Bradbourne Lakes, Extended Phase 1 Habitat Survey 2 March 2019 2 Methods

Bradbourne Lakes

Extended Phase 1 Habitat Survey

Prepared by LUC March 2019

Planning & EIA LUC LONDON Offices also in: Land Use Consultants Ltd Registered in England Design 43 Chalton Street Bristol Registered number: 2549296 Landscape Planning London Edinburgh Registered Office: Landscape Management NW1 1JD Glasgow 43 Chalton Street Ecology T +44 (0)20 7383 5784 Lancaster London NW1 1JD FS 566056 EMS 566057 LUC uses 100% recycled paper GIS & Visualisation [email protected] Manchester

Project Title: Bradbourne Lakes

Client: Sevenoaks District Council

Version Date Version Details Prepared by Checked by Approved by

1.0 19/03/2019 Issue 1 Mungo Nash Amy Coleman David Green

Contents

1 Introduction 2 Site Description 2 Policy and Legislation Considerations 2

2 Methods 3 Desk Study 3 Extended Phase 1 Habitat Survey 3 Limitations and Constraints 4

3 Results 5 Desk Study 5 Extended Phase 1 Habitat Survey 12 Invasive Species 13 Bats 14 Badger 14 Birds 14 Reptiles 15 Great Crested Newt 15

4 Discussion 16 Designated Sites 16 Habitats 16 Invasive Species 19 Bats 19 Badger 20 Birds 20 Reptiles 21 Great Crested Newt 22

Appendix 1 23 Policy and Legislation 23

Appendix 2 27 Figure 3.1 – Extended Phase 1 Habitat Survey Map 27

Appendix 3 29 Extended Phase 1 Habitat Survey – Target Notes 29

Tables Table 3.1 Desk Study – Designated Sites 5 Table 3.2 Desk Study – Relevant Species Records 6 1 Introduction

1.1 In February 2018, LUC was appointed by Sevenoaks District Council to develop landscape proposals at Bradbourne Lakes in Sevenoaks, hereafter known as the ‘Site’.

1.2 To date work conducted by LUC includes production of an initial landscape design vision proposals, which provides outline proposals for the Site. These comprise naturalised areas in the north and south, designated play and picnic areas, seating areas and water play equipment, park buildings, open areas of grassland for events use and lake improvements (comprising dredging, bank stabilisation and vegetated lake edges). Full details of the outline proposals are reported within the Vision Plan1.

1.3 This report presents the findings of the Extended Phase 1 Habitat Survey, which was required to inform the developing design proposals, including highlighting further survey requirements, potential mitigation and broad recommendations for ecological enhancements.

1.4 This report has been prepared for the exclusive use of Sevenoaks District Council. No part of this report should be considered as legal advice.

Site Description

1.5 The Site is a quiet local park situated 2km north west of Sevenoaks town centre. It comprises five ornamental lakes and amenity parkland with scattered trees and dense woodland vegetation. The Site covers approximately 3.5 hectares, and is severed into two sections by Betenson Avenue. The Site is bounded by Bradbourne Vale Road to the north and residential gardens to the east, west and south.

Policy and Legislation Considerations

1.6 The appraisal has been prepared in accordance with relevant legislation and policy. Further detail is provided in Appendix 1, however the primary documents are of relevance:

• The Wildlife and Countryside Act of 1981 (as amended); • The Countryside and Rights of Way Act (CRoW Act), 2000 (as amended); • The Natural Environment and Rural Communities Act (NERC Act), 2006; • The Conservation of Habitats and Species Regulations 2017; • The Protection of Badgers Act 1992; • The National Planning Policy Framework (DCLG 2018); and • Sevenoaks Core Strategy 2011.

1 Bradbourne Lakes – A Vision for the Future. LUC. August 2018.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 2 March 2019 2 Methods

2.1 The methods adopted are outlined below. They accord with the best practice guidance documents for survey and appraisal produced by the Chartered Institute of Ecology and Environmental Management2 and the British Standards Institute3.

Desk Study

2.2 To provide additional background to the appraisal and to highlight likely features or species groups of interest, a study of available biological records was undertaken to identify sites designated for their nature conservation value, and existing records of protected or notable species of relevance A search of the following resources was undertaken, within a 1km radius from the Site:

• Kent and Medway Biological Records Centre; • Multi-Agency Geographical Information for the Countryside (MAGIC); • Ordnance Survey (OS) mapping; and • Aerial photography. 2.3 The absence of a species from biological records cannot be taken to represent actual absence. Species distribution patterns should be interpreted with caution as they may reflect survey/reporting effort rather than actual distribution.

Extended Phase 1 Habitat Survey

2.4 A Phase 1 Habitat Survey was undertaken within boundaries of the Site in line with standard methods4.

2.5 Phase 1 Habitat Survey provides a rapid means of classifying broad habitat types in any given terrestrial site.

2.6 The survey also considered the suitability of the Site to support notable or protected flora or fauna. Species considered included those identified during the desk study, or those considered appropriate by the surveyor during the survey. Detailed surveys were not completed for these species; however, based on an understanding of species ecology, consideration was given to the potential of the Site to provide sheltering or foraging habitat and/or connectivity to allow dispersal between populations. Further information is provided in the ‘Results’ section below.

2.7 The survey was undertaken on the 29th of January 2019 by Mungo Nash GradCIEEM. Weather conditions during the survey were cold and overcast with a light breeze.

2 Survey guidance is available at http://www.cieem.net/sources-of-survey-methods-sosm- and appraisal guidance is available at http://www.cieem.net/guidance-on-preliminary-ecological-appraisal-gpea-.

3 British Standards Institute (2013). BS42020:2013 Biodiversity – Code of Practice for Planning and Development. 4 Joint Nature Conservation Committee (1990). Handbook for Phase 1 Habitat Survey. JNCC, Peterborough.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 3 March 2019 Limitations and Constraints

General

2.8 It is important to note that ecological surveys provide information regarding the ecological baseline of a site for only a ‘snapshot’ of time. Therefore, if significant time lapses between the surveys and the further development or implementation of proposals updated ecological surveys may be required to identify any change in the baseline, such as natural succession of habitats, or local extinction or colonisation of species. Ecological surveys can generally be considered as up to date for 1 to 3 years dependent on the nature of the site, ecological baseline, proposals and likely impact. Therefore if a year lapses between the progressions of development proposals, it is recommended that ecological advice is sought regarding the applicability of the survey findings.

Invasive Species

2.9 As the Extended Phase 1 Habitat Survey was conducted at a sub-optimal time for identifying plant species there were seasonal constraints identifying invasive plants on Site (e.g. Japanese knotweed / giant hogweed). Therefore presence / absence of invasive species cannot be determined with high levels of confidence on the basis of this survey. If a full survey for invasive species is required to inform further works, it is recommended that this occurs between the optimal period of May – September to provide full confidence in the survey.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 4 March 2019 3 Results

Desk Study

3.1 The findings of the desk study are presented in the Tables 3.1 and 3.2 below. These tables list designated sites and relevant protected and notable species which have been recorded within a 1km search radius from the Site boundary.

Table 3.1 Desk Study – Designated Sites

Name of Site Designation Description Distance from site

Non-Statutory Sites Sevenoaks Gravel Pit Site of Special Sevenoaks Gravel Pit, now flooded and fed by 120m north Scientific Interest the River Darenth, is noted for its assemblage (SSSI) of breeding and wintering birds.

The most numerous breeding species include Canada geese Branta canadensis, greylag geese Anser anser, mallard Anas platyrhynchos and tufted duck Aythya fuligula. Other breeding species including the great-crested grebe Podiceps cristatus, kingfisher Alcedo atthis, moorhen Gallinula chloropus and coot Fulica atra. Wintering and passage wildfowl include pochard Aythya ferina, shelduck Tadorna tadorna, teal Anas crecca and shoveler Spatula clypeata. Passage waders are also attracted including greenshank Tringa nebularia and green sandpiper Bartramia longicauda. The uncommon little ringed plover Charadrius dubius is a regular breeding species here.

