CHAPTER 8.0 CULTURAL HERITAGE

8.0 CULTURAL HERITAGE ...... 8-1 Introduction ...... 8-1 Legislation, Policy and Guidance ...... 8-2 Consultation ...... 8-11 Parameters Used for Assessment ...... 8-18 Assessment Methodology ...... 8-19 Baseline ...... 8-31 Incorporated Mitigation ...... 8-49 Additional Mitigation ...... 8-68 Residual Effects ...... 8-70 Summary ...... 8-70

FIGURES (bound separately in Volume 2) Figure 8.1 ...... Non-Designated Heritage Assets within 1km of the Site Figure 8.2 ...... Designated Heritage Assets within 2km of the Site and ...... Ditton Conservation Area Figure 8.3 ...... Designated Heritage Assets within Aylesford Conservation Area Figure 8.4 ...... Selected Heritage Assets Beyond 2km from the Site Figure 8.5 ...... Extract from Ordnance Survey map, 1897 Figure 8.6 ...... Historic Landscape Character Types

APPENDICES (bound separately in Volume 3) Appendix 8-1 ...... Cultural Heritage Plates Appendix 8-2 ...... Site Gazetteer Appendix 8-3 ...... Summary of Heritage Assets Excluded from Further Assessment

Please note that a full list of acronyms is provided in the context to this PEIR and should be referred to when reading this Chapter.

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Introduction

8.1.1 This Chapter provides an assessment of the likely significant effects of the construction, decommissioning and operational phases of the Proposed Extension upon archaeological and Cultural Heritage Assets (Assets). This includes the effects upon the setting of Assets which may result from the Proposed Extension.

8.1.2 Each Asset referred to within this Chapter is listed in Appendix 8-2 (Gazetteer). The location of the Assets contained within the Appendix 8-2 are also illustrated on Figures 8.1 to 8.4.

Competence

8.1.3 AOC Archaeology Group is a Registered Organisation of the Chartered Institute for Archaeologists (CIfA), which ensures that there is regular monitoring and approval by external peers of internal systems, standards and skills development.

8.1.4 AOC Archaeology Group conforms to the standards of professional conduct outlined in the CIfA’s Code of Conduct1, Standard and Guidance for Historic Environment Desk Based Assessment2 and Standard and Guidance for Commissioning Work or Providing Consultancy Advice on the Historic Environment3

8.1.5 In addition, AOC is ISO 9001:2015 accredited, in recognition of the Company’s Quality Management System.

1 CIfA (2014). Chartered Institute for Archaeologists' (CIfA) Code of Conduct (available at: https://www.archaeologists.net/sites/default/files/CodesofConduct.pdf ) 2 CIfA (2017). Standard and guidance for historic environment desk-based assessment The Chartered Institute for Archaeologists (available at: http://www.archaeologists.net/sites/default/files/CIfAS%26GDBA_3.pdf ) 3 CIfA 2014b Standard and guidance for Commissioning Work or Providing Consultancy Advice on the Historic Environment. The Chartered Institute for Archaeologists (available at: http://www.archaeologists.net/sites/default/files/CIfAS&GCommissioning_1.pdf )

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Legislation, Policy and Guidance

8.2.1 Where any development may have a direct or indirect effect on designated Assets, there is a legislative framework to ensure the proposals are considered with due regard for their impact on the historic environment. This Section outlines the legislative framework and national, local and regional planning policy and guidance.

Legislation

8.2.2 Statutory protection for archaeology is outlined in the Ancient Monuments and Archaeological Areas Act 1979 as amended by the National Heritage Act 1983. A schedule of nationally important archaeological sites subject to legal protection is maintained by Historic England (HE), which is a statutory consultee in the planning process.

8.2.3 Listed Buildings and Conservation Areas receive protection under the Planning (Listed Buildings and Conservation Areas) Act 1990.

National Policy

National Policy Statements

8.2.4 As outlined in Chapter 3, the relevant National Policy Statements (NPSs) provide the primary basis for decisions by the Secretary of State (SoS) on Nationally Significant Infrastructure Projects.

8.2.5 Section 5.8 of NPS EN-1, ‘Overarching National Policy Statement for Energy’ sets out the policy position for the assessment of impacts on the heritage environment in relation to nationally significant infrastructure projects. It sets out the following requirements of relevance to the assessment of the Proposed Extension: • Paragraph 5.8.2 of the NPS states that “The historic environment includes all aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, landscaped and

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planted or managed flora. Those elements of the historic environment that hold value to this and future generations because of their historic, archaeological, architectural or artistic interest are called “heritage assets”. A heritage asset may be any building, monument, site, place, area or landscape, or any combination of these. The sum of the heritage interests that a heritage asset holds is referred to as its significance”. • The NPS EN-1 states that “as part of the ES, the applicant should provide a description of the significance of the heritage assets affected by the proposed development and the contribution of their setting to that significance. The level of detail should be proportionate to the importance of the heritage assets and no more than is sufficient to understand the potential impact of the proposal on the significance of the heritage asset.” • Para. 5.8.4 of the NPS states that Assets which are demonstrably of equivalent significance should be considered subject to the same policy considerations. As such NPS recognises that “There are heritage assets with archaeological interest that are not currently designated as scheduled monuments, but which are demonstrably of equivalent significance”. • Para. 5.8.6 of the NPS states that “Potential impacts on other non- designated heritage of lesser value than designated heritage should also be considered by the Secretary of State, on the basis of “clear evidence that the assets have a heritage significance that merits consideration in its decisions”. • Para. 5.8.14 states “There should be a presumption in favour of the conservation of designated heritage assets and the more significant the designated heritage asset, the greater the presumption in favour of its conservation should be. Once lost heritage assets cannot be replaced and their loss has a cultural, environmental, economic and social impact. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Loss affecting any designated heritage asset should require clear and convincing justification. Substantial harm to or loss of a grade II listed building park or garden should be exceptional. Substantial harm to or loss of designated assets of the highest significance, including Scheduled Monuments; registered battlefields; grade I and II* listed buildings; grade I and II* registered parks and gardens; and World Heritage Sites, should be wholly exceptional.”

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8.2.6 NPS EN-3, ‘Overarching National Policy Statement for Renewable Energy Infrastructure’, outlines the impact assessment principles relevant to biomass/waste combustion plant applications. In relation to significant adverse effects to nationally recognised designations, consent for renewable energy projects should only be granted ‘‘Where it can be demonstrated that the objectives of designation of the area will not be compromised by the development, and any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by the environmental, social and economic benefits” (para. 2.5.33).

8.2.7 EN-3 continues at paragraph 2.5.34 to states that the decision taker should take into account the: “positive role that large-scale renewable projects play in the mitigation of climate change, the delivery of energy security and the urgency of meeting the national targets for renewable energy supply and emissions reductions” in determining whether the substantial public benefits of a proposed development outweigh any loss or harm to the significance of a Designated Asset.

8.2.8 It is considered that this Chapter fully addresses the requirements of the NPSs.

The National Planning Policy Framework (NPPF)

8.2.9 The National Planning Policy Framework (NPPF) was published by the Ministry of Housing Communities and Local Government (MHCLG) in March 2012 and updated in July 2018 and again in February 2019. The NPPF sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally prepared plans for development should be produced and assessed. Chapter 16 of the document is concerned with ‘Conserving and enhancing the historic environment’. It identifies Assets as ‘an irreplaceable resource’ and notes that ‘they should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations’4.

4 MHCLG. (2019) National Planning Policy Framework Paragraph 184. (Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/810197/NPPF_Feb_2 019_revised.pdf)

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8.2.10 In relation to determining planning applications, the NPPF states that ‘local planning authorities should require an applicant to describe the significance of any Assets affected, including any contribution made by their setting. The level of detail should be proportionate to the Assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance5.

8.2.11 Where Designated Assets are concerned great weight should be given to the Asset’s conservation. The more important the Asset the greater the weight should be. Any harm to or loss of significance should require ‘clear and convincing justification. Substantial harm to or loss of: 1. grade II listed buildings or grade II registered parks or gardens should be exceptional; 2. assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional’6

8.2.12 Where proposals are predicted to lead to substantial harm or the total loss of significance to a Designated Asset paragraph 195 states that ‘local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss’. Where ‘a development proposal will lead to less than substantial harm to the significance of a designated asset’ paragraph 196 states that ‘this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’7.

8.2.13 Impacts upon non-designated Assets are also a pertinent planning consideration. Paragraph 197 states: ‘In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset’8.

5 Ibid, para189. 6 Ibid, para 194. 7 Ibid 8 ibid

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8.2.14 Where an Asset is to be lost, either in part or in whole, as a result of the development, the local planning authority should require developers to ‘record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence (and any archive generated) publicly accessible’9.

Local Planning Policy

Kent Minerals and Waste Local Plan 2013-2030

8.2.15 The Kent Minerals and Waste Local Plan10 was adopted in 2016. Policies DM 5 and DM 6, below, are relevant to this assessment.

Policy DM 5: Heritage Assets – “Proposals for minerals and waste developments will be required to ensure that Kent's heritage assets and their settings, including locally listed heritage assets, registered historic parks and gardens, Listed Buildings, conservation areas, World Heritage Sites, Scheduled Ancient Monuments, archaeological sites and features and defined heritage coastline,(110) are conserved in a manner appropriate to their significance. Proposals should result in no unacceptable adverse impact on Kent's historic environment and, wherever possible, opportunities must be sought to maintain or enhance historic assets affected by the proposals. Minerals and/or waste proposals that would have an impact on a heritage asset will not be granted planning permission unless it can be demonstrated that there is an overriding need for development and any impacts can be mitigated or compensated for, such that there is a net planning benefit.”

Policy DM 6: Historic Environment Assessment – “Proposals for minerals and waste development that are likely to affect important heritage assets will only be granted planning permission following: 1. preliminary historic environment assessment, including field archaeological investigation where appropriate, to determine the nature and significance of the heritage assets

9 Ibid, para 199. 10 Kent County Council, adopted 2016. Kent Minerals and Waste Local Plan 2013-2030.

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2. appropriate provision has been secured for preservation in situ, and/or archaeological excavation and recording and/or other historic environment recording as appropriate, including post-excavation analysis and reporting, archive deposition and access, and interpretation of the results for the local community, in accordance with the significance of the finds 3. agreement of mitigation of the impacts on the significance of the heritage assets, including their fabric, their setting, their amenity value and arrangements for reinstatement Tonbridge and Malling Borough Council Local Development Framework

8.2.16 The Tonbridge and Malling Borough Council (TMBC) Local Development Framework (LDF) presently comprises a suite of documents, which include: the Managing Development and the Environment Development Plan Document (adopted April 2010); the Core Strategy (adopted September 2007); and the Development Land Allocations DPD (adopted April 2008).

8.2.17 Cultural heritage is dealt with by specific policies contained within the Managing Development and the Environment Development Plan Document. Although the document defers to national planning policy for matters relating to statutorily designated Assets, the following policies relating to Locally Designated Assets are pertinent to this assessment:

POLICY SQ2: Buildings included within the Local List of Buildings of Architectural or Historic Interest adopted by the Council will be retained wherever possible and protected from development that would harm their setting or local historic or architectural interest.11

POLICY SQ3: Development will not be permitted where it would harm the overall character, integrity or setting of the Historic Parks and Gardens identified on the Proposals Map and listed in Annex SQ3, or which might prejudice their future restoration.12

11 Tonbridge and Malling Borough Council. (2010). Managing Development and the Environment Development Plan Document, 45. 12 Ibid., 46.

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8.2.18 A small portion of the southwestern corner of the Site lies within the administrative area of Maidstone Borough Council (MBC). The Maidstone Borough Local Plan was adopted in October 2017 and Policy SP 18 sets out the local authority’s approach to the historic environment.

Policy SP 18: The Historic Environment - To ensure their continued contribution to the quality of life in Maidstone Borough, the characteristics, distinctiveness, diversity and quality of heritage assets will be protected and, where possible, enhanced. This will be achieved by the council encouraging and supporting measures that secure the sensitive restoration, reuse, enjoyment, conservation and/or enhancement of heritage assets, in particular designated assets identified as being at risk, to include: i. Collaboration with developers, landowners, parish councils, groups preparing neighbourhood plans and heritage bodies on specific heritage initiatives including bids for funding; ii. Through the development management process, securing the sensitive management and design of development which impacts on heritage assets and their settings; iii. Through the incorporation of positive heritage policies in neighbourhood plans which are based on analysis of locally important and distinctive heritage; and iv. Ensuring relevant heritage considerations are a key aspect of site master plans prepared in support of development allocations and broad locations identified in the local plan.13

Emerging Local Planning Policy

8.2.19 A new Tonbridge and Malling Local Plan was submitted to the Planning Inspectorate for examination in January 2019. Once adopted, this document will replace the current suite of documents forming the LDF. Proposed Policy LP11 (Designated Areas) represents a commitment to follow national planning policy in relation to the historic environment: 1. For the following listed designations, as illustrated or defined on the proposals map, the Council will apply the relevant policy in the National

13 Maidstone Borough Council (2017). Maidstone Borough Local Plan, 72-73

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Planning Policy Framework or whatever represents the relevant national planning policy at the time the planning application is determined. • Special Areas of Conservation (SAC) • Sites of Special Scientific Interest (SSSIs) • Green Belt • Historic Parks & Gardens • Scheduled Ancient Monuments • Conservation Areas • Areas at risk of flooding

2. For listed buildings and ancient woodland the Council will apply the policy in the National Planning Policy Framework or whatever represents the relevant national planning policy at the time the planning application is determined. 3. If a development proposal is in conflict with the relevant national policy then it will be in conflict with this Policy.14

8.2.20 A Conservation Area Appraisal has been prepared for the Holtwood Conservation Area, which was adopted by TMBC in 201115. No Conservation Area Appraisals appear to have been prepared for Aylesford or Boxley Abbey Conservation Areas or for Ditton Conservation Area.

Guidance

8.2.21 Planning Practice Guidance on the historic environment was published in April 2014 by the Ministry of Housing Communities and Local Government to expand upon the policies contained within the NPPF and it was last updated in July 2019. The guidance on harm to the significance of Assets resulting from impacts upon their setting is of most relevance to this assessment. Paragraph 18 Reference ID: 18a-018-20190723 (Revision date: 23 07 2019) of the updated guidance states: “What matters in assessing whether a proposal might cause harm is the impact on the significance of the heritage asset. As the National

14 Tonbridge and Malling Borough Council (2019). Tonbridge and Malling Borough Council Local Plan: Regulation 22 Submission, January 2019, 22-23. 15 Tonbridge and Malling Borough Council (2011). Holtwood Conservation Area: Conservation Area Appraisal, adopted November 2011.

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Planning Policy Framework makes clear, significance derives not only from a heritage asset’s physical presence, but also from its setting16.”

8.2.22 In December 2017, Historic England (HE) published a guidance document on setting as part of their Good Practice Advice Notes intended to explain how to apply the policies contained in the NPPF. It states: “Setting is not itself a heritage asset, nor a heritage designation, although land comprising a setting may itself be designated. Its importance lies in what it contributes to the significance of the heritage asset or to the ability to appreciate that significance.”17.

8.2.23 The HE guidance sets out the ways in which setting may contribute to the value of an Asset. It advocates a five stage approach, comprising: • the identification of the Assets; • an assessment of the contribution of setting to the Asset’s value; • an assessment of potential effects upon the setting (and thus the value of the Asset) by a proposed development/change; • an exploration of potential enhancement and/or mitigation measures; and • to make, document and monitor the outcomes of the decision made.18

8.2.24 This guidance provides a checklist of potential attributes of setting which may contribute to or make appreciable the value of the Asset in question. HE acknowledges that the checklist is non-exhaustive and that not all attributes will apply in all cases.

8.2.25 This assessment has regard to this checklist but, in the interests of proportionality, only discusses attributes of setting where these are found to contribute to the value of an Asset.

8.2.26 In relation to the fourth bullet above, in many cases effects upon setting are ‘less than substantial’ and are not significant. As such, it is not always necessary or appropriate to propose mitigation or enhancement measures as outlined by

16 Ministry of Housing, Communities and Local Government (MHCLG). 2019. Planning Practice Guidance (available at https://www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment) 17 Historic England (2017). Good Practice Advise Note 3, Second Edition: Setting, 4. 18 Historic England (2017). Good Practice Advice Note 3: Setting, 8.

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this approach. Where relevant, mitigation and enhancement measures are identified as part of this assessment.

8.2.27 The final bullet point set out in the HE guidance above does not apply to this assessment as the monitoring of decision outcomes can only be undertaken once a planning decision has been made.

