Our Ref: 169.1 23Rd July 2012 Ms Lillian Harrison Integrated Strategy

Our ref: 169.1

23rd July 2012

Ms Lillian Harrison Integrated Strategy and Planning Invicta House County Hall Maidstone Kent ME14 1XX

Dear Ms Harrison Minerals and Waste Sites Development Plan Document Preferred Options 1. Introductory comments Thank you for consulting Kent Wildlife Trust on the Preferred Options for the Minerals Sites DPD and the Waste Sites DPD. Kent Wildlife Trust wishes to supplement our comments submitted as part of the Issues and Options consultation in relation to some sites. Whereas previously we only had resources to investigate the ecology on site and whether the proposed activity would impact on designated sites and Biodiversity Action Plan habitats, with the reduction of sites to be assessed we have now had the opportunity to investigate potential in- combination impacts especially in relation to the European network and Local Wildlife Sites.

1.1 Habitat Loss We are concerned that in some instances, where clusters of sites are proposed within a limited geographical area, there is a risk that the impact will lead to irrevocable damage to the habitats contained within the designated sites. Although in many instances the restoration proposed will substantially enhance the ecological significance of the site to be developed, for colonisation of the re-created habitats to be viable the habitat and species already present will need to be conserved and where possible enhanced and managed. We are concerned that in many instances the site information does not include appropriate safeguards to ensure this is achieved. It is our view that before many sites are allocated there will need to be further investigation, to ascertain whether these sites are viable. We do not feel this should be left until the application process as without the above investigations it is not possible to prove there would not be a significant impact on the Natura 2000 and Ramsar network in conformity with the Conservation of Habitats and Species Regulations 2010 or the nationally and locally designated sites in conformity with the National Policy Planning Framework paragraph 113. (See Section 2 Policy Context for further details of the above national policy)

1.2 Nitrogen Deposition It would appear from the Habitats Regulations Assessment that the issue of nitrogen deposition is assessed as either not felt to be pertinent due to the distance of the site from the nearest European site, or it is recommended that this issue be dealt with at the application stage. We can find very little evidence that a thorough assessment has been undertaken regarding the in- combination impacts of nitrogen deposition on the sensitive Natura 2000 network and no information regarding impact to the lower designations. As a County wide plan it is important that the impacts of this plan in-combination with other County plans such as the Transport Plan, alongside the proposed development contained within the LDFs of the Local Authorities is fully assessed to ensure that the plans contained within the Minerals and Waste LDF do not produce an in-combination impact that will significantly affect the integrity of the European network.

To achieve this it will be important to establish a baseline regarding the condition present within the sites at the present time to establish their vulnerability to increases in NOx and to ensure that any deleterious impacts are identified. Baseline data is available for many of the sites and we would be happy to provide details regarding where the information can be sourced

The next stage within the study should be to ascertain the predicted level of vehicle movements from each site and the routes that these vehicles are likely to use. In relation to waste sites and plant equipment within Minerals Sites there should be an assessment of the level of nitrogen dioxide likely to be emitted and the distances at which NOx will impact on the habitats contained within the Natura 2000 network. Once these studies have been completed information should be available regarding the in-combination increase in traffic on roads within 200m of the SACs as a result of the plans and the emissions from minerals and waste facilities. This is particularly important in relation to habitats containing calcareous grassland, ancient woodland, sand dune habitat and vegetated shingle as these habitats are susceptible to NOx.

Once this information is obtained an in-combination assessment with the plans detailed above can be carried out by assessing this information with that submitted as part of the Local Authority LDF process and individual applications. Although details may be incomplete Kent County Council will be able to evidence that a thorough assessment has been undertaken using all information available and appropriate mitigation can be devised to ensure no significant in- combination impacts on the European network as a result of the proposed plan.

Having examined the proposed sites we have identified potential impacts on the following Natura 2000 Sites either due to increased traffic on the adjacent road network or emissions from Mineral and Waste facilities

 North Downs Woodlands SAC  Lydden and Temple Ewell Downlands SAC  Folkestone to Etchinghill Escarpment SACD  Dover to Kingsdown Cliffs SAC  Sandwich Bay SAC  Thanet Coast SAC  Queendown Warren SAC  Dungeness SAC

To ensure the impacts of NOx are assessed on the national and county designations the information contained within the study may be able to be used.

1.3 Sulphur Emissions Sulphur emissions from waste sites could also have an impact on the ancient woodland habitats contained within the designated sites. Sulphur can cause death to the sensitive lichens and other flora which is essential to conserve to rich biodiversity present within the ancient woodlands. Kent Wildlife Trust do not have expertise in either the level of sulphur likely to be emitted from the waste sites or the distance at which this may have an impact but we are concerned that where waste sites are adjacent or within the immediate locality of ancient woodland these habitats could experience damage. We recommend that the threats be identified and safeguards written into the site policies to alleviate impact.

1.4 Hydrology and Water Quality Within a number of sites there are threats that the proposed mineral or waste uses will impact on the hydrology and/or water quality essential to maintain the wetland habitats contained within internationally, nationally and locally designated sites. In relation to the Local Wildlife Site network there are some sites that could be heavily impacted due to the water system that feeds the sites being disrupted or polluted as a result of the a number of large quarries proposed adjacent to or within the locality of the LWSs. There is a high risk that such intensive quarrying will lead to significant deterioration of these important habitats. It is our view that to ensure only the appropriate level of quarrying is permitted there needs to be an assessment of in- combination impacts with a landscape scale mitigation strategy devised for all sites likely to have an impact. This should include an assessment of the level of extraction that can be undertaken without damage to the wetland and wet woodland habitats and restoration that involves landscape scale enhancement to link, extend and manage the habitats present in the long term.

1.5 Noise and Disturbance This issue is particularly relevant to sites that may cause an impact on the Special Protection Areas within the locality of the sites as the SPAs are designated for their bird interest. The over- wintering and breeding birds for which the SPAs are designated are particularly prone to disturbance as a result of noise which can limit the time they are able to feed and reduce their health and fecundity. Although we have not identified sites that are likely to have an impact individually, we are concerned that there may be in-combination impacts within the area of The Swale SPA where three brickearth sites and a recycling plant are proposed. These sites should be assessed for in-combination impacts within the HRA alongside any plans contained within the LDF of neighbouring authorities. Appropriate mitigation such as phasing and noise reduction should be written into site policies if impacts are identified.

1.6 Supporting Habitats Closely linked to the previous comments it will also be important to assess the three brickearth sites for their importance as supporting habitats for the SPA birds. We note that within the HRA only one site is identified as supporting habitat and would question why site 98 and 102 have not been identified. It is likely that this will only be ascertained by an on the ground survey. This issue would also apply to Site 22 if found to contain supporting habitat.

1.7 The Contribution of Restoration to the Delivery of the Biodiversity Opportunity Areas The Biodiversity Opportunity Areas (BOAs) have been identified to endeavour to provide nature conservation at a landscape scale. They aim to conserve and buffer designated sites and important Biodiversity Action Plan habitats and connect these sites and habitats to form a landscape scale ecological network that extends through Kent and Medway. There are 16 BOAs within Kent and Medway. They have been identified scientifically using the information contained within Kent Landscape Information System to map existing habitats and sites and then accessing computer programmes that identify where habitat restoration is possible using the underlying geology and other indicators such as the presence of floodplain.

All Local Authorities that have devised a Green Infrastructure thus far have used the BOAs as a basis for their mapping and there are significant opportunities to ensure that the BOAs are delivered on the ground through development and other funding streams such as Higher Level Stewardship Schemes, Community Projects and grants. The Green Infrastructure and Biodiversity planning Guide has recently been produced by the Wildlife Trusts in association with Town and Country Planning that provides useful information on how green infrastructure can be incorporated into development.