There is also a large rookery and the site also supports one of the few significant colonies of sand martins Riparia riparia in West Kent. Botanical and entomological interest of the site is limited, however is noted as developing. Thirteen species of dragonfly are present including the locally-distributed downy-emerald dragonfly Cordulia aenea. Plants of note include small cud-weed Filago minima, dwarf elder Sambucus ebulus, and slender bird's-foot trefoil Lotus angustissimus.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 5 March 2019 Table 3.2 Desk Study – Relevant Species Records

Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

Plants

White Helleborine Convention on International Trade in N/A Cephalanthera damasonium Endangered Species

Broad-leaved Helleborine Convention on International Trade in N/A Epipactis helleborine Endangered Species

Marsh-Orchid Convention on International Trade in N/A Dactylorhiza fuchsii x Endangered Species praetermissa = D. x grandis

Bird's-nest Orchid Convention on International Trade in N/A Neottia nidus-avis Endangered Species

Common Twayblade Convention on International Trade in N/A Neottia ovata Endangered Species

Greater Butterfly-orchid Convention on International Trade in N/A Platanthera chlorantha Endangered Species

Blunt-leaved Bog-moss Habitats Directive_V 120m north Sphagnum palustre

Sphagnum recurvum Habitats Directive_V 120m north Sphagnum recurvum

Common Spotted-orchid Convention on International Trade in 120m north Dactylorhiza fuchsii Endangered Species

Southern Marsh-orchid Convention on International Trade in 120m north Dactylorhiza praetermissa Endangered Species

Man Orchid Convention on International Trade in N/A Orchis anthropophora Endangered Species

Early-purple Orchid Convention on International Trade in N/A Orchis mascula Endangered Species

Green-winged Orchid Convention on International Trade in N/A Anacamptis morio Endangered Species

Pyramidal Orchid Convention on International Trade in 120m north Anacamptis pyramidalis Endangered Species

Bee Orchid Convention on International Trade in 120m north Ophrys apifera Endangered Species

Fly Orchid Convention on International Trade in N/A Ophrys insectifera Endangered Species

Snowdrop Habitats Directive_V; 850m east Galanthus nivalis Convention on International Trade in Endangered Species

Bluebell Wildlife and Countryside Act 1981 850m east Hyacinthoides non-scripta (Schedule 8)

Pennyroyal Wildlife and Countryside Act 1981 1000m north Mentha pulegium (Schedule 8); Countryside and Rights of Way Act 2000

Bogbean Convention on International Trade in 850m east Menyanthes trifoliata Endangered Species

Insects

Roman Snail Habitats Directive_V; 120m north Helix (Helix) pomatia Wildlife and Countryside Act 1981(p)

Crustaceans

Bradbourne Lakes, Extended Phase 1 Habitat Survey 6 March 2019 Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

White-clawed Freshwater Habitats Directive_II; 450m north Crayfish Berne Convention_III; Austropotamobius pallipes Wildlife and Countryside Act 1981(p); Countryside and Rights of Way Act 2000

Amphibians and Reptiles

Smooth Newt Berne Convention_III; 20m west Lissotriton vulgaris Wildlife and Countryside Act 1981(p)

Great Crested Newt Habitats Directive_II: 120m north Triturus cristatus Berne Convention_II; Wildlife and Countryside Act 1981; Countryside and Rights of Way Act 2000

Adder Berne Convention_III; 120m north Vipera berus Wildlife and Countryside Act 1981(p)

Grass Snake Berne Convention_III; 300m north Natrix helvetica Wildlife and Countryside Act 1981(p)

Common Lizard Berne Convention_III; 450m north Zootoca vivipara Wildlife and Countryside Act 1981(p)

Slow-worm Berne Convention_III; 900m south Anguis fragilis Wildlife and Countryside Act 1981(p)

Common Toad Wildlife and Countryside Act 1981(p) 1000m north west Bufo bufo

Common Frog Habitats Directive_V; 1000m north west Rana temporaria Berne Convention_III; Wildlife and Countryside Act 1981(p)

Mammals (excluding bats)

Water Vole Wildlife and Countryside Act 1981, Not available Arvicola amphibius Countryside and Rights of Way Act 2000

Badger Berne Convention_III, 400m north east Meles meles Badger Act

Common Shrew Berne Convention_III 500m north west Sorex araneus

Pygmy Shrew Berne Convention_III 500m north west Sorex minutus

Hedgehog Berne Convention_III 1000m north west Erinaceus europaeus

Water Shrew Berne Convention_III 1000m north Neomys fodiens

Bats

Daubenton’s Bat HabDir:A4; 100m north Myotis daubentonii Berne Convention:A2; Bonn Convention:A2; Wildlife and Countryside Act 1981

Noctule Bat HabDir:A4; 100m north Nyctalus noctula Berne Convention:A2; Bonn Convention:A2; BAP; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 1981;

Pipistrelle Bat HabDir:A4; 100m north Pipistrellus pipistrellus Berne Convention:A3; Bonn Convention:A2; Wildlife and Countryside Act 1981

Bradbourne Lakes, Extended Phase 1 Habitat Survey 7 March 2019 Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

Soprano Pipistrelle Bat HabDir:A4; 100m north Pipistrellus pygmaeus Berne Convention:A2; Bonn Convention:A2; BAP; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 1981

Brown Long-eared Bat HabDir:A4; 100m north Plecotus auritus Berne Convention:A2; Bonn Convention:A2; BAP; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 1981;

Nathusius’ Pipistrelle Bat HabDir:A4; 100m north Pipistrellus nathusii Berne Convention:A2; Bonn Convention:A2; Wildlife and Countryside Act 1981

Serotine Bat HabDir:A4; 300m north west Eptesicus serotinus Berne Convention:A2; Bonn Convention:A2; Wildlife and Countryside Act 1981;

Birds

Black-tailed Godwit BAP; 450m north Limosa limosa Berne Convention:A3; Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 19811

Cuckoo BAP; 450m north Cuculus canorus Berne Convention:A3; Birds of Conservation Concern4: Red; Natural Environment and Rural Communities (Section 41); KRDB2

Curlew BAP; 450m north Numenius arquata Berne Convention:A3; Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Fieldfare Berne Convention:A3; 450m north Turdus pilaris Birds of Conservation Concern4:Red; BirdsDir:A2.2; Wildlife and Countryside Act 19811

Grasshopper Warbler BAP; 450m north Locustella naevia Berne Convention:A2; Birds of Conservation Concern4:Red; KRDB1; Natural Environment and Rural Communities (Section 41)

Grey Wagtail Berne Convention:A2; Birds of 450m north Motacilla cinerea Conservation Concern4:Red

Bradbourne Lakes, Extended Phase 1 Habitat Survey 8 March 2019 Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

Hen Harrier Berne Convention:A3; 450m north Circus cyaneus Birds of Conservation Concern4:Red; Bonn Convention:A2; Convention on International Trade in Endangered Species:A; BirdsDir:A1; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 19811

House Sparrow BAP; 450m north Passer domesticus Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Kingfisher Berne Convention:A2; 450m north Alcedo atthis Birds of Conservation Concern4:Amber (subsp. Red); BirdsDir:A1; Wildlife and Countryside Act 1981

Lesser Redpoll BAP; 450m north Carduelis cabaret Berne Convention:A3; Birds of Conservation Concern4:Red; KRDB1; Natural Environment and Rural Communities (Section 41)

Lesser Spotted BAP; 450m north Woodpecker Berne Convention:A2; Dendrocopus minor Birds of Conservation Concern4:Red; KRDB2; Natural Environment and Rural Communities (Section 41)

Linnet BAP; 450m north Carduelis cannabina Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Marsh Tit BAP; 450m north Parus palustris Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Mistle Thrush Berne Convention:A3; 450m north Turdus viscivorus Birds of Conservation Concern4:Red; BirdsDir:A2.2

Nightingale Berne Convention:A2; 450m north Luscinia megarhynchos Birds of Conservation Concern4:Red; Bonn Convention:A2.

Pied Flycatcher Berne Convention:A2; 450m north Ficedula hypoleuca Birds of Conservation Concern4:Red; Bonn Convention:A2

Pochard Berne Convention:A3; 450m north Aythya ferina Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.1.