Consultation

8.3.1 A Scoping Report was submitted to PINS who act on behalf of the SoS on the 14th November 2019 (Appendix 6-1) and The Planning Inspectorate produced a Scoping Opinion (Appendix 6-2) which was adopted by the SoS on 24th December 2019. Further consultation has also subsequently been undertaken directly with HE, Kent County Council (KCC), Tonbridge and Malling Borough Council (TBMC) and Maidstone Borough Council (MBC).

8.3.2 A summary of relevant points made within the Scoping Opinion and through direct consultation are provided in Table 8.1, which also identifies where these points are addressed in this Chapter.

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Table 8.1: Summary of Issues Raised During Consultation

Consultee Comment Response to Consultation

Scoping Responses

The Planning In Section 4.1, ID 4.1.1 of the Scoping Opinion, the Inspectorate agrees This assessment has scoped out direct and cumulative impacts Inspectorate that direct and cumulative effects on upon upstanding and buried archaeology. th (24 upstanding and buried archaeology can be scoped out of the ES due to December it being unlikely that significant effects to buried and upstanding 2019) archaeology will occur as the Proposed Development is located on a disused quarry and: “any archaeological remains which may have been present will have been removed”, as stated in Scoping Report Paragraph 6.2.7.

In Section 4.1, ID 4.1.2, of the Scoping Opinion the Inspectorate does Impacts upon the setting of Assets during the construction not agree that this matter [impacts upon the setting of Assets during the phase have been considered as part of this assessment and are Construction Phase] can be scoped out of the ES as insufficient evidence presented in Section 8.7. is presented in the Scoping Report to support the Applicant’s view that that no significant effects to Assets and historic landscapes will arise during the construction phase.

In Section 4.1, ID 4.1.3, of the Scoping Opinion the Inspectorate states The Study Area is depicted in Figures 8.1 to 8.4 and has been that the Study Area should be clearly depicted on plans and diagrams agreed as appropriate with relevant consultees as outlined, where appropriate and should be fully justified within the ES based on below, in this table. guidance, best practice and consultation with relevant consultation bodies.

In Section 4.1, ID 4.1.4, of the Scoping Opinion the Inspectorate states Conservation Areas and other Designated Assets within the that information regarding nearby and likely to be affected Conservation agreed Study Area and selected Designated Assets beyond the Areas and an up to date list of Designated Assets should be included in Study Area are depicted in Figures 8.2 to 8.4. the ES. The ES should also include updated figures depicting the Spatial information for Scheduled Monuments, Listed Buildings, locations of the Conservation Areas and the Designated Assets relevant Registered Parks and Gardens and Registered Battlefields was to the assessment of impacts from the Proposed Development.

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Consultee Comment Response to Consultation

downloaded from HE’s Listing Data Download Area19 in August 2019 for production of the Scoping Report; this data was then checked in February 2020 during the production of this Chapter to identify any changes, and was checked again in June 2020 before submission. Similarly, information on Conservation Areas, including boundary maps and Conservation Area Character Appraisals, where available, were accessed via the Tonbridge and Malling and Maidstone Borough Council websites in August 2019 and again in February 2020, and was checked again in June 2020 before submission. Information on Non-designated Assets, including Locally Listed Buildings and Historic Parks and Gardens, was received from KCC Historic Environment Record (HER) on 31st July 2019.

In Section 4.1, ID 4.1.5, of the Scoping Opinion the Inspectorate states Full details of the Zone of Theoretical Visibility (ZTV) production that a description of the GIS analysis, ZTV mapping, and site visits, are set out in Chapter 09, Landscape and Visual. including meteorological conditions, should be included in the ES, as well A discussion of how GIS analysis and site visits have been used as an explanation of how the aforementioned methods have been utilised to establish the current setting of Assets and how this to determine the current setting and cultural value of the Assets. contributes to their cultural heritage value are discussed below in paragraphs 8.5.2 to 8.5.6. Details of the methodology used for the site visits, including the dates of visits and meteorological conditions are set out in paragraphs 8.5.7 and 8.5.8.

In Section 4.1, ID 4.1.6, of the Scoping Opinion the Inspectorate states A detailed methodology is set out in Section 8.5. that the ES should include a detailed description of the criteria used to The methodology (as set out in the Scoping Report) has been determine the: agreed with HE, KCC’s Conservation Officer, MBC • Significance of the Asset;

19 https://services.historicengland.org.uk/NMRDataDownload/default.aspx

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Consultee Comment Response to Consultation

• Sensitivity of the Asset; Conservation Officer and TMBC Planning Policy Officer, as • Magnitude of the impact; and detailed below. • The significant effect level. The Applicant should make effort to agree the proposed methodology with the relevant consultation bodies.

In Section 4.1, ID 4.1.7 of the Scoping Opinion the Inspectorate states Section 8.8 sets out additional mitigation measures (e.g. those that the ES should include a detailed description of all required mitigation beyond incorporated mitigation that may be required). Section measures, the likely efficacy of the measures and how they will be 8.9 identifies residual effect, following the implementation of secured through the DCO or other legal mechanism. additional mitigation.

In Section 4.1, ID 4.1.8, of the Scoping Opinion the Inspectorate states Consideration of vehicle movements and their associated effect that it is not clear if vehicle movements and their associated effects such on setting, including noise and emissions have been as noise and emissions to air, will be taken into consideration when considered, where appropriate, in Section 8.6. assessing effects on Assets. The ES should assess impacts to Assets arising from vehicle movements where significant effects are likely to occur.

Historic HE was consulted on the appropriateness of the proposed Study Area A 2km Study Area has been used to identify Assets which could England and impact assessment methodology following the note in the Scoping potentially be subject to setting effects. ZTV mapping has further Opinion, that these should be agreed with consultees wherever possible. been examined to identify selected Assets beyond 2km which HE provided a response via email on 29th January 2020 advising that may be particularly sensitive to setting effects. they were content with a 2km Study Area for identifying Assets which Effects upon the setting of Assets during the construction and would potentially be subject to setting effects and were content with the operation phase are considered in Section 8.6. proposed methodology as set out in the Scoping Report. The proposed methodology set out in the Scoping Report is fully detailed in Section 8.5.

Kent County The KCC Conservation Officer was consulted on the appropriateness of As above. Council the proposed Study Area and impact assessment methodology following Heritage the note in the Scoping Opinion, that these should be agreed with consultees wherever possible.

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Consultee Comment Response to Consultation

Conservation The KCC Conservation Officer provided a response via email on 23rd Team January 2020 advising that they were content with a 2km Study Area for identifying Assets which would potentially be subject to setting effects and were content with the proposed methodology as set out in the Scoping Report.

The KCC Archaeology Officer provided a consultation response to the This PEIR chapter does not consider the potential for impacts Statement of Community Consultation (SoCC) on the 3rd June 2020. This upon buried archaeological remains of a Palaeolithic nature as consultation noted that KCC considered that there is unlikely to be highly per the agreement by PINS to scope this topic out. significant archaeological issues for this scheme due to the level of The Proposed Extension lies within an area previously subject historic disturbance, development and quarrying on the site over the to quarrying and which was later used for landfill. The Proposed preceding century. KCC further agrees that there are unlikely to be Extension also lies wholly within the site of the Existing Station. archaeological remains. They however note that they consider that there Given that any Palaeolithic remains would have been located is still a need to ensure that there is a suitable specialist assessment above or at the interface with the Ragstone it is unlikely that any undertaken, with provision for fieldwork if deposits with potential are such remains survive on the Site. The western portion of the Site encountered. Palaeolithic issues are unlikely to affect the further detailed does not appear to have been subject to quarrying, however design issues being discussed at this stage, but provision will need to be only reprofiling of bunds and associated earthworks are planned made for archaeological fieldwork. KCC does not consider Prehistoric in this part of the Site. This will not require any ground reduction, archaeology potential as a major issue for the current consultation, but it but rather a building up of level. As such in line with the proposal should be considered at a later stage. to scope this topic out of the assessment, and agreement of this by PINS, further consideration is not given here.

KCC Archaeology Officer noted that there will be consideration of the The Scoping Report noted that impacts upon the setting of all impact of this scheme on the setting of Assets, but not including Designated Assets, regardless of whether they were archaeological sites. KCC Archaeology Officer would like to clarify that archaeological in nature or built heritage, would be considered. there are some archaeological sites which should be included in the Impacts upon the setting of Kits Coty Neolithic Monuments, assessment of Assets such as Kits Coty Neolithic monuments, Boxley Aylesford Conservation Area and Bridge and Boxley Abbey are Abbey, Aylesford historic town and bridge. There are also some known considered in Section 8.5 of this Chapter. pill boxes close to the Site and there should be some consideration of Consideration of impacts upon non-designated pill boxes is the impact on the setting of these non-designated structures. made in Section 8.7 at the request of KCC.

Maidstone The MBC Conservation Officer was consulted on the appropriateness of As above. Borough the proposed Study Area and impact assessment methodology following

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Consultee Comment Response to Consultation

Council the note in the Scoping Opinion, that these should be agreed with Conservation consultees wherever possible. Officer The MBC Conservation Officer provided a response via email on 23rd January 2020 advising that they were content with a 2km Study Area for identifying Assets which would potentially be subject to setting effects and were content with the proposed methodology as set out in the Scoping Report.

Tonbridge & TMBC do not have a dedicated Conservation Officer but the Planning The potential for impacts upon the setting of Preston Hall (Site Malling Department was consulted on the appropriateness of the proposed 8) have been considered, however, a detailed assessment has Borough Study Area and impact assessment methodology following the note in not been undertaken due to the lack of intervisibility with the Council the Scoping Opinion that these should be agreed with consultees Proposed Extension. Full justification for this is set out in wherever possible. Appendix 8-3. TMBC Senior Planning Policy Officer provided a response via email on The potential for impacts upon the character and setting of 31st January 2020 advising that they concurred with the comments made Holtwood Aylesford (Site 114) and Aylesford Conservation Area by the MBC Conservation Officer (as set out above) and were therefore (Site 113), and Designated Assets therein, have been content with a 2km Study Area for identifying Assets which would considered. However, a detailed assessment of Holtwood potentially be subject to setting effects and were content with the Aylesford has not been included due to a lack of intervisibility proposed methodology as set out in the Scoping Report. with the Proposed Extension. Full justification for this is set out TMBC particularly highlighted the Listed Building at Preston Hall and the in Appendix 8-3. Impacts upon the setting of Aylesford Conservation Areas of Aylesford and Ditton. Conservation Area are considered in Section 8.7. In their consultation response on the Landscape and Visual Assessment Ditton Conservation Area (Site 253) is located beyond the 2km (via email dated 31st January 2020) the TMBC Planning Policy Officer Study Area but consideration of impacts upon its setting and requested that consideration be given to providing viewpoints from character have been included at the request of TMBC. This Boxley Abbey (Site 2) and St Andrew’s Chapel (Site 110). assessment is set out in paragraphs 8.6.44 to 8.6.45 and 8.7.60 to 8.7.61. Discussion on the viewpoints proposed by TMBC is provided in Chapter 09, Landscape and Visual. Assessment of impacts upon the setting of Boxley Abbey (Site 2) is presented in Paragraphs 8.6.25 to 8.6.26 and 8.7.25 to 8.7.27.

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Consultee Comment Response to Consultation

Consideration of the potential for impacts upon the setting of St Andrew’s Chapel (Site 110) have been considered. However, a detailed assessment has not been included due to lack of intervisibility with the Proposed Extension. Full justification for this is set out in Appendix 8-3.

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Parameters Used for Assessment

8.4.1 The overall approach to the use of the Rochdale Envelope and the parameters that have been assumed for the assessment of likely significant environmental effects arising from the Proposed Extension is set out in Chapter 5.0 of this PEIR. Those parameters have been used, where relevant, to inform the assessments in each topic specific Chapter of this PEIR.

8.4.2 In order to provide a robust assessment, each topic specific Chapter has been prepared on a reasonable worst-case scenario for that given topic. This being the worst-case scenario that could reasonably be expected to occur within each of the parameters set. The reasonable worst-case scenario for each topic differs depending upon the assessments being undertaken. However, all assessments have been undertaken within the broadest reasonable applicable parameters, to ensure the assessment is precautionary in its approach.

8.4.3 With regard to Cultural Heritage, the reasonable worst-case scenario for the Proposed Extension has been based upon the following assumptions: • A tower crane (height approximately 103m and therefore the tallest, and hence most visible item of plant) would be present at the Site for a nineteen month period (between months 15 and 34 of the construction phase), with mobile cranes also present for a further six month period towards the end of the construction period. Cranes would also be visible for a brief (approximately six-week period) during the dismantling of the existing Stack; • The existing Stack and the Shared Stack will be visible together for a period of 25 months; • that the height and positioning of the proposed Shared Stack are fixed at 90m above the platform level; • the height of the lower stack ladder and Continuous Emission Monitoring System (CEMS) are not fixed but will not exceed 44m above the platform level. • the height of the Boiler House roof is at 37m above the platform level; and • the height of the rooftop equipment is not fixed but not expected to exceed 5m above the Boiler House roof (in line with the schedule of parameters).

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8.4.4 The reason that this is considered to represent the reasonable worst case assessment scenario for the assessment of Cultural Heritage is that it would be these elements of the Proposed Extension which may be visible from Designated Assets within the Study Area and, as such, it is these elements which have the potential to contribute to effects upon the setting of these Assets. While other parameters might not be fixed, these relate to elements which are located at lower levels of the Proposed Extension. Given the distances between the Proposed Extension and the Assets assessed and the intervening built environment these elements of the Proposed Extension would not be visible from the Assets and, as such, variations to their parameters would not affect the settings of the Assets.

Assessment Methodology

Methodology

8.5.1 This assessment of cultural heritage effects has been undertaken in accordance with current planning policy and guidance set out in accordance with UK Government 2017 Regulations20. This assessment conforms to the standards of professional conduct outlined in the Chartered Institute for Archaeologists' Standards and Guidance.

Study Area

8.5.2 In order to establish a historic environmental baseline, understand the context of the Site, and assess the potential for significant effects on Assets resulting from the Proposed Extension a Study Area has been established as follows: • All Designated Assets within 2km of the Site, which include: Scheduled Monuments; locally and statutorily Listed Buildings; Conservation Areas; Protected Military Remains; locally designated Historic Parks and Gardens; and • Designated Assets along the proposed Grid Connection route, which extends beyond the 2km Study Area in places; and All Non-designated

20 Town and Country Planning. (2017). 2017 No. 571 The Town and Country Planning (Environmental Impact Assessment) Regulations 2017

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Assets recorded within 1km of the Site by the Kent Historic Environment Record (HER).

8.5.3 These Study Areas were determined to be sufficient to develop the heritage baseline based on the size of the Site, the type and height of the Proposed Extension, the coverage of the ZTV and the nature of the Assets within the surrounding area; along with the character of the location of the Site within an urban and industrial area north of Maidstone. The appropriateness of these Study Areas was agreed with the relevant consultees (see Table 8.1 above)

8.5.4 Consideration has also been given to the likely impact of the Proposed Extension upon the settings of three selected Scheduled Monuments and one Non-designated Asset located beyond the 2km Study Area, which represent part of group of Neolithic chambered tombs (the ‘Medway Megaliths’): Kit's Coty House Long Barrow (Site 249; List Entry Number: 1012939); Little Kit's Coty House Megalithic Tomb (Site 250; List Entry Number: 1013673); The White Horse Stone (Site 251; List number: 1005181) and the Coffin Stone (Site 252; HER number: TQ 76 SW 7). These all lie within the ZTV and are Assets of a type which are generally particularly sensitive to changes to their settings and as such are included in this assessment.

8.5.5 Consideration has been given to Ditton Conservation Area (Site 253) which is located beyond the 2km Study Area, at the request by TMBC. Consideration has also been given to non-designated pill boxes within the 2km Study Area (Sites 143, 147-151, 155-157, and 191) at the request of KCC Archaeology Officer.

8.5.6 No World Heritage Sites, Registered Battlefields, or Registered Parks and Gardens are located within 2km of the Site and as such the potential for effects upon them are not considered further.

Site Walkover and Settings Assessment

8.5.7 A walkover survey of the Site was conducted on the 23rd October 2019 in order to assess the baseline conditions and potential for heritage constraints within

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the area to the west of the Existing Station where the Proposed Extension would be located.

8.5.8 The settings assessment comprised initial desk-based data gathering, using the sources and covering the agreed Study Area outlined above, to identify Assets which could potentially be subject to effects upon their setting. These Assets were plotted in ArcGIS 10.7.1 to gain an understanding of their distribution in relation to Site and to gain an early understanding of the character of their locations (e.g. urban, industrial, rural). ArcGIS was also used to superimpose ZTV mapping supplied by the LVIA consultant against Assets. This allowed for an identification of those Assets which would have theoretical views of the Proposed Extension. Setting assessment visits to those Assets within the Study Area and within the ZTV were conducted on the 22nd and 23rd of October 2019 in mostly dry and overcast conditions. These site visits aimed to identify the current setting of the Assets and how this contributes to the value of the Assets, this included consideration of the type and function of Assets, their topographical location, the character of the area in which they are set and was largely guided by consideration of, but not limited to, the checklist of potential attributes of setting which may contribute to or make appreciable the value of the Asset in question21.