Within our response we have endeavoured to identify the sites that are within a BOA and the targets most relevant to these sites. We have also identified sites that would make important connections between BOAs. We recommend that where the site is within a BOA the restoration plan conforms to the targets formulated for the BOAs. This will enable the Mineral and Waste Sites to contribute to the creation of a landscape scale ecological network which will provide significant benefits for biodiversity in the future. Where the site is outside the BOA but could make an important connection and alleviate impact on the adjacent designated sites it would also be extremely valuable for these to be restored back to ecological habitat to enable species to move between BOAs. Details of the sites within and adjacent to the BOAs are contained within section 5 and the detailed comments for individual sites within sections 3 and 4.

2. Policy Context

2.1 The Conservation of Habitats and Species Regulations 2010 The above regulations have been formulated to transpose Britain’s commitments under the Habitats Directive and Birds Directive into British law. The regulations ensure, amongst other requirements, that the Natura 2000 and Ramsar network are protected from direct and indirect impact from developments individually and in-combination with other plans and projects that could impact on the network.

21.—(1) Where it appears to the appropriate nature conservation body that an application for consent under regulation 20(2)(a) relates to an operation which is or forms part of a plan or project which- (a) is likely to have a significant effect on the site (either alone or in combination with other plans or projects), (b) is not directly connected with or necessary to the management of the site, and they shall make an appropriate assessment of the implications for the site in view of that site's conservation objectives.

(2) In the light of the conclusions of the assessment, they may give consent for the operation only after having ascertained that the plan or project will not adversely affect the integrity of the site.

In respect of many of the sites within the Minerals and Waste DPDs, it is Kent Wildlife Trust’s view that the HRA has either not identified all the issues relevant to the site or has not dealt with them at a strategic level to ensure that the sites can be delivered without causing significant impact on the European network. Kent Wildlife Trust requests the opportunity to meet to discuss these issues with the Minerals and Waste Team at the earliest opportunity.

(For impacts that could occur on the Natura 2000 and Ramsar network see introductory comments. For specific issues relating to individual sites see detailed comments contained within sections 3 and 4)

2.2 The National Planning Policy Framework In relation to the protection of internationally, nationally and locally designated sites and wider ecological networks Paragraph 113 states that:- Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.

In relation to the protection of SSSIs and LWSs we are concerned that there are threats to the integrity of the sites due to individual and in-combination impacts. In certain cases the in- combination impacts of clusters of sites could have a detrimental impact on a number of locally designated sites. Kent Wildlife Trust requests the opportunity to meet to discuss these issues with the Minerals and Waste Team at the earliest opportunity.

(For impacts that could occur on the designated sites, see introductory comments. For specific issues relating to individual sites see detailed comments contained within sections 3 and 4. For landscape scale restoration see section 5)

3. Detailed Comments on Minerals Sites

3.1. Soft Sand Sites

Site 6 Land adjacent to Platt Industrial Estate We note that this site has been scoped out of the HRA for impacts on the European network. This is a confusing assessment as Site 61 of the Waste Sites DPD is scoped in for in- combination impacts with Site 105, but Site 105 is scoped out. (See comments in relation to the above sites for further details regarding our concerns) It is our view that Site 105 should be scoped into the assessment and therefore due to the proximity of this Site to Site 105 it will also follow that this site also needs to be assessed for in-combination impacts on the North Downs Woodlands SAC as a result of in-combination nitrogen deposition. We request clarification regarding the criteria used to assess possible impact for all these sites. (See introductory comments regarding County wide investigations in relation to NOx)

This site is within the Greensands, Heaths and Commons BOA and in close proximity to TM02 Valley Wood and Wrotham Golf Course LWS designated for its remnant heathland and ancient woodland habitats. A fragment of ancient woodland is also present at Firemanshaw Wood. There are opportunities to extend these habitats within the restoration plans in partnership with the other sites.

Within the previous consultation we recommended that the site be restored to woodland and heath. It is important to maintain connectivity between the ancient woodlands within the restoration plan; however, due to the site’s location within the BOA we now feel that restoration should primarily be acidic grassland or heath re-creation. We are concerned that no heathland restoration is detailed within the plan with the site being restored to previous conditions. We welcome the restoration opportunities identified for woodland and ponds but feel that the plans should reflect the targets of the BOA.

In-combination impacts with Site 105 on TM02 LWS will need to be considered and we would recommend that a joint restoration, management and monitoring program be devised incorporating Site 6, 105 and Site 24 and the Local Wildlife Sites that may be impacted. We would welcome the opportunity to discuss this further. If in-combination impacts on the LWS are not assessed as part of the final DPD and appropriate mitigation and restoration measures incorporated into the final policy, we would object to the allocation of this site.

Site 24 Land North of Addington Lane This site is further to the north of the Greensands Heaths and Commons BOA than the previous site and is adjacent to TW29 Ryash Woods LWS. Within Kent Wildlife Trust’s previous consultation response we highlighted the need to ensure that there was no change to the hydrology of Ryash Wood LWS and the water supply to the woodland as a result of the proposed quarrying. The LWS is designated as it contains wet ancient woodland which is dependent on the water supply to the streams and ditches that interlace site 24. We can find no reference to the safeguarding of the water supply within the site specific considerations. We recommend that safeguards to ensure the water supply and hydrology of the LWS are not impacted are incorporated within the policy for this site.

We welcome the recommendation that heathland or acidic grassland will be created, however due to the sensitivity of the area we are concerned that there is still a suggestion that this site will be restored to agriculture. Due to the possible impacts on Ryash Wood LWS it is our view that it is essential that within the final policy a commitment is secured to restore the site back to acidic grassland or heath to help deliver the BOA target.

We recommend that a joint restoration, management and monitoring program be devised incorporating Site 6, 105 and Site 24 and the Local Wildlife Sites that may be impacted. We would welcome the opportunity to discuss this further. As this site is an extension to the Addington (Wrotham) Quarry there are opportunities to extend the heathland and grassland habitat into the area being worked at the present time. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.

If hydrological impacts on the LWS are not assessed as part of the final DPD and appropriate mitigation, restoration and management measures incorporated into the final policy, we would object to the allocation of this site.

Site 75 Boltons Field Lenham This site is not within a BOA but provides important extension to the Mid Kent Greensands and Gualt BOA. There are also likely to be in-combination impacts on the Local Wildlife Site network with Sites 76 and 77 as they are all in close proximity to locally designated sites.

Kent Wildlife Trust seeks clarification regarding the restoration for this site. As identified within the Issues and options consultation this site is within 127m of Pasture and Ponds Lenham Forstal LWS. Our most recent representation for Shepherds Farm Quarry expressed disappointment with the mitigation strategy proposed. As the original application was historic there was little scope to improve the mitigation, however any new proposal will need to comply with the more rigorous ecological protection now in force within the NPPF.

We are concerned that despite mention of the need to mitigate the Local Wildlife Site habitat already lost and provision of neutral grassland and ponds to mitigate any impact the extension may have, it is advised that restoration should complement the existing consented area. It appears that the site would be supported if restoration is to agriculture with acid or neutral grassland and/or other biodiversity improvements. These uses are likely to be in conflict with each other unless the agricultural use was very low level conservation grazing. Any additional fertiliser, herbicide or pesticides used would lead to enrichment of the neutral grassland and damage to the flora and invertebrate communities. If intensive grazing were established on site then there would be very little benefit to ecology as the neutral grassland could not establish or thrive. Due to the damage already incurred to the LWS it is imperative that any further quarrying seeks to compensate for past habitat destruction and enhances all available habitat for biodiversity to extend the habitats already present in the area.

For the above reasons we would urge Kent County Council to obtain a firm commitment to the restoration of all the extension to neutral grassland and ponds and the provision of a management and monitoring plan to secure the management of the extension in the long term. If appropriate safeguards to conserve the Local Wildlife Site and restoration to extend biodiversity are not incorporated within the final site policy we would object to allocation of this site.

