Land off Glyders, Benfleet

Preliminary Ecological Appraisal

Prepared by CSA Environmental

on behalf of Vistry Group

Report Ref: CSA/5491/01

April 2021

This report may contain sensitive ecological information. It is the responsibility of the Local Authority to determine if this should be made publicly available.

Report Date Revision Prepared Approved Comments Reference by by CSA/5491/02 30/03/2021 - MD/JW JW Draft for comment CSA/5491/02a 07/04/2021 A MD/JW JW Final

CONTENTS Page

Executive Summary 1

1.0 Introduction 2

2.0 Legislation, Planning Policy & Standing Advice 3 Legislation 3 National Planning Policy 3 Local Planning Policy 3 Standing Advice 3

3.0 Methods 4 Desk Study 4 Field Survey 5 Limitations 5 Evaluation and Assessment 5

4.0 Baseline Ecological Conditions 7 Nature Conservation Designations 7 Habitats and Flora 11 Fauna 14

5.0 Discussion 18 Nature Conservation Designations 18 Habitats and Flora 20 Fauna 21

6.0 References 23

Appendices Appendix A: Habitats Plan & Photographs Appendix B: Legislation, Planning Policy and Standing Advice Appendix C: Desk Study Information

EXECUTIVE SUMMARY

Residential development is being promoted at Land off Glyders, Benfleet through the Local Plan.

CSA Environmental was instructed by Vistry Group to undertake a Preliminary Ecological Appraisal (PEA) of the Site to identify ecological constraints to development, inform recommendations for design, highlight opportunities for ecological enhancement and determine any additional investigation/survey work necessary. As part of this PEA, a desk study and extended Phase 1 Habitat survey of the Site were undertaken in March 2021.

The Site lies adjacent to Benfleet & Southend Marshes SSSI, with adjacent habitat comprising scrub and grassland habitats managed as a country park with well-established paths. Subject to detailed design of open space and other appropriate safeguards set out herein, indirect recreational effects as a result of a modest increase in local population are not predicted to be significant in relation to adjacent land.

No indirect effects upon Essex Coastal (‘Habitats’) Sites are predicted subject to the adherence to the Essex Coast Recreational Avoidance Mitigation Strategy (RAMS), including tariff payments, education and the provision of sufficient natural greenspace on-site and links to local footpath networks.

The Site itself comprises dense scrub, plantation woodland and an area of pasture. These habitats are generally common and widespread and are of limited intrinsic botanical interest. As such, opportunities for Biodiversity Net Gain (BNG) exist at the Site through landscaping and habitat creation.

The Site is known to support populations of certain protected species, including reptiles and badger. Mitigation measures have been set out herein in respect of these which could be readily delivered alongside development to address any adverse effects upon such populations and to implement development lawfully. The details of any mitigation would be informed by detailed further survey work.

Subject to the measures set out herein, it is predicted that development of the Site could be implemented proceed without significant adverse ecological impacts. Recommendations have been provided for ecological enhancement measures that could be delivered as part of the proposed development.

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1.0 INTRODUCTION

This report has been prepared by CSA Environmental on behalf of Vistry Group. It sets out the findings of a Preliminary Ecological Appraisal (PEA) of Land off Glyders, Benfleet (hereafter referred to as ‘the Site’). Residential development is proposed at the Site and is being promoted through the Local Plan for around 30 dwellings.

The scope of this appraisal has been determined with due consideration for best-practice guidance provided by the Chartered Institute of Ecology and Environmental Management (CIEEM, 2017), and to the Biodiversity: Code of practice for planning and development (BS 42020:2013) published by the British Standards Institution (2013).

The Site occupies an area of c. 2.06ha and is located around central grid reference TQ78418602, to the south-east of South Benfleet. It comprises an area of dense scrub and plantain woodland to the west, with open pasture to the east (see Habitats Plan in Appendix A).

A desk study and extended Phase 1 Habitat survey were undertaken of the Site, the findings of which are presented herein.

This PEA aims to:

• Identify any ecological constraints to development of the Site • Inform design decisions • Identify further ecological surveys and investigation necessary to inform a full Ecological Impact Assessment (EcIA) of the Site • Highlight opportunities for ecological enhancement and Biodiversity Net Gain (BNG)

As set out in best practice guidelines (CIEEM, 2017) a PEA is typically only suitable for planning submission where there are no ecological constraints relating to the project. Where ecological constraints are identified, such as the presence of important ecological features, the effects of development on these features should be assessed within a separate EcIA report, which would supersede the PEA.

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2.0 LEGISLATION, PLANNING POLICY & STANDING ADVICE

Legislation

Legislation relating to wildlife and biodiversity of particular relevance to this PEA includes:

• The Conservation of Habitats and Species Regulations 2017 (as amended) • The Wildlife and Countryside Act 1981 (as amended) • The Natural Environment and Rural Communities (NERC) Act 2006 • The Protection of Badgers Act 1992

This above legislation has been addressed, as appropriate, in the production of this report. Further information on the above legislation is provided in Appendix B.

National Planning Policy

The National Planning Policy Framework (NPPF) (Ministry of Housing, Communities and Local Government, 2019) sets out the government planning policies for England and how they should be applied. Chapter 15: Conserving and Enhancing the Natural Environment, is of particular relevance to this report as it relates to ecology and biodiversity. Further details are provided in Appendix B.

The Government Circular 06/2005, which is referred to by the NPPF, provides further guidance in respect of statutory obligations for biodiversity and geological conservation and their effects within the planning system.

Local Planning Policy

A number of local planning policies relate to ecology, biodiversity and/or nature conservation. These are summarised in Table 1 of Appendix B. These policies have been addressed, as appropriate, in the production of this report.

Standing Advice

Natural England and Defra’s Standing Advice (Natural England & Defra, 2014) regarding habitats and protected species aims to support local authorities and forms a material consideration in determining applications in the same way as any individual response received from Natural England following consultation. Standing advice has therefore been given due consideration, alongside other detailed guidance documents, in the production of this report.