Red-necked Grebe Berne Convention:A2; 450m north Podiceps grisegena Birds of Conservation Concern4:Red; Bonn Convention:A2

Redwing Berne Convention:A3; 450m north Turdus iliacus Birds of Conservation Concern4:Red; BirdsDir:A2.2; Wildlife and Countryside Act 1981

Bradbourne Lakes, Extended Phase 1 Habitat Survey 9 March 2019 Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

Scaup BAP; Berne Convention:A3; 450m north Aythya marila Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41); Wildlife and Countryside Act 1981

Skylark BAP; Berne Convention:A3; 450m north Alauda arvensis Birds of Conservation Concern4:Red; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Song Thrush BAP; Berne Convention:A3; 450m north Turdus philomelos Birds of Conservation Concern4:Red; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Spotted Flycatcher BAP; Berne Convention:A2; 450m north Muscicapa striata Birds of Conservation Concern4:Red; Bonn Convention:A2; Natural Environment and Rural Communities (Section 41)

Starling BAP; Birds of Conservation 450m north Sturnus vulgaris Concern4:Red; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Tree Sparrow BAP; Berne Convention:A3; B 450m north Passer montanus irds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Turtle Dove BAP; Berne Convention:A3; 450m north Streptopelia turtur Birds of Conservation Concern4:Red; Bonn Convention:A2; Convention on International Trade in Endangered Species:A; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Twite BAP; Berne Convention:A2; 450m north Carduelis flavirostris Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Whimbrel Berne Convention:A3; 450m north Numenius phaeopus Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.2; Wildlife and Countryside Act 1981

Whinchat Berne Convention:A2; 450m north Saxicola rubetra Birds of Conservation Concern4:Red; Bonn Convention:A2

White-fronted Goose BAP; Berne Convention:A3; 450m north Anser albifrons Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.2; Natural Environment and Rural Communities (Section 41)

Willow Tit BAP; 450m north Parus montanus Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Bradbourne Lakes, Extended Phase 1 Habitat Survey 10 March 2019 Taxon Name Protection/Designation Distance and Orientation of Latest Record from Site

Wood Warbler BAP; 450m north Phylloscopus sibilatrix Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Woodcock Berne Convention:A3; 450m north Scolopax rusticola Birds of Conservation Concern4:Red; Bonn Convention:A2; BirdsDir:A2.1

Yellow Wagtail BAP; 450m north Motacilla flava Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Yellowhammer BAP; 450m north Emberiza citrinella Berne Convention:A2; Birds of Conservation Concern4:Red; Natural Environment and Rural Communities (Section 41)

Bradbourne Lakes, Extended Phase 1 Habitat Survey 11 March 2019 Extended Phase 1 Habitat Survey

3.2 Habitat descriptions are set out below. While considering this information, reference should be made to the Phase 1 Habitat Map presented in Figure 3.1, Appendix 2, and Target notes presented in Appendix 3.

Standing Water

3.3 Four of the five waterbodies within Bradbourne Lakes were located in the section of parkland south of Betenson Avenue. Of these four waterbodies the waterbody furthest north was the most formal in nature, and bordered amenity grassland which was mown short. The three lakes to the south were more naturalistic, being surrounded woodland and scrub habitats, described below.

3.4 A large waterbody was noted in the central west portion of parkland north of Betenson Avenue. The waterbody was surrounded by dense vegetation, comprising woodland, scrub and scattered trees (described below). To the south of the waterbody there was a large vegetated island, comprising co-dominant alder Alnus glutinosa and willow Salix sp. dense scrub. Running Water

3.5 A small stream which was fed from the south end of the northern lake was noted running north to south, the brickwork of the stream supported abundant pendulous sedge Carex pendula. The stream ran underneath Betenson Avenue and, in the parkland south of Betenson Avenue, was noted along the east boundary of the Site.

3.6 A small flowing ditch was noted running through the north east of the Site, which fed the north end of the northern lake. Woodland

3.7 A thin band of woodland habitat was noted around the 3 naturalistic lakes to the south. The canopy comprised a range of species including frequent hazel Corylus avellana, sycamore Acer pseudoplatanus, ash Fraxinus excelsior, willow, beech Fagus sylvatica, lime Tilia sp., London plane Platanus x hispanica, alder, holly Ilex aquifolium, wild cherry Prunus avium and elder Sambucus nigra. Robinia Robinia pseudoacacia and birch Betula sp. were rarely noted. Of these, lime, hazel, willow and beech were noted as locally dominant. Scrub layers within the woodland were thin, and were planted to restrict access to the lakeside. Species included box honeysuckle Lonicera nitida, box Buxus sempervirens, elder, cherry laurel Prunus laurocerasus and Portuguese laurel Prunus lusitanica. Garden privet Ligustrum ovalifolium was rarely noted. The ground flora comprised dominant Ivy Hedra helix which was also noted growing up trees. Locally frequent stands of daffodil Narcissus sp. and winter heliotrope Petasites fragrans and male fern Dryopteris filix-mas were noted in the ground flora.

3.8 The thickest band of woodland bordered the south and north west boundaries of the southern most lake. Locally dominant rows of mature lime and elder were planted along the southern boundary. Access was restricted in places and deadwood piles were noted on the woodland floor. The scrub layer was more developed and comprised a number of saplings including occasional cherry, lime and sycamore with rarely noted holly, bramble Rubus fruticosus agg., horse chestnut Aesculus hippocastanum and yew Taxus baccata. The ground in this location was notability damper than the rest of the Site and locally dominant patches of pendulous sedge Carex pendula were noted in the ground flora.

3.9 The waterbody furthest south supported two islands with abundant willow, cherry laurel and alder.

3.10 Within the segment north of Betenson Avenue, woodland habitat was noted to the south west and north. To the south west woodland comprised occasional poplar, elder, yew and hazel with locally dominant cherry laurel. The scrub layer comprised dominant bramble and ivy. A large London plane with a basal cavity was noted on a small island in the middle of the stream running north to south. Along the eastern boundary of the lake, woodland composition included frequent alder and hazel, with occasional ash and elder. A cedar Cedrus sp. tree and a single dawn redwood Metasequoia glyptostroboides were also noted.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 12 March 2019 3.11 Woodland in the north of the Site comprised occasional aspen Populus tremula, English oak Quercus robur, alder, ash, hazel, sycamore, lime, holly and cherry. London plane and yew were rarely noted. The scrub layer comprised locally dominant dense bramble scrub with frequent elder, holly, cherry laurel, snowberry Symphoricarpos albus and spindle Euonymus europaeus. Ivy was dominant in the ground flora, with locally frequent patches of lords and ladies Arum maculatum and flag iris Iris pseudacorus. A footpath ran through the woodland and box honeysuckle was noted planted as informal hedging around the path. Amenity Grassland with Scattered Trees

3.12 A large open area comprising amenity grassland with scattered trees was noted to the north and north west, typical of managed parkland habitats. Scattered trees included unidentified conifer species, red oak Quercus rubra, beech, cherry, birch, holm oak Quercus ilex and an unidentified tree of the walnut (Juglandaceae) family. A locally dominant patch of poplar Populus sp. was also noted, in addition to a single monkey puzzle Araucaria araucana tree. The amenity grassland contained common and widespread grass species including abundant perennial rye grass Lolium perenne and red-fescue Festuca rubra. In places there were locally dominant patches of ribwort plantain Plantago lanceolata.

3.13 To the south east and central east portion of the parkland north of Betenson Avenue amenity grassland with scattered trees was noted. Tree species included occasional ash, willow, sycamore, hazel, oak and wild cherry. Holly was rarely noted. Bulb flora included locally frequent stands of snowdrop Galanthus nivalis and daffodil. Locally dominant stands of hazel, managed as coppice, were also noted within this area. Fences

3.14 The east, west and south park boundaries were adjacent to residential gardens. These were often fenced. Linear Features

3.15 On the banks of the stream to the east a linear treeline comprising holly, hazel and yew was noted. Hardstanding

3.16 Hardstanding paths were noted around the Site. A small area of crazy paving was noted around the formal pond to the north.

