options Consultation. Options Policy SE02 of TDC Draft Local Plan to 2031 – Preferred Options states that, in considering planning Consultation applications on or near sites that may be affected by ground gas or land instability, the local planning (2015) authority may require specialist site investigation. It also states that, where the local planning authority is satisfied that the risks from landfill or ground instability can be overcome, planning consent may be granted subject to conditions or a legal agreement specifying the necessary measures to be carried out. Policy SE03 relates to development on sites that may be affected by contamination. It states that “in the case of sites where contamination is only considered to be a possible risk, a site investigation will be required by condition”.
DDC The Dover Core Strategy refers to National Planning Policy (PPS23, subsequently superseded by the Adopted NPPF). Dover Adopted Local Plan notes the presence of protected geological conservation sites within the Local Plan district and the general requirement to protect these, (2002) and Core Strategy (2010)
KCC (Local The policies identify the requirement for significant workable mineral resources to be protected from Plan Saved sterilisation by development. A detailed discussion of relevant minerals planning policy is provided in Policies and Appendix 14B within Volume 5, Document 5.4.14B). emerging policies within Kent Minerals and Waste Plan 2013- 30)
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Policy reference Policy issue
Soils and Agricultural Land
National planning EN-1 Para 5.10.15 requires that applicants provide a justification for developments that affect best and most policies versatile agricultural land. Poorer quality agricultural land (grades 3b, 4 and 5) require less weight with respect to site selection (except in upland areas).
Para 5.10.18 reiterates the weight that should be accorded to best and most versatile agricultural land, in the context of sustainable development, and requires applicants to define mitigation measures that would minimise impacts on soil resources.
The potential effects of the proposed development on soil resources and agricultural land have been assessed in Sections 14.16 and 14.17 of this Chapter.
EN-5 Para 2.10.8 acknowledges that there is little evidence that exposure of crops, farm animals or natural ecosystems to transmission line EMFs has any agriculturally significant consequences.
NPPF Paragraph 17 identifies the 12 principles that should underpin decision making, including the principle of seeking to direct development to brownfield sites, or where development is on agricultural land, to use poorer quality land in preference to best and most versatile (BMV) agricultural land.
The potential effects of the proposed development on soil resources and agricultural land have been assessed in Sections 14.16 and 14.17 of this Chapter.
Soil The strategy highlights the importance of the protection of soils, especially in agricultural landscapes and Strategy for during development. England240 The potential effects of the proposed development on soil resources and agricultural land have been assessed in Sections 14.16 and 14.17 of this Chapter.
Local planning CCC LP Policy EMP12 protects BMV agricultural land from permanent development. policies Policy EMP12
240 Defra. Safeguarding our Soils: A Strategy for England. 2011. (Online) Available from: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69261/pb13297-soil-strategy-090910.pdf (Accessed 30 June 2015).
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Policy reference Policy issue
TDC LP Policy protecting BMV land not saved; new plan is being prepared. Policy CCP
Thanet Policy E18 protects BMV agricultural land against irreversible loss. Preferred Option Draft Local Plan
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Legislative context Geology 14.2.2 The assessment of effects related to land quality (contamination, gas etc.) is primarily governed by the Environmental Protection Act (EPA) 1990 and the Contaminated Land (England) Regulations 2006 (as amended by The Contaminated Land (England) (Amendment) Regulations 2012). Minerals receptors fall under the remit of the Town and Country Planning Act 1990, and geo-conservation receptors under The Wildlife and Countryside Act 1981 (as amended). Soils and agriculture 14.2.3 Statutory Instrument 2015 No. 595, The Town and Country Planning (Development Management Procedure, England) Order 2015, Schedule 4, paragraph (y), stipulates that Natural England should be consulted before the grant of permission on projects that lead to the permanent loss of >20 ha of BMV agricultural land. Natural England Technical Information Note TIN049241 emphasises the need to protect BMV land through the planning system and the protection of soils that are subject to temporary disturbance as a consequence of development.
14.3 Data gathering methodology
Desk study 14.3.1 The baseline conditions in relation to geology, land quality, soils and agricultural land have been established using the data sources listed in Table 14.2.
Table 14.2 Sources of data used to establish baseline
Organisation Data supplied
Geology
British Geological 1:10,000 scale superficial and solid geology mapping. Survey Mineral resource mapping for Kent (scale 1:100,000). Historical borehole logs (available at http://www.bgs.ac.uk/geoindex/).
Kent County Council Kent Minerals and Waste Local Plan 2013-2030 Submission Document’ (July 2014), particularly mineral safeguarding maps 20 and 22. Saved policies of Kent Minerals Local Plan Adopted December 1993.
Kent & Medway Locations of Regionally Important Geological Sites. Biological Records Centre
GeoConservation Online records (http://www.geoconservationkent.org.uk/) Kent regarding features of importance / interest at Regionally Important Geological Sites.
241 Natural England. Agricultural Land Classification: Protecting the Best and Most Versatile Agricultural Land. 2012.
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Organisation Data supplied
Natural England Citation / designation records for Sites of Special Scientific Interest.
Coal Authority Digital data set of coal mining risk areas.
Environment Agency Data set of current and historical landfill locations.
Landmark Information Historical topographical mapping, Contaminated Land Group Register entries & notices, discharge consents, enforcement and prohibition notices, pollution prevention and control records (e.g. IPC, PPC, LAPPC), registered radioactive substances sites, substantiated pollution incidents register, landfill records, licensed waste management and transfer sites, prosecutions relating to authorised processes, hazardous substances sites (COMAH, NIHHS, explosive sites), fuel station entries, planning hazardous substances consents and enforcements, BGS natural geohazards data sets and BGS recorded mineral sites.
Geotechnical Draft ground investigation logs and laboratory chemical Engineering Ltd results from limited preliminary investigation undertaken in October 2015 (provided in Annex 14.1A of Appendix 14B within Volume 5, Document 5.4.14B).
Soils and Agriculture
National Soil 1:250,000 scale National Soil Map, digital dataset (NATMAPvector Resources Institute, and associated datasets). Cranfield University
Soil Survey of Bulletin No. 15, Soils and Their Use in South East England, England and Wales Harpenden 1984.
Ministry of Agricultural Land Classification of England and Wales Agriculture, Fisheries 1:250,000 scale; and Food (MAFF), Climatological Data for Agricultural Land Classification. now Defra
Survey work 14.3.2 Targeted site walkover inspections have been undertaken to inform the land contamination assessment, as discussed in Appendix 14A within Volume 5, Document 5.4.14A. 14.3.3 Preliminary intrusive investigations have been undertaken, comprising 2 cable percussion boreholes and 5 machine-dug trial pits, together with dynamic cone penetrometer testing (although this does not provide material descriptions or laboratory samples, so is of limited relevance to the assessment, with the exception being the logs from 4 hand dug service avoidance pits). Laboratory chemical analysis was undertaken on a total of 10 soil samples. General site investigation records and laboratory results certificates are provided in Annex 14.1A of Appendix 14B within Volume 5, Document 5.4.14B). Soil profile characteristics obtained from the preliminary intrusive investigation that are specifically relevant to agricultural land
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and soil resources are provided in Appendix 14C within Volume 5, Document 5.4.14C).
14.4 Environmental Impact Assessment consultation
Environmental Impact Assessment scoping 14.4.1 A Scoping Opinion for the Richborough Connection project was prepared by PINS see Appendix 1A within Volume 5, Document 5.4.1A. The SoS has consulted on the Scoping Report and the responses received relevant to Geology, Soils and Agriculture are summarised in Table 14.3. This table summarises how all consultee comments resulting as appropriate from consultations and/or the Scoping Report have been addressed in the ES.
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Table 14.3 Consultee comments and responses to EIA scoping
Consultee Comments How addressed in the ES
Geology
Public Health England PHE requested that details of The ES is informed by a land contamination desk study Appendix 14A within Volume (PHE) any hazardous contamination 5, Document 5.4.14A, which includes the identification of potential areas of be provided. They advised contamination (this appendix also makes reference to the findings of preliminary ground that public health effects investigation undertaken in 2015). The associated human health risk assessment in this should consider off-site appendix considers all relevant health receptors, including off-site receptors. In human receptors. They also accordance with DEFRA/EA good practice (e.g. CLR11242), where this has identified provided advice on methods potential source – pathway -receptor linkages (e.g. the potential for significant effects), for assessing human health further intrusive investigation will be undertaken as necessary prior to construction to risk from soil contamination. ensure that adequate mitigation will be incorporated. This will include ground gas monitoring.
The ES explains the process by which the further intrusive investigation data will be obtained and interpreted. Human health risk assessment methods will be in accordance with the advice provided by PHE. This will include the assessment of soil contamination data against the most recent UK health-based guideline values; this approach has also been adopted when considering the data from the preliminary 2015 ground investigation (Appendix 14A within Volume 5. Document 5.4.14A).
Coal Authority The Coal Authority confirmed Effect scoped out of the ES – see Section 14.8 of this Chapter. that, whilst most of the proposed development falls within the defined coalfield, it is located outside both the Development High Risk Area and any area of surface coal resources. Accordingly, they would not expect the ES to include a detailed
242 DEFRA/Environment Agency. Model procedures for the management of land contamination. 2004.
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Consultee Comments How addressed in the ES
consideration of either the potential impact of coal mining legacy on land stability or the sterilisation of coal resources.
Natural England Natural England advised that Geo-conservation receptors identified and potential effects scoped out, based on the EIA should consider the detailed justification (see Section 14.8 of this Chapter). effects on geo-conservation/ geodiversity sites, including regionally important sites.
The Planning The ES should consider any The potential effects are assessed in Section 14.12 of this Chapter. Inspectorate potential structural stability effects of piling works on existing structures (e.g. buildings and bridges).
The Secretary of State The assessment of effects from the mobilisation of contamination is based on a land recommends that sediment contamination desk study Appendix 14A within Volume 5, Document 5.4.14A, which disturbance and mobilisation identifies the potential sources of contamination, how the proposed development may of potential contamination interact with these, and the potential effects on sensitive human health receptors. The sources should be carefully potential effects on receptors outside the scope of the Geology, Soils & Agriculture assessed, in view of the assessment (e.g. surface water, groundwater and ecosystems) are discussed in sensitivity of the site and its Section 14.18 of this Chapter. surroundings. This includes the presence of a range of sensitive ecological receptors together with agricultural and residential / recreational uses.
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Consultee Comments How addressed in the ES
The Secretary of State Detailed desk study information is provided in Appendix 14A and Appendix 14B welcomes the proposed within Volume 5, Documents 5.4.14A and 5.4.14B. Whilst limited preliminary ground detailed geological desk investigation has been considered in the preparation of this ES, further more detailed study and that this will be ground investigations will be undertaken post-consent and pre-construction. The supported by walkovers and approach to this further ground investigation, including how it will be secured through intrusive ground the DCO Requirements, is described in Section 14.9 of this Chapter. The investigations in targeted assessments of effects relating to land contamination and ground stability are locations. If investigations presented on reasonable worst case assumptions, which are justified with reference to are to be delayed until post- the supporting desk study information and preliminary ground investigation findings. consent the ES should explain how these are secured through requirements in the DCO and describe the worst case scenario used in the assessment.
The Secretary of State notes Potential ground instability effects are assessed in Sections 14.10, 14.11 and 14.12 of the presence of active and this Chapter, with a focus on locations of potential Made Ground, in accordance with inactive minerals sites, the PINS advice. Minerals Safeguarding Areas and waste landfills within the Mineral sterilisation effects are assessed in Section 14.13 of this Chapter, with site boundary. The reference to Appendix 14C within Volume 5, Document 5.4.14C and consultation assessment should therefore with KCC. consider potential impacts on these receptors, for example the stability of the land to support the pylons and whether the pylons (either during site preparation, construction or operation) will blight/sterilise the current or future uses.
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Consultee Comments How addressed in the ES
Cross reference should also Section 14.18.3 of this Chapter. be made to the assessment of effects on ecology, the water environment and socio- economics.
The presence of In terms of land contamination effects, these receptors fall outside the scope of the watercourses, underdrainage assessment. Effects on the surface water environment from any site-derived and field ditches in the contamination are considered in Chapter 13 within this document. The land vicinity of the site means contamination assessment identifies potential sources of contamination that may affect there is potential for effects to these receptors, but not the effects on these receptors. Hence, it is not considered extend to a wide geographic necessary to extend the Study Area specifically due to potential contamination effects area. It is therefore important on the surface water environment. Rather, the Study Area has been defined relative to that the study area for the the receptors relevant to the Geology, Soils & Agriculture assessment, as discussed in assessment is considered Section 14.8 of this Chapter. The effects on soils and agricultural land are site carefully and justified, to specific. Disruption to agricultural drainage will be fully mitigated by embedded ensure all potentially mitigation measures as summarised in Table 14.7. significant effects are assessed.
Soils and Agriculture
Natural England Natural England has More accurate baseline ALC estimates, including Subgrades 3a and 3b obtained using requested that the potential the National Soil Map – see Table 14.2. for soil disturbance be Effects on soil resources and agricultural land are assessed in Sections 14.16 and assessed with respect to the 14.17 of this Chapter. sustainable use of land and Construction methods will include mitigation measures minimising disturbance to soil the ecosystems services that resources and ensuring that the land quality is maintained – see Table 14.7. soils provide as a natural resource. As a consequence, the assessment of soil resource should consider the potential
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Consultee Comments How addressed in the ES
impact on BMV agricultural land and the construction methods should ensure the soil resource is protected.
Planning Authorities The access routes and other Estimates of the affected areas of BMV land are included in the assessment in Section operational areas including 14.17 of this Chapter. car parks and set down areas required to construct the pylons are to be taken into account in the assessment of the potential effect on BMV agricultural land.
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Statutory Consultation 14.4.2 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed consultees and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising in newspapers, inspection of documentation at selected locations and parish and town council briefings. 14.4.3 National Grid prepared a PEIR which was publicised at this consultation stage in February 2015. National Grid sought feedback on the environmental information presented in that report. Feedback received during statutory consultation was considered by National Grid and incorporated where relevant in the design of the project and its assessment and presentation in this ES. 14.4.4 A summary of the statutory consultation representations received (relevant to EIA) and National Grid’s responses is provided in Volume 6, Document 6.1 (Consultation Report). A summary of the main statutory consultation representations received from prescribed and non-prescribed bodies in relation to the geology, soils and agriculture assessment are presented in Table 14.4.
Table 14.4 Consultee comments and responses to PEIR
Consultee Comments and How addressed in the ES considerations
CCC CCC noted that, in respect of Limited preliminary ground contaminated land, some investigation has been undertaken, intrusive work and further including investigation of ground assessment work will be conditions at Broad Oak Lodge Farm required prior to development landfill. This identified the presence of in some areas. They advised asbestos containing material in this that the results of any such location, which has been considered as work should be submitted for part of the worst case conditions used approval along with any to assess the potential human health remediation measures. The effects from contamination, in Section investigations should include 14.14 of this Chapter and in confirmation of the waste Appendix 14A within Volume 5, type associated with Broad Document 5.4.14A. Oak Lodge Farm Landfill.
CCC also advised that Further intrusive investigation to be appropriate asbestos surveys undertaken prior to construction and should be undertaken prior to delivered as a DCO requirement, as the demolition of any old discussed in Section 14.9 of this buildings and the findings Chapter. The CEMP Appendix 3C reported to them. They within Volume 5, Document 5.4.3C highlighted that asbestos describes the investigation process that should be removed from the will be undertaken, including the site by an appropriately submission of remediation measures. licensed contractor in accordance with the relevant
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Consultee Comments and How addressed in the ES considerations
legislation, and Whilst the proposed development does recommended that this not involve the demolition of any should be a condition of any buildings, the potential presence of permission. asbestos in structures will be considered in advance of any demolition works (i.e. removal of pylons and overhead lines) and asbestos surveys will be undertaken if necessary. Any surveys required will be undertaken in accordance with the Control of Asbestos Regulations, 2012 and the results reported to the relevant local planning authorities.
Persons with Access roads for construction This potential impact has been Interest in and the short and long term assessed and appropriate general Land (PILs) restriction to land will affect environmental measures are included 10671 farm management. The in the CEMP Appendix 3C within construction programme and Volume 5, Document 5.4.3C. The length of time that individual location of access routes has been fields will be unavailable for discussed and agreed with PILs. agricultural use was raised as National Grid has worked, and an issue. This point also continues to work, closely with appears to be associated landowners on whose land the with issues related to the proposed equipment will be sited to construction of the negotiate easement and compensation Richborough Connection terms where appropriate. followed by dismantling of the existing PX route.
One Potential restriction to use of The impact on farming businesses has respondent Grade 1 and Grade 2 been considered as part of the socio- (anon.) agricultural land. economic appraisal Chapter 15 within this document.
PILs 101 The PIL’s land lies in Section National Grid has worked, and D and is used for growing continues to work, closely with high value vegetable crops, landowners on whose land the particularly onions. proposed equipment will be sited to negotiate easement and compensation terms where appropriate.
PILs 101, Potential disruption/damage The effect will be readily mitigated by 10656, to underdrainage (field drainage re-routing and reinstatement 10671, 10696 drainage) resulting in as summarised Table 14.7. flooding, costly rectification, and impact on land value.
PILs 10696 PILs 10696 has reserved Mineral rights and compensation are a mines and minerals beneath financial, legal and property issue, the land subject to the rather than an environmental/EIA issue. application and they wish to National Grid has worked, and
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Consultee Comments and How addressed in the ES considerations
protect those rights going continues to work, closely with forward. They note that the landowners on whose land the 'National Land Right Strategy' proposed equipment will be sited to is being adopted by National negotiate easement and compensation Grid. They consider this to be terms where appropriate. unfair on the leasehold occupiers of the land who are not being incentivised to cooperate with National Grid proposals.
14.4.5 KCC was also consulted at this stage, in relation to minerals planning. Appendix 14B within Volume 5, Document 5.4.14B was submitted to KCC. In response to the findings of this report, KCC stated that they do not envisage an objection to the proposed development with respect to safeguarding of minerals. 14.4.6 Subsequent to publication of the PEIR, Appendix 14A within Volume 5, Document 5.4.14A was submitted in draft form to CCC, TDC and DDC. This appendix comprises a land contamination desk study report, which forms the basis of the assessments of potential effects relating to land contamination and ground gas that are presented within this chapter. The final version provided in Appendix 14A within Volume 5, Document 5.4.14A is as per the draft, with the following exceptions: It contains reference to the findings of the preliminary (October 2015) ground investigation, which were unavailable at the time of the submission of the draft. Revisions made during finalisation of the report for completeness / consistency. These do not affect the overall report conclusions. 14.4.7 Responses to the draft report have been provided by CCC and DDC, as follows: CCC stated that they are “happy with the content, conclusion and recommendations for some intrusive investigation in areas where new pylons are to be constructed, in areas of possible contamination along with possible gas protection measures to be included in the temporary structures at Westbere”. DDC stated that they understand that the report “is to form part of the ES within the EIA, and the scope of the report is to address direct land contamination and ground gas issues only, in relation to human health, agricultural land and the built environment.” Within this context, they state that they are “satisfied all potential hazards, pathways and receptors have been addressed within the report, and viewed as a PRA, demonstrates that the development is feasible in principle” and that they “do not foresee any problems with submitting the Desk Study, in its final form, as part of the DCO application, and any outstanding contamination issues, as detailed in the report, can be dealt with as part of the planning process, prior to construction”. 14.4.8 Natural England (NE) were consulted via a meeting in November 2015 on the assessment of the effects on soils and agricultural land and stated that they do not envisage an objection to the proposed development in this respect. Geological SSSI were also discussed at the meeting, with NE subsequently providing agreement that
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potential effects on geological SSSI can be scoped out of the assessment (discussed further in Section 14.8 of this Chapter).
14.5 Overall geology baseline
Current baseline Geology 14.5.1 The published superficial geology of the Order limits and surrounding area is shown on Figures 14.1a–d within Volume 5, Document 5.3.14. Superficial deposits are sporadic in Sections A and B, and absent in some locations. Where they are present, published mapping indicates that they consist primarily of Head deposits (unconsolidated clay and silt), together with alluvium following the routes of natural watercourses. Historical borehole logs available from the BGS record a Head thickness of approximately 3m (recorded as ‘clayey brickearth’) approximately 150m north of proposed pylon PC11. 14.5.2 The superficial geology recorded on published mapping to underlie the majority of Section C comprises tidal flat deposits (silt and clay), although these are less ubiquitous near the boundaries with Sections B and D, where Head deposits and areas devoid of superficial deposits are present. This includes the area to the south of Gore Street, where borehole logs available from the BGS indicate deposits recorded as topsoil and alluvium to c.1.1m depth, over ‘possible’ Head deposits of ‘loose light brown clayey fine sandy silt with occasional zones of soft grey silty clay’, to a depth of 5.5m. 14.5.3 The superficial geology recorded on published mapping to underlie the majority of Section D comprises tidal flat deposits (silt and clay), aside from small areas where superficial deposits are recorded to be absent and one small area of Head between proposed pylons PC45 and PC46. BGS borehole records are available from the easternmost part of the Order limits (shown on published mapping to be underlain by tidal flat deposits), which indicate clay and silt deposits ranging from 5.2m to 6.7m in thickness. The material includes soft/very soft grey silty clay and grey/black sand with organic content. 14.5.4 The published solid geology for the Order limits and surrounding area is shown on Figures 14.2a–d within Volume 5, Document 5.3.14. Sections A and B are predominantly underlain by deposits of the London Clay Formation, with small subcrops of Harwich Formation (sand and gravel), Lambeth Group (sand) and Thanet Formation (sand, silt and clay) in the west of Section A and the east of Section B. Borehole logs available from the BGS indicate the London Clay thickness to generally range between 10m and 23m in the vicinity of the Order limits in these Sections. 14.5.5 The solid geology recorded on published mapping to underlie the majority of Section C is the Thanet Formation, with a small area of Lambeth Group (sand) in the south east and an area underlain by the Margate Chalk Member near Sarre. The uppermost part of the Thanet Formation is recorded at 5.5m below ground level in an historical borehole log from the area to the south of Gore Street (approximately 270m north of the location of proposed pylon PC41), comprising ‘loose / compact brownish grey fine sandy clayey silt’ over ‘firm to stiff brown and greyish green very silty fine sandy clay, becoming dense clayey silty fine to medium sand’.
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14.5.6 The solid geology recorded on published mapping to underlie Section D is the Thanet Formation. BGS borehole records available from the easternmost part of the Order limits indicate the Thanet Formation to be present at c.5-7m below ground level (beneath superficial deposits) in this area, comprising grey / green sand and sandy clay. The base of the Thanet Formation was not proven in these boreholes. 14.5.7 The summary of the geology provided above is based on published mapping and historical borehole records. Consideration of borehole and trial pit records from the preliminary ground investigation undertaken in 2015 generally corroborates the published mapping, as described in Appendix 14A within Volume 5, Document 5.4.14A. The investigation included the assessment of ground conditions at Broad Oak Lodge Farm Landfill, which was recorded to consist of a 5.4m depth of Made Ground, generally comprising mixed cohesive and granular deposits containing brick, concrete, metal, wood, glass and plastic. Asbestos containing material (ACM), comprising fragments of corrugated roofing, was encountered at 2.0m below ground level within this landfill. The only other location to record Made Ground was close to the Canterbury PC Gantry location, where 0.8m of Made Ground comprising brown slightly gravelly slightly sandy silty clay was recorded, with the non-natural constituents consisting of ash gravel. Mineral Designations 14.5.8 The relevant minerals designations within the Order limits are detailed in Appendix 14B within Volume 5, Document 5.4.14B, and briefly summarised as follows: The mapped extent of the Head deposits is designated by KCC as a Mineral Safeguarding Area (MSA) for brickearth (described by the British Geological Survey as silty loams that are usually found in association with river gravels). There is also evidence of sand and gravel having been historically extracted from areas mapped as Head. Alluvium deposits within the Order limits are designated by KCC as a MSA for sub-alluvial river terrace deposits. This is because sand and gravel occurs as inferred flood plain terrace deposits associated with, and underlying, present day alluvium. No active mineral extraction sites lie within the Order limits and no licences to extract are pending at the time of preparing this ES. An ‘Area of Search’ for sand and gravel overlaps the Order limits in the area of proposed pylon PC4. KCC has advised that, in all probability, this area was never worked, and this is corroborated by a review of published historical mapping. Geological Conservation Sites 14.5.9 There are no RIGS or geologically designated SSSIs within the Order limits. Two sites were identified in general proximity of the Order limits within the Scoping Report: Chislet Colliery Tip RIGS and Sturry Pit SSSI. However, with regard to advice from PINS within the Scoping Opinion, and to ensure a comprehensive baseline description, details of all RIGS within 500m of the Order limits and SSSI of geological importance within 1km of the Order limits are provided below. The locations of the sites referred to are shown on Figures 14.2a-14.2d within Volume 5, Document 5.3.14. Chislet Colliery Tip RIGS. This site is located approximately 120m to the south of the Order limits (Section B). It contains the remnants of a colliery spoil tip on
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land that is, in part, currently used for industrial/commercial purposes. The spoil deposits contain fossilised flora and fauna, including fossilised marine worms, which are unusual within Coal Measures deposits (these normally indicate a freshwater habitat). The site is considered useful for palaeogeographical and palaeoenvironmental research. Sturry Pit SSSI. This is located approximately 450m south of the Order limits (Section A). It is designated on the basis of gravel deposits of significance for geological and archaeological research purposes, specifically deposits that are useful for correlating Pleistocene sedimentary stratigraphy. Sandwich Bay to Hacklinge Marshes SSSI. This site is located adjacent to the north of the Order limits (Section D). The SSSI is a large coastal site, primarily located around Pegwell Bay. However, a small spur of the designation comes inland, which is the part that is adjacent to the Order limits. The SSSI is designated on the combined basis of ecological and geological interest features. However, the geological interest features relate only to coastal exposures at Pegwell Bay (primarily sedimentary and palaeontological features), over 1km from the Order limits, rather than the part of the SSSI that is adjacent to the Order limits. Monkton Chalk Pit RIGS. This is located approximately 450m north of the Order limits (Section C). It comprises a disused quarry that contains ‘good chalk fossils’, together with a visible section of a geological fault and various periglacial and sedimentary interest features. Chequer’s Wood and Old Park SSSI. This site is located 800m from the Order limits (Section A). It contains geological interest features at Fordwich Pit, which contains gravel exposures with archaeological remains that are useful for correlating Pleistocene sedimentary stratigraphy. Adverse land quality, ground contamination and ground instability 14.5.10 Baseline conditions relevant to adverse land quality have been considered in accordance with the scope of the assessment defined in the Scoping Report and PEIR. The assessment of potential effects associated with ground contamination is limited to effects on human health (e.g. via exposure to soil, ground gas etc.). Ground contamination may also affect other receptors that are considered elsewhere in the ES, specifically Controlled Waters and aquatic ecosystems. Therefore, there is an area of overlap with the Water Environment assessment. To address this, potential contamination sources have been identified within this chapter, but the potential effects of the proposed development on surface water and groundwater quality are considered in Chapter 13 within this document. Therefore, the baseline conditions discussed below make reference to potential contamination sources only. 14.5.11 Similarly, the defined scope of the assessment in relation to ground instability effects is focussed on potentially abnormal ground conditions that may cause significant localised effects on the stability of buildings, infrastructure or adjacent land (e.g. deposits of landfill waste). Therefore, the baseline conditions discussed below relate specifically to such abnormal conditions. A discussion of baseline conditions in relation to natural geohazards that are outside the scope of the assessment (e.g. ground instability associated with compressible silt and clay) is provided in Appendix 14D within Volume 5, Document 5.4.14D.
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14.5.12 The EA records five historical landfills recorded within the Order limits, as shown on Figures 14.3a–d within Volume 5, Document 5.3.14. Shelford Landfill (Section A): This landfill consists of deposits used to infill a former quarry. Historically, it was licensed to accept various waste deposits, including inert waste, household waste, special waste and liquid sludge. It remains active, being currently licensed to accept household, commercial and industrial waste. Broad Oak Lodge Farm Landfill (Section A): This landfill was licensed to accept inert waste. However, as identified in Appendix 14A within Volume 5, Document 5.4.14A, asbestos containing material (ACM) has been encountered within this landfill. Henden-Westbere Landfill (Section A): This landfill consists of deposits used to infill a former quarry. It was licensed to accept inert, commercial and household waste. Hersden Tip (Section B): This landfill consists of deposits used to infill a former quarry. It was licensed to accept inert and commercial waste. Richborough Landfill Complex (Section D): There are various historical and active landfill sites within the Order limits at its easternmost end in Richborough. These are located approximately 350m south of the LoD for the proposed new 400kV infrastructure and are included within the Order limits due to the requirement to construct a new maintenance access across the landfills, which will be the only activity within their footprint. 14.5.13 There are also various landfills present in the general vicinity of the Order limits (i.e. outside the Order limits boundary), which may be of relevance when considering ground gas migration risks. Landfill records within 750m of the Order limits have been considered, with those that are of potential relevance identified as follows: Oldfield Avenue & Sturry Road Landfills: These are located approximately 400m south of the Order limits (Section A) and received various waste including household waste (both landfills) and special waste (Sturry Road only). Cliffsend Landfill: This is located approximately 670m north east of the Order limits (Section D) and received inert and household waste. 14.5.14 Whilst further landfills within 750m of the Order limits are shown on Figures 14.3a-d within Volume 5, Document 5.3.14, these were not licensed to accept materials with a high ground gas generation potential (i.e. household waste, special waste and sludge), so are not listed above. 14.5.15 Historical land use within the Order limits is generally agricultural, although various small scale industrial uses have occurred in certain locations, primarily involving quarrying. A full description of historical land use of potential contaminative significance and the type of contaminants that may be associated with the land uses identified is provided in Appendix 14A within Volume 5, Document 5.4.14A, with features of particular relevance summarised below. The locations are shown in Appendix 14A (specifically on Figures 14A.1-14A.4 within that appendix). Several backfilled former quarries are present within and adjacent to the Order limits, particularly in Section A. This includes a former quarry underlying the
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proposed location of proposed pylon PC2. In addition to soil contamination and ground gas, quarry backfill may also represent a cause of ground instability. Other historical land use within the Order limits includes an area of plantation/commercial orchards (Section A; still present), a sewage works (Section A), a recycling centre (Section A; still present), and an animal cemetery (Section C). The easternmost part of the Order limits contains part of the former Richborough power station site (Section D). Land use adjacent to the Order limits includes sewage works (Sections A and D) and a wastewater treatment works (Section D), backfilled quarries (Sections A and B), a gas pressure reducing station (Section C; still present), a tar distillery (Section A) and a ‘filter house’ (Section A). These land uses have the potential to present a source of ground gas. 14.5.16 As part of the preliminary 2015 ground investigation, laboratory chemical analysis was undertaken on 9 samples of natural materials, together with 1 sample of the Made Ground from Broad Oak Lodge Farm landfill. Sample locations, depths, borehole logs and chemical results are provided in Appendix 14A within Volume 5, Document 5.4.14A, together with an assessment of the data. The natural deposits were recorded to contain low contaminant concentrations that are assessed as not presenting a human health risk. The Made Ground also recorded low contaminant concentrations, with the primary risk associated with this material identified to be the presence of asbestos containing material. 14.5.17 Parts of the Order limits, particularly in Sections C and D, contain tidal flat deposits (clay and silt, often containing remnant organic matter) which are likely to have high standing groundwater levels. Such conditions can be conducive to the generation of methane, although typically gas flow rates and lateral migration are limited in waterlogged conditions. 14.5.18 A review of the Envirocheck data sets listed in Table 14.2 identifies the following within, or within 250m of, the Order limits: 1 prosecution relating to authorised processes, 3 registered waste treatment sites, 13 licensed waste management sites, 3 recorded pollution incidents to land and 5 discharge consents to land. Details of these items are provided and discussed in full in Appendix 14A within Volume 5, Document 5.4.14A. 14.5.19 Chislet Colliery was historically located to the east of Hersden and to the south of the Order limits. Evidence suggests that the workings of concealed Coal Measures strata extended from the colliery into the Order limits. The depth of the coal seams is well in excess of 100m and there is no potential for shallow mine workings. There are no recorded historical mine entries within, or within 20m of, the Order limits.
Future baseline 14.5.20 There are no foreseeable significant changes anticipated in relation to geology or land contamination either prior to, or during, the construction and operational phases. The future baseline in relation to land contamination would not be expected to deteriorate, as it is assumed that any future activities would be permitted/controlled in accordance with current contaminated land legislation. Similarly, the future baseline in relation to ground stability would not be expected to substantially change, as the proposed development is not in a location where ground stability is susceptible to changes in climate (i.e. no areas of peat bog, steep slopes etc.).
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14.6 Overall soils and agricultural land baseline
Baseline Soil resources 14.6.1 Terminology relating to, and details of, the methodology used to obtain the baseline are described in Appendix 14C within Volume 5, Document 5.4.14C. 14.6.2 Figures 14.4a–d within Volume 5, Document 5.3.14 present the map of soil associations within the Order limits. Their distribution is summarised in Table 14.5.
Table 14.5 Soil Associations present within the Order limits
Map code Soil association Area (ha) % Sections
814c NEWCHURCH 2 155.3 49.1 C, D
711h WICKHAM 4 55.7 17.6 A, B
841e PARK GATE 39.3 12.4 A, B
571y HAMBLE 1 27.1 8.6 A, C, D
813d FLADBURY 3 31.5 10.0 A, B
511f COOMBE 1 4.2 1.3 C
581c SONNING 2 3.2 1.0 A
Total 316.3* 100 -
Note: based on the LandIS NATMAP dataset, excludes areas classed as urban.
14.6.3 The approximate locations and properties of soil associations, and their component soil series, are summarised below. 14.6.4 The 814c Newchurch 2 association is present on the majority of the land in Sections C and D. It comprises clayey soils formed in marine alluvium, in the region they are found on the low ground separating the Isle of Thanet from the mainland. They usually occur on generally flat land, which encourages the risk of flooding in places, especially in the winter. For successful and efficient cultivation, drainage measures are needed to maximise the number of workable days. The major land use is permanent grassland with cereals and root crops grown in some drier locations. 14.6.5 The association is most commonly characterised by the Newchurch series, pelo- calcareous alluvial gley soils, which cover 60% of the association area, accompanied by the non-calcareous clayey Wallasea series, which cover a further 30% of the association, pelo-alluvial gley soils. Several other soil series can be found locally in the remaining 10% of the association area. Agricultural land quality on these soils is predominantly limited by wetness. Low lying areas may be limited by flood risk. The soils are Wetness Class III where adequate drainage measures have been installed. Combined with the climatic conditions in the area, this limits the quality of agricultural land to ALC Subgrade 3a and 3b for Newchurch and Wallasea soils, respectively.
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Newchurch series are graded higher due to calcareous clay topsoil, which compared to non-calcareous clay topsoil is generally better structured and consequently better drained and easier to cultivate. 14.6.6 The 711h Wickham 4 association within the Order limits is present largely in Section A, with a few areas in Section B. It consists of slowly permeable, seasonally waterlogged fine loamy over clayey and fine silty over clayey soils with grey and ocherous mottles throughout. The clayey soils and poor infiltration can lead to rapid runoff in some areas, especially where the soils are typically found: on gently sloping valley sides and foothills. A typical land use is grassland; however winter cereals can be grown in areas of sloping land where underdrainage has been installed. Furthermore, woodland areas are common due to the heavy texture of the soils and the resultant poor drainage. 14.6.7 Wickham soil series dominates covering approximately 60% of the association area. They are typical stagnogley soils, fine loamy or fine silty over clayey and with grey and ochreous mottles throughout. In Kent they are developed on London Clay and are mostly fine silty in their upper layers. Soils of this association are predominantly limited by wetness (Wetness Class IV, or Class III possible with drainage). The effectiveness of field drainage is not known therefore it has therefore been assumed that drains are present and in working conditions. Assuming that the topsoil is of medium silty clay loam texture (<27% clay content), in the given climatic conditions (123–133 Field Capacity Days, FCD), the land quality is limited to ALC Subgrade 3a. 14.6.8 Associated Denchworth and Windsor series, comprising 20% of the association area each, are pelo-stagnogley soils, clayey to the surface and are found where drift is very thin or absent. Due to depth to gleying of less than 40cm these soils belong to Wetness Class IV which combined with clay loam topsoil texture and climatic conditions (123–133 FCD) limits the quality of the land to ALC Subgrade 3b. 14.6.9 841e Park Gate association is present in Sections A and B between Broad Oak and Chislet Business Park. It comprises deep stoneless silty clay loam soils. They are moderately permeable and affected by seasonally high water table and are therefore often waterlogged, with grey and ocherous mottles, at depth. In Kent the association occurs as narrow strips along valley bottoms and as wider spreads on the lower slopes of the valleys. They are typically used for cereal and roots crops; land is also suitable for orchards. 14.6.10 Park Gate soils, deep stoneless silty typical argillic gleys are dominant, covering 70% of the association area. They are accompanied by Hook soils, gleyic argillic brown earths, which cover a further 20% of the association area, and a few less significant soil series which cover the remaining 10%. Park Gate soils are seasonally waterlogged (Wetness Class III or IV), Hook soils are only seasonally affected (Wetness Class II). Drainage measures can reduce the duration of waterlogging. Based on the characteristics of the soils series it is concluded that the quality of agricultural land is limited by wetness to ALC Grade 2 or 3a, where Park Gate soils occur, and is not limited or only limited to Grade 1, where Hook series are present. 14.6.11 The 571y Hamble 1 association is present within the Order limits in Section A south west of Sturry and in two small areas at the boundary between Sections C and D. It comprises deep stoneless silty loam or silty clay loam soils. These are naturally permeable and well-drained, however they are prone to slaking and capping, which can reduce infiltration and increase runoff to adjacent land. Some soils suffer waterlogging at depth. These are typical of gently sloping land, and allow the cultivation of a wide variety of crops including fruit, cereals, vegetables and salads.
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14.6.12 Main component soil series are stoneless well drained silty Hamble soils, typical argillic brown earths, which cover 30% of the association area. They are accompanied by less well drained Hook soils, gleyic argillic brown earths with grey mottling in the subsoil, which cover a further 20% of the association area, and Bursledon soils, stagnogleyic argillic brown earths with mottled slowly permeable subsoils below a thick brownish subsurface horizon, which cover 15%, and Frilsham soils, well drained fine loamy typical argillic brown earths over Chalk at moderate depth, covering 10% of the association area. 14.6.13 The 813d Fladbury 3 association is present in Section A in the area surrounding the existing Canterbury North 400kV/132kV Substation and in Section B in the north of the route between Deer Downs and Wantsum Walk. It comprises clayey alluvial soils on the floodplains. The soils in this association are slowly permeable and are often permanently waterlogged due to high levels of groundwater. Agricultural capability is generally poor, restricted to unimproved meadows, fens and mires. 14.6.14 Fladbury series, grey clayey pelo-alluvial gley soils, typically cover 65% of the association area. Fine silty Conway series, typical alluvial gley soils and similar but fine loamy Enborne soils cover 15% and 10% of the association area, respectively, with 10% covered by several other soil series of minor importance. 14.6.15 The soils of the Fladbury 3 association are limited by wetness and the risk of flooding due to their low permeability and high groundwater levels, which, even where drainage is successful, may remain high for long periods in winter (Wetness Class III or IV). Locally, where undrained, Fladbury soils stay wet into the growing season (Wetness Class V), in backswamps and other depressions, where peat or humose topsoils have formed, the soils are permanently waterlogged (Wetness Class VI). Therefore, within the Order limits Fladbury 3 association is predominantly limited by wetness and the potential risk of flooding to ALC Grade 4. 14.6.16 The 511f Coombe 1 association within the Order limits is present in one small area in Section C. It comprises generally deep, well-drained, calcareous, and silty soils. They are mainly located on flat valley floors, however thinner soils occur on gently undulating slopes with a chalk parent material. These soils in all locations will grade down into a flinty, chalky drift. Soils typically support cereal crops and grassland, with root vegetable and fruit production locally. 14.6.17 The association is dominated by the Coombe series, covering 40% of the association area, which is fine silty typical brown calcareous earth in which the brown subsoil merges downwards into thick, flinty chalky drift. The next most frequently occurring soils in this association are Panholes series, typical brown calcareous earths, covering a further 20% of the association. The other soil series which cover significant areas in Coombe 1 association are: Andover soils, brown rendzinas; Charity soils, typical argillic brown earths; and Millington soils, very similar to Coombe series, covering 10% of the association area each. The remaining 10% of the association is comprised of several other soil series. All soils in Coombe 1 association are well drained (Wetness class I) and surplus rainwater passes easily downwards through the soil and underlying chalk. They are usually slightly to moderately droughty. The properties of soils in this association generally do not pose limitation to agricultural productivity and therefore they are classed as Grade 1. 14.6.18 The 581c Sonning 2 association is present within the Order limits in one location, in Section A, in the Westbere temporary site compound. The association is characterised by reddish, well-drained, flinty coarse loamy and gravelly soils and subject to summer droughtiness. Consequently the land is often used for dairy
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farming and grassland, with widespread woodlands due to the stoniness of the soils which restricts direct-drilling of crops. 14.6.19 Sonning soils, reddish, flinty coarse loamy over gravel, typical paleo-argillic brown earths are dominant soil series and cover 40% of the association area. They are accompanied by seasonally waterlogged fine loamy or fine silty over clayey, typical stagnogley soils of Wickham series, which cover a further 20% in this association. Berkhamsted soils, developed in flinty coarse loamy over clayey drift and loamy gravelly Bockmer soils, similar to Sonning series cover 10% of the association area each. Sonning and Brockmer soils are characterised by small reserves of water and all crops suffer moderately or severely from drought in most years, which limits the quality of agricultural land to ALC Subgrade 3a. Berkhamsted soils are occasionally or seasonally waterlogged (Wetness Class II or III) due to moderately permeable clayey subsoil, which limits the quality of agricultural land to ALC Grade 2 or Subgrade 3a. Wickham soils have slowly permeable subsoils and are seasonally waterlogged (Wetness Class III), which limits the quality of agricultural land to ALC Subgrade 3a, assuming that the underdrainage has been installed where required. Agricultural land 14.6.20 Agricultural Land Classification (ALC) is a standardised method for classifying agricultural land according to its versatility, productivity and workability, based upon inter-related parameters including climate, relief, soil characteristics and drainage. These factors form the basis for classifying agricultural land into one of five grades. BMV agricultural land is classified as Grades 1, 2 and Subgrade 3a, and is afforded a degree of protection against development within planning policy. Moderate to poor quality land is designated Subgrade 3b or Grades 4 and 5, and is restricted to a narrower range of agricultural uses. 14.6.21 The provisional 1:250,000 ALC map for the south east of England Region identifies land of ALC grades 1, 2, 3 and 4 within the Order limits and is shown on Figures 14.5a–d within Volume 5, Document 5.3.14. The map does not provide distinction between Subgrade 3a and 3b and therefore to inform the assessment more precise classification based on the distribution of soil associations and percentage of component soil series was prepared, details of which are provided in Appendix 14C within Volume 5, Document 5.4.14C. Because only the proportion and not the spatial distribution of soil series within each soil association is given in the dataset, it is not possible to map the Subgrade 3a and 3b areas ALC obtained from this data. The summary ALC for the soil associations shown on Figures 14.4a–d within Volume 5, Document 5.3.14 is provided in Table 14.6.
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Table 14.6 Agricultural Land Classification distribution in soil associations
Soil association ALC within the Order limits (ha) ALC within the Order limits* (%)
1 2 3a 3b 4 1 2 3a 3b 4
NEWCHURCH 2 - - 104.0 51.2 - - - 34.2 16.8 -
WICKHAM 4 - - 33.4 22.3 - - - 11.0 7.3 -
PARK GATE 4.3 19.6 15.3 - - 1.4 6.4 5.0 - -
HAMBLE 1 19.4 6.0 - - - 6.4 2.0 - --
FLADBURY 3 - - -- 21.5 -- - - 7.1
COOMBE 1 4.2 - - - - 1.4 - - - -
SONNING 2 - 0.2 3.0 - - - 0.1 1.0 - -
Total 27.9 25.8 155.7 73.5 21.5 9.2 8.5 51.1 24.1 7.1
BMV Non-BMV BMV Non-BMV
209.4 95.0 68.8 31.2
*Of non-urban land (excludes the River Stour and land classified as urban and lake in the LandIS NATMAP dataset, as well as 0.03ha area of 573a Waterstock association in Section B, near Upstreet (land under a road).
Future baseline 14.6.22 The baseline soils and agricultural land will not change significantly as a result of natural processes and systems during the project lifetime as the time period is too short, however they have the potential to change due to other new development and there may also be a potential effect due to climate change. Climate change 14.6.23 During operation of the project, climate change may result in changes in the agricultural land quality within the route243. Land which was previously identified as BMV Grade 1 and 2 is likely to remain BMV. It can also be expected that the majority of land which is currently Subgrade 3a will remain BMV, with a small proportion downgrading to Subgrade 3b as a result of an increase in winter rainfall. However, as a consequence of changes to seasonal rainfall patterns particularly in the summer months, the amount of BMV land in the region is likely to increase. 14.7 Embedded environmental measures incorporated into the proposed development 14.7.1 The proposed development includes a range of embedded environmental measures see Appendix 3B within Volume 5, Document 5.4.3B. Those relating to Geology, Soils and Agriculture are summarised Table 14.7.
243 Keay et al, 2014. Journal of Agricultural Science. The implications of a changing climate on Agricultural Land Classification in England and Wales.
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Table 14.7 Proposed embedded environmental measures
Potential receptor Predicted changes and Incorporated measure potential effects
Construction workers Potential human health risks Use of appropriate occupational health and safety measures, e.g. Personal during the dismantling and Protective Equipment (PPE), to protect site workers from soil contamination and construction phase. any potentially hazardous construction materials (e.g. fuels, chemicals).
Those adjacent to working Potential human health risks Intrusive investigation and pre-construction risk assessments (including piling risk areas (e.g. agricultural from soil contamination. assessments) will be undertaken where necessary prior to construction, in workers, walkers etc.) and accordance with the procedure detailed in Section 3.4 of Appendix 3C within construction workers Volume 5, Document 5.4.3C. The findings will be used to inform dust control and occupational health and safety measures, together with any soil treatment or disposal requirements. Any work in locations identified to contain asbestos will be undertaken in accordance with The Control of Asbestos Regulations, 2012. Depending on specific circumstances, this may include the use of specialist protective equipment for construction workers (e.g. respiratory equipment), soil handling and storage procedures to minimise fibre release and confirmatory air monitoring. Specialist working methods will be adopted when decommissioning pylons that may overlie landfill waste (i.e. pylons PX6 and PX23), as detailed in Section 3.4 of Appendix 3C within Volume 5, Document 5.4.3C.
Construction workers and Potential human health risks Appropriate occupational health and safety measures to protect construction existing buildings within/ from ground gas during the workers, in accordance with the Confined Spaces Regulations 1997. close to the Order limits construction phase (e.g. Confirmatory ground gas monitoring during construction works that may intersect asphyxiation of construction gas sources or affect gas migration pathways, to ensure no off-site migration risk. workers due to ground gas In the very unlikely event that perimeter monitoring indicates that the works are accumulation within work causing significant gas migration, then intervention would be undertaken to trenches, or risks to users of prevent this affecting nearby buildings (e.g. installation of in-ground ventilation nearby buildings due to gas measures/gas barriers). migration and accumulation).
Land Quality Release of contamination to All use and storage of chemicals to be undertaken in accordance with EA land from construction Pollution Prevention Guideline (PGG) notes, and controlled and monitored under
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Potential receptor Predicted changes and Incorporated measure potential effects
activities (e.g. fuel spillage, the CEMP detailed requirements provided in Appendix 3C within Volume 5, re-use/importation of soils) Document 5.4.3C. Any re-use of site won soils or importation of soils will be and associated health risks to undertaken in accordance with a Materials Management Plan or Environmental construction workers and Permit, which includes demonstrating that it does not present a risk to health or future site users (e.g. on land the environment. All incoming soils (e.g. any imported material used to form temporary occupied by the access routes) will be subjected to chemical compliance testing, to ensure Project that is subsequently suitability. returned to agriculture).
Proposed new infrastructure Effects due to areas of poor The proposed 400kV route has been designed to avoid locations of potential (e.g. pylons ground stability. localised abnormal adverse ground instability as far as reasonably practicable, particularly the recorded landfills. Intrusive investigation will be undertaken where necessary prior to construction, in accordance with the procedure detailed in Section 3.4 of Appendix 3C within Volume 5, Document 5.4.3C, with the findings used to ensure that the engineering design is suitable for any localised adverse ground conditions (e.g. backfilled former quarries).
Pylons (below ground Degradation of concrete Pre-construction site investigation to include concrete classification testing. concrete) foundations due to chemically Concrete classification will be determined in accordance with relevant adverse ground conditions guidance244, to ensure that the stability of pylons is not compromised by (e.g. sulphate attack). chemically adverse ground conditions.
Soils Soil compaction and Incorporation of Defra’s best practice guidelines245 for handling and storage of degradation of structure soils within the CEMP. These guidelines recommend, inter alia: during soil handling and requirements for soil stripping, storage, reinstatement and aftercare; storage. that soil management is informed by site specific soil properties obtained from soil resource survey (carried out post-consent); preparation of Soil Management Plan contained within the CEMP Appendix 3C within Volume 5, Document 5.4.3C.
244 Building Research Establishment (BRE). Special Digest 1: Concrete in Aggressive Ground’, Building Research. 2005. 245 Defra. Construction Code of Practice for the Sustainable Use of Soils on Construction Sites, 2009.
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Potential receptor Predicted changes and Incorporated measure potential effects
Agricultural land Temporary loss and potential Restoration following dismantling of the existing 132kV overhead line, access degradation of agricultural routes, and working areas. Best practice as described above: incorporation of Soil land as a result of pylon and Management Plan into CEMP see Appendices 3B and 3C within Volume 5, access track construction. Documents 5.4.3B and 5.4.3C specifying appropriate cultivation of undisturbed agricultural land which would be excluded from use during construction.
Agricultural drainage Construction of pylons and Agricultural drainage systems across fields and into adjacent fields to be access routes may result in reinstated by bespoke design for each pylon to reroute all disturbed agricultural drainage systems underdrainage after construction. Protection of underdrainage under temporary being disrupted/severed. access roads. Construction compound surrounding underdrainage to be maintained by temporary system for the duration of the construction programme. Underdrainage within the compound area to be reinstated after construction.
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14.8 Scope of the assessment
Potential receptors 14.8.1 The receptors with the potential to be affected by the proposed development comprise: Ground stability: Pylons and other associated development e.g. access routes and cabins (during construction and operational phases). Nearby buildings and structures (construction phase only, e.g. due to ground vibration caused by piling); Land contamination (ground gas): Temporary buildings (cabins) within construction compounds, and existing built development within the Order limits and on adjacent land (e.g. farm buildings) (during construction phase). Land contamination (human health): Construction workers and users of adjacent land (construction and decommissioning phases only). Future users of land that is temporarily occupied by the proposed development during the construction phase, but subsequently returned to its original use on completion of construction (operational phase only). Minerals resources (during construction, operational and decommissioning phases); Agricultural land; Soil resources; and Agricultural drainage systems.
Spatial and temporal scope 14.8.2 The spatial scope in relation to land contamination and ground gas is primarily the Order limits, although effects relating to both off-site contamination sources and receptors will be considered in accordance with the risk assessment provided with the land contamination desk study Appendix 14A within Volume 5, Document 5.4.14A. The temporal scope of the assessment in relation to construction phase human health and ground gas effects is the duration of ground disturbance associated with construction and dismantling activities (June 2017– December 2021). The temporal scope in relation to operational phase human health effects (i.e. on future users of land that is temporarily used by the proposed development during construction, but subsequently returned to its previous use) is the infrastructure lifetime. 14.8.3 The spatial scope in relation to minerals sterilisation is the Order limits, although effects will be considered within the context of the regional extent of safeguarded minerals. The temporal scope in relation to minerals sterilisation is the infrastructure lifetime and subsequent decommissioning phase. 14.8.4 The spatial scope in relation to ground stability effects is primarily the Order limits, together with any nearby buildings or other structures that may be affected by ground instability. The temporal scope in relation to ground stability effects on new infrastructure is the infrastructure lifetime, whilst the temporal scope in relation to the
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effects of ground vibration caused by piling is the duration of the construction phase (June 2017-December 2021). 14.8.5 The spatial scope in relation to soils and agricultural land equals the Order limits as no soils and agricultural land would be disturbed outside this area as a consequence of the proposed development. 14.8.6 The temporal scope pertaining to the effects on soils and agricultural land is the duration of ground disturbance associated with construction and dismantling activities (June 2017–December 2021). The loss of agricultural land would be temporary where land is going to be restored back to agriculture, and permanent within the pylon footprint. In the latter case, the effect will persist throughout the infrastructure lifetime. The effect on soil resources (disturbance and potential loss) is relevant to the construction and the decommissioning stage.
Potentially significant effects 14.8.7 The potentially significant effects relating to the proposed development (including inter-related and cumulative effects), which are subject to further assessment in this chapter, are summarised below: potential effects on pylons and other associated development (construction and operational phases) due to poor ground stability as a result of localised areas of landfill and historical industrial land use (e.g. backfilled quarries). Where feasible, potential effects have been avoided by ensuring that the proposed new 400kV route avoids these features. However, potential effects in specific pylon locations (e.g. proposed pylon PC2 underlain by a backfilled former quarry) remain and therefore further assessment is required; potential effects of piling operations on the stability of nearby bridges and structures; potential effects on safeguarded minerals due to sterilisation (construction and operational phases). Safeguarded minerals that may be affected by the proposed development have been identified by the baseline conditions assessment and Appendix 14B within Volume 5, Document 5.4.14B; potential effects on human health (construction workers and adjacent site users) from soil contamination (construction phase only), and on future users of land that is temporarily occupied by the proposed development during the construction phase, but subsequently returned to its original use on completion of construction (operational phase only); potential effects on human health from ground gas during construction; specifically from ground gas ingress into construction compound buildings. Assessment is also required in relation to the potential risk of gas migration to existing built development, including buildings both within the Order limits and buildings on adjacent land; and potential compaction and / or damage to soil structure and permanent removal (loss) of soil during the construction phase, due to stripping, storage and replacement of topsoil and subsoil. Inter-related effects 14.8.8 There are potential inter-related effects relating to land contamination, as follows:
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leaching of soil contamination to groundwater and/or surface water. This provides a potential inter-related effect with water quality receptors that is discussed in Chapter 13 within this document; discharge of abstracted groundwater to land (e.g. water resulting from dewatering of foundation excavations), affecting its contamination status. This provides an inter-related effect with Chapter 13 within this document; and generation of dust affected by elevated contaminant concentrations, leading to adverse effects on air quality and wildlife. This provides a potential inter-related effect with receptors considered under Chapter 12 and Chapter 9 within this document. 14.8.9 There is also a potential for inter-related effects associated with minerals sterilisation, due to the potential for this to lead to socio-economics effects (e.g. reduction in minerals supply to the local construction sector), providing an inter-related effect with Chapter 15 within this document. Cumulative effects 14.8.10 The developments that have been scoped in for the assessment of cumulative effects described in Table 5.2 in Chapter 5 within this document. These have been considered in the context of potential cumulative effects on safeguarded minerals, ground stability, soil contamination, ground gas soils and agricultural land. The assessment of cumulative effects is presented in Chapter 16 within this document.