We recommend that a joint restoration, management and monitoring program be devised incorporating Site 75, 76 and Site 77 and the Local Wildlife Sites that may be impacted. We would welcome the opportunity to discuss this further. As this site is an extension to the Shepherds Farm Quarry there are opportunities to extend the heathland and grassland habitat into the area being worked at the present time. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.

Site 76 Chapel Lane Lenham Site 76 is not within a BOA but runs along the boundary of the Mid Kent Greensands and Gualt BOA. The proposed operations are likely to have an impact on the adjacent LWS if not mitigated. Therefore Kent Wildlife Trust welcomes the conditions that have been put in place to safeguard the hydrology and water courses within the proposed quarry. We are also pleased to note that the restoration is to be acidic grassland and heathland. The safeguarding of the water resources and restoration plan will limit the impact on the adjacent Lenham Heath and Chilston Park LWS and extend this habitat into the surrounding countryside. As this site is just outside the Mid Kent Greensands and Gualt BOA the proposed heathland and acidic grassland will form a valuable addition to this landscape scale corridor. To ensure management of the re-created habitat we would recommend that the final policy specifies that a management and monitoring strategy and appropriate funding for management in the long term be secured as part of any permission granted.

As this site is situated within the proximity of Site 75 and 77 we recommend that the operators work together to achieve landscape scale enhancement connecting existing LWSs with the new habitats wherever possible. If a management and monitoring Strategy is not secured as part of the final site policy we would object to the allocation of this site.

Site 77 Burleigh Farm and Tile Lodge Charing Site 77 is not within a BOA but will provide a valuable extension to the Mid Greensands and Gualt if restored for biodiversity. We note that this site is 540m from Pastures and Ponds Lenham Forstal LWS. We apologise for not identifying impacts within the initial consultation. Although the proposed plans will not affect the LWS directly, due to the interconnected water system between the proposed quarry and the LWS we have concerns that any impact on the water system within the site could lead to changes in the water quality and supply that feed the LWS, especially when viewed in-combination with Site 75. Within the final policy it will be important to clearly specify investigation of hydrology especially in relation to the LWS and protection of the water courses wherever possible. We are pleased that this issue has been included within the specifications for the site.

We welcome the proposed restoration of heathland and acidic grassland creation. However the site specifications also state that low level agriculture will be restored. The ecological and agricultural uses are likely to be in conflict with each other unless the agricultural use was very low level conservation grazing. Any additional fertiliser, herbicide or pesticides used would lead to enrichment of the acidic grassland and heath and damage to the flora and invertebrate communities respectively. If intensive grazing were established on site then there would be very little benefit to ecology as the ecological habitats could not establish or thrive. We would therefore urge Kent County Council to obtain a firm commitment to the restoration of the site to acidic grassland and heath habitat

Site 97 Shrine Farm Site 97 is within the mid Kent Greensands and Gualt BOA, is surrounded by ancient woodland part of which is designated as Postling Wents LWS and has been identified within the HRA as possibly having impacts on Folkestone to Etchinghill Escarpment SAC. (See below for further details regarding possible impacts on the Natura 2000 Network) Due to these sensitivities although we welcome the mitigation recommended of the stand-off areas to ensure the ancient woodlands are buffered and protection of the water habitats, we continue to have very high concerns regarding the viability of such a large extraction in such a sensitive area. We note that the proposed restoration is to low level farmland which will provide little mitigation for ecology other than the connections between the woodlands. We would urge Kent County Council to consider the targets within the BOA statement and design any mitigation to help to deliver these targets. The most relevant targets will be dependent on the underlying geology but it would seem most appropriate due to the ancient woodland surrounding the site that woodland or wood pasture to be re-created.

We note that an impact to Folkestone to Etchinghill Escarpment SAC has been identified within the HRA due to increased emissions on the M20. However we are concerned the assessment implies that the proposed vehicle movements of 50 vehicles per day will not result in an exceedance in the critical loads for this site and denigrates assessment of these impacts to the application stage.

Kent Wildlife Trust has been concerned for a number of years regarding the in-combination impact on Folkestone to Etchinghill Escarpment SAC, Dover to Kingsdown Cliffs SAC and Lydden and Temple Ewell Downlands SAC as a result of the rises in traffic from a number of developments that will increase traffic along the M20, A20 corridor. These include

 The Dover Ports Expansion  Whitfield Urban Expansion  The Shepway Strategic Corridor  Sites put forward as part of the Dover Sites Allocations DPD

However despite this pressure on the above sites yet again the assessment of impact is denigrated to the application process. We note that the criteria of 200 extra vehicle movements per day have been used to justify the position in regards to this site. Although the site alone may not generate 200 vehicle movements, an assessment is required regarding in-combination impacts with other developments. The in-combination impact is likely to far exceed 200 vehicle movements. We are concerned that if a strategic approach is not taken then the in-combination impacts are likely to be underestimated. We would advise that any in-combination impacts be assessed as part of the HRA for the Minerals Sites DPD with appropriate mitigation measures to alleviate impacts in respect of Site 97. (See introductory comments section 1.2 regarding concerns relating to Nitrogen Deposition)

As Dover to Kingsdown Cliffs SAC, already exceeding the critical nitrogen deposition level, and Lydden and Temple Ewell Downlands SAC are also situated within 200m of the road network we question why these sites have not been included within the assessment of impact. We recommend that impact on these SACs considered within the HRA unless it can be proved that the vehicle movements will not transport minerals on the part of the transport network adjacent to these sites.

Unless an in-combination assessment is undertaken on impacts and a resilient mitigation package with significant ecological benefits is incorporated within the policy to mitigate impact on the SAC, LWS and adjacent ancient woodland we would strongly object to this site being allocated as the current plans do not conform to national policy contained within the Conservation of Habitats and Species Regulations and the NPPF Paragraph 109 and 113. Appropriate assessment and mitigation of impacts on the SACs within the M20 corridor, the provision of a management and monitoring plan to secure the long term management of any habitat created is essential if ecological impact is to be mitigated.

Site 105 Borough Green Sandpit Extension Wrotham We are concerned that the HRA has identified this site as possibly having an in-combination impact on the North Downs Woodlands SAC with Site 61 of the Waste Sites DPD, however whereas Site 61 is scoped in for further assessment for impact of emissions this site is scoped out. We would query why this decision has been taken and ask for clarification. We are concerned that the increase in 78 vehicles has been described as minimal. Although individually the sites may not have an impact on the SAC the point of in-combination assessments are to ascertain what the current level of impact is and how the proposed development throughout the area will affect the site when viewed as a whole. Although the vehicle movements may be small this increase could be enough to cause the SAC to exceed the critical load for nitrogen deposition. Many development could state that the increases are small however when looked at as a whole they could be causing a significant impact on the European network. For this reason, as stated within our introductory comments, we recommend that a County wide study be undertaken in relation to NOx, to ascertain the true in-combination impacts of the plan on all the European sites at threat when viewed in-combination with other plans. We object to the conclusion of the HRA that there will be no impact from this site on the Natura 2000 network.

This site is in close proximity to site 6 and on the periphery of the Greensands Heath and Commons BOA. Therefore it will be important to examine the in-combination impacts of this site on Valley Wood and Wrotham Golf Course LWS and the ancient woodland fragments within the area. As stated for Site 6 and 24 there are possibilities to recreate and connect the heathland and woodland habitats within the area if the operators work together each reflecting the other sites restoration plans.

We are therefore concerned that the proposed restoration for this site is to amenity grassland and woodland. Such restoration will not fully realise the biodiversity benefits and it is our view that amenity grassland would not provide appropriate mitigation for the impacts both individually and in-combination with Site 6 on the Local Wildlife Site adjacent to the site. Unless appropriate safeguards to conserve the habitats contained within the Local Wildlife Site and a resilient restoration package is devised to mitigate any residual impact on the LWS and extend habitat we would object to the allocation of this site.