Significance Criteria

Assessing Cultural Value and Importance

8.5.9 The definition of cultural significance is readily accepted by heritage professionals both in the UK and internationally and was first fully outlined in the Burra Charter, Article One, which identifies that ‘cultural significance’ or ‘cultural heritage value’ means aesthetic, historic, scientific, social or spiritual value for past, present or future generations22. This definition has since been adopted by heritage organisations around the world, including HE. The NPPF23 defines cultural significance as: “The value of a heritage asset to this and future

21 Historic England (2017). Good Practice Advice Note 3: Setting, 8. 22 ICOMOS (1999). Burra Charter Article 1.2. 23 For the definition of ‘significance’ the NPS states at footnote 118 that ‘Save for the term “Designated Heritage Asset (covered in 5.8.3 above), these and other terms used in this section are defined in Annex 2 to PPS5, or any successor to it’ As NPPF is the successor to PPS5, reference has been made to the NPPF.

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generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting.”24

8.5.10 The term ‘cultural value’ will be used throughout this assessment as opposed to ‘cultural significance’, in order to avoid confusion with the concept of a ‘significant effect’ in EIA terms.

8.5.11 All Assets have some value. However, some Assets are judged to be more important than others. The level of that importance is, from a cultural resource management perspective, determined by establishing the Asset’s capacity to inform present or future generations about the past. In the case of many Assets their importance has already been established through the designation (i.e. scheduling, listing and register) processes applied by HE.

8.5.12 The criteria used to establish importance are presented in Table 8.2 and are drawn from the Department of Media, Culture and Sports publication, Principles for Selection of Listed Buildings,25 and the Scheduled Monuments Policy Statements published by the same body,26 which outline the criteria for designating Assets.

24 MHCLG (2019). NPPF, 71. 25 DMCS (2018). Principles for Selection of Listed Buildings. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/757054/ Revised_Principles_of_Selection_2018.pdf 26 DMCS (2013). Scheduled Monuments Policy Statements.

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Table 8.2: Criteria for Establishing Importance Importance Criteria International • World Heritage Sites; and • Scheduled Monuments (Actual and Potential); National • Grade I and II* Listed Buildings; • Grade I and II* Registered Parks and Gardens; • Registered Battlefields; and • Fine, little-altered examples of some particular period, style or type. Regional • Grade II Listed Buildings; • Grade II Registered Parks and Gardens; • Conservation Areas; • Major examples of some period, style or type, which may have been altered; and • Asset types which would normally be considered of national importance that have been partially damaged (such that cultural heritage value has been reduced). Local • Locally Listed Assets; • Lesser examples of any period, style or type, as originally constructed or altered, and simple, traditional sites, which group well with other significant remains, or are part of a planned group such as an estate or an industrial complex; and • Asset types which would normally be considered of regional importance that have been partially damaged or Asset types which would normally be considered of national importance that have been largely damaged (such that their cultural heritage value has been reduced). Negligible • Relatively numerous types of remains; • Findspots or artefacts that have no definite archaeological remains known in their context; and • Asset types which would normally be considered of local importance that have been largely damaged (such that their cultural heritage value has been reduced).

Assessing Sensitivity of Assets to Changes to their Setting

8.5.13 Whilst determining the relative cultural value of an Asset it is essential for establishing its importance, it is widely recognised27 that the importance of an Asset is not the same as its sensitivity to changes to its setting. Thus, in determining effects upon the setting of Assets by a proposed development, both importance and sensitivity to changes to setting need to be considered.

8.5.14 Setting is a key issue in the case of some, but by no means all, Assets. A nationally important Asset does not necessarily have high sensitivity to changes to its setting (relative sensitivity) this may be because its value lies in its other characteristics and its setting is not a factor which contributes demonstrably to

27 Lambrick (2008). Setting Standards: A Review prepared on behalf of the IFA.

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its value. An Asset’s sensitivity refers to its capacity to retain cultural heritage value in the face of changes to its setting. The ability of the setting to contribute to an understanding, appreciation and experience of the Asset and its value also has a bearing on the sensitivity of that Asset to changes to its setting. Assets with high sensitivity will be vulnerable to changes that affect their settings, and even slight changes may reduce their value or the ability of setting to contribute to the understanding, appreciation and experience of the Asset. Less sensitive Assets will be able to accommodate greater changes to their settings without significant reduction in their value, and in spite of such changes the relationship between the Asset and its setting will still be legible.

8.5.15 The criteria for establishing an Asset’s relative sensitivity are outlined in Table 8.3.

Table 8.3: Criteria for Establishing Relative Sensitivity Sensitivity Definition High An Asset whose setting contributes significantly to an observer’s understanding, appreciation and experience of it and its value should be thought of as having High Sensitivity to changes to its setting. This is particularly relevant for Assets whose settings, or elements thereof, contribute directly to their value (e.g. form part of their Evidential and Aesthetic Value28). For example, an Asset which retains an overtly intended or authentic relationship with its setting and the surrounding landscape. These may in particular be Assets such as ritual monuments that have constructed sightlines to and/or from them, or structures intended to be visually dominant within a wide landscape area e.g. castles, tower houses, prominent forts etc. An Asset, the current understanding, appreciation and experience of which, relies heavily on its modern aesthetic setting. In particular an Asset whose setting is an important factor in the retention of its cultural value. Medium An Asset whose setting contributes moderately to an observer’s understanding, appreciation and experience of it and its value should be thought of as having Medium Sensitivity to changes to its setting. This could be an Asset for which setting makes a contribution to value, but whereby its value is derived mainly from its physical evidential values. This could for example include Assets which had an overtly intended authentic relationship with their setting and the surrounding landscape but where that relationship (and therefore the ability of the Assets’ surroundings to contribute to an understanding, appreciation and experience of them and their value) has been moderately compromised either by previous modern intrusion in their setting or the landscape, or where the Asset itself is in such a state of disrepair that the relationship with setting cannot be fully determined. An Asset, the current understanding, appreciation and experience of which, relies partially on its modern aesthetic setting regardless of whether or not this was intended by the original constructors or authentic users of the Asset. An Asset whose setting is a contributing factor to the retention of its cultural value.

28 Historic England (2008). Conservation Principles, 28-29.

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Sensitivity Definition Low An Asset whose setting makes some contribution to an observer’s understanding, appreciation and experience of it and its value should generally be thought of as having Low Sensitivity to changes to its setting. This may be an Asset whose value is mainly derived from its physical evidential values and whereby changes to its setting will not materially diminish our understanding, appreciation and experience of it or its value. This could for example include Assets which had an overtly intended authentic relationship with their setting and the surrounding landscape, but where that relationship (and therefore the ability of the Assets’ surroundings to contribute to an understanding, appreciation and experience of them and their) has been significantly compromised either by previous modern intrusion to its setting or landscape, or where the Asset itself is in such a state of disrepair that the relationship with setting cannot be determined. Marginal An Asset whose setting makes minimal contribution to an observer’s understanding, appreciation and experience of it and its value should generally be thought of as having Marginal Sensitivity to changes to its setting. This may include Assets for which the authentic relationship with their surrounding has been lost, possibly having been compromised by previous modern intrusion, but who still retain cultural value in their physical evidential value and possibly wider historical and communal values.

8.5.16 The determination of an Asset’s sensitivity is first and foremost reliant upon the determination of its setting. The criteria set out in Table 8.3 are intended as a guide. Assessments of individual Assets are informed by knowledge of the asset itself, of the Asset type if applicable, and by undertaking site visits to establish the current setting of the Assets. This allows for the use of professional judgement and each Asset is assessed on an individual basis. It should be noted that individual Assets may fall into a number of sensitivity categories e.g. a country house may have a high sensitivity to alterations within its own landscaped park or garden, but its sensitivity to changes in the wider setting may be less.

8.5.17 In establishing the relative sensitivity of an Asset to changes to its setting, the setting must first be identified. This Chapter outlines a range of factors which are considered when establishing the setting of an Asset and therefore determining its sensitivity. These are used as a guide in assessing each Asset from known records and in the field. In defining these criteria, emphasis will be placed on establishing the current setting of each Asset and how the Proposed Extension would affect it.

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Assessing Magnitude of Change

8.5.18 Determining the magnitude of change caused by the Proposed Extension requires an identification of the change to the setting of any given Asset, and in particular changes to those elements of the setting that inform its cultural value. Table 8.4 outlines the main factors affecting magnitude of change:

Table 8.4: Factors Affecting Magnitude of Change Site Details Importance of detail for assessing magnitude of change 1) Proximity to the Increasing distance of an Asset from the Proposed Extension will, in most Proposed Extension cases, diminish the effects on its setting. 2) Visibility of The proportion of the development that is likely to be intervisible with the development (based Asset, for example due to the relative elevations of the both the Asset and a on visualisations proposed development, will usually directly affect the magnitude of change where appropriate) on its setting. 3) Complexity of The more visually complex a landscape is, the less prominent the Proposed landscape Extension may appear within it. This is because where a landscape is visually complex the eye can be distracted by other features and will not focus exclusively on the Proposed Extension. Visual complexity describes the extent to which a landscape varies visually and the extent to which there are various land types, land uses, and built features producing variety in the landscape. 4) Visual This refers to the existence of features (e.g. tree belts, forestry, landscaping obstructions or built features) that could partially or wholly obscure the Proposed Extension from view.

8.5.19 It is acknowledged that Table 8.4 primarily deals with visual factors affecting setting. Whilst the importance of visual elements of settings, e.g. views, intervisibility, prominence etc, are clear, it is also acknowledged that there are other, non-visual factors which could potentially result in setting effects. Such factors could be other sensory factors, e.g. noise or smell, or could be associative. In coming to a conclusion about magnitude of change upon setting, this assessment will make reference to traffic, noise, air quality, and landscape and visual assessments, as appropriate.

8.5.20 Once the above has been considered, the prediction of magnitude of change in setting is based upon the criteria set out in Table 8.5. In applying these criteria, particular consideration will be given to the relationship between the Proposed Extension and those elements of setting which have been qualitatively defined as most important in contributing to the value of the Asset and the ability to understand, appreciate and experience it and its value.

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Table 8.5 Criteria for Classifying Magnitude of Change in Setting Magnitude Criteria High • Direct and substantial change in view affecting a significant sightline to or from a ritual monument or prominent fort; • Direct and substantial change in view affecting a key ‘designed-in’ view or vista from a Designed Landscape or Listed Building; • Direct severance of the relationship between an Asset and its setting; • Major imposition within a Cultural Landscape; • A change that alters the setting of an Asset such that it threatens the protection of the Asset and the understanding of its cultural value. Medium • Oblique change in view affecting an axis adjacent to a significant sightline to or from a ritual monument but where the significant sightline of the monument is not obscured; • Oblique change in view affecting a key ‘designed-in’ view or vista from a Designed Landscape or Listed Building; • Partial severance of the relationship between an Asset and its setting; • Notable alteration to the setting of an Asset but not directly affecting those elements of the setting which contribute most to the understanding of the cultural value of the Asset; • Notable, but not major, imposition within a Cultural Landscape; • A change that alters the setting of an Asset such that the understanding of the Asset and its cultural value is marginally diminished. Low • Peripheral change in view affecting a significant sightline to or from a ritual monument, designed landscape or building; • Minor imposition within a Cultural Landscape; • A change that alters the setting of an Asset, but where those changes do not materially affect an observer’s ability to understand, appreciate and experience the Asset or its value. Marginal • All other changes to setting None • No setting changes

Assessing Level of Effect on Setting

8.5.21 The level of effect resulting from changes in the setting of Assets is judged to be the interaction of the Asset’s sensitivity (Table 8.3) and the magnitude of the change (Table 8.5) and also takes into consideration the importance of the Asset (Table 8.2). In order to provide a level of consistency the assessment of sensitivity, the prediction of magnitude of change and the assessment of level of effect have been guided by pre-defined criteria. A qualitative descriptive narrative is also provided for each Asset to summarise and explain each of the professional value judgements that have been made in reaching a conclusion on sensitivity of the Asset and the magnitude of change.

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8.5.22 The interactions that guide the determination of level of effect on settings of the Assets in question is shown in Table 8.6.

Table 8.6: Level of Effect on the Setting of Assets Magnitude of Change Relative Sensitivity Marginal Low Medium High High Minor Minor- Moderate Major Moderate Medium Negligible Minor Minor- Moderate Moderate Low Neutral Negligible Minor Minor- Moderate Marginal Neutral Neutral Negligible Minor The levels of effect recorded in grey highlighted cells are considered ‘significant’ in EIA terms.

Harm

8.5.23 NPS EN-1 sets out policy tests in relation to harm to Designated Assets. It states that: “There should be a presumption in favour of the conservation of designated heritage assets and the more significant the designated heritage asset, the greater the presumption in favour of its conservation should be. Once lost heritage assets cannot be replaced and their loss has a cultural, environmental, economic and social impact. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. Loss affecting any designated heritage asset should require clear and convincing justification. Substantial harm to or loss of a grade II listed building park or garden should be exceptional. Substantial harm to or loss of designated assets of the highest significance, including Scheduled Monuments; registered battlefields; grade I and II* listed buildings; grade I and II* registered parks and gardens; and World Heritage Sites, should be wholly exceptional.”29

8.5.24 The NPPF builds upon this and where Designated Assets are concerned, requires us to make an assessment as to the level of harm which could be caused to Designated Assets by development. It requires a judgement to be made as to whether that harm is ‘substantial’ or ‘less than substantial’. Where

29 Department of Energy & Climate Change. 2011. Overarching National Policy Statement for Energy (EN-1), Para 5.8.14 (available at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/47854/1938- overarching-nps-for-energy-en1.pdf)

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no effect is predicted or where effects are predicted to be neutral, e.g. where a proposed development may be perceptible but will not materially affect the setting of an Asset or diminish its cultural value, it may be found that there will be no harm to an Asset. The level of harm predicted, or lack thereof, establishes whether the planning test should be applied and where harm is found the level of that harm establishes the correct policy test. Extant guidance on harm relevant to this assessment is set out in the PPG and states: “Proposed development affecting a heritage asset may have no impact on its significance or may enhance its significance and therefore cause no harm to the heritage asset. Where potential harm to designated heritage assets is identified, it needs to be categorised as either less than substantial harm or substantial harm (which includes total loss) in order to identify which policies in the National Planning Policy Framework (paragraphs 194 - 196) apply30.”

8.5.25 The PPG notes that the ‘substantial’ harm is a ‘high test’ and that, as such, it is unlikely to result in many cases. What matters in establishing whether harm is ‘substantial’ or not, relates to whether a change would seriously adversely affect those attributes or elements of a Designated Asset that contribute to or give it its value.

8.5.26 In terms of effects upon the setting of Designated Assets, it is considered that only those effects identified as ‘significant’ in this assessment will have the potential to be of ‘substantial’ harm. Where no significant effect is found, the harm is considered to be ‘less than substantial’. This is because effects only reach the significance threshold if their relative sensitivity to changes in setting is at the higher end of scale, or if the magnitude of change is at the higher end of the scale.

8.5.27 For many Designated Assets, setting may not contribute to their value or the contribution to value may be limited. For these Assets, even High magnitude changes to setting are unlikely to have adverse effects on the value of the Designated Asset. As set out in Table 8.5, lower ratings of magnitude of change tend to relate to notable or perceptible changes to setting but where these

30 Ministry of Housing, Communities and Local Government (MHCLG). 2019. Planning Practice Guidance (available at https://www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment)

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changes do not necessarily obscure or damage elements of setting or relationships which directly contribute to the value of Assets. As such, effects that are not significant will result in ‘less than substantial’ harm. Where there are no effects or effects are deemed to be Neutral there will be no harm.

8.5.28 Where significant effects are found, a detailed assessment of the level of harm will be made. Whilst non-significant effects will cause ‘less than substantial’ harm, the reverse is not always true. That is, the assessment of an effect as being ‘significant’ does not necessarily mean that the harm to the Asset is ‘substantial’. The assessment of level of harm in this Chapter, where required, will be a qualitative one, and will largely depend upon whether the effects predicted would result in a major impediment to the ability to understand or appreciate the Asset in question by reducing or removing its information content and therefore reducing its cultural value.

Mitigation

8.5.29 Where adverse effects are identified, mitigation measures will be proposed which will seek to avoid or reduce identified effects. Where it is not possible to avoid or reduce the level of effect the potential to offset any significant effects are considered.