Scoped out effects 14.8.11 The Scoping Report and PEIR identified a number of effects to be scoped out, as preliminary desk-top studies indicated that they were unlikely to be significant and therefore not subject to further assessment. The issues that have been scoped out are as follows. Potential effects on ground instability due to historical coal mining (construction and operational phases). The Order limits lie within a Coal Mining Reporting Area. Evidence suggests that workings of concealed Coal Measures strata extended from the colliery into the Order limits. However, the depth of the coal seams is in excess of 100m and there is no potential for shallow mine workings to be present. Furthermore, the relevant colliery (Chislet Colliery) closed in 1969 and any associated ground movements of substance would be expected to have ceased by the late 1970s. Therefore, ground instability effects are unlikely to be significant. This conclusion accords with comments received from the Coal Authority as part of the EIA scoping process, summarised in Table 14.3. Potential damage to below ground concrete from adverse ground conditions (operational phase only). The design of below ground concrete (pylon foundations etc.) will meet the requirements of BRE Special Digest 1244 and will be determined based on site investigation findings as part of the detailed construction design process. Therefore, effects from adverse ground conditions on below ground concrete will not be significant. Paragraph 3.10 of the Scoping Opinion (Appendix 1A within Volume 5, Document 5.4.1A) states that PINS is in agreement with the scoping out of this effect. Potential effects on maintenance workers (human health) from contaminated soils (operational phase). Maintenance activities will not routinely involve ground
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disturbance. Additionally, should any ground disturbance be undertaken, maintenance workers will adopt suitable PPE. Therefore, human health effects on this receptor during the operational phase will not be significant. Paragraph 3.10 of the Scoping Opinion states that PINS is in agreement with the scoping out of this effect. Potential effects on human health from ground gas (operational phase only). The proposed development does not involve the construction of any permanent buildings or other enclosed spaces. Any potential effects on existing built development within the Order limits or off-site receptors would primarily be associated with the disturbance of gas generating soils or the introduction of new migration pathways. The cause of these effects would be construction activities and their primary effect during the construction phase. Therefore, whilst there is the potential for these effects to persist into the operational phase (at a lower level of significance), they will be assessed as a construction phase effect. Paragraph 3.10 of the Scoping Opinion states that PINS is in agreement with the scoping out of this effect. Potential ground instability effects associated with the bearing capacity of the ground (excluding specific abnormal issues such as the presence of landfill deposits). Paragraph 3.10 of the Scoping Opinion states that PINS is in agreement with the scoping out of this effect. Common naturally occurring geohazards that affect the bearing capacity of the ground, such as the presence of soft compressible ground, are therefore not considered in this chapter. Such hazards are common in various parts of the UK and managing and preventing them is a routine engineering consideration that does not require detailed assessment within the ES. Nevertheless, these are a relevant construction consideration in certain parts of the Order limits. Therefore, to demonstrate that these routine issues will not significantly affect the constructability of the proposed development or adversely affect surrounding land, Appendix 14D within Volume 5, Document 5.4.14D provides a discussion of the likely occurrence of these hazards within the Order limits, the nature of the hazards, and how routine engineering design measures will allow for safe construction that will not be adversely affected by these hazards. The measures described fall within the scope of engineering design defined in the project description in Chapter 3 of this document and the measures defined in Appendix 3C in Volume 5, Document 5.4.3C. Potential effects on Chislet Colliery RIGS (construction and operational phases). Based on the Scoping Opinion, detailed additional justification has been provided in relation to geological conservation receptors, in Paragraphs 14.8.12 to 14.8.18 of this Chapter.
Potential effects on Sturry Pit SSSI (construction and operational phases). Based on the Scoping Opinion, detailed additional justification has been provided in relation to geological conservation receptors, in Paragraphs 14.8.12 to 14.8.18 of this Chapter. The permanent loss of BMV agricultural land amounts to 1.08ha (0.56ha if land released from dismantling of the 132kV PX route is taken into account), based on the footprint of the proposed 400kV route and existing 132kV PY route permanent diversion pylons shown in Figure 14.4 within Volume 5, Document 5.3.14; summary of land take areas is presented in Table 14.12.
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BMV land temporarily excluded from agricultural production for access routes and working areas would be restored following the construction period. Based on the above the loss of BMV agricultural land has been scoped out of the assessment. The dismantling of the 132kV PX route will increase the area of agricultural land in the locality, as the area within the footprint of many of these pylon bases will be returned to agricultural use consistent with the remainder of the fields within which they are situated. As a consequence, it is considered that as land underneath the pylons that has not been available for agricultural uses will be restored and managed such that agricultural uses can be returned, the effects are beneficial. Potential disruption to agricultural drainage systems due to removal, blocking or severance of field drains and open drainage ditches have been scoped out as it can be fully mitigated by embedded environmental measures see Table 14.7. Geological conservation receptors 14.8.12 There are no designated sites within the Order limits, so no potential for the development to have direct effects on geological conservation receptors. Based on the Scoping Opinion, the potential for the proposed development to have indirect effects on any RIGS within 500m of the Order limits and SSSI with geological interest features within 1km of the Order limits has been considered in detail. There are five such sites: Chislet Colliery Tip RIGS, Sturry Pit SSSI, Sandwich Bay to Hacklinge Marshes SSSI, Monkton Chalk Pit RIGS, and Chequer’s Wood & Old Park SSSI. The locations of these sites are shown on Figures 14.2a-14.2d within Volume 5, Document 5.3.14. The means by which these sites could theoretically be indirectly affected by proposed overhead line construction and dismantling are as follows: (i) destabilisation of the ground by construction works, causing damage to / collapse of slopes / quarry faces / exposures containing geological interest features, (ii) deposition of construction dust obscuring the features of scientific interest, (iii) loss of access to the site, and (iv) changes in water levels (e.g. rises in groundwater levels obscuring geological interest features within a disused quarry). 14.8.13 Although at its closest point Chislet Colliery RIGS is located 120m from the Order limits, this is due to the presence of proposed access routes (minimal ground disturbance). The RIGS is 500m from the location of the nearest 132 kV infrastructure to be dismantled and 900m from the LoD for the proposed new 400 kV infrastructure. The installation and removal of pylons has no potential to have any ground instability effects that could feasibly affect the receptor over the distances involved. The deposition of construction dust does not have the potential to obscure or affect the geological interest features at the site. This would require large scale dust generation, which would be very unlikely to occur in association with works of the nature of the proposed development, and would clearly be prevented for other reasons (e.g. air quality, nuisance etc.) in any case. The RIGS is located to the south of the A28, whilst the Order limits is located to the north of this road, such that the proposed development will not affect access. The intervening ground conditions between the locations of ground disturbance associated with the proposed development and the RIGS comprise London Clay (low permeability). The limited shallow hydraulic continuity associated with this geological setting prevents the potential for the RIGS to be affected by changes in groundwater levels.
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14.8.14 Sturry Pit SSSI is located approximately 450m from the Order limits and 800m from the Limits of Deviation for the proposed new 400 kV infrastructure. It contains exposures and deposits of Pleistocene gravels. Destabilisation of the ground by construction works leading to damage / collapse of the gravel pit faces is not feasible over the distances involved. The nature of the SSSI does not place it at potential risk from dust deposition from the proposed development (e.g. the SSSI designation does not relate to the presence of hard to distinguish fossils that could easily be obscured by dust). More importantly, as with Chislet Colliery Tip RIGS, effective dust controls will be required to manage other environmental aspects of the project (e.g. air quality and human health), which would negate any potential for dust deposition at levels that could obscure the geological interest features over the distances involved. Access to the site, which is within a residential area, will not be prevented by the proposed development. There is potential hydraulic continuity between the SSSI and permeable deposits of Lambeth Group and Harwich Formation strata near Canterbury that are crossed by the Order limits (approximately 800m from the SSSI). However, any dewatering associated with the proposed development activities would be restricted to limited quantities of groundwater from shallow excavations, such that there is no potential for regional changes in groundwater levels that could affect the geological features of the SSSI over the distances concerned. Additionally, any effects associated with the discharge of water arising from the works (e.g. groundwater removed from shallow excavations) will be permitted under the discharge consent regime. 14.8.15 Sandwich Bay to Hacklinge Marshes SSSI is located adjacent to the Order limits. However, this is a large SSSI that is designated on the basis of both ecological and geological interest features. It is the ecological, rather than geological, features of interest that adjoin the site. The geological features of scientific interest are coastal exposures at Pegwell Bay, over 1km from the Order limits. There is no potential for the proposed development to indirectly affect the stability, quality or accessibility of these exposures over this distance. 14.8.16 Monkton Chalk Pit RIGS is located approximately 450m from the Order limits. However, this is due to the requirement to use an existing track for maintenance access, which involves minimal ground disturbance and has no potential to cause indirect effects on the RIGS. There are no proposed 132kV dismantling works or 400kV construction works within 1km of this RIGS and no potential for the proposed development to indirectly affect the stability, quality or accessibility of the geological interest features at this site. 14.8.17 Chequer’s Wood and Old Park SSSI is located approximately 800m from the Order limits and approximately 950m from the nearest proposed pylon dismantling or construction works. The geological features of interest at this site are similar to those at Sturry Pit SSSI (Pleistocene gravel exposures within a disused quarry / pit), with the primary difference being that this site is further from the Order limits than Sturry Pit. Therefore, for the same reasons as Sturry Pit SSSI, there is no potential for the proposed development to affect the geological interest features at this site via ground instability, dust deposition or changes in groundwater levels. Chequer’s Wood and Old Park SSSI is located to the south of the A28 and access will not be affected by the proposed development. 14.8.18 On the basis of the expanded scoping rationale provided above, it is concluded that the proposed development does not have the potential to feasibly cause indirect effects on geological conservation sites. Accordingly, potential effects on geo-
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conservation receptors have been scoped out of the assessment and are not considered further. NE has provided agreement to this scoping decision, in relation to receptors within their jurisdiction (i.e. SSSI).
14.9 Assessment methodology
Methodology for prediction of effects 14.9.1 The prediction of effects will be achieved by assessing the significance of each potential effect. The assessment has been undertaken using the evaluation methodology detailed below. 14.9.2 For soils and agriculture, the assessment methodology considers the following: the potential effect on BMV agricultural land (land take) during the construction phase (should the area of disturbance be greater than 20ha, in total); and the potential effect on soil resources during the construction period, which can in turn compromise the quality of restored agricultural land. 14.9.3 The assessment of potential effects relating to soil contamination (human health and ground gas) is based on the legislation listed at the start of this chapter, together with accompanying guidance regarding the implementation of this legislation. In particular, the assessment has been undertaken using the approach recommended in CLR11242 and CIRIA 552246. The underlying principle behind this approach is the assessment of risks by the identification of any viable potential source-pathway- receptor linkages. Once any such linkages have been identified, then the significance of any associated effects can be determined as a function of the receptor sensitivity and the magnitude of the potential effect for each identified potential source-pathway-receptor linkage. In addition to these factors, CIRIA 552 also recommends that the likelihood of an effect occurring should be considered when undertaking land contamination risk assessments. This factor has been incorporated into the assessment methodology as follows: Receptor sensitivity classifications reflect the probability of an effect occurring i.e. where the nature of a receptor makes it more likely to be affected by contamination, the sensitivity classification is higher. The magnitude of effect classifications are based on the conservative assumption that any identified potential effects will occur (based on reasonable worst case conditions). Only where there is no significant risk of significant harm to human health is the magnitude of effect assessed as negligible. The assessment is supported by the land contamination desk study provided in Appendix 14A within Volume 5, Document 5.4.14A. This identifies all of the potential source-pathway-receptor linkages associated with the proposed development and assigns a level of risk to these, which reflects (amongst other things), the likelihood of an effect occurring. 14.9.4 There is no equivalent published methodology that relates to mineral sterilisation or localised areas of poor ground stability. For consistency, a similar approach has
246 CIRIA. CIRIA 552 “Contaminated Land Risk Assessment: A Guide to Good Practice”. 2001.
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been adopted to assess these effects (i.e. combination of receptor sensitivity and magnitude of potential effects). 14.9.5 For agricultural land, the guideline criteria for determining the magnitude of change from the baseline (pre-development) condition are based on a threshold of the loss of 20ha of the BMV agricultural land, which is taken from Natural England Technical Information Note TIN049 and referenced in the NPPF. In the absence of specific and documented guidance relating to the determination of the magnitude of change from baseline conditions in relation to the soil resources, other criteria are based on professional experience. The stated criteria have been adopted in previous assessments that have been agreed and accepted as best practice, and are based upon permanent/irreversible changes and long-term/short-term/temporary changes to the soil resources arising as a result of development. 14.9.6 The assessment criteria for receptor sensitivity and magnitude of effect are provided in Table 14.8 and Table 14.9.
Table 14.8 Receptor sensitivity criteria for geological receptors
Receptor Criteria sensitivity
Geology Soils and agriculture
High Human health, where receptor characteristics BMV soils and agricultural promote the likelihood of a significant land (ALC Grades 1, 2 contaminant linkage (e.g. due to high levels and Subgrade 3a). of exposure to soil/dust and/or prolonged exposure). For example, children using residential gardens or public recreation areas, construction workers routinely exposed to soils. Infrastructure of national strategic/ economic significance. Geological deposits of key national or regional economic importance or of national statutory scientific designation (e.g. SSSI). Geological deposits under ongoing extraction or with license to extract pending.
Medium Human health, where receptor characteristics Moderate quality soils and provide limited potential for a significant agricultural land (ALC contaminant linkage. For example, workers in Subgrade 3b). commercial premises. Infrastructure of key regional amenity/ economic importance. Built environment (e.g. existing buildings, bridges or structures). Geological deposits of local economic importance or of locally designated scientific significance e.g. RIGS. Geological deposits with a significant/ recognised potential for future extraction.
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Receptor Criteria sensitivity
Geology Soils and agriculture
Low Human health or built environment receptors, Lower quality soils and where receptor characteristics significantly agricultural land (ALC minimise the likelihood of a significant Grade 4 and lower), soils contaminant linkage or effect. For example, within urban environment. users of car parks. Infrastructure of local/private amenity/ economic importance. Geological deposits of negligible economic importance, with no significant potential for future extraction.
Table 14.9 Criteria for magnitude of effect for geological receptors
Magnitude Criteria of effect
Geology Soils and agriculture
Major Land contamination or ground gas that Area of BMV agriculture results in a short term (acute) risk to human permanently lost >20 ha. health. Examples include soil displaying highly elevated cyanide concentrations. Soil resources Immediate/catastrophic damage to permanently lost to infrastructure or buildings / structures (i.e. agricultural use and no leading to risk of severe injury or death). other onsite use identified. Development prevents exploitation of economic resources or has major detrimental effects on the quality of a mineral resource and the viability of extraction. Development causes major permanent (irreversible) damage or loss of access to a designated geological conservation site.
Moderate Exposure to contamination that, by way of its Area of BMV agriculture characteristics and extent, may result in long lost >20 ha for a term (chronic) risk to human health. temporary period. Significant disruption/damage to key infrastructure, with the capacity to affect Soil resources handled public supply networks. and stored within the Minor / gradual damage to buildings / construction site. structures, which may affect their function and / or value. Development impedes, but does not prevent, exploitation of a mineral resource and/or has a moderate detrimental effect on its quality. Development is likely to reduce, but not preclude, the economic viability of extraction. Development causes major temporary
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Magnitude Criteria of effect
Geology Soils and agriculture
(reversible) damage or minor permanent damage to a designated geological conservation site, or causes significant disruption to access (but not permanent loss of access).
Minor Land contamination at concentrations above >20 ha non BMV that which might be considered ‘normal agricultural land background’ (e.g. presence of Made permanently lost to a non- Ground), but unlikely to present a significant agricultural development. human health risk. Damage to infrastructure that affects functionality, but does not cause significant disruption or affects only minor private supplies temporarily. Development has a detrimental effect on a minor proportion of a mineral resource, or a small detrimental effect on a larger proportion of the resource. Development causes minor reversible damage to a designated geological conservation site, particularly damage to peripheral aspects that are not integral to its geo-conservation value, or temporary minor restriction of access.
Negligible No significant harm to sensitive receptors, >20 ha non-BMV including no significant potential for adverse agricultural land short term or long term human health effects. temporarily disturbed and Any non-permanent human health risks to taken out of agricultural construction workers can be fully prevented production. by means of personal protective equipment. No significant damage to infrastructure. Development has a negligible effect on economically important deposits. Development does not damage geological conservation sites.
14.9.7 The methodology for determining the potential significance of effects comprises combining the assessments of receptor sensitivity and magnitude of effect using the matrix in Table 14.10.
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Table 14.10 Significance of effects assessment matrix
Receptor Magnitude of effect sensitivity
Major Moderate Minor Negligible
High Major Moderate Moderate Negligible
Medium Moderate Moderate Minor Negligible
Low Minor Minor Minor Negligible
14.9.8 Effects identified as ‘Major’ or ‘Moderate’ are considered to be significant. Effects assessed as ‘Minor’ and ‘Negligible’ are not significant. 14.9.9 Table 14.10 does not include coincidental beneficial effects that can occur as part of a development, such as the removal or alteration of an at-risk receptor. Where relevant, such effects are identified separately and assigned a classification of ‘beneficial’. 14.9.10 For the purpose of the following assessments of effects, the construction phase is defined as the period during which any dismantling or construction works are undertaken. The operational phase is defined as the period after the new 400kV overhead line has been fully constructed, the 132kV PX route has been dismantled and removed, and all construction activities associated with the scheme completed. The life cycle of the development is completed by the decommissioning phase, defined as the period during which dismantling of the 400kV line and associated land restoration is undertaken.
Order limits and Limits of Deviation 14.9.11 The Order limits defines the maximum extent of land in which the proposed development may take place, including all temporary construction works such as access routes, bridges etc. Within this there are LoD, which define a maximum distance or measurement of variation within which the new 400kV line and temporary and permanent diversions of the 132kV infrastructure will be sited. The assessment has been undertaken based on the assumption that this work may take place anywhere within the specific LoD defined for an individual work element. For example, the assessment of effects resulting from ground disturbance from the construction of a new 400kV pylon is based on the assumption that the pylon may be located anywhere within the LoD taking into consideration the conductor swing (as on Figures 14.1 (a-d) to 14.5 (a-d) within Volume 5, Document 5.3.14). For associated development that does not have a specified LoD (such as access routes and temporary construction compounds), the assessment is based on the proposed positions of the infrastructure within the Order limits.
Intrusive ground investigation 14.9.12 It was stated in the PEIR that intrusive ground investigation would be undertaken in advance of the ES. However, it has subsequently been decided to defer the intrusive ground investigation until post-consent (aside from the limited preliminary investigation referred to previously). In arriving at this decision, the suitability of a
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land contamination and ground stability assessment based on desk study and non- intrusive survey (i.e. walkover inspection) information has been considered in the context of the requirements of NPS-EN1 and the NPPF (as summarised in Table 14.1). 14.9.13 In accordance with appropriate guidance (NPPG38) the submission of an assessment based on desk study information is considered acceptable for assessing land contamination and ground gas risk in circumstances where the desk study clearly demonstrates that the risk from contamination can be satisfactorily reduced to an acceptable level. With regard to the findings of the land contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) and the significance assessments provided below, it is considered that the proposed development falls into this category, and therefore that a desk-based assessment is appropriate. 14.9.14 Appendix 14A within Volume 5, Document 5.4.14A and the significance assessments provided subsequently within this chapter are based on reasonable worst case assumptions regarding ground conditions. The appendix and the significance assessments demonstrate that the potential effects are such that there is a high degree of confidence that effects can be avoided or reduced by the implementation of ‘routine’ measures using techniques common to redevelopment on brownfield land. As identified by the desk study, it is likely that the implementation of any measures of this nature would be focussed on the small number of specific locations where the proposed development involves ground disturbance in areas of historical industrial land use. To provide confidence in the assessment, and define any specific remediation requirements, intrusive ground investigation will be undertaken prior to construction. Where possible, this will be undertaken across the LoD, to provide good characterisation of the materials present in advance of construction. However, there will be a specific commitment to pre-construction ground investigation at the following locations: pylon PX6 – dismantling of 132kV pylon within the recorded extent of Shelford Quarry Landfill (outside the area of current active landfill operations); proposed pylon PC2 – construction of 400kV pylon on a backfilled former quarry; pylon PX23 – dismantling of 132kV pylon within the recorded extent of Hersden Tip landfill; Westbere compound site – installation of a construction compound within the recorded extent of Henden-Westbere landfill; access route to the Richborough compound site – this crosses landfill deposits to the south of the former Richborough power station; and access route to proposed pylon PC4 – this crosses Broad Oak Lodge Farm Landfill. 14.9.15 It is proposed that the delivery of intrusive investigations at the above locations is a requirement of the DCO. This will be achieved by Requirement 13 of the draft DCO (Volume 2, Document 2.1), which requires that a written scheme of works required to address ground conditions must be submitted to and approved by the relevant planning authority (in consultation with the EA) prior to any stage of the development commencing. To prepare a scheme of works that meets this requirement, it will be necessary for intrusive investigations to have been undertaken at the locations listed above. Therefore, Requirement 13 of the draft DCO provides a formal mechanism
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to ensure that suitable intrusive ground investigation, as defined by the desk study findings, is undertaken prior to construction. It also ensures that any contamination effects will be adequately mitigated, via the requirement for pre-construction approval by the relevant planning authority (in consultation with the EA). 14.9.16 This approach is compliant with the advice of PINS (i.e. Paragraph 3.61 of the Scoping Opinion which states that the ES should explain how post-consent ground investigations will be secured through the requirements of the DCO) and NPPG, which advises that “local authorities can use planning conditions, where the relevant tests are met, to ensure that development (other than that required to be carried out as part of an approved scheme of remediation) should not commence until the identified stages in delivering a remediation scheme have been discharged”.
14.10 Assessment of effects: Pylons and access routes (ground instability effects)
Construction and operational phase 14.10.1 Ground stability effects on pylons are only of relevance once the 400kV overhead line is completed and operational. However, the date upon which this becomes the case will overlap with the construction phase, as dismantling work on the 132kV line (defined as part of the construction phase) will continue after the 400kV line is completed and operational. Accordingly, the potential effects relate to both the construction and operational phases. The potential effects would be the same during both phases, so have been assessed a single item below. 14.10.2 The receptor sensitivity has been assessed as high, as the 400kV overhead line constitutes infrastructure of national strategic and economic importance. 14.10.3 Potential ground stability effects that are outside the scope of ‘standard’ engineering design may occur in relation to backfilled quarries and landfills. The proposed pylon locations avoid recorded landfills. The only location where proposed pylons fall within the boundaries of backfilled quarries is at proposed pylon PC2. Therefore, this pylon represents the reasonable worst case scenario for the purpose of the assessment. The nature of Made Ground in this location is unknown. However, in the worst case, this may comprise materials of unsuitable bearing capacity to support pylons. Intrusive ground investigation will be undertaken in this location prior to construction (required by the draft DCO, as discussed above), to inform foundation design and ensure the stability of the pylon. Should this identify that the ground is unsuitable for shallow foundations, then piled foundations will be selected to ensure that pylons are founded in competent strata. Should ground conditions be marginal (i.e. slightly too soft / loose for standard pad and chimney foundations), then localised increases in shallow pad dimensions may be considered before defaulting to piling, for commercial reasons. The findings of the ground investigation, together with required foundation solution and any associated environmental protection measures (e.g. measures to protect groundwater from the mobilisation of contamination in the event that piling is required), will be specified within the scheme or works required by Requirement 13 of the draft DCO. 14.10.4 The foundation methods discussed above all represent routine and commonly adopted engineering options for construction in areas of backfilled ground. Therefore, there is a high level of confidence that these measures will lead to a
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magnitude of effect of negligible. Correspondingly, the overall ground instability effects on pylons have been assessed as negligible and not significant. 14.10.5 Various proposed construction and maintenance access routes cross backfilled former quarries. There will also be access routes across landfill deposits around the edge of Shelford landfill (for the 132 kV infrastructure dismantling), Hersden Tip landfill (required for the removal of pylon PX23), Broad Oak Lodge Farm landfill (scaffolding access route for the construction of proposed pylon PC4) and the landfills to the south of the proposed new Richborough 400kV Substation (long term maintenance access). Constructing access routes across such land is common practice, and any potential ground instability effects on these tracks will be addressed as part of the standard construction design process (e.g. use of geo-grids/reinforced access routes), following intrusive investigation. Therefore, the assessment of effects presented above in relation to pylons is considered to be valid for access routes (i.e. negligible and not significant), on the basis that there will be a negligible magnitude of effect. 14.10.6 As previously described, potential ground stability effects associated with natural geohazards are outside the scope of the assessment. Appendix 14D within Volume 5, Document 5.4.14D and Appendix 3C within Volume 5, Document 5.4.3C demonstrate that the engineering design and construction methods associated with the proposed development are suitable to ensure the constructability of the proposed new infrastructure, in relation to the following natural geohazards: collapsible ground, landslides, compressible ground, ground dissolution, running sand and shrinking / swelling clays.
Decommissioning phase 14.10.7 The potential effects relate to the installation and presence of pylons and are not relevant in relation to the decommissioning phase. The only exception is the potential effects associated with access routes, as access will be required to decommission the 400kV route at the end of its operational lifetime. These effects are assessed identically to at the construction phase (i.e. the use of geo-grids / reinforced access routes where necessary will prevent ground instability effects). Therefore, decommissioning phase effects are assessed as negligible and not significant.
14.11 Assessment of effects: Construction compound (ground instability effects)
Construction phase 14.11.1 The proposed construction site compound at Westbere partially overlies the historical Henden-Westbere landfill, which is recorded to have received inert, commercial and household waste. As such, there is the potential for ground settlement that could affect the stability of the site. 14.11.2 The construction site compound will contain mobile temporary modular units (portakabins or similar), rather than semi-permanent office-type buildings. The receptor sensitivity has been assessed as low, as there is minimal potential for a risk to the stability of surrounding or underlying ground associated with the siting of buildings of this type (assuming that they are situated appropriately relative to slopes) i.e. the receptor (building) characteristics significantly minimise the likelihood of an effect occurring. The magnitude of effect has been assessed as negligible, as
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modular construction cabins typically exert low ground loads, and therefore ground settlement effects would not be expected to be significant (in the worst case, these would only affect the functionality of the compound). This provides an overall effect assessment of negligible and not significant.
Operational Phase 14.11.3 The effect relates to a specific receptor that will only be present at the construction phase. Therefore, it is not relevant to the operational phase.
Decommissioning Phase 14.11.4 The effect relates to a specific receptor that will only be present at the construction phase. Therefore, it is not relevant to the decommissioning phase.
14.12 Assessment of effects: Nearby buildings and structures (ground instability effects)
Construction phase 14.12.1 The potential for construction activities to cause ground instability that may damage nearby buildings and structures falls into two categories (i) slope instability/landslides, (ii) damage due to vibration or ground settlement caused by piling.
Slope instability / Landslides 14.12.2 As discussed in Appendix 14D within Volume 5, Document 5.4.14D, the Order limits is not considered to be at risk from landslide hazards associated with natural deposits / slopes. Micro-siting, within the LoD, will ensure that construction works do not affect any minor localised slopes (e.g. sensible siting of infrastructure relative to the toes of slopes). 14.12.3 Disturbance of Made Ground displaying locally poor stability may be unavoidable at proposed pylon PC2. However, this area is generally flat and construction works do not present a potential cause of slope failure. Similarly, the Westbere compound site is flat and the installation of a compound in this location does not present a slope stability risk (or a risk to adjacent land from ground settlement, for the reasons discussed in Section 14.11 of this Chapter). The other locations where the proposed infrastructure falls within the footprint of historical industrial land use, as identified in Appendix 14A within Volume 5, Document 5.4.14A (e.g. pylon PX6, pylon PX23 and the access routes to proposed pylon PC4 and the Richborough compound site) all involve minimal ground disturbance (e.g. installation of access routes), so do not present the potential to destabilise the ground.
Vibration / Ground settlement 14.12.4 The use of piled foundations, particularly driven piles, has the potential to cause ground vibration that could damage nearby structures (e.g. buildings, bridges and structures). The effects of ground vibration on structures are controlled by the soil type, the distance to the structure, and the piling energy. The propagation of vibrations is greatest in denser / stiffer soils. A distance buffer, beyond which the potential for ground vibration effects will be discounted, will be specified following the appointment of a Piling Contractor. The distance buffer will be based on the type of
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piling rig, pile type & dimensions, soil conditions and theoretical energy per driving blow. Reference will also be made to data provided in BS5228-2:2009+A1:2014 (with particular reference to tables B.2 and D.1 to D.11). 14.12.5 In locations where buildings and structures could be affected by ground vibrations from driven piles (i.e. the piling location falls within the distance buffer of an existing structure), then augered piles should be used. Augered piles produce minimal ground vibration and are not considered to present a potential of risk of damage to the buildings and structures. 14.12.6 Ground settlement effects have been considered in relation to proposed pylon PC2, where the construction of the pylon may lead to settlement of the surrounding Made Ground deposits. This pylon is approximately 25m from the nearest structure (a road). It is not considered that the installation of a single pylon has the potential to lead to sufficient ground settlement of the quarry backfill to structurally affect the road. 14.12.7 In summary, the proposed development does not have the potential to cause slope stability or landslide effects, or ground settlement effects, and the potential for vibration caused by piling to affect nearby buildings and structures will be prevented by the selection of appropriate piling techniques. Therefore, the magnitude of effect has been assessed as negligible. Buildings / structures are assessed as a medium sensitivity receptor. This provides an overall effect assessment of negligible and not significant.
Operational phase 14.12.8 This potential effect relates to construction activities and is not relevant at the operational phase.
Decommissioning phase 14.12.9 This potential effect relates to construction activities and is not relevant at the decommissioning phase.
14.13 Assessment of effects: Mineral resources 14.13.1 A Mineral Planning Report is provided in Appendix 14B within Volume 5, Document 5.4.14B. This identifies that safeguarded minerals within the Order limits (Head and alluvium) are sporadic, narrow, thin and subject to numerous physical constraints such as roads, buildings, and woods. Appendix 14B concludes that neither the Head nor the alluvium are sufficiently extensive within the Order limits for mineral extraction to be practically and commercially viable. Furthermore, Appendix 14B identifies that the degree of sterilisation of Head deposits associated with the proposed development would be inconsequential within the context of the overall extent of this mineral locally, and that the alluvium deposits are too narrow to comprise a workable deposit. The significance assessments for the construction, operational and decommissioning phases are informed by these findings.
Construction phase 14.13.2 The construction phase effectively prevents mineral extraction within the Order limits for its full duration. The MSA have been classified as a low sensitivity receptor, as Appendix 14B within Volume 5, Document 5.4.14B identifies the deposits to be of negligible economic importance, with no significant potential for future extraction.
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The potential magnitude of effect has been classified as negligible, providing an overall significance assessment for temporary sterilisation during the construction phase of negligible and not significant.
Operational phase 14.13.3 The operational phase will affect a much smaller lateral extent of mineral deposits than the construction phase, with sterilisation being restricted to working stand-offs around pylons (generally taken as a cone extending 45° upwards from the base of the foundation, or from the pile cap in the case of piled foundations) and the footprint of other project infrastructure (e.g. maintenance accesses). As per the construction phase, the receptor sensitivity at the operational phase is assessed as low. The magnitude of effect has been assessed as negligible, with reference to the findings of Appendix 14B within Volume 5, Document 5.4.14B, the very limited extent of deposits affected and the fact that the 132kV PX infrastructure removal will counter- balance sterilisation to an extent. This provides an overall significance assessment for permanent minerals sterilisation during the operational phase of negligible and not significant.
Decommissioning phase 14.13.4 Decommissioning of the 400kV infrastructure would cause similar minerals sterilisation effects to the construction phase, with temporary sterilisation of a small proportion of a low sensitivity receptor. As with the construction phase, the receptor sensitivity and magnitude of effect criteria have been assessed as low and negligible respectively, providing an overall assessment for temporary sterilisation during the decommissioning phase of negligible and not significant.
14.14 Assessment of effects: Human health (soil contamination)
Construction phase 14.14.1 The construction phase involves the disturbance of soils on agricultural land, which possess a low potential to contain elevated concentrations of soil contaminants. Construction activities may also involve the disturbance of soils in locations where specific other historical land uses have been identified (i.e. the potential contamination sources summarised in the baseline conditions description above and discussed in detail in the land contamination desk study in Appendix 14A within Volume 5, Document 5.4.14A). 14.14.2 Appendix 14A within Volume 5, Document 5.4.14A considers the location and nature of potential contamination sources in the context of the design of the proposed development (i.e. locations where ground disturbance is likely to occur) to identify where receptors (construction workers and adjacent site users) may be affected by soil contamination during the construction phase. It provides a Conceptual Site Model (which identifies the potential source-pathway-receptor linkages) and qualitative human health risk assessment. This identifies that, in general, significant source- pathway-receptor linkages are unlikely, due to the nature of the potential contamination sources and the proposed development (i.e. construction of overhead electricity transmission infrastructure with limited, localised, ground disturbance on land whose primary historical and current use is agricultural). However, localised exceptions to this have been identified, where Made Ground or landfill waste deposits may be present that are likely to be disturbed by the construction activities. Of
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particular relevance are the location of proposed pylon PC2 (overlying a backfilled former quarry), the proposed access track to proposed pylon PC4 (this crosses Broad Oak Lodge Farm landfill, which contains asbestos containing material), and the locations where existing pylons PX6 and PX23 will be removed (both within historical landfills). The potential human health risk to construction workers and adjacent site users has been assessed by the desk study as moderate, based on the reasonable worst case associated with these locations. The assessment of significance in the following paragraphs has been informed by these findings. 14.14.3 There are two potential receptors; construction workers and adjacent site users. The sensitivity of each receptor type is classified as follows: Construction workers: Without adequate protection, construction workers would routinely be involved in direct contact with soils and therefore classified as a high sensitivity receptor. However, occupational health and safety measures (Table 14.7) will minimise the potential for a significant source-pathway-receptor linkage. Therefore, the receptor sensitivity has been classified as medium.
Adjacent site users: Exposure to dust / vapours arising from the construction activities is possible, but would be expected to be intermittent and of short duration. Therefore, the receptor sensitivity has been classified as medium (i.e. receptor characteristics provide limited potential for a significant contaminant linkage). 14.14.4 As identified by the desk study (Appendix 14A within Volume 5, Document 5.4.14A), the proposed development involves limited ground disturbance, primarily in areas where there is a low risk of soil contamination. However, there are localised exceptions where the risk may be higher (as noted above). These locations provide the reasonable worst case scenario on which the assessment of potential effects is based. 14.14.5 The nature of any Made Ground deposits at proposed pylon PC2 is not known. Shelford Landfill (dismantling of pylon PX6) accepted inert waste, household waste, special waste, and liquid sludge. Hersden Landfill (dismantling of pylon PX23) accepted inert and commercial waste. With consideration of the local historical land use, a reasonable worst case scenario for these locations (i.e. for the basis of the assessment of potential effects) is considered to be the presence of asbestos containing materials, sewage works waste and soils contaminated with hydrocarbons, metals and polychlorinated biphenyls (PCBs). Such materials have the potential to cause a high magnitude of effect on construction workers and adjacent site users, due to the potential for acute health risks. In combination with the receptor sensitivities identified above, this would provide overall significance assessments of moderate (significant) in relation to both receptor types. This indicates that, as recommended by Appendix 14A, Volume 5, Document 5.4.14A, intrusive ground investigation is required in the locations that have a specific potential to display these worst case conditions, to ensure that measures can be implemented in accordance with the CEMP (Appendix 3C within Volume 5, Document 5.4.3C) to reduce the potential effects to negligible. 14.14.6 As discussed in Section 14.9 of this Chapter, intrusive ground investigation will be delivered as a DCO Requirement prior to construction, including targeted investigations at these locations. The pre-construction ground investigation will also include targeted investigations at three other locations where construction works may intersect Made Ground deposits (Westbere compound, access route to proposed
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pylon PC4 and Richborough compound), although these only involve very shallow groundworks (<0.5m) to form access routes and are therefore less relevant to the consideration of worst case conditions (noting that the potential presence of asbestos containing materials at the access route to pylon PC4 is already covered by the worst case scenario discussed above, in any case). 14.14.7 The ground investigation process that will be undertaken is detailed in the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). In summary, this will comprise targeted borehole drilling and trial pitting, chemical analysis of soils, gas monitoring, human health and ground gas risk assessments. The investigation findings will be used to determine a scheme of works to address any contamination risks, which will require approval by the relevant planning authority (in consultation with the EA), as required by Requirement 13 of the draft DCO. 14.14.8 The environmental measures that may be identified by this process will fall within the general scope listed in the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). Based on the worst case conditions described above, these would comprise the following: Dust suppression measures (e.g. spraying with water), minimisation of dust generation (e.g. sheeting of soil stockpiles, planning of work to avoid temporary stockpiling in windy / exposed areas etc.) and construction phase compliance monitoring. Work in accordance with The Control of Asbestos Regulations 2012, including the use of appropriately qualified operatives, asbestos resistant PPE (e.g. respiratory protection), safe storage and off-site disposal of asbestos containing soils (e.g. arisings from piling), together with dust control measures and supporting compliance air monitoring, to ensure that airborne fibres are not generated at concentrations that present a risk to adjacent site users. Remediation of soils affected by contamination (e.g. bioremediation of hydrocarbon-contaminated soils). Off-site disposal of any highly contaminated materials that cannot be directly re- used, or remediated and re-used, in accordance with the procedures described in the Outline Waste Management Plan (Appendix 3D within Volume 5, Document 5.4.3D). Adoption of specialist PPE and clean working procedures (e.g. decontamination units) if handling or excavating materials derived from sewage works. Dust suppression and perimeter compliance monitoring to prevent risks to adjacent site users. Specialist working methods when decommissioning pylons that may overlie landfill waste. These include: minimisation of disturbance of surrounding soil when excavating foundations (foundations to be removed to 1.5m below ground level), use of personal protective equipment by construction workers (as required by the ground conditions), re-instatement of any very minor damage to landfill capping (to an engineered specification) and removal of any waste arisings to a landfill. Compliance testing on all incoming materials, to ensure chemical suitability.
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14.14.9 It should be noted that that the full range of measures listed in the CEMP (summarised above) is based on worst case conditions, and it is unlikely that these will be required in full. However, the full range is presented to demonstrate that any contamination that could reasonably be expected will be mitigated to levels where the magnitude of effect will be negligible, via a process that will be secured by Requirement 13 of the draft DCO. Therefore, there is a high degree of confidence that, by following this process, the resulting effects of soil contamination on human health during the construction phase will be negligible and not significant (combination of medium receptor sensitivity and negligible magnitude of effect). The assessment of significance above relates to potential risks from pre-existing contamination (i.e. exposure to contaminated soils). It does not consider the risk of construction activities, such as fuel storage, introducing new sources of land contamination that may present a health risk. This will be prevented by appropriate environmental permitting and control of construction activities (e.g. compliance with EA PPGs) and controlled by the CEMP, and therefore will be negligible and not significant.
Operational phase 14.14.10 Areas of land will be temporarily occupied by the proposed development during the construction phase and returned to their original use (in general this is agricultural) during the operational phase. Should the proposed development leave a legacy of land contamination, then there is the potential for it to cause an adverse human health effect on future site users. This may occur if (a) activities associated with the proposed development introduce new contamination to the ground (e.g. by fuel spillages), or (b) activities associated with the proposed development mobilise pre- existing contamination (e.g. by bringing contaminated soil from depth to near surface locations). 14.14.11 Appendix 14A within Volume 5, Document 5.4.14A identifies that the potential risk to future site users is moderate, but can be reduced to negligible by compliance with appropriate environmental permitting and controls during the construction phase (e.g. compliance with EA PPG notes) and appropriate re-use of soils under a Materials Management Plan (MMP). These measures form part of the embedded environmental measures listed in Table 14.7. Therefore, allowing for the incorporation of these measures, the magnitude of effect has been assessed as negligible. The receptor sensitivity has been assessed as high (as future users of land could include agricultural workers who could be routinely exposed to soils). This provides an assessment of effects on future land users from soil contamination of negligible and not significant.
Decommissioning phase 14.14.12 The potential effects during the future decommissioning of the proposed new 400kV infrastructure would be expected to generally be similar to those at the construction phase, as decommissioning involves similar levels of ground disturbance (e.g. excavation of pylon foundations to 1.5m below ground level). Therefore, the potential effects at the decommissioning phase have been classified as per those at the construction phase (i.e. medium sensitivity for site workers, medium sensitivity for adjacent land users, and negligible magnitude of effect). This results of an overall assessment of effects of negligible and not significant.
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14.15 Assessment of effects: Human health (ground gas)
Construction phase – Site compound buildings 14.15.1 The proposed construction compound at Westbere is located partially within the recorded boundary of Henden-Westbere landfill, which accepted household waste. The land contamination desk study (Appendix 14A within Volume 5, Document 5.4.14A) concludes that the potential gas risk to buildings at this compound is moderate, on the following rationale: the nature of the source: given the presence of household waste, a reasonable worst case assumption is to assume that significant ground gas generation may be ongoing; the features of the receptor: the only buildings / enclosed spaces associated with the compound will be modular metal units (portakabins or similar). Such buildings typically consist of non-jointed floors, have a high air through-flow, and do not incorporate foundations that could cause preferential gas migration. They also do not incorporate any below ground sub-structures that could encourage the migration / accumulation of gas; and the proposed layout of the compound, which indicates that the temporary cabins will be located outside the recorded landfill area. 14.15.2 The desk study concludes that the potential for a viable source-pathway-receptor linkage in relation to the Richborough compound (which will be built off existing hardstanding) can be discounted. 14.15.3 The assessment of significance provided has been informed by these findings, and is based on buildings / enclosed spaces at the Westbere compound as these are the only receptor identified to potentially be at risk. The characteristics of the buildings limit the potential for gas ingress (as discussed above). Furthermore, there are a range of standard construction design measures that can be incorporated into building design to reduce the ground gas risk. These include the use of raised construction (i.e. clear void space below cabins), gas resistant membranes and/or gas alarms. Such measures are routinely used within compound buildings on sites where a gas risk is present (e.g. sewage works, landfills), so represent proven ‘routine’ design measures. Allowing for the incorporation of these standard measures within the design of the site compound buildings, then even in the worst case scenario that significant ground gas generation is ongoing within the deposits underlying the proposed compound area, the magnitude of effect will be negligible (as gas will be unable to accumulate to concentrations at which it presents an explosion or asphyxiation risk) and the receptor sensitivity medium, providing an overall assessment of effects of negligible and not significant. The specification of gas protection measures will be determined as part of the detailed design process prior to construction, based on site investigation results (including the results of gas monitoring). Site investigation will be secured via the DCO requirements, as previously discussed.
Construction phase – Existing buildings within / adjacent to the Order limits 14.15.4 The desk study (Appendix 14A within Volume 5, Document 5.4.14A) identifies that the proposed development does not generally involve ground disturbance in locations where a potentially significant ground gas source may be present. It identifies that, where there are exceptions to this (e.g. at proposed pylon PC2, pylon
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PX6 and pylon PX23), the level of ground disturbance is such that gas generation or migration are unlikely to be significantly affected. The desk study assesses the potential for the construction works to cause a significant risk of gas migration to existing buildings, with a particular focus on the locations listed above, the proposed access track across the Richborough landfills, the establishment of the Westbere compound and the presence of natural soils containing organic matter (the tidal flat deposits in Sections C and D). The desk study concludes that the risk to existing buildings is low. The assessment of effects presented below is informed by the findings of the desk study. 14.15.5 As the potential receptors include occupied buildings, the receptor sensitivity has been classified as high. 14.15.6 As recommended by Appendix 14A within Volume 5, Document 5.4.14A, and discussed in detail above, confirmatory intrusive investigation will be undertaken prior to construction, including gas monitoring at / near proposed pylon PC2, pylon PX6 and pylon PX23. Where this process identifies the presence of ground gas, then it is anticipated that the scheme of works required under Requirement 13 of the draft DCO will include perimeter monitoring during construction works in affected areas, to ensure that any potential migration risk to nearby buildings is monitored. In the very unlikely event that perimeter monitoring indicates that the works are causing significant gas migration, then intervention would be undertaken to prevent this affecting nearby buildings (e.g. changes to working methods, installation of in-ground ventilation barriers); again these measures would be approved in advance by the relevant regulatory authority, via inclusion in the approved scheme of works. There is a high degree of confidence that, following the implementation of this approach, which follows the standard approach to contaminated land risk assessment and remediation recommended by CLR11242, the magnitude of effect will be negligible. Therefore, the resulting effect will be negligible and not significant.
Operational phase 14.15.7 Ground gas effects during the operational phase have been scoped out of the assessment.
Decommissioning phase 14.15.8 Decommissioning works will involve ground disturbance and therefore, similarly to construction works, have the potential to affect ground gas migration pathways and rates. The effect would be expected to be lesser than at the construction phase, as the level of ground disturbance will be less (removal of foundations to 1.5m depth, as opposed to the installation of foundations by methods including piling). Therefore, on the basis that construction phase effects have been assessed as negligible and not significant, it follows that decommissioning phase effects will also be negligible and not significant.
14.16 Assessment of effects: disturbance and loss of soil resources
Construction phase 14.16.1 Soils would be disturbed as a consequence of handling, temporary storage and reinstatement during the construction of the pylons and associated development works and the demolition of the existing 132kV PX overhead line. Environmental
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measures have been included in the design of these works such that, where practical, access roads and operational areas would be shared to support both aspects of the proposed development. Also, where possible, access routes follow existing farm tracks and field boundaries. 14.16.2 Land within the footprint of the new pylons includes pylons of the proposed 400kV route and permanent diversion of the PY route. Soil in these areas would be temporarily disturbed and reinstated. Arable use of the land would not be possible, therefore it will be non-agricultural except where pylons are located in fields used as permanent pasture, of which few exist within the Order limits. Where not in arable use, the soil would continue to perform its other ecological functions, such as supporting wild plant and animal life, water filtration, carbon sequestration and storage. 14.16.3 All access routes would be temporary: a typical construction haul width is 4m, however a swathe of land up to 12m wide would be required to accommodate for topsoil storage and fencing. This greater width (worst case) was used to estimate the area of soil disturbed for construction of the access routes (see Table 14.11).
Table 14.11 Analysis of the potential effects on soil resources during the construction and phase of the proposed development
Aspect of the development Area Comments (ha)
Land within the footprint of new pylons 1.08 Topsoil temporarily removed, (proposed 400kV route and PY route reinstated, non-arable use. permanent diversions)
Access 70.1 Topsoil temporarily removed.
Working areas 45.6 Topsoil temporarily removed.
Land within the footprint of PX route 0.54 Soils returned to agricultural (restored) use.
Note: Non-agricultural and urban land not included in the assessment (7ha within working areas and/or used for access routes)
14.16.4 The area of soils disturbed during construction phase would not exceed 115.7ha of which <81.9ha is BMV agricultural land. Because the majority of the soil would be
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disturbed on a temporary basis the magnitude of the effect is moderate and, on the basis that this includes BMV agricultural land, the effect would be moderate and significant. Environmental measures summarised in Table 14.7 would ensure that the soil resources are sufficiently protected during construction so that the soil profile is reinstated to an equivalent agricultural land classification. The adoption of mitigation reduces the effect to minor and not significant.
Operational phase 14.16.5 During the operational phase localised soil disturbance may be required to allow for maintenance of the infrastructure. As it would always be temporary and typical area of BMV land affected would be less than 20ha, the effect on soil resources would be non-significant. Environmental measures used in the construction phase would be maintained (see Table 14.7).
Decommissioning phase 14.16.6 Should future decommissioning of the 400kV route be required it is assumed that a similar extent of working areas and access would be required as for its construction, which would result in a similar area of disturbed soils. The effect on soil resources would be moderate and therefore significant. The same mitigation measures as used in the construction phase would be taken reducing the effect to minor and not significant.
14.17 Assessment of effects: temporary loss of agricultural land
Construction phase 14.17.1 Within the Order limits, there are significant areas of BMV agricultural land that could potentially be affected on a temporary basis during the construction period. Table 14.12 provides a summary of the potential land take with reference to ALC within the Order limits. 14.17.2 The total working area, which is currently in agricultural use that will be required for the construction of the proposed 400kV overhead line combined with the area required for the dismantling of the existing overhead line is approximately 115.7ha which includes all access routes and adjacent land required for storage of stripped soils and fencing. The areas which will be used both for the construction and decommissioning would be out of agricultural use for a maximum period of 4.5 years (from June 2017 until December 2021), while the areas used only for construction or decommissioning would be restored after a shorter period of time, typically in the order of months, such that individual fields would be affected for a period of less than one growing season. 14.17.3 Additional areas of undisturbed land may be out of agricultural production due to fragmentation of fields caused by the location of working areas, however they will not be disturbed and will be managed as grassland for the exclusion period. Their extent was not estimated as it will depend on the farm management and crop rotation specific constraints and cost-benefit comparison between continued management of smaller fields and excluding them from arable production.
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Table 14.12 ALC grade of land potentially disturbed or temporarily used for construction of the proposed development and demolition of the existing overhead line within the Order limits
Grade of Agricultural Land (ha)
1 2 3a 3b 4 Total
Working 2.8 22.2 8.2 5.4 7 45.6 areas
Access 2.8 30.3 15.6 10.4 11 70.1
New pylons 0.02 0.34 0.26 0.18 0.28 1.08 (PC and PY diversion)
Removed - 0.15 0.15 0.08 0.15 0.53 (PX route) - gain
Total 0.02 0.19 0.11 0.11 0.13 0.56 permanent
BMV 0.32 non-BMV 0.24
Total 5.6 52.5 23.76 15.8 18 115.7 temporary
BMV 81.9 non-BMV 33.8
Notes: See Appendix 14C within Volume 5, Document 5.4.14C for the source of estimates and details of methodology. The development also uses 7ha of non-agricultural and urban land.
14.17.4 The design and construction of access routes within the Order limits will vary depending on the nature and potential frequency of use. The analysis in Table 14.12 has been based on a maximum land swathe width of 12m, which includes 4m to 6m track and area for topsoil storage and fencing. The area of temporary land take is greater than 20ha of BMV agricultural land. Therefore, in accordance with the criteria in Table 14.10 the effects would be moderate and significant. Environmental measures summarised in Table 14.7 would ensure that the land is restored to the same agricultural quality and reduce the effects to minor and not significant.
Operational phase 14.17.5 During the operational phase, temporary exclusion of land from agricultural use may be required to allow for maintenance of the infrastructure. Typically, the area of BMV land affected during temporary works would be confined to an area considerably less than 20ha, as the pylon route would be constructed in a phased programme, as well as the dismantling of the PX route. Following completion of construction, temporary works would be restored and returned to agricultural use. Therefore, the effect is considered to be negligible and not significant. The same environmental measures as used in the construction phase would be maintained (see Table 14.7).
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Decommissioning phase 14.17.6 Should future decommissioning of the 400kV route be required it is assumed that similar extent of working areas and access would be required as for its construction, which would result in a similar areas of temporary land take. Following the implementation of the environmental measures outlined in Table 14.10 the effects would be minor and therefore not significant.
14.18 Conclusions of significance evaluation 14.18.1 The findings of the significance assessment in relation to geology and land quality are summarised in Table 14.13.
Table 14.13 Summary of significance of effects
Receptor and Magnitude Receptor Significance Rationale effects of effect sensitivity level
Ground instability Negligible High Not Significant ground (pylons and Significant instability effects access routes) – (Negligible) prevented by the construction, selection of appropriate operational and foundations and access decommissioning track construction phases methods.
Ground instability Negligible Low Not The nature and design (construction significant of the compounds compound) – (Negligible) prevents a significant construction effect. phase only
Ground instability Negligible Medium Not Use of augered (nearby buildings significant foundations in locations and structures) – (negligible) requiring piling where construction assessment indicates phase only that driven piles may affect the stability of nearby structures.
Minerals Negligible Low Not Assessment based on sterilisation – significant the findings of construction, (Negligible) Appendix 14B within operational and Volume 5, Document decommissioning 5.4.14B. phases
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Receptor and Magnitude Receptor Significance Rationale effects of effect sensitivity level
Health risks to Negligible Medium Not Environmental construction Significant management and workers and (Negligible) occupational health and adjacent site safety controls for the users from soil construction phase will contamination – be specified in construction and accordance with the decommissioning CEMP, based on pre- phases construction ground investigation findings. DCO requirement for a scheme of works to be submitted to, and approved by, the relevant regulatory authority prior to the commencement of any phase of development, detailing the environmental management and occupational health and safety controls that will be implemented to ensure that there is no significant risk to human health (i.e. negligible magnitude of effect).
Human health Negligible High Not Compliance with risks to future significant environmental users of land that (Negligible) management good is temporarily practice procedures occupied by the and re-use of soils proposed under an MMP, in development accordance with the during the embedded measures in construction Table 14.7, will prevent phase and a significant effect (i.e. subsequently lead to a negligible returned to magnitude of effect). agricultural use (operational phase)
Health risks to Negligible Medium Not Construction design workers within the Significant mitigation measures to Westbere (Negligible) be incorporated into construction building design. compound from Measures to be ground gas – selected from a
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Receptor and Magnitude Receptor Significance Rationale effects of effect sensitivity level
construction standard range for phase only constructing temporary modular buildings on sites with a ground gas risk, based on pre- construction site investigation results.
Human health, Negligible High Not Pre-construction due to ground Significant ground investigation gas migration to (Negligible) and gas monitoring to existing built be undertaken at development potentially affected (both within the locations, as a Order limits and requirement of the on adjacent land) DCO. Findings to be - construction and used to inform decommissioning construction phase gas phases controls, which will be specified in the scheme of works for approval by the relevant regulatory authority.
Soil disturbance Minor Medium Not Environmental Significant measures (Appendix (Minor) 3B within Volume 5, Document 5.4.3B) are considered to be standard practice on construction projects and are incorporated into the CEMP (Appendix 3C within Volume 5, Document 5.4.3C).
Temporary loss of Minor Medium Not As above. agricultural land Significant (access roads (Minor) and working areas)
Key/footnotes Major High Significant Moderate Medium Not Minor Low Significant Negligible Negligible
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Inter-related effects Soils and Agricultural Land 14.18.2 Inter-related effects may occur with terrestrial ecology, water environment, and socio- economics receptors. The effects of soil disturbance on designated ecological habitats are subsumed within the overall assessment of effects on these receptors within Chapter 9 within this document. The effects on surface water and groundwater due to potential release of silt laden water as a consequence of soil disturbance have been assessed in Chapter 13 within this document as not significant, on the basis of incorporated environmental measures (e.g. the use of sediment traps). All soils are considered to be of economic value and support a range of agricultural activities. The effects on farm businesses due to permanent and temporary land take are assessed in Chapter 15 within this document. Geology and land contamination 14.18.3 Inter-related effects may occur with water environment, air quality, terrestrial ecology and socio-economics receptors. 14.18.4 The proposed development generally presents a relatively low risk of mobilising soil contamination to groundwater or surface water. Chapter 13 within this document concludes that, with appropriate incorporated environmental measures, including pre-construction ground investigation where necessary, the effect of the proposed development on surface water and groundwater quality will be not significant. It also states that any effects on ecology associated with watercourses as a result of changes in water quality are predicted to be not significant. 14.18.5 The potential for groundwater discharges from the proposed development to affect land quality will be prevented by the appropriate permitting of all discharges (i.e. under the discharge consent system), as described in the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). Therefore, the significance of this inter- related effect has been assessed as negligible. 14.18.6 The potential for contamination in dust to adversely affect human health has been assessed, within this chapter, as negligible. Dust control, suppression and monitoring measures will be implemented, as described in the CEMP (Appendix 3C within Volume 5, Document 5.4.3C). These measures will be designed based on the findings of pre-construction ground investigation which, as discussed, will include focussed investigations at the minority of locations where ground disturbance associated with the proposed development intersects with recorded historical industrial land use. The findings of these investigations will allow specific dust control measures to be targeted to the nature of the ground disturbed at individual locations. As these measures will prevent significant effects on adjacent land users (human health), it follows that they will also prevent the potential for any wider effects on air quality or risks to wildlife. Therefore, the significance of inter-related effects with air quality and wildlife receptors has been assessed as negligible. 14.18.7 The minerals sterilisation effects associated with the proposed development have been classified as negligible. Therefore, there is no potential for wider effects on the local economy associated with the loss of mineral supply, and potential inter-related effects on socio-economics receptors have been assessed as negligible.