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3.0 METHODS

Desk Study

The Multi-Agency Geographic Information for the Countryside (MAGIC) online database was reviewed in March 2021 to identify nature conservation designations within the following search radii:

• Special Protection Areas (SPA), Special Areas of Conservation (SAC) and Ramsar sites within 10km of the Site (including possible/proposed sites) • Sites of Special Scientific Interest (SSSI), National Nature Reserves (NNR), Local Nature Reserves (LNR) within 3km of the Site • Other relevant data e.g. Ancient Woodland Inventory within 1km of the Site

A review was undertaken of the location of any such designations, their distance from and connectivity with the Site, and the reasons for their designation. This information was used to determine whether they may be within the Site’s zone of influence.

Essex Wildlife Trust (EWT) and Essex Field Club (EFC) were contacted for details of any non-statutory nature conservation designations and records of protected/notable habitats and species. This information was requested for an area encompassing the Site and adjacent land within c. 2km of its central grid reference. This search area was selected to include the likely zone of influence upon non-statutory designations and protected or notable habitats and species.

Further online resources were reviewed for information which may aid the identification of important ecological features. The Woodland Trust’s online Ancient Tree Inventory was reviewed for known ancient or veteran trees within the Site and adjacent land. Interactive online mapping provided by the charity ‘Buglife’ was used to determine whether the Site falls within an Important Invertebrate Area.

[In accordance with Natural England’s Great Crested Newt Mitigation Guidelines (2001), a desktop search was undertaken to identify ponds within 500m of the Site which may have potential to support breeding great crested newts Triturus cristatus, using Ordnance Survey (OS) mapping, the MAGIC database and aerial photography.

Where possible under the terms of the data provider, relevant desk study data are presented in Appendix C.

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Field Survey

Extended Phase 1 Habitat Survey An extended Phase 1 Habitat survey was carried out in fine and dry weather conditions on 19 March 2021 by Jamie Woollam CEcol MCIEEM, encompassing the Site and immediately adjacent habitats that could be viewed.

Phase 1 Habitat survey is a method of classification and mapping wildlife habitats in Great Britain. It was originally intended to provide “…relatively rapidly, a record of the semi-natural vegetation and wildlife habitat over large areas of countryside.” The Phase 1 Habitat survey method has been widely ‘extended’ beyond its original purpose to allow the capture of information at an intermediate level between Phase 1 and Phase 2 Habitat surveys, and here includes the following:

• More detailed floral species lists for each identified habitat • Descriptions of habitat structure, the evidence of management and a broad assessment of habitat condition • Mapping of additional habitat types (e.g. hardstanding) • Identification of Priority Habitats under Section 41 of the NERC Act • Identification of Habitats Directive Annex I habitat types • Evidence of, or potential for, European Protected Species (EPS) (including bats, great crested newt, dormouse and otter) • Evidence of, or potential for, other protected species (including birds, reptiles, water vole, badger and certain invertebrates) • Evidence of, or potential for, other notable species (including S41 Species of Principal Importance as well as notable, rare, protected or controlled plants and invertebrates)

Results of the extended Phase 1 Habitat survey are presented on the Habitats Plan in Appendix A, with habitats and species lists provided within text herein.

Limitations

There were no specific limitations to the desktop study or extended Phase 1 Habitat survey, which was conducted at a suitable time of year and in good conditions. It is acknowledged that botanical species flowering later in the year may not have been obvious/in leaf or flower and therefore these may have not been recorded. However, the aim of broadly characterising habitats and their potential to support notable or protected flora and fauna was not compromised.

Evaluation and Assessment

The evaluation and assessment of ecological features is beyond the scope of a PEA and has therefore not been undertaken here. Formal evaluation and assessment of any identified important ecological

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features should be undertaken as part of either a full EcIA, or receptor- specific survey and assessment in accordance with the published CIEEM method (CIEEM, 2018).

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4.0 BASELINE ECOLOGICAL CONDITIONS

Nature Conservation Designations

Statutory There are no statutory designations covering any part of the Site.

Seven international statutory, four national statutory and a single local statutory designation was identified within 10km, 3km and 3km of the Site, respectively. These statutory designations are described in Table 1 below.

Non-Statutory Eight non-statutory designations were identified within 1km of the Site, all of which are Local Wildlife Sites (LWSs). These non-statutory designations are described in Table 1 below.

Table 1. Statutory and Non-Statutory Designations within search radii

Distance & Site Name & Direction from Special Interests or Qualifying Features Designation Survey Area International Designations within 10km Consists of mudflats, saltmarshes and grassland along the north shore of the Thames estuary. In many locations there Benfleet and is a sea wall which divides the terrestrial Southend Marshes c. 0.3m south-east (freshwater and coastal grazing marsh) Ramsar from the intertidal and marine zones. The marine areas consist of saltmarsh, mudflats, shell banks and areas of seagrass. The combination of terrestrial, subtidal Benfleet and and intertidal habitats is ideal for a Southend Marshes c. 0.3m south-east diversity of water birds, such as dark SPA bellied brent geese, grey plover, knots and dunlins. Located on the outer Thames estuary, Thames Estuary mostly on the south bank, the site and Marshes c. 5.4km south consists of a complex mosaic of brackish Ramsar water, intertidal saltmarsh, mudflats, saline lagoons and grazing land. Large areas of mudflats are exposed during low tide providing ideal foraging Thames Estuary c. 5.4km south habitats for a number of bird species and Marshes SPA including ringed-plover, avocet and dunlin. Consists of a narrow strip tidal mud Crouch and Roach along the banks of the rivers Crouch c. 8.5km north Estuaries (Ramsar) and Roach. Home to a diversity aquatic and terrestrial invertebrates and plants. This strip of tidal mud is utilised by a large Crouch and Roach c. 8.5m north number of feeding birds in the winter, Estuaries (SPA) including dark-bellied brent geese.