Scope

8.5.30 Based on the Scoping Opinion and direct consultation with HE, KCC, TMBC and MBC, as outlined in Table 8.1, this Chapter assesses the potential for setting impacts associated with the Proposed Extension on locally and statutorily Designated Assets during both the construction and the operational phase. Consideration has been given to Assets, within the agreed 2km Study Area and those beyond 2km (based on ZTV mapping) which may have intervisibility with the Proposed Extension and are particularly sensitivity to changes to their setting as referred to above in paragraph 8.5.4.

8.5.31 The Site was previously subject to Ragstone quarrying and landfilling and as such PINS has agreed that this is likely to have removed any upstanding or

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buried archaeological remains and direct impact upon upstanding and buried archaeological remains has been scoped out.

8.5.32 Impacts resulting from the installation of the grid connection are also considered in this Chapter.

Limitations

8.5.33 This assessment is based upon data obtained from publicly accessible archives as described in paragraph 8.6.1, a walkover survey and site visits to Designated Assets for the purpose of undertaking an assessment of impacts upon setting. Data was received from the KCC HER in July 2019 and downloaded from the National Heritage List website in August 2019. NHLE data and information on Conservation Areas, held by MBC and TMBC, was checked in June 2020 to identify any changes. The assessment does not contain records added after this date.

8.5.34 Although efforts were made to visit every Designated Asset within 2km of the Site, some Assets are not publicly accessible. In cases where no access was available, assumptions have been made about the likely impact of the Proposed Extension based upon what can be established about their settings from the nearest publicly accessible areas, mapping and Asset records as contained in regional and national databases consulted for this assessment.

Baseline

Data Sources

Desk Study

8.6.1 A desk study was undertaken to characterise the Site and surrounding area and identify the setting baseline of Designated Assets within the Study Area. The following sources were used to gather baseline information: • National Heritage List for England data (NHLE); for Designated Asset data;

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• National Map Library, National Library of Scotland (NLS), Causewayside, Edinburgh: For old Ordnance Survey maps (1st & 2nd Edition, small- and large-scale) and pre-Ordnance Survey historical maps; • Kent Historic Environment Record (HER); for Historic Environment Record data. • Kent Archives (Kent History and Library Centre); for historic maps and documents relating to the area surrounding the Site; and • The Genealogist Online; for historic Tithe maps and apportionments.

Site Visits

8.6.2 In addition to the desk study a walkover survey of the Site was conducted on the 23rd October 2019, in overcast conditions. The walkover survey was undertaken to provide a contextual understanding of the Site and surrounding area which would inform the settings assessment. Appendix 8-1 provides a series of photographic plates to illustrate the observations made below.

8.6.3 The eastern part of the Site is occupied by the Existing Station and paved areas for access and parking (see Appendix 8-1, Plate 8.1). The western part of the Site, where the Proposed Extension would be located, was found to be occupied by the restored quarry and hardstanding surrounding the Existing Station. A screen bund of earth (comprised of a combination of inert materials from the excavated existing station footprint and onsite soils) separates the Existing Station from the western part of the Site (see Appendix 8-1, Plate 8.2).

8.6.4 The eastern part of the Site was observed to be very well-screened from the immediately surrounding area by dense vegetation on all sides (see Appendix 8-1, Plates 8.3 and 8.4). The Existing Station, excluding the Stack, are screened from areas immediately surrounding the Site to the north, west and south. A bank and vegetation planted along the west of Laverstoke Road was also observed to partly screen the Site from the industrial area immediately to the east.

8.6.5 Setting assessment visits to those Assets within the Study Area and within the ZTV were conducted on the 22nd and 23rd of October 2019 in mostly dry and overcast conditions. These site visits sought to identify the current setting of the

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Assets and how this contributes to their value. This included consideration of the type and function of Assets, their topographical location, the character of the area in which they are set and was largely guided by consideration of, but not limited to, the checklist of potential attributes of setting which may contribute to or make appreciable the value of the Asset in question31.

8.6.6 Descriptions of the settings of the visited Assets are given in paragraphs 8.6.24 to 8.6.46 below.

Environmental Baseline

Existing Scenario

Historic Environment

8.6.7 The historic environment baseline provides contextual information relating to the development of the Site and the surrounding area. It is used to understand the relationship between the Site and the surrounding landscape and built features therein and thus informs the assessment of setting impacts which may result from the Proposed Extension on Designated Assets within the Study Area and selected Assets beyond.

8.6.8 The Site was formerly occupied by Aylesford (later Allington) Quarries and Tonguewood Quarry. These are first shown on an Ordnance Survey map published in 1933 (surveyed 1931)32. By the 1970s33 the quarry had extended from the railway line in the east to the site of the Existing Station and the Proposed Extension. Historic Landscape Characterisation (HLC) data supplied by KCC HER indicates that the eastern and central portions of the Site, where the Existing Station and Proposed Extension are located respectively, are characterised as Type 12.1 Active and disused Chalk [Ragstone] quarries (Figure 8.6). Note that while the HLC identifies chalk as the material being

31 Historic England (2017). Good Practice Advice Note 3: Setting, 8.

32 Ordnance Survey 1933 (surveyed 1931) Kent XXXI.14 (Aylesford: Boxley; Maidstone) available at: https://maps.nls.uk/view/103678667 33 Ordnance Survey 1972-1974 OS Plan available at: https://www.old-maps.co.uk/#/Map/573824/157864/10/101320

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extracted, superseded modern Ordnance Survey maps indicate that it was in fact Ragstone. The western portion of the Site is characterised as Type 1.10 Medium regular with straight boundaries (parliamentary type enclosure); it is included within the Site boundary but only reprofiling of bunds and associated earthworks are planned in this part of the Site. This will not require any ground reduction, but rather a building up of levels.

8.6.9 Review of the HER data indicates that Assets ranging in date from the Palaeolithic through to the modern period, including Second World War remains, are located within the Study Area and the Medway Valley Palaeolithic Project indicates medium potential for Palaeolithic remains in the area of the Site. However, previous quarrying activities on the Site, as outlined above, are likely to have removed all potential for archaeological remains to survive within the area of the Proposed Extension footprint.

8.6.10 No Designated Assets are located within the Site. There are two Scheduled Monuments located within the Study Area: Aylesford Bridge (Site 1) and the Cistercian Abbey at Boxely (Site 2). A further three Scheduled Monuments (Sites 249 to 251) are located beyond the Study Area and have been included in this assessment for the reasons set out in Paragraph 8.5.3. There are 111 Listed Buildings located within the Study Area would include five Grade I Listed Buildings and 10 Grade II* Listed Buildings; the rest are Grade II Listed. Two Protected Military Remains sites are located within the Study Area, as are three Conservation Areas; these include Aylesford (Site 113) and Holtwood Aylesford (Site 114) as well as Boxley Abbey (Site 2), though the Conservation Area for the latter largely coincides with the Scheduled Area. Ditton Conservation Area (Site 253) is located beyond the Study Area but has been included in the assessment at the request of TMBC. In addition to the Designated Assets noted above, the HER identified one locally Listed Building, Lockwood House (Site 162), and two Local Historic Parks or Gardens (Sites 117-118). Consideration has also been given to non-designated pill boxes within the Study Area (Sites 143, 147-151, 155-157, and 191) at the request of KCC Archaeology Officer.

8.6.11 Data regarding Non-designated Assets and archaeological events was obtained from KCC Historic Environment Service HER in July 2019. This identified Assets dating from the prehistoric period through to the modern period. The text below

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provides an overview of the development of the area within which the Proposed Extension would be located. This is presented by period to enable an understanding of the historic character of the area. Full details of the Assets and events recorded within the Study Area are set out in Appendix 8-2 (Site Gazetteer).

8.6.12 There is evidence of prehistoric use of the landscape within the Study Area from the Palaeolithic period through to the Iron Age. As noted above the Medway Valley Palaeolithic Project indicates medium potential for Palaeolithic remains in the area of the Site and the HER records three Palaeolithic hand axes (Site 153) which were recovered from Bryce’s Sand Pit, Forstal Road, Aylesford to the north of the Site on the opposite side of the River Medway and a further three from Preston Hall (Site 209). Several Mesolithic artefacts have been recovered within the Study Area and these include tranchet axes (Sites 119 & 135), a flint sickle and a pick (Site 129), a further pick (Site 130) and a hammerstone (Site 184).

8.6.13 Several early Neolithic Megalithic monuments, some of which are Scheduled, are located c. 2.7km to 3.1km to the north of the Site. Although located beyond the Study Area, the following Assets have been included in this assessment: Kit’s Coty House Long Barrow (Site 249); Little Kit’s Coty House Megalithic Tomb (Site 250); The White Horse Stone (Site 251); and the Coffin Stone (Site 252). These form part of an important group of early Neolithic chambered tombs known as the ‘Medway Megaliths’, together with a cluster of broadly contemporary monuments on the western side of the Medway Valley, located c.8.4km to 8.7km to the west and northwest of the Site: Addington Long Barrow (List Entry number: 1015978); The Chestnuts (List Entry number: 1012917); and Coldrum Long Barrow (List Entry number: 1013069).

8.6.14 Although seemingly forming complementary groups on either side of the River Medway, there is no evidence for closely related Neolithic monuments or the development of a later ‘ritual landscape’ such as that seen at other monumental Neolithic complexes like Stonehenge34. Late Neolithic and Bronze Age remains

34 Ashbee, P. (1993). The Medway Megaliths in Perspective. In Archaeological Cantiana Volume 111: pp. 57 to 111; Killick, S. (2010). Neolithic Landscape and Experience: The Medway Megaliths. In Archaeological Cantiana, Volume 130: pp. 339 to 349.

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within the Study Area comprise several findspots from which artefacts have been recovered (Sites 128, 131, 134, 138, 172 & 174). Some of these, such as seven late Bronze Age gold torcs recovered from the river at Aylesford (Site 128), are likely to represent votive offerings.

8.6.15 Evidence for Iron Age activity is also largely derived from findspots (Sites 126, 132,168, 180 &183). However, more substantial remains in the form of an Early Iron Age ditch and bank, with a small hearth constructed on the top of the ditch fills, was encountered during archaeological investigations at the Museum of Kent Rural Life (Site 190) to the east of the Site.

8.6.16 A Roman burial was found in a stone quarry in Allington (Site 121) and noted to be 100 yards from a villa site. The HER records further Roman burials (Site 123) to the north of the Museum of Kent Rural Life, noting these were recovered from a sandpit near Cobtree Hall. The HER entry provides details of the recovery of a number of artefacts of probable Roman date including several urns which were kept by workmen. The site of the recovery of these artefacts now lies under the M20. Roman building material (Site 189) was also recovered during excavations at the Kent Museum of Rural Life and included painted plaster, roof and box-flue tile, tessera and ragstone rubble. This indicated a Roman building may have been located in the vicinity but no in situ remains appear to have been found. All other Roman remains recorded by the HER are findspots and have included pottery, coins and beads.

8.6.17 Allington (‘Elentun’) is recorded in the Domesday Book of 1086 in the Hundred of Eyhorne, with an estimated population of sixteen households35. It has been suggested that Allington Castle (Site 6) was built on the site of a Saxon fortification, demolished by the Danes36. Evidence for Early Historic occupation of the area includes a Jutish burial (Site 124) found northwest of Preston Hall. Interred with the human remains were a Frankish blue glass vase, a Kentish jewelled brooch and two spear heads. The HER entry also notes that additional artefacts of Anglo-Saxon date were found at Preston Hall pit and included jugs

35 Open Domesday. Accessed at: https://opendomesday.org/place/TQ8456/allington/ 36 Hasted, E. (1998). 'Parishes: Allington', in The History and Topographical Survey of the County of Kent: Volume 4 (Canterbury, 1798), pp. 448-454. British History Online http://www.british-history.ac.uk/survey- kent/vol4/pp448-454 [accessed 9 February 2020].

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and further spearheads. An Anglo-Saxon brooch (Site 133), a silver coin (Site 169), and an iron knife (Site 173) have also been recovered from the Study Area.

8.6.18 The HER records the site of a medieval hall (Site 125) below the present late nineteenth century Preston Hall (Site 8), c.500m west of the Site. Within the Study Area at Aylesford, the HER records medieval quarrying (Site 145) and medieval wall foundations uncovered through archaeological evaluation at 488 Station Road (Site 158). Later medieval Assets recorded elsewhere within the Study Area comprise the findspots of an Anglo-Norman silver penny (Site 188), a ceramic vessel (Site 213), and an iron key (Site 216).

8.6.19 The sites of numerous post-medieval farmsteads (Sites 192 to 202) within 1km of the Site attest to the formerly agrarian character of much of the area surrounding the Site. The 1897 Ordnance Survey map (Figure 8.5) shows orchards of White House Farm and a small quarry just within the eastern boundary of the Site and the deer park and landscaped grounds of Preston Hall to the west. The majority of the Site is depicted as open ground, prior to the extensive quarrying of the twentieth century. By this time the Site was surrounded by two railways: the London, Chatham and Dover Railway and the North Kent Line. Other post-medieval Assets recorded within the Study Area include: buildings re-built within the Museum of Kent Rural Life (Sites 163 to 167, and 248); Allington Lock (Site 139); a brick and tile works (Site 152); paper mill (Site 154); and numerous find spots of post-medieval objects recorded by the Portable Antiquities Scheme (Sites 171, 175 to 177, 181, 182, 186, 203, 210 to 212, and 214).

8.6.20 The Site and surrounding area were extensively quarried throughout much of the twentieth century (see Paragraph 8.5.2), with quarrying of areas of former agricultural land and fruit tree production. A 1934 lease concerning three and a half acres of land required by Messrs Bensted and Sons for Allington Quarry listed 1,360 fruit trees including apples, pears, and young trees with currants underneath (Kent Archives: U1515/E232).

8.6.21 Most modern Assets recorded by the HER relate to Second World War defensive structures; pillboxes were constructed in strategic locations overlooking the River Medway and railway lines (Sites 147 to 151; 155 to 157,

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& 191). Preston Hall (Site 8) was also used as a military hospital during the Second World War (Site 208).

Setting

8.6.22 This section identifies Designated Assets within the Study Area, the settings of which could potentially be impacted upon by the development of the Proposed Extension. It also sets out the current setting of the Designated Assets. As such this section complies with Stage 1 of the HE guidance on setting. This section also defines the current settings of the identified Assets and assesses the contribution that their settings make to their cultural value (thus fulfilling the Stage 2 guidance requirements). The baseline is then used when assessing the potential for impacts upon the setting of Assets that could result from the Proposed Extension.

8.6.23 ZTV mapping and site visits established that many Designated Assets, within the Study Area, would have no intervisibility with the Proposed Extension and these therefore have been excluded from further assessment. Consideration has also been given to the potential for Assets outside the ZTV to be seen with the Proposed Extension, from additional locations. Appendix 8-3 (Summary of Heritage Assets Excluded from Further Assessment) outlines the reasons for excluding these Assets from further assessment. Where there are associated Assets or there are Assets located near to one another these have been grouped.

8.6.24 Designated Assets with potential to be affected by the Proposed Extension are considered below, together with selected Assets which are beyond the Study Area.

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Boxley Abbey Scheduled Monument and Conservation Area (Site 2)

8.6.25 Boxley Abbey (Site 2) represents a Cistercian abbey founded in 1146 by William of Ypres and dissolved in 153837. It is now designated as a Scheduled Monument and Conservation Area. The Scheduled area includes: the Grade I Listed 13th to 14th century former hospitum, the Barn at Boxley Abbey (Site 4; Appendix 8-1, Plate 8.5); the Grade II* Listed Boxley Abbey House (Site 105), which incorporates part of the west range of the abbey; and the Grade II Listed 15th to 16th century timber framed Abbeygate Cottages (Site 76).

8.6.26 The remains of the abbey are contained within an angular precinct wall, which forms the boundary of the Scheduled Monument and Conservation Area (Figure 8.2 and Figure 8.5) and separates the abbey from agricultural land beyond. The abbey and associated structures are situated within a predominantly rural agricultural environment, with farmland and the scarp of the North Downs prominently visible to the north. The rural setting of the abbey has recently been encroached upon by the construction of the M20 Motorway immediately to the south, although mature trees planted throughout the abbey precinct and surrounding area contribute to the maintenance of a secluded setting for all of the Listed Buildings within the Scheduled Monument and Conservation Area (Appendix 8-1, Plate 8.5). The immediately surrounding agricultural land contributes to the setting of Boxley Abbey and contributes to the historical understanding of the Asset. It is considered that the abbey has a Medium sensitivity to change to its immediate agricultural surroundings but has a Low sensitively to more distant change beyond its immediate surroundings.

Ruins of Great Cossington at Cossington Farm (Site 53)

8.6.27 Site 53 represents the ruined remains of a probable 16th to early 17th century manor house situated at Cossington Farm. The immediate surroundings of the ruins are rural and agricultural in nature, which contribute to the understanding of the Asset. However, the surrounding landscape to the south of the Asset has

37 Page, ed. (1926). 'Houses of Cistercian monks: The abbey of Boxley', in A History of the County of Kent: Volume 2, ed. William Page (London, 1926), pp. 153-155. British History Online http://www.british- history.ac.uk/vch/kent/vol2/pp153-155 [accessed 10 February 2020].