Invasive Species

3.17 No invasive aquatic plants were noted within the Site. However, due to the hydro-connectivity of the Site, heavy recreational use and presence of wildfowl, there is potential for aquatic invasive species to be present, or establish in the future. Additionally, a review of biological records identified the following aquatic invasive species within 1km of the Site:

• Duck-potato Sagittaria latifolia; • Canadian waterweed Elodea Canadensis; • New Zealand pigmyweed Crassula helmsii; and • Himalayan balsam Impatiens glandulifera. 3.18 In the north of the Site there were a number of small stands of rhizomatous bamboo of the Phyllostachys genus, likely ‘garden escapees’. Snowberry was also noted within the woodland to the far north of the Site.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 13 March 2019

Bats

3.19 A review of biological records identified the following bat species within 1km of the Site: • Common pipistrelle Pipistrellus pipistrellus; • Serotine bat Eptesicus serotinus; • Nathusius's pipistrelle Pipistrellus nathusii; • Soprano pipistrelle Pipistrellus pygmaeus; • Brown long-eared bat Plecotus auritus; • Noctule bat Nyctalus noctula; and • Daubenton’s bat Myotis daubentonii. 3.20 The extensive open waterbodies, woodland and grassland habitats within the Site provided optimum habitat for foraging bats. Habitat included a variety of habitat niches capable of supporting range of species, including those which favour open or cluttered environments.

3.21 The dense canopy of trees formed by woodland and scattered trees provided good connectivity to the surrounding area. In particular, woodland and large waterbodies found within the Sevenoaks Gravel Pit Special Site of Scientific Importance (SSSI) provides optimal opportunities for foraging, commuting and roosting within the wider landscape.

3.22 Many mature trees were noted on Site with features suitable to support bat roosts (such as cavities, cracked limbs and lifted bark). Additionally, many trees in the woodland were noted to have dense ivy growing up them, potentially obscuring features with the potential to support roosting bats or providing potential roost features in their own right.

Badger

3.23 A review of biological records identified badger within 1km of the Site. 3.24 Woodland, dense scrub and open woodland within both the north and south of the Site provided optimal habitat for badger to forage and establish setts. Additionally, small sections of woodland had restricted public access, thereby reducing the potential for disturbance and increasing the suitability of these areas for sett building.

3.25 No signs of badger were recorded during the surveys. However, given the mobile nature of this species and tendency to build new setts, there is potential for badgers to disperse from suitable habitat in the wider area to form new setts within the Site.

Birds

3.26 Woodland, dense scrub and scattered tree habitats found on Site provide nesting and foraging opportunities for a range of common and widespread bird species.

3.27 The Site is likely to support a relatively diverse assemblage of birds due to the presence of woodland, grassland and open water habitats. Due to the proximity of the Site to the Sevenoaks Gravel Pits SSSI and the suitability of the habitats on Site, it is likely this includes species of principal importance and red-listed species of conservation concern (BoCC).

3.28 Woodland species of principle importance/BoCC which likely use the Site include: • Lesser spotted woodpecker Dryobates minor; • Spotted fly catcher Muscicapa striata;

Bradbourne Lakes, Extended Phase 1 Habitat Survey 14 March 2019 • Bullfinch Pyrrhula pyrrhula; • Song thrush Turdus philomelos; • Woodcock Scolopax rusticola; • Nightingale Luscinia megarhynchos; • Marsh Tit Poecile palustris; and • Cuckoo Cuculus canorus. 3.29 Wetland and water specialists also likely use the Site, including grey wagtail Motacilla cinerea and kingfisher Alcedo atthis.

3.30 Due to the suitability of the running water habitats on Site (including streams with brick channel walls), and proximity of the Site to the Sevenoaks Gravel Pit, there is potential for kingfisher to nest on or in the vicinity of the Site.

3.31 Wildfowl were noted on Site, including mallard and a number of Canada geese Branta canadensis.

Reptiles

3.32 A review of biological records identified the following entries for reptiles within 1km of the Site: • Slow worm Anguis fragilis; • Common lizard Zootoca vivipara; • Grass snake Natrix helvetica; and • Adder Vipera berus. 3.1 The Site supports suitable habitat for common and widespread reptile species, such as open grassland, watercourses, waterbodies, scrub and woodland habitat which provide opportunities for reptiles to forage, shelter and hibernate.

Great Crested Newt

3.2 A review of biological records included a single record of great crested newt (GCN) Triturus cristatus 120m north of the Site. Within the Sevenoaks Gravel Pit SSSI.

3.3 The desk study identified 15 waterbodies within 1km of the Site. Of the 15 waterbodies seven were isolated from the Site by a dense urban network of roads and residential houses. The remaining eight waterbodies were located within Sevenoaks Gravel Pit SSSI which is adjacent to the Site to the north.

3.4 Five large waterbodies were noted on Site, providing potential breeding habitat for GCN. Additionally, the Site provides optimal terrestrial habitat (including open grassland, woodland and scrub) for potential populations of GCN to forage, shelter and hibernate.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 15 March 2019 4 Discussion

Designated Sites

4.1 Sevenoaks Gravel Pit SSSI lies directly north of the Site and supports a wide assemblage of breeding and wintering birds. Given small scale and scope of the project it is thought that proposals are unlikely to impact this site directly.

4.2 The Site is hydrologically connected downstream of the Sevenoaks Gravel Pit SSSI, from which the streams and waterbodies found on Site are fed.

Habitats

4.3 The Site was mostly comprised of standing water, formed of five lakes. Four of the lakes were noted for their woodland edges and were heavily silted, likely due to a build-up of leaf litter and over-shading. These lakeside woodland habitats were noted to be of greater ecological value than other habitats on Site and comprised a diverse range of species. In particular, woodland along the south boundary of the Site comprised a range of trees of differing ages and condition, providing a wide range of ecological niche.

4.4 Other habitats on Site are generally common and widespread and easily replicated, including scattered trees and amenity grassland. However it should be recognised that the survey was undertaken at a sub-optimal time of year, and grassland may potentially be species-rich and of greater value than apparent during the survey.

4.5 It is understood that proposals will seek to retain and protect features of increased ecological value, including standing water and woodland habitats to the north and south.

4.6 Potential impacts on retained habitats as a result of the development include accidental damage during works (including damage to or compaction of tree roots), smothering from construction- related dust, and pollution from runoff. Aquatic habitats are at particular risk from contamination, run-off and pollution. The implementation of best practice construction is required to minimise these risks, for example:

• Phasing of works to avoid disturbance to large areas of habitats; • Secure storage and safe disposal of any materials and substances to prevent accidental contamination;

• Prevention or reduction of dust through timing of works or damping down; • Control of surface water runoff, including from damping down, preventing contamination of waterbodies; and

• Trees and vegetation are protected in accordance with best practice methods and guidance, BS5837: Trees in relation to design, demolition and construction.

Opportunities for Enhancement

4.7 It is recommended that ecological enhancements focus on improving the quality of water habitats and maximising the ecological potential of boundary habitats, including woodland to the south and north. Developing design and future management should also seek to retain and enhance ecological connectivity between the Site and the Sevenoaks Gravel Pit SSSI. In particular, woodland and running water habitats should be retained and connected where possible.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 16 March 2019 Selective Pruning and Felling of Trees

4.8 Proposals should seek to retain mature trees of higher ecological value whilst retaining the varied assemblage of tree species on Site.

4.9 A reduction of tree canopy and selective felling of a small number of trees around the lakes would help to increase light levels and reduce leaf litter within the ponds. In particular, felling trees along the south aspect of the waterbodies would be most beneficial.

4.10 Increased light levels caused by pruning and tree works may also encourage establishment of marginal vegetation. Therefore these works should be carried out prior to (or in conjunction with) works to enhance aquatic and marginal vegetation. This will help to maximise the chance of successful colonisation of marginal species.

4.11 It is recommended that any large diameter timber produced as part of potential felling works is stacked in an undisturbed area of woodland. These habitats are of particular importance to invertebrates and can be scarce within woodland habitats. Wet Woodland Creation

4.12 Locally dominants stands of alder and willow were noted around in the south of the Site, suggesting suitability for the establishment of wet woodland habitat (a habitat of principle importance). Creation of this habitat would benefit from additional planting of willow, which supports a wide range of invertebrate species, targeted along the banks of the waterbody to the south of the Site. To aid establishment this should be done in consideration to water levels, ensuring planted areas remain wet. Dredging

4.13 Outline proposals include dredging. Dredging would likely improve the water-holding capabilities and water quality of waterbodies on Site. An improvement of water quality would likely support a wider range flora and provide additional habitat niche for a range of species. The impacts of dredging with regards to protected species are discussed separately.

