SECTION C MINERALS AND WASTE DISPOSAL
Background Documents - the deposited documents, views and representations received as referred to in the reports and included in the development proposals dossier for each case and also as might be additionally indicated.
Item C1 First time sewer network and upgrade of existing wastewater treatment works and associated infrastructure for New Romney, Greatstone-on-Sea and Lydd-on-Sea – SH/05/0053
A report by Head of Planning Applications Unit to Planning Applications Committee on 19 July 2005.
An application for a first time sewer network to serve individual properties in existing settlements, associated upgrade of existing wastewater treatment works and associated infrastructure to serve the settlements of New Romney, Greatstone-on-Sea and Lydd-on- Sea by Southern Water Plc.
Recommendation: subject to completion of a legal agreement Planning Permission BE GRANTED.
Local Member: Mr F Wood-Brignall Unrestricted
Introduction
1. Members of the Planning Applications Committee visited the area and two sites in particular, The Lade Car Park, Greatstone-On-Sea and Church Road construction compound, New Romney on 31 May 2005. The minutes of that visit are appended to this report (Appendix 1).
The Site and Surroundings
2. The planning application area is complex and is probably best understood by reference to the site plans on the following pages. It encompasses most of New Romney, all of Greatstone-on-Sea and Lydd-on-Sea; detailed descriptions of areas where there are particular issues will be given later in the report.
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3. The land use within the scheme area is predominantly residential with some commercial and retail businesses, the latter located primarily in New Romney. Parts of the proposed first time sewerage (FTS) and some of the pumping stations would be located on the periphery of the built up area, which is bordered by low lying agricultural and pasture land. The landscape is generally open with views across a wide area. To the south of New Romney and west of Greatstone, lies the Denge Marsh. Within this area are a number of designated sites including the Dungeness Candidate Special Area of Conservation (cSAC), Dungeness to Pett Level Special Protection Area (SPA) as well as several Sites of Special Scientific Interest (SSSI’s) and a National Nature Reserve (NNR).
4. The main roads running through the area include the A259, which runs through New Romney and is the main route into the scheme area. The B2071 runs between New Romney and Littlestone-on-Sea, thereafter connecting to the coast road that runs down through Greatstone-on-Sea and on to Lydd-on-Sea.
5. New Romney Wastewater Treatment Works (WTW) itself lies to the east of the Romney Hythe and Dymchurch Railway line south of Littlestone-on-Sea and north of Greatstone-on-Sea and is reached via a dedicated access road off the B2071. The WTW is sited against a backdrop of a wooded tree belt on the edge of open rough grassland that stretches over
6. 500m to the south of the southern edge of housing in Littlestone-on-Sea. It is generally well located within the landscape and shielded from most views they mostly being from a distance.
Location Plan
7. I attach the following site plans showing the extent of the scheme in New Romney, Greatstone-on-Sea and Lydd-on-Sea. Large scale versions of these plans will be displayed in the council chamber at committee and the report will be available on the website.
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New Romney Location Plan
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Greatstone Location Plan
Need for the Scheme
8. The UK water regulator, OFWAT, is responsible for ensuring that water companies carry out their responsibilities under the Water Industry Act 1991. They also have a responsibility to ensure that the Urban Waste Water Treatment Directive (UWWTD) is complied with. Under the UWWTD, member states have until December 2005 to provide first time sewerage to urban areas with a population equivalent threshold of 2000 persons. However, OFWAT has granted a derogation of this obligation to Southern Water until 2007.
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9. Shepway District Council also requested through Section 101A of the Water Industry Act 1991 that first time sewerage be provided for New Romney. The Applicant has a duty to respond to this.
Proposal
10. The application is to provide a First Time Sewerage (FTS) collection system for New Romney, and Greatstone-on-Sea and Lydd-on-Sea (hereafter referred to as Greatstone). The majority of properties in New Romney and all properties in Greatstone currently use either septic tanks or cesspools for wastewater and sewerage collection.
11. The proposed scheme would comprise in total approximately 29km of rising main and gravity sewer with associated infrastructure as well as requiring an upgrade to New Romney WTW. The scheme can effectively be split into three parts, the system proposed for New Romney; the system proposed for Greatstone and the upgrade to the treatment works. I shall now describe the proposal for each part in a little more detail.
12. New Romney FTS would comprise a gravity sewer system with pipelines running beneath the roads. These would feed into a series of pumping stations located around the periphery of the town and providing the necessary pressure to transport sewage east to the existing New Romney WTW. The pumping stations would in most cases be sited on open land immediately adjacent to the peripheral roads.
13. The following are the key elements of the New Romney FTS scheme:
• 5950m of sewer constructed in open cut trench; • 600m of rider sewer constructed in open cut trench; • 1340m of sewer constructed by trenchless methods; • 3150m of rising main constructed in open cut trench; and • 5 submersible pumping stations and one storage chamber
14. In addition at four of the five pumping stations a temporary site compound would be required for materials and equipment storage and general site facilities e.g. portacabin offices, toilets, fuelling facilities etc. The compounds would be located immediately adjacent to the pumping station sites. Compounds at pumping stations 1 and 3 would be larger to also serve as main construction compounds for works associated with the laying of the sewers. All compounds would be fenced off and secured to prevent unauthorised access.
15. Greatstone-on-Sea FTS would comprise a vacuum sewer system. As with the New Romney section all pipelines would run beneath the roads, with Coast Drive acting as C1.5
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the main artery. Following negotiations a combined pumping station/public toilet building would be constructed within the existing car park opposite the junction of Coast Drive and Taylor Road with a minor extension to the rear of the car park. From here sewage would be pumped northwards where a connection would be made to the existing sewer system located approximately at the junction of Dunes Road and Alfred Road.
16. The following are the key elements of the Greatstone FTS scheme:
• 11,100m of vacuum sewer of sizes 110mm to 200mm diameter • Four vacuum sewer sub catchments discharging to the vacuum station • 518 approx. number vacuum collection chambers with vacuum system valves • 3,600m of 90mm diameter crossover pipe connecting the collection chambers to the vacuum sewers • Vacuum station with 4 vacuum pumps, 1 vacuum/sewage vessel and 2 pumps discharging to Dunes Road pumping station via a 2980 long 200mm diameter rising main
17. Two temporary construction compounds are proposed one adjacent to the existing Dunes Road pumping station and the other on the car park adjacent to the proposed vacuum pumping station on Coast Drive. Both compounds would be fenced off and secured to prevent unauthorised access.