Further biodiversity gains and connectivity could be achieved if the existing quarry could also be restored to heathland with woodland connections. Although the Trust understands that as a permitted project this could only be achieved in agreement with the operator the management of the existing quarry and extension for biodiversity would provide more resilient mitigation and thus make all the proposed sites within the area more viable from an ecological standpoint.

3.2 Sharp Sand and Gravel Sites

In-combination impacts of Sites 1, 2, 17, 49 and 71 All these sites are adjacent to four interconnected Local Wildlife Sites that contain wetland habitats dependent on the supply and quality of water that emanates from all the above sites. We question whether this sensitive ecosystem is able to maintain the level of disturbance that will result from almost 4.5 million tonnes of gravel and sand being extracted within the locality, especially considering the quarrying already undertaken within the area. We are extremely concerned that the habitats and water supply will be irreparably damaged. We note that phased quarrying has been recommended for sites 17, 49, and 71 and would recommend that Site 2 be included within the phasing. Kent Wildlife Trust requests, as administrators of the LWS network, that hydrological studies are undertaken throughout the area to inform an assessment regarding the viability of the proposed sand extraction within all these sites. It is our view that this study should inform the level of sand that can be extracted without causing irrevocable impact on the surrounding ecological sites.

To ensure the highest ecological gains throughout the area a connected restoration management and monitoring strategy should be devised within the policy process to ensure that there are no long term impacts on the water supply, supporting wetland habitats and ancient woodland present and that landscape scale enhancement is achieved between all these sites. If hydrological impacts are not fully investigated and extraction levels dictated by the ecological constraints we would strongly object to all the above sites.

Site 2 Beltring Green Farm East Peckham This site is within the Medway Low Weald Wetlands and Grasslands BOA and is likely to have a direct and indirect impact individually and in-combination with other sites on LWS’s within the corridor. The site is adjacent to Stoneham and The Lees LWS and Hale Street Ponds and Pastures LWS. Within the Issues and Options consultation three sites were proposed within this area which would impact on a number of LWSs. Kent Wildlife Trust welcome the exclusion of two of these sites for further consideration as this will alleviate some of the impact on the important water systems that are present within the area. The proposed mitigation of reed beds and ponds could have a significant biodiversity benefit as habitat creation would connect the Shoreham and the Lees Yalding LWS and East Peckham Ponds LWS with Hale Street Ponds LWS and will help to deliver target 2 and 8 of the BOA.

However this is an extremely sensitive area ecologically with four LWSs connected into the water system within the locality and further sites dependant on a reliable water source within the wider landscape. It is therefore essential that there is no impact on the sites either directly via habitat loss or indirectly through changes in the water system either individually or in- combination with other sites. It is imperative that there is a full investigation of the hydrology and water flow of the area before this site is allocated. We recommend that safeguards are written into the final policy that no essential water feed to the surrounding Local Wildlife Sites should be impacted within any quarrying operations and it should be ensured that there is no contamination or pollution of the water system from the proposed operations.

To ensure management of the re-created habitat we would recommend that the final policy specifies that a landscape scale management and monitoring strategy and appropriate funding for management in the long term be secured as part of any permission granted.

Site 17 Moat Park Capel This site is just outside the Medway Low Weald Wetlands and Grasslands BOA Kent Wildlife Trust welcomes the hydrological investigations proposed but would recommend that any water systems running through the site be protected from harm within the final policy. We would also advise that the need to ensure no contamination of the water system is also highlighted.

We are pleased to note that the ancient woodland will be excluded from the site and protected from damage. The mitigation measures required should be detailed within the final policy. The restoration measures of phased wetland restoration are appropriate for this site and will help to deliver target 2of the BOA Statement.

We continue to have serious concerns regarding the individual and in-combination impacts of this site. It is a large site extracting 1.5 million tonnes of sand and gravel and we would question whether the adjacent East Tunbridge Copse Dykes and River Medway LWS can be safeguarded from such extensive quarrying activities. There are also high risks that other sites dependant on the water supply within the area would be impacted.

Site 49 Land North and South of Hammer Dyke Capel This site is not within the BOA but is in close enough proximity to the East Tunbridge Copse Dykes and River Medway LWS to have serious impacts on the LWS and the adjoining sites. As with the previous sites we welcome the safeguards that are proposed to endeavour to protect the ancient woodland and the sensitive designated sites and wetland habitats incorporated within the corridor. In respect of the ancient woodland we recommend that details of how this was to be achieved are laid out within the final policy.

As with the previous two sites we continue to have serious concerns regarding the individual and in-combination impacts on the BOA and the LWSs it contains. We question how the aim to protect the water system present on site can be achieved when 2 million tonnes of aggregate is to be extracted especially when viewed in-combination with other sites adjacent to the LWSs. There are also high risks that other sites dependant on the water supply within the area would be impacted.

Site 71 Stonecastle Farm Quarry Western Extension Whetshed This site is not within the BOA but is in close enough proximity to the East Tunbridge Copse Dykes and River Medway LWS to have serious impacts on the LWS and the adjoining sites. Although we note that there are requirements to safeguard the watercourses crossing the site, and the LWS and surveys are required, there is no requirement for a hydrological survey.

As with the previous sites we continue to have serious concerns regarding the individual and in- combination impacts on the LWSs. We question how the aim to protect the water system present on site can be achieved when 1.07 million tonnes of aggregate is to be extracted especially when viewed in-combination with other sites. There are also high risks that other sites dependant on the water supply within the area would be impacted.

(For details of impacts associated with Site 1 see section 3.7)

Site 73 Lydd Quarry Extension Areas A-D Lydd This site is located within a very sensitive area within the Romney Marshes to Rye Bay SSSI and adjacent to the Dungeness SAC. The proposals are for extensive quarrying within the area which could impact on the ecological viability of the Natura 2000 designation.

The HRA has identified the risks from dewatering of quarries stating

Additionally, minerals sites located near habitats where a balance of saline and fresh water is critical have the potential to affect flows through processes such as dewatering, leading to impacts such as reduced freshwater flows to estuaries and saline intrusion.

We are therefore surprised that the HRA has concluded that no site will lead to impacts due to dewatering. The Dungeness complex relies on a sensitive balance between the saline and freshwater habitats to support the rare flora and invertebrates on site and ensure the survival of the important Great Crested Newt population which is part of the designation. For the above reasons we feel that it is imperative that this site be scoped in for the possible impacts due to dewatering with a full assessment on the viability of the proposed quarrying within the LDF process.

We understand that there are sensitive ditches within the area that will need to be conserved or mitigated the land take could provide supporting habitat for SPA birds and the noise associated with the proposed operations may cause impact on the designated bird species. Therefore we welcome the fact that this issue has been scoped into the HRA for further assessment. This should be done as part of the LDF process not at application stage.

We are also concerned regarding the analysis that there will be no in-combination impacts as a result of the proposed minerals excavation within East Sussex due to the report prepared as part of the Sussex Minerals and Waste LDF. We have not seen the report alluded to and would have a number of queries as to the nature of the assessment.

 Did the assessment take into account the proposed mineral workings within Kent when considering in-combination impacts?  Did the proposed mitigation measures include the in-combination impacts of both schemes together? We wish to discuss this work further to clarify the nature of the assessment and would request sight of any report produced by Sussex County Council to ensure that the mitigation covered increased impacts as a result of the work proposed within Kent. It is our view that a further study assessing the impacts and possible mitigation should be commissioned for the Kent sites with all development in Kent and Sussex being appraised if this has not already been undertaken. It is essential that this is undertaken as part of the LDF process to ensure that this project is viable and will not contravene the Conservation of Habitats and Species Regulations 2010 and must be completed before allocation of this site.