4.14 There is potential for sediment from dredging to be used as a planting substrate (if not heavily polluted). Dredged arisings may be backfilled against willow spilings to create planting beds at the edges of the waterbodies. This should be completed in line with recommendations for marginal vegetation enhancements below. Aquatic and Marginal Vegetation Enhancement

4.15 Marginal vegetation was limited to dominant scrub, with few tall ruderal and semi-aquatic plant species also noted. Enhancement could comprise the introduction of marginal and aquatic planting, through establishing reed banks, or through use of seeded coir matting (with a wet grassland mix) to soften lake-side edges. Lake margins should ideally be well vegetated and loosely managed to provide areas of sheltered terrestrial habitat for species such as amphibians. Additional consideration should be given to the introduction of native aquatic oxygenator plants, which would help improve water quality.

4.16 Suggested plants include: • Cyperus sedge Carex pseudocyperus; • Marsh marigold Caltha palustris; • Yellow flag iris Iris pseudocora; • Soft rush Juncus effusus; • Purple Loostrife Lythrum salicaria; and • Common club rush Schoenoplectus lacustris. 4.17 The flowing ditch found to the north east of the Site would also benefit from targeted sowing of woodland marginal wildflower species.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 17 March 2019

Creation of Reed Beds

4.18 Creation of marginal habitat should include reedbed. Reedbed is a habitat of principle importance and provides breeding, foraging and sheltering opportunities for a wide range of species. Due to the proximity of the Sevenoaks Gravel Pit SSSI is it likely that reedbeds on Site would attract a wide assemblage of bird species. Management of Amenity Grassland

4.19 A relaxation of grassland mowing regimes along woodland and open water habitat borders should be targeted, which would help to establish a more gradual edge of greater benefit to wildlife.

4.20 Additionally, wildflower meadows could be created within existing areas of grassland to provide foraging and sheltering opportunities for a range of wildlife. These could be enhanced and managed through the addition of native wildflower seed mixes and appropriate cyclical mowing regime. Creation of wildflower grasslands should be undertaken in accordance with the advice of specialist seed suppliers and should seek to use native species of local provenance wherever possible. Boundary Enhancement

4.21 Where possible, enhancements should also aim to increase habitat connectivity along the east and west boundaries through the creation of new linear features such as tree-lines and hedges, as well as strengthening existing linear features with native tree and scrub planting. This would provide additional foraging opportunities for species such as bats and birds, as well as improving commuting routes for bats. Dead Hedges

4.22 Established hazel coppice could be used to create traditional dead-hedging, of benefit to invertebrates and small mammals. Wildfowl Management

4.23 Water habitats on Site were subject to heavy pressures from wildfowl populations. The survey noted examples of bank erosion, build-up of faeces and a lack of marginal vegetation. In large numbers these species can contribute towards a reduction in water quality through stripping marginal and aquatic vegetation and eutrophication caused by excess faeces. It is recommended that measures to dissuade large populations of waterfowl are introduced to minimise future damage caused by excess numbers of these species.

4.24 Due to the proximity of the Site to the Sevenoaks Gravel Pit SSSI, control of Canada geese this species will be a challenge, as populations of this species would likely recolonise any available habitat niche. Enhancing marginal vegetation around lake sides would discourage geese from using the Site, which are known to prefer to open waterbodies with minimal cover for potential predators. To maximise the chances of discouraging geese from using the Site this should be done in conjunction with a relaxation of grassland border habitats and use of park interpretation boards to dissuade feeding of waterfowl.

Wildlife Interpretation

4.25 Provision of ecological interpretation could help public to interface with the park which supports an increase in biodiversity (for example, discouraging feeding of wildfowl). Habitat Management Plan

4.26 Development and implantation of a Habitat Management Plan (HMP) to inform future management of the Site and maintain any potential ecological gains. Any HMP should seek to maximise the quality of habitats, through increasing the diversity of habitat niches available.

4.27 The HMP should be informed by a period of monitoring and feedback. This should include consultation with a professional arboriculturalist on ongoing maintenance and management of trees on Site, in line with recommendations made above.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 18 March 2019 Invasive Species

4.28 The Site is sensitive to potential colonisation by invasive aquatic plant species. No invasive aquatic plants were noted during the survey, however it is recommended the Site is monitored annually for invasive species, to inform future management / control of these species.

4.29 The Extended Phase 1 Survey identified a number of ‘garden escapees’, including multiple stands of bamboo. It is recommended that consideration to their removal is given, to prevent further spread along lake side habitat.

Bats

4.30 Legal protection afforded to bats and their roosts is summarised in Appendix 1. In summary all bats and their roosts are subject to the highest level of protection afforded to species in the UK as European Protected Species (EPS).

4.31 The Site supported habitats suitable for roosting, foraging and commuting bats, comprising dense scrub, woodland, scattered trees and waterbodies.

4.32 The Site was well connected to a wider network of optimum bat habitat (including Sevenoaks Gravel Pit SSSI and the railway cutting to the east) by the dense tree canopy of woodland and parkland scattered trees.

4.33 Where possible, management of the Site should seek to retain all features with the potential to support bats. If future proposals require tree felling or significant tree surgery, they may have the potential to disturb, injure and/or kill roosting bats. Additionally, if proposals are to affect the woodland habitat, there is the potential to affect foraging and commuting bats.

4.34 Loss of BRP features or significant tree works/felling should be informed by appropriate survey as detailed below. Further Survey and Mitigation

Roost Surveys

4.35 It is recommended that prior to tree felling, crown reduction or major limb removal works bat surveys are undertaken. This would comprise a preliminary roost inspection of the trees to identify potential roosting features. If roosting features are identified, further survey would likely be required to confirm the status of any potential roosts. Further survey may comprise a bat roost inspection by a qualified tree climber (which can be conducted at any time of year), or dusk and dawn surveys to identify presence, exact location of emerging/returning bats and roost status.

4.36 The optimal bat survey window is May to August, with surveys also possible in April and September subject to weather conditions (and assuming at least two surveys are completed in the optimal window). Activity Surveys

4.37 If significant areas of woodland are to be affected by proposals (including changes to lighting regimes which have the potential to impact bat foraging and movement) then detailed activity surveys may be required to determine the level of use of the habitat by bats. Surveys would be undertaken at dusk and/or dawn, and would need to be dispersed through the survey season, between April and October. Licensing

4.38 If proposals include activities that may cause killing or injury of bats or that would result in the damage, loss or disturbance of a bat roost, a Natural England (NE) Bat Mitigation Licence would be required. More information on NE Bat Licensing is provided in Appendix 1.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 19 March 2019 Opportunities for Enhancement Bat Boxes

4.39 The installation of bat boxes mounted on trees within the woodland habitat across the Site could provide additional opportunities for roosting bats. Bat boxes ideally should be placed at least 4m above ground, sheltered from strong winds with partial exposure to the sun to help promote a stable and suitable temperate regime inside of the bat box. Further guidance on bat box placement and installation is provided through the bat conservation trust5. Habitat Enhancements

4.40 Many of the habitats enhancements made above would also be expected to benefit bats. Works to improve the quality of the waterbodies on site and to introduce areas of aquatic and marginal vegetation will increase the availability of prey for bats. Additionally improving the connectivity of boundary habitats will enhance commuting opportunities for these species.

Badger

4.41 Legislation afforded to badger is detailed in Appendix 1. 4.42 No signs of badger were recorded within the Site. The Site supports suitable badger breeding and foraging habitat, such as woodland and boundary features, which are well connected to suitable habitat in the wider area. In particular, the undisturbed woodland habitats found to the south and to the north of the Site provided ideal habitat for badger to establish new setts. Given badger are highly mobile and can rapidly establish new setts, there is potential for badger to be present within the Site.

Further Survey and Mitigation

Badger Survey

4.43 If proposals have the potential to result in disturbance to badger whilst using their setts, such as ground disturbance works or excavations in habitat suitable for badger, a badger survey may be required. The survey would determine if there are badger present to inform potential mitigation, which may involve the closure or relocation of any setts found on Site. Licensing

4.44 If proposals result in the need to disturb a confirmed badger set then NE licensing would be required. More information on NE licensing is provided in Appendix 1.

Opportunities for Enhancement

4.45 Due to the amenity use of the park and the potential for conflict between park users and this species, ecological enhancements specifically targeting badger are not recommended.