18. New Romney Wastewater Treatment Works upgrade would comprise the following elements:
• Replacement or refurbishment of some of the existing assets in order to optimise operational and treatment efficiency; • Provision of two new humus tanks in order to meet surface loading requirements; • More extensive upgrading work in relation to the inlet works, effluent recycle and washwater facilities; • A UV standby facility • One new primary settlement tank • A new plastic media biological filter; • A deep bed rapid granular media filter; • sludge thickening and storage to handle the increase in sludge production, and • extra storm storage (may be needed)
19. A temporary construction compound would be required adjacent to the northern boundary of the site on land owned by Southern Water. It would include contractor site offices, mess facilities, storage, car parking etc. The compound would extend approximately 20m from the existing access gate fence line, northwards, parallel to the access road and cover an area of 10,000m 2. Access into the compound would be
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via the main WTW access road off Station Road. A separate entrance into the compound would be created in order that normal site operations traffic would not be unduly disrupted. Except for areas incorporated into the new works, the construction compound would be reinstated to agricultural use on completion.
20. Construction of the first time sewerage system necessitates the upgrading of the WTW in order to meet the anticipated more stringent discharge consent. At the present time, a long sea outfall (LSO) is not being included in the scheme and is subject to ongoing discussions between Southern Water, OFWAT and the Environment Agency. The proposed upgrade works at the WTW are therefore based on a “worst case” scenario i.e. most stringent discharge requirements, which would apply without an LSO.
21. The application is accompanied by an Environmental Impact Assessment (EIA). Work on the EIA commenced in May 2004, although outline engineering design and some preliminary environmental studies had been ongoing since earlier in that year. The Environmental Statement presents the studies that have been undertaken, the assessment of potential impacts and the need for mitigation to reduce identified significant impacts.
Appropriate Assessment
22. Where a project is likely to have a significant effect on conservation objectives of a European designated site (either alone or in combination with other plans or projects), and it is not directly connected with or necessary to the management of the site, the Conservation (Natural Habitats, &c.) Regulations 1994 (The Habitats Regulations) require that an appropriate assessment of the impacts be carried out. English Nature has advised that an Appropriate Assessment will need to be undertaken in respect of the Dungeness Candidate Special Area of Conservation.
23. Whilst the process of EIA and Appropriate Assessment are legally separate, they require similar data. The ES submitted with the applications therefore provides much data on which the Appropriate Assessment can be based. However the Applicant has submitted a document with additional information to inform the Appropriate Assessment process.
24. The purpose of the appropriate assessment is to assess the implications of the proposals in respect of the site’s ‘conservation objectives’. The County Council takes advice from English Nature as to the impacts and mitigation proposed towards achieving these conservation objectives. The conclusions of the assessment should enable the competent authority to ascertain whether the proposal would adversely C1.7
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affect the integrity of the site. Planning permission should not be granted until the assessment has concluded positively.
25. I have carried out an Appropriate Assessment on behalf of the County Council and considered the potential ‘in-combination’ effects with the Romney Marsh Countryside Project guided walks to the Listening Mirrors at The Lade. I have concluded that whilst the proposed development (project) could adversely affect the integrity of the site the imposition of conditions/restrictions would avoid adverse effects on the integrity of the site. English Nature have further confirmed their support for this document.
26. I attach a copy of the Appropriate Assessment for Members approval.
Alternatives and Best Practical Environmental Option (BPEO) Assessment
27. Schedule 4, Part 1 (2) of the EIA Regulations requires the applicant to outline the main alternatives studied and give an indication of the main reasons for the scheme proposed, taking into account environmental effects. A full analysis of the alternatives considered is detailed in chapter 1.5 of the ES.
28. Some elements of government advice relating to BPEO cannot readily be applied to wastewater; for example the requirement of regional self-sufficiency is more relevant to other waste streams. However in considering the alternatives the Applicant has arrived at options which follow the environmental criteria of BPEO as laid down in PPG10 that is, “for a given set of objectives, the option that provides the most benefits or the least damage to the environment as a whole, at acceptable cost, in the long term as well as in the short term”.
Policy Context
29. There are extensive planning policy implications relating to these proposals. The policy issues are set out in detail in the Environmental Statement (ES) submitted with the applications. Based upon the designations identified in the ES and the potential impact of the proposal a summary of the relevant policies and advice follows.
Government Guidance
30. Circular 17/91 - Water Industry Investment: Planning Considerations - acknowledges that local planning authorities have a key role in facilitating water industry development proposals. It confirms a presumption in favour of the expansion of wastewater treatment facilities in the interests of long term wastewater management, providing the
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need for such facilities outweigh any adverse land use or environmental impact, and that any such adverse impact is minimised. In considering the environmental impact one must be aware of the sensitive nature conservation and landscape designations. Special care should be exercised in considering proposals which affect designated sites of importance to wildlife (ie SSSI’s, SPA’s, RAMSAR & cSAC’s), where the international significance should normally outweigh development proposals by the water industry. The circular advises “in considering development proposals expeditiously, local planning authorities should nevertheless assess and weigh thoroughly all material considerations and any conflicting demands”.
31. It also acknowledges that siting of water treatment works is constrained by the location of water companies’ water sources and trunk mains. The choice of process is determined by the regulatory standards to be met. The coastline is also protected by various policies which seek to protect its undeveloped character as well as the scientific nature interest along its length.
32. Government guidance on the location and design of development is contained in Planning Policy Guidance notes (PPGs) and Government Circulars. PPGs are to be replaced (through a rolling programme) with focussed statements of national planning policies – Planning Policy Statements (PPS). The Environmental Impact Assessment has been prepared in light of this national guidance.
PPG1 - General Policy & Principles PPS1 - Creating Sustainable Communities PPG7 - The Countryside - Environmental Quality and Economic and Social Development PPS7 - Sustainable Development in Rural Areas PPG9 - Nature Conservation PPS9 - Biodiversity and Geological Conservation PPG10 - Planning and Waste Management PPS10 - Planning for Sustainable Waste Management (consultation draft) PPG13 - Transport PPG15 - Planning and the Historic Environment PPG16 - Archaeology and Planning PPG17 - Planning for Open Space, Sport and Recreation PPG20 - Coastal Planning PPG21 - Tourism PPG23 - Planning and Pollution Control PPS23 - Planning and Pollution Control PPG24 - Planning and Noise
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Regional Policy
33. RPG9 - Regional Planning Guidance for the South East – The regional context for the proposed scheme is set out in RPG9, which identifies the following key development principles for the region:
• Urban areas should be the main focus for development, • Greenfield development should normally take place only after other alternatives have been considered. • Protection and enhancement of the region’s biodiversity, landscape and built and historic heritage.