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Essex Estuaries Consisting mostly of tidal rivers, estuaries Special Area of and mudflats. Contains one of the most c. 8.5km north Conservation extensive expanses of small cord-grass in (SAC) the UK. National Designations within 3km Benfleet and Southend Marshes Consists of areas of broadleaved, mixed Adjacent to the Site of Special and yew woodland, littoral sediment site (south) Scientific Interest and neutral grassland. (SSSI) A brownfield site on Canvey island which recognised as the most densely biodiverse site in the UK, noted for its Canvey Wick SSSI c. 3km south-west diversity of invertebrates. The site mosly consists of grassland, scrub and wetlands. An area of intertidal mudflats and Holehaven Creek c. 2.9km south- marshes along the banks of Holehaven SSSI west Creek. Home to numerous wintering black-tailed godwit Consists of a mosaic of grassland and heath habitats, with southern areas of Thundersley Great the common containing marshy pools. c. 3km north Common SSSI The site also contains woodland mostly consisting of oak, hawthorn and hornbeam. Local Designations within 3km This is a long, linear improved lake surrounded by residential housing. The Canvey Lake Local lake is home to waterfowl such as Nature Reserve c. 1.9km south-east mallards, moorhens, mute swans and (LNR) water rails, as well as a population of water voles. Non-Statutory Designations within 1km The majority of the site consists of grassland undergoing succession to scrub/young woodland. The grassland is dominated by a diversity of grass species including crested dog’s tail, sweet vernal-grass and Yorkshire-fog. Other species include meadow Vicarage Hill Local buttercup, common bird’s-foot-trefoil c. 0.05km north Wildlife Site and pale flax which is scarce. The site also contains horse-grazed pasture and a broadleaved woodland consisting of tree species such as pedunculate oak, sycamore and ash, with an understorey of hawthorn and elder, with ground flora of including native Bluebells. The site has a large badger population. The field has been identified as an England BAP priority habitat of coastal and floodplain grazing marsh. It is a Benfleet Marsh LWS c. 0.7km west surviving part of the Benfleet Marsh which has largely been lost to housing. Common lizards have been found on site and on the eastern edge of the site

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there is a small population of water voles. Contains an extensive area of grazing- marsh, ditches, scattered scrub and inter-tidal habitats. The Site supports populations of reptiles (Common Lizard, West Canvey c. 0.5km south- Adder and Slow Worm) and a Marshes LWS west population of Water Voles. The Site contains three of the England BAP Priority Habitats: Coastal and Floodplain Grazing Marsh, Coastal Saltmarsh and Intertidal mudflats. The site consists mostly of sea wall grassland, with adjacent scrub, non-SSSI saltmarsh, brackish fleets and a tidal lagoon. The sea wall is dominated by grasses and herbaceous species, such as the Nationally Scarce Sea Clover. The sea wall is some to both the Small Heath and Marbled White butterflies. Saltmarsh Benfleet Creek and follows Benfleet Creek and is dominated c. 0.6km south Sea Wall LWS by Sea Purslane and Common Saltmarsh-grass. In the south-eastern corner of the site there is a tidal lagoon containing a community indicative of low to mid saltmarsh at its margins. The borrow dyke and swale also supports a saltmarsh plant community of plants such as sea plantain, common sea lavender and sea club-rush. This consists of two pastures which are classified as Lowland Meadows which is an England BAP Priority habitat. The western-site contains a diverse grassland community indicative of little agricultural Reeds Hill Pasture improvement, containing grass species c. 0.3km north-east LWS such as crested dog’s tail, meadow barley and yellow oat-grass. The eastern pasture does have more signs of agricultural improvement with the presence of white clover and perennial ryegrass. Contains of two fragments of ancient woodland, mostly consisting of hornbeam, with some ash and pedunculate oak and an understory of Wall Wood LWS c. 0.9km north-east aspen, holly and silver birch. The ground floral contains the ancient woodland indicators dog’s mercury, bluebell and yellow archangel. The majority of the works consists of rough grassland, providing a habitat which supports common lizard, grass Benfleet Sewage c. 0.7km west snake and slow worm. The site also Works LWS includes a fringe of saltmarsh and mudflats and remnants of coastal grazing marsh.

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Consists of an area of ancient woodlands. The trees species consist mostly of hornbeam, coppice, but also containing sweet chestnut, ash, bird, field maple, wild cherry and aspen. The understory mostly consists of hazel, holly, Shipwrights Wood c. 1km north-east hawthorn and midland hawthorn. The LWS grown flora is indicative of ancient woodland, containing native bluebell, yellow archangel and Hart’s-tongue. There is a noted diversity of dead wood which may support a diversity of invertebrates.

In addition to the above, the western portion of the Site was identified within “Castle Point Borough Local Wildlife Sites Review 2012” as Glyders Meadow Potential Local Wildlife Site (pLoWS) (number 9). The review includes the following survey information:

“This meadow has not been managed in recent years and so is dominated by coarse grasses, with scrub also invading. A good variety of grasses and herbaceous species are present although generally at low frequency. Species include Crested Dog‟s-tail (Cynosurus cristatus), Meadow Barley (Hordeum secalinum), Red Fescue (Festuca rubra), Sweet Vernal-grass (Anthoxanthum odoratum), Field Wood-rush (Luzula campestris), Meadow Vetchling (Lathyrus nissolia), Common Knapweed (Centaurea nigra), Agrimony (Agrimonia eupatoria), Red Bartsia (Odontites vernus) and Common Bird‟s-foot Trefoil (Lotus corniculatus).

Great Green Bush Cricket and Marble White butterfly, both of local significance, were recorded during the site visit.

The grassland community present in this meadow is of conservation significance, but its current condition prevents its selection as a LoWS. An improvement in management, light grazing and the removal of invading scrub, could be enough to allow the HC9 Lowland Meadow criterion to be applied.”

In addition to the above, the following description was set out

“This small meadow on a steep northerly slope has been recognised as a Potential LoWS (PLoWS9) because of its agriculturally unimproved character, good plant species diversity and the presence of some interesting invertebrate species. It lies on the edge of the Hadleigh Castle and Marshes Living Landscape Area, with the Benfleet and Southend Marshes SSSI immediately to the south. Its management is not favourable at present, with excessive scrub and dominant coarse grass species, which is why it failed to meet LoWS selection criteria.

Recommended Ecological Survey Requirements

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• A PEA should be required to consider the value of the site and the impact of any proposed development; • The habitat is suitable for reptiles and so a full survey should be undertaken; • A botanical survey should be carried out; • An invertebrate survey may be appropriate, focussing on the presence of UK BAP Priority Species such as the fly Dorycera gramineum, and the Brown-banded Carder and Shrill Carder bumblebees.

