APPENDIX 5 GATWICK RUNWAY 2 MOLE GAP TO REIGATE ESCARPMENT SAC & ASHDOWN FOREST SPA/SAC REVISED HABITAT REGULATIONS ASSESSMENT REPORT: STAGE 1 (SCREENING) December 2017 Our Ref: OXF8027 RPS 20 Western Avenue Milton Park Abingdon OX14 4SH rpsgroup.com QUALITY MANAGEMENT Prepared by: Elizabeth White, Nick Betson, Fiona Prismall Reviewed by: Mike Barker, Julia Tindale Authorised by: David Cowan Date: December 2017 (Updated for Revised Draft NPS Consultation) Project Number/Document 8027 – HRA Screening Report Reference: COPYRIGHT © RPS The material presented in this report is confidential. This report has been prepared for the exclusive use of Gatwick Airport Limited and shall not be distributed or made available to any other company or person without the knowledge and written consent of RPS. Revised Habitats Regulations Assessment Screening December 2017 rpsgroup .com /uk CONTENTS EXECUTIVE SUMMARY ..................................................................................................................................... I 1 INTRODUCTION AND PURPOSE OF ASSESSMENT .......................................................................... 1 Background and Purpose of this Report .................................................................................................. 1 HRA Process ............................................................................................................................................ 2 Guidance and Information Used in Preparing this Report ....................................................................... 3 Scheme Description ................................................................................................................................. 4 2 BACKGROUND STUDIES AND CONSULTATION ................................................................................ 5 3 EUROPEAN SITES CONSIDERED ...................................................................................................... 11 Introduction ............................................................................................................................................. 11 Mole Gap to Reigate Escarpment Special Area of Conservation .......................................................... 13 Ashdown Forest Special Area of Conservation ..................................................................................... 16 Ashdown Forest Special Protection Area............................................................................................... 17 4 HRA SCREENING ................................................................................................................................. 19 Introduction ............................................................................................................................................. 19 Potential impacts of the proposed Scheme............................................................................................ 19 Screening Matrices ................................................................................................................................. 21 Consideration of Air Quality Impacts from Surface Access ................................................................... 29 5 SUMMARY AND CONCLUSIONS ........................................................................................................ 34 FIGURES Figure 1 Location of Mole Gap SAC and Ashdown Forest SAC/SPA Figure 2 Mole Gap to Reigate Escarpment SAC Figure 3 Ashdown Forest SAC/SPA APPENDICES Appendix 1 Natural England Consultation Responses Appendix 2 Natural England SSSI Unit Assessments for Mole Gap to Reigate Escarpment Special Area of Conservation component SSSIs Appendix 3 Air Quality Screening Assessment: Mole Gap to Reigate Escarpment SAC Appendix 4 Screening of Potential In-combination effects Appendix 5 Screening of Potential Construction Effects Appendix 6 Mole Gap to Reigate Escarpment Orchid Survey of Unit 23 Report Appendix 7 Records of Discussion on the Survey Report with Natural England and the National Trust Revised Habitats Regulations Assessment Screening December 2017 rpsgroup .com /uk EXECUTIVE SUMMARY S1. This report has been prepared by RPS for Gatwick Airport Limited (GAL) in response to the recently- published revised Habitats Regulations Assessment (Revised HRA) of the revised draft National Policy Statement (Revised NPS). The revised HRA was prepared by WSP for the Department for Transport (DfT) and concludes that each of the alternatives considered for a new runway in the south east of England, namely Heathrow Northwest Runway (LHR-NWR), Heathrow Extended Northern Runway (LHR-ENR) and a Gatwick Second Runway (LGW-2R), would each be likely to have an adverse effect on the integrity European sites for nature conservation or that sufficient uncertainty remains. S2. The Revised WSP HRA includes an Appropriate Assessment of the Government’s preferred scheme at Heathrow (LHR-NWR) and the short-listed alternatives - LHR-ENR and LGW-2R. These have also been revised. For Gatwick, it concludes that the LGW-2R scheme could result in adverse effects on the integrity of the Mole Gap to Reigate Escarpment Special Area of Conservation (MGRE SAC) and the Ashdown Forest SAC and Special Protection Area (SPA). This is surprising insofar as it contradicts all of the previous studies undertaken and reported both on behalf of Gatwick Airport Limited and the Airports Commission which concluded that significant effects at these sites were unlikely. S3. The Revised WSP HRA also concludes that LGW-2R results in fewer types of impact at fewer European sites than LHR-NWR or LHR-ENR, but because of its potential for adverse effects to Annex 1 priority habitats (at MGRE SAC) LGW-2R cannot be considered as an alternative to LHR-NWR. S4. Under the Habitats Regulations the competent authority responsible for the HRA must consult Natural England and have regard to their views. Natural England’s analysis and advice on the relevant issues was provided in response to the Airports Commission’s main consultation (November 2014) and air quality consultation (May 2015). In both cases Natural England said that the potential impacts on European sites that might be affected by surface access required further screening against the criteria in the Design Manual for Roads and Bridges (DMRB) or 1% of the critical load of pollutants. S5. Despite this, little attention is applied to screening of the potential for likely significant effects in the Revised WSP HRA. It proceeds to the Appropriate Assessment stage without proper screening and without consideration of the relevant traffic modelling undertaken for the Airports Commission which has been relied upon elsewhere in the air quality work of both the Airports Commission and the Government. S6. Furthermore, the Revised HRA does not take into account the air quality modelling provided in Appendix 3 of this report (as originally submitted to the DfT in May 2017). This shows clearly that the air quality effects from LGW-2R at the MGRE SAC are not significant and should be screened out, S7. The purpose of this report is to undertake the screening stage of the HRA process for the LGW-2R scheme because it has not been undertaken robustly in the WSP HRA. Revised Habitats Regulations Assessment Screening December 2017 i rpsgroup .com /uk S8. All European sites considered within the Revised WSP HRA and/or Airports Commission studies for LGW-2R have been included (MGRE SAC, Ashdown Forest SAC and Ashdown Forest SPA). The nearest part of any European protected site is approximately 10km (MGRE SAC) from Gatwick airport or any work or associated development likely to be required in connection with the scheme. S9. In common with the previous work on behalf of GAL, the Airports Commission and the Revised WSP HRA, this RPS report concludes that there are no likely significant effects on these European sites by direct effects, either alone or in-combination with other projects. That includes any potential effects during construction or operation by virtue of land take; habitat fragmentation; aerial emissions from airport operations or aircraft; aqueous emissions; noise and vibration; or lighting. S10. The accepted best practice HRA screening process for aerial emissions from road traffic is to follow the methodology set out in the DMRB and accompanying guidance. There are two stages. First, scoping criteria are identified e.g. requiring only roads where there is a traffic increase of more than 1000 vehicles (Annual Average Daily Traffic)(AADT) to be considered. Second, if these criteria are exceeded, the air quality impact from the traffic increase is calculated. Only if the expected increase in -3 oxides of Nitrogen (NOx) are greater than 0.4µg.m is an assessment of the significance of effects by an ecologist required. S11. The traffic effects of the LGW-2R scheme were assessed by Jacobs using the traffic modelling produced in 2015 for the three shortlisted alternatives for the Airports Commission. The approach to this modelling was stated at the time to be in line with the ‘high end demand scenario for each of its schemes, which demonstrated the greatest likely air quality impacts consistent with plausible worst case air traffic and surface transport movements’1. This traffic modelling has been relied upon to underpin all of the Airports Commission and Government assumptions to date for both the preferred LHR-NWR and the short-listed alternatives. These assumptions continue to be relied upon by the DfT