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changed during the twentieth century with the addition of the landscaped Cobtree Manor Golf Course and an overhead powerline to the south. It is considered that the Asset has a Low sensitivity to change outside its immediate rural surroundings.

300 to 302 Pratling Street (Site 54) and 301 to 303 Pratling Street (Site 93)

8.6.28 Together with Little Cossington Farmhouse (Site 20 – excluded from further assessment as set out in Appendix 8-3), 300 to 302 Pratling Street (Site 54) and 301 to 303 Pratling Street (Site 93) represent an attractive group of 18th to 19th century buildings clustered around Little Cossington Farm. The group retain a rural and agricultural setting, with views towards the prominent North Downs scarp possible from both cottages. The Assets’ agricultural surroundings have been encroached upon by the twentieth century industrial buildings to the south, although these are largely screened from view by deliberately planted belts of trees to the south of all the buildings (Appendix 8-1, Plate 8.6). The immediate agricultural surroundings of the cottages contribute to their significance, although it is considered that the Assets have a Low sensitivity to changes within the wider landscape.

Aylesford Conservation Area (Site 113)

8.6.29 Aylesford Conservation Area is located around 1km to the northwest of the Site (Figures 8.2 and 8.3). It encompasses the historic core of the medieval village, which lies largely on the northern side of the River Medway (the River) and extends to the east to include the buildings of the Carmelite Aylesford Friary (Site 3).

8.6.30 The Scheduled Monument and Grade I Listed Aylesford Bridge (Site 1) and originally Norman Grade I Listed Church of St Peter and St Paul (Site 7), form key focal points around which the historic core of Aylesford has developed (Appendix 8-1, Plate 8.7). The churchyard of St Peter and St Paul contains many Grade II Listed 18th and 19th century tombs (Sites 9, 10, 25 to 28, 45, 50, 69 to 71, 78, 83, and 86 to 89).

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8.6.31 Grade II Listed Buildings located closer to the River along the High Street and The Quay largely date from the 18th century and later (Sites 12 to 18, 23, 29, 30, 47, 48, 79, 81, 84, and 90 to 92), although many of these contain earlier fabric from the 15th to 17th centuries. Notable early buildings along the High Street include the timber-framed Grade II* Listed George House (Site 103) and the Chequers Public House (Site 109), which both date to the 16th century.

8.6.32 Other notable buildings within the Conservation Area include the Grade II* Listed early 17th Century Trinity Court Almshouse (Site 111) on the northern side of Rochester Road (Appendix 8-1, Plate 8.9) and the 16th century former hall house, Court Farmhouse (Site 104), to the west of the church.

8.6.33 Aylesford Conservation Area represents an attractive medieval settlement that retains a strong association with the River around which it developed. Although it may be considered to have a High or Medium sensitivity to change within its boundaries, external views out to the wider area are considered less important in understanding the overall setting of the Conservation Area and the historic significance of the buildings within it. Consequently, it is considered that Aylesford Conservation Area has a Low sensitivity to change beyond its boundaries and its immediate vicinity.

Holtwood Aylesford Conservation Area (Site 114)

8.6.34 Holtwood estate was developed from around 1933 by Lyons Green Works of East Sussex, with additional properties constructed by other developers throughout the 1930s38. The estate occupies the steep north-facing slope of Holt Hill and comprises large, detached mock-Tudor properties set back from curving roads. Mature trees planted throughout the Conservation Area contribute to its secluded, sylvian setting and prevent most distant views beyond its boundaries.

8.6.35 However, some glimpsed views of the North Downs across intervening development are possible from the southern part of the Conservation Area, which have been identified as key views in the 2011 Conservation Area

38 Tonbridge and Malling Borough Council (2011). Holtwood Conservation Area Appraisal adopted November 2011. Available at: https://www.tmbc.gov.uk/__data/assets/pdf_file/0008/13688/Holtwood_Cons_Area_adopted.pdf (accessed February 2020)

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Appraisal document39. Given the secluded character of the Conservation Area, which prevents most views outside it, the Asset is considered to have a Low sensitivity to change within the wider landscape.

Cobtree Manor Park (Site 118)

8.6.36 Cobtree Manor Park (the Park) was created in the late 1970s by the Cobtree Charity Trust at the bequest of the late Sir Garrard and Lady Tyrwhitt-Drake 'for the benefit of the inhabitants of Maidstone and other members of the general public'40. The Park comprises play areas and landscaped gardens set within a wooded country park on a southwest facing slope with some distant views possible towards the North Downs scarp, however the wooded nature of the parkland prevents most views outside the Park. The immediate vicinity of the Park is dominated by twentieth century industrial development, with industrial units off Beddow Way and Forstal Road located immediately adjacent to the Park to its north, west and south. The tree-lined Cobtree Manor Park Golf Course, which forms part of the land bequeathed by Sir Garrard and Lady Tyrwhitt-Drake, is located to the east of the Park. The significance of the Assets is largely derived from the character of the Park within its own boundaries.

8.6.37 However, the wider landscape, which as noted above already includes considerable industrial development, does not contribute materially to its significance. On this basis, it is considered to have a Low sensitivity to change beyond its boundaries.

Lenham Cottages (site 248)

8.6.38 Lenham Cottages represent a pair of Grade II Listed 15th century timber framed cottages with a 19th century brick façade. The cottages (formerly Old Street Cottage and Water Street Cottage) were dismantled in advance of the construction of the Channel Tunnel Rail Link in 1999 and re-built in the Museum of Kent Life in 2000.

39 Ibid 40 https://www.parksandgardens.org/places/cobtree-manor-park-maidstone

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8.6.39 The cottages retain a physical evidential value and historical significance as part of the collection of the Museum of Kent Life. Given that the authentic relationship with their original surroundings has been lost, however, they are considered to have only a Marginal sensitivity to changes to their setting.

The ‘Medway Megaliths’ (Sites 249 to 252)

8.6.40 These Assets represent a group of early Neolithic funerary monuments on Bluebell Hill, located c. 2.7km to 3.1km to the north of the Site, and comprise the non-designated Coffin Stone (Site 252) and three Scheduled Monuments: Kit’s Coty House Long Barrow (Site 249); Little Kit’s Coty House Megalithic Tomb (Site 250); and The White Horse Stone (Site 251). These form part of an important group of early Neolithic chambered tombs known as the ‘Medway Megaliths’, together with a cluster of broadly contemporary monuments on the western side of the Medway Valley, located c.8.4km to 8.7km to the west and northwest of the Site: Addington Long Barrow (List Entry number: 1015978); The Chestnuts (List Entry number: 1012917); and Coldrum Long Barrow (List Entry number: 1013069).

8.6.41 The monuments all survive in various states of ruin, although the dimensions of their chamber stones suggest that they would have had unusually tall internal dimensions. As a group, they represent the largest and most grandiose of their kind in southern England41.

8.6.42 Due to their proximity to each other, it is likely that Kit’s Coty House (Site 249), Little Kit’s Coty House (Site 250) and The Coffin Stone (Site 252) would have been intervisible in the Neolithic period and it has been suggested that this may have been a desirable feature in the decision to locate the monuments where they are42. However, dense vegetation now precludes intervisibility between all the monuments.

41 Ashbee, P. (1993). The Medway Megaliths in Perspective. In Archaeological Cantiana Volume 111: pp. 57 to 111: p. 61 – 62. 42 Killick, S. (2010). Neolithic Landscape and Experience: The Medway Megaliths. In Archaeological Cantiana, Volume 130: pp. 339 to 349: p. 347

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8.6.43 Changes within the wider landscape have also altered the settings of the monuments; most notable are the extensive industrial and residential developments at the base of the Medway Valley, which are most clearly visible from Kit’s Coty House (Site 249; Appendix 8-1, Plates 8.17 and 8.18; LVIA viewpoint 2), Little Kit’s Coty House (Site 250; Appendix 8-1, Plate 8.20) and The Coffin Stone (Site 252). The setting of the White Horse Stone (Site 251) has also been altered by the modern railway line and the A229 to its west.

8.6.44 The settings of Little Kit’s Coty House (Site 250) and The Coffin Stone (Site 252) have also been altered by the construction of an overhead powerline immediately to the north of the Assets (Appendix 8-1, Plate 8.19), although this is not considered to diminish the ability to appreciate the Assets’ wider landscape setting in relation to the North Downs scarp beyond.

8.6.45 Although the development of an increasingly visually complex built landscape at the base of the Medway Valley has altered their wider landscape setting and dense vegetation now precludes intervisibility between the monuments, which would once have existed, the original topographical setting of the monuments and its probable influence on their siting in the landscape is still clearly legible. It is therefore considered that these Assets have a High sensitivity to changes to their settings.

Ditton Conservation Area (Site 253)

8.6.46 Ditton Conservation Area is located 2.19km west of the Site and is centred on the Grade II* Listed Church of St Peter AD Vincula (List Entry No: 1099197) (the Church) which dates originally to the 12th century with later additions, including a tower in the 15th century and restoration by Sir George Gilbert Scott in 1860. The Conservation Area extends along New Road to the east of the church and to the northwest along The Stream and Bradbourne Lane. A further three Listed Buildings are located near the junction of The Stream with a ford. These include the Grade II Listed The Old Mill House (List Entry 1349055) and No. 40 The Stream and the Grade II* Listed Stream Cottages. Both The Old Mill and Stream Cottages are 15th century in date and timber framed. No. 40 is 18th century in date and of red brick construction.

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8.6.47 The area around the Church is characterised by mature vegetation including trees and conifer hedges. There is also vegetation along Bradbourne Lane to the west of Ditton Ford and along the watercourse itself. There is less vegetation along The Stream and along New Road and the character in these areas is residential, but the buildings are of mixed date and some quite modern. Elements of setting and character which contribute to the significance of the Conservation Area are primarily related to the Church, which forms a focal point and to the relationships of the Listed Buildings and later settlement with the water course. The Conservation Area and the Designated Assets therein are deemed to be moderately sensitive to changes within the Conservation Area boundaries but of Low sensitivity to changes in the wider landscape.

Non-designated Pill Boxes (Sites 143, 147-151, 155-157 & 191)

8.6.48 All of the pill boxes are located in a modern urban and in many cases semi- industrial setting. Their significance primarily lies in their historical value and their wider contextual associations. On this basis they are judged to be of Low sensitivity to changes to their settings.

Grid Connection

8.6.49 As set out in Chapter 5.0, the connection to the national grid would be undertaken by the District Network Operator (DNO) under their statutory powers under the Electricity Act 1989 and permitted development rights as a statutory undertaker. Accordingly, the works would not fall to be consented under the DCO process. Nonetheless, the Chapters of the PEIR have given consideration to the likely impacts associated with the installation of the Grid Connection, because the connection to the network is a critical requirement for the Proposed Extension to recover energy.

8.6.50 The Existing Station is connected to the Maidstone Sub-Station via an underground connection that runs east around the 20/20 business park and then south through a number of land-uses and suburban areas of northern Maidstone (Route A). The existing grid route is subject to a number of potential environmental and physical constraints, which has led the Applicant to consider

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whether an alternative route may be preferable (Route B). Accordingly, there are two potential grid connection routes for the Proposed Extension, as follows: • Route A: the existing route from the Existing Generating Station, running through undeveloped and suburban areas towards the northern edge of Maidstone; • Route B: an alternative route that follows the A20, and roads within Maidstone town centre.

8.6.51 A description of each route of relevance to this assessment is provided below.

Route A

8.6.52 From the substation, the proposed route runs north along Huntsman Lane and then west along Snowdon Avenue before turning north along Marston Drive. It crosses a public footpath to the rear of the houses on the eastern side of Marston Drive and thereafter runs along Hampton Road before turning northeast and following Bonnington Road. At the northern end of Bonnington Road the route skirts the western edge of Upper Fullingpits Wood before crossing the A249 and travelling east-northeast along Sittingbourne Road. Here it passes the Grade II Listed Chiltern Cottage (List Entry Number: 1086316). It then follows the path to the south of Heath Wood and crosses the recreation ground at Penenden Heath; re-joining the road at the junction of Penenden Heath Road with Boxley Road. It travels in a westward direction along this road until it reaches Invicta Park where it passes across recreations grounds and other open ground. Invicta Park contains the Grade II* Listed Park House (Site 107).

8.6.53 The route then crosses the A229 and travels west along Dickens Road before crossing another recreation ground, the River Medway and Allington Open Space. Allington Open Space contains the Grade I Listed Allington Castle (Site 6), and its associated Grade II Listed Dovecots (Sites 41 & 42) and Barn (Site 73). KCC HER considers the Castle Gardens (Site 117) to be a designed landscape of local importance.

8.6.54 After crossing the northeastern end of Castle Road the route passes immediately west of the Grade II Listed Church of St Lawrence (Site 44) and

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the Locally Listed Lockwood House (Site 162) before traveling in a north- westerly direction along the eastern side of the railway line. A post-medieval copper jetton (Site 203) has been recovered from this location. The route turns west and crosses the railway line to join the Site just south of the M20. Here it will pass immediately adjacent to two Second World War Pillboxes (Site 191 and 147).

Route B

8.6.55 From the substation, the proposed route runs south along Huntsman Lane, past the western side elevation of the Grade II Listed 19th century 27 Ashford Road (List Entry Number: 1086386). The proposed route then follows the southern carriageway of Ashford Road towards the centre of Maidstone, passing through the Ashford Road Conservation Area and adjacent to the 19th century Grade II Listed villas 24 Ashford Road (List Entry Number: 1086389) and 4B and 6 Ashford Road (List Entry Number: 1238949).

8.6.56 The route continues west along King Street, passing twelve Grade II Listed Buildings: the Regency 1 and 3 Ashford Road (List Entry Number: 1086381); Clarendon Place (List Entry Number: 1086320); East Layne House (List Entry Number 1086319); the 1789 Brenchley Almshouses (List Entry number: 1238949); 74 King Street (List Entry Number: 1224563); 72 King Street (List Entry Number: 1086326); 70 King Street (List Entry Number 1086325); 52 and 54 King Street (List Entry Number 1086324); 24 and 26 King Street (List Entry Number 1086323); 20 and 22 King Street (List Entry Number: 1086322); 2 and 4 King Street (List Entry Number: 1086321); 1 and 3 Gabriel’s Hill (List Entry Number: 1336209).

8.6.57 The route then passes west along the northern part of the pedestrianised High Street, which crosses the centre of the Maidstone Centre Conservation Area. It passes around thirty Grade II Listed Buildings and two Grade II* Listed Buildings: the 18th Century Maidstone Town Hall (List Entry Number: 1086305); and 8 and 9 High Street (List Entry Number: 1223181). At the western end of the High Street, the route follows Fairmeadow to the north, passing near to the Grade II Listed Three Lanterns (List Entry Number 1086373), before crossing the River.

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8.6.58 The route would then continue past the Grade II* Listed Former Church of St Peter (List Entry Number: 1086281) along Buckland Road, before joining the A20 London Road and following it in a northwest direction towards the Site. The proposed route passes adjacent to nine Grade II Listed Buildings along London Road, which include three buildings located within the Study Area: Somerfield Terrace (Site 39); Fanum House (Site 40); and 61 London Road (Site 60).

8.6.59 The assessment will consider the potentially significant environmental effects associated with construction and operation of both routes on Assets.

The Proposed HWRC Scenario

8.6.60 A separate planning application for a proposed Household Waste Recycling Centre (proposed HWRC) at the north-eastern edge of the Site was submitted to KCC in December 2019 (application reference KCC/TM/0284/2019) and was awaiting determination at the time of writing. As such, and for the reasons explained in more detail in Chapter 6, it is necessary for the assessment of likely significant effects on cultural heritage to also consider a second scenario, where the proposed HWRC has been implemented. 8.6.61 The proposed HWRC would comprise: • A new household waste recycling facility (the proposed HWRC); • New access from Laverstoke Road; • Re-engineering of existing perimeter earthworks; • Loss of existing tree cover; and • New native woodland planting.

8.6.62 As the proposed HWRC development would also be located within the former Ragstone quarry, it does not have the potential to impact upon archaeological remains in this location, which will already have been removed by the previous quarrying on the Site. As such, this change would not alter the assessment of archaeological effects when compared to the existing scenario.