Enhancement and Compensation Opportunities The management of this meadow could be improved to the extent that it meets LoWS selection criteria, which makes it suitable as a compensation site for other nearby developments. This site, with the improved grassland to the east, has the potential to link CPT12 Vicarage Hill LoWS and the Benfleet and Southend Marshes SSSI”

Consideration of the Site’s potential status as a LoWS is given in the discussion section below.

Ancient Woodland There is no ancient woodland covering any part of the Site or immediately adjacent land. No trees on or adjacent to Site are listed on the Ancient Tree Inventory.

Habitats and Flora

Habitats recorded on-site were classified in line with current Phase 1 Habitat survey guidance (JNCC, 1990), as illustrated in Appendix A. Detailed species lists for each habitat are provided in Appendix D.

Notable Flora Records The EWT and EFC provided 194 records of 68 notable plant species from within the search area. The Site is mostly dominated by scrub, semi- mature trees and some mature trees. Those of potential relevance to the Site include pyramidal orchid Anacamptis pyramidalis, ragged-robin Silene flos-cuculi, Heath Speedwell Veronica officinalis, Lesser Calamint Clinopodium calamintha and Spiny Restharrow Ononis spinosa. There have also been recordings of invasive species Indian Balsam Impatiens glandulifera, Japanese Knotweed Fallopia japonica, floating pennywort Hydrocotyle ranunculoides and giant hogweed Heracleum mantegazzianum.

None of the above species were recorded on-site during the survey

Dense scrub Much of the western portion of the Site has developed into dense scrub over the last c. 15 years, over previous grassland habitats. Woody species comprise cherry plum Prunus cerasifera, young oak Quercus

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robur, bramble Rubus fruticosus agg., hawthorn Crataegus monogyna, young ash Fraxinus excelsior, blackthorn Prunus spinosa, hazel Corylus avellana, dogwood Cornus sanguinea, field maple and Acer campestre. In denser locations, ground flora comprises wood avens Geum urbanum, common dog vioet Viola canina, ivy Hedera helix, arum lily Arum maculatum and wood false-brome Brachypodium sylvaticum.

Glades still exist in some areas of scrub with some patches of grassland habitats present, albeit with none of the notable species previously recorded now present. Vegetation here comprises coarse, rank grasses dominating including false oat grass Arrenatherum elatius elatius with creeping bent Agrostis stolonifera, cleavers Galium aparine, creeping thistle Cirsium arvense, creeping buttercup Ranunculus repens and dandelion Taraxacum officinale agg. These grassland glades were generally species poor, although anthills were noted in a number of locations which may indicate some former interest now lost.

Overall, given the presence of at least three woody species over >75% cover, a reasonable age range, the presence of some pernicious weeds, the absence of well-developed ‘edge’ with un-grazed herbs and presence of clearings/glades, the scrub is concluded to be of fairly poor condition. Without management it is anticipated that the scrub would decline in condition, but would eventually succeed into woodland.

Plantation Woodland East of dense scrub habitats, running north-south through the Site is an area of native planted trees, c. 20years old with some tree guards still noted in position. The belt of plantation has a mixed canopy of oak, hazel, hornbeam Carpinus betulus, hawthorn wild cherry Prunus avium, holy Ilex aquifolium, Scots Pine Pinus sylvestris, ash and field maple. Trees appear to be of a similar age with no management noted. Ground flora of the plantation is relatively sparse, and comprises patchy ivy, bramble and cleavers.

On balance given the complete canopy cover, presence of native species, poor age range, the absence of significant tree damage, limited tree regeneration, absence of significant deadwood habitat, limited protection from adjacent agriculture, lack of obvious management, lack of invasive species, and presence of over 3 woody species per 10m x10m area, the plantation is concluded to be in fairly poor condition.

Improved/Modified Grassland East of plantation woodland is an area open habitat comprising pasture. This sward is dominated by a small range of palatable grasses with a low

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cover of herbs, and is therefore concluded to be agriculturally improved/modified grassland.

Grass cover exceeds 75% with perennial rye grass Lolium perenne, annual meadow grass Poa annua, rough meadow grass P. trivialis recorded most frequently, along with occasional cocks-foot Dactylis glomerata, false oat grass and red fescue Festuca rubra also recorded. Where herbs were recorded these included yarrow Achillea millefolium, creeping buttercup, dandelion, cleavers, lawn daisy Bellis perennis, white clover Trifolium repens, common catsear Hypochaeris radicata, mouse-ear Cerastium vulgaris, meadow vetchling Lathyrus pratensis, groundsel Senecio vulgaris, chickweed Stellaria media, creeping thistle, dove’s foot cranesbill Geranium molle, cut-leaved cranesbill G. dissectum and self-heal Prunella vulgaris.

Given the dominance of palatable grasses, the low abundance of herbs, likely high levels of enrichment and presence of some pernicious weeds, the grassland is concluded to be in poor condition.

Scattered trees A number of individual mature trees were identified during the Site survey, including a mature oak and ash to the southwest boundary within garden habitats, a mature ash within adjacent Benfleet Downs to the southeast boundary, and mature oaks and a horse chestnut Aesculus hippocastanum to the northern boundary within adjacent gardens.

Hedgerows A single hedgerow is present at the Site, along the north-eastern boundary adjacent to a watercourse. This short section of hedgerow comprises elm Ulmus sp. (much of which is suckering and/or now dead) along with hawthorn and some dog rose. An understory is present of nettle Urica dioica, arum lily, cleavers, ground ivy Glechoma hederacea and alexanders Smyrnium olusatrum.

A former hedgerow/field boundary/garden boundary is present along the southern boundary of the Site, and spans the boundary to gardens to the west and the Benfleet Downs park to the west. This feature is now subsumed within scrub and/or wooded habitats such that it no longer qualifies as a hedgerow. However, of note are several mature trees and coppiced hazel on this boundary, along with the presence of some old hedgerow/woodland indictors, including greater stitchwort Ravelera holostea and a wood sorrel Oxalis sp. (possibly garden escape). Badger setts are also present on this boundary.