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15. SOCIO-ECONOMICS AND RECREATION
15.1 Introduction 15.1.1 This Chapter of the ES describes the assessment of the likely significant effects of the proposed development on socio-economic features and on existing and future land uses during the construction, operational and decommissioning phases. 15.1.2 This Chapter should be read in conjunction with the project description in Chapter 3 within this document. This Chapter should also be read with reference to Figure 3.1a-h within Volume 5, Document 5.3.3 in order to assist the understanding of the descriptions and assessment presented.
Limitations of this Environmental Statement 15.1.3 This ES Chapter has been progressed on the basis of information known at the point of assessment and has considered site analysis, desk based work and information gathered through the consultation process. 15.1.4 In the absence of published guidance and advice in relation to socio-economic assessment, the assessment utilises a methodology which has been established, tested and accepted through similar schemes (for example High Speed 2, the Hinkley Connection Project) and relies in part on the professional judgement of the author in drawing conclusions.
15.2 Policy and legislative context
Policy context 15.2.1 The principal guidance for examination of the application is provided by NPS EN-118 and EN-519. At the national level, further guidance is also provided through the NPPF36. 15.2.2 At the local level, policy and guidance has been reviewed in order to identify policies of relevance to the scope of the assessment of potential socio-economic effects. Given the geographic extent of the scheme local policy from CCC, TDC and DDC have been reviewed. Reference is also made to relevant KCC guidance and publications, specifically in relation to public rights of way (PRoW) and tourism. 15.2.3 Table 15.1 lists national and local policies and guidance relevant to the proposed development and its potential effects on socio-economic receptors. Relevant sections of the ES have been cross-referenced to the appropriate policy at Table 15.1, although reference should be made to the Planning Statement (Volume 7, Document 7.1) for the full policy assessment.
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Table 15.1 Policy issues considered in preparing this ES
Policy reference Policy issue National planning EN-1 Section 5.10 provides general guidance on how the ES should assess the effects of the proposed policy development on existing and proposed land uses. Specifically Paragraph 5.10.5 states “The ES should identify existing and proposed land uses near the project, any effects of replacing an existing development or use of the site with the proposed project or preventing a development or use on a neighbouring site from continuing” This should include an assessment of “any effects of precluding a new development or use proposed in the development plan”.
These potential effects are considered as part of the assessment in Section 15.14.
This section of the NPS, through Paragraph 5.10.8 states that the ES should also “seek to minimise the impacts on the best and most versatile agricultural land…. and preferably use land in areas of poorer quality”.
The potential effects on agricultural land uses is considered in Section 15.13 with reference made to Chapter 14 within this document where necessary.
With reference to mitigation, Paragraph 5.10.19 recognises that while “there may be little that can be done to mitigate the direct effects of an energy project on existing use of the proposed site (assuming that some at least of that use can still be retained post project construction) applicants should nevertheless seek to minimise these effects and the effects on existing or planned uses near to the site by the application of good design principles, including the layout of the project”.
Paragraph 5.10.23 refers specifically to the potential sterilisation of land and states “Where a project has a sterilising effect on land use (for example in some cases under transmission lines) there may be scope for this to be mitigated though, for example, using or incorporating the land for nature conservation or wildlife or for parking and storage in employment areas”.
The potential effects on the sterilisation of sites is discussed in Section 15.14.
Paragraph 5.10.24 recognises that “Rights of way, National Trails and other rights of access to land are important recreational facilities” and “The IPC should expect applicants to take appropriate mitigation measures to address adverse effects on coastal access, National Trails and other rights of way”.
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Policy reference Policy issue
The potential effects and proposed mitigation in relation to PRoW and recreational trails is discussed in Section 15.10. The approach and method has sought to respond to these requirements with potential effects on land uses explored and mitigation measures developed where effects are predicted. EN-1 Section 5.12 sets out an approach to energy infrastructure from a socio-economic perspective. The proposed socio-economic scope has been informed by guidance provided through section 5.12.3 which details some of the likely socio-economic effects that should be considered as part of any assessment. Through Paragraph 5.12.5 the guidance recognises the inter-relationship between the socio-economic assessment and other effects such as visual impact.
Where appropriate the Chapter draws on conclusions from other assessments in the consideration of indirect amenity effects.
Furthermore, section 5.12.7 states “The IPC may conclude that limited weight is to be given to assertions of socio-economic impacts that are not supported by evidence (particularly in view of the need for energy infrastructure as set out in this NPS)”.
Consideration has also been given to this statement in defining a scope which can be quantified and evidenced. NPPF This policy framework provides high level guidelines for achieving sustainable development. From a Para 7 socio-economic point of view, the document states the importance of “ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure.” Local Planning Policy CCC Local The Council will not permit the loss of existing allocated employment sites or clusters, allocated on the Plan Policy Proposals Map. ED1 The potential effect on such sites is considered in Section 15.14. CCC Draft Identified Strategic Site Allocations. Those applicable to this assessment include Land at Sturry/Broad Local Plan Oak (SP3 b), and Land North of Hersden (SP3 h) and the potential effect on such sites is considered in Policy SP3 Section 15.14. CCC Draft Identifies land allocated for economic development. Those applicable to this assessment include Broad Local Plan Oak Road/Vauxhall Road and the potential effect on such sites is considered in Section 15.14.
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Policy reference Policy issue
Policy EMP1 CCC Draft Seeks to protect best and most versatile farmland. The potential effects on agricultural land uses is Local Plan considered in Section 15.13 with reference also made to Chapter 14 within this document. Policy EMP12 CCC Draft Seeks to protect visitor accommodation. The potential effects on tourism are considered in Section 15.9 Local Plan with potential benefits for local accommodation considered in Section 15.15. Policy TV3 TDC Local Identifies land allocated for economic development. The potential effect on such sites is considered in Plan Section 15.14. Policy EC1 TDC Local Identifies importance of amenity impacts with respect to new power lines. Potential amenity effects are Plan Policy considered throughout the assessment. CC8 TDC Local Seeks to protect best and most versatile farmland. The potential effects on agricultural land uses is Plan Policy considered in Section 15.13 with reference also made to Chapter 14 within this document. CC9 DDC Core Outlines protection of employment allocations for employment uses. The potential effect on such sites is Strategy considered in Section 15.14. Policy DM2 Other policies - Kent County Council: Making the most of Kent’s Countryside and Coast Guidance This plan sets out an approach to providing access to Kent’s countryside for the benefit of all of Kent’s residents. The plan is written in accordance with the duty set under the Countryside and Rights of Way Act 2000 to prepare a Rights of Way Improvement Plan and therefore forms such a plan for Kent.
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15.3 Data gathering methodology 15.3.1 Data for this Chapter has been gathered from a number of sources to inform the socio-economic baseline and assessment; these are listed in this section.
Desk study 15.3.2 The ES Chapter has drawn from a variety of desk-based sources including: national policy and local development plan documents and guidance; official labour market statistics (Office for National Statistics (ONS) and Nomis247); Visit Kent statistics; Experian Business to Business (B2B) Prospector (online directory using the National Business Database); Natural England Agricultural Land Classification (ALC) information; Public rights of way (PRoW) and formal cycle networks from OS data and a variety of web resources including KCC online mapping; Kent County Council Definitive PRoW mapping; residential, commercial, industrial and tourism receptors from OS data and site surveys; mineral reserves and safeguarded areas identified through KCC planning policy; and online aerial photograph resources (Google Earth).
Survey work 15.3.3 An initial site walkover was undertaken in December 2013 in order to understand the potential route of the proposed development and to gather baseline data on the main socio-economic receptors. 15.3.4 Public rights of way surveys have been undertaken to understand the recreational use of walking routes in the Local Study Area (see Figure 15.1 within Volume 5, Document 5.3.15) with a focus on those routes that are potentially affected by the proposed development. These were undertaken by Intelligent Data Collection Limited in July and August 2014 and a summary of the findings can be found in Chapter 10 within this document. The PRoW surveys were undertaken to inform the assessment and provide a ‘snapshot’ of activity during July and August 2014, which is considered to be representative of usage during the summer months and also during school holidays.
247 A service provided by the Office for National Statistics, to give you free access to the most detailed and up-to-date UK labour market statistics from official sources.
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15.4 Environmental Impact Assessment consultation
Environmental Impact Assessment scoping 15.4.1 In addition to comments derived from consultations, the Scoping Opinion for the Richborough Connection project was received from PINS and is included in Appendix 1A within Volume 5, Document 5.4.1A. The Secretary of State (SoS) consulted on the Scoping Report and the responses received are included in summary below where relevant to Socio-economics and recreation. 15.4.2 Table 15.2 summarises how all consultee comments resulting from the Scoping Report, of relevance to socio-economic receptors have been addressed in the ES.
Table 15.2 Consultee comments and responses to EIA scoping
Consultee Comments How addressed in this ES
Joint It is noted that the scope In explaining why network reinforcement is Councils appears to make little needed, the benefits and reason for the reference to the socio- proposed works are detailed in Chapter 2 economic benefits of the of this document. As such National Grid project, for example, the does not outline the wider national need for the proposal and economic benefits of its projects when the effects of it not going undertaking socio-economic assessment. ahead on electricity supply. When considering whether proposals It would be helpful for the should be granted consent, the decision scope to consider these making body must, as set out in NPS EN- issues. 1, consider whether any adverse effects arising from the proposed development outweigh its benefits. To that end, broader national, regional and local economic benefits arising from having a secure and reliable energy infrastructure will be taken into account by decision makers. The socio-economic benefits of the project have been assessed and considered in Section 15.15.
Civil Regardless of the specific The potential effect of the proposed Aviation routeing of the overhead development on Maypole aerodrome has Authority line, the CAA advises that been considered as part of the the associated structures assessment in Section 15.12. (at a maximum of 46.5m high) will not constitute aviation route obstructions for civil aviation purposes. The CAA therefore have few associated observations other than to highlight that the need for planning deliberations to take into account any relevant aerodrome specific safeguarding issues
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Consultee Comments How addressed in this ES
(DfT/ODPM Circular 1/2003 refers). To that end the CAA note that the proposed route passes in relatively close proximity to a privately operated aerodrome, Maypole. The CAA have copied this correspondence to the aerodrome operator and believe it would be appropriate for any Environment Assessment (or similar) to take account of the potential impact upon Maypole-associated operations.
Statutory Consultation 15.4.3 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed consultees and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising, inspection of documentation at selected locations. 15.4.4 National Grid prepared a PEIR which was publicised at this consultation. National Grid sought feedback on the environmental information presented in that report. Feedback received during Statutory Consultation was considered by National Grid and incorporated where relevant in the design of the proposed development and its assessment and presentation in this ES. 15.4.5 A summary of the Statutory Consultation representations received (relevant to the EIA) and National Grid’s responses are summarised at Volume 6, Document 6.1 (Consultation Report). A summary of the main Statutory Consultation representations received from prescribed and non-prescribed bodies in relation to the socio-economic assessment are presented in Table 15.3.
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Table 15.3 Consultee comments and responses to PEIR
Consultee Comments and considerations How addressed in this ES
Canterbury City The pylon alignment runs directly through the middle of The potential impact of the pylon location PC2 has been Council, Property a strategic employment site at the junction of Broad considered as part of this assessment. Services Oak Road and Vauxhall Road. The site is protected in During design development, and following comments Policy EM1 of the Canterbury District Local Plan 2014, received the pylon location was amended to move the which has recently been submitted to the Planning pylon further south, and less central within the employment Inspectorate for examination. site. Other constraints restrict the pylon being positioned The council consider the site to be a high profile any further south and/or on the opposite side of Vauxhall gateway to the Broad Oak Road commercial business Road. This is explained further in Chapter 2 within this estate and wish to promote a quality employment document. development. Interest has been received in the site from motor retail, light industrial and distribution uses. The council consider the site offers potential to create up to 100 jobs and the Council would benefit from a substantial capital receipt and business rates of approximately £150,000 pa. The pylon situated very close to the sites centre would fragment the site, which is of significant strategic importance, to such an extent that it would be incapable of development other than open storage. We therefore request that the alignment is re-routed along the southern perimeter of the site and the pylon moved to the east of Vauxhall Road.
Kent County Council 1. Advise that National Grid revisit the use of 1. National Grid, through the SOR (see Volume 7, underground cable to minimise….. the impact on the Document 7.4) and COR (see Volume 7, Document 7.7) proposed site allocations as set out in the emerging have considered placing the new connection underground CCC Local Plan 2014 and the SEW proposals at Broad in its entirety, or in sensitive areas along the route. Studies Oak identified in their Water Resource Management indicate that there are no areas where the benefits of Plan (June 2014). placing the connection underground would justify the additional costs.
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Consultee Comments and considerations How addressed in this ES
2. Highlights local concern, particularly in Broad Oak The potential effect of the proposed development on future due to close proximity to houses and local businesses. site allocations is considered further within the assessment of future land uses in Section 15.14. 3. The PRoW team will continue to meet and provide 2. This assessment considers the potential direct effects further comment at the submission stage. and indirect amenity effects on businesses within the Broad Oak area. Proximity to residential properties and the potential effects of this are discussed through Chapters 7 and 11 of this document. 3. Further discussions have been held in relation to temporary impacts on the PRoW network and a hierarchy of mitigation agreed which is considered as part of this assessment in Section 15.10 within this Chapter.
Canterbury 4 1. Significant concern over landscape and visual impact 1. Any landscape and visual effects on socio-economic Business (C4B) and any subsequent detrimental economic impacts. receptors are considered as part of this assessment as an indirect amenity effect. This is only applicable to receptors 2. The extent of the effect on agricultural activities in the considered to have an amenity value. immediate vicinity of the pylons should be considered. 2. The potential effect on agricultural activities / farm 3. Careful and appropriate consideration to be given to business is considered as part of this assessment. disruption of businesses during construction, especially 3. This is considered as part of the construction phase those located at the eastern edge of Sturry and Broad assessment in Section 15.12 within this Chapter. Oak commercial zones. 4. The future potential for a reservoir is considered as part 4. C4B expressed concern in relation to the Broad Oak of the assessment of future land uses in Section 15.14 water site – essential to ensure that the future of the within this Chapter. district is not limited or restricted by water resource limitations. C4B consider both projects are necessary to ensure the future prosperity and growth potential of the district and request National Grid and SEW work in partnership.
Kent and Medway Concerned that the proposed route fails to take into The potential effect on these future receptors is considered Economic Partnership consideration longstanding plans for economic as part of the assessment of future land uses in Section development of Canterbury and Thanet in terms of 15.14 within this Chapter. securing a sustainable water supply. The route puts
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Consultee Comments and considerations How addressed in this ES
the proposed Broad Oak reservoir, road changes and the commercial development in the Sturry area at risk.
Canterbury City 1. Consideration should be given to moving the line in 1. The potential impact of the pylon location PC2 has been Council the vicinity of pylon PC2 and PC4 further from the considered as part of this assessment. employment site and further from the Broad Oak During design development, and taking into consideration Housing Site. feedback received the pylon location was amended to move the pylon further south, and less central within the 2. Further review adjacent to the Broad Oak reservoir employment site. Other constraints restrict the pylon being site. positioned any further south and/or on the opposite side of 3. Moving the line in the vicinity of PC26 and PC 28 Vauxhall Road. This is explained further in Chapter 2, north of Nethergong Campsite. Section 2.4 through the consideration of alternatives and the design evolution and review process. 2. The potential Broad Oak reservoir site has been considered as part of the assessment of future land uses in Section 15.14 within this Chapter. 3. Taking into consideration the feedback received and constraints in this area a design review (see Section 2.4) was undertaken of the pylons in the vicinity of Nethergong Campsite. Pylon locations have been altered in this location and the route in the location of pylon PC28 has moved further north and east, away from Nethergong Campsite. The alignment of pylons PC26 and PC27 has been maintained due to other constraints to be considered in this area, however, pylon PC27 has been moved further north and east from the campsite. This is assessed further in the assessment of effects on tourism in Section 15.9 and further information on the consideration of project design evolution and mitigation is provided in Chapter 2, Section 2.4 of this document.
Dover District Council Appendix 1 - Work Plans (sheets 15/18 and 17/18) – Details of temporary closures of PRoW were shared with details needed regarding temporary closure of PRoW councils during May 2015. During a meeting to discuss and any temporary suspension of navigation rights. general approach to the management of PRoW, a
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Consultee Comments and considerations How addressed in this ES
hierarchy of mitigation was agreed and is considered further through this assessment of PRoW and cycle routes in Section 15.10.
Hillreed/Persimmon Supporting of the increased separation distance This housing allocation has been considered as part of the Homes – Hersden between housing and the route when compared to assessment of future land uses in Section 15.14 and Housing Site existing 132kV. when considering cumulative effects at Section 15.16.5.
Nethergong Camping 1. Pylon just 120m from nearest tent. Concerns over Taking into consideration feedback received and visual, noise (hot spells and damp conditions). constraints in this area, a design review was undertaken of the pylons in the vicinity of Nethergong Campsite. Pylon 2. Detrimental effect on the future potential of the locations have been altered in this location and the business. Top Site in the UK for foraging (Independent alignment in the location of pylon PC28 has moved further on Sunday) and Top 75 Family Sites in UK (Cool north and east, away from Nethergong Campsite. The Camping). route of pylons PC26 and PC27 has been maintained due 3. Will stop plans for expansion and diversification. to other constraints to be considered in this area, however, 4. Wider indirect effect – campers using local post office pylon PC 27 has been moved further north and east from stores, pubs and activities at least once during a stay. the campsite. 2013 survey estimates £250,000 spent in East Kent by This design change moves the route as far north as campers. possible without impacting on other environmental 5. No other similar campsite this side of Tunbridge receptors. Wells. 6. Reviews drive their business and it will suffer on first The potential effect of the proposed development on negative review about pylons. Nethergong Campsite is considered further in the assessment of effects on tourism in Section 15.9. Further information on the consideration of project design evolution and review process is provided in Chapter 2, Section 2.4 of this volume.
Natural England The final ES should consider potential impacts on Consideration is given to these receptors under the broad access land, public open land, rights of way and coastal heading of Recreation in Section 15.9. access routes. Consideration should also be given to the North Downs Way National Trail.
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Consultee Comments and considerations How addressed in this ES
Reference to relevant PRoW Improvement Plans to The North Downs Way National Trail routes south east identify PRoW that should be maintained or enhanced. from Canterbury and is therefore not considered as part of the assessment.
Robin Hood Events Consultation suggests the operation would not be able The potential effects of the proposed development on this to continue on the current site with the presence of the business have been considered in Section 15.9 with overhead line. This is largely a perception of customer consideration given to the current lease arrangement and issue rather than a safety issue. feedback from the operator. Suggestion that it’s not an ideal site due to access and nuisance from the waste site. Lease up in 2016.
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Other non-statutory engagement 15.4.6 Socio-economic and recreation topic specific meetings were held on 16 June 2014 and 15 May 2015 with relevant officers from KCC, DDC and TDC. The scope of these meetings included: the proposed method for baseline data collection: in particular PRoW/recreational route count surveys; community and recreation receptors of interest; and approach to mitigation in relation to potential impacts on the PRoW network.
15.5 Overall socio-economic baseline 15.5.1 The socio-economic baseline has been considered at two spatial levels, reflecting the proposed study area for the assessment, as defined below. Local Study Area: The Local Study Area utilises data from Lower Super Output Areas (LSOAs); geographic areas in England and Wales designed to improve the reporting of small area statistics. The Local Study Area as defined comprises those LSOAs through which the development passes. However, LSOAs are at a larger geographic scale than the Order limits. Therefore the Local Study Area covers a greater area than the Order limits as illustrated on Figure 15.1 within Volume 5, Document 5.3.15. Wider Study Area: The Wider Study Area covers the KCC administrative boundary. This seeks to address potential socio-economic effects within the broader area. The Wider Study Area has been largely analysed through suitable secondary data and used to provide a more general socio-economic overview. 15.5.2 For the purposes of the assessment and to assist with reporting, the route of the proposed development has also been divided into four sections; A, B, C, and D. Their definitions can be found in Chapter 2, Paragraphs 2.4.74 to 2.4.77. 15.5.3 This baseline is intended to provide an overview of the key socio-economic characteristics in the Local Study Area, providing comparison to the Wider Study Area, the South East region, and England. A more detailed baseline of specific receptors relevant to the proposed development is set out within the assessment. 15.5.4 The baseline conditions have been informed by site visits and a review of third party data from published sources. It is recognised that the baseline may not list all receptors within the study area, however it includes all identified receptors from the review undertaken and is considered representative of the baseline at the time of the site visits and review of data. 15.5.5 The proposed study area is shown on Figure 15.1 (within Volume 5, Document 5.3.15) with the administrative areas within the defined Local Study Area outlined in Table 15.4 .
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Table 15.4 Local Study Area definition
Local Authority LSOAs
Canterbury City Council Canterbury 010C Canterbury 010D Canterbury 011B Canterbury 011C Canterbury 011D Canterbury 011E Canterbury 013C
Dover District Council Dover 001A Dover 001C
Thanet District Council Thanet 014A Thanet 014B Thanet 014C Thanet 014D
Source: ONS LSOA date, 2015 15.5.6 According to 2011 census data, the Local Study Area’s population was 21,000; this represents only 1% of the Wider Study Area’s total population. Whilst the Local Study Area covers parts of Canterbury, Dover and Thanet, it is relatively rural and hence the population is relatively small. Table 15.5 provides more context, and compares the population of the Local Study Area to those of the Wider Study Area, the South East region and England. 15.5.7 The table also presents data on population growth and shows that the Local Study Area’s population grew by 11% between 2001 and 2011, broadly in line with growth in the Wider Study Area (10%) and above growth in the South East region and England (both 8%).248
Table 15.5 Population
Area Population Population Growth 2001 – 2011
Local Study Area 21,000 11%
Wider Study Area 1,463,700 10%
South East 8,634,800 8%
England 53,012,500 8%
Source: ONS, Census of Population, 2001 and 2011
248 Office for National Statistics, Census of Population, 2001 and Census of Population, 2011
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15.5.8 The rural nature of the Local Study Area is reflected through analysis of population density data which shows how it significantly differs from the Wider Study Area, South East region and England as a whole. 2011 Census data shows that the population density in the Local Study Area was only 1.5 persons per hectare whilst the population densities for the Wider Study Area, the South East region and England are all above four persons per hectare. This is shown in Table 15.6.249
Table 15.6 Population density
Area Population Density (persons per hectare)
Local Study Area 1.5
Wider Study Area 4.1
South East 4.5
England 4.1
Source: ONS, Census of Population, 2011 15.5.9 The age distribution of residents in the Local Study Area is broadly similar to the age distributions of the Wider Study Area, the South East region, and England, although it is notable that the Local Study Area does have a slightly higher proportion of its population aged 65 and over, at 20% compared to 16% in England as a whole. From a socio-economic standpoint, the data shows a similar proportion of the population are of working age in the Local Study Area as in the broader economy. This can be seen in Graph 15-1: Age distribution249.
249 Office for National Statistics, Census of Population, 2011
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Graph 15-1: Age distribution
100% 90% 20% 18% 17% 16% 80% 70% Age 0 - 15 60%
50% 62% 63% 64% 65% Age 16 - 64 40%
% of Population of % 30% Age 65 + 20%
10% 18% 19% 19% 19% 0% Local Study Area Wider Study Area South East England
Source: ONS, Census of Population, 2011 15.5.10 Qualifications and skills in the Local Study Area can be analysed through the 2011 census data, at National Vocational Qualification (NVQ) Levels which correspond with qualifications from GCSE level through to university degrees, and other types of qualifications such as apprenticeships. These are recorded for people aged between 16 and 64 and are summarised in Graph 15-2: Qualification level comparison. This shows the different types of NVQ qualifications, with the percentages of people who obtain these as their highest qualification.
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Graph 15-2: Qualification level comparison
Source: ONS, Census of Population, 2011 15.5.11 When compared to the qualification levels in the Wider Study Area and England, the Local Study Area performs relatively well, although it performs worse than the South East region in relation to the higher education Level 4 qualifications. Despite this, with respect to Level 3 qualifications, the Local Study Area (14%) outperforms the Wider Study Area (12%), the South East (13%) and England (12%). With regard to apprenticeships and other qualifications, the Local Study Area performs in line with the wider areas. However, in the Local Study Area, 24% of the working age population do not have any qualifications; a higher proportion than the Wider Study Area (22%), South East Region (19%) and England (22%)249. 15.5.12 The Index of Multiple Deprivation (IMD)250is a study of deprivation within English local councils, completed at an LSOA level. The Index covers seven aspects of deprivation: income, employment, health deprivation and disability, education skills and training, barriers to housing and services, crime and living environment. The Local Study Area consists of 13 LSOAs in the Canterbury, Dover, and Thanet districts; analysis shows that eight of these areas lie within the top half of most deprived areas in England, whilst five of the areas lie within the bottom half of most deprived areas in England. However, there are no LSOAs in the Local Study Area which lie in the least deprived quartile. Therefore, the study area has low levels of relative deprivation by English standards. 15.5.13 Analysis of economic activity provides an insight into the available labour force in an area. It involves looking at the percentage of people aged between 16 - 74 who are full-time and part-time employees, self-employed workers, full-time students and unemployed. The Local Study Area has a relatively similar age distribution structure to the Wider Study Area, the South East region, and England, with approximately two thirds of its population aged between 16 and 74. However, when looking at how many of these people are economically active, it is notable that the Local Study Area
250 Department for Communities and Local Government, English Indices of Multiple Deprivation, 2010
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has a lower percentage than its comparators. Only 67% of those aged between 16 and 64 in the Local Study Area are economically active compared to the Wider Study Area (72%), the South East (72%) and England (70%). It is considered that this reflects the higher level of retirement across the Local Study Area, which is 17% compared to 14% across the broader area249. 15.5.14 With regards to businesses in the Local Study Area, analysis of 2014 UK business counts251 provides comparisons between the sectoral make-up of the Local Study Area’s economy, and those of the Wider Study Area, the South East and England. The analysis shows a localised concentration of agriculture, forestry and fishing sectors; 10% of businesses in the Local Study Area operate within these sectors, compared to the Wider Study Area (4%), South East region (3%) and England (4%) as well as motor trades; 7% of businesses in the Local Study Area compared to 3% in the Wider Study Area, South East Region and England respectively. This reflects the largely rural nature of the Local Study Area and the concentration of motor trades around Canterbury. For example, there are relatively few businesses operating in the professional, scientific and technical sector in the Local Study Area (11%) compared to the Wider Study Area (15%), the South East region (18%) and England (16%). With the exception of these differences, the distribution of businesses across sectors in the Local Study Area is similar to those of the Wider Study Area, the South East region and England as shown in Table 15.7.
Table 15.7 Business Sectors in the Study Area
Local Study Wider Study South Area Area East England
1 : Agriculture, forestry & fishing (A) 10% 4% 3% 4%
2 : Mining, quarrying & utilities (B, D and E) 1% 1% 1% 1%
3 : Manufacturing (C) 6% 5% 5% 5%
4 : Construction (F) 13% 13% 11% 10%
5 : Motor trades (Part G) 7% 3% 3% 3%
6 : Wholesale (Part G) 4% 5% 4% 5%
7 : Retail (Part G) 8% 10% 9% 10%
8 : Transport & storage (including postal) (H) 3% 3% 3% 3%
9 : Accommodation & food services (I) 6% 6% 6% 6%
251 Office for National Statistics, UK Business Counts, 2014
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Local Study Wider Study South Area Area East England
10 : Information & communication (J) 4% 6% 9% 7%
11 : Financial & insurance (K) 0% 2% 2% 2%
12 : Property (L) 3% 3% 3% 4%
13 : Professional, scientific & technical (M) 11% 15% 18% 16%
14 : Business administration & support services (N) 6% 7% 8% 7%
15 : Public administration & defence (O) 0% 1% 1% 1%
16 : Education (P) 2% 3% 3% 2%
17 : Health (Q) 5% 6% 5% 6%
18 : Arts, entertainment, recreation & other services (R, S, T and U) 6% 6% 7% 7%
Source: ONS, UK Business Counts, 2014
15.5.15 Tourism is a sector of particular importance in the Wider Study Area, providing jobs for approximately 52,000 employees, equivalent to 8% of the region’s work force. Despite this importance, the area surrounding the proposed development has a generally low proportion of tourism receptors, with the exception of Canterbury itself. 15.5.16 In 2011, with the addition of multiplier effects, tourism generated approximately £3 billion in turnover in the Wider Study Area, whilst the sector’s turnover in England for the same year was around £30 billion. As shown in Table 15.8, it is estimated that the expenditure associated with domestic overnight trips in Kent and Medway was approximately £588 million in 2011252. The table provides a summary of the distribution of this spending across Canterbury, Dover and Thanet.
252 Tourism South East (TSE), The Economic Impact of Tourism on Kent and Medway Estimates for 2011, December 2012
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Table 15.8 Tourism expenditure in Kent and Medway
Area Domestic Percentage of Overseas Percentage of Kent’s expenditure Kent’s domestic expenditure overseas tourism (£) tourism (£) expenditure expenditure
Kent and £588m n/a £272m n/a Medway
Canterbury £64.7m 11% £62.8m 23%
Dover £58.8m 10% £21.8m 8%
Thanet £64.7m 11% £34.6m 12%
Source: Tourism South East, ‘The Economic Impact of Tourism on Kent and Medway Estimates for 2011’, December 2012 15.5.18 From Table 15.8 it can be seen that overseas visitor expenditure in Kent and Medway was less than half of domestic expenditure in 2011, valued at £272 million. The distribution of spending across Canterbury, Dover and Thanet shows differences, with Canterbury receiving a much larger share of expenditure from overseas visitors, reflecting the prominence of Canterbury as one of the main tourist destinations in the area in terms of accommodation and visitor attractions.
15.6 Embedded environmental measures incorporated into the proposed development 15.6.1 The proposed development includes a range of embedded environmental measures (see Appendix 3B within Volume 5, Document 5.4.3B). Those relating to the proposed development’s effects on socio-economic receptors are discussed in Table 15.9. From a socio-economic perspective, these are measures which are taken into account in the assessment of socio-economic receptors. These environmental measures should be read alongside the proposed development description set out in Chapter 3 along with measures set out in Chapter 14 which seek to reduce effects on agricultural land.
Potential receptors 15.6.2 The assessment considers all socio-economic or recreation receptors that would be potentially affected by the proposed development. This includes both direct effects and indirect amenity effects. On this basis, the socio-economic and recreation receptors considered in this Chapter can be separated into the following broad categories:
tourism253;
253 Tourism includes accommodation, eateries and tourism activities.
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public rights of way and cycle routes; community infrastructure; other businesses; agricultural land; and employment land allocations and other emerging developments.
15.6.3 Within these broad receptor categories, all receptors are considered for direct effects and indirect amenity effects.254 The exception is other businesses where the assessment identifies a subset of sensitive business receptors as those businesses which are considered to place an indirect amenity value on their surroundings, which could be affected by the proposed development. 15.6.4 Business receptors along the route have been identified where it is deemed their socio-economic outputs are more likely to be sensitive to changes in amenity; for example, a specialist manufacturing businesses which requires negligible background vibration for their manufacturing processes. 15.6.5 Potential sensitive business receptor sectors include: performing arts facilities; recreation and sport facilities; advanced manufacturing; and
moving picture and sound recording.255 15.6.6 The above scope has evolved through the development of this ES and reflects comments received through the formal scoping process, as well as Statutory Consultation. 15.6.7 A full list of the receptors considered under each of the broad categories is contained in Appendix 15A within Volume 5, Document 5.4.15A. This presents a long list of receptors identified through desk based and site based work as having the potential to experience effects from the proposed development. Specifically in relation to business receptors, the long list also draws upon data from the Experian B2B Prospector which details the types of business and their location. This data has also been mapped on Figure 15.4 within Volume 5, Document 5.3.15 in order to show the distribution of businesses within the area surrounding the proposed development. From this Prospector we have also been able to distinguish between sensitive businesses and other businesses (also shown on Figure 15.4). The potential of these sensitive businesses to experience an indirect amenity effect has then been assessed utilising data from the ZTVI as shown in Figure 15.5 within Volume 5, Document 5.3.15. 15.6.8 In order to focus the scope of the assessment, the long list of receptors identified has been distilled into a short-list which forms the focus for the assessment of effects
254 An indirect/amenity effect relates to the benefits and wellbeing that users gain from using a resource for its intended function. 255 Note: These sectors are based on SIC code sector definitions as used in the Experian B2B business data.
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within this Chapter. This process is summarised in Appendix 15A within Volume 5, Document 5.4.15A.
Table 15.9 Proposed embedded environmental measures
Potential Predicted Incorporated measure receptor changes and potential effects
Businesses The use of roads Construction would be planned so that access to and by construction socio-economic receptors would be maintained. community traffic, could lead to Examples include night time scaffolding over facilities restricted access to roads to avoid disruption and temporary socio-economic diversion of PRoW in order to allow continued receptors. use and access.
Users of Temporary closure A hierarchy of mitigation has been discussed PRoW of PRoW could and agreed with the relevant LPAs which seeks network restrict access. to manage closures where possible (e.g. scaffold and manned crossings) retaining rights of way as per current routes. Further detail on this can be found in the PRoW Management Plan (see Appendix 3H within Volume 5, Document 5.4.3H). Where this is not possible diversion routes for PRoWs effected have been identified and are shown on Access and Rights of Way Plans in Volume 4, Document 4.7. Although National Grid will therefore seek to minimise disruption to users wherever possible, in line with the PRoW Management Plan, the DCO would provide National Grid the powers to stop up PRoW and implement diversions as submitted if necessary.
The The proposed Construction works, where the route crosses the Canterbury to development’s Canterbury to Ramsgate railway line, would be Ramsgate rail overhead crossing scheduled so that disruption is minimised and line of the Canterbury rail services are unaffected. This would include to Ramsgate rail works scheduled for times when rail services are line, during not operating. construction, could cause temporary disruption to rail services and users in the Local Study Area.
Landowners The proposed The design review process included a series of development could discussions with landowners in order to ensure cause effects on that such effects are minimised through careful landowners routeing and pylon positioning. through siting of
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Potential Predicted Incorporated measure receptor changes and potential effects
pylons and land- take.
Users of the The proposed Temporary bridges will be built to the height of River Stour development the lowest existing structure. for navigation through use of Advance notice of works to be circulated temporary bridges through local access groups. could cause Advance signage of any temporary structure to disruption to users be placed along the river. of this waterway. Emergency mooring facilities to be installed in order to provide refuge should users require during periods of closure.
15.7 Scope of assessment
Spatial and temporal scope 15.7.1 The spatial scope of the socio-economic assessment primarily focusses on the Order limits as the area within which changes to socio-economic receptors are most likely to occur. 15.7.2 In addition, the assessment considers broader potential economic effects within the wider local and regional economy, as well as indirect amenity effects which are considered for sensitive receptors within the Zone of Theoretical Visual Influence (ZTVI). This is shown on Figure 15.5, within Volume 5, Document 5.3.15 and is consistent with the data shown on Figure 7.2 within Volume 5, Document 5.3.7. 15.7.3 Construction of the proposed development is planned to commence in Summer 2017 (subject to the appropriate consents being granted) with the new connection to be commissioned in October 2018. 15.7.4 Based on these dates, the Socio-economic assessment has been based on the following temporal scope: the existing socio-economic and recreation baseline in 2014/2015 (or latest published data); the effects of the proposed development during a construction period of Summer 2017 to Autumn 2018 for the new 400kV overhead line; the effects of the proposed development during a construction period of Autumn 2019 to Spring 2021 for the dismantling of the existing PX route overhead line; the effects of the proposed development during operation of both the new 400kV and existing PX route overhead line (Autumn 2018 to Spring 2021); the effects of the proposed development during operation of the 400kV line following dismantling and removal of the existing PX route overhead line (post Spring 2021); and
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the effects of the proposed development during decommissioning of the 400kV line. 15.7.5 Further information in relation to the construction programme is provided in Chapter 3 within this document.
Potentially significant effects 15.7.6 As part of the assessment, it is considered that the following effects have the potential to be significant and therefore are progressed to formal assessment in order to establish their likely significance (see Sections 15.9-15.15). Effects on tourism receptors (including accommodation, eateries and tourism attractions) during construction (including dismantling of the PX route), operation and future decommissioning: During all phases there could be direct effects on any such receptors within the Order limits. There could also be indirect amenity effects on receptors during all phases of the development. Effects on the local community and other users of the PRoW network due to temporary severance or closure of access during construction (including dismantling of the PX route) or future decommissioning: Construction access routes or working areas may temporarily sever PRoW and/or local roads. Effects on users of the River Stour for navigation purposes due to construction of the temporary bridge crossings and 400kV conductor stringing works: there would be short periods of access restrictions for certain works during construction and future decommissioning. Effects on land owners and tenants due to temporary land take for construction, PX route dismantling and future decommissioning activities: Access to the pylon locations will be made via temporary access routes and working areas will be established around the proposed pylon locations leading to temporary land take. These construction requirements would render land temporarily unusable. Effects on land owners and tenants of agricultural land due to permanent land take (new infrastructure) or land gain (removal of the PX route): The proposed development would lead to some permanent land take with the areas occupied by the pylon footprint deemed unusable for arable agriculture. There may be some land gain through the removal of the PX route where areas currently under pylons are returned to agriculture. Effects on land owners and tenants of agricultural land as a direct result of maintenance activities: Maintenance during the operational phase of the scheme would require land access and therefore may disrupt land use for owners and/or tenants. This is expected to be minimal due to the infrequent maintenance requirements of the proposed development. Effects on future land uses in the surrounding area: The proposed development has the potential to affect the viability and/or delivery of allocations in the Local Plan either through direct effects (e.g. temporarily or permanently rendering part of a site undevelopable) or indirect amenity effects (e.g. through affecting the overall desirability of the site by affecting the amenity value). The proposed development also has the potential to temporarily delay or prevent development not included as part of the local plan during construction. The operational phase
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has the potential to prevent or effect viability/desirability of development not included as part of the local plan should the proposed development run through land identified for future development or limit the potential of future development due to amenity effects. Effects on the local and regional economy due to construction employment and spend on construction materials: Construction of the proposed development would lead to direct positive effects such as employment opportunities within the construction sector, as well as supply chain opportunities associated with specialist services (e.g. ground works) and/or construction materials (e.g. quarried stone). Effects on local businesses associated with local spend during construction: Construction activities have the potential to lead to indirect or catalytic economic benefits in the form of increased local spend associated with construction workers staying within the local area (accommodation costs) and construction worker spend in local facilities (e.g. eateries and convenience stores). Effects on the local and regional economy due to the generation of permanent additional employment or permanent loss of employment within businesses or tourism resources: The operational phase of the proposed development has the potential to generate a small amount of indirect employment locally and/or support employment through spend associated with maintenance activities and maintenance personnel in the local area. Effects on the local and regional economy due to indirect or catalytic economic effects during operation: The operational phase of the proposed development may lead to some limited supply chain opportunities within the local or regional economy through induced spend from those employed to maintain the proposed development. Such spend will be proportionate to the anticipated minimal maintenance requirements. Inter-related effects 15.7.7 The following potential inter-related effects are considered as part of this assessment: Effects on the users of community infrastructure from construction activities (e.g. effects of noise, construction traffic, air quality and visual intrusion). Construction and decommissioning processes have the potential to affect the amenity of various receptors. The detailed assessment of visual, traffic, noise and air quality effects is provided in Chapters 7, 10, 11 and 12 within this document respectively. However combined amenity effects on specific receptors of amenity value are considered as part of this Chapter. This effect would be limited to receptors deemed to have a positive amenity value (a receptor which benefits from its surroundings, for example tourism resources, outdoor community resources and specialised manufacturing) and will not be considered for all identified socio-economic resources. Effects on the users of community infrastructure as a result of other permanent environmental effects (e.g. visual, noise): These will be considered with reference to the amenity value of a resource or receptor. Given the often subjective value placed on resources by individuals, the approach to assessing amenity will work
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closely with other environmental disciplines (e.g. landscape and visual, transport and noise) in order to draw conclusions. Effects on businesses (excluding those related to tourism) from construction activities. Construction processes have the potential to affect the amenity of these receptors. This effect would be limited to receptors deemed to have a positive amenity value (a receptor which benefits from its surroundings) and will not be considered for all identified socio-economic resources. This assessment will consider the effects that could arise once the 400kV overhead line is operational and the dismantling of the PX route is taking place. Effects on businesses (excluding those related to tourism) as a result of other permanent environmental effects (e.g. visual, noise): These will be considered with reference to the amenity value of a resource or receptor. Given the often subjective value placed on resources by individuals, the approach to assessing amenity will work closely with other environmental disciplines (e.g. landscape and visual, transport and noise) in order to draw conclusions. Cumulative effects 15.7.8 Potential for cumulative effects is provided through an assessment at Chapter 16 and includes potential cumulative effects of the proposed development together with other identified major development proposals that were scoped in to the assessment (see Chapter 5, Table 5.1 within this document). 15.7.9 From a socio-economic and recreation perspective, potential cumulative effects are considered to be limited as follows: Construction employment: A number of strategic projects have been identified as part of the assessment of future land uses and collectively these could bring cumulative effects in relation to demand and employment of construction staff. Accommodation bedspaces: A proportion of the staff employed on the proposed development will be housed within existing accommodation in the local area. Occupancy of these bedspaces alongside similar occupancy from other major projects could lead to cumulative effects on the availability of accommodation in the local area.
Scoped out effects 15.7.10 The Scoping Report and PEIR identified a number of effects to be scoped out of the EIA, as desktop studies and initial site work considered that they were unlikely to be significant and therefore not subject to further assessment. The socio-economic issue that has been scoped out of this assessment is as follows. Effects on property prices. This is not a matter that requires assessment under the EIA Regulations and is not a material consideration in the determination of planning merits of the proposal. An assessment of effects on house prices has not been required on other similar NSIP projects and the SoS, through the Scoping Opinion agreed that the matter can be scoped out of the assessment.
Assumptions 15.7.11 The following assumptions should be noted with respect to this socio-economic assessment.
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Construction employment data has been provided by National Grid and is based on experience on similar projects elsewhere in the UK and is considered to represent the most accurate way of assessing potential employment benefits of the proposed development. The findings of a National Grid Study into the effects of National Grid major infrastructure projects on socio-economic factors256 have been used to inform the assessment of perceived effects, particularly in relation to business and recreational effects. The key findings of this study relate to perceived effects of National Grid major projects diminishing as they go through the development process. Moreover, the study finds that a majority of businesses and recreational users do not perceive there to be an impact from National Grid projects on their own business/personal behaviour. Indirect amenity effects have been assessed based on the findings of other related assessments including visual, traffic, noise and air quality effects provided in Chapters 7, 10, 11 and 12 within this document respectively. The timescales referred to within the assessment are based on the construction programme at the time of writing. This may change during detailed design once a main contractor has been appointed.
15.8 Assessment methodology
Methodology for prediction of effects 15.8.1 There is no definitive guidance on significance criteria for socio-economic effects; as such the assessment draws on existing industry accepted practice. The focus of the assessment is on determining whether effects would change patterns of activity; social or economic. The assessment methodology should be read in conjunction with the scope of the socio-economic assessment which is outlined in the previous section. 15.8.2 The significance of a socio-economic effect has been determined by assessing both the magnitude of the effect and the sensitivity of the receptor. 15.8.3 The magnitude of an effect represents its severity. Key factors to be considered when assessing magnitude include the extent (number of groups and/or individuals257, or businesses affected) and the value of the resource. For example, an effect on a heavily trafficked PRoW which is part of a National Trail would have a higher magnitude than an effect on a less trafficked local PRoW. Table 15.10 details the guideline criteria for assessing the effect magnitude. 15.8.4 Only those receptors deemed to lie within the Order limits are expected to experience direct effects. This approach ensures that potential direct construction effects (e.g. where receptors interact with construction access routes and construction compounds) and potential direct operational effects (e.g. where a receptor interacts with the overhead line are considered. Given this, the majority of the socio-economic
256 ERM, Imperial College London, Ipsos MORI, and Bridge Economics, Imperial College London and ERM (2014), A Study into the Effect of National Grid Major Infrastructure Projects on Socio-economic Factors 257 For the purposes of the assessment individuals refers to users of a receptor/resource (e.g. a PRoW or community facility) and does not include individuals in the sense of residential properties.
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assessment explores potential indirect amenity effects on receptors. This assessment focuses on receptors located within the Zone of Theoretical Visual Influence (ZTVI) which have the potential to experience indirect amenity effects. The ZTVI provides a search area within the Wider Study Area in which indirect amenity effects would be expected to occur. Direct and indirect amenity effects are therefore assessed based on separate magnitude criteria, which are each set out in Table 15.10 and Table 15.11.
Table 15.10 Magnitude of effects – direct effects
Magnitude Criteria of effects
High An effect that would be adverse/beneficial and very likely to affect a large number of businesses, groups or individuals. An economic resource with a total of 50 full time employees. A social resource which is considered nationally significant (e.g. National Trail).
Medium An effect that would be adverse/beneficial and that is likely to affect a moderate number of businesses, groups or individuals. An economic resource with a total of 25 full time employees. A social resource which is considered regionally significant (e.g. Regional Trail or Long Distance Route).
Low An effect that would be adverse/beneficial and that is likely to affect a small number of businesses, groups or individuals. An economic resource with a total of five full time employees. A social resource which is considered to be locally significant (e.g. public footpath or community centre).
Negligible An effect that is anticipated to have a slight or no effect on the operation of businesses or the well-being of individuals.
15.8.5 The assessment will consider both economic and social resources. It should be noted that, given the context of the Order limits being mainly agricultural land, land use is considered as an economic resource for the purposes of the assessment. 15.8.6 The above framework is considered suitable for assessing direct effects (where the route directly encroaches on a resource) and isolation effects (where the route prevents access to a resource such that its activity level is affected). However, a different approach is taken for indirect amenity effects. 15.8.7 An indirect amenity effect relates to the benefits and wellbeing that users gain from using a resource for its intended function. For example, a hotel renowned for its views and gardens would have a positive amenity value. More specifically, the amenity value of a resource may be affected by a combination of factors such as: air quality, noise and vibration and traffic. As such, the indirect amenity assessment draws on the conclusions from other assessments which could lead to a socio- economic effect.
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15.8.8 The approach to determining the magnitude of an indirect amenity effect is summarised in Table 15.11.
Table 15.11 Effect magnitude – indirect amenity effects
Effect magnitude Criteria (amenity)
High Two or more residual significant effects are identified where both are major in nature.
Medium Two residual significant effects are identified with one being major in nature.
Low Two residual significant effects are identified with both being moderate or less in nature.
Negligible One or no significant residual effects identified.
15.8.9 The sensitivity of a receptor relates to the scope for the receptor to overcome an effect. For example, an effect on a distribution facility owned by a firm with multiple premises in the local area with spare capacity would be viewed as less sensitive than an equivalent firm for which the affected distribution facility is its only property. The criteria for sensitivity are the same for both direct and indirect amenity effects. Table 15.12 details the guideline criteria for assessing the receptor sensitivity.
Table 15.12 Receptor sensitivity
Receptor Criteria Sensitivity
High Businesses, individuals or groups who are at risk and that have little or no capacity to experience the effect without incurring a material loss (or gain).
Medium Businesses, individuals or groups who are at risk and that have some capacity to experience the effect without incurring a material loss (or gain).
Low Businesses, individuals or groups who are at risk and that generally have capacity to experience the effect without incurring a material loss (or gain).
15.8.10 Sensitivity is a key dimension to the assessment of indirect amenity effects. This can be illustrated by considering an adverse visual effect on two different receptors258. For a tourism business the visual effect could have a negative effect on activity whereas for a distribution company the effect would not be expected to affect
258 When considering indirect amenity, the assessment does not include individual residential properties unless they have a business function which is considered to have an amenity value (e.g. B&B accommodation).
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business activity. As such, the sensitivity for the amenity assessment is essentially a binary choice; either a resource is sensitive to amenity effects or it is not. Sensitive resources would be expected to largely comprise tourism resources, outdoor community resources and specialised manufacturing which is sensitive to noise/vibration effects as detailed in Paragraph 15.7.2. 15.8.11 When a resource is considered to be sensitive to indirect amenity effects and is subject to a high or medium magnitude effect, the overall amenity effect is deemed to be significant.
Significance evaluation methodology 15.8.12 The significance of a socio-economic effect is determined by combining both the magnitude of the effect and the sensitivity of the receptor. The approach to determining significance is summarised in Table 15.13.
Table 15.13 Determining significance
Magnitude of effect Sensitivity of receptor High Medium Low Negligible
Moderate Major adverse/ Major adverse/ Minor adverse/ adverse/ High beneficial – beneficial – beneficial – not beneficial – significant significant significant significant
Moderate Major adverse/ Minor adverse/ adverse/ Negligible – not Medium beneficial – beneficial – not beneficial – significant significant significant significant
Moderate Minor adverse/ adverse/ Negligible – not Negligible – not Low beneficial – not beneficial – significant significant significant significant
15.8.13 As set out in the socio-economic section of the EIA Scoping Report, the following have not been included in the ES socio-economic assessment: Business survey: The potential for using a business survey to support the assessment of business effects has been scoped out. Whilst business surveys can be used to help with socio-economic assessment, there are two reasons for scoping this out in this instance: first, the nature of the area and the proposed development is such that few businesses would be directly affected by the scheme. Second, the survey should only be used to provide information on the extent of business operations; such data has been obtained from a secondary source (Experian) for the purposes of this assessment instead of undertaking business surveys. No quantitative assessment on tourism has been undertaken in line with the Scoping Opinion from the SoS (see Paragraph 3.10). The assessment does however utilise available tourism data and published studies and applies
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professional judgement to reach conclusions. The assessment has provided a qualitative assessment of the effects on tourism, focussing on tourism related businesses that could be affected by the proposed development along with amenity effects to tourism and recreation resources. 15.8.14 As described in Section 15.7, the assessment initially considered a long list of receptors that were identified through the baseline work. Through an initial assessment as detailed in Appendix 15A within Volume 5, Document 5.4.15A, this long list has been distilled to a short-list of receptors, focussing the assessment on those receptors with the potential to experience significant effects, together with socio-economic receptors of particular importance to the local economy. The full list of receptors and assessment conclusions can be found at Appendix 15A. 15.8.15 Business receptors included within the assessment are those identified through the baseline which are considered to have the potential to experience direct effects or indirect amenity effects. For the purpose of the indirect amenity assessment a sensitive business has been defined as one which benefits from its surroundings and whose socio-economic activities are likely to be sensitive to changes in amenity. Reference is made where necessary to Figure 15.5 within Volume 5, Document 5.3.15 and other Chapters of the ES.
Order limits and Zone of Theoretical Visual Influence 15.8.16 Only those receptors deemed to lie within the Order limits see Chapter 3, Paragraph 3.1.3) are expected to experience direct effects. This area, which contains the LoD (see Paragraphs 3.1.4 to 3.1.6) is considered to represent the area over which construction, operational and decommissioning development activities would take place. 15.8.17 Moreover, the assessment also considers receptors located within the ZTVI which have the potential to experience indirect amenity effects (see Figure 15.5 within Volume 5, Document 5.3.15). The ZTVI provides a search area within the Wider Study Area in which indirect amenity effects would be expected to occur.
15.9 Assessment of effects: tourism
Predicted effects and their significance 15.9.1 The assessment of effects on tourism receptors (including accommodation, eateries and tourism attractions) explores potential direct effects on those receptors within the Order limits and potential indirect amenity effects on tourism receptors located within the ZTVI. For each Section (A-D), the assessment highlights the type of receptor within close proximity to the route prior to considering potential effects. Specific reference is made to a receptor where they lie within the Order limits and therefore have the potential to experience direct effects, or where there is potential for indirect amenity effects (e.g. where other Chapters have drawn conclusions in relation to effects on a given receptor). Where receptors fall outside one of these scenarios, the assessment makes broad conclusions for all receptors within the given Section. Section A – Stour Valley 15.9.2 A number of tourism receptors were identified in Section A including: Robin Hood Events at Goose Farm;
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Broad Oak touring caravan park; Royal Oak Pub; and Bluebell Wood Park. 15.9.3 With the exception of Robin Hood Events, these receptors lie outside the Order limits and therefore no direct construction, operational or decommissioning phase effects are predicted. 15.9.4 Robin Hood Events lies within the Order limits and within close proximity to a construction access and could therefore experience potentially significant effects. 15.9.5 During construction any potential direct effects will be mitigated through careful construction programming, with the current construction programme proposing works which may affect the receptor proposed to be undertaken in the low tourism season. The magnitude of effect is considered to be medium and therefore not significant. 15.9.6 In assessing the amenity effects consideration has been given to conclusions drawn elsewhere in this ES. The landscape and visual assessment concluded a minor adverse, not significant effect on Goose Farm and no other disciplines concluded a significant effect on the receptor thus the amenity magnitude is negligible and the effect is not significant. 15.9.7 During the operational phase, it is considered that Robin Hood Events at Goose Farm could continue to operate in proximity to the proposed development, leading to no direct effects, although conversations with the current operator have suggested that the business may choose to seek an alternative site to avoid disruption from the proposed development. 15.9.8 As with the construction phase, no significant effects have been drawn in other ES Chapters and thus the amenity magnitude at Robin Hood Events is negligible and the effect is not significant. 15.9.9 Through consultation, the potential for perceived effects has also arisen in relation to the potential effect of the proposed development on business trade during operation. Concerns largely relate to the potential for repeat business. Previous research259 has explored the impact of National Grid infrastructure on socio-economic factors including businesses and recreational users. The research undertook a series of business and user surveys across a range of National Grid projects, including five projects that are already built (ex-post), two proposed projects (ex-ante) and two control locations. The surveys were undertaken following a review of available literature on the public perception of infrastructure development. 15.9.10 In considering effects on businesses, the research showed that the quantity of perceived impacts decreased as projects develop from hypothetical to ex-ante (before construction) and ex-post (after construction). Surveys also demonstrated that following project completion, levels of perceived impacts decrease rapidly as well as showing that respondents for ex-ante projects were found to have the highest levels of project awareness, attributed to increased levels of engagement by National Grid. The survey findings demonstrate that as the proposed development moves
259 ERM, Imperial College London, Ipsos MORI, and Bridge Economics and Imperial College London, (2014), A Study into the Effect of National Grid Major Infrastructure Projects on Socio-economic Factors
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from ex-ante to ex-post, perceived effects generally decrease with further reductions after project completion. 15.9.11 In reference to recreational users (tourists and visitors to a survey area), the research found that the majority of users indicated that a National Grid project would not affect their behaviour or spend in an area, even though respondents did perceive that negative impacts would occur. The most common of these perceived impacts was in relation to the landscape, although many respondents also highlighted a general dislike for infrastructure projects. 15.9.12 The evidence therefore suggests that increased familiarity and information in relation to proposed projects reduces the perceived effects with ex-post projects having notably less perceived effects. Section B – Sarre Penn Valley 15.9.13 Tourism and recreation receptors within Section B include: Nethergong Camping on Sandpit Hill to the north of Upstreet; Chislet Court Farm B&B; Stodmarsh National Nature Reserve; and The Hayloft B7B. 15.9.14 During construction these receptors would not experience any direct effects as they generally lie outside the Order limits. 15.9.15 There is the potential for indirect amenity effects at Nethergong Campsite due to the receptor’s proximity to the proposed development. In particular, there is a construction access route adjacent to the campsite which could have a significant indirect amenity effect. The campsite is located north of the A28, Island Road and just south of the Order limits. The existing PX route currently runs to the south of Nethergong Camping. 15.9.16 In assessing the amenity effects consideration has been given to conclusions drawn elsewhere in this ES. The landscape and visual assessment identifies a significant (moderate adverse) effect. The construction noise assessment does not draw a specific conclusion in relation to Nethergong Campsite as it is not a residential receptor, although it concludes that noise levels at the nearest residential property (Nethergong Farm) would not be significant in the daytime and night time (see Chapter 11, Section 11.9). Despite this it is acknowledged that some construction noise effects could be experienced by users of the campsite. Given this potential and taking a precautionary approach the amenity magnitude is low and receptor sensitivity high which lead to a potentially significant effect. 15.9.17 In order to avoid such an effect, the main construction activities for the area in close proximity to the campsite (pylons PC24-28) are proposed between January and May 2018, outside of the peak visitor season and within months when the campsite is closed (end of October to 1st April or Easter, whichever is first). While the stringing of the overhead line is planned to take place in July and August 2018, this activity creates less noise than those planned earlier in the year (e.g. pylon foundation works including piling). In addition, National Grid will be working to strict working hours and noise limits which will, in any case, limit the potential effect on users of the campsite. This is considered to reduce the likelihood of the receptor experiencing the effect, reducing the sensitivity to medium and therefore an effect which is not significant.