In-combination impacts are also possible as a result of the plans within Rother and Shepway districts, especially in respect of tourism. This issue has been highlighted within both Local Authority Core Strategies and there are initial plans to undertake surveys and devise an access strategy to endeavour to mitigate increased impacts as a result of the plans. We can see no reference to assessment for in-combination impacts as a result of the above plans with only the minerals workings in Sussex being identified as an issue. There may be scope for Kent County Council to support this work financially and commit to only deciding to permit this site if the studies show that all impacts can be mitigated.

We do not agree that the Lydd airport expansion can be discounted as it is a permitted project by Shepway District Council and therefore any possible in-combination impacts should be included as part of any assessment. This is particularly pertinent in the case of nitrogen deposition. There were concerns regarding the impact of increased plane movements on the flora and invertebrates within the Natura 2000 site. We are concerned that in-combination impacts as a result of the proposed quarrying may increase this impact causing significant damage to the designated habitats and species.

Kent Wildlife Trust is extremely concerned regarding the lack of detail and assessment especially in relation to in-combination impacts and would wish to discuss this further to try to agree a way forward which will ensure that in-combination impacts are ascertained within the plan process to assess whether the project is viable and if so what mitigation measures are required to ensure no significant impacts will ensue from the proposed works. If this site is not investigated thoroughly for impacts and viability as detailed and resilient mitigation measures put in place to safeguard the Dungeness complex from individual and in-combination impacts we would strongly object to the allocation of this site.

3.3 Silica Sand Sites

Site 24 North of Addington Lane Trottiscliffe See detailed comments within section 3.1 Soft Sand Sites

3.4 Chalk Sites for Agricultural and Engineering Use

Site 63 Pinden Quarry North West Extension This site is adjacent to Disused Railway Cutting Longfield LWS. However the LWS is restricted to the railway cutting and the proposed extension is to the NW of the existing quarry and therefore should have no impact on the LWS. However KLIS shows that the proposed extension is within woodland. Although not ancient in origin it would be beneficial to preserve as much of this habitat. The LWS contains chalk grassland and the surrounding habitat contains neutral grassland. Therefore due to the sensitive nature of the infill it may be more beneficial to create species rich grassland with its nature being dictated by the final conditions on site. 3.5 Brickearth Sites

Site 19 Paradise Farm Hartlip and Newington This site is identified within the Issues and Options consultation and the HRA as within the locality of Queendown Warren SAC and we highlighted the possible impacts as a result of nitrogen deposition within our response. We agree with the HRA that due to the phased nature of the work to be undertaken and the limited time for these works, 12 weeks per year, that there are unlikely to be significant individual impacts as a result of the brickearth extraction. However we are concerned that we can find no reference to analysis of in-combination impacts as a result of other proposed projects that may be using the road network. As stated within our introductory comments it is our view that the issue of in-combination impacts of Nitrogen Deposition should be considered at a County scale as part of the LDF process with vehicle movements and destinations being identified and impact calculated. This is especially pertinent for this site due to the fact that the critical load for calcareous grassland is already being exceeded on site and significant new development is proposed within the Swale Core Strategy. If the above nitrogen deposition study is not undertaken and all in-combination impacts fully assessed within the HRA and final Minerals DPD we would object to allocation of this site.

Due to its sensitive location within the locality of Queendown Warren SAC and the residual and in-combination impacts on the SAC that may be caused by the increase in vehicle movements we are surprised that the restoration plan is to agriculture. It is our view that if extraction is to be permitted within the locality of any SAC opportunities for biodiversity conservation should be included within the restoration plan to ensure positive gains for wildlife outweigh the negative impacts that will result from the proposed quarrying. We would therefore recommend that

Site 98 Jefferies Site Teynham, Barbary Farm Norton Ash near Faversham and Site 102 Barrow Green Farm Teynham The Trust is concerned that the above sites could have an in-combination impact on the Swale SPA and Ramsar sites especially when viewed in-combination with Site 91. We apologise for not identifying the possible in-combination impacts of these sites on the SPA and Ramsar within the Issues and Options consultation. This is due to the three brick earth sites being submitted at a late stage within the process.

Although the habitats within and adjacent to the sites are grade 1 agricultural land there is a risk that the level of quarrying proposed could impact on the hydrology of the SPA and Ramsar Sites. As the water flow is paramount to the functioning of the European sites and the survival of the bird species for which the SPA is designated it is our view that all the above sites should be scoped into the HRA for possible impacts on the hydrology with an overall hydrological assessment undertaken for the three brickearth sites. We note that this issue has not been identified within the initial assessment and we would value the opportunity to discuss this further.

In relation to all four sites there may be a chance that the agricultural land contains supporting habitats for the SPA bird species. We note that this issue is identified within the initial HRA for site 101. We would question why this site has been scoped in whilst the other three sites which will also cause loss of agricultural land have been scoped out. We recommend that wintering and breeding bird surveys are undertaken on all habitats to be lost before final submission of the Minerals and Waste Sites DPDs to ensure that no supporting habitat is lost. Finally we would recommend that the in-combination impacts of noise from all four sites be considered within the HRA. We note that Site 91 has been identified for possible noise impacts and is very close to the SPA. We feel that alone this site is unlikely to have a significant impact unless it contains supporting habitat, however in-combination impacts are possible due to the extraction activities within the surrounding area. Due to the above concerns we would object to the HRA conclusions that Site 98 and 102 can be scoped out of the HRA at this point.

If in-combination impacts are found to be present due to the above pressures then it maybe pertinent to phase the three brickearth sites to ensure that only one site is operational at any time to alleviate impact.

(For details of landscape scale restoration see section 5)

3.6 Clay Sites

Site 60 Norwood Quarry Kent Wildlife Trust has no objection to the proposed extension to the above site. Woodland is present within the extension. This should be conserved if possible and if lost should be replaced within the restoration. As this site is adjacent to the North Kent Marshes BOA we recommend that the site be restored largely to wetland habitats. We welcome the aim to restore some of this site to woodland and ponds but would advise that to gain the optimum ecological enhancement agricultural uses should be excluded from the restoration plan.

3.7 Mineral Importation Sites

Site 1 This site is within the Medway Low Weald Wetlands and Grasslands BOA and adjacent to Site 2. Although we have no objections to the continued operation of the depot due to the significant impact of sites 2, 17, 49, and 71 we recommend that there should be no further impact from this site to the water system feeding the adjacent Stoneham and Lees LWS and the protection of the ancient woodland. We welcome the proposed screening which will extend the woodland within the area but would recommend that the quarry be enhanced for biodiversity with habitat recreation being to wetland habitats, reflecting the targets of the BOA. Stringent safety measures should be included to ensure that there is no contamination of the surrounding LWS from operations on site and no in-combination impacts with the above sites.

3.8 Secondary and Recycled Aggregate Sites

Site 21 F.M Conway Rochester Way Dartford This site is within the Thameside Green Corridor and is opposite Dartford Heath LWS. As stated within the Issues and Options consultation there is a risk that increased emissions due to the processes on site and the extra vehicles that the proposed extension of the recycling facilities will generate. This will need to be assessed in-combination with site 11 of the Waste Plan and could be included within the County wide project

As heathland can be damaged by NOx in particular, we welcome the commitment to provide mitigation for any impact on the heathland habitat. We would recommend that this be in the form of a contribution for the habitat restoration being undertaken within the LWS by Groundwork. If the built structure is to be extended there are also opportunities to provide additional heathland or acidic grassland habitat in the form of a green roof. We recommend that clauses detailing appropriate mitigation be incorporated within the site policy to ensure no impact on the adjacent LWS.

Site 65 Land North of Stevens and Carlotti Richborough This site is within the Lower Stour BOA as are Site’s 54, 64. As identified within the HRA all sites are in close proximity to a number of sensitive Natura 2000 designations. We are concerned that the HRA only identifies in-combination vehicle movements. It is Kent Wildlife Trust’s view that it is imperative that the impact of the emissions produced as a result of the waste and recycling processes planned, and predicted vehicle movements, be assessed both individually and in-combination with the other sites within the plan. Other pressures such as recreational pressure due to the proposed development in Dover and Thanet, and direct habitat loss and disturbance as a result of the pipelines, wind farms and the costal path should also be considered within the assessment of in-combination impacts.