34. There are specifically a number of policies contained within the guidance that are relevant to this proposal namely, Q7: Rural Development, Q8: Sustaining Rural Communities, E1: Areas of International and National Importance for Nature Conservation, Landscape and Cultural Value E2: Biodiversity, E4 Wider Countryside including Coastal and River Environment and INF: The Water Cycle.
35. During 2004/5, the South East England Regional Assembly (SEERA) is undertaking a comprehensive review of RPG 9. SEERA will prepare the draft regional spatial strategy, with a view to publishing the Draft Proposals for consultation, and submitting the new South East Plan to the Government later this year.
Development Plan Policy
Kent Structure Plan 1996
S1 - Seeks to promote sustainable forms of development. S2 - Seeks to conserve and enhance the quality of Kent’s environment. S9 - Highlights the need for co-ordinated implementation, and the relationship between infrastructure provision and land availability. ENV1- Protection of the countryside for its own sake. ENV2 - Conserve and enhance Kent’s landscape and wildlife (flora and fauna) habits. ENV15 - Conserve and enhance the character, quality and functioning of Kent’s built environment. ENV20 - Seeks to ensure that development is planned and designed so as to avoid or minimise any potential pollution impacts. ENV22 - Need in relation to environmental and other material interests NR2 - Encourages wastewater treatment development subject to the need outweighing any environmental impact and that any such adverse impact is minimised.
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NR3 - Aims to protect groundwater from development that would have an unacceptable effect on groundwater quality or the yield of water.
36. The Structure Plan emphasises the importance of sustainable planning of water and wastewater. It says that, of the services needed to sustain new and existing development, water supply, sewerage and wastewater treatment ‘deserve particular consideration’, in view of the cost of using remote supply sources or treatment facilities and possible environmental implications.
37. The Structure Plan acknowledges that significant improvements have been made to the quality of effluent discharged to watercourses, estuaries and the sea, and the Government’s advice to local authorities to support water industry development proposals. It notes that new or expanded sewerage and wastewater treatment facilities will be needed and that their provision can have significant implications for local environments, but that ‘their location will often be constrained by geology and topography.
Kent Waste Local Plan 1998
38. There are no specific policies that relate to the provision of a first time sewerage network.
Shepway District Local Plan
39. The adopted local plan covers the period up to 2001 and is currently in the final stages of review and therefore is largely replaced by the Revised Deposit Draft which carries increasingly greater weight in the development control process. However the adopted local plan recognised that the present system of sewerage infrastructure would constrain future development and contained a number of policies specifically aimed at requiring connection to mains drainage above a certain scale of development. The Plan acknowledged that a scheme for the first time sewerage of certain areas was likely to be requisitioned in the future. The Local Plan also contains a number of policies to protect designated areas within the countryside and policies designed to protect and enhance the built environment.
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Emerging Planning Policy
The Kent & Medway Structure Plan – Deposit Plan September 2003
40. The deposit plan acknowledges the role of New Romney as the key rural service centre for the Romney Marsh area and supports measures to stimulate the rural economy (Policy CC3).
41. Existing Structure Plan policies to protect the environment are largely reaffirmed, with policies to protect and enhance the built environment and cultural hermitage.
42. The Deposit Draft notes that water companies are ‘investing heavily in upgrading (wastewater) treatment processes provided at coastal sites’. The proposed policy for wastewater (the equivalent to Structure Plan Policy NR2) is NR8, the relevant part of which states:
“The development of new or expansion of existing water supply or wastewater facilities will be supported where:
• There is a demonstrable need to serve existing and /or development proposed in accordance with the development plan; and
• This represents the best environmental option; and use and environmental impacts are minimised through appropriate mitigation.”
Shepway District Council Local Plan Revised Deposit Draft 2002
43. One of the key aims of the plan in the application area is to foster sustainable development. The broad sustainable development objectives of the plan are to ensure effective protection of the environment, to promote the efficient use of natural resources, to meet people’s needs, to encourage economic growth and employment opportunities and reduce the need to travel.
44. The relevant sections of the ES give detailed indication of how the scheme will impact on the environment and discuss how the proposed scheme accords with the policies of the development plan. It is argued in the application that bringing about improvements to the sewerage disposal system in New Romney and Greatstone-on- Sea would benefit the quality of life of residents and would improve the environmental performance of the waste management system. It is further argued that this would be achieved without the loss of environmental quality and no long-term disbenefits that would be contrary to development plan policy.
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Consultees
45. Shepway District Council – No objection subject to SDC agreeing specification for the new public toilet (and pumping station) building at The Lade car park, implementation of mitigation measures to protect occupants of dwellings near pumping stations at Church Road and Dunes Road, protection of water resources to satisfaction of the EA, provision of fencing to protect shingle verges along Coast Drive, protection of archaeological interests, open communication with local community during construction and efforts form applicant to keep costs of connection down and where possible, provide financial assistance.
46. New Romney Town Council – No objection
47. Lydd Town Council – approves the amended plans
48. St Mary in the Marsh Parish Council – no views received
49. Folkestone & Dover Water Company – no views received
50. English Nature – Is satisfied with the Appropriate Assessment carried out by the County Council as the Competent Authority and subject to the measures contained in the CCP being conditioned would have no objection to the proposals.
51. Kent Wildlife Trust – Would like to see the bund (and 5m strip adjacent) at the Church Road compound seeded with a grass mix of local species and managed. Seek identification of the compensatory habitat for any potential translocation of protected reptiles be identified at the earliest opportunity. Comment that rare and scarce plant habitats are not referenced in the code of construction practice (Case Officer comment: The ES identifies compensatory planting). No objection subject to securing the mitigation measures detailed in the ES.
52. Environment Agency – make comment regarding biodiversity and water quality and resources issues, however requirements can be secured by condition, or will be addressed through Agency monitoring regime.
53. SEEDA – support the proposals as it is considered they would support tourism and regeneration in the area.
54. English Heritage – broadly content with approach outlined in ES and is happy that any further modifications are agreed with KCC Heritage Conservation team.
55. KCC Traffic Planning – no objection.
56. Jacobs Babtie (Noise, Dust and Odour) – No objection subject to mitigation measures. C1.13
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57. Jacobs Babtie (Landscaping) – Greatstone Vacuum Pumping Station - There is an inherent visual impact and blocking of views with this installation is very difficult to mitigate in this very specific landscape/seascape. There should be a strong case of need with no alternatives being possible for this to be acceptable and a certainty that the structures are as compact as possible. Temporary Compounds – are variable in size are all relatively large and do represent a significant short term impact. Mitigation within the contract term is impossible except for very localised screening. Pump Stations – have opportunities for minor planting works to reduce local impacts. A scheme of landscaping should be submitted for approval to address the above issues, to include species, sizes and numbers of plants. Details of fences and details of tree protection and replacement trees where appropriate should be shown.