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15.9.18 During the operational phase, the tourism receptors identified in Section B would not experience significant direct effects as they lie outside of the Order limits. 15.9.19 As with the construction phase, only the landscape and visual assessment concludes a significant (moderate adverse) effect at Nethergong Camping during operation. The operational noise assessment concludes that operational noise levels are assessed as negligible during dry conditions and low adverse during wet conditions (see Chapter 11, Paragraph 11.15.20). Therefore, from a socio-economic perspective, the amenity magnitude is negligible and the effect is not significant. 15.9.20 In relation to indirect amenity effects National Grid have made every effort, through the design review process to liaise with receptors (e.g. Nethergong Camping) and position the proposed development as far away as possible, given other constraints and receptors in that location, in order to limit indirect effects. As described in Chapter 2 of this Volume at Paragraph 2.6.46 as part of the design review process at Nethergong (between pylons PC24 to PC28) a request was made to move the draft route further north of the Sarre Penn to minimise noise and visual effects on the residential properties and those camping at the campsite at Nethergong. This change was incorporated into the draft route. Taking on board feedback from the Statutory Consultation and other environmental considerations proposed pylon PC28 has been relocated further north and east, and positioning of pylon PC27 re-aligned reducing potential amenity effects on Nethergong Camping. It was not possible to move the route any further from the campsite in this location due to other environmental constraints. 15.9.21 Through consultation the potential for perceived effects has also arisen in relation to the potential effect of the proposed development on business trade during operation. Concerns largely relate to the potential for repeat business. Such concerns must be considered in the context of the existing baseline and published research. The campsite currently operates successfully with the smaller 132kV PX route located approximately 210m to the south. Although the removal of the PX route will offer some benefit to the amenity of the site, National Grid recognise the potential perceived effects of the proposed development given the different location, to the north of the campsite and the size of the pylons when compared to the existing infrastructure. 15.9.22 In considering this, the assessment takes into account previous research260 that has explored the impact of National Grid infrastructure on business and on recreational users. As described in Paragraphs 15.9.10 – 15.9.12 it is anticipated that such perceptions would decrease as the proposed development progressed from the ex-ante to ex-post and operational stages. The research also found that on the whole, the presence of National Grid infrastructure does not stop people from using a facility and that whilst some people may not return because of the presence of pylons, new people will continue to use the site. The assessment considers that Nethergong Camping could continue to operate successfully following completion of the proposed development. Section C – Chislet Marches 15.9.23 In Section C, tourism receptors include:
260 Ipsos MORI, Bridge Economics, Imperial College London and ERM (2014), A Study into the Effect of National Grid Major Infrastructure Projects on Socio-economic Factors
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The Rising Sun B&B;
Equestrian centre on Gore Street;
Sarre Windmill; and
Monkton Nature Reserve. 15.9.24 The tourism receptors in Section C are not expected to experience significant effects in either the construction or operational phases; the receptors do not lie in the Order limits and hence would not experience direct effects and the assessment results of other disciplines means receptors would experience negligible indirect amenity effects which are not significant. Section D – Ash Level 15.9.25 In Section D, key tourism receptors include: Foxhunter Park Caravan Park; Wayside Caravan Park; The River Stour navigation; and Richborough Fort and Roman Amphitheatre. 15.9.26 The majority of these receptors are not expected to experience significant effects in either the construction or operational phases. With the exception of parts of the River Stour navigation, the receptors do not lie in the Order limits and hence would not experience direct effects while the assessment results of other disciplines means receptors would experience negligible indirect amenity effects which are not significant. 15.9.27 In relation to the River Stour navigation the proposed development has the potential to effect navigation for visitors and local uses though a number of temporary restrictions for construction of temporary bridges and stringing of the new 400kV line. National Grid is working with the local user group who will be made aware of all short- term closures to the navigation and therefore when the works have greatest potential to affect users. 15.9.28 In the unlikely event that visitors haven’t contacted the local user group prior to using the navigation, National Grid will provide advance warning signs to make users aware of the works. In addition, National Grid also propose to provide emergency mooring facilities in order that vessels can stop prior to the works if required. This emergency mooring will take the form of a post on the river bank with a chain and buoy, enabling users to moor safely when temporary closures are in place. With temporary bridge structures being built to the height of existing bridges, and with the mitigation measures described it is considered that during operation the works are anticipated to bring a negligible effect to users of the navigation which is not significant. No new structures over the River Stour are proposed during operation and therefore no effects are predicted.
15.10 Assessment of effects: Users of PRoW and cycle routes 15.10.1 The assessment of effects on PRoW and cycle routes considers direct effects on the routes where they are crossed by the proposed development and/or affected during
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construction (e.g. used in full or in part as construction accesses or crossed by construction/dismantling access routes). The assessment also considers indirect amenity effects on receptors, particularly where they run parallel to the proposed development. When considering indirect amenity effects, the assessment has been completed in the context of the current baseline and the presence of pylons within the landscape (the PX route). 15.10.2 The assessment is made in the context of the PRoW Management Plan which is included at Appendix 3H within Volume 5, Document 5.4.3H. The Management Plan demonstrates a planned approach to the management of PRoW during the construction of the proposed development to ensure public safety while minimising disruption to users. A number of temporary PRoW closures are identified in all four Sections during construction. It is National Grid’s intention to keep the majority of PRoW’s open via management and use of short-term, temporary closures where absolutely necessary in order to balance the risks to the public against the potential disruption that removing such a risk would cause. 15.10.3 Through consultation with the Joint Councils a hierarchy of mitigation has been agreed which reflects this approach and seeks to manage closures where possible (e.g. scaffold and manned crossings) retaining rights of way as per current routes and seeking to minimise the effect on users. This hierarchy includes: use of signs to both PRoW users and construction vehicles to allow safe crossing of construction roads; Using contract staff to hold PRoW users for short periods (a few minutes) while vehicles pass or construction activities are undertaken; creation of short diversion, for example around scaffold tower or other work sites; and fully closing a PRoW and signing an acceptable diversion route. 15.10.4 Each of these measures is described in further detail within the PRoW Management Plan. No permanent closures are required as part of the proposed development. 15.10.5 Although the above hierarchy will be applied wherever possible, the assessment has considered a worst case with a need to divert PRoW at locations where they interact with construction activities. These potential diversions are shown in the Access, Rights of Way and Public Rights of Navigation Plans (see Volume 4, Document 4.7) and illustrate that a suitable diversion is possible in all locations. Although National Grid will therefore seek to minimise disruption wherever possible through management measures, in line with the PRoW Management Plan, the DCO would provide the powers to stop up PRoWs and implement diversions as submitted if necessary. 15.10.6 The complex nature of the construction programme means that PRoW could be affected in a number of ways, with different closure types proposed. Broad approaches are provided in Table 15.14 with full details provided in the PRoW Management Plan in Appendix 3H within Volume 5, Document 5.4.3H.
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Table 15.14 Proposed approaches to PRoW management / closure
Reason for closure Broad approach – Closure type
Road construction and removal Short-term managed with two day closures in the majority of locations. Short-term managed crossing with several week long closures with alternative route (diversion) provided. Long-term complete closure with alternative route (diversion) provided in one location.
Scaffold installation and removal Short-term managed closure with two day closures in the majority of locations. Long-term complete closure in one location for duration of the works.
Bridge construction Long-term complete closure with alternative route (diversion) provided for the duration of the works. Long-term managed with several week long closures.
Stringing of the 400kV Short-term managed with two day closures.
PY diversion Long-term managed with two day closures.
Install access for PX route Short-term managed closure with two day removal closures.
Destringing of the PX route Short-term managed closure with several half a day closures.
Remove access for PX route Short-term closure with alternative route removal (diversion) provided.
15.10.7 In order to further understand the potential effect of such closures on the PRoW network, PRoW surveys were undertaken along the main routes potentially affected. These were manual, 12 hour count surveys undertaken by Intelligent Data in July and August 2014. Count locations are shown in Figures 15.3a-15.3d within Volume 5, Document 5.3.15, results are discussed below.261 In general, the surveys recorded very low levels of activity. 15.10.8 National Grid will undertake pre-commencement condition surveys of the affected PRoW prior to construction. Any affected PRoW will subsequently be reinstated as a minimum to the same condition as was recorded in the survey prior to construction works.
261 Please note where surveys results found no usage these have not been reported (these locations were West of Lynne Wood, Southwest of Goose Farm, Northwest of Goose Farm, East of Gore Street and Walmers Hill.
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Baseline conditions: Section A – Stour Valley 15.10.9 Section A contains a number of PRoW and recreational routes. Prominent routes include: The Stour Valley Walk - a long distance walking route that follows the River Stour from its source at Lenham, through Canterbury and down to the Straits of Dover. The Saxon Shore Way - a regional trail that crosses the Local Study Area. National Cycle Route 1 - a long distance cycle route which comes through Canterbury and south of Hersden, Upstreet and Sarre, and eastwards towards Sandwich. Local routes identified through Statutory Consultation - to the north of Broad Oak around Mayton Farm and leading to Blean Woods, including footpaths CB78, CB71 and Bridleway CB36. 15.10.10 There a number of footpaths within Section A that have been surveyed as part of the assessment. Survey results for these footpaths are included in Table 15.15 with count locations and the overall PRoW network shown on Figure 15.3a within Volume 5, Document 5.3.15.
Table 15.15 PRoW manual count data - Section A
PRoW count location PRoW Grid reference Daily manual reference count
West of Lynne Wood CB51 E616489, N160523 15 (A01)
Southwest of Goose CB48 E616489, N161060 0 Farm (A02)
Northwest of Goose CB46 E616279, N161314 2 Farm (A03)
Heel Lane (A04) CB41 & E616372, N161782 12 CB78
Barnet’s Lane (A05) CB80 E616796, N162207 27
Kemberland Wood CB58 E617866, N162246 9 (A06)
Mayton Lane, Broad CB71 & E616386, N161968 10 Oak (A07) CB70
Mayton Farm (A08) CB36 E615673, N162060 6
Source: Intelligent Data, 2014
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Predicted effects and their significance: Section A – Stour Valley 15.10.11 In total 12 PRoW are identified as being directly affected by construction of the proposed development, all of which are footpaths, with the exception of CB80 which is a bridleway. A total of 30 work items have been identified which would require closure of these 12 footpaths at various times, with the duration of the potential effect ranging between six and 26 days, depending on the works proposed. 26 of the work packages (87%) would lead to effects that are predicted to last between two and four weeks with the remaining four work packages (13%) leading to effects lasting upwards 5+ weeks to a maximum of six weeks. 15.10.12 For the purposes of this assessment, the approach contained within Table 3.1 of Appendix 3H (Volume 5, Document 5.4.3H) has been used. This proposes that the majority of potential effects within Section A are managed closures for a short time period with two day-closures proposed. This type of management is proposed on 11 of the 12 PRoW affected where certain works packages allow. Diversion routes have been identified for the day closures, should they be required. 15.10.13 For those works that would lead to a potential effect over a longer duration or require closure with diversion, which is the case on four of the 12 PRoW, the following approaches are proposed: Footpath CB47a – short-term closure (three weeks) associated with access route removal. A diversion is proposed that utilises CC17, Kilndown Gardens, Westerham Close, CC16A/CC16, Farleigh Road and Broad Oak Road. Footpath CB48 – five weeks managed closure with potential for several week long closures to enable access route construction and removal. A diversion is proposed utilising CB51, CB48, CB60 and Shalloak Road during closures. Footpath CB44/CB46 – five weeks of managed closure with potential for several week long closures to enable road construction and removal. A diversion is proposed which utilises Shalloak Road, Mayton Lane, CB41 and CB44. Bridleway CB80 – long-term closure for six weeks to enable access route construction. A diversion is proposed which utilises Barnet’s Lane, Sweechgate and Herne Bay Road. 15.10.14 Where routes are to remain accessible through managed closure, direct construction effects are considered to be minor and not significant. 15.10.15 Where closures are required for a longer duration (i.e. above five weeks) and are to be managed, with periods of extended closure, suitable diversions have been proposed and would be implemented through Article 13 which provides National Grid the powers to stop-up and divert PRoW as listed in Schedule 7 of the DCO and shown on the Access, Rights of Way and Public Rights of Navigation Plans (see Volume 4, Document 4.7). With diversions provided, construction effects to users of these routes are expected to be minor and not significant with continued access maintained or short diversions provided. 15.10.16 In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction phase due to the transient nature of users and the temporary nature of any such amenity effect. 15.10.17 The same applies for the operational phase, with no significant direct or indirect amenity effects. Some local routes would benefit from the removal of the PX route
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while others would have minor adverse effects from the presence of the 400kV overhead line. 15.10.18 There are no significant direct effects on the Stour Valley Walk, Saxon Shore Way or National Cycle Route 1 during construction within Section A. Moreover, the assessment results of other disciplines means they would not experience significant indirect amenity effects.
Baseline conditions: Section B – Sarre Penn Valley 15.10.19 The Stour Valley Walk and the Wantsum Walk regional trails also both run through Section B. In addition, National Cycle Route 1 also runs through the Section. 15.10.20 A number of footpaths in this section were surveyed as part of the assessment. Results of the counts are included in Table 15.16 with count location and the PRoW network in Section B shown in Figure 15.3b within Volume 5, Document 5.3.15.
Table 15.16 Manual count data - Section B
PRoW count location PRoW Grid reference Daily manual reference count
Chislet Business Park CB100 & E620815, N162998 52 (B01) CB100A
North of Chislet CB100 & E620668, N163223 4 Business Park (B01a) CB119
Nethergong Penn (B02) CB118 & E621850, N163403 1 CB119
South of Nethergong CB117 & E621904, N163403 4 Penn (B03) CB118
Source: Intelligent Data. 2014
Predicted effects and their significance: Section B – Sarre Penn Valley 15.10.21 In total, eight PRoW are identified as being directly affected by construction of the proposed development, all of which are footpaths. A total of 35 work items have been identified which would require closure of these nine footpaths at various times, with the duration of the potential effect ranging between 9 and 40 days, depending on the works proposed. 16 of the work packages (48%) would lead to effects that are predicted to last between two and five weeks with 19 work packages (52%) leading to effects lasting upwards of five weeks to a maximum of ten weeks. 15.10.22 The approach within the PRoW Management Plan is that the majority of potential effects within Section B are managed closures for a short time period with two day- closures proposed. This type of management is proposed on 11 of the 12 PRoW effected where certain works packages allow. Diversion routes have been identified for the day closures, should they be required.
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15.10.23 For those works that would lead to a potential effect over a longer duration or require closure with diversion, which is the case on three of the eight PRoW, the following approaches are proposed: Footpath CB118 – managed closures of between five and ten weeks with several week long closures to enable access route construction and removal. A diversion is proposed which utilises CB119, CB100, Island Road and CB117. Footpath CB100 – managed closures of between five and ten weeks with several week long closures to enable access route construction and removal. A diversion is proposed which utilises Island Road, CB117, CB118 and CB119. Footpath CB128 – managed closures of between five and ten weeks with several week long closures to enable access route construction and removal. A diversion is proposed which utilises CB124 and Island Road. 15.10.24 Where routes are to remain accessible through managed closure, direct construction effects are considered to be minor and not significant. 15.10.25 Where closures are required for a longer duration (i.e. above five weeks) and are to be managed, with periods of extended closure, suitable diversions have been proposed and would be implemented through Article 13 which provides National Grid the powers to stop-up and divert PRoW as listed in Schedule 7 of the DCO and shown on the Access, Rights of Way and Public Rights of Navigation Plans (see Volume 4, Document 4.7). With diversions provided, construction effects to users of these routes are expected to be minor and not significant with continued access maintained or short diversions provided. 15.10.26 In addition, the socio-economic assessment found no significant indirect amenity effects during the construction phase due to the transient nature of users and the temporary nature of any such amenity effect. 15.10.27 During the operational phase, there are no significant direct or indirect amenity effects expected on the PRoW and recreational receptors identified. Some local routes would benefit visually from the removal of the PX Route while others would have minor adverse effects from the 400kV route. 15.10.28 There are not expected to be significant direct effects on the Stour Valley Walk, Wantsum Walk or National Cycle Route 1 during construction within Section B. The 400 kV route will bisect the Stour Valley Walk and Wantsum Walk in Section B though they currently bisect the 132kV so the change is expected to be negligible. Moreover, the assessment results of other disciplines means they would not experience significant indirect amenity effects.
Baseline conditions: Section C – Chislet Marches 15.10.29 Sarre Penn and the Chislet Marshes are home to a number of local footpaths. As with Sections A and B, the Saxon Shore Way and Wantsum Walk regional trail and the National Cycle Route 1 all pass through Section C. In addition, Regional Cycle Route 15 goes through Section C near Sarre. 15.10.30 Manual surveys in Section C were undertaken on the Wantsum Walk. Results of this count are shown in Table 15.17 with the PRoW and count locations shown in Figure 15.3c within Volume 5, Document 5.3.15.
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Table 15.17 Manual count data - Section C
PRoW count location PRoW Grid reference Daily manual reference count
Wantsum Walk (C01) CB114 & E623202, N164258 8 CB124
East of Gore Street (C02) TE24 E627333, N164277 0
Walmers Hill (C04) CB125 E623451, N163760 0
Source: Intelligent Data, 2014
Predicted effects and their significance: Section C – Chislet Marshes 15.10.31 In total three PRoW are identified as being directly affected by construction of the proposed development, all of which are footpaths. A total of 14 work items have been identified which would require closure of these three footpaths at various times, with the duration of the potential effect ranging between nine and 35 days, depending on the works proposed. Six of the work packages (43%) would lead to effects that are predicted to last between 2 and 5 weeks with the remaining eight work packages (57%) leading to effects lasting five weeks and upwards to a maximum of ten weeks. 15.10.32 The approach within the PRoW Management Plan is that the majority of potential effects within Section C are managed closures for a short time period with two day- closures proposed. This type of management is proposed on all three of the PRoW effected where certain works packages allow. Diversion routes have been identified for the day closures, should they be required. 15.10.33 For those works that would lead to a potential effect over a longer duration or require closure with diversion, which is the case on two of the three PRoW, the following approaches are proposed: Footpath CB125 – managed closures lasting between five and ten weeks with potential for several week long closures to enable access route construction and removal. A diversion is proposed which utilises CB124, CB128 and Island Road. Footpath TE24 – managed closures lasting between three and seven weeks with potential for several week long closures to enable access route construction and removal. A diversion is proposed which utilises TE25 and TE23. 15.10.34 One of the closures (CB125) is along a section of the Saxon Shore Way / Wantsum Walk Long Distance Trail to the east of Upstreet. Although of medium magnitude the effect is considered to be minor adverse and not significant due to management and the ability of users to continue to walk the route. 15.10.35 Similarly the managed closure of the other footpaths and the proposed diversions for during week long closures would lead to a low effect which is considered not significant. In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction phase due to the transient nature of users and the temporary nature of any such amenity effect.
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15.10.36 During the operational phase, there are no significant direct or indirect amenity effects expected on the PRoW and recreational receptors identified. Some local routes would benefit visually from the removal of the PX route while others would have minor adverse effects from the 400kV route. 15.10.37 The National Cycle Route 1 and Regional Cycle Route 15 would be unaffected during construction in Section C as they do not experience direct effects and the assessment results of other disciplines means they would not experience significant indirect amenity effects.
Baseline conditions: Section D – Ash Level 15.10.38 The Ash Level contains many local footpaths and Section D also includes the Saxon Shore Way regional trail, National Cycle Route 1 and Regional Cycle Route 15. 15.10.39 Manual surveys in Section D were undertaken at three locations. Results of these counts are shown in Table 15.18 with the PRoW network and count locations shown in Figure 15.3d within Volume 5, Document 5.3.15.
Table 15.18 Manual Count Data - Section D
PRoW Count Location PRoW Grid Reference Daily Traffic Reference Count
South of Monkton TE23 E628236, N164155 13 (D01)
Abbots Wall (D02) TE32 E629819, N163369 9
Marsh Farm Road (D03) TE35 E630819, N162852 21
Source: Intelligent Data, 2014
Predicted effects and their significance: Section D – Ash Level 15.10.40 In total four PRoW are identified as being directly affected by construction of the proposed development, all of which are footpaths. A total of 25 work items have been identified which would require closure of these three footpaths at various times, with the duration of the potential effect ranging between 3 and 45 days, depending on the works proposed. 15 of the work packages (60%) would lead to effects that are predicted to last between two and five weeks with the remaining 10 work packages (40%) leading to effects lasting five weeks and upwards to a maximum of 12 weeks. 15.10.41 As with other Sections National Grid propose to implement managed closures with day closures where possible in order to minimise disruption to users. This approach will be applied on all effected PRoW for certain works with the following approaches also adopted for works on two of the four PRoW: Footpath TE26 – long-term (10 week) closure to enable bridge and access route construction. A diversion is proposed which utilises TE35, Marsh Farm Road, Watchester Lane, TE31 and TE32.
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Footpath EE42 - managed closures ranging between ten and 12 weeks with potential for several week long closures to enable bridge construction and access route construction and removal associated with Pylons PC 51-52. A diversion is proposed which utilises EE54, EE55, Lower Goldstone, EE50, Richborough Road, EE48A and EE48B. Footpath EE42 – Long-term closure for ten weeks for bridge construction associated with Pylon PC60. A diversion is proposed which utilises EE54, EE55, Lower Goldstone, EE50, Richborough Road, EE48A and EE48B. 15.10.42 Closures relating to EE42 would affect sections of the Saxon Shore Way Long Distance Path leading to a medium magnitude of effect which is considered to be minor adverse and not significant due to management and the ability of users to continue to walk the route or utilise the diversion proposed. 15.10.43 Other managed closures on the footpath network would lead to low effects which are considered not significant. In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction phase due to the transient nature of users and the temporary nature of any such amenity effect. 15.10.44 During the operational phase, there are no significant direct or indirect amenity effects expected on the PRoW and recreational receptors identified. Some local routes would benefit from the removal of the PX Route while others would have minor adverse effects from the 400kV route. 15.10.45 The National Cycle Route 1 and Regional Cycle Route 15 would be unaffected during construction in Section D as they do not experience direct effects and the assessment results of other disciplines means they would not experience significant indirect amenity effects.
15.11 Assessment of effects: users of community infrastructure 15.11.1 The assessment of effects in relation to community infrastructure has focussed on receptors within the Order limits which may experience direct effects as well as those receptors within the Local Study Area which may experience indirect amenity effects during the construction and operational phase. For each Section (A-D), the assessment highlights the type of receptor within close proximity to the route prior to considering potential effects. Specific reference is made to a receptor where they lie within the order limits and therefore have the potential to experience direct effects, or where there is potential for indirect amenity effects (e.g. where other Chapters have drawn conclusions in relation to effects on a given receptor). Where receptors fall outside one of these scenarios, the assessment makes broad conclusions for all receptors within the given Section. A full list of receptors considered can be found in Appendix 15A within Volume 5, Document 5.4.15A.
Predicted effects and their significance Section A – Stour Valley 15.11.2 A number of community facilities are located in Section A with a focus on Sturry. The type of receptors within Section A include: Canterbury Sea Cadet hut; Junior King’s school;
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Sturry Library; Sturry Parish Council/Community Centre; Sturry Church of England Primary School; All Saints Church, Westbere; Canterbury Seventh-Day Adventist Church; Sisters of Our Ladies of the Missions Church; Sturry Anglican Methodist United Church; and Spires Academy. 15.11.3 With the exception of the Sea cadets, receptors are located outside of the Order limits and therefore no direct construction or operational phase effects are predicted while the assessment results of other disciplines means they would not experience significant indirect amenity effects. 15.11.4 Potential effects on Canterbury Sea Cadets stems from the access to this facility forming part of the construction access route. This could result in a potential significant direct effect, however traffic management would be put in place to ensure continued use of the facility and National Grid will undertake ongoing dialogue with the Sea Cadets in order to ensure their operations are not affected by the proposed access. This mitigation would mean the magnitude of the effect is negligible and thus the effect would be not significant. 15.11.5 It is not considered that construction or operational traffic and associated works (e.g. road closures) will be at a level to affect people’s ability to reach and continue to utilise these facilities. National grid, through ongoing dialogue and principles within the CTMP (see Appendix 3G in Volume 5, Document 5.4.3G), will ensure that access is maintained to any facilities which are potentially affected by the proposed development and therefore effects would be negligible and not significant. 15.11.6 In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction or operational phases with use of these facilities unaffected by the proposed construction activities or operation of the proposed development. Section B – Sarre Penn Valley 15.11.7 There are a number of community facilities in Section B; focussed on the settlements of Chislet, Hersden, Hoath and Nethergong. These include facilities such as: Chislet Church of England Primary School; Chislet Church and village hall; St Mary Church, Stodmarsh; Stodmarsh National Nature Reserve; Tina Rintoul Children’s Centre; Chislet Colliery Welfare Club; Hersden Neighbourhood Centre Association;
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St Dunstan’s Catholic Church; Hoath Primary School; and Hersden Community Primary School. 15.11.8 Direct construction effects are not expected as the community facilities lie outside the Order limits. It is not considered that construction or operational traffic and associated works (e.g. road closures) will be at a level to affect people’s ability to reach and continue to utilise these facilities. National Grid, through ongoing dialogue and principles within the CTMP (see Appendix 3G in Volume 5, Document 5.4.3G), will ensure that access is maintained to any facilities which are potentially affected by the proposed development and therefore effects would be negligible and not significant. 15.11.9 In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction or operational phases with use of these facilities unaffected by the proposed construction activities or operation of the proposed development. Section C – Chislet Marches 15.11.10 There are two community infrastructure receptors identified in Section C which could experience potentially significant direct or indirect amenity effects during construction; this is also the case for the operational phase: Monkton Nature Reserve; and St Nicholas at Wade Church. 15.11.11 Direct construction effects are not expected as the community facilities lie outside the Order limits. Access to the facilities during both construction and operation of the proposed development will be maintained through ongoing dialogue and principles within the CTMP (see Appendix 3G in Volume 5, Document 5.4.3G). 15.11.12 In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction or operational phase with users able to continue to utilise and enjoy these facilities alongside these phases of the proposed development. Section D – Ash Level 15.11.13 There are a number of community facilities in this section, such as: Ash, Cartwright and Kelsey Church of England Primary School; Nash Nursery; Minster Church of England Primary School; Minster Day Nursery; Monkton Church of England Primary School; Monkton Methodist Church; Minster Parish Council; Ash Village Hall; and
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Minster Village Hall. 15.11.14 The community infrastructure receptors identified in Section D, will not experience significant direct construction effects, as they lie north of the rail line and outside the Order limits. It is not considered that construction or operational traffic and associated works (e.g. road closures) will be at a level to affect people’s ability to reach and continue to utilise these facilities. National Grid, through ongoing dialogue and principles within the CTMP (see Appendix 3G in Volume 5, Document 5.4.3G), will ensure that access is maintained to any facilities which are potentially affected by the proposed development and therefore effects would be negligible and not significant. 15.11.15 In addition, the socio-economic assessment finds no significant indirect amenity effects during the construction or operational phases with use of these facilities unaffected by the proposed construction activities or operation of the proposed development.
15.12 Assessment of effects: other businesses 15.12.1 The assessment below considers construction related effects on other businesses within the local area, as well as considering operational effects on the business community.
Predicted effects and their significance 15.12.2 The assessment of potential effects on other businesses has been undertaken utilising business information obtained from the Experian B2B Prospector. Direct effects were considered on the full dataset with all businesses mapped and those within the Order limits considered (see Figure 15.4 within Volume 5, Document 5.3.15). This figure presents a broad indication of business location and detailed analysis has established that only two businesses lie within the Order limits and therefore have the potential to experience direct effects. 15.12.3 In order to consider indirect amenity effects, the full data set was analysed alongside the sensitive business definition in order to create a data subset. 15.12.4 These businesses were then mapped alongside ZTVI data in order to indicate those businesses that have the potential to experience indirect amenity effects (see Figure 15.5 within Volume 5, Document 5.3.15). 15.12.5 It is important to note that, in order to avoid duplication, tourism receptors have not been included within this section. See Section 15.9 of this Chapter for the tourism assessment. Section A – Stour Valley 15.12.6 A large number of business receptors have been identified in Section A. This number has been influenced by the presence of the City of Canterbury which is home to a large number of businesses. Despite this concentration, only two businesses fall within the Order limits and therefore are considered to have the potential to experience direct effects. The two businesses in question are located on the corner of Farleigh Road and Broad Oak Road, Canterbury, are oversailed by the existing PX route which is to be dismantled. These businesses may therefore experience some limited disturbance during dismantling of this section of the PX route however, given the nature of the businesses any effect is considered to be minor and not
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significant. During operation, these businesses may experience a minor beneficial effect due to the removal of the PX route which is considered to be not significant. 15.12.7 No other businesses in Section A lie within the Order limits and therefore no other direct effects are identified during construction or operation. 15.12.8 Access to businesses within close proximity of the proposed development will be maintained through traffic management and ongoing liaison during the construction programme. 15.12.9 Given the more urban nature of Section A, a larger variety of businesses have been identified as sensitive receptors, including leisure and recreation receptors, nurseries, shops and also home based businesses such as landscape gardening. There are also some businesses identified near to the PX Route, located around the business park off Broad Oak Road. However, the assessment results of other disciplines means they would not experience significant indirect amenity effects during construction or operation. Section B – Sarre Penn Valley 15.12.10 In Section B, several businesses have been identified, clustered around the A28 Island Road. Chislet Business Park is located just south of Island Road, and includes a number of sensitive businesses. This includes similar receptors to those identified in Section A, but also some specific business services. The Section also contains Canterbury Industrial Park and the Lakeview Business Park, which contain a range of retail and industrial based businesses and are located to the south of the A28. 15.12.11 Maypole Airfield has been identified as a potentially sensitive receptor. It lies in the north of Section B, outside the Order limits and would not experience any significant direct effects during construction. During operation, due to the airfield operating a circuit height of 800 feet and, coupled with the Civil Aviation Authority response to scoping, this receptor would not experience any significant direct or indirect amenity effects. 15.12.12 Given their locations outside the Order limits, no business receptors have been identified in Section B as experiencing significant direct effects. Given the nature of the businesses within this Section no indirect amenity effects have been concluded. 15.12.13 During operation, the access to Chislet Business Park, north of the A28 Island Road, is proposed as a maintenance access. Given the low volume of maintenance activities associated with the proposed development, this is not expected to materially impact on the economic activity at the Business Park. No other direct or indirect amenity effects have been identified for business receptors within Section B during operation. Section C – Chislet Marches 15.12.14 There are no sensitive receptors, with the exception of tourism receptors (see Section 15.9) in this section located within the Order limits and therefore no significant direct effects are identified. Sensitive receptors in the Local Study Area are located to the north of the rail line, outside the Order limits, and, given the assessment results of other disciplines means they would not experience significant indirect amenity effects.
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Section D – Ash Level 15.12.15 There are no sensitive receptors, with the exception of tourism receptors (see Section 15.9), in this section located within the Order limits and therefore no significant direct effects are expected. Sensitive receptors in the Local Study Area are located to the north of the rail line, outside the Order limits, and, given the assessment results of other disciplines means they would not experience significant indirect amenity effects.
15.13 Assessment of effects – users (land owners and tenants) of agricultural land 15.13.1 The assessment has been compiled to explore potential effects on broad socio- economic receptor categories. Further consideration of the effects on agricultural land quality is provided in Chapter 14 within this document. This assessment focusses on the potential effects of the proposed development on the operation of the agricultural business/land holding. 15.13.2 The construction of the proposed development would require temporary use of land for the construction works; for example the construction access routes, site compounds, pylon working areas and lay down areas. Through the design development, and in accordance with the NPS EN1, National Grid has sought to identify a preferred 400kV overhead line connection route which minimises effects on landowners and for the most part, consultation with land owners/tenants has highlighted that construction activities are not considered likely to significantly affect the long-term operation of farm businesses while short-term effects will be compensated in accordance with National Grid’s statutory obligations. 15.13.3 Once operational, the extent of land taken out of its current agricultural use would be limited to the footprint of the pylons with some land owners benefiting through the removal of the PX route and return of land to former uses. 15.13.4 Operation would also include access rights on land in which a pylon is sited or is oversailed by the proposed development. In the majority of cases it is not considered that any such restrictions would limit the current land use functions along the proposed development corridor.
Baseline conditions 15.13.5 The assessment of effects on agricultural land has focussed on direct effects on land holdings within the Order limits with a focus on the LoD in relation to land affected by permanent infrastructure. During construction, these effects may include temporary land-take through the establishment of access routes and working areas, which have also been assessed, while during operation it is permanent land-take at pylon locations which is assessed. 15.13.6 The assessment also broadly considers the quality of agricultural land affected and uses Natural England’s classification scale from Grade 1 through to Grade 5: Grade 1 – excellent land quality; Grade 2 – very good land quality; Grade 3 – good to moderate land quality (this can be separated into Grade 3a – good and Grade 3b – moderate);
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Grade 4 – poor land quality; and Grade 5 – very poor land quality. 15.13.7 Using this grading system, Grade 1 through to 3a are described as Best and Most Versatile (BMV) agricultural land; this is the land which is most productive and thus would be expected to have the highest economic value. 15.13.8 Effects associated with the loss of agricultural land as a resource are considered as part of the assessment included in Chapter 14 within this document. This section focuses on how the proposed development will affect the use of agricultural land. Section A – Stour Valley 15.13.9 Agricultural land within Section A is shown on Figure 14.5a within Volume 5, Document 5.3.14 and is primarily classified as Grade 3, with some areas classified as Grade 2. The Section contains primarily arable farmland as well as Goose Farm which is higher value horticulture (orchards). Approximately 90% of the land within the LoD in this section is BMV agricultural land. 15.13.10 It is proposed that construction would see the erection of 16 lattice pylons within the Section along with the removal of 21pylons associated with the PX route. Section B – Sarre Penn Valley 15.13.11 Agricultural land within Section B is shown on Figure 14.5b within Volume 5, Document 5.3.14, and is mainly characterised by arable farmland. The LoD within this section pass through approximately 50% BMV agricultural land. 15.13.12 The Section contains proposals for 12 lattice pylons along with the removal of 18 pylons associated with the PX route. Section C – Chislet Marches 15.13.13 This section is characterised by arable farmland with the main settlements including Sarre and Gore Street. Agricultural land within Section C is shown on Figure 14.5c within Volume 5, Document 5.3.14. Large amounts of agricultural land in the section are classified as Grade 1, although the majority of this is north of the LoD and further south below the Stour River. In terms of the LoD, in general, approximately 75% of the land it passes through is BMV agricultural land. 15.13.14 The Section contains proposals for 15 lattice pylons along with the removal of 19 pylons associated with the PX route. Section D – Ash Level 15.13.15 In Section D, the majority of agricultural land is Grade 1 land as shown in Figure 14.5d within Volume 5, Document 5.3.14. The LoD intersects a very small amount of Grade 1 land and large amounts of Grade 3 land; approximately 95% of the land the LoD pass through in this Section is classified as BMV agricultural land. 15.13.16 The Section contains proposals for 17 lattice pylons along with the removal of 21 pylons associated with the PX route.
Predicted effects and their significance 15.13.17 Agricultural receptors will experience some temporary direct effects during construction, with areas of agricultural land made unavailable for agricultural purposes while construction is completed. Chapter 14 of this document estimates
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this temporary land take to be in the region of 167.4 hectares which will be taken out of agricultural production to facilitate the proposed development. Given the temporary nature of the construction works and the small amount of land take in the context of the extent of agricultural land within the local study area, the effects are assessed as having a negligible effect on economic activity, with agricultural activities able to continue on surrounding land and land owners appropriately compensated for the temporary loss of agricultural land. 15.13.18 During the operational phase it is predicted that receptors would experience some permanent direct effects through land-take associated with pylon locations with Chapter 14 of this document estimated a permanent land take of approximately 0.3 hectares. Despite this, the construction of pylons on the land holdings is not expected to materially affect economic activity and thus is not considered to be significant. The removal of the PX route pylons as part of the proposed development would also bring some permanent positive effects to agricultural land with the land returned to agriculture where the surrounding land use allows. The overall effect on the use of agricultural land in the operational phase is considered to be negligible and not significant.
15.14 Assessment of effects – future land uses 15.14.1 The assessment has considered how the proposed development could affect future potential and proposed development in the wider area (employment allocations and other emerging developments) including the delivery of sites allocated in the Local Plan as well as those developments not included as part of the Local Plan. This assessment focuses on potential direct effects where the location of the proposed development may prevent or restrict the known future land use and development. The location of the developments discussed below is also shown on Figure 5.1a and 5.1b within Volume 5, Document 5.3.5.
Predicted effects and their significance Section A – Stour Valley 15.14.2 Within Section A the following future land uses have been established at the time of writing this assessment: Employment allocation on Vauxhall Road, Canterbury. Site with potential for a range of employment uses. South East Water (SEW) is planning a new reservoir north west of Broad Oak. While the scheme is identified in SEW Water Resource Management Plan the project has no planning status at this present time. There has been ongoing dialogue between National Grid and SEW to ensure that the development is able to proceed. An assessment of route options in the vicinity of the proposed reservoir can be seen in Appendix 2D within Volume 5, Document 5.4.2D. Strategic Development Site (SP3) Site 2: Sturry and Broad Oak as identified within the CCC Draft Local Plan. The allocation lies to the east of the Order limits on land between Sturry and Broad Oak and indicates potential redevelopment for up to 1,000 houses and associated development (e.g. open space, business and community facilities).
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Sturry Link Road: This will form part of the SP3 Site 2 development and is currently in design development. 15.14.3 These developments are not assessed as experiencing significant direct construction effects. Whilst the construction programme for the sites is not fully known it is suggested that construction would overlap in the case of the Sturry Link Road and the associated Sturry and Broad Oak strategic development site. In the case of the reservoir, development is likely to take place long after the construction of the proposed development. The proposed land uses can therefore continue alongside the proposed development or follow the construction period. In the case of Vauxhall Road, although pylon PC2 is located within the site it is considered that a range of employment uses would remain viable on the site and certain uses could even use land surrounding and underneath the pylon (e.g. parking of vehicles). 15.14.4 None of the receptors are considered to be sensitive to indirect amenity effects from a socio-economic point of view. No significant effects have been identified in the operational phase. Section B – Sarre Penn Valley 15.14.5 There is a strategic allocation to the north of Hersden, east of Square Wood (see Figure 5.1a within Volume 5, Document 5.3.5). This land has been allocated for housing, as identified in the Canterbury City Council Draft Local Plan. This allocation is south of the Order limits, in close proximity to the A28 Island Road and therefore would not be affected by the construction and operation of the proposed 400kV line. The Order limits for the removal of the PX route however do run on the northern boundary of the site and therefore some minor effects may be experienced during construction of the proposed 400kV route, however, the dismantling and removal of the PX route is considered to be beneficial for the proposed land use. Section C – Chislet Marches 15.14.6 No future land uses or proposed development in the wider area have been identified in Section C. Section D – Ash Level 15.14.7 The following future land uses have been identified within Section D: Thanet Solar Farm: a 5MW solar farm with associated arrays and infrastructure with planning permission. Discovery Park Masterplan: outline planning application to include new employment floorspace. New electricity substation and converter station site at Richborough in connection with Nemo Link. 15.14.8 Both the solar farm and substation and converter station lie partially within the Order limits for the proposed development and have the potential therefore to experience direct effects during construction. The Discovery Park Masterplan sites lies outside of the Order limits and therefore is not expected to experience any direct effects. National Grid is aware of the proposals and is working with the developers to ensure that all projects can be delivered. These land uses are not therefore expected to experience significant direct or indirect amenity effects during the construction phase. 15.14.9 The proposed land uses in this Section would be unaffected in the operational phase.
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15.15 Assessment of effects: local and regional economies 15.15.1 This section of the assessment considers scheme wide benefits to the local and regional economies in relation to direct employment generated by the proposed development. 15.15.2 This assessment utilises data obtained from National Grid and considers potential business benefit that may be felt through the presence of the project (e.g. direct employment opportunities and construction material spend), as well as the construction workforce in the local area (e.g. accommodation nights and spend of workers). Construction spend 15.15.3 At the time of writing the capital cost of the proposed development was estimated to be £75 million, including an estimated £67 million for the installation of the proposed 400kV overhead line connection and a further £8 million for the removal of the PX Route. 15.15.4 Although further detail in relation to the sourcing of labour, plant and capital equipment will emerge following tendering and award of contracts, this assessment utilises National Grid’s experience on similar projects to make an assessment based on a number of ratios or scenarios. 15.15.5 When exploring scheme spend it is estimated that approximately 65% will be spent on civil engineering and the remaining 35% will be spent on plant and equipment. This leads to an estimated spend of £48.75 million and £26.25 million respectively (based on the estimated £75 million capital cost). The type of spend and activities falling into these broad categories is summarised in Table 15.19.
Table 15.19 Construction activities
Civil engineering Plant and equipment
Construction of access routes, working areas Pylon materials. and ground preparation.
Delivery of materials to site. Conductors and wiring.
Excavation and piling works. Cabling, joints and terminations.
Pylon construction, stringing of conductors and cranage.
Reinstatement of land.
15.15.6 From previous experience, National Grid envisage that the geographic split of this spend would be as follows: Civil engineering – While National Grid at the time of writing could not rule out the possibility of some overseas labour on specific civil engineering tasks, the assumption is that all of these activities would be undertaken by UK based contractors and a UK labour force.
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Plant and equipment – Some of the expenditure on plant and equipment would likely be spent in the UK, although past experience suggests that most, if not all, suppliers are companies located outside of the UK.
15.15.7 Based on the above assumptions it can be concluded that the proposed development will generate an estimated £48.75 million of net additional expenditure in the UK through civil engineering contracts. This expenditure would not be realised without the proposed development. The plant and equipment expenditure would generate no net economic effect either locally or at the UK level. Construction employment 15.15.8 The construction employment profile for the proposed development is set out in Graphs 15-3 and 15-4.
Graph 15-3 Employment Profile (installation of the 400kV overhead line connection – Average people per day by month)
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Graph 15-4 Employment profile (PX route removal – Average people per day by month)
15.15.9 Using the data from National Grid it is estimated that the proposed development would generate approximately 224 construction worker years262.
15.15.10 At its peak, the installation of the 400kV overhead line connection will employ an average of 150 people per day over the month of October 2017, a figure which decreases to an average of six people per day over the month of December 2018. The peak in employment represents the time within the construction programme when most teams required to complete the proposed development are on site (e.g. bellmouth, piling, access route, scaffold, pylon assembly, wiring, pylon painting and bridge construction teams). On average, across the 400kV overhead line connection phase, the proposed development is estimated to employ 59 people per day.
15.15.11 During the PX dismantling and removal, National Grid estimates that at its peak the proposed development will employ 75 people per day during the month of April 2020, decreasing to just 12 people per day during the month of May 2021. On average, the PX removal is estimated to employ 34 people per day over the course of the construction programme.
15.15.12 Of the employment generation created by the proposed development, National Grid estimate that on average, 17% of those employed will be from the local area, reflecting the specialist nature of the work and the transient nature of the specialist teams that move around the country working on similar projects.
15.15.13 On the basis of this average, it is estimated that the installation of the 400kV overhead line connection would generate employment in the region of 10 local people per day on average over the construction programme. Furthermore, it is estimated that the PX removal would employ on average 6 local people over the
262 Note – this is based on the employment profiles shown in the graph and the assumption 222 working days per worker with 6 day working weeks.
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course of the construction programme. Given the context of the Local Study Area and Wider Study Area, these jobs can easily be absorbed by the local economy.
15.15.14 While the above local contractors are not considered to bring any additional spending to the local economy as their living expenses would be incurred regardless of the proposed development, other contractors employed through the proposed development would bring additional economic benefits associated with induced spend.
15.15.15 This spend would bring benefits to those businesses who benefit, for example, accommodation providers, restaurants and convenience retailers. Estimates from National Grid suggest a per diem for each non-local worker263 of £50. This represents additional spending within the local economy which would not occur without the proposed development. 15.15.16 Applying this per diem spend to those non-local workers it is estimated that the proposed development could bring in the region of £2.4 million of additional spend within the local economy over the period of two years and four months. This is relatively small compared to the total estimated tourism expenditure of £860m per annum in Kent and Medway, according to a 2011 study252, but nonetheless is not an insignificant level of spend in the local area. Employee accommodation 15.15.17 The presence of non-local staff within the workforce would lead to demand for accommodation within the study area. Based on the average number of workers per week and the proportion of non-local workers on the project, it is estimated that at its peak, bedspace demand will be in the region of 144 bedspaces. 15.15.18 From previous experience, National Grid anticipate the breakdown of demand as shown in Table 15.20 from non-local staff. This demand will vary dependent upon the end contractor with those choosing to use more overseas labour bringing an increase in demand for short-term let properties and less of a demand for caravan and camping spaces.
Table 15.20 Total accommodation nights from non-local staff
Accommodation UK based Estimated Contractor Estimated type contractor numbers with numbers overseas labour
Caravan & camping 50% 24,077 25% 12,038
Short-term let 20% 9,631 50% 24,077 properties
Serviced 20% 9,631 15% 7,223 Accommodation
Travel from home 10% 4,815 10% 4,815
263 Non-local worker includes those workers staying overnight in the proposed development area.
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15.15.19 As identified in the baseline, the wider study area has a strong tourism offering and accordingly has a range of temporary accommodation options. It is expected that the accommodation requirement from the construction workforce would have a positive economic impact for the local economy. Operational spend and employment 15.15.20 Any operational spend in relation to the proposed development would largely relate to the purchase of component parts and labour for maintenance activities. Based on current operations, National Grid anticipates that the majority of parts would be procured from international suppliers whilst labour would be contracted to a network of national suppliers. 15.15.21 Although the labour elements of operational spend give rise to limited opportunities for induced spend in the local economy this is likely to be negligible in the context of operational maintenance visits. 15.15.22 In this context, once operational, the proposed development is expected to generate only a small number of jobs and the required operational workforce would be sourced from existing National Grid contracts. Decommissioning spend and employment 15.15.23 The economic effects in relation to spend and employment during future decommissioning are considered to be broadly consistent, although of a smaller magnitude, with the construction phase of the proposed development, as detailed above. 15.15.24 Should the proposed development be decommissioned staffing requirements would be similar to construction, bringing some local employment benefits and associated per dium spend within the local economy.
15.16 Conclusions of significance evaluation 15.16.1 The assessment has concluded that there are no significant socio-economic effects in either the construction, operational or decommissioning phases of the proposed development. 15.16.2 The assessment has considered in detail receptors that have the potential to experience significant adverse/beneficial effects from the proposed development (direct and indirect) and the conclusions as summarised in Table 15.21 have been made.
Table 15.21 Summary of effects
Receptor and Summary of Summary rationale effects significance
Robin Hood No direct or indirect Potential direct construction / Events at amenity effects during decommissioning effects would be mitigated Goose Farm construction/future through construction programme and the decommissioning or facility could continue to operate during operation – Not operation should they so wish, leading to no significant. direct effects.
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Receptor and Summary of Summary rationale effects significance
With reference to other ES Chapters, no significant indirect amenity effects have been drawn during construction, operational or future decommissioning phases.
Nethergong No direct effects during The receptor lies outside of the Order limits Camping construction, operation and therefore would not experience any or future direct effects during construction or decommissioning. operation. Potential significant With reference to other ES Chapters, indirect amenity effects although significant indirect amenity effects during construction. are considered likely during construction, These would be partially main works are programmed during Jan- mitigated through May in order to avoid peak visitor season programme of works – and therefore limit potential amenity effects Not significant. on users of the camp site.
Users of the No direct or indirect While works over the receptor lie within the River Stour amenity effects during Order limits temporary structures are to be Navigation construction or future built to the height of existing structures decommissioning – Not thereby leading to no effect on navigation. significant. Where short-term closures are required, National Grid is working with local user groups and will install advance signage on the river. Emergency moorings will also be provided and therefore receptors will not experience any significant effects.
Stour Valley No direct or indirect Due to distance between the proposed Walk amenity effects during development and the long distance path. construction, operation or future decommissioning – Not significant.
Saxon Shore No direct or indirect Although a couple of sections of the long Way amenity effects during distance path would be temporarily closed construction, operation during construction (within Sections C & D), or future the proposed managed closure will retain decommissioning – Not access along the route. significant. No direct or indirect amenity effects have been identified during construction operation or decommissioning.
Wantsum No direct or indirect Although a section of the long distance path Walk amenity effects during would be temporarily closed during construction, operation construction (within Section C), the or future proposed managed closure will retain decommissioning – Not access along the route. significant. No direct or indirect amenity effects have been identified during construction, operation or future decommissioning.
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Receptor and Summary of Summary rationale effects significance
National No direct or indirect Due to distance between the proposed Cycle Route 1 amenity effects during development and the long distance path. construction, operation or future decommissioning – Not significant.
National No direct or indirect Due to distance between the proposed Cycle Route amenity effects during development and the long distance path. 15 construction, operation or future decommissioning – Not significant.
Canterbury Residual direct Site access is along construction access Sea Cadets construction effect – Not route. Access will be maintained through significant. management and ongoing liaison.
Maypole No direct or indirect Site is located outside of the Order limits Airfield amenity effects during and given operational circuit height no direct construction, operation or indirect amenity effects are concluded or future during construction, operation or future decommissioning – Not decommissioning. significant.
Chislet No direct or indirect Although site access forms a maintenance Business amenity effects during access route, this is not expected to Park construction, operation materially impact on the economic activity at or future the business park. decommissioning – Not No significant indirect amenity effects significant. concluded.
Scheme wide benefits 15.16.3 The assessment of socio-economic effects has concluded a number of scheme wide benefits in relation to local and regional economies. In summary, the main benefits include: Approximately £48.75 million of net additional expenditure in the UK through civil engineering contracts; Peak employment generation of 150 and 75 people per day by month for the installation of the 400kV overhead line connection and PX removal respectively; An average of 10 and 6 local people per day potentially employed on the installation of the 400kV overhead line connection and PX removal respectively; Approximately £2.4 million of additional spending within the local economy from non-local workers; and Peak bedspace demand of up to 144 bedspaces.
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Inter-related effects 15.16.4 The assessment of inter-related effects as part of the socio-economic assessment has focussed on indirect amenity effects on receptors considered to have a positive amenity value. This assessment is specific to socio-economic receptors and seeks to consider how amenity effects could potentially affect the function and operation of socio-economic receptors that are reliant on their local amenity. 15.16.5 A summary of findings of the inter-related assessment on such receptors is included in Table 15.21 above. No significant inter-related effects have been concluded during construction or operation.
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16. CUMULATIVE EFFECTS
16.1 Introduction 16.1.1 This chapter describes the potential ‘inter-project’ cumulative effects from the interaction of the proposed development and other ‘major’ developments (as defined in Section 5.8 within Chapter 5 of this document) where there is the potential for combined environmental effects. ‘Inter-related’ (or intra-project) cumulative effects are considered within each of the technical chapters of this document. 16.1.2 This approach was agreed with the local authorities (KCC, CCC, DDC and TDC) at a meeting on 18 November 2015.
16.2 Environmental Impact Assessment consultation
Environmental Impact Assessment (EIA) scoping 16.2.1 A request for a Scoping Opinion for the Richborough Connection project was submitted in August 2014, and the Scoping Opinion Report was received from PINS on 18 September 2014 and is included in Appendix 1A within Volume 5, Document 5.4.1A. The Secretary of State has consulted on the Scoping Report12 and the responses received are summarised in Table 16.1 where relevant to the assessment of inter-project cumulative effects.
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Table 16.1 Consultee comments and responses to EIA scoping
Consulted Comments How addressed in this ES
Secretary of State The Secretary of State considers that the ES should not be a Inter-related effects are considered in each technical series of disparate reports and stresses the importance of chapter. Inter-project effects are considered in this considering interrelationships between factors and cumulative Chapter. impacts.
The potential cumulative impacts with other major As above. The proposed development is assessed in developments will need to be identified. The significance of the context of the existing environment including such impacts should be shown to have been assessed existing development such as overhead lines. against the baseline position (which would include built and Other developments to be considered were discussed operational development). In assessing cumulative impacts, and agreed with the local planning authorities, as other major development should be identified through discussed in Section 5.8 of this document. consultation with the local planning authorities and other relevant authorities on the basis of those that are: • projects that are under construction; • permitted application(s) not yet implemented; • submitted application(s) not yet determined; • all refusals subject to appeal procedures not yet determined; • projects on the National Infrastructure’s programme of projects; and • projects identified in the relevant development plan (and emerging development plans - with appropriate weight being given as they move closer to adoption) recognising that much information on any relevant proposals will be limited.
The ES should include an impact assessment to identify, describe and evaluate the effects that are likely to result from the project in combination with other projects and activities that are being, have been or will be carried out.