It is Kent Wildlife Trusts understanding that if further information is acquired during the planning process of a site, including at the detailed stage, a HRA should be required and appropriate mitigation agreed to alleviate impact. Therefore, in the light of the proposed nitrogen deposition study, if Site 64 and 65 are found to have an individual or in-combination impact not identified within the original assessment and still require detailed planning permission for any aspect of the development, the planning permission will need to be reviewed and impacts assessed with appropriate mitigation measures formulated for any impact not mitigated within the original application

Assessment of individual and in-combination impacts should be undertaken as part of the LDF process not deferred to application stage as recommended within the HRA. It is our view that the impacts of emissions from the procedures proposed and the additional vehicle journeys as a result of these developments should be included in a County wide study on nitrogen deposition with individual and in-combination impacts being fully mitigated within any plan. Without such an assessment at a strategic level Kent County Council will not be able to evidence that there will be no significant impact on the European network and therefore will not be in conformity with the Conservation of Habitats and Species Regulations 2010 and we would strongly object to the allocation of all three sites.

This site is adjacent to Ash Level and South Richborough Pasture LWS. We continue to have concerns regarding the indirect impacts on the habitats contained within the LWS, which is an extensive area designated for its grazing marsh wet dykes, ditches and scrapes water bodies and river habitats. There is an extremely rich biodiversity on site including rare invertebrates such as the shinning ramshorn snail, 12 species of dragonfly, 135 species of moth and 22 species of butterfly, good populations of 3 reptile species, water vole and brown hare. The site is of importance for farmland, migratory and breeding birds with some SPA species using the site. Kent Wildlife Trust has historically had concerns regarding the poor water levels on the site due to over draining. However recently we have led a large project to increase the water flows on site creating scrapes and ditches that can be utilised by the flora and fauna present on the LWS. We are undertaking a two year project to increase the numbers of shinning ramshorm snail in the site.

We are very concerned that due to the nature of the LWS, the activities planned for this site in combination with sites 64 and 65 in the waste sites document will cause damage to the LWS through pollution and impact on the water flows. It is imperative that impacts are considered at a policy level with appropriate mitigation provided if this site is to be allocated. However we can see no safeguards within the plan to protect the LWS from harm. We would be happy to discuss appropriate mitigation measures further. Pending the outcome of these discussions, we object to the allocation of this site.

As these sites are permanent facilities there is not as much opportunity to provide positive gains for biodiversity as in the Mineral Sites DPD. However there are opportunities to provide enhancement to the site not being used for waste purposes. Due to the sites location within a BOA and their proximity to sensitive Natura 2000 sites we recommend that any facility be designed to fulfil the BOA targets. The most appropriate target would appear to be:-

1. Protect and enhance existing BAP priority habitats and designated sites.

Although calcareous grassland is not specifically mentioned in this context depending on the geology there may be opportunities to create a chalk grassland Green Infrastructure within the site and opportunities to create a green roof reflecting the habitats currently found on site and within the locality. Although we understand that as planning permission has been permitted this enhancement cannot be required, we recommend that if possible agreement is reached provide the above enhancements to achieve the maximum gains for biodiversity and alleviate some of the possible impact.

Site 72 Unit 14 Canterbury Industrial Estate This site is within the Lower Stour Wetlands BOA and adjacent to Former Hersden Quarry LWS. We welcome the exclusion of the LWS from the site but would continue to have concerns regarding possible impacts due to pollution and emissions on the important lichen heath community within the LWS. To ensure no impact on the LWS safeguards should be incorporated within the site policy to ensure no pollution as a result of the washing of aggregates and no nutrients are released as a result of the recycling of domestic waste proposed within the Waste Sites DPD. If a facility is to be provided as part of the development there may be opportunities to establish a lichen heath green roof to extend the rare habitat on the LWS into the site.

Of more concern are the possible impacts on the Stodmarsh SPA, SAC, Ramsar and SSSI site immediately adjacent to the site. In-combination with the waste uses proposed for this site there are risks that the marshes could be polluted due to contaminants entering the water system as a result of the washing of aggregates, deterioration of air quality which could impact on the sensitive flora and disturbance due to noise on the SPA bird species.

We note that the noise and air and water quality are identified within the HRA however it is recommended that impacts should be investigated at the application stage. It is Kent Wildlife Trust’s view that any impacts need to be identified before allocation with appropriate mitigation measures incorporated into the final site policy. If assessment of impact and mitigation is left until application Kent County Council cannot guarantee that there will be no impact on the Natura 2000 and Ramsar network as a result of the proposed uses and the plan will not be in conformity with the Conservation of Habitats and Species Regulations 2010.

Site 91 Animal Products Site, Faversham It is Kent Wildlife Trust’s view that there is unlikely to be an individual impact on the Swale SPA from this site due to the open landscape within the area. However we are pleased to note that this site has been scoped into the HRA for noise impacts. We do have concerns that there could be an in-combination impact in respect of loss of supporting habitats and noise when assessed in-combination with Sites 98, 101 and 102 identified for brickearth extraction. (For further information in regards to in-combination impacts see section 1 and 3.5) Site 99 Broomway Ltd Swanscombe This site is situated within the Thameside Green Corridors BOA the peninsular has been included in the mapping due to its possible national importance for rare invertebrates. We raised concerns regarding this site during the Issues and Options stages however having consulted entomologists familiar with the site we can confirm that this site does not contain habitat known to be of importance to these species. We therefore do not object to allocation of this site.

There are opportunities for this site and Site 107 of the Waste Sites DPD to recreate habitat for invertebrates through green infrastructure and green roofs and help to deliver BOA target 4.

4. Protect and manage the most significant brownfield sites, and ensure the long-term survival of their important wildlife, including UK BAP Priority invertebrates. Incorporate and seek to deliver the relevant targets in the national Habitat Action Plan for Open Mosaic Habitats on Previously Developed Land, as these are developed.

We have discussed the invertebrate issue with Lafarge as part of the Dartford LDF process and prepared a Statement of Common Ground. There are opportunities to contribute to a landscape scale project for both these sites in cooperation with development proposed within the Dartford LDF process. We recommend that clauses are written into site policies for both the above sites to increase and extend the habitat for these important species. 4. Detailed Comments on Waste Sites For many of the sites put forward as part of the Waste Sites DPD we have already provided detailed comments within the previous section. We do not intend to duplicate these comments and therefore where issues are common reference will be made to our comments on the minerals sites.

4.1 Energy from Waste

Site 13 Allington Waste Management Facility, Aylesford Kent Wildlife Trust has no objection in principle to the expansion of the Allington Waste Management Facility. However it would appear from the HRA that there is a risk that emissions from the proposed uses may impact on the Natura 2000 network within the area. Due to the distance of the facility from the North Downs Woodlands SAC and the need to produce an overall study of the in-combination impacts of emissions, we would also recommend that an assessment is undertaken of the movement of vehicles and their routes to ascertain whether there is to be increased pressure on the SAC as a result of NOx from increased traffic on roads 200m from the site.

There is a block of ancient woodland within the vicinity of the site. Impacts relating to the increase of emissions on the woodland should be assessed as part of the wider study, with measures formulated to ensure all impacts are mitigated. This could include securing the management of the ancient woodland block.