58. Public Rights of Way – No views received
59. County Archaeologist – satisfied that with the mitigation proposed in the application and the commitments contained in the Applicants letter dated 4 July 2005 the proposal can be adequately mitigated.
60. KCC Biodiversity Officer – The proposal would not have an adverse impact on the nationally or internally designated sites. Some loss of semi-natural habitat will occur but this could be mitigated through appropriate habitat enhancement measures. Providing the applicants submit acceptable mitigation schemes for great crested newts and reptiles I have no objections.
Local Member
61. The Local Member Mr F Wood-Brignall was notified of the application on 14 January 2005 and re-notified upon the amended plans on 27 May 2005.
Representations
62. The application has been advertised and 20 site notices were posted around New Romney, Greatstone-On-Sea and Lydd-On-Sea. A neighbour notification exercise was undertaken, approximately 230 letters of representation have been received, although 203 of them were a standard letter (objecting to the pumping station proposed for the Lade car park) which people signed. Three letters offer support for the scheme. A summary of those comments is included at Appendix 2. A further round of neighbour notification (including those who wrote in initially) was undertaken upon the amended and additional information, to date I have received 5 letters of objection and 5 in support of the scheme (subject to there being no compulsion to the householder to join the scheme). The following comments are made:
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• Local people do not want to • Property prices will fall connect to this scheme and • People will not use the car park pay £6,500 per property. because of the smell. • Present systems are perfectly • The scheme will cause major adequate. disruption to local residents • Underground sewerage pipes trying to access their homes. will encourage rats to • There should be no pollutants proliferate along this coast. discharged into the sea from • The coastline is a natural the vacuum pumping station. habitat which will be further intruded upon by the proposed pumping station building.
Discussion
63. It is important to acknowledge that the proposed scheme is required to ensure compliance with the Urban Waste Water Treatment Directive which requires schemes in place by the end of 2005. OFWAT has already agreed a derogation of the deadline until 2007, provided construction has started in 2005. Furthermore Shepway District Council have requested that first time sewerage be provided for New Romney.
64. Having said that, Section 54A of the 1990 Act requires that applications are determined in accordance with the Development Plan unless material considerations indicate otherwise. This proposal will need to be considered in the light of the adopted and the emerging development plan policies relating to this type of development. These must then be balanced against the environmental and amenity impacts such a proposal may have, and in the light of the relevant policies of the Shepway District Local Plan. The proposal is considered to be in general accordance with the policy as outlined at the ‘Policy Context’ section of my report, in that it would result in improvements to the quality of the treated effluent to the benefit of the areas’ economic prosperity. Specific environmental protection policies will however still be relevant to ensuring adequate mitigation measures are in place to compensate for any environmental impacts as a result of the proposed scheme.
65. The geographic extent of this proposal is expansive and I therefore propose to discuss the areas which are likely to have the greatest impact, this essentially centres on the proposed construction compounds, pumping stations and treatment works itself. I shall follow the formula set out in the site description C1.15
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and deal with works in and around New Romney, the works in and around Greatstone-On Sea and Lydd-On Sea and then the Wastewater Treatment Works. However before moving on to these specific areas there are some general comments to make.
66. The laying of the sewers themselves will in the majority be by an open cut trench method with either total (rolling) road closures, or in some cases traffic management measures (temporary traffic signals with single lane working). Disruption will be kept to an absolute minimum. Alternatively a trenchless method of construction would be used where the depth of the sewer is excessive and open cut trench excavation impracticable.
67. The applicants have submitted a Code of Construction Practice that establishes and sets out the construction methodology and relevant legislation, guidelines and best practice (including reference to the requirement for a Health, Safety and Environmental Management Plan (HASEMP) to be complied with by the appointed contractor). In other words it sets out the actions that would be taken to protect and where practical enhance the environment throughout the construction period and includes matter such as measures to avoid disturbance to wildlife. Such a document is extremely useful and its contents can be conditioned in a succinct and clear manner without the need for numerous construction activity conditions.
68. Both the Environmental Statement and the Code of Construction Practice detail amenity-safeguarding measures, such as dust suppression, noise attention and measure to protect surface and ground water all of which satisfy the County Council’s consultees. Planning Conditions could ensure these measures are adhered to.
New Romney First Time Sewerage
69. In and around New Romney it is proposed to construct 5 pumping stations, each of will require a temporary construction compound for materials and equipment storage and general site facilities e.g. toilets, portacabin offices etc. The location of these compounds can be seen on the location plan earlier in this report. Compounds 1 & 3 (Church Lane and Church Road respectively) would be larger and also serve as main construction compounds for works associated with the laying of the main sewer. Each of these locations has been carefully selected after consideration of the impacts upon the following aspects.
• Landscape and Visual • Archaeology and Cultural Heritage • Ecology and Nature Conservation
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• Soils, Geology and Contaminated Land • Water Quality and Water Resources • Noise and Vibration • Air Quality • Tourism, Recreation and Community Effects • Traffic and Transport
70. It is accepted that there will be some temporary (and to a lesser extent some permanent) impacts at these sites. Following consultation with statutory consultees I am satisfied that conditioning the measures identified in the ES and CCP ensures appropriate mitigation in all these areas other than Archaeology, which I shall deal with later in this report. I would however wish to add conditions to secure the submission of screening/landscaping and lighting details.
71. With specific reference to Compound 3 (Church Road) following representations from immediate neighbours I have secured an amended plan (see below) which addresses some of their concerns. It is now proposed that a 5-metre strip of land is safeguarded from the southern boundary of the site with Dering Cottage to protect any hedging/trees on the common boundary. To the north of this and to further screen Dering Cottage from the equipment and activities on the compound it is proposed to construct a 2 metre high bund (8 metres at the base). This means the site offices will be located at least 18 metres from Dering Cottage and behind the bund. Furthermore the bund will ‘wrap around’ the frontage to Church Road so that the proposed offices and associated parking are also screened from Martinfield Manor, a bed and breakfast establishment on the opposite side of Church Road. It is proposed that the bund would be seeded and managed appropriately during its life and thereafter the topsoil would be re-spread and the land returned to agricultural use. It is not possible to relocate the entrance to the site because of its close proximity to an existing junction. I do not consider it appropriate to seek the relocation of the pumping station to either side of the field as suggested by the landowner. This is because either it would be closer to the residents of Dering Cottage or it would involve a greater land take by virtue of requiring a longer access track and a vehicle turning area all on open agricultural land. I am satisfied that the amended proposals for this compound are now acceptable subject to the above condition.