Short linear sections of bramble scrub are present within open grassland to the east of the Site which potentially indicate the presence of lost hedgerows or field boundary fences. However, given their length and

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the lack of any woody species remaining, these linear features do not comprise hedgerow habitats.

Fauna

Bats A total of 57 bat records were identified within the search area, dating from 1981 to 2019. These include the following species: common pipistrelle Pipistrellus pipistrellus, soprano pipistrelle Pipistrellus pygmaeus, noctule Nyctalus noctula, brown long-eared Plecotus auritus, serotine Eptesicus serotinus, Daubenton's Myotis daubentonii and Natterer's Myotis nattereri. The closest records are of a brown long-eared bat at c. 0.5km from the Site to the north-west.

No obvious roosting features were noted in any trees at the Site, including mature trees on the northern and southern boundary. It is likely that adjacent properties and trees in the wider area provide roosting opportunities for bats.

The western half of the Site provides some good foraging and navigation opportunities for bats, given the structural diversity and maturity of habitats. By contrast the eastern portion of the Site, comprising pasture with limited structural or botanical diversity provides far fewer such opportunities.

Survey work carried out in 2014 of the Site found common pipistrelle to make use of the Site.

Badger The EWT and EFC have provided 30 records of badger Meles meles from within the search area, dating from 1994 to 2019. The closest record dates from 2009, and is c. 0.1km from the central grid reference of the site. This data was provided by EFC to a resolution of 100m. The location of this seems to relate to Vicarage Hill which is known to support a large badger population.

A main badger sett was noted on the southern boudary within adjacent private gardens, beneath mature oak and ash trees. The sett, viewed from the Site boundary, was noted to have at least five active holes with significant spoil heaps and bedding. As such, the sett is anticipated to be a ‘main sett’. Some snuffle holes and clear paths were noted leading to/from the sett and across much of the Site. Given the cover of dense scrub, it is possible that other associated badger setts are present on-site and/or setts could be dug into the slope of the hill in many locations.

In addition to sett digging, the whole site provides foraging opportunities for badger, with earthworms likely to be in abundance in both wooded and open habitats.

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Dormouse No records of dormouse Muscardinus avellanaius were identified within the search area. Previous surveys of the site in 2014 were understood to prove the likely absence of dormice at the time.

There remains some potential for dormice to use the Site, if presence in the adjacent Benfleet Downs site. However, the Site itself is not of sufficient size/quality to support a self-sustaining dormouse population and, if absent at Benfleet Downs they are likely to be absent on-site also.

Riparian Mammals A total of seven records of water vole Arvicola amphibius were identified within the search area, dating from 2012 to 2019. The closest record is c. 0.9km from the Site. All seven of these records occur in an area of marshes to the west of the Site covering Benfleet marsh and West Canvey Marshes. There were found to be no records of otter Lutra lutra were identified within the 2km search area,. The closest record is c. 2.2km from the Site, dating to 1979.

The majority of the Site provides no opportunities for water vole or otter being principally terrestrial habitat. A small stretch of watercourse is present to the northeast of the Site. However, given its very low water level, heavy shading, and limited links to other more suitable habitat, neither otter or water vole are likely to make use of this watercourse.

Other Mammals No records of brown hare Lepus europaeus or harvest mouse Micromys minutus were identified within the search area. The Site provides some opportunities for these species within grassland habitats (where sufficiently long for harvest mouse, and sufficemntly open for brown hare). Dense scrub and wooded habitats also provided refuge for both these species.

Four records of hedgehog Erinaceus europaeus were identified within the search area, dating from 2005 to 2014. The closest record is c. 0.7km from the Site. The Site provides a modest range of opportunities for hedgehog, particularly where adjacenr garden habitats remain open to dispersal.

Birds A total of 676 records of 126 bird species were identified within the search area, dating from 1980 to 2020. Those of potential relevance to the Site include Red Kite Milvus milvus, Barn Owl Tyto alba, hobby Falco subbuteo, sparrowhawk Accipiter nisus and nightingale Luscinia megarhynchos.

The dense scrub and wooded habitats to the west provide the greatest foraging, nesting and refuge habitats for woodland and garden birds.

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The open grassland to the east provides some foraging opportunities for some species, but are located close to cover which may dissuade ground nesting species such as skylark, given predation risks.

Reptiles A total of 134 records of four reptile species were identified within the search area including common lizard Zootoca vivipara, adder Vipera berus, grass snake Natrix natrix (syn. N. helvetica) and slow-worm Anguis fragilis. An abundance of records have been identified c. 0.05km east of the eastern Site boundary to a grid reference to a precision of 100m. Here there were 13 records of common lizard and one record of adder.

Surveys of the Site in 2014 confirmed the presence of a small population of common lizard, slow worm and grass snake, making use of glades within dense scrub habitats. Habitats contionue to provide opportunities for reptiles to the west of the Site, albeit with open glades likely to reduce in size over time. The eastern open area of the Site provides very little opportunity for reptiles is grassland remains short and/or heavily grazed.

Amphibians A total of 55 records of 3 amphibian species were identified within the search area, including common frog Rana temporaria, common toad Bufo bufo and great crested newt Triturus cristatus (‘GCN’). In respect of GCN there are records of three female and two males GCN recorded c.300m away to the southeast, although the location could only be accurately determined to 100m2. MAGIC searches of granted GCN licences revealed that the closest licences recorded were 3km to the south-east on the Site on Canvey island.

The western portion of the Site provides suitable terrestrial opportunities for amphibians, including GCN, if breeding opportunities are present nearby.

No ponds are present on-site which provide suitable breeding opportunities for amphibians. Five ponds appear to be present within a dispersible range of the Site (c.500m) for amphibians, based on OS mapping. All five of these ponds are clustered to the south-east of the site within Benfleet Down, the closest being approximately 0.3km away. At this distance, given the presence of highly suitable habitat in their vicinity, amphibians, including GCN are unlikely to disperse to the Site in favour of more local terrestrial habitat.

Invertebrates The Site is located within the Thames Estuary Important Invertebrate Area (IIA). A total of 1393 records of 391 invertebrate species were identified within the search area. Those of potential relevance to the Site include white-letter hairstreak Satyrium w-album, heath fritillary Melitaea athalia,

5491 Land off Glyders, Benfleet – PEA Page 16

grizzled Skipper Pyrgus malvae, shrill carder bee Bombus sylvarum and red-shanked carder-bee Bombus ruderarius.