Birds

4.46 Legislation afforded to nesting birds is detailed in Appendix 1. 4.47 The Extended Phase 1 Habitat Survey included an assessment of habitats within the Site to support potential bird populations. The Site provides opportunities for a range of common and widespread birds to nest in trees, scrub and woodland. Furthermore, the Site likely supports an assemblage species of principal importance and red-listed species of conservation concern (BoCC), due to the presence of woodland and water habitats and the proximity of the Site to the Sevenoaks Gravel Pits SSSI.

5 https://www.bats.org.uk/our-work/buildings-planning-and-development/bat-boxes/putting-up-your-box

Bradbourne Lakes, Extended Phase 1 Habitat Survey 20 March 2019 Further Survey and Mitigation

4.48 If proposals will results in the loss of suitable bird habitat, including trees, dense scrub and hedgerows, there is potential for nesting bird to be affected. Work programmes should consider sensitive timings for vegetation clearance and removal of trees. These works should be undertaken between September-February (inclusive) to avoid the nesting season. If this cannot be achieved, inspections for the presence of bird nests should be undertaken by a suitably qualified and experienced ecologist prior to works commencing.

4.49 If birds’ nests are present and likely to be affected by works, a suitable protection site would be required until such time that the young have fledged and the nest is no longer active. This would likely result in delays to the programme and would need to be informed by a suitability qualified ecologist.

4.50 Additionally, prior to the commencement of any works affecting watercourse banks a pre- inspection check for kingfisher should be conducted by a suitability qualified ecologist.

Opportunities for Enhancement

Habitat Enhancements

4.51 Key species and BoCC species are known to occur locally and are considered likely to benefit directly as a result of the habitat creation and enhancements proposed above, particularly wetland species such as grey heron, kingfisher, reed bunting, sedge warbler, reed warbler and grey wagtail. Bird Boxes

4.52 The Site would benefit from the provision of bird boxes, in particular species-specific boxes for UK Biodiversity Species Action Plan Priority Species.

4.53 Proposals should seek to improve nesting cover and provide refuges for waterfowl. These could be positioned on the banks of the islands noted in the south and north lakes. These islands provide undisturbed habitat within the park, which may attract a wider assemblage of wildfowl to use the Site. Kingfisher Nesting Banks

4.54 It is thought that kingfisher likely use the Site. There is opportunity to incorporate a kingfisher nesting bank within the banks of the stream, providing additional nesting opportunities for this species.

Reptiles

4.55 Legislation afforded to reptiles is detailed in Appendix 1. 4.56 A search of biological records identified recent records of all four common and widespread reptiles (grass snake, adder, slow worm and common lizard) within the nearby Sevenoaks Gravel Pit SSSI. The Site provides suitable habitat for reptiles to forage, shelter and bask and it is thought likely that reptiles are present on Site. Proposals would involve disturbance of suitable reptile habitat therefore would risk injury or death to these species.

4.57 It is thought that due to the nature of the proposals risk to these species can be managed through implantation of precautionary measures and production of an Ecological Method Statement.

4.58 Precautionary methods may include: • An ecological watching brief conducted by a suitably experienced ecologist. • Habitat management techniques, such as gradual removal of vegetation to disperse populations from areas of high risk into adjacent suitable habitat.

• Creation of reptile hibernacula in a suitable position, away from areas to be affected by works.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 21 March 2019 • A destructive search of natural refugia prior to commencing works and the relocation of any reptiles to aforementioned created hibernacula.

Further Survey and Mitigation

4.59 Detailed reptile surveys would help to inform targeted mitigation and enhancement for these species. Reptile surveys can be undertaken between March – September.

Opportunities for Enhancement

Deadwood features

4.60 Management of woodland on Site should promote the creation and retention of deadwood, such as log and brash piles along boundary habitats and retention of standing deadwood where health and safety considerations permit. This would provide valuable habitat for reptiles, small mammals and invertebrates. Grassland Management

4.61 The relaxation of grassland management to promote the development of areas of tussock grassland would provide suitable foraging, basking and sheltering opportunities for these species. Habitat Enhancements

4.62 It is considered likely that reptiles will benefit directly as a result of the habitat creation and enhancements proposed above, as these enhancements will increase ecology niche for reptile prey species and provide additional sheltering and hibernation opportunities for these species.

Great Crested Newt

4.63 Legislation afforded to GCN is detailed in Appendix 1. 4.64 Due to proximity of the Site to the optimal GCN habitat of the Sevenoaks Gravel Pits SSSI, recent GCN recordings during the desk study and suitability of habitat on Site there is potential for this species to be present within Bradbourne Lakes, despite the road to the north which presents a limited barrier to dispersal.

4.65 Proposed dredging would involve major disturbance of aquatic habitat and likely result in the loss or disturbance of adjacent suitable terrestrial GCN habitat (including woodland and dense scrub). Therefore if GCN are present proposals would risk injury or death to this species.

Further Survey and Mitigation

eDNA Sampling

4.66 Initially, eDNA sampling of the ponds on Site should be completed to determine whether GCN are present or absent. eDNA samples can be collected between April-June inclusive. If eDNA survey confirmed presence then full GCN surveys would be required to establish a population estimate (see below). Pond Surveys

4.67 GCN pond surveys would be required in the event that the eDNA survey confirms GCN presence. Six survey visits would be required to establish a population estimate and inform potential mitigation. This would need to be undertaken between March – June. Licensing

4.68 If surveys confirm presence of GCN then works would require NE licensing. More information on NE licensing is provided in Appendix 1.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 22 March 2019 Appendix 1 Policy and Legislation Statutory nature conservation sites and protected species are a ‘material consideration’ in the UK planning process (DCLG 2012). Where planning permission is not required, for example on proposals for external repair to structures, consideration of protected species remains necessary given their protection under UK and EU law. Natural England Standing Advice aims to support Local Planning Authorities decision making in respect of protected species (Natural England 2012). Standing advice is a material consideration in determining the outcome of applications, in the same way as any individual response received from Natural England following consultation. The Conservation of Habitats and Species Regulations 2017 transpose the requirements of the European Habitats Directive (Council Directive 92/43/EEC) and Birds Directive (Council Directive 79/409/EEC) into UK law, enabling the designation of protected sites and species at a European level. The Wildlife and Countryside Act 1981 (as amended) forms the key piece of UK legislation relating to the protection of habitats and species. The Countryside Rights of Way Act 2000 provides additional support to the Wildlife and Countryside Act 1981; for example, increasing the level of protection for certain species of reptiles. The Protection of Badger Act 1992 provides specific protection for this species. The Wild Mammals Protection Act 1996 sets out the welfare framework in respect to wild mammals, prohibiting a range of activities that may cause unnecessary suffering. Species and Habitats of Principal Importance for Conservation in England and Wales and priority habitats and species listed in the Kent Biodiversity Action Plan (BAP) are species which are targeted for conservation. The government has a duty to ensure that involved parties take reasonable practice steps to further the conservation of such species under Section 41 of the Natural Environment and Rural Communities Bill 2006. In addition, the Act places a biodiversity duty on public authorities who ‘must, in exercising their functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’ (Section 40 [1]). Criteria for selection of national priority habitats and species in the UK include international threat and marked national decline. The National Planning Policy Framework (MHCLG 2018) states (Section 15) that the planning system should identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks; promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.

It also states that local planning authorities should refuse planning on the following principles:

• If significant harm to biodiversity resulting from a development cannot be avoided, adequately mitigated, or, as a last resort, compensated for;

• If development is on land within or outside a Site of Special Scientific Interest (SSSI), and is likely to have an adverse effect on it (the exception being where the benefits of the development in the location proposed clearly outweigh its likely impact);

• If development results in the loss or deterioration of irreplaceable habitats, such as ancient woodland and ancient or veteran trees (unless there are wholly exceptional reasons and a suitable compensation strategy exists). Additionally the NPPF states that development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to incorporate biodiversity improvements in and around developments should be encouraged, especially where this can secure measurable net gains for biodiversity.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 23 March 2019 Sevenoaks Core Strategy Policy SP11 (Biodiversity) states that “The biodiversity of the District will be conserved and opportunities sought for enhancement to ensure no net loss of biodiversity. Sites designated for biodiversity value will be protected with the highest level of protection given to nationally designated Sites of Special Scientific Interest, followed by Local Wildlife Sites and sites of local importance for biodiversity. Designated sites will be managed with the primary objective of promoting biodiversity whilst also providing for appropriate levels of public access. Opportunities will be sought for the enhancement of biodiversity through the creation, protection, enhancement, extension and management of sites and through the maintenance and, where possible, enhancement of a green infrastructure network to improve connectivity between habitats.”