8.6.63 The inclusion of the proposed HWRC would add a new built element to the east of the Existing Station. However, given the relatively low nature of the propsoed

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HWRC and its location in relation to the Existing Station and to the Designated Assets in the Study Area, it is unlikely to be perceptible from most of the Assets identified. Assets to the west are located beyond the Existing Station and within a residential area and, as such, the proposed HWRC would not form an element of the baseline setting of these Assets. Similarly, Assets located in the arc from the south to the east of the Site are located beyond the Maidstone East Link Railway Line and the Medway Valley Line and within or beyond industrial and residential development and, as such, the proposed HWRC would not form an element of the baseline setting of these Assets. For those Assets to the north of the Site any visibility of the proposed HWRC would be partially screened by the bank and vegetation adjacent to the M20. To the west of the Site, the proposed HWRC would be entirely screened by the bank and the Existing Station. The Landscape and Visual assessment prepared for the proposed HWRC application deemed visibility from the North Downs to be very limited43 especially as this would feature a dark roof and canopy of the external waste bays which would minimise perceptibility of the proposed HWRC in views. As such the inclusion of proposed HWRC would not alter the baseline setting of those Assets described above. Incorporated Mitigation

8.7.1 The project description (Chapter 5.0) provides a description of the key mitigation measures that have been incorporated into the design of the Proposed Extension. These include retention of existing woodland, scrub and grassland vegetation in the eastern part of the Site, and the planting of a new native woodland planted along the crest of the new landform to be created linking with the retained vegetation to the east located closer to the site boundary (it should be noted that the development of the proposed HWRC would result in the loss of some of the retained vegetation on the eastern bund). The lower slopes of the earthworks would be seeded with species-rich grassland. Native scrub would also be planted along the lower slopes on the inner side of the earthworks. New native hedges would be planted at the boundary between the new landscaping and hard surfaced areas. A small orchard would be created at the foot of the earthworks. The entirety of the retained and new vegetation would be managed

43 AXIS (2019). Allington Household Waste Recycling Centre: Landscape and Visual Impact Assessment. Available at: https://www.kentplanningapplications.co.uk/Planning/Display/KCC/TM/0284/2019

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proactively by the Applicant, with key objectives being to maximise biodiversity across the Site and to reinforce the screening of views of the Extending Station from outside.

8.7.2 In addition to the above the site level is proposed to be lowered in order to reduce the overall height of the Proposed Extension. Furthermore, a Shared Stack is proposed, rather than two, to minimise the visual impact of this element of the Proposed Extension.

8.7.3 This incorporated mitigation has been taken into consideration when assessing effects below.

Construction and Decommissioning Phase Effects

Construction - Assessment of Effects against Existing Baseline

8.7.4 As consideration of direct impacts upon upstanding and buried archaeological remains have been scoped out of this assessment, construction phase effects relate to the potential for impacts upon the setting of Designated Assets and may result from increased noise or dust due to construction traffic or construction activities. Similarly, the presence of construction machinery, including cranes, particularly a tower crane of c. 103m, has the potential to impact upon the visual setting of Designated Assets.

8.7.5 Any impacts upon the setting of Assets during the construction phase will be temporary and will cease once the Proposed Extension is operational.

8.7.6 Construction phase effects upon the settings of Assets are not judged to have more than a minor-moderate level of effect for any of the Assets considered in this assessment (see Table 8.7 in Section 8.9, Summary of Potential Settings Effects). This is largely due to the distance between the Site and the Designated Assets that have potential intervisibility with the Site. The majority of the construction phase works will not be visible from Designated Assets within the Study Area as they will take place at ground level and be screened from the Site by the existing vegetation as well as intervening built structures. Visibility of construction phase works from the majority of Assets will only become

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possible during later stages of construction when crane(s) will be required for the construction of the Proposed Extension and the Shared Stack. Visibility of cranes with the upper elements of the Proposed Extension being constructed will be temporary and intermittent. While there may be a brief period where the upper levels of the building, two Stacks and the cranes are visible impacts resulting from these will not be significant and indeed while the view may be briefly more cluttered, it will not be to the extent that that the impacts predicted during the operational phase would be exceeded. For these reasons, and in the interest of proportionality, brevity and avoidance of repetition a detailed assessment of impacts upon the setting of individual Assets is not provided here, under construction effects, and the reader is referred to Table 8.7 in Section 8.9 of this Chapter, which provides a Summary of Potential Effects and the detailed assessment of operational phase effects below, which should be taken as being equivalent to the levels of effects arising during construction.

8.7.7 Noise and vibration effects during construction on Assets are likely to be limited due to distance to the Assets, intervening bunding (during the early stage of construction) vegetation and the existing built environment. No significant traffic and transport construction effects have been identified in Chapter 15.0, Traffic and Transport and as such impacts upon these elements of setting would not be significantly affected

8.7.8 On this basis, there would be no significant effects upon the setting of Assets occurring during the construction phase and these effects are considered to amount to considerably less than substantial harm in terms of the NPS and NPPF.

Decommissioning - Assessment of Effects against Existing Baseline

8.7.9 It is unclear at what point decommissioning and demolition of the Proposed Extension would occur and what changes there would be in methods and approach to decommissioning facilities in the intervening period. Notwithstanding, this could be a part of the project and it is necessary to consider whether this would have the potential to give rise to likely significant effects.

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8.7.10 As a result of the uncertainty regarding the timing and approach to decommissioning, for the purpose of this assessment, it has been assumed that similar techniques and / or approaches would be used as were implemented for the construction phase. Thus, the impacts from decommissioning would be equivalent to those associated with the Construction Phase.

8.7.11 However, in taking this approach, it is also recognised that the DCO application is for an extension to an Existing Station and the assessment of construction phase impacts only relates to the construction activity associated with the Proposed Extension. When decommissioning occurs, it may apply to the entire Generating Station. Such operations would be of a slightly different scale to the effects assessed for the construction phase of the Proposed Extension. Nevertheless, it is reasonable to assume that similar construction techniques and mitigation measures would be applied, and that the outcome of the construction phase assessment remains a reasonable proxy for the assessment of construction phase effects.

8.7.12 The assessment of construction phase effects has concluded that any effects on the settings of Designated Assets would be temporary, are not considered significant and are deemed to amount to considerably less than substantial harm in terms of the NPS’s and NPPF. The effects of decommissioning are not expected to alter those conclusions.

Construction and Decommissioning of Grid Connection

8.7.13 As stated in section 12.6 above, two potential grid connection routes are being considered for the Proposed Extension (Route A and Route B). This section assesses the potential construction and decommissioning phase impacts each route would have upon Cultural Heritage Assets.

Construction of Grid Connection (Rotes A and B)

8.7.14 The installation of the grid connection Route B is likely to cause temporary effects on the setting of the Conservation Areas that it passes through and Listed Buildings that it passes adjacent to as described in paragraphs 8.6.47 to 8.6.57 above. Temporary effects are likely to comprise visibility of the

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construction plant and construction noise and vibrations caused by the groundworks. Given that any effects on the settings of Designated Assets would be temporary, these are not considered significant and are deemed to amount to considerably less than substantial harm in terms of the NPS and NPPF.

8.7.15 The installation of grid connection Route A is similarly likely to cause temporary effects on the setting of the Listed Buildings it passes near to, though it passes far fewer than passed by Route B. Temporary effects are likely to comprise visibility of the construction plant and construction noise and vibrations caused by the groundworks. Given that any effects on the settings of Designated Assets would be temporary, these are not considered significant and are deemed to amount to considerably less than substantial harm in terms of the NPS and NPPF.

8.7.16 Route B is largely located in modern roadways and so unlikely to result in direct effects upon buried archaeological remains as the route will have been subject to previous disturbance for construction and maintenance of the road and insertion and maintenance of services. As Route A passes through or along the edge of a number of recreation grounds, woodlands and open spaces there is potential for direct effects upon hitherto unknown buried archaeological remains. As such Route B is considered to be preferable from an archaeology and cultural heritage perspective.

Decommissioning of Grid Connection

8.7.17 At the end of its operational life, it is anticipated that the ducting for the Grid Connection would be left in situ, such that there would be no decommissioning works and therefore no potential significant effects upon Assets.

Assessment of Construction and Decommissioning Phase Effects against the proposed HWRC Baseline Scenario

8.7.18 The proposed HWRC is unlikely to be perceptible from most Designated Assets within the Study Area for reasons set out in paragraphs 8.6.59 to 8.6.62 and therefore would have no effect on the setting of these Assets. The proposed HWRC may, however, be distantly perceptible from higher ground towards the

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North Downs scarp to the north the Site, although potential visibility of the proposed HWRC from the North Downs is anticipated to be very limited44 and any visibility is likely to be minimised through mitigation which will see the roof of the proposed canopy in a dark colour to minimise the perceptibility of the proposed HWRC in views.

8.7.19 Given the location and relative size of the HWRC in relation to the Existing Station, it would not cause any significant alterations to the current baseline settings of Designated Assets assessed herein. As such construction and decommissioning phase effects against the proposed HWRC Scenario would not differ from those outlined above against the current baseline. No significant effects have been identified and non-significant effects are considered to amount to considerably less than substantial harm in terms of the NPS’s and NPPF.

Operational Phase Effects

Assessment of Operational Phase Effects with Two Stacks

8.7.20 As set out in Chapter 13.0, the Proposed Extension will operate for 15 months with two Stacks producing separate emissions (with a period of 24 months when both the existing Stack and the Shared Stack will be up). Any additional impacts upon the setting of Assets during the period when two Stacks are visible will therefore be temporary.

8.7.21 Site visits have indicated that the existing Stack is most visible from specific locations within the northeast part of Aylesford Conservation Area (Site 113), largely due to topography and the relatively short distance between the Conservation Area and the Site (see Table 8.7 in Section 8.9, Summary of Potential Effects). It is therefore considered that for the period when two Stacks are visible there would be the greatest level of effect on the setting of the Aylesford Conservation Area (Site 113) and Designated Assets within it. The visualisations of the two Stacks presented in Chapter 09, Landscape and Visual

44 AXIS (2019). Allington Household Waste Recycling Centre: Landscape and Visual Impact Assessment. Available at: https://www.kentplanningapplications.co.uk/Planning/Display/KCC/TM/0284/2019

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depicts that the existing Stack is largely obscured by the Shared Stack in views from Aylesford Bridge (Site 1; Chapter 09, viewpoint 8) and it is likely that the two Stacks will be more perceptible as individual adjacent structures from other parts of the Conservation Area.

8.7.22 The temporary visibility of two Stacks in views towards the Site from specific parts of Aylesford Conservation Area (Site 113) are likely to slightly increase the level of effect on the setting of the Conservation Area when compared to the operational phase when there is just one Shared Stack. However, given that the new Shared Stack will be located in close proximity to the existing Stack in any views towards the Site, the presence of two Stacks is not anticipated to alter the magnitude of change compared to the presence of one Stack. The magnitude of change to the setting of Aylesford Conservation Area during the period when two Stacks are visible (Site 113) is therefore considered Low and the level of effect would therefore be Negligible and not significant. Any harm would be considerably less than substantial in terms of the NPS’s and NPPF.

8.7.23 The temporary presence of two Stacks is also not anticipated to increase the magnitude of change to the settings of any other Asset beyond that set out in the assessment of operation phase effects with one Shared Stack below. In all cases, the temporary visibility of two Stacks is likely to represent only a relatively minor alteration to views that already distantly feature the existing Stack against a backdrop of other industrial development (as illustrated in Chapter 09, Landscape and Visual, viewpoint 2).

8.7.24 As such, effects during the limited period of time when two Stacks would be visible would not differ materially from those when there is one Shared Stack. No significant effects have been identified and non-significant effects are considered to amount to considerably less than substantial harm in terms of the NPS’s and NPPF.

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Assessment of Effects with One Shared Stack

Boxley Abbey Scheduled Monument and Conservation Area (Site 2)

8.7.25 Boxley Abbey (Site 2) is located 1.66km to the northeast of the Site. The abbey is contained within an angular precinct wall and surrounded by agricultural land. It is considered to have a Low relative sensitivity to changes beyond its immediate rural setting. Boxley Abbey is very well screened from the surrounding landscape by dense plantations of trees, both within the abbey precinct and planted along the M20 motorway immediately to the south of the abbey. Most of the precinct of Boxley Abbey, including the Grade II* Listed Boxley Abbey House (Site 105) lies entirely outside the ZTV for the Proposed Extension. The ZTV does indicate partial visibility of the Propose Extension from the Grade I Listed Barn at Boxley Abbey (Site 4) and the Grade II Listed Abbeygate Cottages (Site 76), although site visits indicate that this is likely to be limited to glimpsed views of the new Stack above intervening vegetation. Consequently, the Proposed Extension would be only fleetingly visible from specific areas within the abbey precinct. It may be perceptible as a new feature in the wider setting of the Assets but given the distance and the limited views it would not materially affect an observer’s ability to understand, appreciate and experience the Asset or its value.

8.7.26 Ninety-five percent of the HGV traffic accessing the Site during operation would route via junction 5 of the M20 motorway with only a nominal amount of HGV trips routeing along the A20 corridor into the surrounding built up areas. Given the distance between the Asset group and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the Boxley Abbey Assets.

8.7.27 The Proposed Extension is therefore considered to represent, at most, a Low magnitude of change to the setting of this Asset. This would result in a Negligible level of effect, which is not considered significant in EIA terms and represents considerably less than substantial harm in terms of the NPS’s and NPPF.

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Ruins of Great Cossington at Cossington Farm (Site 53)

8.7.28 The Grade II Listed ruins of Great Cossington at Cossington Farm Site 53 are located 1.8km to the north of the Site. The Asset lies partially within the ZTV for the Proposed Extension building and wholly within the ZTV for the Shared Stack, indicating the potential for visibility of the Proposed Extension. However, site visits indicated that buildings surrounded by mature trees immediately to the south would interrupt any distant views towards the Proposed Extension. The rural, agricultural nature of the ruins’ immediate surroundings are considered to contribute to the understanding of the Asset, although it is considered to have a Low sensitivity to changes to the wider landscape.

8.7.29 Given the distance to the Site and the intervening development to the south of the Asset the addition of the Proposed Extension may be perceptible from this Asset but it would not materially affect an observer’s ability to understand, appreciate and experience this Asset or its value.

8.7.30 As mentioned above 95% of the HGV traffic accessing the Site during operation would route via junction 5 of the M20 motorway with only a nominal amount routeing along the A20 corridor into the surrounding built up areas. Given the distance between the Asset and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the ruins of Great Cossington.

8.7.31 As such magnitude of change would be Low, which would result in a Negligible level of effect. This is not considered significant in EIA terms and represents considerably less than substantial harm in terms of the NPS’s and NPPF.

300 to 302 Pratling Street (Site 54) and 301 to 303 Pratling Street (Site 93)

8.7.32 Sites 54 and 93 are Grade II Listed Buildings 1.43km to the north of the Site, both buildings have principal elevations facing towards the east. The Assets’ immediate agricultural surroundings contribute to their understanding, although it is considered that the Assets have a Low sensitivity to change within the wider landscape. The Proposed Extension would be distantly visible in views towards the buildings from further north along Pratling Street, although dense belts of

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conifers planted to the south of the buildings would preclude any potential visibility towards the Proposed Extension from immediately outside the buildings themselves (Appendix 8-1, Plate 8.6). Key views of the North Downs scarp to the northeast of the buildings would not be changed.

8.7.33 The Proposed Extension would not alter the immediate agricultural surroundings of the Assets nor would it affect key views. Therefore, it is considered that it would not materially affect an observer’s ability to understand, appreciate and experience the Asset or its value.

8.7.34 Given the distance between the Assets and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of these Listed Buildings at Pratling Street.

8.7.35 The Proposed Extension is considered to represent a Low magnitude of change and consequently a Negligible level of effect, this is not considered significant in EIA terms and represents considerably less than substantial harm in terms of the NPS and NPPF.

Aylesford Conservation Area (Site 113)

8.7.36 Aylesford Conservation Area is 862m northwest of the Site at its nearest point and is considered to have a Low sensitivity to change beyond its boundaries for the reasons set out in Section 8.5 above. Views of the Proposed Extension are likely to be limited to the northeast part of the Conservation Area. The site visits established that there is no potential intervisibility between the Proposed Extension and much of the western part of the Conservation Area, including Aylesford Friary (Site 3) and associated buildings: the 15th Century Gatehouse and Walls (Site 5); and the Roman Catholic Shrine of Our Lady of Mount Carmel (Site 112). The seventeenth century Court Lodge Farmhouse (Site 85) and timber-framed Barn (Site 82) to the north of the Friary also have no potential intervisibility with the Proposed Extension.

8.7.37 Within the eastern part of the Conservation Area, there appears to be no potential intervisibility between the part of the Conservation Area located to the south of the River Medway and the Proposed Extension; this area includes the

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19th century cottage, 460 Station Road (Site 22) and former school and schoolmasters house Village School and Rosalind’s Cottage (Site 57). These Assets are therefore excluded from further assessment, as set out in Appendix 8-3.

8.7.38 Views towards the Proposed Extension would, however, be possible from the historic core of Aylesford in the eastern part of the Conservation Area, particularly from higher areas to the north of the river.