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Consulted Comments How addressed in this ES
The following types of projects should be included in such an Developments to be scoped in and out of the assessment, (subject to available information): assessments were discussed and agreed with the local a). existing completed projects; planning authoirites and are set out out Tables 5.2 and b). approved but uncompleted projects; 5.3 of this document. c). ongoing activities; d). plans or projects for which an application has been made and which are under consideration by the consenting authorities; and e). plans and projects which are reasonably foreseeable, i.e. projects for which an application has not yet been submitted, but which are likely to progress before completion of the development and for which sufficient information is available to assess the likelihood of cumulative and in-combination effects.
The Secretary of State considers it is imperative for the ES to The overall approach that has been taken to defining define the meaning of ‘significant’ in the context of each of the significance is outlined in Chapter 5 of this document. specialist topics and for significant impacts to be clearly identified. The Secretary of State recommends that the criteria Each individual technical chapter within this document should be set out fully and that the ES should set out clearly describes the method used to determine significance in the interpretation of ‘significant’ in terms of each of the EIA their associated ‘Assessment methodology’ sections. topics. Quantitative criteria should be used where available. This is then adopted for the cumulative assessment in The Secretary of State considers that this should also apply to this Chapter. the consideration of cumulative impacts and impact inter- relationships.
Joint Councils The Councils require a separate cumulative impacts chapter The approach adopted in this document has been to to be provided. consider inter-related effects in each technical chapter, and to consider inter-project effects separately in this It is currently proposed to report cumulative effects within the Chapter. This reflects the approach adopted in the technical chapters rather than as a standalone chapter of the Environmental Statement for the Hinkley Point C ES. Whilst this may be appropriate for inter-project cumulative Connection Project. effects (i.e. effects arising in combination with effects from other projects or developments), we do not consider it
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Consulted Comments How addressed in this ES
appropriate in relation to intra-project cumulative effects, i.e. The approach allows the inter-related effects that relate multiple effects on a particular receptor. It may be the case to each of the technical topics to be clearly identified that a sensitive receptor, for example an occupier of a nearby and considered within each of the chapters so that the dwelling, could be impacted by numerous different types of reader can easily understand and follow what the likely effects from this project and any such cumulative impact significant effects would be. The inter-project effects needs to be considered properly. In order to protect the have been presented in a separate chapter as they interests of sensitive receptors, and in accordance with best introduce information not otherwise discussed in the practice, a separate cumulative impacts chapter is required. technical chapters relating to other developments.
In addition to the developments identified in the Scoping Developments to be scoped in and out of the Report, the Councils consider assessments were discussed and agreed with the local that the following schemes should also be considered in the planning authoirites and are set out out Tables 5.2 and cumulative assessment: 5.3 of this document.
• Richborough Energy Park - Peaking Plant; • Estover Combined Heat and Power Plant, Discovery Park (DOV/13/00701); • Discovery Park masterplan (DOV/13/00783); • Proposed solar farm, Woodlands Farm, Calcott Hill, Sturry (Canterbury ref: CA/14/00169); and • Any potential future uses identified close to the site area in the adopted and emerging Kent County Council Minerals and Waste Plans.
Public Health The assessment should identify cumulative and incremental Developments to be scoped in and out of the England (PHE) impacts (i.e. assess cumulative assessments were discussed and agreed with the local impacts from multiple sources), including those arising from planning authorities and are set out out Tables 5.2 and associated development, other existing and proposed 5.3 of this document. development in the local area, and new vehicle movements associated with the proposed development; associated Transport emissions associated with the proposed transport emissions should include consideration of non-road development are considered in Chapter 10 of this impacts (i.e. rail, sea, and air). document. Potential inter-related effects arising from
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Consulted Comments How addressed in this ES
transport emissions are also considered in Chapter 9 and Chapter 12 of this document.
Natural England The ES should include an impact assessment to identify, Developments to be scoped in and out of the (NE) describe and evaluate the effects that are likely to result from assessments were discussed and agreed with the local the project in combination with other projects and activities planning authorities and are set out out Tables 5.2 and that are being, have been or will be carried out. 5.3 of this document.
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Statutory Consultation 16.2.2 Statutory Consultation took place over a period of seven weeks between 10 February and 27 March 2015 in accordance with the Act. Prescribed and non-prescribed bodies and members of the public were included in the consultation. Various methods of consultation and engagement were used in accordance with the SoCC including letters, website, public exhibitions, publicity and advertising, inspection of documentation at selected locations and parish and town council briefings. 16.2.3 National Grid prepared and publicised a PEIR in February 2015 and sought feedback on the environmental information presented in that report. Feedback received during the Statutory Consultation was considered by National Grid and incorporated where relevant in the design of the proposed development and its assessment and presentation in this ES. 16.2.4 No responses with regards the assessment of inter-development effects were received during this consultation.
16.3 Methodology 16.3.1 Section 5.8 in Chapter 5 within this document sets out the approach adopted in this ES to the assessment of cumulative effects. 16.3.2 The assessment of inter-project cumulative effects presented in this Chapter takes into account the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (as amended) which states an ES must include: “...a description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term permanent and temporary, positive and negative effects of the development.” 16.3.3 The assessment has followed the advice set out in PINS Advice Note 930 which states: “The potential cumulative impacts with other major developments will also need to be carefully identified such that the likely significant impacts can be shown to have been identified and assessed against the baseline position (which would include built and operational development). In assessing cumulative impacts, other major development should be identified through consultation with the local planning authorities and other relevant authorities on the basis of those that are: under construction; permitted application(s), but not yet implemented; submitted application(s) not yet determined; projects on the PINS Programme of Projects; identified in the relevant Development Plan (and emerging Development Plans - with appropriate weight being given as they move closer to adoption) recognising that much information on any relevant proposals will be limited; and
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identified in other plans and programmes (as appropriate) which set the framework for future development consents/approvals, where such development is reasonably likely to come forward.” 16.3.4 In the context of the above, ‘major’ developments are considered to be developments as defined in the Town and Country Planning (Development Management Procedure) (England) Order 2010 (i.e. development of 10 or more dwellings, over 1ha in area, buildings of more than 1,000m2, waste development or development which involves the winning and working of minerals or the use of land for mineral- working deposits). 16.3.5 Consultation was undertaken with the local planning authorities (KCC, CCC, TDC and DDC) throughout the preparation of the ES with regards the scope of the assessment of cumulative effects. It was agreed that the cumulative assessment would consider other major developments within the CCC, TDC and DDC local authority boundaries. Although it is acknowledged that a typical standard lattice 400kV pylon approximately 50m high can be discerned at distances up to 10km, from distances over 3km, whilst it may be possible to discern an overhead line on a clear day, it would not form a prominent part of that view. The study area for the assessment does not therefore extend to distances beyond the local authority boundaries. 16.3.6 Based on the agreed study area, and the guidance provided in PINS Advice Note 9, the major developments which it was agreed would be taken forward, as agreed with the local authorities on 26 August and 18 November 2015, are shown on Figure 5.1a - 5.1d (Volume 5, Document 5.3.5) and described in Table 16.2. Each development has been given a specific identification reference (‘Development ID’) for ease of reference throughout this Chapter. 16.3.7 Table 16.2 identifies the developments considered in the cumulative assessment as ‘Committed developments’, ‘Pre-application stage developments’, or ‘National Grid permitted development’. It should be noted that more detailed information was available for the ‘Committed developments’ and ‘National Grid permitted development’, often including detailed layout drawings and planning and/or environmental assessment reports. In contrast, only high-level or ‘illustrative’ information was available for the ‘pre-application stage’ developments. 16.3.8 Note that no projects ‘under construction’ or on the PINS Programme of Projects are included as no such developments were located within the agreed study area.
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Table 16.2 Developments considered within the assessment of inter-project cumulative effects
Development ID Development name Brief description
Committed developments
A Discovery Park Biomass The proposals include the erection of a biomass combined heat and power plant with fuel Plant, Ramsgate Road, storage. The plant will include a boiler hall, turbine hall, air cooled condenser, flue gas Sandwich treatment, plant room, offices and utilities. The chimney height would be 55m. The boiler hall is Grid ref: TR337597 the tallest structure shown at 35m high.
[Development 13 on Figure 5.1d within Volume 5, Document 5.3.5]
B Thanet Solar Farm, 5MW solar farm with associated solar panels, invertors, substations, security fence, access, Ramsgate Road infrastructure and associated works. The development would comprise parallel banks of photo- Grid ref:TR328620 voltaic panels (each 2m x 4m) mounted on angled supports at a height of 2.5m. The lowest point of the solar panels will be 0.8m above ground level. The only new semi-permanent structures will be the inverter cabinets and substations and associated hardstanding. The existing mature hedgerow along the northern perimeter of the site will be retained and enhanced as part of the scheme. Access will be via an existing farm track and the site will be fenced with 2.43m high galvanised wire fencing, finished in green and installed behind new or existing hedgerows. New hedgerows will be planted to enhance the biodiversity of the site and to minimise visual effects.
[Development 7 on Figure 5.1d within Volume 5, Document 5.3.5]
C Discovery Park Discovery Park is an existing operational employment site including offices/laboratories, Masterplan warehouses, industrial units, and associated plant/infrastructure. A resolution to grant planning Grid ref: TR330585 permission has been given for the outline planning application for the masterplan for Discovery Park which includes the demolition of remaining buildings (29,000 sqm) and change of use (159,000 sqm), 120,000 sqm of new floorspace (B1/B2/B8/D1), up to 1,000sqm A3/A4, and up to 500 dwellings. The existing office buildings within the centre of the site are to be retained. The planning application site extends to 72.5ha (179 acres) and forms the majority part of the 88ha Discovery Park site.
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Development ID Development name Brief description
[Development 8 on Figure 5.1d within Volume 5, Document 5.3.5]
D New 400kV substation and The Nemo Link is a High Voltage Direct Current interconnector which will connect the electricity converter station at systems of the UK and Belgium. The hybrid planning application relates to the development of Richborough as part of the a converter station (comprising main building, service building, storage building, single phase Nemo Link project and converter transformers, mechanically switched capacitor (MSC), shunt reactor, outdoor high internal access route voltage electrical equipment, distribution network operator substation and diesel generator) and Grid ref:TR332623 a new 400kV substation required to connect the converter station to the national grid on the former Richborough power station site and the installation of underground electricity cables.
The proposed converter station and 400kV substation development will comprise approximately 8 hectares. The overall dimensions of the converter station building are approximately 149m long, 93m wide and 30.3m high with the main 400kV substation building approximately 52.2m long, 21.5m wide and 15m high. It is understood that the main converter station building were to be constructed in part around the steel frame of the former Richborough power station’s turbine hall which was left in situ following demolition works. However, more recent information suggests that the existing turbine hall will now be demolished.
[Development 9 on Figure 5.1d within Volume 5, Document 5.3.5]
E Richborough Energy Park Two detailed planning applications have been submitted containing proposals for new - Peaking Plant, infrastructure on the site, and for a peaking plant to generate electricity. It is anticipated that the Richborough power station proposed development will comprise an array of diesel fired generators with approximately 42 Grid ref: TR332622 megawatts (MW) output, along with associated fuel storage, parking, and access. The proposals include a Power station, nine buildings 6m x 2.4m wide x 2.6m high and four chimneys 35m high.
Also proposed is the formation of an internal road network, erection of a weighbridge and office building together with associated landscaping and the installation of 0.45m razor wire to existing perimeter fence.
[Development 12 on Figure 5.1d within Volume 5, Document 5.3.5]
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Development ID Development name Brief description
Pre-application stage projects
F Strategic Development The site is included as a strategic allocation in the CCC draft local plan and seeks to provide: Site SP3 Site 2: Sturry and Broad Oak • land for employment; Grid ref: TR170603 • residential development; • improvements to parking facilities at Sturry Station; And • contributions to sustainable transport measures, including enhanced public transport opportunities, cycling and walking; • a new footbridge over the railway linking the new car park to the village centre; • small business units providing improved local services; • new public open spaces for recreation and leisure new football and cricket pitches; • new allotments and managed wildlife areas; and • a range of community facilities.
Sturry Link Road As identified in the CCC draft local plan (policy T14 Sturry Relief Road). This will form part of Grid ref: TR170603 SP3 site 2 development. New development sites allocated in Herne Bay, Sturry, Broad Oak and Hersden will be required to fund a Sturry relief road that avoids the level crossing by providing a new road bridge, including a bus lane over the railway line.
[Development 2 on Figure 5.1a within Volume 5, Document 5.3.5]
G Strategic Development This site is also included in the CCC draft local plan. Potential development could comprise up Site SP3 Site 8: Land to 500 dwellings, employment and community uses. [Development 3 on Figure 5.1a/b within North of Hersden Volume 5, Document 5.3.5] Grid ref: TR202623
H Communications Mast, Communications mast on the same site as Development B. Ramsgate Road Grid ref: TR328620 The proposed development includes the construction of a 320m high guyed steel lattice structure with anchor points and navigational warning lights and a site compound, secure perimeter fence, single storey equipment structure and associated development.
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Development ID Development name Brief description
It is recognised that this will be a tall structure, exceeding the height of the existing communications masts and wind turbine at Richborough and the height of the former power station cooling towers and chimney.
[Development 17 on Figure 5.1d within Volume 5, Document 5.3.5]
National Grid Permitted Development
I Canterbury North 400kV Upgrades to National Grid 400kV substation infrastructure and associated works including Substation demolition of existing buildings (existing garage, office, and workshops), alterations to flood Grid ref: TR160595 defence wall, new fencing, replacement plant and machinery building within compound and new internal access route. Installation of a new shunt reactor and associated access route at the substation.
[Development 4 on Figure 5.1a within Volume 5, Document 5.3.5]
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16.3.9 Following consultation with and agreement from the relevant local authorities, the developments summarised in Table 5.3 within Chapter 5 of this document have not been taken forward in the assessment and are scoped-out for the following reasons. The development: does not comprise ‘major’ development as defined in the Town and Country Planning (Development Management Procedure) (England) Order 2010; is understood to have already undergone construction or will be complete and operational before construction of the Richborough Connection project and therefore is part of the current baseline or will form part of the future baseline conditions and has been considered on that basis; is unlikely to have commenced prior to the completion of the Richborough Connection project and insufficient information is available to complete an assessment at this time. Therefore any cumulative effects assessment would need to be completed by the developer/applicant for that particular proposal; or is of sufficient distance from the Richborough Connection project that significant cumulative effects are not likely to occur. 16.3.10 Potential inter-project cumulative effects relating to each technical discipline are discussed below. The majority have considered potential effects by development. The exceptions to this are Historic Environment (Section 16.6), Biodiversity (Section 16.7); Geology, Soils and Agriculture (Section 16.12) and Socio-economics and recreation (Section 16.13); the rationale for the approach adopted is decribed in each section.
16.4 Assessment of Cumulative Effects: Landscape 16.4.1 An assessment of the potential inter-project cumulative effects from the interaction of the Richborough Connection Project and other major development proposals in the vicinity on Landscape is provided below. The assessment considers potential cumulative effects from each development scoped in to the assessment (see Table 16.2) in turn. 16.4.2 The assessment of potential cumulative effects on landscape character including effects on landscape elements and designations, judgements have been based on the method provided at Chapter 6, Section 6.8 of this document and Appendix 6A within Volume 5, Document 5.4.6A.
Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich 16.4.3 The application site falls wholly within The Sandwich Corridor defined within the DDC Landscape Character Areas (LCA) and outside the Richborough Connection project Order limits. The Sandwich Corridor LCA includes the large industrial estate for Pfizer, with a series of smaller individual industrial estates scattered within the area. Associated large scale car parks dominate significant sections of land. The DDC LCA includes that “There is an array of large scale, modern buildings, similar in style, with lots of windows, other glass panels and brick facades. The area is undergoing large-scale change with road widening and further industrial development. The lighting is dominant at night especially the roads and car parks which become more
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visible, the buildings are also heavily illuminated. The industrial buildings are square, high rise and built close together, producing a dominating and view blocking effect within the flat topography. They appear out of scale and character to the surrounding landscape and historic built vernacular of Sandwich itself.” Background documents relating to Landscape 16.4.4 A Landscape Statement has been prepared by Lloyd Bore264 as part of the planning application. The Landscape Statement states that “The development proposed is not dissimilar in terms of its physical appearance to many of the existing structures on the Discovery Park site. The proposed structures are large, but they would be free standing in an open landscape, but set in the context of other nearby large structures. The tallest chimney on the Discovery Park site is currently 43m in height.” The assessment also provides that the current combined heat and power (CHP) proposal is also consistent with historical land use/functions in the Sandwich corridor and surrounding areas, which have associations with power generation and “it is anticipated that the proposed development would have no adverse impact on the character or historic setting of Sandwich.” Landscape effects of the Committed Development 16.4.5 The Landscape statement prepared by Lloyd Bore concludes by stating “The surrounding landscape is one in which large scale industrial and commercial developments are already present. The CHP proposals would not introduce an unexpected new form or style of development into these views”. No significance of effect judgement has been given in this assessment but the landscape statement concludes that “…It will not significantly alter the nature, character or composition of the landscape, or the key views. It will not bring about a significant change in the perception of existing amenity value which is already determined by large scale industrial developments”. 16.4.6 Those aspects of Development A would result in potential effects on the landscape character include: The introduction of new buildings including the proposed chimney height would be 55m and the boiler hall shown at 35m high. Dominant lighting at night especially the roads and car parks. A blocking effect as a result of the proposed buildings within the flat Ash Levels topography. Potential for the built form to appear out of scale and character to the surrounding landscape and historic built vernacular of Sandwich itself. Effects on the Sandwich Corridor LCA. Richborough Connection project landscape receptors potentially affected by the Development 16.4.7 The existing PX Route and the existing large structures at Great Stonar Discovery Park are present in the landscape and reduce the susceptibility to change of the landscape from a new 400kV overhead line and from Development A. The Richborough Connection project study area extends as far as the Ash Level and
264 Landscape Statement, Estover Energy Proposed Biomass CHP Plant, ref 2711/R001, Lloyd Bore Ltd, July 2013
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Richborough Castle LCAs which have a respective low and medium susceptibility to change. Landscape elements which contribute to the LCAs include ditches, arable and pasture land and the vegetation associated with the River Stour. 16.4.8 The sensitivity of the landscape to the Richborough Connection project and Development A would be low given the landscape’s low susceptibility to change and the local value of the Sandwich Corridor LCA landscape within which Development A is proposed. The LCA is physically open, whilst visually enclosed by the large buildings associated with Discovery Park. Summary of the Richborough Connection project Landscape effects 16.4.9 No significance of effect has been identified as part of the Landscape Assessment for the Richborough Connection project as the study area does not extend as far as the Sandwich Corridor LCA, however the baseline assessment does include a description of Great Stonar and the presence of the existing buildings at Discovery Park which are large scale and in part industrial in nature. Effects are considered on the Ash Level which are predicted as minor adverse. 16.4.10 As stated above and discussed in Chapter 6, Section 6.10 of this document, the Richborough Connection project would have a minor adverse effect on landscape elements in the Ash Level in Section D. These features of the landscape which characterise the Ash Level have a low sensitivity to the proposed 400kV overhead line. The effect would be not significant. Potential Cumulative Effects (at operation) 16.4.11 The landscape is already influenced by existing infrastructure and urbanising influences and in the long term Development A would not be a discordant or major alteration to the features or characteristics of the LCAs identified. The significance of effect of the Richborough Connection project would be negligible as the proposed development would fit with the scale, landform and pattern of the landscape and enable the restoration of valued characteristic features partially lost through other uses to improve the landscape quality. 16.4.12 In terms of the cumulative magnitude of effect this would amount to no more than the partial alteration to key features or characteristics of the existing landscape and the introduction of prominent elements in the Sandwich Corridor LCA which are already present. The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development A would be negligible in the long term and therefore the significance of effect would not increase as a result of Development A. The effect would be not significant. Development B - Thanet Solar Farm, Ramsgate Road 16.4.13 The site is located close to the east cost of Kent, midway between Ramsgate (to the north) and Sandwich (to the south) within the Ash Level LCA. The area surrounding the site has been subject to change over the past few years. These have primarily been centred on the Richborough power station Site, culminating in the demolition of the cooling towers and clearance on the Richborough power station site in early 2012.
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Background documents relating to Landscape 16.4.14 A Planning, Design and Access Statement prepared by Montagu Evans265 provides at paragraph 6.42 that the northern perimeter of the site is where the areas of landscape and biodiversity value lie as the boundary is formed by the River Stour and that the site falls within the Ash Level and the site consists of semi-improved grassland, drained by a series of interconnected wet ditches which discharge into the River Stour. 16.4.15 A Landscape and Visual Impact Statement also prepared by Montagu Evans266 states that the development “will change the landscape from undeveloped pasture to a semi-industrial site. However this effect will be temporary; the pasture will remain in situ beneath the panels” and there will be no loss of landscape features. The document provides an assessment of the magnitude of change which is considered to be high given the change in the site, but given that the landscape features are of low sensitivity, the overall effect upon the landscape of the site are judged to the moderate. Landscape effects of the Committed Development 16.4.16 Those aspects of Development B would result in potential effects on the landscape character include: The introduction of a new installation of banks of photo-voltaic panels measuring 2.0m x 4.0m. Change to character of the Ash Level. Introduction of inverter cabinets and substations and associated hardstanding and potential for the built form to appear out of character to the surrounding landscape. 16.4.17 The Landscape and Visual Impact Statement states that “The development will change the character of the site itself, moving it towards that of the Sandwich Corridor LCA. However it is considered that the proposed development will not have any effects on the wider Ash Level LCA beyond the railway embankment. Whilst the change in character on the site itself is moderate, the effect upon the character of the LCA as a whole is considered to be negligible as the site is screened by the railway.” The Landscape and Visual Impact Statement concludes that the proposed development will have a very minor effect within the landscape. Whilst the effect upon the Ash Level LCA is high immediately surrounding the site, the wider area remains unaffected. Furthermore the statement provides that “the natural undulation of the landscape and the physical feature of the railway help to mask the low-lying development to the extent that it will have no discernable effect.” Richborough Connection landscape receptors potentially affected by the Development 16.4.18 The existing PX Route and Richborough Connection project fall within the Ash Level LCA where the solar farm is proposed. The Richborough Connection project Order limits includes the land proposed for Development B which falls within the Ash Level, this LCA has a low susceptibility to change. Landscape elements which contribute to the LCAs include ditches, arable and pasture land and the vegetation associated
265 A Planning, Design and Access Statement prepared by Montagu Evans (September 2013) 266 LVIA for Thanet Solar Ltd, prepared by Montagu Evans, September 2013
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with the River Stour. The sensitivity of the landscape to the Richborough Connection project and the proposed solar farm would be low given the landscape’s low susceptibility to change and the local value of the Ash Level LCA landscape within which Development B is proposed. Summary of the Richborough Connection project Landscape effects 16.4.19 As discussed in Chapter 6, Section 6.10 of this document the Richborough Connection project generally would have a minor adverse effect on the Ash Level LCA as there would be a low scale of change in an area already influenced by overhead lines and urbanising features in Section D. The landscape is already influenced by existing infrastructure and urbanising influences and in the long term the proposed development would not be a discordant or major alteration to the features or characteristics of the Ash Level LCA identified. 16.4.20 The Richborough Connection project would have a minor adverse effect on landscape elements during operation. The landscape features which characterise the Ash Level have a low - moderate sensitivity to the proposed 400kV overhead line. The effect would be not significant. Potential Cumulative Effect 16.4.21 Cumulatively the magnitude of effect caused by both developments would not increase the significance during their operation. Development B would involve a partial alteration to key features of the existing landscape character within the Ash Level, however, the landscape already includes renewable energy sites including Ebbsfleet Solar Farm, and Development B would not be out of character or cause detriment to the Ash Level LCA by loss of characteristic features. Furthermore the landscape is already influenced by the existing PX and PY routes which lie to the immediate south of the proposed solar farm development site. The sensitivity of the landscape is low and cumulatively the significance of effect would be minor adverse. This effect is not significant. 16.4.22 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and solar farm would be negligible in the long term. Development C - Discovery Park Masterplan 16.4.23 The site of Development C is adjacent to the A256 and Discovery Park is an existing operational employment site which accommodates approximately 255,000sqm of existing floorspace in a range of buildings (and associated structures) that include offices/laboratories, warehouses, industrial units, and associated plant/infrastructure. 16.4.24 The site falls wholly within the Sandwich Corridor LCA. Background Documents relating to Landscape 16.4.25 The planning background documents for Development C include a planning application document for committee purposes (2014)267 detailing the resolution to grant permission for the development. The document acknowledges that the proposals are in outline form and as such, the detailed design of any of the buildings cannot be fully considered at this stage and that whilst large, there are well designed, modern buildings that have become an established part of the local and wider landscape. The masterplan shows that a landscape strip of at least 40 metres could
267 Report to Planning Committee, authored by Lesley Jarvis (not dated)
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be provided around the western and southern edge of the site (between the highway and the proposed dwellings). It is considered that the landscaping along this stretch would be of particular importance, as it could provide a layering effect, to soften this development, from medium to longer distance views. In particular, this would reduce the impact of the proposal upon the conservation area to the south. 16.4.26 The Planning Statement268 states at paragraph 6.99 “The proposed development will alter the visual appearance of the landscape” however at paragraph 6.32 it states “The entire Park would be set within a high quality landscape which provides passive security for occupiers, an attractive setting for their activity, and integrates the site into the wider landscape setting.” Landscape effects of the Committed Development 16.4.27 Those aspects of Development C would result in potential adverse effects on the landscape character include: Demolition of some existing buildings. Erection of new commercial floorspace. Buildings up to 20m high. Associated site preparation/enabling, demolition, infrastructure, and landscaping works and provision of car parking. Change to character of the Sandwich Corridor LCA. 16.4.28 The ES269 for Development C contains a Landscape and Visual Impact Assessment (LVIA) of the proposed development. This sssessment identifies and assesses the impacts of the proposal on the site itself, and also the surrounding area. This part of the ES is in accordance with the scoping response that had been received from the District Council. This document assesses the environmental impacts of the proposal during construction, and during operation. During operation the following effects have been predicted: Moderate beneficial impacts of local and site landscape character and a result of the indicative masterplan. This would require the retention and enhancement of existing landscape features of value, integration of new landscape features of value, and ongoing management of the site to promote ecological habitat potential. Moderate beneficial impacts on footpaths and cycle ways as a result of the opening up of the western half of the site for public access. New public routes would contribute positively to the creation of sustainable development, by forming connections with the existing public route network, and connecting the site to Sandwich. Richborough Connection project landscape receptors potentially affected by the Development 16.4.29 The existing PX Route and the existing large structures at Great Stonar Discovery Park are present in the landscape and reduce the susceptibility to change of the
268GVA Grimley. Discovery Park Planning Statement. Document Ref. DP/Rep/3.1. January 2014. 269 Burro Happold. Discovery Park Environmental Statement. Report 031593; Revision 01. 20 January 2014.
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landscape from a new 400kV overhead line and Development C. The Richborough Connection project Order limits extends as far as the Ash Level and Richborough Castle LCAs which have a respective low and medium susceptibility to change. Landscape elements which contribute to the LCAs include ditches, arable and pasture land and the vegetation associated with the River Stour. 16.4.30 The sensitivity of the landscape to the Richborough Connection project and Development C would be low given the landscape’s low susceptibility to change and the local value of the Sandwich Corridor LCA landscape within which Development C is proposed. The LCA is physically open, whilst visually enclosed by the large buildings associated with Discovery Park. Summary of the Richborough Connection project Landscape effects 16.4.31 No landscape effects have been identified on the Sandwich Corridor LCA as part of the Landscape Assessment for the Richborough Connection project as the study area does not extend as far as the Sandwich Corridor LCA. However the baseline assessment does include a description of Discovery Park and the presence of the existing buildings at Discovery Park which are large scale and in part industrial in nature. Potential Cumulative Effects (at operation) 16.4.32 As discussed in Chapter 6, Section 6.10 of this document the proposed 400kV overhead line would have a minor adverse effect on landscape elements in the Ash Level in Section D. These features of the landscape which characterise the Ash Level have a low - moderate sensitivity to the proposed 400kV overhead line. The effect would be not significant. 16.4.33 The landscape is already influenced by existing infrastructure and urbanising influences and development and in the long term Discovery Park would be assimilated into the Sandwich Corridor LCA and wider Ash Level. 16.4.34 Cumulatively the magnitude of effect caused by both developments would not increase the significance during their operation. Development C would involve alteration to key features of the existing landscape character, however, the landscape already includes mixed development and would not be out of character or cause detriment to the Sandwich Corridor LCA by loss of characteristic features. Furthermore the landscape is already influenced by the existing PX and PY 132kV routes. The sensitivity of the landscape is low and cumulatively the significance of effect would be minor adverse. This effect is not significant. 16.4.35 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development C would be negligible in the long term. Development D - New 400kV substation and converter station at Richborough as part of the Nemo Link project 16.4.36 The Development D site mainly falls within ‘The Wantsum and Lower Stour Marshes’ LCA, although the underground cable connection crosses a small section of the ‘Thanet’ LCA, which is to the north of ‘The Wantsum and Lower Stour Marshes’ LCA.
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Background documents relating to Landscape 16.4.37 A Design and Access Statement (February 2013)270 for Development D includes at paragraph 5.27 that landscaping will be implemented around the perimeter of the converter station and 400kV substation to help integrate the proposed development site into the landscape setting. Landscaping will largely consist of tree planting at the eastern boundary with existing shrub and poplar trees at the northern boundary being retained and enhanced. Species rich grassland, areas for a mixture of native and fruit tree planting and ecological corridors are also proposed as part of the wider landscaping works for the estate road which is currently being developed under a separate planning application by Richborough A Limited. Paragraph 5.23 provides that the converter station and 400kV substation have been carefully designed to consider the existing and proposed surroundings, including the Thanet Offshore Wind Farm 132kV substation and the UK Power Networks 132kV substation immediately south of the proposed site and the proposed Richborough Energy Park. 16.4.38 The Non Technical Summary (February 2013)271 for Development D includes a summary on landscape and views which includes the following statements “The converter station and substation development would be consistent with the existing landscape character of the site and immediate surroundings and would match the scale of existing industrial built form. The existing landscape character of the underground cable route is generally urban as the route runs close to the A256 and the landscape will be reinstated following construction.” It continues with the summary assessment and states “The underground cable route would have no effect on landscape character or views 15 years after the reinstatement of land. The above ground cable route through the northern part of Pegwell Country Park will be quickly re-established as chalk grassland resulting in a very limited negative effect on landscape and views after reinstatement. Following 15 years’ establishment of the planting proposals surrounding the converter station and substation site it is anticipated that there would be a small negative effect on landscape character as the development would increase the extent of industrial development evident in the locality.” 16.4.39 The Design and Access Statement includes that the converter station and 400kV substation buildings will be clad in galvanised steel around steel frames. A recessive green colour lightening gradually to a green-white finish will be used on the converter station building which will enable it to appear recessive in the surrounding landscape. The 400kV substation will be finished in a recessive green cladding to match the lower sections of the converter station. The tallest part of the proposed converter station and 400kV substation will be the valve halls of the converter station. 16.4.40 A full Landscape Assessment of Development D is provided in the ES (February 2013)272 and includes at paragraph 10.103 that the landscape within and surrounding the application site is not covered by any landscape designations and is generally judged to be of local value to nearby residents and at paragraph 10.104 that the landscape condition of the application site and immediate surroundings is generally poor. This reflects recent development along the coastline and changes in
270 Nemo Link Design & Access Statement, dated February 2013 271 Nemo Link Environmental Statement, February 2013, prepared by TEP for National Grid Nemo Link Limited 272 Ibid
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agricultural practices in the surrounding landscape. It is concluded that overall the landscape is of low sensitivity to change. Landscape effects of the Committed Development 16.4.41 Those aspects of Development D would result in potential effects on the landscape character include: The introduction of a main building: The tallest part to a maximum height of approximately 30.8m will be based around the former turbine hall frame and will be approximately 38.3m long and 93m wide. Service and Storage buildings: These buildings will be approximately 27.4m long, 13.6m wide and 14.5m high. The tallest equipment for electrical equipment will be overhead gantries at approximately 15m high. A new National Grid 400kV substation. External lighting. Effects on the ‘Wantsum and Lower Stour Marshes’ LCA. The condition of this landscape character area has been determined as being poor, and the area has been assessed as being moderately sensitive to landscape change. 16.4.42 At completion the following assessments have been made in paragraphs 10.124 – 10.127 of the ES: “Following reinstatement of the cable swathe the magnitude of effect on landscape character as a result of the proposed cable route (including the overground section of cable through the northern part of Pegwell Country Park and along the A256 in this locality), would be negligible. The overground cable route would comprise a low adverse magnitude of effect on the landscape. The landscape has a low sensitivity to change and overall the underground cable route would result in a neutral significance of effect. Implementing the Proposed Development at the converter station and substation site would be consistent with the existing character of the A256 coastal corridor between Ramsgate and Sandwich, which already comprises industrial development and includes the derelict site of the former Richborough power station. The magnitude of effect on the landscape character of the converter station and substation site on completion (and prior to mitigation) would be low adverse. The landscape has a low sensitivity to change which would result in a minor adverse significance of effect (prior to mitigation). The assessment concludes that after 15 years following establishment of the structure planting proposals, surrounding the converter station and substation, “the residual effects on landscape character would be minor adverse.”
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Richborough Connection project landscape receptors potentially affected by the Development 16.4.43 The nearest section of 400kV overhead line of the Richborough Connection project falls within the Former Wantsum Channel LCA where Development D is proposed. This LCA is of medium sensitivity. Landscape elements which contribute to the LCA include ditches, arable and pasture land and the vegetation associated with the River Stour and the setting to Minster, Monkton, Sarre and St Nicholas. Section D is the only section of the proposed development where a section of the PY route would run parallel with the 400kV overhead line. This gives rise to a lower magnitude of effect as there would be a smaller alteration only to important features of this LCA and the introduction of features which are already present in the landscape, although they would be larger in scale. Summary of the Richborough Connection project Landscape effects 16.4.44 As discussed in Chapter 6, Section 6.10 of this document the Richborough Connection project in Section D would result in a minor adverse effect on the Former Wantsum Channel as there would be a low scale of change in an area already influenced by overhead lines and urbanising features. This is not significant. Potential Cumulative Effects 16.4.45 Although Development D would introduce elements that are generally characteristic of the surrounding landscape, it would extend built development across the existing derelict site, which would increase the extent of industrial development presently evident in the locality. 16.4.46 Cumulatively the magnitude of effect caused by both developments would not increase the significance during their operation. Furthermore the landscape is already influenced by the existing PX and PY routes and wider industrial and former industrial landscape. The sensitivity of the landscape is medium and cumulatively the significance of effect would be moderate adverse as there would be a perceivable scale of change to the character of the landscape for the medium and long-term. This effect is significant. 16.4.47 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development D would be moderate adverse in the long term. This will only occur where effects of the proposed 400kV substation and converter station overlap with the effects of the overhead line. Development E - Richborough Energy Park - Peaking Plant, Richborough power station 16.4.48 A landscaping strategy has been prepared as part of the proposals for Development E, which will incorporate appropriate ecological mitigation and a range of measures to enhance the ecology of the site. The western part of the site will be protected and enhanced as part of the proposed development and appropriate measures will be implemented to ensure no adverse impacts will occur to nearby designated sites. Background Documents relating to Landscape 16.4.49 The ES273 for Development E describes the location of the Peaking Plant which is bounded by the UK Power Networks 132kV substation to the north, a thin strip of
273 URS. Richborough Peaking Plant Facility and Internal Road Network & Landscaping; Environmental Statement. December 2012.
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grassland to the east beyond which is the A256 Ramsgate to Sandwich Road, part of a 8 ha site with planning permission for a waste recycling service to the south, and the River Stour to the west. A number of potential environmental sensitivities/sensitive receptors are included at section 2.4, and include landscape receptors as follows: Ash Level and South Richborough Pasture Woods which is located on the opposite side of the River Stour from the site; Roman Fort and Amphitheatre. 16.4.50 The ES provides a full landscape assessment at Chapter 14. Paragraph 14.4.6.2 describes the Kent LCAs which cover the application site and Figure 14-4 shows that Development E falls within the Sandwich Corridor LCA and the internal roads fall within the Former Wantsum Channel LCA. The landscape assessment states that “Due to its openness, degree of exposure and semi-natural habitats, the Sanwich Corridor is assessed as being of High sensitivity.” and the Former Wantsum Channel LCA is also of High sensitivity due to “its flatness, openness and the presence of numerous historic features”. Landscape effects of the Committed Development 16.4.51 The ES for Development E outlines the potential effects of the development on the landscape at paragraph 14.5.2.1.1 which include the following: Site clearance operations, including the removal of existing trees and scrub and existing earthworks; Removal of existing structures, materials and debris from the site and establishment of temporary site compounds; Stockpiling of materials on the site; Construction of temporary haulage roads across the site; and Movements of heavy construction traffic and other vehicles. 16.4.52 Potential impacts of the Peaking Facility are discussed at 14.5.2 and the assessment states “At Year 15 it is assumed that new planting would be well established and that management of existing vegetation would have been effective in enhancing the perimeter screening and habitat diversity. Any likely residual Impacts have been identified. Although the planting scheme surrounding the Peaking Plant Facility Site would have begun to mature, screening the 3m high acoustic fence, the presence and prominence of the 35m high chimney stacks and the operation of the generators within the Site would continue to result in adverse, direct and indirect Impacts on LCA D: The Sandwich Corridor, following 15 years of operation. Given the small part of this LCA which would be occupied by the Peaking Plant Facility and its low sensitivity, the impact would not be significant and is therefore considered minor adverse. Indirect Impacts on the character of the surrounding area would continue to result from intervisibility with the Peaking Plant Facility Site and in particular the proposed chimney stacks which would permanently alter the skyline locally. Sky-glow caused by the escape of light during operation after dark would cause adverse, indirect Impacts on character locally. These impacts, however, would not be significant and are considered minor adverse.”
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16.4.53 Potential impacts on the internal road network and landscaping are considered at paragraph 14.5.2.2.1 and discussed as follows: “By Year 15 of operation the mitigation planting would have begun to mature and would provide structure to the eastern boundary of the site in particular. There would continue to be adverse, direct impacts on LCA D and LCA H although these are expected to minor adverse and not significant. The remaining areas would experience either negligible or minor adverse impacts.” Richborough Connection project landscape receptors potentially affected by the Development 16.4.54 The nearest section of 400kV overhead line of the Richborough Connection project falls within the Former Wantsum Channel LCA to the immediate right of the Development E site. This LCA is of medium sensitivity. Landscape elements which contribute to the LCA include ditches, arable and pasture land and the vegetation associated with the River Stour and the setting to Minster, Monkton, Sarre and St Nicholas. Section D is the only section of the proposed development where a section of the PY route would run parallel with the 400kV overhead line. This gives rise to a lower magnitude of effect as there would be a smaller alteration only to important features of this LCA and the introduction of features which are already present in the landscape, although they would be larger in scale. Summary of the Richborough Connection project Landscape effects 16.4.55 As discussed in Chapter 6, section 6.10 of this document the Richborough Connection project in Section D would result in a minor adverse significance of effect on the Former Wantsum Channel as there would be a low scale of change in an area already influenced by overhead lines and urbanising features. This is not significant. Potential Cumulative Effects 16.4.56 Cumulative effects would arise from the increased scale and extent of built development on land which is currently open and exposed but which is currently of poor quality and value. 16.4.57 However, cumulatively the magnitude of effect caused by both developments would not increase the significance during their operation. Furthermore the landscape is already influenced by the existing PX and PY 132kV routes and wider industrial and former industrial landscape. It is considered that the cumulative effect of the two schemes on landscape character would be adverse but not significant. The sensitivity of the landscape is medium and cumulatively the effect would be minor adverse due to the perceived scale of change in this character area. This effect is not significant. 16.4.58 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development E would be minor adverse in the long term and not significant.
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Pre-application stage projects Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak and Sturry Link Road 16.4.59 The development site falls within The Stour Valley (Sturry and Fordwich) LCA and Stour Valley Slopes LCA as defined in the Canterbury District Landscape Character Areas. Background documents relating to Landscape 16.4.60 There are no specific documents relating to landscape or an assessment available. The key information is provided on the developer website274 and within the CCC draft local plan. Landscape effects of the Committed Development 16.4.61 Those aspects of Development F would result in potential adverse effects on the landscape character include: Development of business, community infrastructure and up to 1,000 new homes. Associated site preparation/enabling, demolition, infrastructure, and landscaping works and provision of car parking. Change to character of the The Stour Valley (Sturry and Fordwich) LCA and Stour Valley Slopes LCA. Richborough Connection project landscape receptors potentially affected by the Development 16.4.62 Landscape receptors include the following: Den Grove Ancient woodland. Individual trees and hedgerow. Stour Valley (Sturry and Fordwich) and Stour Valley Slopes LCAs. Canterbury AHLV. Sturry conservation area. Summary of the Richborough Connection Project Landscape Effects 16.4.63 Stour Valley Slopes: The overall condition is poor and there are many detracting features in the landscape which downgrade the overall character. Overall, the magnitude of effect on landscape character arising from the construction operations would be minor adverse. A moderate magnitude of effect would be experienced where working areas would be clustered, where ancient woodland is coppiced or where the landscape is more open or on elevated ground enabling longer distance views. These effects would reduce further away from the construction operations. The Stour Valley Slopes are of low sensitivity and the overall effect would be minor adverse and not significant. 16.4.64 Stour Valley (Sturry and Fordwich): The land use is mainly improved pasture with an overall moderate condition and medium sensitivity. Where the valley has remained
274 ED Sturry Ltd and Somerlee Homes Ltd. Updated strategic diagram from Canterbury City Council draft plan for final consultation. No date available. Available from http://www.sturrybroadoak.info/about.html
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undeveloped and the traditional pattern of ditches and meadows is distinct there is a strong landscape character. Localised direct effects on landscape character would arise from the removal and laying of hedgerows and hedgerow trees prior to construction. Overall, the magnitude of effect on landscape character arising from the construction operations would range from low to moderate adverse. Moderate magnitudes of effect would be experienced where working areas would be more visible. Elsewhere activities would give rise to low adverse effects which would reduce to minor adverse and negligible further away from the construction operations. The overall effect would be minor adverse and not significant. Potential Cumulative Effects (at operation) 16.4.65 As discussed in Chapter 6, Section 6.10 of this document the proposed 400kV overhead line would have a minor adverse effect on landscape elements in Section A. These features of the landscape which characterise the Stour Valley have a low - moderate sensitivity to the proposed 400kV overhead line. The effect would be not significant. 16.4.66 The landscape is already influenced by existing infrastructure and urbanising influences and development and residential character of Broad Oak and Sturry. These settlements already experience a landscape with existing overhead infrastructure. The Richborough Connection project will remove the existing PX route through Broad Oak and avoid these settlements. 16.4.67 Cumulatively the magnitude of effect caused by both the Richborough Connection project and Development F would not increase the significance during their operation. Development F would involve alteration to key features of the existing landscape character however the landscape already includes mixed development and would not be out of character or cause detriment to the Stour Valley by loss of characteristic features. Furthermore the landscape is already influenced by the existing PX route. The sensitivity of the landscape is low and cumulatively the effect would be minor adverse. This effect is not significant. 16.4.68 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development F would be negligible in the long term. Development G - Strategic Development Site SP3 Site 8: Land North of Hersden Background documents relating to Landscape 16.4.69 No specific documents have been published at this stage with regards to a landscape assessment. Background information is provided on the Hume Planning website.275 16.4.70 Information includes that “Following a recent announcement by the National Grid the preferred pylon route will not affect the allocation north of Hersden and Hume Planning will reflect this updated position when appearing later at the Canterbury Local Plan Examination.” 16.4.71 The Development G site falls within the Hoath Farmlands LCA as defined in the Canterbury Landscape Character Assessment.
275 Hume Planning Consultancy. Strategic Site identified north of Hersden in the submission version of the Canterbury Local Plan. 25 June 2014. Available from http://www.humeplanning.co.uk/news/strategic-site-identified-north-hersden- submission-version-canterbury-local-plan/
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Landscape effects of Development 16.4.72 Those aspects of Development G which would result in potential adverse effects on the landscape character include: Development of business, community infrastructure and up to 500 new homes. Associated site preparation/enabling, demolition, infrastructure, and landscaping works and provision of car parking. Change to character of the The Hoath Farmlands LCA. Richborough Connection landscape receptors potentially affected by the Development 16.4.73 Key receptors include: Individual trees and hedgerow (low sensitivity). Hoath Farmlands LCA (medium sensitivity). Summary of the Richborough Connection project Landscape effects 16.4.74 Hoath Farmlands: This is an open arable landscape with medium to large scale fields with small isolated woodland and of medium sensitivity. The overall condition is poor and there has been extensive loss of hedgerows as a result of agricultural intensification. The magnitude of change would be low as construction activities would result in a minor alteration to key features and would be a low scale of change in the short term. This would be a minor adverse effect and is therefore not significant. Potential Cumulative Effects 16.4.75 As discussed in Chapter 6, Section 6.10 of this document the proposed 400kV overhead line would have a minor adverse effect on landscape elements in Section A. These features of the landscape which characterise the landscape have a low - moderate sensitivity to the proposed 400kV overhead line. The effect would be not significant. 16.4.76 The landscape is already influenced by existing infrastructure and residential development. These settlements already experience a landscape with existing overhead infrastructure. The Richborough Connection project will however be closer to Development G. 16.4.77 Cumulatively the magnitude of effect caused by both the Richborough Connection project and Development G would not increase the significance during their operation. Development G would involve alteration to key features of the existing landscape character however the landscape already includes mixed development and would not be out of character or cause detriment to the Hoath Farmlands by loss of characteristic features. Furthermore the landscape is already influenced by the existing PX route. The sensitivity of the landscape is low and cumulatively the significance of effect would be minor adverse. This effect is not significant. 16.4.78 The cumulative significance of effect on landscape character as a result of the Richborough Connection project and Development G would be negligible in the long term.
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Development H - Communications Mast, Ramsgate Road Background documents relating to Landscape 16.4.79 A Screening Opinion request prepared by Montagu Evans276 states that the proposed development has a very limited number of issues from which impacts could arise, predominantly focussing on the landscape and visual effects of the scheme. 16.4.80 The Screening Opinion received from Dover District Council277 (9 September 2015) considers the characteristics of the potential impacts and states “Having considered the characteristics of the development, the sensitivity of the location and characteristics of potential effects, it is considered that the proposed development will likely have significant effects on a large number of receptors arising predominantly from the operational stage of the mast. In summary the development will likely have significant effects on heritage assets, ecology and ornithology, the landscape and visual amenity, socio-economics and health matters (perceived and/or actual).” Landscape effects of the Committed Development 16.4.81 The Request for a Screening Opinion prepared by Montagu Evans states that “It is noted that the site [of Development H] can be seen from the Richborough Fort Scheduled Ancient Monument when looking towards Pegwell Bay and Ramsgate. The impact of the proposals against this setting is considered to be minimal given the industrial character of the immediate area and the setting of the Power Station, Ebbsfleet Solar Farm and the Southern Water treatment facility behind the proposals”. 16.4.82 Those aspects of the proposed Communications Mast which could result in potential effects on the landscape character include: The introduction of a new mast circa 320m high. Effects to character of the Ash Level. Richborough Connection project landscape receptors potentially affected by the Development 16.4.83 The existing PX Route and Richborough Connection project fall within the Ash Level LCA where Development H is proposed. The Ash Level LCA has a low susceptibility to change. Landscape elements which contribute to the LCAs include ditches, arable and pasture land and the vegetation associated with the River Stour. The sensitivity of the landscape to the Richborough Connection project and Development H would be low given the landscape’s low susceptibility to change and the local value of the Ash Level LCA landscape. Summary of the Richborough Connection project Landscape effects 16.4.84 As discussed in Chapter 6, Section 6.10 of this document the Richborough Connection project generally would have a minor adverse effect on the Ash Level LCA as there would be a low scale of change in an area already influenced by overhead lines and urbanising features in Section D. The landscape is already influenced by existing infrastructure and urbanising influences and in the long term
276 Request for Screening Opinion for proposed communications mast, submitted to Dover District Council and prepared by Montagu Evans, dated 18 August 2015. 277 Dover District Council. EIA Screening Opinion for a 320m high Communications Mast. 09 September 2015.
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the proposed development would not be a discordant or major alteration to the features or characteristics of the Ash Level LCA identified. Potential Cumulative Effects 16.4.85 The proposed 400kV overhead line would have a minor adverse effect on landscape elements during operation. The landscape features which characterise the Ash Level have a low - moderate sensitivity to the proposed 400kV overhead line. The effect would be not significant. 16.4.86 Cumulatively the magnitude of effect caused by both developments would have the potential to increase the significance of effects during their operation. Development H would result in a notable alteration to the existing landscape character within the Ash Level due to the height and visibility of the structure and the introduction of a new structure into this part of the LCA. The landscape is however already influenced by the existing PX and PY routes which lie to the immediate south of the proposed communications mast site. The sensitivity of the landscape is low and cumulatively the effect would be moderate adverse. This effect is significant. 16.4.87 The cumulative effect on landscape character as a result of the Richborough Connection project and Development H would be minor adverse in the long term which is not significant.
National Grid Permitted Development Development I - Canterbury North 400kV Substation Background documents relating to Landscape 16.4.88 There are no specific documents relating to landscape prepared for the proposals at this stage. Landscape effects of the Committed Development 16.4.89 The Planning Statement prepared by CgMs (March 2015)278 whilst specifically dealing with the mitigation for new ponds includes that “amenity effects are confined to those associated with the excavation activities, vehicle and machinery movements and any water pumping activities. Amenity effects can be controlled by appropriate site management techniques and will not give rise to significant issues. There will be limited excavation machinery and personnel involved in the operations. Hours of working will be restricted to avoid the need for mobile lighting and excavators will be fitted with ‘white noise’ systems to avoid impacts associated with reversing alarms.” Richborough Connection project landscape receptors potentially affected by the Development 16.4.90 The sensitivity of the landscape to the Richborough Connection project and Development I would be low given the landscape’s low susceptibility to change and the absence of a sensitive landscape character area in which the proposals would be sited. Summary of the Richborough Connection project Landscape effects 16.4.91 As discussed in Chapter 6, Section 6.10 of this document the Richborough Connection project generally would have a minor adverse effect on the Canterbury AHLV which has a low sensitvity as there would be a low scale of change in an area
278 Planning Statement for the Proposed Mitigation Ponds prepared by CgMs on behalf of National Grid, dated March 2015
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already influenced by overhead lines and urbanising features and existing National Grid 400kV and UK Power Networks 132kV substations in Section A. The landscape is already influenced by existing infrastructure and urbanising influences and in the long term the proposed development would not be a discordant or major alteration to the features and such infrastructure would be complimentary to the Richborough Connection project. Potential Cumulative Effects 16.4.92 The proposed 400kV overhead line would have a minor adverse effect on landscape elements during operation. The effect would be not significant. 16.4.93 Cumulatively the magnitude of effect caused by both developments would not increase the significance of effect during their operation. The landscape is however already influenced by the existing wirescape and substations. The sensitivity of the landscape is low and cumulatively the effect would be minor adverse and not significant. 16.4.94 The cumulative effect on landscape character as a result of the Richborough Connection project and Development I would be negligible in the long term which is not significant.
Combined cumulative effects 16.4.95 The potential cumulative effects arising from the construction of the Richborough Connection project against a baseline situation consisting of all consented projects is considered for Section D where there are six committed developments in close proximity which have the potential to effect the same receptors: Discovery Park Biomass Plant (Development A); Thanet Solar Farm (Development B); Discovery Park Masterplan (Development C); Nemo Link associated development (Development D); Richborough Energy Park Peaking Plant (Development E); and Richborough Communications Mast (Development H). These receptors are as follows: Former Wantsum Channel LCA; The Sandwich Corridor LCA; The Ash Level LCA; and The Richborough Castle LCA. 16.4.96 Cumulatively the magnitude of effect caused by all six developments would have the potential to increase the significance during their operation. The developments would involve a notable alteration to the existing landscape character areas due to the height and visibility of the structures and the introduction of a new structures into the LCAs. The landscape is however already influenced by the existing PX and PY routes. The sensitivity of the landscape varies from low in the Ash Level LCA to exceptional in the Richborough Castle LCA and cumulatively the significance of effect would be moderate adverse. This effect is significant. 16.4.97 With reference to paragraph 7.28 of the GLVIA 3rd Edition, the proposed development would not comprise a ‘tipping point’ which would give rise to greater significance of adverse effects on the landscape cumulatively with other projects. The assessment establishes that the cumulative changes do not exceed the tipping
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point that would fundamentally change the landscape character and exceed the limits of acceptable development defined by the development plans.
16.5 Assessment of Cumulative Effects: Visual effects 16.5.1 Cumulative visual effects are the combined effects that arise through the interaction of two or more developments, whether of the same type or not, within the landscape and visual baseline context. They are described as effects that can be caused by combined visibility, which occur where the observer is able to see two or more developments from one viewpoint, and/or sequential effects which occur when the observer has to move to another viewpoint to see the different developments. Sequential effects usually arise where road or footpath users travel regularly along routes. 16.5.2 The cumulative visual assessment assesses the potential cumulative effects on views which may result from the combined effects of the Richborough Connection project and other major development proposals scoped-in, as identified in Table 16.2 within this Chapter and as shown on Figures 5.1a to 5.1d within Volume 5, Document 5.3.5. The assessment is considered by development and is undertaken in accordance with the method provided at Section 7.8 within Chapter 7, of this document and Appendix 7A within Volume 5, Document 5.4.7A.
Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich Background documents reviewed 16.5.3 To inform the cumulative assessment reference has been made to the visual appraisal presented in the Landscape Statement for Development A dated July 2013264. Visual effects of the Committed Development 16.5.4 The visual appraisal considered the visual characteristics of the site with four viewpoints agreed with DDC as LPA; two representing sensitive vantage points and two representing typical views. These viewpoints were the White Cliffs Country Trail/Saxon Shore Way (high sensitivity receptor), Richborough Fort (very high sensitivity) and two views from public rights of way crossing the Princes Golf Links (sensitivity not stated). 16.5.5 The baseline conditions are described such that ‘the Discovery Park site and associated development and structures have a high degree of visual accessibility from nearly all directions, largely due to the level topography, the general absence of significant areas of intervening vegetation cover, the substantial scale of existing development and the light colour and sometimes reflective materials and finishes used’. Discovery Park is further described as being a ‘significant and prominent visual component of the landscape, attracting the eye and impacting upon many views within the study area’. 16.5.6 The visual appraisal describes the magnitude of change on views from the public rights of way as being low, mainly due to the presence of intervening vegetation. The magnitude of change on views from Richborough Fort is described as being medium with the chimney and turbine hall being visible through and beyond a substantial belt of vegetation that runs along the south eastern boundary of the Fort. It states that
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the CHP plant ‘would represent one of many built developments within the Discovery Park complex and its presence would not be unexpected in the view’. 16.5.7 The appraisal concludes that the potential for adverse visual impacts upon the setting of Richborough Fort and from other viewpoints must be viewed in the context of existing large scale commercial and industrial developments already within Discovery Park. Development A will introduce new built forms into key views but will not significantly alter the nature, character or composition of those views. Richborough Connection project visual receptors potentially affected by the Development 16.5.8 The combined or sequential visibility of Development A and the Richborough Connection project has the potential to affect the following visual receptors: people on the Saxon Shore Way (ref D1.F3), Stour Valley Walk (ref D2.16) and on Sustrans Routes 1 and 15 (ref D1.F10); residents living on Castle Road, Richborough (ref D2.13); visitors to the Richborough Roman Fort (ref D2.14); road users on the Richborough Way (ref D2.8) & A256, Sandwich by-pass (ref D1.R3) and railway users (ref D1.R6); and people at their place of work on the A256 (ref D1.B1) and at Discovery Park (ref D2.15). Summary of the Visual effects arising from the Richborough Connection project 16.5.9 These public and private visual receptors were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in minor adverse or negligible effects and these are not significant. Potential Cumulative Effects (at operation) 16.5.10 The two developments are approximately 2km apart. The proposed 400kV overhead line and Development A would only be seen in the same view when viewed from the north. Road users on the elevated Richborough Way (D2.8) would see the 400kV pylons in the middle distance and the Development A in the far distance. The developments would both be seen in the context of the industrial setting of Ebbsfleet, Richborough and Great Stonar and would not be unexpected or particularly prominent. The combined visual effect would be negligible and not significant. 16.5.11 Visitors to the Richborough Roman Fort (ref D2.14), residential properties on Castle Road (ref D2.13) and walkers on the Saxon Shore Way (ref D1.F3) and Stour Valley Walk (ref D2.16) would experience combined visual effects where the observer has to turn their head to see both developments from the same viewpoint. However, given the distance of view and the low alteration to the view, the cumulative effects remain minor adverse and are not significant. 16.5.12 Sequential visual effects would arise for road users on the A256, Sandwich by-pass (ref D1.R3), cyclists on the Sustrans Route 15 (ref D1.F10) and railway travellers on the Ramsgate to Sandwich railway line (ref D1.R6). These receptors would observe the two developments in sequence and with a fairly large distance between them. The low alteration to the view and the relatively large time lapse between
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appearances would not give rise to a higher level of significance and the cumulative effects remain negligible and are not significant. Development B - Thanet Solar Farm, Ramsgate Road Background documents reviewed 16.5.13 To inform the cumulative assessment reference has been made to the Landscape and Visual Impact Statement for Development B, dated September 2013265. Visual effects of the Committed Development 16.5.14 The LVIA appraised the visual characteristics of the site and identified 6 publicly accessible viewpoints within the Zone of Theoretical Visibility (ZTV). Representing the views of recreational visitors to the Richborough Roman Fort, the Saxon Shore Way and those passing through the area by rail. The LVIA notes that ‘the proposed solar farm would have some moderate adverse visual effects on the Saxon Shore Way over the life of the development when walkers are in relatively close proximity and where gaps in vegetation would allow open views towards the development’. At the northern end of the footpath views are fleeting and glimpsed and are considered minor and adverse. In longer distance views from Richborough Fort there would be no visual effect due to effects being ‘significantly reduced due to the low lying nature of the development, the separating distances and the interposing landscape features’. In all cases it is noted that the proposed development would be seen in the context of large industrial and commercial buildings and in an area already characterised by renewable energy generation. Richborough Connection project visual receptors potentially affected by the Development 16.5.15 The combined or sequential visibility of Development B and the Richborough Connection project has the potential to affect the following visual receptors: people on the Saxon Shore Way (ref D1.F3) and on the railway (ref D1.R6); people at their place of work on the A256 (ref D1.B1); and visitors to the Richborough Roman Fort (ref D2.14). Summary of the Visual Effects arising from the Richborough Connection Project 16.5.16 These public and private visual receptors were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in effects of minor adverse or negligible significance and these are not significant. Potential Cumulative Effects (at operation) 16.5.17 The two developments are in close proximity to one another. The proposed 400kV overhead line and Development B would be seen together in easterly views from nearby sections of the Saxon Shore Way (ref D1.F3). The terminal standard lattice pylon and a sequence of low height pylons would be seen crossing the near and middle distance view with the solar farm partially visible beyond intervening hedgerows. The two developments would introduce additional but familiar elements into a moderate portion of the view and the magnitude of effect would be moderate adverse. The cumulative visual effects would give rise to a higher level of significance from a short section of this PRoW and are considered to be moderate adverse, which is significant.
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16.5.18 Rail users (ref D1.R6) would have transient and partial views of the 400kV pylons and Development B in the near and middle distance. There would be a low alteration to the view which would not give rise to a higher level of significance and the cumulative effects remain negligible and are not significant. 16.5.19 Visitors to the Richborough Roman Fort (ref D2.14), would experience combined visual effects, however given the distance of view and the very low alteration to the view, the cumulative visual effects remain minor adverse and are not significant. 16.5.20 Workers in their place of work at industrial and commercial businesses along the A256 (ref D1.B1) would experience combined visual effects, however given that the proposed developments would not be discordant with the baseline environment, and the small proportion of the view affected, the cumulative visual effects remain negligible and are not significant. Development C - Discovery Park Masterplan, Sandwich Background documents reviewed 16.5.21 To inform the cumulative assessment reference has been made to the Planning Statement268 and also to the case officer’s report to the planning committee267 for Development C. Visual effects of the Committed Development 16.5.22 The existing built form at Discovery Park already has a significant impact on both the local environment and views from further afield. This is because of the scale of the buildings and the very flat topography. The parameter plans show the tallest buildings to be located at the northern end of the site, which is considered less sensitive. The Planning Statement for Development C states that although the proposed development will alter the visual appearance of the landscape the development will not detract from the setting of Discovery Park in the wider landscape. 16.5.23 The Development C masterplan shows that a landscape strip of at least 40m would be provided around the western and southern edges of the site (between the highway and the proposed dwellings). It considers that the landscaping along this stretch would be of particular importance, as it would provide a layering effect, to soften the development, from medium to longer distance views. 16.5.24 The Planning Statement states at paragraph 6.99 “The proposed development would alter the visual appearance of the landscape” however at paragraph 6.32 it states that ‘the entire Park would be set within a high quality landscape which provides passive security for occupiers, an attractive setting for their activity, and integrates the site into the wider landscape setting”. 16.5.25 The planning report refers to the LVIA which identifies a number of moderate and minor adverse visual effects arising during the construction phase, such as from HGV movements; the moving and re-location of materials, construction lighting and accommodation. 16.5.26 Adverse visual effects arising from the operation phase are limited to short range views from Monk’s Way and from other publicly accessible highways and footpaths. However the planning report states that "through the provision of high quality design, and landscaping provision, this can be in part mitigated”. 16.5.27 Whilst the site is highly visible from long distance views, the report considers that it would remain relatively self-contained and the proposed development would ‘taper’
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with lower level buildings around the perimeter and the bulkier, higher buildings located centrally, and to the north. This would ensure that there would be no hard/harsh elevations alongside the main access route, which would be visible from a longer distance. Richborough Connection project visual receptors potentially affected by the Development 16.5.28 The combined or sequential visibility of Development C and the Richborough Connection project has the potential to affect the following visual receptors: people on the Saxon Shore Way (ref D1.F3), Stour Valley Walk (ref D2.16) and on Sustrans Routes 1 and 15 (ref D1.F10); residents living on Castle Road, Richborough (ref D2.13); visitors to the Richborough Roman Fort (ref D2.14); road users on the Richborough Way (ref D2.8) & A256, Sandwich by-pass (ref D1.R3) and railway users (ref D1.R6); and people at their place of work on the A256 (ref D1.B1) and at Discovery Park (ref D2.15). Summary of the Visual effects arising from the Richborough Connection project 16.5.29 These public and private visual receptors were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in minor adverse or negligible effects and these are not significant. Potential Cumulative Effects (at operation) 16.5.30 The two developments are approximately 2km apart. The proposed development and Development C would only be seen in the same view when viewed from the north. Road users on the elevated Richborough Way (ref D2.8) would see the 400kV pylons in the middle distance and the extended Discovery Park in the far distance. The developments would both be seen in the context of the industrial setting of Ebbsfleet, Richborough and Great Stonar and would not be unexpected or visually prominent. The combined visual effect from these receptors would be negligible and not significant. 16.5.31 Visitors to the Richborough Roman Fort (ref D2.14), residential properties on Castle Road (ref D2.13) and walkers on the Saxon Shore Way (ref D1.F3) and Stour Valley Walk (ref D2.16) would experience combined visual effects where the observer has to turn their head to see both developments from the same viewpoint. However, given the distance of view and the low alteration to the view, the cumulative effects remain minor adverse and are not significant. 16.5.32 Sequential visual effects would arise for road users on the A256, Sandwich by-pass (ref D1.R3), cyclists on the Sustrans Route 15 (ref D1.F10) and railway travellers on the Ramsgate to Sandwich railway line (ref D1.R6). These receptors would observe the two developments in sequence and with a fairly large distance between them. The low alteration to the view and the relatively large time lapse between appearances would not give rise to a higher level of significance and the cumulative effects remain negligible and are not significant.
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Development D - New 400kV Substation and Converter Station at Richborough as part of the Nemo Link project Background documents reviewed 16.5.33 To inform the cumulative assessment reference has been made to the LVIA, the cumulative assessment chapter and the NTS of the ES271 and the Design and Access Statement for Development D270. Visual effects of the Committed Development 16.5.34 The LVIA identifies public and private visual receptors likely to be affected by the proposed development. The majority of views are considered to be of local (low) importance. The views from Richborough Roman Fort have been recorded as being of moderate importance. No views were recorded as being of high (national) importance. 16.5.35 The assessment describes that some receptors with views towards the proposed development would experience moderate to minor adverse visual effects during construction and on completion (and prior to mitigation), the most significant being for a small number of visual receptors closest to the site and those at elevated viewpoints, with more distant and low lying visual receptors experiencing a neutral effect. Those receptors experiencing moderate adverse (and therefore significant) effects were identified as the Saxon Shore Way at the Former Richborough power station and Sandwich Boat trips on the River Stour. 16.5.36 The LVIA states that measures have been incorporated into the development proposals to mitigate effects on landscape and views during construction and on completion of Development D. ‘Mitigation of the long-term effects on landscape and views would be achieved by using colour graded cladding to the converter station building ranging from a muted green at the building’s base to off-white at the roofline, and muted green cladding to the substation building to minimise landscape and visual effects. Native tree and shrub planting is proposed to the western site boundary adjacent the River Stour, to provide filtering and screening of the converter station and substation buildings and associated outdoor equipment particularly in views looking north, east and southwest towards the site from the Saxon Shore Way and River Stour’. 16.5.37 The residual effects on public views with mitigation planting and after 15 years establishment would be moderate to minor adverse from the section of the Saxon Shore Way and the River Stour adjacent to the converter station and 400kV substation site. It would be difficult to screen all of the buildings entirely due to their height but tree and shrub planting along the riverside would screen some parts of the buildings and the external equipment, resulting in views of the upper part of the converter station building only. Richborough Connection project visual receptors potentially affected by the Development 16.5.38 The combined or sequential visibility of Development D and the Richborough Connection project has the potential to affect the following visual receptors: people on the Saxon Shore Way (ref D1.F3) and on the railway (ref D1.R6); residents living on Castle Road, Richborough (ref D2.13); people at their place of work on the A256 (ref D1.B1); and visitors to the Richborough Roman Fort (ref D2.14).
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Summary of the Visual effects arising from the Richborough Connection project 16.5.39 These public and private visual receptors were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in minor adverse or negligible effects and these are not significant. Potential Cumulative Effects (at operation) 16.5.40 The two developments are in close proximity to one another. The proposed 400kV overhead line and the proposed converter station and 400kV substation would be seen together in easterly views from nearby sections of the Saxon Shore Way (ref D1.F3). The terminal standard lattice pylon and a sequence of low height pylons would be seen crossing the near and middle distance view with the converter station and 400kV substation buildings clearly visible beyond. The two developments would introduce additional but familiar elements into a moderate portion of the near view and the magnitude of effect would be moderate adverse. The cumulative visual effects would give rise to a higher level of significance from a short section of this PRoW and are considered to be moderate adverse, which is significant. These findings are consistent with the findings of the cumulative assessment within the ES for Development D. 16.5.41 Workers in their place of work at industrial and commercial businesses along the A256 (ref D1.B1) are low sensitivity receptors which would experience combined visual effects. The two developments would introduce additional but familiar elements into a moderate portion of the near view and the magnitude of effect would be moderate adverse. The cumulative visual effects would give rise to a higher level of significance and are considered to be minor adverse, which is not significant. 16.5.42 People living on Castle Road (ref D2.13) and visitors to the Richborough Roman Fort (ref D2.14), would experience combined visual effects, however given the distance of view and the low alteration to the view, the cumulative visual effects remain minor adverse and are not significant. 16.5.43 Rail users (ref D1.R6) would have transient and partial views of the 400kV pylons and the converter station and 400kV substation buildings in the near and middle distance. There would be a low alteration to the view which would not give rise to a higher level of significance and the cumulative effects remain negligible and are not significant. Development E - Richborough Energy Park - Peaking Plant, Richborough power station Background documents reviewed 16.5.44 To inform the cumulative assessment reference has been made to the LVIA within the Richborough Peaking Plant Facility and internal Road Network ES273. Visual effects of the Committed Development 16.5.45 The LVIA states that the construction and operation of Development E would give rise to significant adverse effects on four visual receptors. These are the residents of Castle Cottages and Castle Farm Cottages at Richborough, people visiting Richborough Roman Fort, people on the Saxon Shore Way and in Pegwell Bay Country Park. These receptors are also likely to experience significant residual effects (moderate adverse) after 15 years, once mitigation planting has matured.
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This is mainly as a result of these receptors’ proximity to the development and where the chimney stacks would break the skyline, appearing taller and more conspicuous than other features within their landscape context. Mitigation planting is expected to partially screen the peaking plant facility, acoustic fence and the internal road network at ground level within a 15 year period. Richborough Connection project visual receptors potentially affected by the Development 16.5.46 The combined or sequential visibility of the proposed peaking plant and the Richborough Connection project has the potential to affect the following visual receptors: people on the Saxon Shore Way (ref D1.F3), Stour Valley Walk (ref D2.16) and on Sustrans route 15 (ref D1.F10); road users on the Richborough Way (ref D2.8) & A256, Sandwich by-pass (ref D1.R3) and railway users (ref D1.R6); residents living on Castle Road, Richborough (ref D2.13); visitors to the Richborough Roman Fort (ref D2.14); and people at their place of work on the A256 (ref D1.B1) and at Ebbsfleet Farm (ref D1.B4). Summary of the Visual effects arising from the Richborough Connection project 16.5.47 These public and private visual receptors were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in minor adverse or negligible effects and these are not significant. Potential Cumulative Effects (at operation) 16.5.48 The two developments are in close proximity to one another. The proposed 400kV overhead line and Development E would be seen together in easterly views from sections of the Saxon Shore Way (ref D1.F3). The terminal standard lattice pylon and a sequence of low height pylons would be seen crossing the near and middle distance view with the peaking plant facility visible on the north side of the River Stour. The two developments would introduce additional but familiar elements into a moderate portion of the near view and the magnitude of effect would be moderate adverse. The cumulative visual effects would give rise to a higher level of significance from a short section of this PRoW and are considered to be moderate adverse, which is significant. 16.5.49 From the Stour Valley Walk (ref D2.16) and the Sustrans route 15 (ref D1.F10) people would see glimpses of the 400kV pylons and Development E in the distant view. The developments would both be seen in the context of the industrial setting of Ebbsfleet, Richborough and Great Stonar and would not be unexpected or visually prominent. The combined visual effect from these receptors would be negligible and not significant. 16.5.50 Workers in their place of work at industrial and commercial businesses along the A256 (ref D1.B1) and at Ebbsfleet Farm (ref D1.B4) would experience combined visual effects, however given that the proposed developments would not be
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discordant with the baseline environment, and the small proportion of the view affected, the cumulative visual effects remain negligible and are not significant. 16.5.51 Road users on the Richborough Way (ref D2.8) & A256, Sandwich by-pass (ref D1.R3) and rail users (ref D1.R6) would have transient and partial views of the 400kV pylons and Development E in the near and middle distance. There would be a low alteration to the view which would not give rise to a higher level of significance and the cumulative effects remain negligible and are not significant. 16.5.52 People living on Castle Road (ref D2.13) and visitors to the Richborough Roman Fort (ref D2.14), would experience combined visual effects, however given the distance of view and the low alteration to the view, the cumulative visual effects remain minor adverse and are not significant.
Pre-application stage projects Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak and Sturry Link Road Background documents reviewed 16.5.53 The key source of information was the developer website279 and the CCC draft local plan. There are no specific documents relating to landscape or views. Potential visual effects of the strategic allocation 16.5.54 Those aspects of Development F which would give rise to potential effects on views include: the construction of business, community infrastructure and up to 1,000 houses; a new relief road including a road bridge over the railway; associated site preparation, enabling works, infrastructure and landscaping work; and the removal of existing trees or hedgerows to create access points and to accommodate the development. 16.5.55 The development would give rise to changes in views, introducing built form and infrastructure into the open land to the north of the railway line, to the west of Sturry and to the south of Broad Oak. 16.5.56 An area of proposed tree planting is shown along the southern edge of the masterplan area, suggesting that near views of the development from the south would be screened or filtered from view. The woodlands on rising land to the north of the masterplan area (Dene Grove Wood) are shown as remaining intact and it is anticipated that this would provide a consistent backdrop in longer views from the south, such as from the Sturry Road and from Fordwich. A wooded horizon line would remain. Richborough Connection project visual receptors potentially affected by the Development 16.5.57 The combined or sequential visibility of the strategic development site and the Richborough Connection project has the potential to affect the following visual receptors:
279 http://sturrybroadoak.info/about.html
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people on local PRoW (ref A1.F5, A1.F6, A1.F16) and the Stour Valley Walk (ref A2.2), on Sustrans route 1 (ref A1.CY1) and on the North Downs Way (ref A3.2); people on local roads (ref A1.R3, A1.R4, A1.R7) and the railway (ref A1.R11); workers in their place of work (ref A1.B4, A1.B6, A1.B7, A1.B8, A1.B12) and the Junior Kings School (ref A1.C3); and residents on the edge of Sturry (ref A1.H16, A1.H17, A1.H18, A1.H19), on the Sturry Road (ref A1.H15), on Shalloak Road (ref A1.H14, A1.H22) and on the south side of Broad Oak (ref A1.H26, A1.H29, A1.H30 A1.H32). Summary of the Visual effects arising from the Richborough Connection project 16.5.58 There are a small number of visual receptors with near views of the proposed 400kV overhead line which are assessed as experiencing a moderate adverse magnitude of effect with a moderate proportion of the view affected for the long term. These are the PRoW alongside the railway (ref A1.F5), the southern end of Shalloak Road (ref A1.R4) and residential properties with open views of the north Stour Valley slopes (ref A1.H14, A1.H15 and A1.H22). This would result in moderate adverse effects which are considered significant. 16.5.59 The PRoW south of Broad Oak (ref A1.F16) would experience long term moderate beneficial effects which are significant, due to the removal of the PX route from the near view and the proposed 400kV overhead line would not be visible. 16.5.60 All other visual receptors identified above were assessed as experiencing a low adverse, negligible or low beneficial magnitude of effect in views arising from the RCP, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in effects of minor adverse, negligible or minor beneficial significance and these are not significant. Potential Cumulative Effects (at operation) 16.5.61 The proposed 400kV overhead line and Development F are in close proximity to one another, with the overhead line passing to the immediate south west and crossing an area identified as future open space on the masterplan for Development F. The developments would be seen together in views to the north and west from nearby roads, PRoW, properties and places of work. The view would change from that of large open fields with some hedgerows, woodland blocks and overhead transmission lines to that of suburban development with a prominent landscape setting and a woodland backdrop. 16.5.62 The closest receptors (ref A1.F5, A1.R4, A1.H14, A1.H15 and A1.H22) would experience combined visual effects but these would be minimised by the presence of open space and tree planting between the receptors and the proposed residential development area, as shown on the illustrative masterplan. This would filter and potentially screen some views of the new housing. Although this would not give rise to a higher level of significance, the cumulative effects are moderate adverse and are significant. 16.5.63 Residential receptors and a PRoW on the south side of Broad Oak (ref A1.H26, A1.H29, A1.H30, A1.H32 and A1.F16) would experience a moderate or major magnitude of effect arising from the introduction of new development in close proximity, with a large proportion of the view altered, where agricultural land and open fields would be replaced by housing. The proposed 400kV overhead line would
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be barely perceptible in the view, and the PX route would have been removed from the view. However the cumulative effects would be more substantial than those arising from the Richborough Connection project alone and would give rise to a higher level of significance; they are considered to be moderate adverse and are significant. 16.5.64 Other road users, rail travellers, a school and workers in their place are low sensitivity receptors which would experience combined visual effects. The two developments would introduce additional and some familiar elements into a moderate portion of the near and middle distance view and the magnitude of effect would be moderate adverse. The cumulative visual effects would not give rise to a higher level of significance and are considered to be minor adverse, which is not significant. Development G - Strategic Development Site SP3 site 8: Land North of Hersden Background documents reviewed 16.5.65 Background information is available on the Hume Planning website275 although no specific documents have been published with regards to landscape or visual matters. Reference has been made to the draft Masterplan prepared by Barton Wilmore dated June 2015, which shows Development G set within a landscape framework, with open space and recreation provision on the north and eastern boundaries of the site. Potential visual effects of the strategic allocation 16.5.66 Those aspects of Development G that would result in potential visual effects include: the construction of homes, business units and community facilities; associated site preparation, enabling works, infrastructure and landscaping work; and the removal of existing trees or hedgerows to create access points and to accommodate the development. Richborough Connection project visual receptors potentially affected by the Development 16.5.67 The combined or sequential visibility of the strategic development site and the Richborough Connection project has the potential to affect the following visual receptors: residential properties on the northern edge of Hersden (ref B1.H4 and B1.H5), on Bredlands Lane (ref B1.H1, B1.H2, B1.H3a, B1.H3b, A1.H62), on the A28 (ref B1.H6), at Tile Lodge (ref B1.H9, B1.H10, B1.H11) and Hoath (ref B1.H12, B1.H13, B1.H14 and A1.H63) and at Chislet Business Park (ref B1.H7 and B1.H8); users of the recreational and community facilities in Hersden (ref B1.S1, B1.C1, B1.C2 and B1.C3); workers in their place of work at Chislet Business Park (ref B1.B4 and B1.B5); and users of PRoW (ref B1.F1 and B1.F2) and local roads (B1.R1, B1.R2, B1.R3 and B1.R5.
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Summary of the Visual effects arising from the Richborough Connection project 16.5.68 There are visual receptors with near views of the proposed 400kV overhead line which are assessed as experiencing a moderate adverse magnitude of effect with a moderate proportion of the view affected for the long term. These are at Tile Lodge (ref B1.H9, B1.H10 and B1.H11), at Chislet Business Park (ref B1.H7 and B1.H8) the PRoW crossing the Sarre Penn Valley (ref B1.F1). This would result in moderate adverse effects which are considered significant. 16.5.69 All other visual receptors identified above were assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the Richborough Connection project, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in minor adverse or negligible effects which are considered not significant. Potential Cumulative Effects (at operation) 16.5.70 The proposed 400kV overhead line is routed along the Sarre Penn Valley to the north of Development G. At the north western corner of the site the overhead line would lie approximately 130m from it with this distance increasing to 550m at the north east corner. Two woodlands lie between the two developments, Park Rough and the smaller Ash Plantation. Development G extends roughly as far north as the existing PX route. 16.5.71 The developments would be seen together in views from the north; from properties on the edge of Hoath (ref B1.H12, B1.H13, B1.H14), from properties at Chislet Business Park (ref B1.H7 and B1.H8), from Marley Lane (ref B1.R4), and from PRoW crossing the valley (ref B1.F1 and B1.F2). The proposed 400kV overhead line would be seen crossing the view with the strategic development land visible beyond, on the southern valley slopes. The view would change from that of open fields with hedgerows, woodland blocks and overhead transmission lines to that of suburban development with a prominent landscape framework. The foreground woodland would remain and would continue to screen and filter some views. The new housing would be in context with the existing Lakesview International Business Park and traffic moving on the A28 which already serve to urbanise the view to some extent. The proposed 400kV overhead line and the strategic development site would alter a moderate proportion of near and middle distance views and a low proportion of distant views. The magnitude of effect would range from minor to moderate and adverse. However the cumulative effects would be more substantial than those arising from the Richborough Connection project alone and would give rise to a higher level of significance. The effects on the receptors identified here are considered to be moderate adverse and are significant. 16.5.72 From properties at Tile Lodge (ref B1.H9, B1.H10, B1.H11) and on Bredlands Lane (ref B1.H1, B1.H2, B1.H3a, B1.H3b, A1.H62) which are located to the west of the strategic development site there would be combined visual effects arising from the introduction of additional development into the middle distance view. The effects would be minimised to some extent by the presence of open space and tree planting between the receptors and the proposed residential development area for Development G, as shown on the draft illustrative masterplan. This would filter and potentially screen some views of the new housing. Although this would not give rise to a higher level of significance, the cumulative effects are moderate adverse and are significant.
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16.5.73 Other road users, workers in their place and people at the school and community centre are low and medium sensitivity receptors which would experience combined visual effects. The two developments would introduce additional and some familiar elements into a low portion of the near and middle distance view and the magnitude of effect would be minor adverse. The cumulative visual effects would not give rise to a higher level of significance and are considered to be minor adverse, which is not significant. 16.5.74 Residents and workers at Chislet Business Park (ref B1.H7, B1.H8, B1.B4 and B1.B5) would experience combined visual effects where the observer has to turn their head to see both developments from the same viewpoint. The proposed 400kV overhead line would be seen in near views to the north and north west and Development G in middle distance views to the south and south west. The PX route would be removed from the near view to the south and south west and the draft masterplan shows a large area of recreational open space with trees and retained hedgerows at the north east corner of the site in proximity to these receptors. These factors would help to mitigate visual effects and are not considered to give rise to a higher level of significance; the cumulative effects would remain moderate adverse and are significant. 16.5.75 From properties on the northern edge of Hersden (ref B1.H4 and B1.H5), and from the recreation ground (ref B1.S1) and community facilities (ref B1.C2 and B1.C3) there would be no combined visual effects. This is because the introduction of development into the near view would curtail views screening the proposed 400kV overhead line from view as it crosses along the valley to the north. Development H - Communications Mast, Ramsgate Road Background documents reviewed 16.5.76 A Request for a Screening Opinion276 includes that Development H has a very limited number of issues from which impacts could arise, citing visual impact, ecology and flood risk as the main points of consideration. Potential visual effects of the proposed development 16.5.77 Those aspects of Development H that would result in potential visual effects include: the construction of a 320m high guyed steel lattice structure with anchor points and navigational warning lights; and a site compound, secure perimeter fence, single storey equipment structure and associated development. 16.5.78 The Request for a Screening Opinion identifies that the visual impacts arising from Development H are likely to be limited to effects upon local views and the setting of heritage assets. 16.5.79 In relation to cumulative effects, the Request for a Screening Opinion states that ‘a Visual Impact Assessment is to be submitted as part of the planning application. Whilst there are some major infrastructure projects happening in and around the site, it is not considered that cumulatively they will have a negative impact on the surrounding area’. 16.5.80 In relation to the spatial scope of potential effects the Request for a Screening Opinion suggests that “the geographical area that would fall within the Theoretical Zone of Visual Influence (TZVI) could extend as far as 5 miles. Whilst this is a
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considerable area, the local population is predominantly confined to a limited number of settlements. Given the design of the proposals and the lightweight construction, the visual impact is likely to be limited, unlike a solid structure. A detailed TZVI based on GIS topographical data and computer modelling of the scheme would be used to inform the Heritage, Landscape and Visual Impact Assessment and to confirm the area to be assessed. A number of key views would be assessed, including those from Ramsgate / Pegwell Bay, Richborough Fort and Sandwich. An assessment on the setting of designated heritage assets would also be undertaken, and discussed alongside the views in the submitted technical document. The assessment would be undertaken in accordance with GLVIA3.” 16.5.81 Having assessed the scheme against Schedule 3(1) of the EIA Regulations, the Request for a Screening Opinion does not consider that the proposals for Development H are of more than local importance (i.e. would not have a regional impact) and would not give rise to significant environmental effects. Richborough Connection Project visual receptors potentially affected by the Development 16.5.82 Given the height of the mast there is the potential for all visual receptors within the 5 mile radius TZVI to be affected by the combined or sequential visibility of Development H and the Richborough Connection project to some degree. This would include all Richborough Connection project visual receptors in Section D and those in the eastern part of Section C, including Sarre, St Nicholas at Wade and West Stourmouth. Potential Cumulative Effects (at operation) 16.5.83 Given the lattice steelwork construction of Development H it would be visually permeable and benefit from backgrounding in a similar way to lattice pylons. 16.5.84 The greatest visual effects would be experienced by those receptors in closest proximity with visibility decreasing over distance. 16.5.85 The proposed 400kV overhead line and Development H would be seen in the same view by a number of public and private visual receptors. Development H is in close proximity to the pylons at the eastern end of the route. The two developments would introduce additional but familiar elements into the view and the magnitude of effect would range from moderate through to negligible depending on the distance of the view. For the closest receptors, such as walkers on the Saxon Shore Way (ref D1.F3), the magnitude of effect would be moderate adverse. The cumulative visual effects would give rise to a higher level of significance and are considered to be moderate adverse, which is significant. The number of receptors to which this assessment applies is relatively low. 16.5.86 People living on Castle Road (ref D2.13) and visitors to the Richborough Roman Fort (ref D2.14), would experience combined visual effects, however given the distance of view and the low alteration to the view, the cumulative visual effects remain minor adverse and are not significant. 16.5.87 For the majority of public and private receptors in Section D with middle and longer distance views the proportion of the view altered by the additional structures is low and the magnitude of effect would be minor. The developments would not be discordant with the baseline view, being seen in the industrial context of Ebbsfleet, Richborough and Great Stonar and would not be unexpected. The combined visual effect would be minor adverse and not significant.
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16.5.88 Public and private visual receptors in Section C would see glimpses of the 400kV pylons and the upper section of the communications mast in the distant view. The combined visual effect from these receptors would be negligible and not significant.
National Grid Permitted Development Development I - Canterbury North 400kV Substation, Canterbury Background documents reviewed 16.5.89 Reference has been made to the Site Layout plans280 and the Planning Statement for the Proposed Mitigation Ponds278 for Development I. Potential visual effects of the permitted development 16.5.90 Those aspects of Development I that would result in potential visual effects include the demolition of existing buildings (garage, office, 3 workshops and environmental services centre), alterations to a flood defence wall, new fencing, replacement plant and machinery building within the compound and a new internal access road. These works would be undertaken entirely within the current site boundary. Richborough Connection project visual receptors potentially affected by the Development 16.5.91 The combined or sequential visibility of Development I and the Richborough Connection project has the potential to affect the following visual receptors: people on local PRoW (ref A1.F2 and A1.F3); local road users (ref A1.R11); workers in their place of work along the Broad Oak Road (ref A1.B1 and A1.B2); residents in Hales Place (ref A1.H1 and A1.H3), on Broad Oak Road (ref A1.H13) and north of the A28 (ref A1.H12); and community receptors (Sea Cadets HQ and recycling centre) on Vauxhall Road (ref A1.C1). Summary of the Visual effects arising from the Richborough Connection project 16.5.92 There is one group of visual receptors which is assessed as experiencing significant adverse visual effects. These are the community receptors (of medium sensitivity) on Vauxhall Road (ref A1.C1) which would experience a partial alteration to the existing view with a moderate proportion of the view affected in the long term. Views north would include lightly filtered views of PC1 and the terminal gantry, and two other pylons in close proximity. The PX route pylons and conductors would be removed from the middle distance view north-west towards the landfill site. The significance of effect would be moderate adverse which is considered significant. 16.5.93 Some visual receptors would experience beneficial effects arising from the RCP due to the removal of the PX route from the near and middle distance view and the introduction of the 400kV overhead line is the very distant view or not visible at all. These are receptors at Hales Place (ref A1.H1 and A1.H3) and PRoW (ref A1.F2 and
280 Canterbury 400kV Substation, Shunt Reactor drawings MMD-336658-E-SK-CA-XX-2004, 2005 and 2006. Prepared by Mott McDonald
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A1.F3). The significance of effect would be moderate beneficial which is considered significant. 16.5.94 All other visual receptors identified above have been assessed as experiencing a low adverse or negligible magnitude of effect in views arising from the RCP, with a low alteration to the existing view or a barely perceptible change within a long distance view. This would result in effects of minor adverse or negligible significance which are considered not significant. Potential Cumulative Effects (at operation) 16.5.95 The proposed 400kV overhead line and Development I are in close proximity to one another, with the overhead line dropping down and connecting into the gantry at the eastern end of the 400kV substation site. The developments would be seen together in views from the north and north east from the adjacent road (ref A1.R11), from properties (ref A1.H13) and places of work (ref A1.B1 and A1.B2). The magnitude of effect would be minor due to the low proportion of the near view altered by the works. The cumulative visual effects would not give rise to a higher level of significance and are considered to be minor adverse, which is not significant. 16.5.96 All other visual receptors identified as potentially experiencing combined visual effects would experience a low or negligible magnitude of effect arising from the introduction of additional and some familiar elements into a low portion of the middle distance view. The cumulative visual effects would not give rise to a higher level of significance and are considered to be minor adverse or negligible, which is not significant.
Combined cumulative effects 16.5.97 There are potential combined cumulative visual effects arising from the Richborough Connection project and all committed developments in Section D where there are six committed developments in close proximity to one another and to the Richborough Connection project, and which have the potential to affect the same visual receptor. These projects are Discovery Park Biomass Plant (Development A); Thanet Solar Farm (Development B); Discovery Park Masterplan (Development C); Nemo Link associated development (Development D); Richborough Energy Park Peaking Plant (Development E); and Richborough Communications Mast (Development H). 16.5.98 The only visual receptor identified as being likely to experience combined cumulative visual effects is the Saxon Shore Way which is routed alongside the River Stour and passes in close proximity to the cluster of developments at Richborough. From a section of the PRoW, the proposed 400kV overhead line and the proposed buildings and structures associated with the developments would be seen together in views from sections of the Saxon Shore Way (ref D1.F3). The developments would introduce a number of additional but familiar elements into near and middle distance views on both sides of the River Stour. Where the path is in close proximity, the buildings and structures would occupy a large portion of the view and the magnitude of effect would be major adverse. Where the path is further away a low proportion of the view would be altered and the magnitude of effect would be minor adverse. For a time, and whilst the walker is on the section of PRoW closest to the developments, the combined cumulative visual effects would give rise to a higher level of significance and are considered to be major adverse. From other, more distant sections of PRoW the combined cumulative visual effects would remain as moderate adverse. These are significant effects.
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16.5.99 No other visual receptors are likely to experience significant combined cumulative visual effects. 16.5.100 With reference to paragraph 7.28 of GLVIA3, the Richborough Connection project would constitute a ‘tipping point’ which would give rise to greater significance of adverse effects cumulatively with other projects on only a small number of visual receptors. These receptors are: the Saxon Shore Way (ref D1.F3), arising from the combined cumulative visual effects of the Richborough Connection project and the other committed developments in Richborough; residential receptors and a PRoW on the south side of Broad Oak (ref A1.H26, A1.H29, A1.H30, A1.H32 and A1.F16) arising from the cumulative visual effects of the Richborough Connection project and Development F; and residential receptors on the edge of Hoath (ref B1.H12, B1.H13, B1.H14), residential receptors at Chislet Business Park (ref B1.H7 and B1.H8), from Marley Lane (ref B1.R4), and from PRoW crossing the Sarre Penn valley (ref B1.F1 and B1.F2), arising from the cumulative visual effects of the Richborough Connection project and Development G. 16.5.101 With the exception of the above, it is considered that the Richborough Connection project would not constitute a ‘tipping point’ which would give rise to a greater significance of cumulative adverse visual effects when considered with other projects.
16.6 Assessment of Cumulative Effects: Historic environment 16.6.1 The cumulative assessment considers the potential cumulative effects which may result from the combined effects of the Richborough Connection Project and other major development proposals scoped-in, as identified in Table 16.2 of this Chapter. 16.6.2 Cumulative effects on heritage assets are considered by individual receptor, following the identification of specific developments which have the potential to give rise to adverse cumulative effects in Chapter 8 of this document. This structure allows the potential for different scenarios and different combinations of proposed and consented developments to be considered and better reflects Historic England guidance on assessing change to setting81. 16.6.3 Receptors which have been identified as experiencing effects from the Richborough Connection project and one or more of the developments identified in Table 16.2 are discussed below.
Richborough Port 16.6.4 Developments which could give rise to an adverse cumulative direct effect on this receptor include the following: Committed development: Development B (Thanet Solar Farm); and Pre-application stage development: Development H (Richborough Communications Mast).
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Reference to Key Documents 16.6.5 This assessment of the potential cumulative effects of the proposed developments is based on information provided in the Heritage Assessment Report for Development B281. No detailed proposals for Development H Mast are available, and reference has been made to public exhibition materials produced by Vigilant Global282. Assessment of potential effects – during Construction Richborough Connection project 16.6.6 Section 8.9 of this document notes that the proposed development would give rise to very limited disturbance of peripheral areas of Richborough Port which were formerly in use as sidings. These effects would be effectively mitigated by an agreed programme of archaeological investigation. Development B 16.6.7 The Heritage Assessment Report noted that the Thanet Solar Farm could give rise to disturbance of elements of Richborough Port, although it was noted that any disturbance would be located away from the known or recorded locations of former structures. Development H 16.6.8 The proposed Richborough Communications Mast would be located within the site to be occupied by the consented Thanet Solar Farm, and is expected to give rise to very localised disturbance of archaeological deposits within this area, which appears to be within areas of former sidings and open ground within the former port area. Assessment of potential effects – during Operation 16.6.9 Any adverse direct effects would occur during construction and no adverse cumulative effects are anticipated during the operation of the Richborough Connection project. Cumulative effects 16.6.10 Archaeological remains at Richborough Port could be subject to an adverse cumulative effect arising from the combination of the disturbance caused by the construction of the proposed PC route taken in combination with Development B and Development H. These other developments are, similar to the proposed overhead line, outside the principal areas of archaeological interest. Consequently, the most significant elements of the port would not be affected. Cumulative disturbance caused by the construction of the proposed 400kV route would present a low magnitude of cumulative change and any effect would be not significant. 16.6.11 Other developments within the former port area, including Development D (Nemo Link Converter Station and National Grid 400kV Substation), Development E (Energy Park/Peaking Plant), Development A (Discovery Park Biomass Plant) and elements of Development C (Discovery Park Masterplan) are located in areas which have previously been substantially disturbed by construction, alteration and demolition of the former Richborough power station and Pfizer/Discovery Park developments,
281 URS 2013 Heritage Assessment Report for Thanet Solar Farm 282 http://www.richboroughmast.co.uk/RICHBOROUGH_MAST_Panels_WEB.pdf
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meaning that near surface and upstanding remains do not survive in any meaningful way.
Sturry conservation area and associated listed buildings 16.6.12 Proposed developments which could give rise to an adverse cumulative direct effect on this receptor are limited to the Pre-application stage Development F (Sturry and Broad Oak strategic development, incorporating Sturry link road). Reference to key documents 16.6.13 This assessment of potential cumulative effects of is based on information provided in the CCC draft Local Plan, and on indicative development proposals for Development F274. Assessment of potential effects – during Construction 16.6.14 As noted at Section 8.10 of this document, any change to the character or setting of the Sturry conservation area would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.15 Section 8.10 of this document noted that no change was anticipated in the setting of the listed buildings within the Sturry conservation area as a result of the construction and operation of the proposed 400kV overhead line, but that the conservation area would be subject to a low magnitude of adverse change resulting from the construction of a single pylon within a peripheral area of the conservation area. Development F 16.6.16 Without detailed proposals, it is difficult to assess the magnitude of potential change, but the available plans show that it is likely that negative change caused by construction of new residential development on agricultural land in the setting of the Sturry conservation area would be mitigated by the use of tree planting and could be balanced to a degree by traffic and public realm enhancements within the core of the conservation area permitted by the construction of the Sturry Link Road. 16.6.17 The route of the link road shown by the CCC draft Local Plan and the Development F proposals shows that this road would cut across the water meadows between the core of the conservation area and the location of proposed pylon PC3. This would present a degree of harm to the conservation area, which could be mitigated by planting proposed in the Sturry Broad Oak proposals and balanced by the reduction in traffic through the core of the conservation area. Cumulative effects 16.6.18 Proposed Pylon PC3 would be located in a small area of water meadow that would be materially and perceptually entirely separated from the remainder of the conservation area by the proposed link road and associated bridges. This would have the effect of providing a strong perceptual edge to the conservation area, severing the water meadows in which PC3 would be present from the rest of the conservation area. By being located beyond the propsoed link road when seen on the approach from the core of the conservation area, this change would have the
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effect of reducing any perceptual change in the character of the conservation area caused by the presence of the proposed Richborough Connection project. 16.6.19 Views of the proposed Richborough Connection project outside the conservation area from the footpath along the northern edge of the conservation area would be restricted, if not entirely precluded by residential development and tree planting, and the proposed 400kV route would only be visible from the western part of the conservation area, where it would be seen with the proposed link road. 16.6.20 While the overall magnitude of change within the conservation area and its setting would increase with the Richborough Connection project and Development F seen together, the change to the character of the conservation area caused by the proposed link road element and the increased screening presented by the remainder of the Development F proposals would limit the extent to which the Richborough Connection project would contribute to any cumulative change to a negligible magnitude. Any effect would be not significant. 16.6.21 In that there would be no change in the settings of listed buildings within the Sturry conservation area arising from the construction of the proposed Richborough Connection project, the proposed development would not contribute to any cumulative change to these designated heritage assets.
Sarre conservation area and associated listed buildings 16.6.22 Proposed development which could give rise to an adverse cumulative indirect effect on this receptor is limited to Development H (Richborough Communications Mast). Reference to key documents 16.6.23 No detailed documents are available, but reference has been made to public exhibition materials published by Vigilant Global282. Assessment of potential effects – during Construction 16.6.24 As noted at Section 8.10 of this document, any change to the character or setting of the Sarre conservation area would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.25 Section 8.10 of this document notes that the Richborough Connection project would not be readily discernible in views from Sarre conservation area nor would it appear in views of the conservation area and that consequently, any change to significance would be of negligible magnitude. Other than Sarre Court, where any loss of significance arising from change to setting was assessed as of negligible magnitude, the settings of listed buildings within the conservation area would not be affected. 16.6.26 Immediately outside the conservation area, change to significance arising from change in the setting of Tollgate Cottage was assessed as negligible, and change to significance arising from change in the setting of Sarre Mill was assessed as of low magnitude, falling to negligible on the removal of the existing UK Power Networks 132kV PX route.
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Development H 16.6.27 Development H would be visible only as a very distant element of the background to views from the fringes of the conservation area. Visibility of this proposed development from the core of the conservation area would be precluded by planting and intervening buildings from within the conservation area. 16.6.28 Development H would not be visible in views from Sarre Mill at ground level, nor in simultaneous views of Sarre Mill from the A28 Canterbury Road in which the Richborough Connection project would appear as a distant background feature, but would appear in successive views as the viewer looked eastwards, away from the mill. 16.6.29 Development H would be visible from Tollgate Cottage, although as a very distant feature partially obscured by garden and hedgerow planting to the south of the house. Cumulative effects 16.6.30 The restricted visibility of Development H from Sarre is such that the magnitude of any change to significance arising from cumulative change in the setting of the conservation area or listed buildings within it from the addition of the Richborough Connection project to a baseline including Development H would be of negligible magnitude and any effect would be not significant. 16.6.31 The visible separation of Development H from the proposed Richborough Connection project in views of Sarre Mill from the north and north-east means that any change to significance arising from cumulative change in the setting of Sarre Mill would be of negligible magnitude and any effect would be not significant. 16.6.32 The restricted visibility of Development H from Tollgate Cottage, taken with its separation from the asset, is such that the magnitude of any change to significance arising from cumulative change in the setting of the conservation area or listed buildings within it from the addition of the Richborough Connection project to a baseline including Development H would be of negligible magnitude and any effect would be not significant.
Anglo-Saxon cemetery at Sarre 16.6.33 Proposed development which could give rise to an adverse cumulative indirect effect on this receptor is limited to Development H. Reference to key documents 16.6.34 No detailed documents are available, but reference has been made to public exhibition materials published by Vigilant Global282. Assessment of potential effects – during Construction 16.6.35 As noted at Section 8.10 within this document, any change to the setting of the Anglo- Saxon cemetery at Sarre would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects.
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Assessment of potential effects – during Operation Richborough Connection project 16.6.36 Section 8.10 of this document noted that the Richborough Connection project would give rise to a low magnitude of adverse change to significance which would fall to negligible on the removal of the existing UK Power Networks 132kV PX route overhead line. Development H 16.6.37 Development H would be visible with the Richborough Connection project in simultaneous views from the southern edge and eastern part of the cemetery, although as a very distant feature. Cumulative effects 16.6.38 While Development H would be visible from the cemetery, it would appear as a distant feature, perceptually separated from the cemetery by the low-lying land of the former Wantsum Channel. Consequently cumulative change arising from the addition of the Richborough Connection project to a baseline including Development H would give rise to a change to significance of negligible magnitude and no significant effect would arise.
Minster conservation area 16.6.39 Proposed development which could give rise to an adverse cumulative indirect effect on this receptor is limited to Development H. Reference to key documents 16.6.40 No detailed documents are available, but reference has been made to public exhibition materials published by Vigilant Global283. Assessment of potential effects – during Construction 16.6.41 As noted at Section 8.10 of this document, any change to the character or setting of the Minster conservation area would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.42 Section 8.10 of this document identified the potential change to significance arising from change in the setting of the church of St Mary’s, Minster as a result of the construction and operation of the Richborough Connection project as of negligible magnitude. Visibility of the proposed development in views of or from the conservation area would be precluded and no adverse effects are anticipated. Development H 16.6.43 Views of Development H from the conservation area would be screened by intervening structures and simultaneous visibility of the tower of St Mary’s Church, the proposed Richborough Connection project and Development H would be restricted to more distant views of the conservation area from the higher ground to
283 Ibid
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the north and east, in which the proposed communications mast would appear as a distant feature in the background of views. In these views, the spire of St Mary’s has a reduced prominence and the proposed Richborough Connection project would be visible only as a distant background feature and would be largely backgrounded as a result of the change in level. Cumulative effects 16.6.44 The magnitude of cumulative change arising from the addition of the Richborough Connection project to a cumulative baseline of Development H would be negligible and the effect would be not significant.
Richborough Castle 16.6.45 Developments which could give rise to an adverse cumulative direct effect on this receptor comprise the following: Committed development: Development A (Discovery Park Biomass Plant); Development B (Thanet Solar Farm); Development C (Discovery Park Masterplan); Development D (New 400kV substation and converter station for Nemo Link); Development E (Richborough Energy Park); and Pre-application stage development: Development H (Richborough Communications Mast). Reference to key documents 16.6.46 No detailed documents for tDevelopment H are available, but reference has been made to public exhibition materials published by Vigilant Global282. The Historic Environment sections of the Development E ES273, the Development D ES271, the landscape statement for Development A264271 (no heritage statement is available on the DDC planning website), the Heritage Assessment Report and Landscape and Visual Impact Statement for Development B266 and the Cultural Heritage section of the ES for Development C269. Assessment of potential effects – during Construction 16.6.47 As noted at Section 8.10 of this document, any change to the setting of Richborough Castle would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.48 Section 8.10 of this document assessed the potential change to significance arising from change in the setting of Richborough Castle a result of the construction and operation of the proposed 400kV overhead line as as of negligible magnitude. Development A 16.6.49 The Landscape Assessment for the Discovery Biomass Plant noted that there would be some adverse change in the setting arising from the visibility of the additional buildings and chimneys. This adverse change was, however, considered in the context of the plant’s location beyond the existing industrial and office buildings at Discovery Park and the former presence of the much larger chimneys and buildings
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at Richborough power station. It was concluded that no harm would arise to the significance of the asset. Development B 16.6.50 The Heritage Assessment Report for the Thanet Solar Farm did not offer any assessment of change to setting, merely noting that such assessment would be necessary to understand the potential change in the setting of Richborough Castle. The Landscape and Visual Impact Statement noted in respect of visual effect experienced by visitors to the fort that the proposed development ‘is easily absorbed by the open view and is barely distinguishable’. Development C 16.6.51 The cultural heritage assessment contained within the ES for the Discovery Park Masterplan noted that the proposed developments would give rise to a ‘small’ effect arising from incremental change to the existing area of industrial and commercial activity. Development D 16.6.52 The ES for Development D noted the potential visibility of this development in views of and from Richborough Castle, but argued that the presence of the proposed development in an area of existing and former electricity generating and transmission use meant that there would be no change in the significance of Richborough Castle. Development E 16.6.53 Visibility of Development E in views of and from Richborough Castle would largely be restricted to views of the chimneys of the Peaking Plant, with other elements of this development being screened from view by intervening planting. This visibility led to an assessment of this effect as ‘minor adverse’ in the Environmental Statement. Development H 16.6.54 No formal assessment has been undertaken of the proposed Richborough Communications Mast, but public exhibition photomontages suggest that it will be prominently visible in views north from Richborough Castle, and in views of Richborough Castle from the north and south. It would, however, remain within the area of existing industrial development at the former Richborough power station, although it would be substantially taller than the present communications masts which are visible in these views. Cumulative effects 16.6.55 Developments A and C would result in incremental change to the configuration of the generally industrialised area to the east and north of Richborough Castle. Any visibility of these developments would be in the context of the existing industrial and commercial buildings and would not give rise to any discernible change in the relationship of Richborough Castle to its setting or to the character of that setting. Views to these developments from Richborough Castle would also be filtered by the planting to the east side of the scheduled monument. Consequently, taken individually or together with the proposed Richborough Connection project, any additional change would be insufficient to give rise to any significant adverse cumulative effects. 16.6.56 Developments D and E would be more clearly visible from Richborough Castle, but would remain confined within the area of clearly visible industrial activity, and would
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remain perceptually separated from the asset by the agricultural land to the north of Richborough Castle. While occupying the former site of Richborough power station, these developments would present new structures in the view where these had not previously been present. Taken together or with the proposed Developments B and H these developments could present a perceptual reinforcement of the industrial nature of the area to the north of the asset arising primarily from changes to the former Richborough power station site as a result of the construction of Developments D, E and H resulting in an elevated magnitude of change in the area to the north of Richborough Castle. There would be no change in the more rural landscape to the west of the asset, and these developments would not result in any sense of further encroachment towards the asset or any sense of encirclement. 16.6.57 The proposed Richborough Connection project would be visible in simultaneous views with Developments B, D, E, and H, further reinforcing the increasingly visible industrial development to the north of Richborough Castle. In these views, the limited visibility of the proposed Richborough Connection project means its contribution towards a cumulative adverse effect would be restricted. In addition the separation of these developments from Richborough Castle and the incremental nature of the change in its setting means that these effects would of negligible magnitude and be not significant.
Historic landscape character – Section A 16.6.58 Proposed developments which could give rise to an adverse cumulative effect on historic landscape character in Section A are limited to Development F (Sturry and Broad Oak strategic development, incorporating Sturry link road). Reference to key documents 16.6.59 This assessment of the potential cumulative effects of the proposed developments is based on information provided in the CCC draft Local Plan, and on indicative development proposals for Sturry Broad Oak274. Assessment of potential effects – during Construction 16.6.60 As noted at Section 8.11 of this document, any lasting change to historic landscape character would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.61 Section 8.11 of this document noted that a low magnitude of change to historic landscape character in Section A was anticipated as a result of the construction and operation of the proposed 400kV overhead line, primarily as a result of changes to ancient woodland at Kemberland Wood and orchard planting around Broad Oak and Calcot. Development F 16.6.62 Without detailed proposals, it is difficult to assess the magnitude of potential change, but the available plans suggest that the development of agricultural land for residential use would give rise to a degree of adverse change to historic landscape character through the loss of existing features such as field boundaries and paths, and by the change of use.
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16.6.63 The route of the link road shown by the CCC draft Local Plan and the Development F proposals shows that this road would cut across the water meadows to the east of Sturry. Again, this would present a potential adverse change to historic landscape character through the creation of a new route, and by potentially blocking old routes through the landscape. Summary 16.6.64 The change in land use to residential development from what is now woodland and agricultural land on the north side of the Sturry conservation area, and the construction of the link road between Shalloak Road and Sturry Road resulting from Development F, would interact with the proposed overhead line. In this case any loss of historic landscape character would arise primarily from the residential development, in that the Richborough Connection project would follow the existing landscape division presented by the woodland at Lynne Wood, which will not be altered by the proposed residential development. 16.6.65 While the overall magnitude of change to historic landscape character would increase with these developments taken together, the contribution of the proposed Richborough Connection project to any change in historic landscape character would be of negligible magnitude and any effect would be not significant.
Historic landscape character – Section B 16.6.66 Proposed development which could give rise to an adverse cumulative effect on historic landscape character in Section B is limited to Development G (Strategic Development Site SP3 Site 8: Land North of Hersden). Assessment of potential effects – during Construction 16.6.67 As noted at Section 8.11 of this document, any lasting change to historic landscape character would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.68 Section 8.11 of this document noted that a low magnitude of change to historic landscape character in Section B was anticipated to arise from the construction and operation of the proposed 400kV overhead line, primarily as a result of the proposed Richborough Connection project presenting a new linear feature within the historic landscape. Development G 16.6.69 The proposed development north of Hersden would give rise to a degree of adverse change to historic landscape character as a result of the change in use of the agricultural land north of the existing village. However, this change would be localised and the proposed development would be clearly separated from the proposed Richborough Connection project. Cumulative effects 16.6.70 The proposed Richborough Connection project would cut across the agricultural land to the north of the proposed development north of Hersden and would present a discernible cumulative effect. The proposed Richborough Connection project would
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remain clearly separated from Development G and these two developments would be seen in clearly different historic landscape contexts. As a result cumulative effects on historic landscape character in Section B would be of negligible magnitude and not significant.
Historic landscape character – Section C 16.6.71 No developments have been identified which would give rise to any adverse cumulative effects on historic landscape character.
Historic landscape character – Section D 16.6.72 Developments which could give rise to an adverse cumulative direct effect historic landscape character in Section D comprise the following: Committed developments: Development A (Discovery Park Biomass Plant); Development B (Thanet Solar Farm); Development C (Discovery Park Masterplan); Development D (New 400kV substation and converter station for Nemo Link); Development E (Richborough Energy Park); and Pre-application stage development: Development H (Richborough Communications Mast). Reference to Key Documents 16.6.73 Key documents reviewed are discussed in paragraph 16.6.46 of this chapter. Assessment of potential effects – during Construction 16.6.74 As noted at Section 8.11 of this document, any lasting change to historic landscape character in Section D would be experienced as an effect during the operation of the proposed Richborough Connection project and effects have been considered as operational effects. Assessment of potential effects – during Operation Richborough Connection project 16.6.75 Section 8.11 of this document assessed the potential change to significance arising from change to the historic landscape character of of Section D resulting from the construction of the proposed 400kV overhead line as of low magnitude. Development A 16.6.76 Development A would give rise to minimal change to historic landscape character in that it would be located in an area of existing modern industrial and commercial development. Development B 16.6.77 Development B would present limited change to historic landscape character in that its layout would respect the existing field system and that visibility of the proposed development in the relatively flat landscape of the former marshes would be restricted. Development C 16.6.78 Development C would give rise to minimal change to historic landscape character in that it represents reconfiguration of an area of existing modern industrial and commercial development.