Bats All British species of bat are listed on the Wildlife and Countryside Act 1981 (as amended) Schedule 5. It is an offence to deliberately kill, damage, take (Section 9(1)) a bat; to intentionally or recklessly disturb a bat whilst it occupies a place of shelter or protection (Section 9(4)(b)); or to deliberately or recklessly damage, destroy or obstruct access to a bat roost (Section 9(4)(c)). Given the strict nature of these offences, there is an obligation on the developer and owner of a site to consider the presence of bats. All British bats are listed on the Conservation of Habitats and Species Regulations 2017, Schedule 2. Regulation 41 strengthens the protection of bats under the 1981 Act against deliberate capture or killing (Regulation 41(1) (a)), deliberate disturbance (Regulation 41(1) (b))6 and damage or destruction of a resting place (Regulation 41(1) (d)). A bat roost is defined as any structure or place which is used for shelter or protection, irrespective of whether or not bats are resident. Buildings and trees may be used by bats for a number of different purposes throughout the year including resting, sleeping, breeding, raising young and hibernating. Use depends on bat age, sex, condition and species as well as the external factors of season and weather conditions. A roost used during one season is therefore protected throughout the year and any proposed works that may result in disturbance to bats, and loss, obstruction of or damage to a roost are licensable. Application for a Natural England EPS Licence Development works that may cause killing or injury of bats or that would result in the damage, loss or disturbance of a bat roost would require a Natural England (NE) Bat Mitigation Licence. For a Mitigation licence to be granted three tests must be met. Evidence is needed to determine these three tests: whether there is a need for the development which justifies the impact on the European Protected Species (EPS); whether there is an alternative which would avoid the impact and need for an EPS licence; and whether mitigation proposed is sufficient to maintain the conservation status of the EPS in question. A Mitigation Licence application will generally only be considered by NE on receipt of planning consent, and once any pre-commencement conditions of relevance to ecology have been discharged. There are two licensing routes now available for bats, which comprise:

Full NE England EPS Mitigation Licence:

• NE aim to determine the application within six weeks (although this can take longer). • The application comprises three components including an application form (broad details of the applicant, site and proposals); a detailed Method Statement providing the survey methods and findings, impact assessment and mitigation measures (including detailed maps and schedule of works); and a Reasoned Statement outlining the „need‟ for the development and consideration of alternatives. NE Low Impact Class Licence

• This new route provides an alternative, quicker route (with a much reduced application form, and a target of 10 days to determine an application).

6 Relates specifically to deliberate disturbance in such a way as to be likely to significantly affect i) the ability of any significant group of animals of that species to survive, breed or rear or nurture their young or ii) the local distribution of that species.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 24 March 2019 • This Low Impact Class Licence is only available to Registered Consultants identified by NE. • This is available for sites which support up to three low status roosts (day roosts, night roosts, feeding roosts and transitional roosts) of a maximum of three common species. The common species which can be covered by this licence include common pipistrelle, soprano pipistrelle, brown longeared, whiskered, Brandts, Daubenton‟s and Natterer‟s bat.

• All licensed works require evidence that there is a need for the development and that appropriate mitigation, including seasonal constraints and provision of alternative habitat and/or roosting structures is considered.

• This licence cannot be used in relation to trees. Several species of bat, including brown long-eared and soprano pipistrelle are listed as species of principal importance under the NERC Act (2006). Section 41 of the Act is used to guide decision-makers such as public bodies, including local and regional authorities, in implementing their duty under section 40 of the Natural Environment and Rural Communities Act 2006, to have regard to the conservation of biodiversity in England, when carrying out their normal functions.

Reptiles All UK reptiles and amphibians are legally protected from intentional and reckless killing and injury under the Wildlife and Countryside Act 1981 (as amended).

Badger Badger are subject to legal protection under the Protection of Badgers Act (1992). Works which may result in damage to a badger sett, or potential disturbance to badger using setts, must be undertaken under a Natural England licence.

Nesting Birds Birds and their nests are protected by the Wildlife and Countryside Act 1981 (as amended). This Act gives protection to all species of bird with regard to killing and injury, and to their nests and eggs with regard to taking, damaging and destruction. Certain species listed on Schedule 1 of the Act, are afforded additional protection against protection.

Great Crested Newts All great crested newts (GCN) are listed on the Wildlife and Countryside Act 1981 (as amended) Schedule 5. It is an offence to deliberately kill, damage, take (Section 9(1)) a GCN; to intentionally or recklessly disturb a GCN whilst it occupies a place of shelter or protection (Section 9(4)(b)); or to deliberately or recklessly damage, destroy or obstruct access to a GCN place of shelter (Section 9(4)(c)). Given the strict nature of these offences, there is an obligation on the developer and owner of a site to consider the presence of bats. All great crested newts are listed on the Conservation of Habitats and Species Regulations 2010, Schedule 2. Regulation 41 strengthens the protection of bats under the 1981 Act against deliberate capture or killing (Regulation 41(1) (a)), deliberate disturbance (Regulation 41(1) (b))[1] and damage or destruction of a resting place (Regulation 41(1) (d)). Great crested newt resting place is defined as any structure or place which is used for resting, shelter or protection by GCN at any life stage, irrespective of whether or not GCNs are resident. A variety of aquatic, marginal and terrestrial habitats can be used by GCNs for a number of different purposes throughout the year including resting, sleeping, foraging, breeding, migrating and hibernating. Use depends on GCN age, sex and condition as well as the external factors of season and weather

[1] Relates specifically to deliberate disturbance in such a way as to be likely to significantly affect i) the ability of any significant group of animals of that species to survive, breed or rear or nurture their young or ii) the local distribution of that species.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 25 March 2019 conditions. A resting place used during one season is therefore protected throughout the year and any proposed works that may result in disturbance to GCN, and loss, obstruction of or damage to a resting or sheltering place are licensable. Application for a Natural England EPS Licence Development works that may cause killing or injury of GCNs or that would result in the damage, loss or disturbance of a GCN resting or sheltering place would require a Natural England (NE) GCN Mitigation Licence. For a Mitigation licence to be granted three tests must be met. Evidence is needed to determine these three tests: whether there is a need for the development which justifies the impact on the European Protected Species (EPS); whether there is an alternative which would avoid the impact and need for an EPS licence; and whether mitigation proposed is sufficient to maintain the conservation status of the EPS in question. A Mitigation Licence application will generally only be considered by NE on receipt of planning consent, and once any pre-commencement conditions of relevance to ecology have been discharged. There are two licensing routes now available for GCNs, which comprise: Full NE England EPS Mitigation Licence:

• NE aim to determine the application within six weeks (although this can take longer). • The application comprises three components including an application form (broad details of the applicant, site and proposals); a detailed Method Statement providing the survey methods and findings, impact assessment and mitigation measures (including detailed maps and schedule of works); and a Reasoned Statement outlining the ‘need’ for the development and consideration of alternatives. NE Low Impact Class Licence

• This new route provides an alternative, quicker route (with a much reduced application form, and a target of 10 days to determine an application).

• This Low Impact Class Licence is only available to Registered Consultants identified by NE. • This licence might apply if the following criteria are met:

o The footprint of the activity must not extend beyond a certain threshold size, in terms of area of impact affecting habitat used and relied upon by great crested newt (for resting). This size is determined in part by the distance from a waterbody used by GCN, with larger areas of land- take being acceptable at greater distance from waterbodies;

o Typically the activity would be of a relatively short duration, i.e. up to six months and no longer than 12 months; and

o Waterbodies used by great crested newts must not be affected; although ditches along linear schemes that are used by great crested newts may be temporarily impacted across a part of their length.

• All licensed works require evidence that there is a need for the development and that appropriate mitigation, including seasonal constraints and provision of alternative habitat is considered.