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72. As stated above, the archaeological impacts of this part of the proposed scheme has been an area of considerable concern. It is acknowledged that New Romney is a settlement of considerable historic and archaeological significance, with much of the surviving archaeology considered to be of national importance. These remains are associated with the development of the settlement from the Anglo-Saxon period as a port to an important early medieval Cinque Port and later medieval market town and harbour. The decline of New Romney during the post medieval period and the limited extent of large scale modern development has led to the apparent survival of important and distinctive archaeology throughout the present settlement, often just below the ground surface but also at depths of 1m of more. On this basis the proposed works for the sewer scheme within New Romney is likely to have major impacts on important archaeology. The County Archaeologist was not satisfied with the extent of mitigation put forward. Following a period of negotiation the Applicant has now agreed to an improved package of mitigation which includes:
• A financial contribution of £20,000 be made towards the management/co- ordination by KCC Heritage of archaeological investigation by local
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residents/other interested individuals to cover other works which are located outside the public highway (i.e. mainly ‘internal’ laterals on private land. • There will be an extension of the archaeological mitigation measures to cover the construction of the external laterals located in the public highway; • Every effort will be made to secure the appointment of a single archaeological consultant/contractor for the work, but this is a commitment that cannot be imposed on the main contractor at this stage.
73. The County Archaeologist is now satisfied with this commitment.
Greatstone-On-Sea First Time Sewerage
74. As with the New Romney section all pipelines would run beneath the roads, with Coast Drive acting as the main artery. The proposal for Greatstone is a vacuum sewer system. The reasons for this choice of system have been set out in a separate paper by the Applicants to inform and support the ‘alternatives’ detail contained within the ES. Essentially the other options of deep gravity and shallow gravity systems were discounted because either of the need for deep trenches in unstable ground or the requirement for a large number of pumping stations.
75. This choice of system inevitably leads to the need for a larger pumping station to accommodate all of the required equipment at one more centralised location. The environmental impact was considered to be less with this option and I would not disagree with this conclusion. The Applicant then carried out a detailed site search within the catchment area looking for a site of adequate size, with good access and the least environmental impact. This search resulted in the proposed pumping station and construction compound being located on The Lade car park in font of the public toilets.
76. As set out in the proposal section, following negotiations, the scheme has been amended so that instead of two separate buildings, one new building containing both the pumping station and public toilets is now proposed. Initially the majority of objection letters were against the construction of a separate building to house the pumping station because of visual impact, loss of facilities and blocking of views. Following reconsultation with all of those that objected I have to date received only 5 letters of objection (see publicity section of report).
77. The construction of one combined building reduces the visual impact and takes up less space on the car park. One effect of constructing one new building is the requirement to extend the hard surfaced area to the back of the car park, where the impact upon the SAC has been carefully considered. English Nature
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has stated that they have no objection to this proposed extension. English Nature has also requested protection measures along the shingle verges of Coast Drive to prevent damage from vehicles during the construction period. These protection measures have also been set out in the Appropriate Assessment carried out by the County Council upon this proposed development and are detailed in the CCP. Beyond the above measures the Applicant also proposes to:-
• resurface the whole of the car park at the end of the works, • mark up parking bays, • reinstate the disabled walkway and • amend the construction programme and delay work at the car park until after 1 October 2005 with completion by the end of March 2006 to avoid the busiest times of the year
78. Given all of the above safeguarding measures and the amendments to the building which have been secured I am satisfied that this choice of location for the pumping station is acceptable.
79. One further tempoaray construction compound is proposed for this part of the scheme adjacent to the existing pumping station at Dunes Road. The residents of 94 Dunes Road which backs onto the site have expressed concern regarding the generator proposed to the rear of the existing pumping station building. The generator is being installed for emergency purposes only, in the event of a power failure it would keep the pumping station operational thereby preventing the sewers from backing up. A condition could secure submission of the acoustic shrouding and details of the location of the exhaust for prior approval. It would also be necessary to run the generator about once a month for a period of an hour to ensure it is working adequately. The Applicants have written directly to the residents setting out all of these details and subject to the conditions mentioned above I am satisfied adequate mitigation is being proposed.
New Romney Wastewater Treatment Works (WTW)
80. The upgrade works are set out earlier in this report and are essentially being proposed in order to meet the anticipated more stringent discharge consent and the Urban Wastewater Treatment Directive. It is possible that a long sea outfall may be required in the future, the treated effluent currently discharges to the Littlestone sewer, but it is not proposed at present. The upgrade works are
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therefore based on a ‘worst case’ scenario i.e. most stringent discharge requirements, which would apply without an LSO.
81. The WTW is sited against a backdrop of a wooded tree belt on the edge of open rough grassland that stretches over 500 metres to the south to the southern edge of housing in Littlestone-on-Sea. It is generally well screened with any views mainly being from a distance. There is however some scope to add to the tree planting around the WTW and I therefore propose a condition to secure this as part of the overall landscaping scheme for the works as set out in the ES. The assessment of visual impacts concludes that with the proposed landscaping the effects of the development would not be significant upon either public footpaths or bridleways. As an extra precaution I also intend to condition that details of all lighting proposed at the works be submitted for approval.
82. The ES considers all the potential impacts that could result from the upgrading of the works. Along with the CCP it proposes a number of mitigation measures to limit those impacts. There has been no major objection to the proposed development at the WTW and I am therefore satisfied that with the proposed mitigation measures the development at the WTW is acceptable.
Conclusion
83. I have set out earlier in my report the need for the development proposed. It is fundamentally required in order to meet European Directives and has I understand been a long-term aim of the District Council to have mains sewerage available to all local residents. Against this support for the scheme one must weigh the environmental impacts of the proposed development, indeed as an EIA development it must be subject to detailed scrutiny. The EIA regulations require consideration of not only direct but also indirect and cumulative impacts that may result form the scheme. The ES indicates that although some potentially significant impacts are likely to occur, with the implementation of appropriate mitigation, these could be reduced to acceptable levels. The CCP submitted following negotiation with the Applicant endorses and reinforces those mitigation measures. The one area that was not adequately addressed in either of these documents was Archaeology, as discussed earlier in my report. However following agreement by the Applicant to enter into a legal agreement to secure the mitigation measures identified by the County Archaeologist, this significant impact could be alleviated.
84. I consider that the mitigation measures put forward, along with the additional conditions discussed in the report adequately address the impacts of the scheme. Given that adequacy and the underlying need for the development, on balance I am satisfied that the proposal is acceptable.