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Development D 16.6.79 Visibility of Development D from Section D would be episodic except in closer views, with elements of this development being screened from view by intervening hedgerow planting. Again, no discernible loss of historic landscape features would arise as the proposed development would be located within the site of the former Richborough power station. Development E 16.6.80 Visibility of Development E from Section D would largely be restricted to views of the chimneys of the Peaking Plant, with other elements of this development being screened from view by intervening planting. Again, no discernible loss of historic landscape features, would arise as the proposed development would be located within the site of the former Richborough power station. Development H 16.6.81 No formal assessment has been undertaken of Development H, but public exhibition photomontages suggest that it will be prominently visible across Section D, but would not give rise to any discernible loss of historic landscape features, given its limited development footprint. Cumulative effects 16.6.82 Taken together, the developments above would present a low magnitude of cumulative change to historic landscape character in Section D. The largest developments would occupy land which is already, or has recently been in modern industrial and commercial use and which does not contribute positively to historic landscape character. The developments outside these area, i.e. Development B and Development H, are located adjacent to the former power station site and their design and nature means that they would present relatively small and incremental changes to the historic landscape character of a limited part of Section D. The addition of the proposed Richborough Connection project to this baseline would not perceptually extend this area of industrial activity and consequently no adverse cumulative effect is anticipated.
Conclusions 16.6.83 In all cases, notwithstanding the potential for the effects of developments considered within the cumulative assessment to be considered significant when assessed in their own right, the magnitude of cumulative change presented by the addition of the proposed Richborough Connection project would be insufficient to give rise to any significant adverse cumulative effect.
16.7 Assessment of Cumulative Effects: Biodiversity 16.7.1 Only developments for which an identified potential significant cumulative effect could occur have been scoped in and assessed in terms of the effects on biodiversity. Biodiversity receptors are scoped in to the cumulative assessment according to the methodology provided in Chapter 9, Section 9.7 of this document. 16.7.2 Biodiversity receptors which have been scoped in as having the potential to be subject to potentially significant cumulative effects from the Richborough Connection project, and one or more of the scoped in developments (see Table 16.2), are identified in Tables 9A.1-9C.1, within Volume 5, Document 5.4.9A-5.4.9C. For
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those receptors and developments scoped in to the assessment, potential cumulative effects arising are discussed below. The effects are assessed as per the methodology provided in Section 16.3 above and Chapter 9, Section 9.8 of this document. 16.7.3 Based on the assessment of effects on biodiversity from the Richborough Connection project (Chapter 9 of this document), the potential for significant cumulative effects to occur is considered to be low; it is expected that embedded environmental measures and standard industry best practice measures would be required for each of these developments, in the same way that they are required for the proposed Richborough Connection project, in order to limit any significant effects or breaches of legislation. As effects would likely be reduced to ‘not significant’ for all receptors, and there are no significant effects assessed in respect of the proposed Richborough Connection project, the likelihood of such effects combining to cause a cumulative significant effect would be low.
Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich 16.7.4 Documents reviewed relating to the Discovery Park Biomass Plant include: Dover District Council (DDC) Screening Decision284; Existing and proposed site layout drawings285; and Biomass Combined Heat & Power Plant – Planning Statement. Development B - Thanet Solar Farm, Ramsgate Road 16.7.5 Documents reviewed relating to the Thanet Solar Farm application include: Planning, Design and Access statement265; and Ecology Assessment286. Development C - Discovery Park Masterplan 16.7.6 Documents reviewed relating to the Discovery Park Masterplan include: Existing and proposed site layout plans287; Planning Statement268; and Environmental Statement269.
284 Letter from Dover District Council to Estover Energy Limited dated 8 May 2013 regarding Screening Opinion for the erection of a Biomass Combined Heat Power Plant Location: North-east side of Discovery Park, Ramsgate Road, Sandwich, CT13 9ND. Letter reference: DOC/13/00305 285 Site Location Plan (13_00701-SITE_LOCATION_PLAN-236536); Boundary plan (13_00701-BOUNDARY_PLAN- 236533); Block Plan (13_00701-BLOCK_PLAN-236534) Proposed Biomas Plan, drawing no. 1281-013, sheet 1 of 4, revision A8, dated 26/07/2103; and Site Sections (13_00701-SITE_SECTIONS-236537), drawing number 13034-F014 C, dated 19 June 2013 286 URS. Richborough Solar Farm - Ecology Assessment. Report ref 46369027. September 2013. 287 Prepared by Planit IE, Drawing No. PL1238 .1_ M120 D, Rev D, dated 18/11/13; Indicative Masterplan: prepared by Planit IE, Drawing No. PL1238.1_M100E, Rev E, dated 03/01/14.
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Development D - New 400kV substation and converter station at Richborough as part of Nemo Link project 16.7.7 Documents reviewed relating to the new 400kV substation and converter station at Richborough include: Nemo Link Design and Access Statement270; Nemo Link ES271; and The recommendation for planning approval288. Development E - Richborough Energy Park - Peaking Plant, Richborough Power Station 16.7.8 Documents reviewed relating to the Richborough Energy Park application include: Environmental Statement273.
Pre-application stage developments Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak and the Sturry Link Road 16.7.9 Documents reviewed include: The Sturry Broad Oak Masterplan274; and Canterbury’s proposed Road improvements289. Development G - Strategic Development Site SP3 Site 8: Land North of Hersden 16.7.10 Documents reviewed include: Strategic Development site layout plan for North Hersden275. Development H - Communications Mast, Ramsgate Road 16.7.11 Documents reviewed include: Request for a Screening Opinion276; Screening Opinion277; and Richborough Energy Park Site Location Plan290.
National Grid Permitted Development Development I - Canterbury North 400kV Substation [CA/15/00601] 16.7.12 Documents reviewed include: Existing and proposed site layout plans292; Planning Statement: Proposed Mitigation Ponds278; and Canterbury North 400/132kV Substation – Pond Specification291.
288 Thanet District Council. Recommendation of planning approval. Undated. 289 Canterbury City Council. Canterbury’s Proposed Road Improvements – getting the city moving. 2014. http://media.kentonline.co.uk/filerepository/2014/3/27/14032751430-Canterbury%20new%20roads-01.pdf 290 Vigilant Global. Site Location Plan, drawing number VG-PR2-00xx-Master_B 320M 001, Issue B, dated 24/01/2015 291 Amec for National Grid. Technical Note: Canterbury North Substation - Pond Specification. March 2015.
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16.7.13 Further to the documents above, draft derogation European Protected Species licence applications for great crested newt and dormice were available to the Richborough Connection project.
Assessment of Potential Cumulative Effects – Ancient woodland, veteran trees and lowland mixed deciduous woodland (Den Grove Ancient Wood) 16.7.14 No significant effects on this receptor have been identified for the Richborough Connection project. The proposed Richborough Connection project would result in very low/low level change to woodland habitat during the 132KV PX dismantling in construction phase. Tree planting where the 132KV PX route is removed, would, in operation improve connectivity across Den Grove, and over the medium to long term would compensate for loss of mature woodland canopy elsewhere with a low level positive effect. Very low negative effects would result in decommissioning. Overall, a neutral effect is assessed. 16.7.15 Development F is located adjacent to and in Den Grove Wood, designated as ancient woodland. The woodlands shown on the illustrative layout masterplan (Den Grove Wood) are shown as remaining intact. Some supplementary planting is to take place in the centre, eastern and south areas of Development F. This would compliment the planting to be undertaken as part of the proposed Richborough Connection project. 16.7.16 The proposed route of the Sturry link Road element of Development F cuts through the south and east of Den Grove Wood, potentially severing an eastern section of wood. This route is however, predominantly through the areas of proposed new planting, rather than existing ancient woodland, thus minimising direct and associated indirect effects on the woodland. In the medium to long term (alongside operation of the Richborough Connection project) it would be expetced that management of the woodland would result in positive effects. It would be expected that despite some negative effects in construction phase, the development would be subject to best practice and legal measures as appropriate, and that in combination with the proposed Richborough Connection project, effects are considered to be not significant.
Assessment of Potential Cumulative Effects – Rivers 16.7.17 No significant effects on this receptor have been identified for the Richborough Connection project. Chapter 13 of this document has concluded that there would be no significant effects to river water quality during construction, operation or decommissioning; inclusive of the embedded environmental measures and the CEMP (Volume 5, Documents 5.4.3B and 5.4.3C respectively). Effects in respect of biodiversity are limited to land cover and changes which are limited and temporary in nature in all phases of development, and are assessed overall as very low/low level of change, and are effects are not significant. 16.7.18 A number of the scoped in developments are located sufficiently close to river habitat to have potentially significant effects. Developments A-G are all located adjacent to, or could indirectly affect, the River Great Stour/River Stour. 16.7.19 Potential direct effects as a results of scoped in developments are associated with the potential bridging of the River Great Stour at Broad Oak, as part of Development F (a small watercourse in Den Grove Wood also intersects this development). As this development is at pre-application stage, full development proposals are currently
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unavailable. No direct effects as a result of the proposed Richborough Connection project are assessed. Therefore, potential direct effects upon the river as a result of Development F are considered to be independent from the Richborough Connection project. 16.7.20 Any cumulative effects upon this receptor as a result of the scoped in developments and the proposed Richborough Connection project are limited to indirect effects (via pollution) during construction, operation and decommissioning. Embedded environmental measures included as part of the proposed Richborough Connection project would ensure that indirect effects are not significant (Chapter 13 and Section 16.10 and 16.11 of this document). The remaining scoped in developments (where development proposals are available) do, or would be required to include similar measures to reduce indirect effect. Consequently, it would be expected that despite some negative effects in construction phase, the developments would be subject to best practice and legal measures as appropriate, and that in combination with the proposed Richborough Connection project, effects are considered to be not significant.
Assessment of Potential Cumulative Effects – Great Crested Newts 16.7.21 No significant effects on this receptor have been identified for the Richborough Connection project. The proposed Richborough Connection project would not directly affect any known breeding great crested newt (GCN) ponds. Potential indirect effects are limited to the short term loss of suitable terrestrial habitat and associated disturbance. Embedded environmental measures would ensure legal compliance and maintenance of favourable conservation status. Given the short term low level of change in construction, the relative short term very low change in operation, and temporary very low change in decommissioning, the overall magnitude of change on GCN to be very low negative, and the resultant effect is not significant. 16.7.22 Developments A-D did not record any GCN within ~500m and therefore there are not considered to be any significant cumulative effects as a result of these developments and the proposed Richborough Connection project. 16.7.23 Developments F and G would be likely to affect known GCN breeding ponds in Sections A and B of the Order limits, (Great Crested Newt Survey Report, Volume 5, Document 5.4.9I). These populations of GCN would not be significantly affected by the proposed Richborough Connection project through the inclusion of embedded environmental measures, and no significant cumulative effects are considererd likley. 16.7.24 A single pond would be lost and ~0.695ha of suitable terrestrial habitat would be removed as part of Development I at Canterbury North 400kV/132kV substation permitted development works; a GCN licence has been granted by Natural England for these works (2015-12714-EPS-MIT). Appropriate mitigation has been included to ensure there is no net loss of ponds and reduce risks of direct harm to GCN. A detailed masterplan has been devised in consultation with Natural England and forms part of the proposed Richborough Connection project derogation licence for GCN to ensure that cumulative effects are fully considered. This demonstrates that there would be no negative residual impacts from the combined effects of the proposed Richborough Connection project and permitted development works, and together with embedded environmental measures, the favourable conservation status of the overall local population of GCN would be maintained and cumulative effects upon GCN are considered to be not significant.
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16.7.25 Detailed development proposals for the remaining scoped in developments are not available. However, it is considered that since best practice during survey, assessment and mitigation would be required for consents to be issued in respect of the pre-application stage developments, potential significant cumulative effects would be avoided. Consequently, subject to best practice and legal measures as appropriate, in combination with the proposed Richborough Connection project, effects are considered to be not significant.
Assessment of Potential Cumulative Effects – Bats 16.7.26 No significant effects on this receptor have been identified for the Richborough Connection project. The proposed Richborough Connection project would result in the loss of two small transitional roosts and the disturbance of another small transitional roost, all considered to support common bat species. All works would be undertaken subject to a NE derogation licence and embedded environmental measures to ensure the maintenance of favourable conservation status. Given the short term low level of change in construction, the temporary very low change in operation, and temporary very low/low change in decommissioning, the overall magnitude of change on bats is considered to be very low and negative, and the resultant effect is not significant. 16.7.27 Developments B, D and E would have no direct effects upon bat roosts and indirect effects upon these receptors are limited to the loss of low value foraging/commuting habitats and disturbance through lighting. Each development includes environmental measures to minimise these effects, therefore cumulative effects as a result of these developments are considered to be not significant. 16.7.28 Works for Development I at Canterbury North 400kV/132kV Substation may be subject to a NE derogation licence (separate to any for the proposed Richborough Connection project), which may require the demolition of three buildings containing small transitional/satellite roosts of soprano pipistrelle and common pipistrelle (maximum three bats each). A large soprano pipistrelle maternity roost supporting at least 418 bats has also been identified at the Canterbury North 400kV/132kV Substation, although this would be retained, undisturbed by the proposed scoped in development works. Further survey work will be carried out in 2016 to confirm the status of the roosts within Canterbury North 400kV/132kV Substation, and to inform any licence application and mitigation measures292. If required, mitigation proposals are, however, likely to include: exclusion of bats from roost features outside of the hibernation period; provision of alternative roosting habitat; sensitive design of site lighting plan to avoid light spill onto roosts; and soft strip of buildings under the supervision of a licensed bat ecologist. With the implementation of the measures described it is assessed that the favourable conservation status of common and soprano pipistrelle bats at the site would be maintained given the low conservation status of those roosts being lost, and the adaptable nature of the common and widespread species to be affected. The Canterbury North 400kV/132kV Substation upgrade works are not considered to have any in combination effects on the same populations of bats affected the proposed Richborough Connection project therefore
292 Detailed design for the Canterbury North 400kV/132kV substation upgrade works are in development which may limit the requirement for the demolition of buildings at Canterbury Substation. However, this assessment is based on information known at this point which may be subject to change. Thus, no mitigation scheme for bats (including compensation, monitoring and maintenance) is yet prepared. This is expected to be detailed in mid 2016 if required.
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cumulative effects as a result of these developments are considered to be not significant. 16.7.29 The remaining developments are at an early stage in design and effects in respect of bats are therefore not defined. Development F and to a lesser extent G may affect bat roosting and activity depending on detailed design. However, any potential direct effects would require legal compliance via a NE derogation licence(s), which would ensure there is no net loss of roosting habitat and reduce the risk of harm/injury to bats. Other indirect effects would be limited to loss of foraging/commuting habitat and disturbance through lighting. Given the small size of the associated development sites and large areas of retained optimal foraging/commuting habitats cumulative indirect effects likely as a result of these developments are considered to be not significant.
Assessment of Potential Cumulative Effects – Dormice 16.7.30 No significant effects on this receptor have been identified for the Richborough Connection project. Surveys in 2014 and 2015 within suitable habitat across the proposed Richborough Connection project Order limits identified evidence of dormice at four discrete locations Canterbury North 400kV/132kV substation, Kemberland Wood, Broad Oak, and Chislet Business Park North. All the works required within the four discrete areas supporting dormouse would be subject to embedded environmental measures via a derogation licence from NE, (listed in Volume 7, Document 7.2) and summarised in the Biodiversity Mitigation Strategy, within Volume 5, Document 5.4.3E). As a result of the embedded environmental measures, it is assessed that the favourable conservation status of dormouse populations within the Order limits would be maintained. Given the short term low level of change in construction, the long term low/medium change in operation, and temporary very low/low change in decommissioning, the overall magnitude of change on dormice is considered to be low positive, and the resultant effect is not significant and therefore effects are assessed as not significant. 16.7.31 The permitted development works for Development I, at Canterbury North 400kV/132kV Substation are being conducted under a NE derogation licence with regards to dormouse (licence reference 2015-9344-EPS-MIT). The proposed Richborough Connection project working area overlaps with the permitted development working area and therefore the same population of dormice would be affected. The interaction of these projects and of the areas with dormouse populations within the Order limits have been considered with regards to cumulative effects in the NE Licence submissions for both projects, within the ‘Masterplan’ documents of these licences. The detailed masterplan forms part of the proposed Richborough Connection project derogation licence for dormouse and the embedded environmental measures contained within would ensure no significant effects from the combined impact of the proposed Richborough Connection project and permitted development works at Canterbury North 400kV/132kV Substation. The favourable conservation status of the overall local population of dormouse would be maintained and cumulative effects upon dormouse from the interaction between these projects are considered to be not significant. 16.7.32 No dormice were recorded outside Sections A and B of the Order limits area for the proposed Richborough Connection project, therefore only Developments F and G may result in change upon the same dormouse populations as the proposed Richborough Connection project. The Hersden, Sturry and Broad Oak strategic
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development sites and the Sturry link road are located to the south of the Order limits, and habitats which may connect dormouse populations in the Order limits to these proposed development areas were surveyed as part of the proposed Richborough Connection project and were not found to support dormouse. Thus, it is considered that any populations of dormouse which may be present within the Order limits are currently separate and independent from the scoped in developments. The embedded environmental measures within the proposed Richborough Connection project result in a very low magnitude positive change (not-significant) is assessed for dormouse as a result of improved habitat suitability from coppicing works, therefore cumulative effects upon dormouse from the interaction between these projects are considered to be not significant.
Assessment of Potential Cumulative Effects – Chislet Marshes, Sarre Penn and Preston Marshes LWS (including Park Rough) 16.7.33 No significant effects on this receptor have been identified for the Richborough Connection project. A total of 14 proposed Richborough Connection project pylons would be located within the receptor. Eleven of these would be situated within arable fields not valued for biodiversity (in this assessment, see Tables 9A.1-9C.1, Appendices 9A-9C, within Volume 5, Document 5.4). The remaining three pylons would all be located within poor semi improved grassland not valued for biodiversity (in this assessment, see Tables 9A.1-9C.1, within Volume 5, Document 5.4.9A- 9C). Habitat loss as a result of the pylon footings would be very limited, and habitat loss as a result of access routes would be temporary and fully reinstated. Other habitats such reedbed, woodlands and hedgerows which would be disturbed, through management or temporary removal would be fully reinstated to ensure no net loss of habitat after construction. Ditches within the LWS which would have short span bridges or culverts installed, would be temporary features during construction and decommissioning. Potential indirect effects are limited to pollution of watercourses which would be minimised via the embedded environmental measures to a level of effect assessed as not significant. 16.7.34 Development G is located immediately adjacent to the LWS, for which detailed development proposals are not available. However, it is considered that since best practice during survey, assessment and mitigation would be required for consents to be issued in respect of the pre-application stage developments, potential significant cumulative effects would be avoided. Proposals for woodland planting would link the LWS to woodlands in the wider landscape and potentially result in a positive effect. Consequently, subject to best practice and legal measures as appropriate, in combination with the proposed Richborough Connection project, cumulative effects are considered to be not significant.
Assessment of Potential Cumulative Effects – Ash Level & South Richborough Pasture LWS – Terrestrial 16.7.35 No significant effects on this receptor have been identified for the Richborough Connection project. The proposed Richborough Connection project falls, in part, within this receptor. Limited areas of habitat would be lost/damaged as part of proposals during construction and decommissioning. Embedded environmental measures would ensure all habitats are reinstated and managed appropriately. Habitat loss as a result of the pylon footings would be very limited, and habitat loss as a result of access routes would be temporary and fully reinstated. Embedded environmental measures would minimise changes to aquatic habitats to a very low
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level. Given the short term low level change in construction, the relative short term low/very low change in operation, and temporary low level change in decommissioning, the overall change to the LWS and its interest features is considered to be negative and of low magnitude and no effect on site integrity is assessed. The resultant effect is not significant. 16.7.36 The only other developments that may potentially directly affect the site are Developments B and H, which are both located entirely within the LWS. The LWS is cited predominantly for its flora and invertebrates (see below for ornithology). Development B would have an permanent impact on the botanical receptors of this area of the LWS due to land take, however much of the land is in arable (not assessed as of value in this assessment, see Tables 9A.1-9C.1, within Volume 5, Document 5.4.9A-9C) and the invertebrate value is restricted to ditch and dyke systems that will remain unaffected when best practice measures are adopted. Habitat loss associated with Development B would be permanent (~14ha) however would only result in the temporary loss/damage to a very small proportion of habitat within the LWS. The LWS comprises a total ~1037ha, the permanent loss of 14ha of the habitat concerned, subject to best practice and legal considerations required, is not considered to alter the integrity of the site therefore cumulative effects are not significant. 16.7.37 No other developments potentially directly affect the LWS. The closest other developments include Developments D and E. Indirect effects upon the terrestrial features of the LWS are limited to dust during construction/decommissioning. Embedded environmental measures included within the proposed Richborough Connection project and within Development B, D and E would ensure cumulative effects as a result of dust are not significant. 16.7.38 The pre-application stage projects would be required to employ best practice measures and obtain any consenting required in respect of features in the LWS. Therefore cumulative indirect effects are considered to be not significant.
Assessment of Potential Cumulative Effects – Ash Level & South Richborough Pasture LWS – Ornithology 16.7.39 No significant effects on this receptor have been identified for the Richborough Connection project. The proposed Richborough Connection project partially falls within the Ash Level & South Richborough pasture LWS. Small areas of habitat would be lost/damaged as part of proposals during construction and decommissioning. Embedded environmental measures included will ensure all habitats are reinstated and are removed outside the breeding bird season. 16.7.40 The only other developments that may potentially directly affect the LWS are Developments B and H, which are both located entirely within the LWS. The LWS is cited predominantly for its ornithological assemblage of breeding and over wintering waders. Development H is not considered to pose any risk of bird collision as it is assumed that it will be appropriately lit and would not create any barrier effect to bird movement therefore any cumulative effects as a result of bird collision are considered to be not significant. 16.7.41 Any indirect effects will be short term and limited to construction and decommissioning only. Development B (~14ha) is entirely located within the LWS and survey work by URS in 2011 recorded up to 11% of the total lapwing numbers from Ash Level & South Richborough Pasture LWS within the proposed solar farm
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site. Mitigation for Development B includes a habitat management plan where all retained habitats would be managed for breeding waders. The loss of terrestrial habitat is not considered to be a significant cumulative effect given proposed mitigation and the relative small amount of habitat loss compared to the total size of the LWS (~1037ha). 16.7.42 Indirect effects associated with disturbance to overwintering birds in the LWS as a result of both the proposed Richborough Connection project and Development B would be minimised by embedded environmental measures to ensure disturbance during construction and decommissioning results in very low levels of change. Other developments within close proximity to the LWS include Developments D and E. Both include very small amounts of habitat loss (outwith the LWS) and would reduce any disturbance by environmental measures. Disturbance to wintering birds is further minimised for both the proposed Richborough Connection project and Development D by the timetabling of works outwith the key wintering months. 16.7.43 It should also be noted that potential cumulative effects as a result of noise, light and vibration would be negligible as both the proposed Richborough Connection project and Development E would not be constructed simultaneously within the LWS. Potential cumulative effects upon the ornithological features of the Ash Level & South Richborough Pasture LWS are considered to be not significant.
Conclusions 16.7.44 In conclusion no significant cumulative effects on biodiversity receptors are expected to occur.
16.8 Assessment of Cumulative Effects: Traffic 16.8.1 The cumulative assessment considers the potential cumulative effects which may result from the combined effects of the Richborough Connection project and other major development proposals scoped-in, as identified in Table 16.2 of this Chapter. 16.8.2 The assessment has been undertaken for the construction phase only for each development and these have been summarised in to those development that are: already committed to start construction at the same time as the Richborough Connection project; and developments that could potentially start construction at the same time as the Richborough Connection project. 16.8.3 Where possible, the assessment has identified the development construction programme, the likely construction traffic flows (HGVs) associated with the works and the likely construction traffic routes to and from the site. The cumulative impact of the construction and dismantling traffic of the Richborough Connection project and other developments on receptors has been identified. 16.8.4 As the predicted operational traffic flow for the Richborough Connection project would be low, the assessment of cumulative effects with other developments has not been assessed.
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Committed developments 16.8.5 At the time of writing it was assumed that the following committed developments could enter construction at the same time as the proposed development: Development A: Discovery Park Biomass Plant – a two year construction programme was expected to start in 2015. However, as this development has no grid connection it has not yet commenced construction and could overlap with the Richborough Connection project. It is estimated that there would be approximately 20 HGVs a day and up to 200 employee movements to the site during peak construction activity. It is likely that the construction traffic for this development and the Richborough Connection project would both use the A256 Ramsgate Road to access work sites. Development B: Thanet Solar Farm –development timescales are not known as the solar farm cannot currently be connected into the UK Power Networks distribution system. However, there could be some overlap in the programme for this project and the proposed development. Details on likely construction flows are currently not available. It is likely that the A256 Ramsgate Road would be used by both construction vehicles to access this development and the Richborough Connection project. Development C: Discovery Park Masterplan –the initial development programme was reported as 2014-2026, with the main construction activity being completed in 2018. The number of construction vehicles for the development in 2018 has been estimated as 338 movements a day. However, it is understood that work has not yet started at the site. There could be some overlap in the construction programme of this project and the Richborough Connection project. It is likely that this development and Richborough Connection project construction traffic would both use the A256 Ramsgate Road to access work sites. Development D: Converter station and National Grid 400kV substation at Richborough as part of the Nemo Link - the site preparation works, construction of the converter station and 400kV substation is planned to be undertaken from mid-2015 to 2018/19. Both the converter station and 400kV substation will be commissioned in October 2018/19. A second supergrid transformer will be commissioned in 2019. The number of construction vehicles has been estimated within its ES271 as 19 two-way HGV trips a day. There could be overlap in this construction programme of the development and the Richborough Connection project. It is likely that construction traffic for this development and the Richborough Connection project would both use the A256 and the A299 to access work sites. Development E: Richborough Energy Park –the construction programme is estimate as being 18 months in the ES for the development273 (start date in 4th Quarter 2013 with finish in late 2014). However, it is understood that this development has not commenced due to network capacity issues and is unlikely to be complete before commencement of the proposed development. The ES indicates that at peak activity (worst case), there would be 80 HGV movements a day. There could be an overlap in this construction programme of the development and the Richborough Connection project. It is likely that construction traffic for this development and the Richborough Connection project would both use the A256 Ramsgate Road to access work sites.
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Pre-application stage developments 16.8.6 In addition the following projects were at pre-application stage and therefore could give rise to cumulative effects: Development F: Strategic Development Site SP3 Site 2: Sturry and Broad Oak – it is assumed that construction would commence in 2016/17 and last for approximately 7 to 8 years. Construction vehicles are likely to access the site using the A28, Herne Bay Road, Vauxhall Road, Broad Oak Road and Shalloak Road. Details on likely construction flows are currently not available. However, based on construction flow numbers for similar developments, it is estimated that there would be approximately 150 HGV movements a day. Development F: Sturry Link Road – improved access in the Sturry area linked to Development Site SP3. Road application is expected to be submitted at the same time as the strategic development site above, with construction likely to be 2017/18. Estimated construction traffic flows are currently not available. The surrounding roads that may be used by both the development and Richborough Connection project construction traffic are Vauxhall Road, A28, Herne Bay Road, Broad Oak Road, and Shalloak Road. Development G: Strategic Development Site SP3 Site 8: Land North of Hersden – construction is unlikely to start until 2017/18 and take between seven and nine years to complete. This is because the LPA has advised the site cannot be developed until after the Sturry Link Road is completed. Details on likely construction traffic flows are currently not available. However, the A28 may be used by both the development and Richborough Connection project construction traffic. However, based on construction flow numbers for similar developments, it is estimated that there would be approximately 150 HGV movements a day. Development H: Communications Mast, Ramsgate – details on likely construction flows are currently not available. However, it is likely that construction traffic for this development and the Richborough Connection project would use the A596 Ramsgate Road to access the site.
National Grid Permitted Development 16.8.7 National Grid is proposing works at the Canterbury North 400kV Substation under its permitted development rights: Development I: Canterbury North 400kV Substation - duration of site works, including commissioning and testing are likely to be from early 2017 until late 2018. The Site Traffic Assessment293 report for the shunt reactor replacement scheme identifies that there could be a total of 1,253 construction vehicle movements over the whole programme. It is estimated that there would be an average of 20 HGV movements a day over two years. It is likely that the construction traffic for this development and the Richborough Connection project would both use the A28, Vauxhall Road and Broad Oak Road to access work sites.
293 Mott Macdonald. Site Traffic Assessment – Canterbury 400kV Substation – Shunt Reactor Replacement. July 2015.
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Assessment of Potential Cumulative Effects – during construction 16.8.8 It is considered that there may be cumulative traffic and transport effects with other developments should the construction programmes identified above continue to overlap with the Richborough Connection project. 16.8.9 At the time of writing, details on all proposed construction flows for these developments were not fully available. Therefore, a full assessment of cumulative effects on receptors cannot be suitably considered. However, it can be identified that the A596 Ramsgate Road, A28, A253 Ramsgate Road, Vauxhall Road and Broad Oak Road are likely to have cumulative traffic and transport effects, particularly in 2018, if all development proceed. 16.8.10 Table 16.3 provides a summary of the predicted construction traffic flows for the other developments.
Table 16.3 Summary of predicted construction flows for other developments
Development Construction Daily Roads affected Programme construction traffic flows (HGV)
Committed developments
Development A 2015 (not started yet 20 A256 so may overlap)
Development B Timescales not known None available – A256 estimated at 15
Development C 2018 338 A256
Development D 2015-2018/19 19 A256 and A299
Development E 2014 (not started yet 80 A256 so may overlap)
Pre-application stage developments
Development F - 2016/2017 None available – A28, Herne Bay Strategic estimated at 150 Road, Vauxhall Development Site Road, Broad Oak SP3 Site 2: Sturry and Road and Shalloak Broad Oak Road
Development F - 2017/2018 None available– Vauxhall Road, A28, Sturry Link Road estimated at 100 Herne Bay Road,
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Development Construction Daily Roads affected Programme construction traffic flows (HGV)
Broad Oak Road, Shalloak Road
Development G 2017/2018 None available– A28 estimated at 150
Development H Late 2015/early 2016 None available – A596 (not started yet so estimated at 20 may overlap)
National Grid Permitted Development
Development I 2017/2018 Estimated at 20 A596
16.8.11 For those developments that have estimated construction flow data available, it has been identified that the A596 Ramsgate Road would have cumulative traffic and transport effects. In terms of Development D and Development C, the construction flows associated with these development would utilise the A256 Ramsgate Road which is a strategic highway route within the area. In total there may be an additional 512 movements a day associated with these developments that could be using the A596 Ramsgate Road at the same time as the construction traffic for the Richborough Connection project. However, as the baseline flows along this road are high the addition of the proposed cumulative traffic flows for these development in combination with Richborough Connection project would have negligible/minor and therefore not significant effects on receptors. 16.8.12 As there are a number of major developments being undertaken near Canterbury, there may be a notable cumulative effect on traffic and transport predominantly along the A28. Should the construction of the Strategic Development sites at Sturry and Broad Oak and Hersden be undertaken at the same time as the Sturry link road and the Richborough Connection project, it is estimated that there would be an additional 400 daily movements along the A28. During peak construction for the Richborough Connection project, it was identified that there would be a moderate adverse effect due to the increase in HGV movements. It is likely that the additional traffic from other developments would lead to a moderate to major adverse cumulative effect on the A28 and surrounding highway network of Herne Bay Road, Broad Oak Road, Shalloak Road and Vauxhall Road. The effects on receptors would be significant.
16.9 Assessment of Cumulative Effects: Noise 16.9.1 Due to the different approaches to the modelling and assessment of construction and operation noise effects, this section has been subdivided into cumulative
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assessments for ‘Construction noise’ and ‘Operational noise’. This mirrors the approach adopted in Chapter 11 of this document.
Construction noise 16.9.2 The assessment of cumulative construction noise effects has considered cumulative effects by development, as these will relate to the geographical location and timing of the proposed developments. Cumulative construction noise effects will only result where developments take place at the same time and are in close proximity. 16.9.3 The cumulative assessment considers the potential cumulative effects which may result from the combined effects of the Richborough Connection project and other major development proposals scoped-in, as identified in Table 16.2 of this Chapter. 16.9.4 Receptors which have been identified as experiencing effects from the Richborough Connection project and one or more of the developments described in Table 16.2 are discussed below. Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich Background documents reviewed 16.9.5 The site location plan and the Noise Assessment Report prepared by RPS294 for the development have been considered. Potential Cumulative effects 16.9.6 There is a separation distance of over 2km between Development A and the Richborough Connection project 400kV overhead line route, therefore there will not be any cumulative construction noise effects. Development B - Thanet Solar Farm, Ramsgate Road Background documents reviewed 16.9.7 To inform the cumulative assessment reference has been made to site location plans295 and Planning Decision Notice296 for the development. No noise impact assessment was prepared for this development. Potential Cumulative effects 16.9.8 Construction works on the Richborough Connection project and Development B will take placen close proximity, however the nearest receptors are located approximately 800m away and the cumulative noise effects will therefore be negligible. Development D - New 400kV substation and converter station at Richborough as part of the Nemo Link project and internal access road
294 RPS. Discovery Park Biomass: Noise Assessment of Proposed Development. 2014. 295 Montagu Evans Site Location Plan Thanet Solar Farm Richborough 296 Application Number DOV/13/00794 Notification of Grant of Full Planning Permission. Dover District Council 2014.
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Background documents reviewed 16.9.9 To inform the cumulative assessment reference has been made to the noise assessment and the non-technical summary of the Nemo Link ES271 and the Design and Access Statement. Potential Cumulative effects 16.9.10 Construction works on the Richborough Connection project and Development D will take place in close proximity, however the nearest receptors are located approximately 800m away and the cumulative noise effects will therefore be negligible. Pre-application stage projects Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak Background documents reviewed 16.9.11 The key source of information was the developer website279 and the CCC draft local plan. There are no specific documents relating to noise. Potential Cumulative effects 16.9.12 Cumulative construction noise effects are possible when construction works for Development F and works on the Richborough Connection project take place simultaneously in close proximity to receptors on Shalloak Road. As no development details for the strategic allocation development are currently available it is not possible to conclude the signficance of such effects. Construction works on the Richborough Connection project are however transient and any cumulative noise effects will be of relatively short duration. 16.9.13 Cumulative construction noise effects with the link road element of Development F are possible when works at PC3 on the 400kV overhead line takes place. The works on pylon PC3 will be of short duration and therefore cumulative effects will also be of short duration. 16.9.14 Predicted noise impacts for the pylon construction alone are predicted to be below the daytime limit of 70dB(A) and the weekend noise limit of 60dB(A) and the cumulative noise effects would be moderate adverse and therefore significant. As noted above however, construction works on the Richborough Connection project are transient and the cumulative noise effects will therefore be of relatively short duration. Development G - Strategic Development Site SP3 Site 8: Land North of Hersden Background documents reviewed 16.9.15 Background information is available on the Hume Planning website275 although no specific documents have been published with regards to noise. Potential Cumulative effects 16.9.16 There is a separation distance of 500m between Hersden and the proposed 400kV overhead line. Development G is located on the land between the Richborough Connection project and existing receptors in Hersden. The Richborough Connection project has negligible noise impact on Hersden, as reported in Chapter 11 of this document. The cumulative noise effects are likely to be negligible, with construction noise from Development G being the prevailing noise impact.
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National Grid Permitted Development Development I - Canterbury North 400kV Substation Background documents reviewed 16.9.17 The site location plan297 and the Planning Statement278 for the proposed development have been considered. Potential Cumulative effects 16.9.18 Cumulative construction noise effects are possible when works on the 400kV overhead line pylons PC1 and PC2 take place, as these are in close proximity to Development I. The works on pylons PC1 and PC2 will be of short duration and therefore cumulative effects will also be of short duration. Predicted noise effects at properties on Vauxhall Avenue and at Greenbridge Park for the pylon construction alone are predicted to be negligible and the cumulative noise effects would be not significant. Cumulative effects – construction traffic 16.9.19 It is considered that there may be cumulative traffic and transport effects with other developments should the construction programmes identified above continue to overlap with the Richborough Connection project. 16.9.20 At the time of writing, details on all proposed construction flows for these developments were not fully available. Therefore, a full assessment of cumulative effects on receptors cannot be suitably considered. However, it can be identified that the A596 Ramsgate Road, A28, A253 Ramsgate Road, Vauxhall Road and Broad Oak Road are likely have cumulative traffic and transport effects, particularly in 2018, if all development proceeds. 16.9.21 For those developments that have estimated construction flow data available, it has been identified that the A596 Ramsgate Road would have cumulative traffic and transport effects. In terms of Developments C, D and E, it is anticipated that the construction flows associated with these developments would utilise the A256 Ramsgate Road which is a strategic highway route within the area. In total there may be an additional 512 movements a day associated with these developments that could be using the A596 Ramsgate Road at the same time as the construction traffic for the Richborough Connection project. However, as the baseline flows along this road are high, the addition of the cumulative traffic flows for these development in combination with the Richborough Connection project would have negligible/minor and therefore not significant effects on receptors. 16.9.22 Cumulative construction traffic effects are considered in Section 16.8 of this Chapter which reports that in terms of Development D, the construction flows associated with this development would utilise the A256 which is a strategic highway route within the area. As detailed in paragraph 16.8.12, there may be a notable cumulative effect on traffic and transport predominately along the A28 due to the number of proposed developments in the Canterbury area. Should the construction of Developments F and G be undertaken at the same time as the Richborough Connection project, it is estimated that there would be an additional 400 daily movements along the A28.The baseline flows along this road are high and the cumulative flows of the Richborough
297 Amec Foster Wheeler Figure 2.1 Site Location. Richborough Connection project Canterbury 400kV Substation New Pond Planning Application
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Connection project with these would have negligible and therefore not significant noise effects on receptors along this road.
Operational noise 16.9.23 This section discusses the cumulative effects of the operational phase of the proposed development and the noise, from both construction and operation, of other developments. Cumulative impact assessment seeks to ascertain if a combination of developments is likely to reach or exceed the limit at which the environment in unable to accept further development. 16.9.24 The cumulative effects for operational noise have been considered for each development. This approach has been adopted due to the relatively short distances over which noise effects effects occur, typically up to several hundred metres, depending on the source. As such, individual noise sensitive receptors are not likely to be affected by more than one noise source, with regards to cumulative effects, due to the large scale of this development and the corresponding distances between committed developments. This section therefore concludes with a combined cumulative effects assessment to assess the potential combined effects at any individual receptor, where these occur. Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich Background documents reviewed 16.9.25 To inform the cumulative assessment reference has been made to the noise assessment presented in the Noise Assessment for Development A prepared by RPS294 dated June 2013. Potential noise effects of the committed development 16.9.26 The assessment indicates that noise levels from Development A would be below background noise levels at nearby receptors during both daytime and night time periods. This would lead to low magnitude effects. Summary of the operational noise arising from the Richborough Connection project 16.9.27 There are no significant operational noise effects arising from the Richborough Connection project in this area. Potential Cumulative Effects (at operation) 16.9.28 The distance between the proposed 400kV overhead line and Development A is sufficiently large (approximately 1.3km) that the cumulative effects are expected to be negligible. Development B - Thanet Solar Farm Background documents reviewed 16.9.29 To inform the cumulative assessment reference has been made to site location plans295 for the development. No noise impact assessment was prepared for this development. Potential noise effects of the committed development 16.9.30 There are not expected to be any significant operational noise effects from Development B.
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Summary of the operational noise arising from the Richborough Connection project 16.9.31 There are no significant operational noise effects arising from the Richborough Connection project in this area. Potential Cumulative effects (at operation) 16.9.32 The distance between the proposed 400kV overhead line and the nearest noise sensitive receptors at this location is sufficiently large (>500m) that the cumulative effects are expected to be negligible. Development C - Discovery Park Masterplan, Sandwich Background documents reviewed 16.9.33 To inform the cumulative assessment reference has been made to the Planning Statement268 and also to the case officer’s report267 to the planning committee. Potential noise effects of the committed development 16.9.34 The information provided to the planning committee indicates that there would be no significant noise effects due to either the construction or operational phases of Development C. Summary of the operational noise arising from the Richborough Connection project 16.9.35 There are no significant operational noise effects arising from the Richborough Connection project in this area. Potential Cumulative Effects (at operation) 16.9.36 The distance between the proposed 400kV overhead line and the nearest noise sensitive receptors at this location is sufficiently large (>3km) that any cumulative effects are expected to be negligible. Development D - New 400kV Substation and Converter Station at Richborough as part of the Nemo Link project Background documents reviewed 16.9.37 To inform the cumulative assessment reference has been made to the noise assessment and the non-technical summary of the Nemo Link ES271 and the Design and Access Statement270. Potential noise effects of the committed development 16.9.38 Development D has the potential to cause minor noise effects due to general construction activities at nearby receptors. Horizontal Directional Drilling activities have the potential to cause short term moderate effects at nearby receptors. 16.9.39 Without mitigation there is potential for the operation of both the converter station and 400kV substation to give rise to complaints from neighbouring properties. Mitigation will be incorporated into the design of the converter station and 400kV substation to ensure noise levels are no higher than the background noise level. This would lead to low magnitude effects. Summary of the operational noise arising from the Richborough Connection project 16.9.40 There are no significant operational noise effects arising from the Richborough Connection project in this area.
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Potential Cumulative Effects (at operation) 16.9.41 The distance between the proposed 400kV overhead line and the nearest noise sensitive receptors at this location is sufficiently large (>500m) that the cumulative effects are expected to be negligible. Development E - Richborough Energy Park - Peaking Plant, Richborough power station Background documents reviewed 16.9.42 To inform the cumulative assessment reference has been made to the noise assessment presented in the Environmental Statement for the committed development prepared by URS273. Potential noise effects of the committed development 16.9.43 The assessment indicates that noise levels from the construction and operation of Development E would be minor adverse and negligible at nearby receptors. Summary of the operational noise arising from the Richborough Connection project 16.9.44 There are no significant operational noise effects arising from the Richborough Connection project in this area. Potential Cumulative Effects (at operation) 16.9.45 The distance between the proposed 400kV overhead line and the nearest noise sensitive receptors at this location is sufficiently large (>500m) that any cumulative effects are expected to be negligible. Pre-application stage projects Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak Background documents reviewed 16.9.46 The key source of information was the developer website274 and the CCC draft local plan. There are no specific documents relating to noise. Potential noise effects of the strategic allocation 16.9.47 Development F may lead to a change in noise climate in the area although the nature of the change is unknown at this stage. The three potentially significant noise sources associated with the development of Development F include: temporary construction works; operational road traffic generation; and operational plant and/or activities (e.g. fixed mechanical and electrical building services plant). 16.9.48 This proposed link road element of Development F may lead to a change in noise climate in the area although the nature of the change is unknown at this stage. The two potentially significant noise sources associated with the development of the Sturry link road include: temporary construction works and operational road traffic. Summary of the operational noise arising from the Richborough Connection project 16.9.49 The spatial scope for a moderate effect from the overhead line is approximately 29m for dry conditions and approximately 102m for wet conditions in this area during quiet night time periods. Two properties in this area currently fall within the moderate adverse impact category due to operational noise from the proposed 400kV overhead line during wet conditions; namely 10 Shalloak Road and 3 Shalloak Road. 16.9.50 Operational noise from the overhead line may have an effect on noise sensitive receptors forming part of Development F which is understood to border the location
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of pylon PC4. Medium magnitude effects would be expected at distances within 29m from the overhead line for dry conditions and 102m from the overhead line for wet conditions. High magnitude effects would be expected within a distance of 40m from the overhead line during wet conditions although there would be no high magnitude effects during dry conditions due to the existing background noise level in the area. Potential Cumulative Effects (at operation) 16.9.51 Traffic levels may vary in the area although a significant change in traffic levels is required to result in a moderate adverse traffic noise impact. Additional traffic noise would add to the background noise climate, against which industrial type sources, such as overhead lines, are assessed. The assessment described in Chapter 11 of this document therefore constitutes a worst case scenario in this regard. In the event of a significant reduction in the background noise level, no properties would fall within the moderate adverse or major adverse significance category during dry conditions and one additional property, namely 8 Shalloak Road, may fall within the moderate adverse significance category during wet conditions. In terms of absolute noise levels this change in noise level, should this occur, would be less than 1dB which is practically imperceptible. The cumulative effects of traffic noise are therefore expected to be negligible. 16.9.52 Any commercial and industrial type premises forming part of Development F would require a noise impact assessment to determine the level of noise impact on nearby noise sensitive receptors. This would require approval by the local authority. An assessment would typically be in accordance with BS4142:2014 with a low magnitude effect to be achieved with the industrial noise rating level being below the prevailing background noise level, which is in line with the assessment of the overhead line noise as assessed in Chapter 11 of this document. Under these circumstances a reasonable worst case situation would be for any proposed industrial or commercial noise rating level to be equal to the background noise level at Broad Oak Farm (10 & 8 Shalloak Road), i.e. 33dB LA90 during dry, quiet night time conditions. It is noted that the assessment would take account of dry conditions, in accordance with BS4142:2014. It is also noted that the level of noise is unlikely to be dependent on whether the conditions are wet or dry. The dry rating level of the proposed 400kV overhead line is approximately 27dB at 10 & 8 Shalloak Road. An additional 33dB rating level would lead to a 34dB cumulative rating level leading to a +1dB assessment level. A +5dB assessment level would typically be an indication of an adverse effect depending on the context. The proposed 400kV overhead line, being at worst 7dB below this level, is unlikely to lead to significant cumulative effect should Development F contain industrial or commercial type noise sources in this location. The cumulative effect is therefore considered to be negligible. 16.9.53 Temporary construction noise would be controlled via a construction noise management plan. Given the higher levels of noise associated with construction compared to overhead line noise there are not expected cumulative effects in this regard and they are therefore considered negligible. 16.9.54 The change in noise climate due to Development F at this site should be assessed via a noise impact assessment. The assessment should be approved by the local authority and should contain suitable noise mitigation measures where appropriate.
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Development G - Strategic Development Site SP3 site 8: Land North of Hersden Background documents reviewed 16.9.55 Background information is available on the Hume Planning website275 although no specific documents have been published with regards to noise. Potential noise effects of the strategic allocation 16.9.56 Development G may lead to a change in noise climate in the area although the nature of the change is unknown at this stage. The three potentially significant noise sources associated with Development G include: temporary construction works; operational road traffic generation; and operational plant and/or activities (e.g. fixed mechanical and electrical building services plant). Summary of the operational noise arising from the Richborough Connection project 16.9.57 The spatial scope for a moderate adverse impact to residential properties from the overhead line is approximately 51m for dry conditions and approximately 124m for wet conditions in this area during quiet night time periods. Only one property falls within the moderate adverse impact category for operational noise from the proposed 400kV overhead line during wet conditions; namely Tile Lodge Farm. Potential Cumulative Effects (at operation) 16.9.58 The distance between the proposed 400kV overhead line and the nearest noise sensitive receptors at this location is sufficiently large (>400m) that the cumulative effects due to this strategic development are expected to be negligible. it is considered that the change in noise climate due Development G should be assessed via a noise impact assessment. The assessment should be approved by the local authority and should contain suitable noise mitigation measures where appropriate. Development H - Communications Mast, Ramsgate Road Background documents reviewed 16.9.59 A Request for a Screening Opinion prepared by Montagu Evans276 for the development states that Development H has a very limited number of issues from which impacts could arise, citing visual impact, ecology and flood risk as the main points of consideration. The Screening Opinion request indicates that operational noise is not significant and that construction noise would be of a short duration. The response from the Environmental Protection Officer for DDC277 concurs that noise issues can be screened out of this development given the proximity of residential receptors. Potential noise effects of the committed development 16.9.60 There are no material sources of operational noise from communications masts. Construction noise would be of a short duration although there are no noise sensitive receptors in the area. Summary of the operational noise arising from the Richborough Connection project 16.9.61 There are no significant operational noise effects arising from the Richborough Connection project in this area.
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Potential Cumulative Effects (at operation) 16.9.62 The distance to between the proposed developments and the nearest noise sensitive receptors is large (>500m). Cumulative noise effects are therefore expected to be negligible. Combined Cumulative Effects 16.9.63 The combined cumulative operational noise effects are the potential effects of multiple committed or planned developments, including the proposed 400kV overhead line, when considered together at any single receptor. It is considered that there are no combined effects at any individual receptor with regards to operational noise.
16.10 Assessment of Cumulative Effects: Air quality 16.10.1 Table 16.2 of this Chapter describes the developments scoped-in to the assessment of cumulative effects as their development timescales are likely to coincide with that of the Richborough Connection project. 16.10.2 Due to the close proximity of these developments to the proposed development, there is the potential for cumulative effects during the construction phase as a result of construction dust. However, it is envisaged that all of the other developments would need to adopt best practice mitigation measures in terms of construction dust, as outlined in Appendix 12A in Volume 5, Document 5.4.12A, or other suitable control options, in which case, the potential cumulative effects from fugitive dust emissions during the construction phase should remain as insignificant. 16.10.3 Any traffic generated by other developments would cause increases in exhaust related pollutants in the vicinity of the Order limits. However, providing liaison with other construction sites in the vicinity of the Order limits is undertaken regarding construction vehicle routes and environmental measures, as detailed in Appendix 12A in Volume 5, Document 5.4.12A, it is not anticipated that this would cause significant cumulative effects, particularly as existing background concentrations are low, and well below their respective air quality objectives. 16.10.4 The proposed development will not adversely affect air quality during its operational phase, and therefore there would be no cumulative air quality effects.
16.11 Assessment of Cumulative Effects: Water environment 16.11.1 Table 16.2 outlines those other proposed and consented developments in the vicinity of the proposed development, the impacts from which could potentially combine with those for the Richborough Connection project to create a cumulative effect. These have been assessed below in relation to potential cumulative effects on the water environment. 16.11.2 Only developments for which a potential hydrological connectivity could be identified have been considered in terms of the effects on the water environment. For example, developments within the hydrological catchments that the Order limits fall within. Outside of this, there is little potential for a cumulative effect to occur, unless a significant interaction via groundwater could be identified. All of the developments identified in Table 16.2 are within the hydrological catchments of the Order limits and have thus been assessed.
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16.11.3 The assessment of cumulative effects on the water environment has been undertaken ‘by development’. This approach was taken so as to be consistent with the approach taken in Chapter 13 of this document, whereby the potential effects of the proposed development on a range of potential receptors across the Order limits was often undertaken on the basis of hydrological connectivity. 16.11.4 As the vast majority of any potential effects identified in this assessment would occur during the construction phase, the timing (of construction) of the other developments with respect to the Richborough Connection project will be key; operational effects have been scoped out of this assessment. With respect to decommissioning, the timing of this is at present unknown, and so can not be considered with respect to other developments in the future, the existence and timing of which also cannot be known at this time. This cumulative assessment therefore primarily addresses effects during the construction phase, and for those developments where construction could potentially coincide. 16.11.5 Proposed and consented developments within the vicinity of the Order limits would have the potential to give rise to adverse cumulative indirect effects on the aquatic environment, water resources and flood risk receptors. Based on the assessment of effects on the hydrological environment from this Richborough Connection project (Chapter 13 of this document), the potential for cumulative effects to occur is considered to be low; it is expected that on-site design mitigation measures and standard industry best practice measures for protection of the water environment will be required for each of these developments, in the same way that they are required for the proposed Richborough Connection project, in order to limit any changes to the aquatic environment, water resources and/or flood risk receptors to ‘not significant’ effects. As effects would likely be reduced to ‘not significant’ for all sites, the likelihood of such effects combining to cause a significant effect would be low. 16.11.6 Although the likelihood of ‘not significant’ effects from more than one development combining to create a cumulatively significant effect would be low, such an eventuality has been considered below.
Committed developments Development A - Discovery Park Biomass Plant, Ramsgate Road, Sandwich [DOV/13/00701] 16.11.7 This development will be located within the north eastern part of the wider Discovery Park site (discussed further below), and within the Great Stonar ‘island’ formed by the loop of the River Stour and the Stonar Cut, as indicated in Development 13 on Figure 5.1d within Volume 5, Document 5.3.5. Background documents reviewed 16.11.8 Documents reviewed relating to Development A include: Dover District Council (DDC) Screening Decision298;
298 Letter from Dover District Council to Estover Energy Limited dated 8 May 2013 regarding Screening Opinion for the erection of a Biomass Combined Heat Power Plant Location: North-east side of Discovery Park, Ramsgate Road, Sandwich, CT13 9ND. Letter reference: DOC/13/00305.
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Existing and proposed site layout drawings299; and Biomass Combined Heat & Power Plant – Planning Statement 300. Water environment effects of the Committed Development 16.11.9 The screening decision from DDC advised that an EIA was not required to accompany the planning application, but noted that a number of consultee responses had been received which should inform the accompanying assessments, including from the Council’s Environmental Protection Department and the EA. The Planning Statement included sections on drainage, flood risk and land contamination. It is noted that the EA required a risk assessment to be prepared relating to potentially contaminated groundwater reaching the River Stour as a result of the foundation piling works. This should ensure no impact to groundwater quality as a result of the development. Both trade effluent and surface water run-off will be tested and treated (if necessary) prior to discharge. The final discharge would be subject to a consent by the EA. The section on flood risk indicates that there would be no increase in flood risk elsewhere as a result of the development. 16.11.10 Effects during the construction phase could include increased sediment yield in runoff or the accidental spillage of chemicals/fuels. The site is located adjacent to the River Stour, and a number of sensitive areas, namely; Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich Bay SAC and Sandwich Bay to Hackling Marshes SSSI, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. Potential effects on these designated sites are likely to be of a limited duration and magnitude due to the distance of the receptors from Development A, and the requirement for all construction sites to adhere to EA Pollution Prevention Guidelines (PPGs). Richborough Connection project water environment receptors potentially affected by the development 16.11.11 As discussed above, the site is located adjacent to the River Stour, and the Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich Bay SAC and Sandwich Bay to Hackling Marshes SSSI. Summary of the water environment effects arising from the Richborough Connection project 16.11.12 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed as of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.13 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With
299 Site Location Plan (13_00701-SITE_LOCATION_PLAN-236536); Boundary plan (13_00701-BOUNDARY_PLAN- 236533); Block Plan (13_00701-BLOCK_PLAN-236534) Proposed Biomas Plan, drawing no. 1281-013, sheet 1 of 4, revision A8, dated 26/07/2103; and Site Sections (13_00701-SITE_SECTIONS-236537), drawing number 13034-F014 C, dated 19 June 2013. 300 Planning Supporting Statement, Biomass Combined Heat & Power Plant, Discovery Park. Prepared by Estover Energy Limited, August 2013.