• Before Natural England can confirm the site is registered and licensable works can commence, an assessment of the three tests must be undertaken by the Registered Consultant. Although this does not need to be submitted to NE, NE may subsequently undertake a review of the project and request to see all evidence as collected by the Consultant. This can only be undertaken following a survey and impact assessment which must be carried out in accordance with licence conditions and GCN best practice guidelines. Great crested newts are listed as species of principal importance under the NERC Act (2006). Section 41 of the Act is used to guide decision-makers such as public bodies, including local and regional authorities, in implementing their duty under section 40 of the Natural Environment and Rural Communities Act 2006, to have regard to the conservation of biodiversity in England, when carrying out their normal functions.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 26 March 2019 Appendix 2

Figure 3.1 – Extended Phase 1 Habitat Survey Map

Bradbourne Lakes, Extended Phase 1 Habitat Survey 27 March 2019 |

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0 25 50 E Meters

Site boundary HS Hard standing VVVVVJ2.1.1 Intact hedge Bradbourne Lakes, (native species-rich) Sevenoaks Phase 1 habitat codes J1.2 Amenity grassland A A A J2.1.2 Intact hedge A1.1.1 Broadleaved woodland (semi-natural) / A2.2 Scrub (scattered) A! A! A! (species-poor) A! A! A! AJ1.2 Amenity grassland J2.2.2 Defunct hedge Figure 3.1: Bradbourne Lakes A1.1.1 Broadleaved woodland (semi-natural)! ! ! / A3.1 Broadleaved scattered (species-poor) Extended Phase 1 Habitat Map / A2.1 Scrub (dense/continuous) A! A! A! A ! ! ! ! ! ! ||||||||| A1.3.1 Mixed woodland (semi-natural) A A A Atrees J2.4 Fence ! ! ! ! ! ! J1.2 Amenity grassland / A3.3 A ! A ! A ! A J2.5 Wall A2.1 Scrub (dense/continuous) ! ! ! Mixed scattered trees ! ! ! ! ! ! ! ! ! ! ! !A3.1 Broadleaved scattered trees J1.4 Introduced shrub . Target notes S!I S!I S!I S!I S!I S!I ! ! ! ! ! J4 Bare ground SI SI SI SI SI SIB6 Poor semi-improved grassland ! ! ! ! ! !( Invasive species SI SI SI SI SI SI ! ! ! ! ! Source: LUC G1 Standing water G2 Running water

Map Scale @A3: 1:1,500 Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community CB:LA EB:Archer_L LUC FIG_3_1_10270_Phase1_A3P 25/02/2019 © Crown copyright and database rights 2019 Ordnance Survey 0100031673 Appendix 3 Extended Phase 1 Habitat Survey – Target Notes

Target Description Photograph Note

1 Frequent robinia Robinia pseudoacacia, hazel Corylus avellana coppice, wild cherry Prunus avium, mature birch Betula sp.. To the north large birch Betula sp., cherry Prunus sp. and holly Ilex aquifolium with ivy Hedera helix noted climbing.

Ground flora includes occasional hogweed Heracleum sp., with frequent creeping buttercut Ranunculus repens, dock, red dead nettle Lamium purpureum, nettle Urtica dioica, locally dominant Spanish bluebell Hyacinthoides hispanica and occasional pendulous sedge Carex pendula.

To the edges of the plot dominant bramble Rubus fruticosus agg. , though not dense and appears managed (strimmed).

2 Small area of ornamental planting. Box honeysuckle dominant Lonicera nitidia, bamboo and bramble Rubus fruticosus agg.

3 Single mature oak Quercus robur within N/A woodland. Grassland beneath dominant daisy Bellis perennis, speedwell species Veronica sp., rib wort plantain Plantago major and snowdrop Galanthus nivalis

Bradbourne Lakes, Extended Phase 1 Habitat Survey 29 March 2019 Target Description Photograph Note

4 2 large mature beech Fagus sylvatica. Features identified with potential to support roosting bats (large cavities present).

5 Locally dominant area of pendulous sedge N/A Carex pendula on wet ground. Large diameter deadwood noted semi-submerged.

6 Stand of locally dominant butterbur Petasites sp.

7 Monkey puzzle Araucaria araucana tree planting amongst scattered trees.

8 Locally dominant stand of poplar Populus sp. N/A

9 Large London plane Acer × acerifolia N/A

10 Island willow Salix sp. overhanging with co- N/A dominant cherry laurel Prunus laurocerasus and alder Alnus glutinosa scrub.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 30 March 2019 Target Description Photograph Note

11 Island in the middle of stream with mature London plane Acer × acerifolia. Cavity noted at base.

12 Hazel Corylus avellana coppice.

13 Dominant stand of cherry laurel Prunus N/A laurocerasus in the scrub layer.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 31 March 2019 Target Description Photograph Note

14 Large stand of bamboo.

15 Locally dominant flag iris Iris pseudacorus. N/A

16 Large mature London Plane Tree Acer × N/A acerifolia.

17 Perennial rye grass, daisy Bellis perennis, N/A cranesbill species Geranium spp. and ribwort plantain Plantago lanceolata

Trees and shrubs along fence comprising single hazel, hydrangea, conifer and beech.

18 Yew Taxus baccata, holly Ilex aquifolium and hazel Corylus avellana treeline leading down to stream. Rare cherry Prunus sp. tree. Sides maintained as a hedge.

19 Scattered trees include poplar Populus sp., conifers, red oak Quercus rubra, beech Fagus sylvatica, cherry Prunus sp., birch Betula pendula, Holm oak Quercus ilex. Grass common N/A and wide spread amenity species, with dominant ribwort plantain Plantago lanceolata.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 32 March 2019 Target Description Photograph Note

20 Hazel Corylus avellana, sycamore Acer pseudoplatanus, cherry Prunus sp.. Scrub layer comprised bramble Rubus fruticosus agg., ivy Hedera helix, cherry laurel Prunus laurocerasus. Rarely noted male fern Dryopteris filix-mas.

21 Woodland no access with dominant alder Alnus glutinosa. Also noted frequent hazel Corylus avellana and rare garden privet Ligustrum ovalifolium and holly Ilex aquifolium. Ground flora comprised dominant ivy Hedera helix. Deadwood piles noted on ground.

22 Note on woodland composition. Occasional Salix N/A sp, English oak Quercus robur, birch Betula sp., ash Fraxinus excelsior and locally dominant alder Alnus glutinosa

Bradbourne Lakes, Extended Phase 1 Habitat Survey 33 March 2019 Target Description Photograph Note

22 Evidence of bank erosion.

23 Small stream NE of site. Pendulous sedge Salix pendula noted.

24 To the north of the Site a large area of woodland was noted. The northern canopy comprised aspen Populus tremula, English oak Quercus robur, alder, ash, hazel, sycamore, lime, holly and cherry. London plane and yew were rarely noted. The scrub layer comprised locally dominant dense bramble scrub with frequent elder, holly, cherry laurel, snowberry Symphoricarpos albus and spindle Euonymus europaeus. Ivy was dominant in the ground flora, with locally frequent patches of lords and ladies Arum maculatum and flag iris Iris pseudacorus. A footpath ran through the woodland and box honeysuckle was noted planted as informal hedging around the path.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 34 March 2019 Target Description Photograph Note

25 North lake island with co-dominant alder Alnus glutinosa and willow Salix sp. dense scrub.

26 A thin band of woodland habitat was noted around the 3 naturalistic lakes to the south. The canopy comprised a range of species including frequent hazel Corylus avellana, sycamore Acer pseudoplatanus, ash Fraxinus excelsior, willow Salix sp., beech Fagus sylvatica, lime Tilia sp., London plane Platanus x hispanica, alder Alnus glutinosa, holly Ilex aquifolium, wild cherry Prunus avium and elder Sambucus nigra.

Scrub layers within the woodland were thin, and were planted to restrict access to the lakeside. Species included box honeysuckle Lonicera nitida, box Buxus sempervirens, elder Sambucus nigra, cherry laurel Prunus laurocerasus and Portuguese laurel Prunus lusitanica.

Ivy Hedra helix was frequently noted in the ground flora as well as growing up trees. Additionally locally frequent stands of daffodil Narcissus sp. and winter heliotrope Petasites fragrans and male fern Dryopteris filix-mas were noted in the ground flora.

Bradbourne Lakes, Extended Phase 1 Habitat Survey 35 March 2019 Target Description Photograph Note

Bradbourne Lakes, Extended Phase 1 Habitat Survey 36 March 2019