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Recommendation
85. I RECOMMEND that SUBJECT to:-
The prior satisfactory conclusion of a legal agreement to secure the agreed contribution toward archaeological mitigation measures and the applicant meeting the County Council’s reasonable legal costs associated with this agreement,
86. PLANNING PERMISSION be GRANTED subject to conditions covering amongst other matters, standard time limit, adherence to submitted plans and documents, adherence to the Code of Construction Practice, approval of a Written Scheme of Archaeological Investigation (to include the mitigation for external laterals to be constructed at the same time as the laying of the main sewer), hours of construction operations, details of all temporary and permanent lighting associated with the scheme, landscaping and screening, details of acoustic screening and exhaust to generator at Dunes Road, details of resurfacing and laying out of bays on The Lade car park; and
87. I FURTHER RECOMMEND THAT Members endorse and approve the Appropriate Assessment carried out by the County Council as the Competent Authority under the Conservation (Natural Habitats & c.) Regulations 1994.
88. I FURTHER RECOMMEND THAT the decision of the Planning Aplications Committee BE ADVERTISED.
Case Officer: Andrea Hopkins 01622 221056
Background Documents - see section heading
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Appendix 1
APPLICATION SH/05/0053 – FIRST TIME SEWER NETWORK AND ASSOCIATED UPGRADE OF EXISTING WASTE WATER TREATMENT WORKS AT NEW ROMNEY AND GRETASTOONE-ON-SEA WASTEWATER TREATMENT SCHEME
NOTES of a site visit held at Tunstall CE Primary School on Tuesday, 31 May 2005.
MEMBERS PRESENT: P M Hill (in the Chair), Mr R W Gough, Mrs E Green, Mr C Hibberd, Mr G A Horne, Mr S J G Koowaree, Mr T A Maddison, Mr W V Newman, Mr A R Poole and Mrs B J Simpson.
OTHER MEMBERS PRESENT: Mrs C Angell, Mr L Christie, Mr A D Crowther and Mrs E Tweed.
OFFICERS: Mr R Gregory (Planning) and Mr A Tait (Legal and Secretariat).
THE APPLICANT: Mr C Finlayson (Barton Wilmore Planning – Agent for Southern Water).
OTHER LOCAL AUTHORITIES: Shepway DC (Cllr Willicombe accompanied by Ms Claire Thompson – Planning). Lydd TC (Cllrs Albrow, Mrs May, Mrs Walsh, Mrs Masters, Snell, Walsh, Ms Dawson, Alford, Goddard and Donohoe), New Romney TC (Cllr Wise).
(1) The Chairman opened the visit by explaining that its purpose was to enable Members to familiarise themselves with the application site and to gather the views of those present.
(2) Mr Gregory introduced the application to provide a First Time Sewerage (FTS) scheme, connecting the New Romney/Lydd/ Greatstone triangle to the main server. The work would involve an upgrade of the New Romney WTW and the construction of a series of pumping stations, including several temporary construction compounds. The piping would mainly be underground, except when surfacing at the main pressure points. As this was an urgently needed
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development , arising out of the Urban Waste Water Treatment Directive, officers and applicants had expended a lot of energy to resolve the problems they had encountered. This had led to a number of amendments.
(3) Mr Gregory went on to say that the Church Road, New Romney site would include a pumping station, temporary construction compound and toilet block.
(4) Mr Gregory also informed the meeting that shingle beaches (such as the one surrounding the car park were internationally protected. English Nature was ensuring that this protection was respected. If permission were granted to this proposal, it would be on the basis of full consultation on all the required conservation measures.
(5) Mr Finlayson, representing the applicants, said that the development required a number of aspects to be dealt with. It was very large, first time and archaeologically sensitive in an area that was environmentally protected in many ways. The area itself was very flat and required pumping stations to be located on the surface. For these reasons a number of alternative solutions had been considered before the present one had been put forward. Permission had now been given for the development to encroach onto the SAC (the beach) during the construction period only. The aim was to complete the work by Spring/Summer 2007.
(6) Councillor Allbrow from Lydd TC said that his authority had two concerns. The first was the outfork pipe, which was not part of this application and was currently being arbitrated upon by DEFRA. The second was the proposal to demolish the toilet block during the construction period. He asked if the Planning Authority could consider the insertion of a penalty clause if the development was not completed on time. Although this was not a planning matter, he also said that he the Town Council would not wish to see this development used as an excuse for the imposition of car parking fees. He was concerned that the new plans had only just been published and wanted to know why the development was now stopping at Battery Road.
(7) Several Lydd Town Councillors pointed out that local people’s views of the sea would be adversely affected by the development.
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(8) Mr Finlayson said that Southern Water was intending to limit the construction period to between the months of October and April. If there was any overrun, temporary toilet facilities would be provided. The new plans had only just been completed following lengthy discussions with Shepway DC.
(9) Mr Wise from New Romney Town Council said that the local people had been waiting for such a facility since 1865. He asked whether it would be possible to grant permission for the New Romney section of the works if other areas proved problematic. He was concerned that costs could escalate if their were further delays. (Mr Gregory replied that this would not be practical in planning terms and that the application had to be determined as submitted).
(10) In response to a question, Mr Finlayson said that the pumping station in the car park would be 10m wide and 18m long. He also explained that the pumping stations could not be located underground because, by law, the electrical equipment had to be above ground. He then said that the site would be used to store materials on a need for need basis and that it would be vacated as quickly as possible. At worst, the construction period would be 21/2 years.
(11) Members then travelled to Church Road, New Romney to look at the site layout for that part of the application.
(12) The Chairman thanked everyone for attending. The notes of this visit would be appended to the Committee report when the application came to be determined.
04/a&a/planapps/misc/011805Site Visit - conways
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Appendix 2
• The generator proposed to the • The siting of the proposed new rear of Dunes Road will cause building would hamper the views of noise and vibration disturbance to drivers exiting the car park and nearby residential properties create an unsafe environment for • The Church Road construction pedestrians, particularly at the bus compound is very large, highly stop and shelter regularly used by visible, has a dangerous access local school children. and would cause a loss of amenity • The proposal will result in 50% of for a period on excess of 2 years. the car park being lost for good. • The pumping station at Church • The new building will dominate the Road should be located in the coastline and obliterate views from extreme corner of the field and not all angles. in the middle of the farmers field. • The proposal will lead to air, noise • KCC should ensure that and light pollution and industrial appropriate reinstatement takes type development within a Site of place on all roads, many of which Special Scientific Interest. are concrete and in a poor state of • The entire proposal is unworkable, repair. unwanted and non-affordable. • Laying pipelines in The Lade car • Southern Water should bear the park and picnic area is the only cost of connection to the system. area where residents and visitors • In the event of a failure raw can sit and view the sea. sewage would back up along • The car park is well used by Coast Drive to the Pilot Public disabled visitors; the Romney House Marsh Countryside Project is • What provisions are there for shortly due to construct a access along Coast Drive for boardwalk onto the shingle beach emergency vehicles. for the benefit of wheelchair users. • Excavating adjacent to the houses • Local shops and businesses rely built on shingle may lead to on the trade brought about by the structural problems. use of the car park.