The western portion of the Site, with scrub / wooded habitats and grassland glades, provide some good structural diversity of habitat for invertebrates albeit with limited botanical diversity. Indeed, the presence of cherry plum provides good early nectar sources for flying invertebrates, with a range of native flowering shrubs to provide nectar through spring and into summer. Whilst the eastern portion of the Site provides contrasting open habitat, this agriculturally improved grassland is species-poor, with limited abundant of herbaceous foodplants or abundant nectar. As such it is unlikely to contribute to invertebrate interest.

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5.0 DISCUSSION

Residential development of around 30 dwellings is proposed at the Site, through draft allocation HO11 Land off Glyders, Benfleet of the proposed Castle Point Local Plan. In addition, the following assessment considers the Concept Masterplan prepared for the Site (CSA/5491/102).

Nature Conservation Designations

Statutory Essex Coast Habitats Sites The Site lies c. 0.3km from the from the Benfleet and Southend Marshes SPA and Ramsar site, the nearest of the wider ‘Essex Coastal’ group of sites. The development site falls within the ‘Zone of Influence’ of this and other Sites in the context of recreational effects to species (principally wintering/breeding bird populations) and habitats (sensitive coastal habitats) as a result of disturbance and/or degradation of habitats. Accordingly, it is likely that the scheme, in combination with other projects or plans, and in the absence of any mitigation, could result in significant adverse effects to Essex Coastal Sites.

The scheme would be implemented in accordance with the Essex Coast Recreational Avoidance Mitigation Strategy (RAMS), whereby a payment is made to the scheme for the implementation of mitigation at the coast, including wardening, public education and access management. This payment would therefore ensure that any minor contribution to scheme makes to impacts, in combination with other projects or plan, would be fully mitigated for.

In addition to the above, the scheme is acknowledged to be located close to the nearest Essex Coast site, Benfleet and Southend Marshes SPA and Ramsar site. As such consideration of the effect of the scheme alone is also required. It is anticipated that new residents are likely to be able to walk from new dwellings to the SPA/Ramsar as part of daily exercise, such as dog walking. However, the scale of new development is modest, with around 30 new dwellings resulting in approximately 72 new residents (assuming 2.4 occupants per household). Furthermore, new open space to the east of the Site provides dedicated space for new residents, with the opportunity to provide key facilities such as dog waste bins and dog exercise areas. Potential links to local footpaths are also identified, which provide walking routes away from the SPA/Ramsar, including circular routes. Additional avoidance measures, such as the promotion of on-site open space, the education of new residents and the promotion of non-SPA/Ramsar walking routes are proposed to ensure any minimal risks of impacts are fully mitigated.

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Overall, subject to the adherence to the Essex Coast RAMS including an appropriate tariff payment, and a package of mitigation relating to on- site open space, provision of dog waste bins and dog exercise areas, local walking routes and new resident education, it is anticipated that any significant adverse effects to Essex Coast Habitats sites can be fully mitigated for.

Further discussion and commentary are provided on this matter within a separate note prepared for consideration of the inspector in relation to duties under the Conservation of Habitats & Species Regulations (2017), as amended.

Benfleet & Southend Marshes SSSI The Site lies adjacent to Benfleet and Southend Marsh SSSI, with the adjacent land comprising grassland and scrub habitats of Benfleet Downs, away from the coastal marshland areas of the SSSI.

As illustrated in the Concept Masterplan, development would be set back west from the Site boundary which borders the SSSI, with open space and landscape planting proposed in this location. As such, no direct effects on the SSSI are anticipated, and no hydrological or other similar environmental connectivity is identified.

The condition of the adjacent SSSI unit (5) is identified as being in ‘unfavourable-recovering’ condition. This condition is based upon the current extent of scrub negatively effecting grassland habitats, but with management underway to reduce the extent of scrub within the SSSI. There are no negative condition criteria relating to recreational disturbance.

Potential pedestrian access is identified linking open space at the Site to the SSSI. Even in the absence of this link, some increase in recreation as a result of the proposed development is anticipated at the SSSI via other access routes. It is important to note that the Benfleet Downs section of the wider SSSI is managed in part for recreational access with various constructed paths running through, and active management of recreation. Furthermore, development of the Site would include substantial open space to the east, with potential footpath links to the north, reducing further the modest increase in recreational pressures on local open spaces.

Overall, given that the scheme would result in a modest increase in local population, provision of open space is proposed along the eastern portion of the Site, and that the adjacent SSSI is subject to active management, development of the Site is not predicted to result in significant adverse effects to the SSSI.

5491 Land off Glyders, Benfleet – PEA Page 19

Non-Statutory LoWSs The Site is spatially removed from all LoWS located in the vicinity such that direct effects upon these designations are not predicted. Furthermore, given the small scale of development, the provision of on- site open space and the inaccessibility of some LoWSs, no significant adverse effects are predicted as a result of a modest increase in recreational pressures locally.

PLoWS Status As set out above, the Site is not covered by any nature conservation designation. However, a 2012 review of the Site identified the western portion, known as ‘Glyders Meadow’ as a Potential Local Wildlife Site (PLoWS). At the time of the review, the Site did not quality as a LoWS. Furthermore, it is clear from the description of the site, as a grassland/meadow, the western portion of the Site has deteriorated somewhat through the almost complete encroachment of dense scrub.

The review identified the need for (a) a Preliminary Ecological Appraisal (PEA) to be undertaken (b) the need for reptile surveys (c) a botanical survey to be conducted and (d) targeted invertebrate surveys. The first matter ‘(a)’ is dealt with via this PEA report, with the second ‘(b)’ via confirmed presence of reptiles during survey work in 2014 with habitats remaining suitable in 2021. In addition, the habitat survey in March 2021 allowed for the broad botanical interest of the Site to be assessed, albeit with some species unlikely to be present/obvious, and a broad assessment of the potential for the Site to support the identified invertebrate species (the picture winged fly Dorycera gramineum, the brown-banded carder and shrill carder bumblebees).