Site 54 Richborough Power Station A, Minster This site is within the Lower Stour BOA as are Site’s 64, 65. Kent Wildlife Trust agrees with the assessment of individual impacts of noise and NOx emissions identified within the HRA However we wish to highlight that any individual and in-combination impacts should include emissions generated as a result of the waste processed proposed

We are concerned that it is recommended that the in-combination impacts with Site 64 and 65 are deferred to the planning application stage. As stated within our introductory comments it is our view that in-combination issues relating to emissions and noise should be assessed at the policy level with a County wide study being commissioned in relation to emissions and in- combination impacts in respect of disturbance due to noise on the Sandwich Bay and Thanet Coast SPA being ascertained before submission of the Minerals and Waste Sites DPDs. Without assessment of in-combination impacts of the sites contained within the plans, coupled with the impacts already identified due to development in Dover and Thanet and pipeline, wind farms and coastal access projects, Kent County Council will be unable to prove that the proposed sites will not cause a significant impact on the Natura 2000 network and there is a risk that the plans will not be in conformity with the Conservation of Habitats and Species Regulations 2010 and we would strongly object to the allocation of all three sites. (See response to Site 65 for further information regarding the need to assess Site 64 and 65 for individual and in-combination impacts as a result of the proposed Plans)

This site is adjacent to Ash Level and South Richborough Pasture LWS. We welcome the exclusion of the parts of the LWS which were within the Issues and Options site however we continue to have concerns regarding the indirect impacts on the habitats contained within the LWS, which is an extensive area designated for its grazing marsh wet dykes, ditches and scrapes, water bodies and river habitats. There is an extremely rich biodiversity on site including rare invertebrates such as the shinning ramshorn snail, 12 species of dragonfly, 135 species of moth and 22 species of butterfly, good populations of 3 reptile species, water vole and brown hare. The site is of importance for farmland, migratory and breeding birds with some SPA species using the site. Kent Wildlife Trust has historically had concerns regarding the poor water levels on the site due to over draining. However recently we have led a large project to increase the water flows on site creating scrapes and ditches that can be utilised by the flora and fauna present on the LWS. We are undertaking a two year project to increase the numbers of shinning ramshorm snail in the site.

We are very concerned that due to the nature of the LWS, the activities planned for this site in combination with sites 64 in the waste sites document and 65 within the Minerals document will cause damage to the LWS through pollution and impact on the water flows. It is imperative that impacts are considered at a policy level with appropriate mitigation provided if this site is to be allocated. We can see no safeguards within the information provided to protect the LWS from harm. We would be happy to discuss appropriate mitigation measures further. Pending the outcome of these discussions, we object to the allocation of this site.

As these sites are permanent facilities there is not as much opportunity to provide positive gains for biodiversity as in the mineral Sites DPD. However there are opportunities to provide enhancement to the site not being used for waste purposes. Due to the sites location within a BOA and their proximity to sensitive Natura 2000 sites we recommend that any facility be designed to fulfil the BOA targets. The most appropriate target would appear to be:-

2. Protect and enhance existing BAP priority habitats and designated sites.

Although calcareous grassland is not specifically mentioned in this context we understand there are opportunities within this site to enhance the existing calcareous grassland on site and there may be opportunities to create a green roof reflecting the habitats currently found on site and within the locality. We recommend that consideration is given to enhancing the site and facilities to achieve the maximum gains for biodiversity.

Site 61 SCA Packaging, New Hythe Aylesford We are concerned that the HRA has identified this site as possibly having an in-combination impact on the North Downs Woodlands SAC with Site 105 of the Waste Sites DPD, however whereas this site is scoped in for further assessment for impact of emissions 105 is scoped out. We would query why this decision has been taken and ask for clarification. We are concerned that the increase in 78 vehicles has been described as minimal.

Although individually the sites may not have an impact on the SAC the point of in-combination assessments are to ascertain what the current level of impact is and how the proposed development throughout the area will affect the site when viewed as a whole. Although the vehicle movements may be small this increase could be enough to cause the SAC to exceed the critical load for nitrogen deposition. Many developments could state that the increases are small however when looked at as a whole they could be causing a significant impact on the European network. For this reason, as stated within our introductory comments, we recommend that a County wide study be undertaken in relation to NOx, to ascertain the true in-combination impacts of the plan on all the European sites at threat when viewed in-combination with other plans. We request that clarification also be provided as to why 105 have been identified as using the A229 and A249 whereas Site 6 within close proximity has not been included within the assessment. We object to the conclusion of the HRA that impact from this site on the Natura 2000 network is likely to be minimal. As stated within the Issues and Options consultation his site is in a sensitive location with a number of important ecological sites adjacent that could be impacted from emissions and drainage from the site. These include

 Holborough and Burnham Marshes SSSI which includes the River Medway  Leybourne Lakes Country Park and LWS which contains extensive water bodies  Eccles Old Pits LWS  The railway corridor that is likely to provide an important migratory corridor for wildlife.

Within the outline application for the warehousing planned for this site there appears to have been little consideration regarding the impacts of drainage and possible contamination on the designations of County and national importance within the surrounding area. Despite the above ecological sensitivities there are still no safeguards within the information provided to protect the national and County designations from impacts due to emissions and drainage. Unless safeguards are included within the final site policy we would object to the allocation of this site.

This site is situated within the Mid Kent Greensands and Gualt BOA which is already being impacted by a number of sites within the Minerals Sites with further sites adjacent to the corridor within both the Minerals and Waste Sites DPDs. Although this is not a designation and therefore does not need to be considered, impact on the BOAs does provide an indication of impacts on the wider ecosystem of an area, and provides a guide within the targets as to how resilience could be increased. Although the proposed development is permanent there are still opportunities to provide enhancements on site such as green infrastructure and green roofs that could contribute to the biodiversity value of the site and extend the linkages within the BOA. We recommend that the design of the development helps to deliver the targets within the BOA statement with the most appropriate target appearing to be target 2 to create heathland and acidic grassland.

Site 107 Land at Lower Road Swanscombe This site is situated within the Thameside Green Corridors BOA the peninsular has been included in the mapping due to its possible national importance for rare invertebrates. We raised concerns regarding this site during the Issues and Options stages however having consulted entomologists familiar with the site we can confirm that this site does not contain habitat known to be of importance to these species. We therefore do not object to allocation of this site.

There are opportunities for this site and Site 99 of the Minerals Sites DPD to recreate habitat for invertebrates through green infrastructure and green roofs and help to deliver the BOA target 4.

Protect and manage the most significant brownfield sites, and ensure the long-term survival of their important wildlife, including UK BAP Priority invertebrates. Incorporate and seek to deliver the relevant targets in the national Habitat Action Plan for Open Mosaic Habitats on Previously Developed Land, as these are developed.

4.2 Hazardous Landfill Site 60 Norwood Quarry and Landfill Extension Kent Wildlife Trust has no objections to the proposed plans for this site provided the investigations detailed within the HRA are undertaken at the policy level to ensure no individual or in-combination impacts on the Swale SPA and Ramsar sites. (See comments within section 3 regarding the recommendations for restoration)

Site 63 Pinden Quarry and Landfill Extension See comments regarding this site within section 3 for details of ecological sensitivities within the locality and recommendations for restoration.

4.3 Non Hazardous Landfill

Site 22 Rushenden Marshes This site is within the North Kent Marshes BOA and is adjacent to the Medway Estuary and Marshes SPA. Although we acknowledge that damage has already occurred due to the operations on site, we have been provided with reliable information that SPA bird’s species have been recorded on site within the recent past. As the appropriate assessment for the application only covered half the site we question why operations have been permitted to expand to cover the majority of the site as detailed within the HRA. Using the precautionary principal and due to the uncertainties regarding use, we advise that an assessment be made regarding whether this site is still used as supporting habitat for SPA species. A full survey should be undertaken focusing on the habitat which has not been disrupted. This should be undertaken as part of the policy process to ensure that this site can be allocated without significant impact on the adjacent European designations.

An assessment should also be undertaken regarding the impacts that previous and proposed operations would have on the hydrology and water quality of the adjoining Ramsar site and the species for which it is designated. Noise may also need to be assessed both individually and in- combination with other sites within the plan and the sites proposed within the Medway Core Strategy. Due to the above issues Kent Wildlife Trust does not agree with the HRA assessment for this site and objects to the decision to scope this site out at the present stage.