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Appendix 3
NEW ROMNEY AND GREATSTONE-ON-SEA FIRST TIME SEWERAGE SCHEME APPROPRIATE ASSESSMENT
This is a record of the appropriate assessment, required by Regulation 48 of the Habitats Regulations 1994 undertaken by Kent County Council in respect of the elements of the proposed New Romney & Greatstone-on-Sea First Time Sewerage Scheme, for which it is the Competent Authority, in accordance with the Habitats Directive (Council Directive 92/43 EEC).
Having considered that the plan or project would have a “likely significant effect” (stage 1) on the Dungeness candidate Special Area of Conservation (SAC) and that the proposed scheme was not directly connected with or necessary to the management of the site, an Appropriate Assessment (stage 2) has been undertaken of the implications of the proposal in view of the site’s conservation objectives.
English Nature was consulted under Regulation 48(3) on 16 May 2005 and their representations, to which Kent County Council has had regard, are attached at Appendix 1. The conclusions of this Appropriate Assessment are in accordance with the advice and recommendations of English Nature.
Title: New Romney & Greatstone-On-Sea First Time Sewerage Scheme
Location: Shepway, Kent
Designations: Dungeness candidate Special Area of Conservation (cSAC) Dungeness to Pett Level Special Protection Area (SPA) (Note: the features for which this site is designated will not be affected by the proposed works so there is no need for an Appropriate Assessment to be undertaken in respect of this site). Description of the Project: The purpose of the proposed scheme is to provide first time sewerage for New Romney, Greatstone-On-Sea & Littlestone-On-Sea and to ensure compliance with the following European Directive:
• The Urban Waste Water Treatment Directive (91/271/EEC) as implemented through the Urban Wastewater Treatment (England and Wales) Regulations 1994
The proposed scheme includes the following works:
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• New Romney first time sewerage. • Greatstone-on-Sea first time sewerage. • New Romney STW upgrade.
In New Romney and Greatstone-on-Sea, mains sewers will be installed under the existing road surface on the main streets. These will be connected to the existing New Romney STW across an agricultural use field. In New Romney, the sewers will be gravity fed but due to the low lying topography of the Romney Marshes area in general, 5 pumping stations will be necessary to provide the necessary pressure to transport the sewage to the STW. The Greatstone-on-Sea element consists of a vacuum sewer system, with a main artery running under Coast Drive and a single pumping station at Lade Car- park. This system was elected as the preferred option for Greatstone-on-Sea because it only requires one pumping station (thus reducing the energy requirements and minimising the visual and landscape impacts). All sewerage pipelines will be constructed using the open trench method, with site compounds at the proposed pumping stations.
A more detailed description of each element of the proposed scheme, the construction methods involved and the alternatives considered can be found in the Environmental Statement Volume 1: Main text. Maps and plans are provided in Volume 3 of the Environmental Statement. The scheme is not directly connected with or necessary to the management of the cSAC. However the scheme has been carefully designed to minimise its effects on the features for which the European site has been designated. The Environmental Statement concludes that the scheme accords with government guidance, strategic and local planning policies.
Brief description of the European Site to which this Appropriate Assessment applies:
Dungeness is the largest shingle structure in the UK and supports one of the most important examples of shingle habitats in Europe. The Annex I habitats that are “a primary reason for the selection of this site” reflect this. They are as follows: • “Annual vegetation of drift lines” This habitat type occurs on deposits of shingle at or just above mean high water spring tides. They generally consist of the lower end of the size range of shingle with varying amounts of sand and are subject to periodic overtopping or displacement by high tides or storms. The distinctive vegetation cover that forms is therefore ephemeral and composed of annual or short lived species. The species composition can be highly variable but at Dungeness, Babbington’s Orache ( Atriplex glabriuscula ) is characteristic. This habitat mostly forms on the accreting eastern shoreline.
• “Perennial vegetation of stony banks”
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Shingle ridges form at the foreshore where a beach is deposited at the limit of high tide. Pebbles are thrown up by storm waves high on the beach, from where the backwash cannot reach them. Over time, a succession of beaches form on permanent dry land. The ridges and furrows that are formed influence the vegetation pattern resulting in a characteristic series of vegetated and bare shingle. Dungeness remains one of the largest and finest examples of this habitat in Europe, despite a history of disturbance and destruction of the shingle surface. Extensive areas of intact parallel ridges exist with valuable examples of prostrate forms of broom ( Cytisus scoparius ) and blackthorn ( Prunus spinosa ).
No other habitats are listed. Great crested newt ( Triturus cristatus ) is the only species listed as “a primary reason for the selection of this site”. A unique feature of the shingle habitat at Dungeness is the proliferation of small water bodies. These are ideal breeding sites for great crested newts and the shingle vegetation structure provides suitable terrestrial habitats and the site thus supports a large and viable population of this species.
In-combination Effects
When the Romney Marsh Countryside Project has guided walks to the Listening Mirrors at Lade, the car park is often at full capacity. Closure of the car park at this time would result in serious traffic disruption and could result in some individuals parking vehicles on the shingle.
Works carried out by TRANSCO are unlikely to have any impact on traffic flows and therefore no effect on the designated areas.
There are no other known ‘in combination or cumulative impacts’ of the scheme at this time.
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APPROPORIATE ASSESSMENT TABLE
The table describes the features of the European site, and any likely direct, indirect or secondary impacts of the aspects of the project for which Kent County council is a Competent Authority (either alone or in-combination with other plans or projects) on the site, proposed mitigation measures and residual impacts. The site’s conservation objectives have been taken into account, including the citation for the site and information supplied by English Nature and the likely effects of the proposals on the international nature conservation interests for which the site was designated.
FEATURE PROPOSED POSSIBLE EFFECTS PROPOSED MITIGATION RESIDUAL ACTIVITY IMPACT
SAC: ANNEX I Closure of Lade Construction staff driving Staff training and erection of Negligible Perennial carpark and vehicles onto shingle physical barrier vegetation of construction of stony banks pumping station Increased risk of public parking onto shingle Construction to take place during winter ‘quiet period’ Negligible when demand for parking is at a minimum. Liaison with RMCP to start guided walks from alternative location.