In respect of the two bee species identified above, plant species typically associated with these species were either absent or in very low abundance during the survey. The shrill carder bee in particular is strongly associated with the presence of narrow-leaved bird’s foot trefoil Lotus glaber, which was not recorded and unlikely to be present at the Site.

Overall, given the deterioration of habitats at the Site, and the collection of additional survey information, it is concluded that the site is unlikely to qualify as a LoWS.

Habitats and Flora

The Site is dominated by common and widespread habitats of lower ecological interest. Previously identified ‘agriculturally unimproved’ grassland to the west of the Site is almost entirely colonised by dense scrub habitats with none of the indicator species previously recorded now present.

5491 Land off Glyders, Benfleet – PEA Page 20

Mature trees & Hedgerows A number of mature trees are present to the Site boundaries, with former hedgerows in these locations and an existing hedgerow to the northeast. It is anticipated that all mature trees and former hedgerows can be retained alongside development. Retained trees and hedgerows would be robustly protected alongside development in line with BS 5837:2012 Trees in relation to design, demolition and construction.

A small section of hedgerow would require removal where potential pedestrian access is made to the northeast of the Site. However, it is anticipated that linear habitat provided north-south along the eastern site boundary would allow for similarly functioning hedgerow habitat to be reinstated.

Biodiversity Net Gain (BNG) Emerging legislative frameworks and policy seeks to leave biodiversity in a better state than prior to development, i.e. development should deliver a Biodiversity Net Gain (BNG). The Site is dominated by habitats of limited botanical ecological interest, and therefore opportunities exist through landscaping and habitat creation to provide Biodiversity net Gain (BNG) in line with paragraph 170(d) of the NPPF3 (2019).

To demonstrate the net effect of development upon biodiversity, any future scheme design, including both landscaping and habitat creation, would be subject to the latest Biodiversity Metric (2.0 Beta at the time of writing) published by Natural England.

Fauna

Further detailed design of the site would be informed by an appropriate scope of surveys, including confirmatory surveys for reptiles and badger known to be present on-site. This suite of survey work would inform design measures to avoid or reduce impacts, and where scheme design necessitates some impacts, mitigation and compensation measures.

In respect of reptiles, it is anticipated that, where populations of common lizard, grass snake and slow worm remain on site, as translocation exercise would be necessary to safeguard these populations and ensure works are implemented lawfully. Reptiles would be translocated from the western portion of the Site to new created habitats (scrub/grassland) within public open space to the east.

In respect of badger, it is anticipated that the existing badger sett to the north of the Site can be fully retained and protected alongside development allowing works to be implemented lawfully. Any works which are in close proximity to the existing sett, or where other setts are subsequently identified, would be implemented under the auspices of appropriate licences from Natural England.

5491 Land off Glyders, Benfleet – PEA Page 21

As set out above the Site is considered unlikely to support important populations of invertebrates, including those species identified as part of the PLoWS status review. However, detailed invertebrate survey would be carried out, in part to guide the creation of new habitats to the east of the Site to maintain any existing invertebrate interest and to target other species of local interest, including various carder bees as set out below.

Opportunities for Ecological Enhancement To promote adherence to the NPPF and emerging local policy the following opportunities for ecological enhancement have been specifically identified for the Site, including linking Vicarage Hill LoWS and the Benfleet and Southend Marshes SSSI:

• A corridor of habitat will be created along the eastern portion of the Site, including grassland, scrub, wooded habitat and a potential wildlife pond, to provide a strong link between Vicarage Hill LoWS and the Benfleet and Southend Marshes SSSI as identified within the LoWS review; • Within the habitat created to the east, invertebrate interests will be targeted, with the inclusion of o species-rich grassland/open habitat (likely requiring some top soil inversion/stripping) to include common and/or narrow-leaved birds foot trefoil, and other rich-nectar sources and invertebrate foodplants; o provision a of wide range of shrub and tree species (including early flowering cherry plum) and; o where drainage requirements allow, a permanently wet core to drainage feature to create a wildlife pond • Provision of new bat roosting (bat boxes), bird nesting (swift bricks) and insect opportunities (bee bricks) within new buildings • Provision of hedgehog gaps in new fencing to promote habitat connectivity across and within the Site

5491 Land off Glyders, Benfleet – PEA Page 22

6.0 REFERENCES

British Standards Institution, 2013. BS 42020:2013 Biodiversity — Code of practice for planning and development. London: BSI.

British Standards Institution, 2012. BS 5837:2012 Trees in relation to design, demolition and construction: Recommendations. London: BSI.

Buglife, no date. Important Invertebrate Areas. [online] Available at: < https://www.buglife.org.uk/resources/important-invertebrate-areas/> [Accessed 2021].

Chartered Institute of Ecology and Environmental Management, 2016. Guidelines for Assessing and Using Biodiversity Data. Winchester: CIEEM.

Chartered Institute of Ecology and Environmental Management, 2017. Guidelines for Ecological Report Writing. Winchester: CIEEM.

Chartered Institute of Ecology and Environmental Management, 2017. Guidelines for Preliminary Ecological Appraisal. 2nd ed. Winchester: CIEEM.

Chartered Institute of Ecology and Environmental Management, 2018. Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater, Coastal and Marine. Version 1.1. Winchester: CIEEM.

Collins, J., ed., 2016. Bat Surveys for Professional Ecologists: Good Practice Guidelines. 3rd ed. London: The Bat Conservation Trust.

Defra, 2011. Biodiversity 2020: A strategy for England’s wildlife and ecosystem services. London: Defra.

English Nature, 2001. Great Crested Newt Mitigation Guidelines. Peterborough: EN.

Joint Nature Conservation Committee, 1990. Handbook for Phase 1 habitat survey – a technique for environmental audit. Revised reprint 2010. Peterborough: JNCC.

JNCC and Defra (on behalf of the Four Countries’ Biodiversity Group), 2012. UK Post-2010 Biodiversity Framework. [pdf] Peterborough: JNCC. Available at: [Accessed 2021].

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Ministry of Housing, Communities and Local Government, 2019. National Planning Policy Framework (NPPF). London: Ministry of Housing, Communities and Local Government.

Multi-Agency Geographic Information for the Countryside (MAGIC), 2013. Interactive Map. [online] Available at: [Accessed 2021].