8.7.39 Visualisations of the Extended Station from the Scheduled Monument Aylesford Bridge (Site 1) indicate that both the Shared Stack and the upper elevations of the Fourth Line would be visible above existing vegetation (LVIA viewpoint 8). Any views of the Fourth Line and the Existing Station including the Proposed Extension, from Aylesford Bridge (Site 1) will include the modern Aylesford New Bridge, opened 1997, prominently visible in the foreground (Appendix 8-1, Plate 8.8; LVIA viewpoint 8).

8.7.40 Site visits indicate that intervening buildings mean that views of the Proposed Extension from elsewhere within the Conservation Area are likely to be limited to glimpsed views of the Shared Stack through gaps between buildings or over rooftops (Appendix 8-1, Plates 8.9 to 8.13).

8.7.41 Given the distance between the Conservation Area and the Assets therein, traffic accessing the Site and the fact that none of this traffic will route through the Conservation Area itself, it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the Aylesford Conservation Area Assets.

8.7.42 Consequently, the magnitude of change is considered Low. The overall level of effect is therefore considered to be Negligible. This is not significant in EIA terms and represents considerably less than substantial harm in terms of the NPS’s and NPPF.

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Holtwood Aylesford Conservation Area (Site 114)

8.7.43 Holtwood Aylesford Conservation Area represents a 20th century estate of individually designed mock-Tudor buildings set within mature woodland, circa 1.1km west of the Site. Mature trees that are intentionally planted throughout the Conservation Area and surrounding it contribute to an intentionally secluded and internalised character for the Conservation Area, which is considered to have a Low sensitivity to changes outside its boundaries. The ZTV indicates variable visibility of both the Fourth Line and Shared Stack, with the greatest potential for visibility occurring along the northern boundaries and in the western extent. Given views of the Proposed Extension are likely to represent glimpsed views from limited parts of the Conservation Area through gaps in vegetation or between buildings, they would therefore not materially affect an observer’s ability to understand, appreciate and experience the Asset or its value.

8.7.44 Given the distance between the Conservation Area, traffic accessing the Site, and the fact that the traffic would not be routed through the Conservation Area itself, it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the Holtwood Aylesford Conservation Area.

8.7.45 On the basis of the above, the magnitude of change is considered Low. The overall level of effect is consequently considered Negligible and therefore not significant in EIA terms and represents considerably less than substantial harm in terms of the NPS’s and NPPF.

Cobtree Manor Park (Site 118)

8.7.46 Cobtree Manor Park (CMP) represents a gently sloping wooded park, located 750m northeast of the Site. It is a locally designated Historic Park and Garden CMP is surrounded to the north, west, and south by industrial development and is considered to have a Low sensitivity to change within the wider landscape, beyond its boundaries. The ZTV indicates fleeting visibility of the Proposed Extension from specific parts of CMP, which would represent relatively distant views through gaps in vegetation. The Proposed Extension would be more clearly visible from the entrance to the park on Forstall Road, although here the

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busy road and intervening industrial buildings dominate its setting and the Proposed Extension would be seen beyond this.

8.7.47 Given the distance between the Asset and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of Cobtree Manor Park.

8.7.48 Given this, the magnitude of change would be Low and consequently the level of effect would be Negligible. This is not considered significant in EIA terms and would represent considerably less than substantial harm in terms of the NPS’sand NPPF.

Lenham Cottages (Site 248)

8.7.49 Lenham Cottages represent a pair of Grade II Listed 15th century timber framed cottages that have been re-built in the Museum of Kent Life, 730m northeast of the Site. Given that their authentic relationship with their original surroundings has been lost, they are considered to have only a Marginal sensitivity to change to their settings.

8.7.50 Potential views of the Proposed Extension would be limited to views of the shared Stack on the skyline to the southwest of the Site, which would also include the stack associated with the Asphalt Plant operated by Hanson Aggregates on the 20/20 Business Park. As such while the Shared Stack would be perceptible it would not materially change the current setting of the Assets.

8.7.51 Given the distance between the Asset and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of Lenham Cottages.

8.7.52 On the basis of the above the magnitude of change would be Low. Given that the building is considered to have a Marginal sensitivity to change, the overall level of effect is considered Neutral and therefore not significant in EIA terms and there would be no harm in terms of the NPS and NPPF.

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The ‘Medway Megaliths’ (Sites 249 to 252)

8.7.53 The ‘Medway Megaliths’ are considered to have High sensitivity to changes to their settings as they were, as set out above, deliberately sited above the Medway Valley with views of the North Downs and were likely sited to be intervisible with each other. Though there have been considerable changes to the character of the landscape, the topographical setting of the Assets can still be experienced and understood.

8.7.54 The Proposed Extension would be located 2.29km to the south of the Assets at the nearest point. The ZTV indicates that the Proposed Extension would be visible from both Kit’s Coty House (Site 249) and Little Kit’s Coty House (Site 250), although visibility from The White Horse Stone (Site 251) and The Coffin Stone (Site 252) is likely to be at least partly precluded by vegetation. It is also worth noting that trees planted around the 19th century railings surrounding Little Kit’s Coty House are likely to prevent any visibility towards the Medway Valley and the Proposed Extension from this monument in the future (Appendix 8-1, Plate 8.20).

8.7.55 Visualisations of the Proposed Extension from the North Downs Way adjacent to Kit’s Coty House (Site 249) indicate that whilst the Shared Stack would be slightly more prominent than the existing Stack, the Shared Stack would represent only a relatively minor alteration to the already developed industrial and residential built landscape at the base of the Medway Valley (Chapter 09, Landscape and Visual, Viewpoint 2). It is not anticipated that there will be any greater visibility of the Proposed Extension from any of the other ‘Medway Megaliths’ (Sites 249 to 251). 8.7.56 Whilst the Proposed Extension would be perceptible from the Assets, it would not interrupt the relationship between the monuments, and it would not feature in key views to the North Downs scarp. In all cases the Proposed Extension would be seen beyond the Medway Valley and thus would not alter the ability to understand the monuments in the context of the valley below. The Proposed Extension would form part of an already complex and semi-industrial landscape on the south side of the Medway Valley.

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8.7.57 As such, while the Proposed Extension would be perceptible it would not represent a material alteration to the current setting of the Assets and would not materially affect the ability to understand, appreciate or experience the Assets.

8.7.58 Given the distance between the Asset group and traffic accessing the Site it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the Medway Megaliths.

8.7.59 On the basis of the above, the magnitude of change would be Low, resulting in a Minor-Moderate level of effect which is not significant in EIA terms and represents considerably less than substantial harm in terms of the NPS’s and NPPF.

Ditton Conservation Area (Site 253)

8.7.60 Ditton Conservation Area’s key setting relationships relate to its development around the Church of St Peter AD Vincula and the along The Stream. Elements of setting which contribute to its heritage value are largely contained within in the Conservation Area’s boundaries. It is judged to be of Low sensitivity to changes to its setting which occur beyond its boundaries.

8.7.61 The Site is located c. 2.19km to the east of the Conservation Area beyond significant modern residential development. The ZTV indicates only fleeting visibility of shared Stack, the Conservation Area lies outside the ZTV for the proposed building, from the northwest limit of the Conservation Area, along Bradbourne Lane to the west of the ford. The majority of the Conservation Area, including all the Listed Buildings within it, lie outside the ZTV for the Proposed Extension.

8.7.62 Given the distance between the Conservation Area, the Designated Assets therein, traffic accessing the Site and the fact that traffic will not be routed through the Conservation Area it is not considered that traffic, and emissions therefrom, would contribute to any impact upon the setting of the Conservation Area.

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8.7.63 Given that visibility of the Proposed Extension from Ditton Conservation Area would be extremely limited and only available from specific areas, it is considered to represent, at most, a Negligible magnitude of change to the setting of the Asset. This would result in a Neutral level of effect, which is not considered significant in EIA terms and represents no harm in terms of the NPS’s and NPPF.

Non-designated Pill Boxes (Sites 143, 147-151, 155-157 & 191)

8.7.64 Ten non-designated pill boxes of Second World War date are recorded in close proximity to the Site. The site of the pill box at Site 156 lies in a modern industrial estate and the HER notes that it its exact location is unknown and it is thought to have been destroyed. All of the other pill boxes are extant and survive in varying conditions. Sites 143, 155 and 191 are located outside the ZTV and will have no views of the Proposed Extension and as such no impacts are predicted upon them. The proposed building and the Shared Stack for the Proposed Extension would be visible from Sites 147 and 149 and only the Stack would be visible from Sites 148, 150, 151 and 157. All of the pill boxes are located in a modern urban and in many cases semi-industrial setting. Their significance primarily lies in their historical value and their wider contextual associations. On this basis they are judged to be of Low sensitivity to changes to their settings.

8.7.65 The Proposed Extension would not intervene in any intervisibility between any of the pill boxes that had not already been affected by other development and its addition to the Existing Station would not materially change the setting of these Assets. As such the magnitude of change is judged to be at most Low. This would result in a Negligible level of effect, which is not significant and amounts to considerably less than substantial harm in terms of the NPS and NPPF.

Historic Landscape Characterisation

8.7.66 Historic Landscape Characterisation (HLC) data supplied by KCC HER indicates that the eastern portion of the Site where the Existing Station is located and centre portion of the Site where the Proposed Extension is planned, is characterised as Type 12.1 Active and disused Chalk [Ragstone] quarries

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(Figure 8.6). Note that the HLC data notes this to be a disused chalk quarry but superceded Ordnance Survey maps indicate that it was in fact Ragston. The western portion of the Site which will be subject to landscaping and reprofiling through building up of levels, is characterised as Type 1.10 Medium regular with straight boundaries (parliamentary type enclosure).

8.7.67 While these characterisations represent the historic landscape characters of these areas, they are no longer readily appreciable on the Site. Later landfill activities and the construction of the Existing Station and the construction of the M20 to the north and the A20 to the west mean that these historic characters are difficult to appreciate. Given that the Proposed Extension represents an addition to the Existing Station and does not extend into the western portion of the Site, it is not considered to alter the existing HLC. Similarly given the location of the Proposed Extension amidst a complex industrial, residential, commercial and transport landscape, it will not materially alter the HLC in any of the surrounding areas, therefore no impact upon the character of HLC is anticipated.

Impact of the Plume

8.7.68 Plume visibility has been modelled as part of the Air Quality Assessment (Chapter 13.0) and is also detailed in the Landscape and Visual Impact Assessment (Chapter 9.0). These have indicated that a plume from the existing stack is visible for a maximum of 17.3% of day light hours and that the length of the plume is less that 50m for approximately 12.5% of daylight hours and exceed 100m for approximately 6.4% of daylight hours.

8.7.69 During the 15 months when both the existing and the Shared Stack are operational the visibility of the plume would be as per the above. The Shared Stack could produce a plume which would be visible for approximately 18.8% of daylight hours. The plume would be shorter than 50m for approximately 15.6% of daylight hours and would exceed 100m for approximately 8.7% of daylight hours. Following the dismantling of the existing stack, the combined plume emitted from the proposed stack would be slightly more visible than the existing plume. There would be an increase in the period when plumes would

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be visible of approximately 1.5% of daylight hours, and the majority of visible plumes would continue to be short.

8.7.70 Overall the changes in the visibility of emissions plumes at the Site brought about by the introduction of the Proposed Extension would not be materially different to the current situation. On this basis impacts upon the setting of Assets resulting from the plume would be neutral and there would be no harm in terms of the NPS’s or the NPPF.

Grid Connection

8.7.71 The grid connection (both routes) will be entirely buried, therefore Designated Assets located along the route will be returned to their original settings and there will be no impact or harm during the operational phase.

Assessment of Effects against proposed HWRC Scenario

8.7.72 The proposed HWRC is unlikely to be perceptible from most Designated Assets within the Study Area for reasons set out in paragraph 8.5.43 and therefore would have no effect on the setting of these Assets. The proposed HWRC may, however, be distantly perceptible from higher ground towards the North Downs scarp to the north of the Site, although potential visibility of the proposed HWRC from the North Downs is anticipated to be very limited particularly as a dark roofed canopy will be used to minimise the perceptibility of the proposed HWRC in views45.

8.7.73 Given the location and relative size of the proposed HWRC in relation to the Generating Station, it would not cause any significant alterations to the current baseline settings of Designated Assets assessed herein. As such effects against the proposed HWRC Baseline Scenario would not differ from those outlined above against the current baseline. No significant effects have been identified and non-significant effects are considered to amount to considerably less than substantial harm in terms of the NPS and NPPF.

45 AXIS (2019). Allington Household Waste Recycling Centre: Landscape and Visual Impact Assessment. Available at: https://www.kentplanningapplications.co.uk/Planning/Display/KCC/TM/0284/2019

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Cumulative Effects

8.7.74 As described in Chapter 6, the cumulative assessments undertaken within each chapter of this PEIR has been carried out by considering which scenario (i.e. development of the Proposed Extension with or without the HWRC) would give rise to the ‘worst-case’ for the assessment of that environmental topic. Once that has been established, it has then been assessed on that basis in conjunction with the cumulative scheme set out below. Where the two scenarios give rise to different worst-case effects, two cumulative scenarios are assessed separately.

8.7.75 For the purposes of the assessment of potentially significant effects on the Cultural Heritage Assets, it has been judged that the ‘HWRC Scenario’ would represent the worst case. This is on the basis that the HWRC may be visible, along with the Proposed Development from some, albeit very limited, Assets.

8.7.76 The approach to the cumulative assessment is discussed in Chapter 6.0. All six identified developments are for residential use; three benefit from planning permission (not yet implemented), whilst the planning applications for the other three have not yet been determined. The schemes are summarised in the Chapter 6.0, and their locations are shown on Figure 6.1.

8.7.77 The potential for significant cumulative effects has been considered for all assets. However, only those Assets which were judged to have the potential to be subject to significant cumulative effects are discussed detail in this assessment. Of the Designated Assets considered for this assessment, only the ‘Medway Megaliths’ (Sites 249 to 252) are deemed to be potentially subject to a significant level of cumulative effect, given that their sensitivity to changes to their settings is considered to be High.

8.7.78 The Applicant, in consultation with TMBC and MBC, has prepared a shortlist of projects to be considered in the cumulative effects assessment. In all cases, the developments considered may represent perceptible new features within an already visually complex, built-up landscape at the base of the Medway Valley. As such, adding the Proposed Extension to the Existing Station, the proposed HWRC and to the developments identified for the cumulative assessment is

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unlikely to result in an increased impact, either additive or synergistic, upon the setting of the ‘Medway Megaliths’ (Sites 249 to 252). In line with the assessment of effects from the Proposed Extension itself, the magnitude of cumulative change would be Low and this would result in a Minor-Moderate level of cumulative effect, which is not significant. The effect would represent considerably less than substantial harm in terms of the NPS and NPPF.

Additional Mitigation

Construction / Decommissioning Mitigation

8.8.1 Given the location of the Designated Assets in relation to the Proposed Extension and the fact that the majority of construction works on Site will be screened in views from Assets in the surrounding area by intervening residential, industrial and transport development, no significant effects upon the setting of Designated Assets or the HLC have been identified during the construction phase. Construction works that are visible from Designated Assets will be limited to the presence of cranes during the later stages of building and Stack construction. Cranes will also be visible for a brief period (approximately six weeks) during the dismantling of the existing Stack. Any such visibility will be temporary and cease on completion of the construction phase. Given the height of the crane(s) required, the tallest of which would be 103m, there are no practicable mitigation measures that can be suggested. However, as no significant effects have been identified, any harm will be considerably less than substantial in terms of the NPS and NPPF and no additional mitigation measures are deemed necessary

8.8.2 Depending on the grid connection route chosen, an archaeological watching brief may be required during ground-breaking works associated with the construction. This would be particularly true for Route A where it passes through recreation grounds, through open space and along woodland edges. These areas will have subject to less disturbance than modern road and carriage ways and there could be potential for buried archaeological remains to survive in these areas.

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8.8.3 It is assumed that decommissioning of the Proposed Extension, or indeed the Existing Station, would utilise similar techniques and / or approaches that would be used during the construction phase. On the basis of this assumption, and as outlined above, no significant effects have been identified, any harm will be considerably less than substantial in terms of the NPS and NPPF and no additional mitigation measures are deemed necessary

8.8.4 It is assumed that on decommissioning the grid connection would be left in situ and as such there would be no impacts. On this basis no mitigation would be required.

Operational Mitigation

8.8.5 No significant effects upon the setting of Designated Assets or the HLC have been identified during operation (either during the operational phase with two Stacks or with one Shared Stack). New bunding created to encompass the whole Existing Station, and vegetation within the Site and the intervening built environment will largely screen the Extended Station from surrounding Assets. Most views towards the Site will therefore comprise distant views of the upper part of the Fourth Line and the Shared Stack, above or through gaps in intervening vegetation and the built environment.