Construction staff driving Staff training and erection of Installation of vehicles onto shingle temporary fence Negligible sewerage pipes along Coast Drive Increased risk of public driving onto shingle to avoid traffic lights Erection of temporary fence
SAC: ANNEX I No effects Not required N/A Annual vegetation of drift lines
SAC: ANNEX II Construction of Impacts lie outside SAC Dealt with under DEFRA N/A Great Crested Pumping Stn No. 5, license Newts New Romney
The assessment has concluded that the scheme as proposed, both alone and in combination with the Romney Marsh Countryside Project, has the potential to adversely affect the integrity of the site.
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However the following conditions and/or restrictions would avoid the potential impacts and adverse effects on the integrity of the site. a) General measures
The high environmental sensitivity of the vegetated shingle adjoining Coast Drive and Lade Car Park has been fully recognised and a high level of importance has been placed on minimising impacts by effective environmental control, mitigation and monitoring. A Construction Management Plan has been prepared, setting out agreed practices and procedures to be followed. All construction staff will be made aware of this and, more specifically, the damage caused by driving vehicles onto the shingle through training. In addition, the following measures have been agreed to mitigate for any potential increased risk of damage caused by the public driving onto the shingle as a result of the proposed scheme. b) Installation of sewers along Coast Drive
A temporary fence will be installed alongside the ‘rolling construction compound’ to provide a physical barrier between construction machinery and the SAC designated area. The fence will also extend 30m either end of the traffic lights to prevent motorists from using the shingle beach as a bypass to the compound. The temporary fence will closely follow the movements of the rolling compound along Coast Drive at all times and remain directly adjacent to the kerb. Following the advice of EN and in order to avoid damage to the vegetated shingle verge, the fence shall consist of the following: • Small concrete blocks are placed directly onto the shingle at the kerb-side. The concrete blocks should have a hole in the middle into which a post can be inserted. • Either “para-webbing” (orange plastic netting) or tiger-tape will then be used to make an obvious barrier (although the latter may be ineffective under windy conditions). • Signs will be placed along the fence to warn construction staff and members of the public that driving over the shingle is prohibited. c) Installation of sewers along residential roads
Parking on the shingle at the ends of the residential roads affected by the works is already prevented by the existence of post and rail fences. Prior to the works starting, a check will be made to ensure that there are no gaps in these fences. Any damage will be repaired to the original specifications and EN and site managers (RMCP) consulted. d) Construction of pumping station at Lade Car-park
In order to mitigate for the potential impacts caused by closure of the car-park, the construction programme has been amended to delay any works on the car park area until 1 st October 2005, with a
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proposed completion date of 1 st April 2006. Whilst the winter period is not ideal for construction, it is outside the peak season of use of the car park and therefore the increased risk of damage to the SAC caused by a lack of parking space is mitigated for.
During the construction works, the site compound will be enclosed by a secure fence which will clearly define the area and prevent access to the sensitive vegetated shingle areas by machinery and vehicles. Construction staff will be allocated parking within the site compound and all staff made aware of the rules not to drive vehicles onto the shingle under any circumstances.
Several guided walks to the Listening Mirrors have been organised during the summer 2005. The above mitigation delaying construction of the pumping station until winter avoids conflict with these events. Close liaison with the RMCP will ensure that no guided walks starting from the Lade car park will take place during the construction period and alternative venues will be arranged. e) Post construction impacts
Following discussions with Shepway DC, the following revisions to the plans will be made to the pumping station at Lade car park:
• The existing toilet block will be demolished and the construction of a new building incorporating public toilets with the pumping station shall be proposed. • The position of the combined building will be amended to cover the footprint of the existing toilets, moving the pumping station away from its current position adjacent to Coast Drive. • The entire car park area will be resurfaced following completion of construction works and car parking bays will be marked up. This will result in a more efficient use of the parking area and increase capacity. • The existing car park perimeter fence will be reinstated to maintain protection to the SAC/SSSI area and prevent vehicle access onto the shingle.
These measures will mitigate for the previously anticipated loss of some of existing area currently used for car-parking. The combination of a single building to accommodate the pumping station and the toilets will be a more efficient use of the site and allow the parking area to be reorganised. The greater capacity which will result from formally marking out parking spaces will help to compensate for the loss of some of the parking area. It is anticipated that the net loss of parking capacity will be very limited.
There will be no post construction impacts after the sewerage pipes have been installed along Coast Drive or the adjacent residential streets.
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Signed Date
Annexe 1: Representations from English Nature
Mrs A. Hopkins Planning Applications Group First Floor, Invicta House Our Ref TR01-2-ConPlan County Hall Your Ref: Pag/SH/05/53 Maidstone 27 June 2005 Kent ME14 1XX
Dear Andrea,
Dungeness Site of Special Scientific Interest (SSSI) Dungeness Special Area of Conservation (SAC) Dungeness National Nature Reserve (NNR) First time sewerage scheme for New Romney and Greatstone on Sea
Thank you for your letter dated 16 th May 2005, enclosing the report prepared for Southern Water to inform the Appropriate Assessment. Your letter formally consults English Nature under Regulation 48(3) of the Conservation (Natural Habitats &c.) Regulations 1994 with regard to the above proposals.
The proposal lies within the Dungeness SSSI and SAC and adjacent to the Dungeness NNR. This site is part of an internationally important SAC on account of the following features:
1. Annual Vegetation of Drift Lines. 2. Perennial Vegetation of Stony Banks 3. Great crested newt.
In the vicinity of the application site the only feature of SAC interest is the Perennial Vegetation of Stony Banks.
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Damage to areas of shingle on this site could have a likely significant affect on the integrity of the SSSI, therefore English Nature advised that Kent County Council would need to undertake an appropriate assessment before considering the outcome of the planning application.
We have submitted our comments on the Environmental Statement in our letter dated 11 th February 2005.
We now confirm that we agree with the conclusions drawn from the report to inform the Appropriate Assessment.
If all the measures outlined in the following documents are adhered to:
• Southern Water New Romney and Greatstone on Sea First Time Sewerage Scheme Code of Construction Practice (CCP) • Environmental Statement for the scheme
English Nature would advise that there would be no adverse effect on the conservation objectives of the candidate SAC and therefore on the integrity of the site.
Please do not hesitate to contact me if you require further assistance.
Yours sincerely,
Jo Dear Conservation Officer
Direct line: 01233 811216 Email: [email protected]
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