Natural England and Department for Environment, Food & Rural Affairs, 2014. Protected species and development: advice for local planning authorities. [online, last updated 2021] Available at: [Accessed 2021].

The Woodland Trust, no date. Ancient Tree Inventory. [online] Available at: [Accessed 2021].

5491 Land off Glyders, Benfleet – PEA Page 24

Appendix A

Habitats Plan & Photographs

icarage Hill Local Wildlife Site

Site boundary

Dense/Mixed scrub

Native Plantation

Mature trees and hedgerows

Improved/Modified grassland

I Site of Special Scientific Interest (SSSI)

Local Wildlife Site (LWS)

Approximate extent of main badger sett

Ditch/running water

I

Benfleet Southend Marshes SSS

Dixies Barns, High Street, Project Land at Glyders, South Benfleet Date March 2021 Drawing No. CSA/5491/ 104 Ashwell, Hertfordshire SG7 5NT Drawing Title Habitats Plan Scale NTS Rev - t 01462 743647 e [email protected] w csaenvironmental.co.uk Client Vistry Group Drawn JW Checked AC

© CSA Landscapes Ltd. Do not scale from this drawing. Refer to figured dimensions only.

Photograph 1. Dense scrub to the east of the Photograph 2. Plantation woodland to the Site centre of the Site

Photograph 3. Plantation Woodland edge (with Photograph 4. Improved/modified grassland to scrub habitats) the east and northeast of the Site

5491 Land off Glyders, South Benfleet – Photographs

Appendix B

Legislation and Planning Policy

The Conservation of Habitats and Species Regulations 2017 (as amended) make prescriptions for the designation and protection of Sites of Community Importance (‘European sites’, i.e. Special Areas of Conservation and Special Protection Areas) and European Protected Species (EPS). The latter include all native bats, great crested newts, dormice, otters and certain reptiles, listed under Annex II of the Regulations. Following the UK’s departure from the European Union, the provisions of the Regulations have been retained through enactment of the Conservation of Habitats and Species (Amendment) (EU Exit) Regulations 2019, which came into force on 31 December 2020.

The Wildlife and Countryside Act 1981 (as amended, principally by the Countryside and Rights of Way Act 2000) forms the basis for protection of statutory designated sites of national importance (e.g. Sites of Special Scientific Interest; SSSIs) and native species that are rare and vulnerable in a national context. Additionally, badgers are protected under the Protection of Badgers Act 1992.

Section 40(1) of the Natural Environment and Rural Communities (NERC) Act 2006 states that each public authority, “must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity.” This legislation makes it clear that planning authorities should consider impacts to biodiversity when determining planning applications, with particular regard to the Section 41 (S41) lists of 56 habitats and 943 species of principal importance. The UK Biodiversity Action Plan (BAP) has been superseded by the Biodiversity 2020 Strategy, however Local BAPs continue to influence biodiversity management and conservation effort, including through the spatial planning system, at the local scale.

The National Planning Policy Framework (2019) (NPPF) sets out government planning policies for England and how they should be applied. With regards to ecology and biodiversity, Chapter 15: Conserving and Enhancing the Natural Environment, paragraph 170, states that the planning system and planning policies should minimise impacts on and provide net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

Paragraph 175 sets out the principles that local planning authorities should apply when determining planning applications:

• If significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts). • Development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted. The only exception is where the benefits of the

5491 Land off Glyders, South Benfleet – Legislation and Planning Policy

development in the location proposed clearly outweigh both its likely impact on the features of the site that make it of special scientific interest, and any broader impacts on the national network of Sites of Special Scientific Interest. • Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists. • Development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.

The Government Circular 06/2005, which is referred to within the NPPF, defines statutory nature conservation sites and protected species as a material consideration in the planning process.

5491 Land off Glyders, South Benfleet – Legislation and Planning Policy

Appendix C

Relevant Desk Study Information

Essex Wildlife Trust Records Centre - designated sites within 2km search boundary for Glyders, South Benfleet area CP28 CP28 CP26 CP23 CP16 CP10 CP24 CP9 CP23 CP23 Ba41 Ba45 CP11 Essex Wildlife Trust Ba41 CP11 CP14 Biological Records Centre CP43 Abbotts Hall Farm Ba43 CP20 CP15 Great Wigborough CP17 Essex CP18 CO5 7RZ

www.essexwtrecords.org.uk CP22 CP41 [email protected] @EssexWTrecords CP12 CP13

Ba46 CP6 CP37 CP25 CP42

CP4

CP39 CP27 CP29 Legend CP4 TQ 7841 8602 Search area LNRs CP19 CP4 Local Wildlife Sites CP36 Ancient Woodlands Th69 BLines ¯ EWT Records Centre Boundary

0 0.325 0.65 1.3 Kilometers 1:31,500 Crown Copyright ©. All Rights Reserved. Ordnance Survey Licence Number: 100025798 Date: 24/03/2021 Created by : Dana Knollova Essex Wildlife Trust Records Centre - designated sites within 2km search boundary for Glyders, South Benfleet area CP28 CP28 CP26 CP23 CP16 CP10 CP24 CP9 CP23 CP23 Ba41 Ba45 CP11 Essex Wildlife Trust Ba41 CP11 CP14 Biological Records Centre CP43 Abbotts Hall Farm Ba43 CP20 CP15 Great Wigborough CP17 Essex CP18 CO5 7RZ Pitsea Marsh www.essexwtrecords.org.uk CP22 CP41 [email protected] @EssexWTrecords CP12 CP13

Ba46 CP6 CP37 CP25 Benfleet and Southend Marshes CP42 CP4

CP39 CP27 Benfleet and SouthendLegend Marshes CP29 TQ 7841 8602 CP4 Search area Local Wildlife Sites Ramsars Holehaven Creek CP19 CP4 SPAs incl. Marine CP36 SSSI Sites Th69 Canvey Wick BLines ¯ EWT Records Centre Boundary

0 0.325 0.65 1.3 Kilometers 1:31,500 Crown Copyright ©. All Rights Reserved. Ordnance Survey Licence Number: 100025798 Date: 24/03/2021 Created by : Dana Knollova