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respect to sediment laden run-off, as aforementioned, the loop of the River Stour and the Stonar Cut is located approximately 6.5km downstream of the Order limits of the Richborough Connection project, with the primary hydrological connection being provided by the River Stour. At such distance, with due consideration of dilution within the tidal River Stour, and the baseline sediment load of such a tidal river, the potential for cumulative effects is considered to be not significant. With respect to physical modification, no such modification to channels have been identified at Development A, and therefore there is no potential for cumulative effects to occur. Development B - Thanet Solar Farm, Ramsgate Road, [DOV/13/00794] 16.11.14 This development will be located immediately adjacent to, and partially within Section D of the Order limits of the Richborough Connection project, adjacent to the River Stour, as indicated in Development 7 in Figure 5.1d within Volume 5, Document 5.3.5. The site falls within the Ash Level and consists of semi-improved grassland, drained by a series of interconnected wet ditches which discharge into the River Stour. Background documents reviewed 16.11.15 Documents reviewed relating to Development B include: Existing and proposed site layout plans299; and Richborough Solar Farm FRA301. Water environment effects of the Committed Development 16.11.16 The FRA for Development B states that “the River Stour (which at this location is at or near sea level) flows adjacent to the site along part of the north-eastern boundary. Apart from this river, no other major watercourses exist within the vicinity of the site, although the fields surrounding the site are occupied by numerous inter-connecting drains. Just beyond the north-western boundary of the site exists a large pond.” 16.11.17 Surface water from this site will drain to the IDB drainage ditches that traverse this site, and ultimately to the River Stour. In terms of effects on the water environment, the vast majority from solar sites are also likely to occur during the construction phase with relatively few once operational. Effects during the construction phase could include increased sediment yield in runoff or the accidental spillage of chemicals/fuels. The magnitude of any effects on the River Stour are likely to be low due to the limited duration or any construction works and the requirement for all construction sites to adhere to EA PPGs. 16.11.18 Effects on the surface water quality of the River Stour are not anticipated given the dilution capacity of the tidal River Stour. Measures would be taken, as part of Development B, to minimise impacts to the IDB watercourses, any of which would also be localised and temporary; the plans submitted with the application indicate no works to the watercourses. A section of underground cable is proposed to link the solar farm to the existing UK Power Networks distribution network, which would involve a section underneath an ordinary watercourse. Land Drainage Consent will be required from the IDB for such works which would provide a mechanism to minimise risks to the water environment.
301 URS, 2013. Richborough Solar Farm Option, Flood Risk Assessment, 47064682, prepared for: Thanet Solar Ltd, March 2013.
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16.11.19 Access ways to some of the electrical substations and inverter cabinets will be provided, although none of these would be sufaced with impermeable material. A number of swales and/or infiltration trenches (the latter if ground conditions indicate that infiltration is possible) will be provided to intercept runoff. The swales will act as temporary storage / infiltration areas to intercept runoff, and will link with the existing drains on site. The final designs for the swales and trenches are subject to a planning condition. 16.11.20 Similar to the Richborough Connection project, the presence of new permanent structures in the floodplain (electrical substations, inverter cabinets and the legs for the solar panels themselves) is considered to have a negligible effect on floodplain storage due to the tidal nature of the floodplain and small volumes involved. The FRA for Development B concluded that the development would have no adverse impact on flood risk elsewhere. Richborough Connection project water environment receptors potentially affected by the development 16.11.21 The site is located adjacent to the River Stour, at the Richborough power station end of the Richborough Connection project. As such there are a number of sensitive areas located downstream of the site, at a similar distance downstream as the Order limits for the Richborough Connection project, namely: Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich Bay SAC and Sandwich Bay to Hackling Marshes SSSI, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. Summary of the water environment effects arising from the Richborough Connection project 16.11.22 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of, during construction, an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.23 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as aforementioned, the designated sites identified above are located at a similar distance further downstream (along the River Stour) of Development B as they are from the Order limits, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. At such distance, with due consideration of dilution within the tidal River Stour, and the baseline sediment load of such a tidal river, the potential for cumulative impacts is considered to be not significant. 16.11.24 With respect to physical modification, with the exception of the section of underground cable for which the Council have imposed a planning condition, no such modification to channels is proposed for Development B, and therefore no cumulative effects are anticipated. The Council’s review of the design of the cable, and the requirement for Flood Defence/Land Drainage Consent from the IDB and/or KCC for any in-channel works, should ensure no adverse effects on the physical
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characteristics of the channels on-site. On this basis, no cumulative effects are anticipated as a result of this development. Development C - Discovery Park Masterplan [DOV/14/00058] 16.11.25 This development is located within the Great Stonar ‘island’ loop of the River Stour, and thus is located some distance downstream of the Order limits. The location of this development is indicated as Development 8 on Figure 5.1d within Volume 5, Document 5.3.5. 16.11.26 A network of drainage ditches cross the site. The Masterplan indicates that additional waterbodies would be provided, such as swales. Background documents reviewed 16.11.27 Documents reviewed relating to Development C include: Existing and proposed site layout plans302; Planning Statement268; and Environmental Statement269. Water environment effects of the Committed Development 16.11.28 An ES was prepared to accompany the planning application for Development C, together with a FRA, and a utilities and foul drainage strategy. Potential effects to the water environment were identified in the EIA for the Masterplan, for which numerous mitigation measures were set out in the ES. It was concluded that, with the exception of floodplain storage, the implementation of these measures would ensure that no significant effects would occur. 16.11.29 With respect to floodplain storage, it was concluded that definitive conclusions could not be made (in terms of any increase in risk elsewhere as a result of amended development levels) at this outline stage. It was noted that hazard mapping was being prepared, and that if a significant effect is deemed to occur, appropriate mitigation will be proposed post submission/at the detailed design stage. 16.11.30 The ES included a section that specifically considered potential cumulative effects, as quoted below:
302 Site plan: Prepared by Planit IE, Drawing No. PL1238 .1_ M120 D, Rev D, dated 18/11/13; Indicative Masterplan: prepared by Planit IE, Drawing No. PL1238.1_M100E, Rev E, dated 03/01/14.
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“Cumulative effects during construction would be minimised through good site practice and adequate pollution prevention measures such as sediment traps and providing designated areas for oil and fuel storage, as is planned for Discovery Park. It is anticipated that if the planned developments incorporate appropriate measures then no significant cumulative effects will occur to water quality during construction. With the implementation of NPPF requirements there should be no significant negative effect associated with the management of surface water in the area as each development is completed. The quality of the surface water run-off may well be improved through the implementation of appropriate SUDS and end of line treatment systems.”
16.11.31 The ES also indicates that new waterbodies and/or improvements to existing waterbodies would occur, which would improve the physical characteristics of the aquatic environment at the site. 16.11.32 Any works within 15m of the River Stour would require Flood Defence Consent from the EA, and any within 8m of IDB watercourses would require Flood Defence/Land Drainage Consent from the IDB. The EA would require a WFD assessment for any in-channel works that they believe could result in deterioration of the morphology of a watercourse. Such controls will ensure that any changes to watercourse morphology would be of low magnitude and localised. Richborough Connection project water environment receptors potentially affected by the development 16.11.33 The site is located adjacent to the River Stour and a number of designated sites, namely: Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich Bay SAC and Sandwich Bay to Hackling Marshes SSSI, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. Summary of the water environment effects arising from the Richborough Connection project 16.11.34 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were all assessed to be of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors (during construction), and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.35 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With due consideration the mitigation proposed in the ES for Development C, together with the conclusions therein, the potential for cumulative impacts is considered to be not significant. In addition, once dilution within the tidal River Stour, and the baseline sediment load of such a tidal river is taken into account, and the fact that only a proportion of the Discovery Park is likely to be under development at the same time as the Richborough Connection project (owing to the anticipated 10 year timeframe for Development C) the risk of effects combining is considered to be low. 16.11.36 With respect to physical modification, the requirement for Flood Defence/Land Drainage Consent and WFD assessment should ensure no adverse effects on the
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physical characteristics of the channels on-site. In fact, the ES indicates that new waterbodies and or improvements to existing waterbodies will improve the physical characteristics of the aquatic environment at the site. On this basis, no cumulative effects are anticipated as a result of this Project. Development D - New 400kV Substation and Converter Station at Richborough as part of the Nemo Link project [F/TH/13/0760] 16.11.37 This development will be located at the site of the former Richborough power station, which remains covered in hardstanding, and immediately adjacent to the Richborough site compound and the River Stour. This site is therefore located downstream of the majority of the Order limits, but upstream of a short section of it. Background documents reviewed 16.11.38 Documents reviewed relating to Development D include: Existing and proposed site layout plans303; and The recommendation for planning approval304. Water environment effects of the Committed Development 16.11.39 The recommendations for planning approval include a number of conditions that will prevent any adverse impacts on the water environment. These include that no development will take place until a detailed sustainable surface water drainage scheme has been submitted and approved in writing by the authority. Together with the FRA approved with the application, this will ensure no increase in flood risk as a result of the development. It will also ensure that surface water is managed via a SuDS treatment train prior to off-site discharge. Further conditions have been imposed relating to: infiltration and piling to ensure no unacceptable risk to groundwater, fuel storage, and the preparation of a CEMP, including siltation and pollution control measures, to ensure the protection of water sensitive receptors during the construction phase. Finally, an Incident Management Plan (IMP) will be required for the operational site, to ensure no dispurption to existing sewerage facilities and drainage systems, and no impact to surrounding water bodies. 16.11.40 Surface water quality impacts are not anticipated, given the environmental measures that would be put in place. No morphology changes are anticipated. Richborough Connection project water environment receptors potentially affected by the development 16.11.41 Similar to the Richborough Connection project, the new 400kV substation and converter station will be located adjacent to the River Stour, and upstream of a number of sensitive areas: Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich bay SAC and Sandwich Bay to Hackling Marshes SSSI, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively.
303 Nemo-Link-Environmental-Statement-Figures. Environmental Statement for the Nemo Link Uk Onshore Components, Prepared by: Sophie Clayton/Bobby Clayton, TEP Limited for National Grid Nemo Link Limited, February 2013. 304 A06 - Former Richborough Station Road Ramsgate FTH130760. Applicant: National Grid Nemo Link Limited.
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Summary of the water environment effects arising from the Richborough Connection project 16.11.42 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.43 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as aforementioned, the designated sites identified above are located at a similar distance downstream (along the River Stour) of Development D as they are from the Order limits (approximately 5km downstream of the Order limits, or 275m if the Stonar Cut flood gates are open), as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. At such distance, with due consideration of dilution within the tidal River Stour, the baseline sediment load of such a tidal river, and the measures to protect the water environment that will be implemented (through the CEMP and IMP), the potential for cumulative effects is considered to be not significant. 16.11.44 No morphology changes are anticipated in relation to the construction of Development D. Numerous measures and controls will be in place to prevent any adverse effects on water quality and therefore no cumulative effects are anticipated. Cumulative effects are therefore considered to be not significant. Development E - Richborough Energy Park - Peaking Plant, Richborough power station [F/TH/12/1016, F/TH/12/1015 & F/TH/14/0388] 16.11.45 This development is located adjacent to Development D, i.e. on the northern side of the River Stour and adjacent and co-located within part of the Order limits. This site is also located downstream of the majority of the Order limits, but upstream of a short section of it. Background documents reviewed 16.11.46 Documents reviewed relating to Development E include: Existing and proposed site layout plans305. Decision notice306. Water environment effects of the Committed Development 16.11.47 Conditions were attached to the planning approval relating to the water environment at Development E, including on surface water drainage, CEMP, and an IMP for the operational site. The requirement to satisfy such conditions prior to the commencement of works should ensure no advese effects on the water environment as a result of Development E.
305 Richborough Energy Park, Peaking Plant Facility. Existing Site Plan, Drawing No. RPS001-PA-126, dated 10/12/12. David Lock Associates; Proposed Site Layout, Drawing No. RPS001-PA-118, dated 18/12/12, David Lock Associates. 306 Letter from Thanet District Council to TEP Limited, dated 30 March 2015 (letter reference: F/TH/13/0760).
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Richborough Connection project water environment receptors potentially affected by the development 16.11.48 Similar to the Richborough Connection project, Development E will be located adjacent to the River Stour, and upstream of a number of sensitive areas: Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich bay SAC and Sandwich Bay to Hackling Marshes SSSI, as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. Summary of the water environment effects arising from the Richborough Connection project 16.11.49 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.50 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as aforementioned, the designated sites identified above are located at a similar distance downstream (along the River Stour) of Development E as they are from the Order limits (approximately 5km downstream of the Order limits, or 275m if the Stonar Cut flood gates are open), as indicated in Figures 5.1d and 9.1d within Volume 5, Document 5.3.5 and Document 5.3.9 respectively. At such distance, with due consideration of dilution within the tidal River Stour, the baseline sediment load of such a tidal river, and the measures to protect the water environment that will be implemented (through the CEMP and IMP), the potential for cumulative impacts is considered to be not significant. 16.11.51 No morphology changes are anticipated in relation to the construction of the new peaking plant. Cumulative effects are therefore considered to be not significant.
Pre-application stage projects Development F - Strategic Development Site SP3 Site 2: Sturry and Broad Oak 16.11.52 The River Stour passes through the southern section of the Development F site, which is immediately downstream of the section of the Order limits in the upper River Great Stour valley in Canterbury. The remainder of this site is located on the northern side of the Great Stour valley; there are few other watercourses within the Development F site boundary. This site drains to the watercourse that passes through the centre of the site, which in turn drains to the River Great Stour. The location of this development is shown as Development 2 in Figure 5.1a within Volume 5, Document 5.3.5. Background documents reviewed 16.11.53 Documents reviewed include: The Sturry Broad Oak Masterplan279. Water environment effects of the proposed development
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16.11.54 Any development at the Sturry Broad Oak development site would be subject to a planning application. It is anticipated that the planning and permitting regimes will provide the necessary controls to ensure no significant impacts on the water environment as a result of the development of this site, as has been/will be required of the Richborough Connection project. This is likely to include planning requirments covering sustainable surface water drainage including infiltration, the preparation of an FRA (on the basis that the development site is over 1ha in area) and the preparation of a CEMP to ensure the protection of water sensitive receptors during the construction phase. 16.11.55 The permitting and consenting regime will require that any works within 15m of the River Stour would require Flood Defence Consent from the EA, and any within 8m of IDB watercourses would require Flood Defence/Land Drainage Consent from the IDB. The EA would require a WFD assessment for any in-channel works that they believe could result in deterioration of the morphology of a watercourse. A discharge consent would be required from the EA for any discharges to controlled waters that the EA deem could present a risk to the water quality of the environment. Such controls will ensure that any changes to watercourse morphology and water quality would be of low magnitude and localised. Richborough Connection project water environment receptors potentially affected by the development 16.11.56 The vast majority of the Development F site is located within the catchment of the River Great Stour, with the extreme northern end on the catchment divide of the Sarre Penn valley. The masterplan indicates that the development will be approximately 100m from the River Stour at its nearest point. Stodmarsh Ramsar, SAC, SPA and SSSI is another 1km downstream. Summary of the water environment effects arising from the Richborough Connection project 16.11.57 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.58 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as discussed above, the measures that are likely to be required of the development, such as a CEMP and drainage strategy should ensure that any change would be negligible. Once the lack of direct hydraulic connectivity to the River Stour is taken into account, the distance of the designated site downstream (along the River Stour) and the dilution effects of the River Stour, the potential for cumulative impacts related to sediment laden run-off is considered to be not significant. 16.11.59 With respect to physical modification, the requirement for Flood Defence/Land Drainage Consent and WFD assessment should ensure no adverse effects on the physical characteristics of the channels on-site. On this basis, no cumulative effects on the water environment are anticipated.
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Development F - Sturry Link Road 16.11.60 The proposed route will link Canterbury to Sturry via a new section of road starting immediately to the north or south of the existing Broad Oak level (railway) crossing, passing through part of the Order limits and then splitting to link to both the existing Sturry Road to the south (through the existing Canterbury Sewage Treatment works) and to the north east (through the wider Development F site). The indicative plans indicate that new bridges over both the railway line and the River Great Stour (crossings over both channels of the Stour may be necessary) will be required, both immediately adjacent and downstream of the Order limits. 16.11.61 The other main watercourse that would intersect the new link road would be the watercourse that passes through Den Grove Wood, downstream of the site, which ultimately discharges to the River Stour. Background documents reviewed 16.11.62 Documents reviewed include: The Sturry Broad Oak Masterplan279; and Canterbury’s Proposed Road Improvements – getting the city moving307. Water environment effects of the proposed development 16.11.63 The Sturry Link Road would be subject to a planning application. It is anticipated that the planning and permitting regimes will provide the necessary controls to ensure no significant impacts on the water environment as a result of the development of this site, as has been/will be required of the Richborough Connection project. This is likely to include planning requirments covering sustainable surface water drainage including infiltration, the preparation of an FRA (on the basis that the development site is over 1ha in area) and the preparation of a CEMP to ensure the protection of water sensitive receptors during the construction phase. 16.11.64 Flood Defence Consent will be required from the EA for any works within 15m of the River Stour, including the proposed bridge. This would ensure that impacts on the river would be minimised. It is likely that the EA would require a clear span bridge design, minimising the potential for any significant impacts to occur. The section of the link road to the south of the railway line will be with the IDB District; any works within 8m of IDB watercourses would require Flood Defence/Land Drainage Consent from the IDB. In-channel works on other watercourses will require consent from KCC. 16.11.65 The EA would also require a WFD assessment for any in-channel works that they believe could result in deterioration of the characteristic (including morphology) of a watercourse. A discharge consent would be required from the EA for any discharges to controlled waters that the EA deem could present a risk to the water quality of the environment. Such controls will ensure that any changes to watercourse morphology and water quality would be of low magnitude and localised.
307 Canterbury City Council. Canterbury’s Proposed Road Improvements – getting the city moving. 2014. http://media.kentonline.co.uk/filerepository/2014/3/27/14032751430-Canterbury%20new%20roads-01.pdf
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Richborough Connection project water environment receptors potentially affected by the development 16.11.66 The Sturry Link Road is located within the catchment of the River Great Stour, and will cross the Stour at its nearest point. Stodmarsh Ramsar, SAC, SPA and SSSI is another 1.5km downstream of the proposed crossing point. Summary of the water environment effects arising from the Richborough Connection project 16.11.67 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.68 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as discussed above, the measures that are likely to be required of the development, such as a CEMP and drainage strategy should ensure that any change would be negligible. Considering the dilution of any change in sediment load in the River Great Stour, and the distance of the designated site downstream, the potential for cumulative impacts related to sediment laden run-off is considered to be not significant. 16.11.69 With respect to physical modification, the requirement for Flood Defence/Land Drainage Consent and WFD assessment should ensure no adverse effects on the physical characteristics of the channels on-site. On this basis, no cumulative effects on the water environment are anticipated. Development G - Strategic Development Site SP3 Site 8: Land North of Hersden Background documents reviewed 16.11.70 Documents reviewed include: Strategic Development site masterplan for North Hersden275. Water environment effects of the proposed development 16.11.71 This development site is located just over the catchment divide of the River Great Stour and the Sarre Penn, being located in the Sarre Penn catchment, at the upper end of the valley. Two small watercourses pass through this site, which then pass through the order limits before ultimately discharging to the Sarre Penn. The development site is located outside of the IDB District, and according to the Development G masterplan, over 200m from the nearest Main River, the Sarre Penn. 16.11.72 Any development at the North Hersden development site would be subject to a planning application. It is anticipated that the planning and permitting regimes will provide the necessary controls to ensure no significant impacts on the water environment as a result of the development of this site, as has been/will be required of the Richborough Connection project. This is likely to include planning requirments covering sustainable surface water drainage including infiltration, the preparation of an FRA (on the basis that the development site is over 1ha in area) and the
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preparation of a CEMP to ensure the protection of water sensitive receptors during the construction phase. 16.11.73 Consent will be required from KCC for any in-channel works to any ordinary watercourses on site, but the absence of any significant (Main Rivers or IDB) watercourses on site means that there will be little scope for development of this site to have an adverse impact on the watercourse morphology. A discharge consent would be required from the EA for any discharges to controlled waters that the EA deem could present a risk to the water quality of the environment. Such controls will ensure that any changes to watercourse morphology and water quality would be of low magnitude and localised. Richborough Connection project water environment receptors potentially affected by the development 16.11.74 Development G is located just over the catchment divide of the Sarre Penn, to which it will drain. Summary of the water environment effects arising from the Richborough Connection project 16.11.75 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.76 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as discussed above, the measures that are likely to be required of the development, such as a CEMP and drainage strategy should ensure that any change would be negligible. Once the lack of direct hydraulic connectivity to the River Stour is taken into account, and the lack of any designated site in the vicinity downstream, the potential for cumulative effects related to sediment laden run-off is considered to be not significant. 16.11.77 With respect to physical modification, the lack of any Main Rivers and IDB watercourses on the site, together with the requirement to obtain consent from KCC for any in-channel works on ordinary watercourses should ensure that any adverse effects on the physical characteristics of the channels on site would be low to negligible. On this basis, no cumulative effects on the water environment are anticipated. Development H - Communications Mast, Ramsgate Road 16.11.78 According to the Request for a Screening Opinion the site compound would be located on previously developed land to the north of the development site and materials craned across. It also indicates that access to Development H for construction would likely be gained via the existing bridge at the municipal waste site, which is one of the crossing points to be used for the Richborough Connection project, but that final details regarding access would be confirmed within the Construction Management Plan.
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Background documents reviewed 16.11.79 Documents reviewed include: Request for a Screening Opinion276; Richborough Energy Park Site Location Plan308; and Richborough Energy Park Proposed Site Plan309. Water environment effects of the proposed development 16.11.80 Potential effects on the water environment would largely be limited to construction related effects. The development would be subject to a planning application. It is anticipated that the planning and permitting regimes will provide the necessary controls to ensure no significant effects on the water environment as a result of the development of this site, as has been/will be required of the Richborough Connection project. 16.11.81 The Request for a Screening Opinion suggests that no EIA is required in relation to pollution, but that it is expected that the Council will seek a Construction Management Plan to be approved. It goes on to say that the proposals would not affect the absorption capacity of the natural environment and that the site could continue to be used as a natural floodplain and by the fauna and flora in its natural state; an Ecological Assessment and Flood Risk Assessment will be provided in support of the application to confirm this position. 16.11.82 Flood Defence Consent will be required from the EA for any works within 15m of the River Stour, including any construction access bridge if the crossing at the municipal waste site could not be utilised. This would ensure that impacts on the river would be minimised. It is likely that the EA would require a clear span design, minimising the potential for any significant impacts to occur. Any works within 8m of the numerous IDB watercourses on-site would require Flood Defence/Land Drainage Consent from the IDB. The EA would also require a WFD assessment for any in- channel works that they believe could result in deterioration of the characteristic (including morphology) of a watercourse. A discharge consent would be required from the EA for any discharges to controlled waters that the EA deem could present a risk to the water quality of the environment. Such controls will ensure that any changes to watercourse morphology and water quality would be of low magnitude and localised. Richborough Connection project water environment receptors potentially affected by the development 16.11.83 As with Development B, the site is located adjacent to the River Stour, at the Richborough power station end of the Richborough Connection project. As such there are a number of sensitive areas located downstream of the site, at a similar distance downstream as the order limits, namely: Thanet Coast and Sandwich Bay SPA, Thanet Coast and Sandwich Bay Ramsar Site, Sandwich Bay SAC and Sandwich Bay to Hackling Marshes SSSI.
308 Site Location Plan, drawing number VG-PR2-00xx-Master_B 320M 001, Issue B, dated 24/01/2015, Vigilent Global, Network Vista Infra Projects. 309 Proposed Site Plan. drawing number VG-PR2-00xx-Master_B 320M 002 Issue B, dated 24/01/2015, Vigilent Global, Network Vista Infra Projects.
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Summary of the water environment effects arising from the Richborough Connection project 16.11.84 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.85 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as aforementioned, the designated sites identified above are located at a similar distance downstream (along the River Stour) of Development H as they are from the Order limits. At such distance, with due consideration of dilution within the tidal River Stour, and the baseline sediment load of such a tidal river, the potential for cumulative effects is considered to be not significant. 16.11.86 With respect to physical modification, it appears that no such modification to channels will be proposed, and therefore no cumulative effects are anticipated. The requirement for Flood Defence/Land Drainage Consent from the EA and IDB should ensure no adverse effects on the physical characteristics of the channels on site. On this basis, no cumulative effects are anticipated.
National Grid Permitted Development Development I - Canterbury North 400kV substation 16.11.87 The works for Development I would include demolition of existing buildings, new fencing, replacement plant and machinery building within the operaitonal compound and new internal access roads. In addition, the construction of two new line entry gantries within the operational site boundary to the north of the site compound will be required. The location of these gantries coincides with an existing pond, which is one of five around the 400kV substation that supports a small to medium metapopulation of great crested newts. Mitigation for these has been set out in a planning statement for the proposed mitigation ponds (discussed further below). 16.11.88 Site works are anticipated to occur between early 2017 and late 2018, which would coincide with the timing of the construction works for the Richborough Connection project at the upstream end of the River (Great) Stour. Background documents reviewed 16.11.89 Documents reviewed include: Existing and proposed site layout plans (3 x built development options)310; Planning Statement: Proposed Mitigation Ponds278; and Canterbury North 400kV Substation – Pond Specification291.
310 Richborough Connection Project, Canterbury 400kV Substation, New Pond Planning Application, Site Location Plan, drawing number 35117-Gos60.dwg squij; Canterbury 400kV Substation, New Shunt Reactor Site Layout – Option 1 (drawing no. MMD-336658-E-SK-CA-XX-2004_P1), Option 2 (drawing no. MMD-336658-E-SK-CA-XX-2005_P1), and Option 3 (drawing no. MMD-336658-E-SK-CA-XX-2006_P1).
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Water environment effects of the proposed development 16.11.90 From the layout plans for Development I it is identified that no works are proposed within consenting distance of the River Stour (within 8m of banktop or toe of any flood defence). There is however the potential for temporary effects from other activities associated with the construction phase. As stated in the Planning Statement and the Pond Specification report, appropriate site management techniques will be employed to ensure that such works will not give rise to significant issues. The legal requirement to avoid pollution of the environment (to comply with UK law), by following the guidance set out in the EA’s PPGs, would ensure that works are undertaken in such a manner that impacts to the Water Environment should be not significant. Furthermore, considering the scale of the River Great Stour at this location, significant dilution of any pollution would be expected to occur to further reduce the possibility of any significant impact. 16.11.91 The planning statement concluded that flood risk would not be increased elsewhere because material excavated when creating the new ponds will be used to fill the pond to be lost (once the great crested newt population has been translocated). Richborough Connection project water environment receptors potentially affected by the development 16.11.92 The red line boundary for the site runs along the channel edge of the River Great Stour, but according to the proposal plans, development works will be almost entirely contained within the existing built development footprint of the existing 400kV substation, or the immediate vicinity. On this basis there will be some buffer between the development and the River Great Stour. Stodmarsh Ramsar, SAC, SPA and SSSI is approximately 2km downstream of the Canterbury North 400/132kV substation site. Summary of the water environment effects arising from the Richborough Connection project 16.11.93 No significant effects on the water environment have been identified for the Richborough Connection project. Potential changes were assessed of negligible magnitude, with the exception of an increase in sediment laden run-off on the aquatic environment and surface water resource receptors, and physical modification to the channel(s) affecting WFD hydro-geomorphological assessment. Potential Cumulative Effects 16.11.94 As indicated above, only effects related to sediment laden run-off and physical modification of the channels could combine to cause a cumulative effect. With respect to sediment laden run-off, as discussed above, National Grid would implement measures to ensure that any change would be negligible. Once the lack of direct hydraulic connectivity to the River Stour is taken into account, the distance of the designated site downstream (along the River Stour) and the dilution effects of the River Stour, the potential for cumulative effects related to sediment laden run-off is considered to be not significant. 16.11.95 With respect to physical modification, no works within 8m of the River Great Stour (or banktop of any defence) is anticipated, so no adverse effects on the physical characteristics of the channels on-site would occur. On this basis, no cumulative effects on the water environment are anticipated.
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Conclusions 16.11.96 In conclusion no signiciant cumulative effects on the water environment are expected to occur.
16.12 Assessment of Cumulative Effects: Geology, Soils and Agriculture 16.12.1 The potential cumulative effects have been considered by receptor type. This approach has been adopted as cumulative effects on geology, soils and agriculture receptors have the potential to occur collectively (i.e. combined effect of multiple developments) in relation to all receptor types. Assessment by receptor type (as opposed to by each cumulative development sequentially) aids in the assessment of these combined effects.
Minerals receptors 16.12.2 Developments which could give rise to an adverse cumulative effect on minerals receptors include the following: Pre-application stage development: Development F (Sturry and Broad Oak strategic development, including Sturry link road); and Development G (Land North of Hersden strategic development). Reference to key documents 16.12.3 Information regarding the Development F has been obtained from the potential developer’s website279 and the CCC draft local plan. 16.12.4 Information regarding Development G has been obtained by reference to a draft masterplan prepared by Barton Wilmore311 (dated June 2015), which shows the extent of the proposed development and an indicative layout. Assessment of potential Cumulative Effects (Construction, Operational and Decommissioning Phases) Richborough Connection project 16.12.5 The minerals sterilisation effects associated with the Richborough Connection project at the construction, operational and decommissioning phases have been assessed as negligible, on the basis that it will not sterilise mineral deposits of economic importance or deposits that have a significant potential for future extraction. Development F 16.12.6 Develpoment F overlies small areas of safeguarded alluvium and Head (together with areas devoid of superficial deposits), which are the same mineral types as the safeguarded minerals within the Order limits. The extent of sterilisation associated with this development is minimal in the context of the overall extent of the Head and alluvium Mineral Safeguarding Area (MSA) in the area. Development G 16.12.7 This site is largely free from superficial deposits, aside from small areas of safeguarded Head. The extent of sterilisation associated with this development is
311 Barton Willmore. Hersden, Canterbury: Draft Masterplan. 2015.
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minimal in the context of the overall extent of the MSA in the area. Summary 16.12.8 The additional minimal minerals sterilisation associated with Developments F and G does not add sufficiently to the negligible minerals sterilisation effects of the Richborough Connection project to introduce a potentially significant minerals sterilisation effect. The potential cumulative minerals sterilisation effect is assessed as negligible and not significant.
Ground stability receptors (Buildings, Structures and Infrastructure) 16.12.9 Developments which could give rise to an adverse cumulative effect on ground stability receptors include the following: Committed developments: Development B (Thanet Solar Farm); Development D (New 400kV substation and converter station at Richborough); and Development E (Richborough Energy Park – Peaking Plant). Pre-application stage developments: Development F and Development G. Reference to key documents 16.12.10 Information regarding Development B has been obtained from planning documentation submitted with planning application reference DOV/13/00794, specifically the Planning Design & Access Statement265 and indicative design drawings prepared by Ardenham Energy. 16.12.11 Information regarding Development D has been obtained from the Nemo Link ES271. 16.12.12 Information regarding Development E has been obtained from the Richborough Peaking Plant Facility and Internal Road Network ES273. Assessment of Potential Cumulative Effects (Construction and Operational Phases) Richborough Connection project 16.12.13 The potential ground instability effects on proposed new infrastructure (e.g. pylons) and nearby buildings and bridges have been assessed as negligible. The proposed development does not have the potential to cause ground instability effects that could damage or destabilise ground that is required by the committed developments listed above. Should any of the cumulative developments be completed contemporaneously with, or in advance of, the proposed development, then there is the potential for piling associated with the proposed development to cause ground vibrations that could affect the other committed developments. This will be prevented by the adoption of appropriate foundation installation methods (e.g. augered piles) when working within defined ‘safety buffers’ of existing or ongoing development. This would also prevent the potential for the proposed development to contribute towards cumulative ground vibration damage to existing buildings and structures (assuming that the other committed developments adopt a similar approach, in accordance with the requirements of BS5228:2009). Development B 16.12.14 This development involves construction work in close proximity of proposed pylons PC58 and PC59, including the construction of a substation and an underground cable. Desk study research does not indicate the presence of any specific ground conditions in this location that would be expected to give rise to abnormal localised
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ground instability risks (e.g. Made Ground). It is not considered that the construction of the solar farm infrastructure in this location could lead to effects that could compromise the stability of the pylons, assuming reasonable construction methods (e.g. use of appropriate piling techniques, no creation of steep slopes etc.). Similarly, the proposed methodology for the proposed development (i.e. use of augered piles where necessary) will prevent any cumulative effect on the solar farm development. Developments D and E 16.12.15 These developments involve construction work in close proximity of the proposed Richborough compound site. The compound site will be situated on an existing hardstanding platform and will consist of lightweight compounds, so will not be prone to either causing or being affected by ground instability / vibration effects. Therefore, there is no potential for cumulative ground instability effects. Development F 16.12.16 This development includes the construction of residential houses in close proximity of the proposed position of proposed pylon PC4. Desk study research does not indicate the presence of any specific ground conditions in this location that would be expected to give rise to abnormal localised ground instability risks (e.g. Made Ground). It is not considered that the construction of properties in this location could lead to effects that could compromise the stability of the pylon, assuming reasonable construction methods (i.e. use of appropriate piling techniques, no creation of unstable slopes etc.). Similarly, the construction of the pylon would not have the potential to affect the stability of the residential development, as the proposed construction methodologies (e.g. use of augered piles where needed) will prevent this, as discussed above. Development G 16.12.17 This development includes proposed residential development within the recorded footprint of Hersden landfill. This landfill was licensed to accept inert and commercial waste and is currently occupied by flat lying agricultural land. The only activities associated with the proposed development within this landfill area are the removal of pylon PX23. Whilst the construction of properties in this area will need to consider ground instability issues, the negligible ground instability effects associated with the removal of pylon PX23 would not be expected to contribute towards any cumulative ground instability. Summary 16.12.18 Potential cumulative ground instability effects fall into three categories (i) cumulative effects on new infrastructure associated with the proposed development, (ii) cumulative effects on other proposed developments, and (iii) cumulative effects on pre-existing buildings and structures. 16.12.19 The potential cumulative effects on proposed project infrastructure are assessed as negligible and not significant. The Richborough Connection project will be constructed in a manner that secures its stability, and it is not anticipated that construction works associated with the other committed developments have the potential to meaningfully affect the stability of the new infrastructure, provided that these adopt reasonable construction good practice (e.g. use of appropriate piling techniques, no creation of unstable slopes etc.). 16.12.20 The potential cumulative effects on other proposed developments are assessed as negligible and not significant. The Richborough Connection project does not have
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the potential to cause sufficient ground instability or ground vibration (allowing for the embedded environmental measures in Chapter 14 of this document) to contribute to cumulative ground instability effects at any of the other proposed developments considered. 16.12.21 The potential cumulative effects on pre-existing buildings and structures from ground vibration have been assessed as negligible and not significant. This effect is only possible should contemporaneous proximate piling works be undertake, which in itself is unlikely. However, even in this situation, the incorporated environmental measures in Chaper 14 of this document would prevent the Richborough Connection project from significantly contributing to any cumulative ground instability effects.
Land contamination receptors (Construction workers and adjacent site users) 16.12.22 Developments considered in relation to potential effects on land contamination receptors include: Committed development: Development D and Development E; Pre-application stage development: Development G; and National Grid permitted development: Development I. Reference to key documents 16.12.23 The key reference documents used to consider cumulative effects are the same as those referred to earlier in this section. Additionally, the Planning Statement for Canterbury North 400kV Substation278 has been considered. Assessment of potential cumulative effects (Construction Phase) Richborough Connection project 16.12.24 The proposed development generally involves limited ground disturbance, primarily on land whose only historical use is agricultural. However, localised areas are present where disturbance of Made Ground is anticipated. Allowing for the incorporated good practice environmental measures (Chapter 14 of this document), which includes dust suppression and control to prevent health risks to adjacent site users, the potential for adverse human health effects from chemical contamination within dust generated by the proposed development has been assessed as negligible. Development D 16.12.25 These developments have the potential to intersect soils affected by contamination associated with the former Richborough power station. There is the potential for effects on construction workers involved in the Richborough Connection project, should any dust generated contain additional contaminants that are not considered within the occupational health & safety measures (i.e. PPE) for that development. Should the developments be undertaken contemporaneously, then occupational health & safety measures for construction workers involved in the Richborough Connection Project will have regard to the contamination status of dust from the adjacent development works, to ensure that there is no cumulative health effect. 16.12.26 Similarly to above, it can be assumed that the other proposed developments will be undertaken in accordance with the requirements of contaminated land legislation,
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preventing a significant risk to adjacent site users. It is therefore not anticipated that there will be a significant cumulative health effect on adjacent site users. Development G 16.12.27 This development potentially involves the exposure of soils at Hersden Tip landfill. If undertaken contemporaneously with the removal of pylon PX23 (also located within this landfill), there is the potential for cumulative health effects from any contamination within dust generated (on both construction workers and adjacent land users). 16.12.28 The potential effects on construction workers would be effectively mitigated by the embedded environmental measures described in Chapter 14 of this document, as PPE appropriate for the dismantling of pylon PX23 would also be suitable for any dust exposure associated with other works involving the exposure of landfill materials (i.e. Development G). 16.12.29 It can be assumed that the development of the committed development site will be undertaken in accordance with current contaminated land legislation and good practice (as per the Richborough Connection project), which will include measures to prevent a significant risk to the health of adjacent site users. As both developments will be undertaken in accordance with this legislation, it is not considered that there will be any significant human health effects on adjacent site users. Development I 16.12.30 Development I involves ground disturbance in some instances. This may lead to the exposure of soils affected by contamination and the generation of dust. However, it is considered that this work can be adequately managed by routine environmental and occupational health and safety measures to ensure that it does not present a risk to adjacent site users (as above, this would be required for legislative compliance), preventing the potential for any cumulative effects with the Richborough Connection project. This is corroborated by preliminary ground investigation data from within the 400kV substation site (i.e. trial pit log from location DCP01 IP, as discussed in Appendix 14A within Volume 5, Document 5.4.14A), which indicates the presence of 0.8m of Made Ground that would not be expected to present a significant source of contaminated soil dust, provided that appropriate construction phase environmental controls were implemented. Summary 16.12.31 The potential for cumulative human health effects on construction workers from contamination in construction dust will be effectively mitigated by the use of appropriate PPE (embedded measure; see Chapter 14 of this document). 16.12.32 Due to the negligible effect of the proposed development on adjacent land users, it is not considered that the addition of any dust inputs from the proposed development to those from other developments that are compliant with legislation will lead to a potentially significant effect. 16.12.33 Therefore, the potential cumulative human health effects from chemical contamination in construction dust, on both construction workers and adjacent site users, have been assessed as negligible and not significant.
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Ground gas receptors (Human health / buildings) 16.12.34 Developments considered in relation to potential effects on ground gas receptors include: Committed development: Development B, Development D and Development E; Pre-application stage development: Development G; and National Grid permitted development: Development I. Reference to Key Documents 16.12.35 The key reference documents used to consider cumulative effects are the same as those referenced previously in this section. Assessment of potential Cumulative Effects Richborough Connection project 16.12.36 The proposed development generally involves limited ground disturbance, primarily on land whose only historical use is agricultural. However, localised areas are present where disturbance of Made Ground is anticipated. Allowing for the embedded environmental measures (Chapter 14 of this document), the potential for adverse human health effects and / or damage to buildings as a result of ground gas ingress (either into new buildings constructed as part of the proposed development or existing buildings within / near the Order limits) has been assessed as negligible. Development B 16.12.37 This development involves excavation / disturbance of natural soils that may contain an elevated organic content. Similar materials will also be disturbed by the Richborough Connection project, predominantly in the locations of proposed new pylons. There is no nearby built development associated with the Richborough Connection project that is at potential risk from ground gas (the proposed Richborough Compound site is separated from this area by a river and will be built off hard surfacing, preventing a potential source-pathway-receptor linkage). The primary receptor for any cumulative ground gas effect is likely to be Development B, which includes the construction of new buildings in which gas may accumulate. It is assumed that these buildings will be constructed with gas protection measures that are appropriate for the gas risk associated with the solar farm development. The embedded environmental measures (e.g.piling risk assessments and correct pile design) associated with the Richborough Connection project will prevent significant gas migration to the solar farm site, such that additional gas protection measures at that site are would not be anticipated to be necessary. Therefore, the potential cumulative effect is considered to be insignificant. Developments D and E 16.12.38 These developments have the potential to intersect Made Ground associated with the former Richborough power station. Assuming adequate environmental controls (as above), there is not considered to be a potentially significant cumulative effect in relation to ground gas ingress into the proposed compound buildings associated with the Richborough Connection project (which will also be located on the 400kV substation site). This is because the Richborough Connection project does not
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present a gas risk to this compound, and it is reasonable to assume that Developments D and E would not be constructed in a manner that created a surface gas risk to construction compounds (as similar buildings will be required in relation to those developments). 16.12.39 The off-site migration of ground gas from this development can be assumed to be subject to environmental controls to ensure no effects on off-site receptors, such that there is no potential for a significant cumulative effect on off-site receptors. Development G 16.12.40 This development potentially involves the exposure of soils at Hersden Tip landfill. Made Ground at this site may present a gas generation source, although the site was not licensed to accept waste with a high biodegradable content (e.g. domestic waste). If undertaken contemporaneously with the removal of pylon PX23 (also located within this landfill), there is the potential for the combined activities to increase gas generation from the landfill deposits. The primary receptor for this would be new buildings at the Development G site. To meet legislative requirements, these would need to be constructed in a manner that provides protection against ground gas from the landfill deposits. It is not anticipated that the additional disturbance to the ground gas regime associated with dismantling pylon PX23 would lead to sufficient gas migration to cause a cumulative gas risk that would necessitate additional protection, particularly given that the landfill was not licensed to accept domestic waste. Development I 16.12.41 This development is likely to involve the disturbance of Made Ground deposits, as a result of construction and demolition works, although it is noted that the limited available ground investigation data from this site does not indicate the likely presence of a gas source (i.e. trial pit log from location DCP01 IP, as discussed in Appendix 14A within Volume 5, Document 5.4.14A). To meet regulatory requirements, the 400kV substation development will need to be undertaken with any environmental controls necessary to prevent the risk of gas migration to both new buildings and existing nearby buildings. Given the negligible effect identified in relation to the Richborough Connection project, it is considered that there is no potential for a cumulative ground gas effect that would increase the risk to Development I or nearby buildings and necessitate additional controls. Summary 16.12.42 There are three potential mechanisms for cumulative effects in relation to ground gas: (i) cumulative effects on the Richborough Connection project, (ii) cumulative effects on other proposed developments, and (iii) cumulative effects on existing buildings. The cumulative assessment in relation to each of these three points is summarised sequentially in the following three paragraphs. 16.12.43 The only built development associated with the Richborough Connection project is the temporary compound sites at Westbere and Richborough. The only proposed developments in sufficient proximity to these to require consideration are Development B, Development D and Development E. There is not considered to be a viable source-pathway-receptor linkage in relation to cumulative effects from Development B. It is reasonable to assume that Developments D and E will be constructed in a manner that does not present a surface gas risk, preventing significant cumulative effects.
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16.12.44 The Richborough Connection project is not anticipated to cause significant ground gas mobilisation. Assuming that other developments are compliant with legislation and are constructed with appropriate gas protection for the ground conditions, it is considered that there will be no significant cumulative effects on these developments (i.e. the cumulative effect would not require additional gas protection at these sites, beyond that required if the sites were considered in isolation). 16.12.45 Similarly, the prevention of significant off-site gas migration from the Richborough Connection project, together with the assumption that this will be achieved at the other proposed developments considered, would be expected to prevent cumulative gas effects on existing buildings in the area. Theoretically, circumstances exist where multiple developments that each did not present a significant gas migration risk could result in a cumulative significant effect. However, this would typically require disturbance of multiple sources with high gas generation potential (e.g. domestic waste landfills) either in close proximity of, or with a preferential migration pathway to, built development. This is not the case in relation to the proposed developments considered. 16.12.46 Therefore, the potential cumulative ground gas effects have been assessed as negligible and not significant.
Soils and agriculture receptors (Soil resources and agricultural land quality) 16.12.47 Developments considered in relation to potential effects on ground gas receptors include: Committed development: Development B; and Pre-application stage developments: Development F and Development G. Reference to key documents 16.12.48 The key reference documents used to consider cumulative effects are the same as those referenced previously in this section. Assessment of potential Cumulative Effects Richborough Connection project 16.12.49 The permanent loss of BMV agricultural land associated with the proposed development, comprising land within the footprint of pylons, which area located on agricultural land. The total permanent loss of agricultural land amounts to 1.1ha, of which 0.6ha is BMV land. This represents a very small area of agricultural land permanently lost within the Order limits and the loss takes place within the footprint of each pylon spaced over a much larger area than the other developments. Therefore, at a local level, the proposed development would not significantly contribute to the cumulative effect. Development B 16.12.50 The development is located on land to the north of the Richborough 400kV substation. The development would result in the temporary loss of 15ha of land to agricultural use for the duration of the consent (approximately 25 years). The soil resources within the footprint of the solar farm would remain largely undisturbed during the developed and would normally support permanent pasture for duration of the development. The predicted impact of Development B on agricultural land and soil resources are minor, temporary and not significant.
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16.12.51 The proposed 400kV overhead line is to be located on land to the south of the solar farm. Two pylons (PC58 and PC59) will be constructed on agricultural land to the west of the Richborough 400kV substation, and east of rail line that delineates the western boundary of the solar farm. The permanent loss of BMV land from these two pylons would amount to <0.1ha. If the whole Richborough Connection project is considered it would add a further 0.6ha of permanent BMV loss. The local cumulative effect of the solar farm and 400kV overhead line on agricultural land would therefore be <20ha, which has been assessed as minor and not significant. Development F 16.12.52 The total area of agricultural land lost as a consequence of this development would be in the order of 48ha, of which >20ha would be BMV land (approximately 32.7ha), therefore a significant effect is predicted, without mitigation. In the case of development, where >20ha of BMV agricultural land would be permanently lost, TIN049 requires that Natural England is consulted, as the statutory consultee. Furthermore, the NPPF directs in Para 112 that the economic importance of BMV agricultural land is taken into account and where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. The potential loss of soil resources can be mitigated through the reuse, where practical, of the soil resource for areas of soft landscaping and for gardens, as defined in the masterplan. In addition, it is anticipated that soil resources would also be used off- site in other construction projects, where soil volumes are limited and this mitigation measure would be defined in any CEMP to accompany a future planning application for the development. However, for both measures, although the loss of the soil resource can be mitigated, it does not mitigate the loss of BMV agricultural land because the soil resource is not used for restoration of agricultural land. 16.12.53 The strategic housing allocation is in an area of agricultural land that is close to, but not adjacent to the Canterbury North 400/132kV Substation site. To the west of Development F, there are two proposed pylons (PC4 and PC5), both of which are located in a field of permanent pasture, used for horse grazing effectively of no agricultural use. The remaining construction activity required for the Richborough Connection project are to the north and west of Development F (also north of the existing PX route overhead line), but they are over 1km away and separated by the Broad Oak and Sturry villages. Therefore, because there is no loss of agricultural land for new pylons located in the vicinity of Development F, no local cumulative effects on BMV agricultural land have been identified here. 16.12.54 If the whole Richborough Connection project is considered it would add approximately 0.6ha to the 32.7ha of permanent BMV land loss due to the Development F, which is a significant effect, although this would be the case without the Richborough Connection project. Furthermore, after deconstruction of pylons in the PX route a minor positive effect is predicted due to the increase in agricultural land (approximately 0.3ha of BMV land), associated with restoration of the footprint beneath existing pylons. Development G 16.12.55 Development G has been identified as a strategic housing development approximately 4km to the east of Canterbury and north of Hersden. The total area of agricultural land lost as a consequence of this development would be in the order of 70ha, of which, on the basis of secondary data would include >20ha (approximately
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43.2ha) of BMV land. In the case of permanent development, where >20ha of BMV agricultural land would be permanently lost, TIN049 requires that NE is consulted, as the statutory consultee. Furthermore, the NPPF directs in Para 112 that the economic importance of BMV agricultural land is taken into account and where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. The potential loss of soil resources can be mitigated through the reuse, where practical, of the soil resource for area of soft landscaping and for gardens, as defined in the masterplan. In addition, it is anticipated that soil resources would also be used offsite in other construction projects, where soil volumes are limited and this mitigation measure would be defined in any CEMP to accompany a future planning application for the development. However, for both measures, although the loss of the soil resource can be mitigated, it does not mitigate the loss of BMV agricultural land because the soil resource is not used for restoration of agricultural land. 16.12.56 The existing PX route is located on the northern boundary of Development G; pylon footprints within this corridor will be restored to agricultural land, resulting in a minor positive effect due to the increase in agricultural land within the footprint of the existing PX route pylons. The proposed 400kV overhead line will be constructed on agricultural land to the north of the PX route, with three pylons (PC16, PC 17 and PC18) to be located on BMV agricultural land; the remaining pylons in the vicinity of Development G will be constructed on Grade 4 agricultural land; therefore no local cumulative effects are predicted here. 16.12.57 If the whole Richborough Connection project is considered it would add approximately 0.6ha to the 43.2ha of permanent BMV land loss due to Development G, which is a significant effect, although this would be the case without the Richborough Connection project. 16.12.58 The environmental measures identified for soils potentially disturbed for the construction and deconstruction of pylons in this section of the Richborough Connection project route would result in the restoration of all temporarily disturbed areas to an equivalent agricultural use following the construction period. Therefore, no cumulative effect on soil resources is predicted. Summary 16.12.59 In summary, if the entire Richborough Connection project is considered together with the above developments it would add approximately 0.6ha to 75.9ha of the permanent BMV loss. If the gain of approximately 0.3ha of BMV land from the decommissioning of the PX route is taken into account the Richborough Connection project would only increase the permanent loss of BMV land by 0.3ha or 0.4%. The cumulative permanent loss would exceed 20ha of BMV land, which is a significant effect, although this would be the case without the Richborough Connection project.
16.13 Assessment of Effects: Socio-economic and recreation 16.13.1 The cumulative assessment considers the potential cumulative effects which may result from the combined effects of the Richborough Connection project and other major development proposals scoped-in, as identified in Table 16.2 of this Chapter. 16.13.2 The assessment considers potential cumulative effects on broad receptor groups where it is considered likely that group will experience such effects. Therefore, not
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all socio-economic and recreation receptor groups identified in Chapter 15 of this document are considered as part of the cumulative assessment. Cumulative amenity effects are not considered and reference should be made to the cumulative assessments associated with landscape and visual and noise effects.
16.13.3 Cumulatively, the proposed development and other major development proposals have the potential to effect the local and regional economies. Such effects would be felt through direct and indirect employment on projects during construction and operation, as well as indirect effects associated with increased spend from non-local workers in relation to day-to-day subsistence and accommodation. The exact cumulative effect is difficult to assess without detailed knowledge of construction timescales and staffing requirements. However, based on the programme information available in relation to the above projects and without employment generation figures the assessment concludes that collectively projects would lead to a cumulative effect ranging from minor to moderate beneficial on the labour market with the extent of the benefit depending on exact employment numbers. The developments will offer a range of local employment and training opportunities and bring associated spend within the local economy.
16.13.4 Given the prominence of accommodation within the local area and the wider region, it is considered that the demands of the proposed development workforce can be satisfied within the existing local accommodation provision without displacing visitors and other business users. On the basis of the information available, it is considered that wider demand for accommodation from the other projects would lead to a negligible cumulative effect on the availability of accommodation within the local and regional economy.
16.14 Conclusions 16.14.1 This chapter has considered the potential inter-project cumulative effects arising from the Richborough Connection project and the other major developments identified in Table 16.2. 16.14.2 Table 16.4 provides a summary of likely significant cumulative effects as concluded in Sections 16.4 - 16.13.
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Table 16.4 Summary of significant inter-project cumulative effects
Development Receptor Magnitude Comments of effect
Landscape
Development D Landscape Moderate This will only occur where effects of the character: adverse proposed 400kV substation and Former converter station overlap with the Wantsum effects of the overhead line Channel LCA
Development H Landscape Moderate In the long term the magnitude of effect character: Ash adverse would reduce to minor adverse and Level LCA therefore not significant
Combined effects: Landscape Moderate With reference to paragraph 7.28 of character: adverse the Guidelines for Landscape and - Development A Visual Impact Assessment 3rd Edition, - Former the proposed development would not - Development B Wantsum comprise a ‘tipping point’ which would - Development C Channel LCA give rise to greater significance of - Development D - The adverse effects on the landscape Sandwich cumulatively with other projects. The - Development E Corridor LCA assessment establishes that the - Development H - The Ash cumulative changes do not exceed the Level LCA tipping point that would fundamentally - The change the landscape character and Richborough exceed the limits of acceptable Castle LCA development defined by the development plans.
Visual
Development B Saxon Shore Moderate Significant effects would only be Way adverse experienced on a short section of this PRoW
Development D Saxon Shore Moderate Significant effects would only be Way adverse experienced on a short section of this PRoW. These findings are consistent with the findings of the cumulative assessment within the ES for Development D
Development E Saxon Shore Moderate Significant effects would only be Way adverse experienced on a short section of this PRoW
Development F - PRoW Moderate Cumulative visual effects would be alongside the adverse minimised by the presence of open railway space and tree planting between the receptors and the proposed residential development area. This would filter
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Development Receptor Magnitude Comments of effect
- Southern end and potentially screen some views of of Shalloak Development F. Road - Residential properties with open views of the north Stour Valley slopes
Residential Moderate The proposed 400kV overhead line receptors and a adverse would be barely perceptible in the PRoW on the view, and the PX route would have south side of been removed from the view. However Broad Oak the cumulative effects would be more substantial than those arising from the Richborough Connection project alone.
Development G - Properties on Moderate The proposed 400kV overhead line the edge of adverse and the strategic development site Hoath would alter a moderate proportion of - Properties at near and middle distance views and a Chislet low proportion of distant views. The Business cumulative effects would be more Park substantial than those arising from the - Marley Lane Richborough Connection project alone - PRoW and would give rise to a higher level of crossing the significance valley
Properties at Moderate Cumulative visual effects would be Tile Lodge and adverse minimised by the presence of open on Bredlands space and tree planting between the Lane receptors and the proposed residential development area. This would filter and potentially screen some views of Development G.
Residents and Moderate The proposed 400kV overhead line workers at adverse would be seen in near views to the Chislet north and north west and Development Business Park G in middle distance views to the south and south west. The draft masterplan for Development G shows a large area of recreational open space with trees and retained hedgerows at the north east corner of the site in proximity to these receptors. These factors would help to mitigate visual effects.
Development H Saxon Shore Moderate The proposed 400kV overhead line Way adverse and Development H would be seen in
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Development Receptor Magnitude Comments of effect
the same view by a number of public and private visual receptors. Development H is in close proximity to the pylons at the eastern end of the route. The two developments would introduce additional but familiar elements into the view and the magnitude of effect would range from moderate through to negligible depending on the distance of the view.
Combined effects: Saxon Shore Moderate Where the Saxon Shore Way is in Way adverse close proximity, the buildings and - Development A structures associated with the proposed developments would occupy - Development B a large portion of the view and the - Development C magnitude of effect would be major - Development D adverse. Where the path is further away a low proportion of the view - Development E would be altered and the magnitude of - Development H effect would be minor adverse.
Traffic
Combined effects: A28 and Moderate Such effects would only occur in the surrounding to major event that construction of - Development F highway adverse Developments F and G (including the network of Sturry link road) were to take place - Development G Herne Bay simultaneously with construction of the Road, Broad Richborough Connection project, which Oak Road, is unlikely. Shalloak Road and Vauxhall Road
Construction Noise
Development F Residential Moderate Construction works on the properties on adverse Richborough Connection project are Shalloak Road transient and the cumulative noise effects will therefore be of relatively short duration.
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