8.8.6 Given the height of certain elements of the Proposed Extension (particularly the Shared Stack) no practicable mitigation can be offered. Further it should be noted that the existing stack forms part of the baseline of the Assets assessed and Proposed Extension will not result in any significant effects. Any harm would be considerably less than substantial in terms of the NPS’s and the NPPF, and on this basis no additional mitigation measures are deemed necessary.

8.8.7 The grid will comprise a buried feature during the operational phase and as such there will be no impacts upon the setting of Designated Assets and no mitigation will be required.

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Residual Effects

8.9.1 As no mitigation is deemed necessary residual effects will be unchanged from the construction, decommissioning, operational and cumulative effects outlined above. However, it should be noted that no significant effects are predicted and any harm to Assets as a result of impacts upon their settings will be considerably less than substantial in terms of the NPS and NPPF. Construction effects will be temporary and will cease on completion of the construction phase.

Summary

8.10.1 This Chapter has assessed the potential impacts of the Proposed Extension on the settings of all Designated Assets within the Study Area and selected Assets located over 2km from the Site. This has included an assessment of construction phase effects, including during the installation of the electricity connection cable, and operational phase effect, including the temporary period when both Stacks would be operational. Consideration has been given to the proposed HWRC and the potential for the plume to impact upon the setting of Assets. Consideration has also been given to the effects of traffic on the setting of Assets. Assets deemed to have no potential intervisibility with the Proposed Extension were excluded from detailed assessment, following an assessment of the ZTV and site visits (See Appendix 8-3 Summary of Heritage Assets Excluded from Further Assessment).

8.10.2 Table 8.7, below, provides a summary of the effects upon the identified receptors.

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Table 8.7: Summary of Residual Effects** – Existing Scenario **Note that as no significant effects are predicted to no mitigation measures have been suggested. There will be no residual construction/decommissioning effects and any such effects will cease with the completion of these phases. Residual operation effects will be as per operation effects. Construction/decommissioning effects and operational effects are summarised in the table below. Site No. Site Name Status Distance to Other Factors Effecting Relative Magnitude of Setting Setting Effect Application Visibility Sensitivity Impact Site Construction / Operational Construction / Operational Decommissioning Phase Decommissionin Phase Phase g Phase 2 Boxley Abbey, SM, CA, 1.66km Views towards the Low Low Low Negligible Negligible (Including including the Grade I, II northeast at Proposed Extension only the following Listed & II* nearest point possible from part of the following Buildings: Barn at Listed Conservation Area and not Designate Boxley Abbey, Buildings from publicly accessible d Assets: Abbey Gate areas. The Conservation Sites 4, Cottages & Boxley Area has a secluded setting 76 105) Abbey House with mature trees preventing most views beyond the immediate rural setting of the Abbey buildings. 53 Ruins of Great Grade II 1.8km north Views towards the Site Low Low Low Negligible Negligible Cossington at Listed interrupted by buildings and Cossington Farm Building mature trees immediately to the south at Cossington Farm. 54 and 93 300 and 302; 301 Grade II 1.43km north No direct intervisibility of Low Low Low Negligible Negligible and 303 Pratling Listed (at its the Proposed Extension at Street Buildings nearest ground level due to dense point) belts of mature trees planted to the south of the buildings. Oblique views featuring the Site and

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Listed Buildings can be gained further to the north along Pratling Street.

113 Aylesford SM, CA, c.862m Visibility of the Proposed Low Low Low Negligible Negligible (Including Conservation Area Grade I, II northwest (at Extension limited to the the Including & II* its nearest northeast part of the following Scheduled Listed point) Conservation Area and Designate Monument and Buildings would vary depending on d Assets: Listed Buildings as the location within the Site 1, 7, detailed in Conservation Area. Views 9, 10,12- Appendix 8.2 towards the Proposed 19, 21, Extension from Aylesford 23-30, 45- Bridge Scheduled 50, 57, Monument (Site 1) would 69-71, 78- be interrupted by the 79, 81, modern Aylesford new 83-92,96, Bridge. Views towards the 103-104, Proposed Extension from 109, 111) elsewhere within the Conservation Area would be limited to glimpsed views of the Shared Stack in between buildings and over the rooftops of Listed Buildings.

Holtwood Aylesford Conservat c.1.1kmwest The ZTV indicates variable Low Low Low Negligible Negligible 114 Conservation Area ion Area at nearest visibility of the Proposed point Extension from within the Conservation Area with the greatest potential for visibility occurring along the northern boundaries and in the western extent. The

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Conservation Area is well screened by mature trees intentionally planted throughout it and around its perimeter, which contribute to its very secluded character and prevent any clear intervisibility with the Proposed Extension.

118 Cobtree Manor Locally 750m Mature trees prevent all but Low Low Low Negligible Negligible Park designate northeast at occasional glimpsed views d Historic nearest point outside the park from within Park & its boundaries. Clearer Garden views towards the Site are possible from the entrance to the park on Forstall Road, although here the busy road and intervening industrial buildings dominate its setting.

143, 147- Non-designated Pill Non- Various Sites 143, 155 and 191 Low Low Low Negligible Negligible 151, 155, Boxes designate nearest have no intervisibility with 157 & 191 d extant pill the Proposed Extension. box (Site Sites 148, 150, 151 and 147) is 157 will have visibility of the located shared Stack only, while within 33m of Sites 148, 150, 151 and the Site but 157 have visibility of the the Proposed Shared Stack and building. Extension is All are set within a modern, located c urban and semi-industrial 620m to the landscape. southwest.

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The furthest extant pill box (Site 150) is located 998m to the northwest 248 Lenham Cottages, Grade II 730m The Asset’s immediate Marginal Low Low Neutral Neutral formerly Old Listed northeast at setting is defined by its Cottage and Water Building nearest point location within the Museum Street of Kent Life (removed from its original setting and rebuilt). Views southwest towards the Proposed Extension are likely to feature the Stack of the Asphalt Plant on the 20/20 business park operated by Hanson. Medway Megaliths SM and 2.29km north Vegetation prevents High Low Low Minor- Minor- 249-252 Non- at nearest intervisibility between the moderate moderate designate point monuments likely to have d existed at the time of their construction, but key visual links between the monuments and the North Downs / Medway Valley still exist. Views towards the Site encompass a relatively visually complex landscape dominated by industrial and residential development at the base of the Medway Valley.

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253 Ditton Conservation Conservat 2.19km west The Conservation Area is Low Negligible Negligible Neutral Neutral Area ion Arear at nearest entirely outside the ZTV for point the Fourth Line and only partially within the ZTV for the Shared Stack, suggesting only fleeting visibility from specific parts of the Conservation Area. Cumulative Effects 249-252 Medway Megaliths SM and 2.29km north Vegetation prevents High Low Low Minor- Minor- Non- at nearest intervisibility between the moderate moderate designate point monuments likely to have d existed at the time of their construction, but key visual links between the monuments and the North Downs / Medway Valley still exist. Views towards the Site encompass a relatively visually complex landscape dominated by industrial and residential development at the base of the Medway Valley.

All other SMs, Between Variable Marginal to Negligible to Negligible Neutral to Neutral to Designate Listed 620m and Low Low to Low Negligible Negligible d Assets Buildings, 2.19km within the Conservat Study ion Areas, Area Local Listed Assets, Non-

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Designate d Assets

Table 8.8: Summary of Residual Effects for Grid Connections – Existing Scenario Grid Assets Type of effect Likely level of effect Likely level of Likely level of Mitigation Residual Connection effected construction operational decommissioning effect Route effect(significant/not effect effect significant) (significant/not (significant/not significant) significant) Grid Designated Temporary Not significant None None None None Connection A Assets as note Setting effect in paragraph 8.6.50 to 8.6.52 Hitherto Permanent Potential significant None None Watching Brief Not significant unknown direct depending upon the on areas buried importance of any outwith archaeological Asset encountered modern roads remains Grid Designated Temporary Not significant None None None None Connection B Assets as note Setting effect in paragraph 8.6.53 to 8.6.57

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Table 8.9: Summary of Residual Effects** – Proposed HWRC Scenario **Note that as no significant effects are predicted to no mitigation measures have been suggested. There will be no residual construction/decommissioning effects and any such effects will cease with the completion of these phases. Residual operation effects will be as per operation effects. Construction/decommissioning effects and operational effects are summarised in the table below. Site No. Site Name Status Distance to Other Factors Effecting Relative Magnitude of Setting Setting Effect Application Visibility Sensitivity Impact Site Construction / Operational Construction / Operational Decommissioning Phase Decommissioning Phase Phase Phase 2 (Including Boxley Abbey, SM, CA, 1.66km Views towards the Low Low Low Negligible Negligible the following including the Grade I, II & II* northeast at Proposed Extension only Designated following Listed nearest point possible from part of the Assets: Sites Listed Buildings Conservation Area and not 4, 76 105) Buildings: Barn from publicly accessible at Boxley areas. The Conservation Abbey, Abbey Area has a secluded setting Gate Cottages with mature trees & Boxley preventing most views Abbey House beyond the immediate rural setting of the Abbey buildings. 53 Ruins of Great Grade II Listed 1.8km north Views towards the Site Low Low Low Negligible Negligible Cossington at Building interrupted by buildings and Cossington mature trees immediately to Farm the south at Cossington Farm. 54 and 93 300 and 302; Grade II Listed 1.43km north No direct intervisibility of Low Low Low Negligible Negligible 301 and 303 Buildings (at its the Proposed Extension at Pratling Street nearest ground level due to dense point) belts of mature trees planted to the south of the buildings. Oblique views featuring the Site and

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Listed Buildings can be gained further to the north along Pratling Street.

113 Aylesford SM, CA, c.862m Visibility of the Proposed Low Low Low Negligible Negligible (Including Conservation Grade I, II & II* northwest (at Extension limited to the the following Area Including Listed its nearest northeast part of the Designated Scheduled Buildings point) Conservation Area and Assets: Site Monument and would vary depending on 1, 7, 9, Listed the location within the 10,12-19, 21, Buildings as Conservation Area. Views 23-30, 45-50, detailed in towards the Proposed 57, 69-71, Appendix 8.2 Extension from Aylesford 78-79, 81, Bridge Scheduled 83-92,96, Monument (Site 1) would 103-104, be interrupted by the 109, 111) modern Aylesford new Bridge. Views towards the Proposed Extension from elsewhere within the Conservation Area would be limited to glimpsed views of the Shared Stack in between buildings and over the rooftops of Listed Buildings.

Holtwood Conservation c.1.1kmwest The ZTV indicates variable Low Low Low Negligible Negligible 114 Aylesford Area at nearest visibility of the Proposed Conservation point Extension from within the Area Conservation Area with the greatest potential for visibility occurring along the northern boundaries and in the western extent. The

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Conservation Area is well screened by mature trees intentionally planted throughout it and around its perimeter, which contribute to its very secluded character and prevent any clear intervisibility with the Proposed Extension.

118 Cobtree Manor Locally 750m Mature trees prevent all but Low Low Low Negligible Negligible Park designated northeast at occasional glimpsed views Historic Park & nearest point outside the park from within Garden its boundaries. Clearer views towards the Site are possible from the entrance to the park on Forstall Road, although here the busy road and intervening industrial buildings dominate its setting.

143, 147- Non- Non- Various Sites 143, 155 and 191 Low Low Low Negligible Negligible 151, 155, designated Pill designated nearest have no intervisibility with 157 & 191 Boxes extant pill the Proposed Extension. box (Site Sites 148, 150, 151 and 147) is 157 will have visibility of the located shared Stack only, while within 33Mis Sites 148, 150, 151 and this the one 157 have visibility of the that you thin shared Stack and building. k destroyed? All are set within a modern, of the Site urban and semi-industrial but the landscape. Proposed

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Extension is located circa 620m to the southwest. The furthest extant pill box (Site 150) is located 998m to the northwest 248 Lenham Grade II Listed 730m The Asset’s immediate Marginal Low Low Neutral Neutral Cottages, Building northeast at setting is defined by its formerly Old nearest point location within the Museum Cottage and of Kent Life (removed from Water Street its original setting and rebuilt). Views southwest towards the Site are likely to feature the Stack of the Asphalt Plant on the 20/20 business park operated by Hanson Medway SM and Non- 2.29km north Vegetation prevents High Low Low Minor- Minor- 249-252 Megaliths designated at nearest intervisibility between the moderate moderate point monuments likely to have existed at the time of their construction, but key visual links between the monuments and the North Downs / Medway Valley still exist. Views towards the Site encompass a relatively visually complex landscape dominated by industrial and residential development at

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the base of the Medway Valley.

253 Ditton Conservation 2.19km west The Conservation Area is Low Negligible Negligible Neutral Neutral Conservation Area at nearest entirely outside the ZTV for Area point the PE and only partially within the ZTV for the Shared Stack, suggesting only fleeting visibility from specific parts of the Conservation Area. Cumulative Effects Medway SM and Non- 2.29km north Vegetation prevents High Low Low Minor- Minor- 249-252 Megaliths designated at nearest intervisibility between the moderate moderate point monuments likely to have existed at the time of their construction, but key visual links between the monuments and the North Downs / Medway Valley still exist. Views towards the Site encompass a relatively visually complex landscape dominated by industrial and residential development at the base of the Medway Valley.

All other SMs, Listed Between Variable Marginal to Negligible to Negligible Neutral to Neutral to Designated Buildings, 620m and Low Low to Low Negligible Negligible Assets within Conservation 2.19km the Study Areas, Local Area Listed Assets, Non-

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Designated Assets

Table 8.10: Summary of Residual Effects for Grid Connections – Proposed HWRC Scenario Grid Assets Type of effect Likely level of effect Likely level of Likely level of Mitigation Residual Connection effected construction operational decommissioning effect Route effect(significant/not effect effect significant) (significant/not (significant/not significant) significant) Grid Designated Temporary Not significant None None None None Connection A Assets as note Setting effect in paragraph 8.6.50 to 8.6.52 Hitherto Permanent Potential significant None None Watching Brief Not significant unknown direct depending upon the on areas buried importance of any outwith archaeological Asset encountered modern roads remains Grid Designated Temporary Not significant None None None None Connection B Assets as note Setting effect in paragraph 8.6.53 to 8.6.57

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8.10.3 Of the assessed Assets, Lenham Cottages (Site 248) is deemed to have only Marginal sensitivity to change, whilst all of the remaining assets, with the exception of the ‘Medway Megaliths’ (Sites 249 to 252), are considered to have a Low sensitivity to change beyond their immediate surroundings. The Proposed Extension is judged to represent a Negligible magnitude of change to the setting of Ditton Conservation Area (Site 253) and a Low magnitude of change to the setting of Lenham Cottages (Site 248), resulting in a Neutral level of effect in both cases. In the case of all remaining Assets judged to have a Low sensitivity to change, the Proposed Extension is anticipated to represent a Low magnitude of setting impact, which results in an overall level of effect that is considered Negligible. In all cases, this represents considerably less than substantial harm or no harm in terms of the NPS and the NPPF and is not considered significant in EIA terms. This is true for both the Existing Station and proposed HWRC.

8.10.4 Consideration has been given to the effects of the Proposed Extension on a selected group of three Scheduled Monuments and one Non-designated Asset located beyond the Study Area, which represent part of an important group of Neolithic megalithic monuments: Kit's Coty House Long Barrow (Site 249); Little Kit's Coty House Megalithic Tomb (Site 250); The White Horse Stone (Site 251) and the Coffin Stone (Site 252). The landscape setting of these monuments is still clearly legible, despite the development of an increasingly visually complex landscape at the base of the Medway Valley and vegetation that precludes intervisibility between the monuments. Consequently, they are considered to have a High sensitivity to change.

8.10.5 Although the Proposed Extension will be partially perceptible from these monuments, it would form part of an already complex and semi-industrial landscape on the south side of the Medway Valley and would not interrupt the relationship between the monuments or feature in key views towards the North Downs. As such, the Proposed Extension would not materially affect the ability to understand, appreciate or experience the monuments and is considered to represent a Low magnitude of change. This results in a Minor-Moderate level of setting effect, which represents less than substantial harm in terms of the NPS and the NPPF and is not significant in EIA terms. This is true for both the without and with HWRC scenario.

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8.10.6 This assessment has not identified any significant effects from the construction, operation or decommissioning of the Proposed Extension on Assets in the surrounding landscape, no further mitigation, beyond that outlined in the project design, is considered necessary. On this basis there will be no residual effects resulting from the construction or decommissioning phases as effects will cease upon completion of these phases. Residual operational effects will be unchanged from the predicted operational effects. There will be no significant residual effect resulting from any of the phases of development. Consideration has been given to effects of two possible grid connection routes. No significant residual effects are predicted, subject to mitigation for Route A, should it be chosen. Route B is the preferred option of an archaeological and cultural heritage perspective.

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