As this site is situated within the North Kent Marshes BOA we welcome the aim to restore the site to environmental uses and recommend that the targets within the BOA Statement are used to guide restoration plans. Targets of most relevance appear to be:-

2. Recreate grazing marsh on arable land and improved grassland in order to extend and connect existing habitats. This should include restoration or recreation of at least 200ha of grazing marsh on the Hoo Peninsula, adjoining the South Thames estuary and Marshes SSSI, and restoration or recreation of at least 100ha of grazing marsh on the Swale, adjoining The Swale SSSI.

We request that KWT is involved in any discussions regarding restoration of this site due to our aim to deliver the BOA network and landholding within the area. At the present time only Natural England and the RSPB are identified in this context.

4.4 Treatment/Materials Recycling Facilities Site 11 Lees Yard and Adjacent Land, Rochester Way Dartford This site is within the Thameside Green Corridors and opposite to Dartford Marshes LWS. There is likely to be an impact on the LWS as a result of nitrogen deposition on the heathland both individually and in-combination with Site 21 of the Minerals Plan. We welcome the clauses incorporated within the site information that any impact due to emissions will need to be mitigated and it is our view that appropriate mitigation could be to provide a financial contribution to the restoration of the heathland being undertaken by Groundwork. There are opportunities to re-create heathland habitat within the both sites by providing green infrastructure and green roofs for new facilities. (For further information regarding NOx, mitigation and habitat extension see comments for Site 21)

Site 14 Longfield Farm Paddock Wood As stated within the Issues and Options Consultation, Kent Wildlife Trust has no objections to the conversion and extension of this site to a recycling centre. There is a woodland block adjacent to the site which though not ancient in origin is likely to be important for wildlife within the area. We recommend that caveats are included within the final site policy to ensure the woodland is preserved and buffered within the design of the recycling plant.

Site 27 Otterpool Quarry, Sellindge Kent Wildlife Trust has no objections to an anaerobic digester and recycling facility on this site.

Site 51 Ridham Iwade This site is with the North Kent Marshes BOA and directly adjacent to the Swale SPA and Ramsar site. We note that this site has already received planning permission and no impacts were identified on the adjacent Swale SPA and Ramsar sites. We would ask for clarification that a HRA was carried out as part of the planning process. If this was not undertaken it is our view that this site should be scoped into the HRA process and impacts especially due to runoff are investigated. If impacts are found to occur and the site is still within the planning process appropriate mitigation should be required as part of any detailed permission.

Irrespective of the individual impacts it is our view that this site should be included in any in- combination assessment on the Swale SPA and Ramsar if residual impact is found to be present. This will enable an accurate assessment of impact to be ascertained and will ensure that Kent County Council are able to ensure that there is no significant impact on the Natura 2000 and Ramsar network in conformity with the Conservation of Habitats and Species Regulation 2010.

Site 63 Pinden Quarry See previous comments for this site.)

Site 64 Richborough Hall Sandwich This site is within the Lower Stour BOA as are Site’s 54, 65. As identified within the HRA all sites are in close proximity to a number of sensitive Natura 2000 designations. We are concerned that the HRA only identifies in-combination vehicle movements. It is Kent Wildlife Trust’s view that it is imperative that the impact of the emissions produced as a result of the waste and recycling processes planned, and predicted vehicle movements, be assessed both individually and in-combination with the other sites within the plan. Other pressures such as recreational pressure due to the proposed development in Dover and Thanet, and direct habitat loss and disturbance as a result of the pipelines, wind farms and the costal path should also be considered within the assessment of in-combination impacts. It is Kent Wildlife Trusts understanding that if further information is acquired during the planning process of a site, including at the detailed stage, a HRA should be required and appropriate mitigation agreed to alleviate impact. Therefore, in the light of the proposed nitrogen deposition study, if Site 64 and 65 are found to have an individual or in-combination impact not identified within the original assessment and still require detailed planning permission for any aspect of the development, the planning permission will need to be reviewed and impacts assessed with appropriate mitigation measures formulated for any impact not mitigated within the original application

We are very concerned that due to the nature of the LWS, the activities planned for this site in combination with sites 54 and 65 will cause damage to the LWS through pollution and impact on the water flows. It is imperative that impacts are considered at a policy level with appropriate mitigation provided if this site is to be allocated. However we can see no safeguards within the plan to protect the LWS from harm. We would be happy to discuss appropriate mitigation measures further. Pending the outcome of these discussions, we object to the allocation of this site.

1. Protect and enhance existing BAP priority habitats and designated sites.

Site 72 Canterbury Industrial Estate Hersden See previous comments for this site

Site 88 Sevington Rail Depot, Ashford We expressed concerns regarding the impacts of this site within the Issues and Options document. However we understand that these issues have now been dealt with at planning application level and we have no objections to the proposed development.

4.5 Sites for Green and Kitchen Waste

Site 23 Blaise Farm Providing the suggested safeguards of an enclosed facility are included within the site policy we would have no objections to a facility within this location.

Site 27 Otterpool Quarry See previous comments for this site

Site 51 Ridham Iwade See previous comments for this site

Site 65 Land North of Stevens and Carlotti Sandwich See previous comments for this site

4.6 Facilities for Household Waste

Site 13 Allington Waste Management Facility See previous comments for this site

Site 37 Cobbs Wood Industrial Estate, Ashford Kent Wildlife Trust has no objection to a new waste transfer station on this site. 5. Landscape Scale Enhancement within the BOAs

5.1 Landscape Scale Enhancement of Sites within the Greensands Heaths and Commons BOA

Within the Minerals Sites DPD there are three sites within the Greensands Heaths and Commons BOA Sites 6, 24 and 105. There are likely to be impacts on Ryash Wood LWS from Site 24 and Valley Wood and Wrotham Golf Course LWS from Sites 6 and 105. We recommend that consideration be given to the in-combination impacts of all four sites and the positive ecological gains that can be made from the restoration and enhancement of these sites.

The Greensands Heaths and Commons BOA have been identified for its acidic ancient woodland and wood pasture and acid grassland and heathland sites. The statement for the Greensands Heaths and Commons BOA contains a specific target for the restoration of sandpits within this corridor

Pursue opportunities for quarries to be restored to maximize their biodiversity potential. Where appropriate, seek restoration to heathland and/or acid grassland as a condition of permissions for aggregates extraction.

We would appreciate the opportunity to work with Kent County Council and the applicants of the Minerals sites to agree restoration plans that both mitigate impact on the adjacent Local Wildlife Sites and provide positive gains for wildlife by creating acidic grassland, heathland and establishing linear links between the ancient woodland and wood pasture sites. Opportunities should also be explored where possible to link up the restored and existing habitats on a landscape scale. This could involve working with the operators of the existing sand extraction sites to review the permissions for restoration on these sites to restore at least a part of these sites to heathland, grassland with woodland connections where appropriate. We feel it would be appropriate from an ecological point of view to provide a policy that covered all sites within and adjoining the BOA and that all operators work together to devise a common management and monitoring strategy that will achieve landscape scale enhancement in the long term. Appropriate funding for habitat management should be secured at a policy level to ensure the restored habitats are maintained in the long term. (See individual comments below regarding site specific issues)

5.2 Connecting the Greensands Heaths and Commons BOA with the Mid Kent Greensands and Gualt BOA and the Mid Kent Woods and Scarp BOA

Site 75 76 and 77 could provide an important connection between the above BOAs. Although not within a BOA all these sites will have impacts on Local Wildlife Sites Due to the geology of the area there are opportunities to create and extend the acidic grassland, heathland and wetland habitats present within the LWS’s and provide connections between the ancient woodlands.

We would appreciate the opportunity to work with Kent County Council and the applicants of these sites to agree restoration plans that both mitigate impact on the adjacent Local Wildlife Sites and provide positive gains for wildlife. Opportunities should be explored where possible to link up the restored and existing habitats on a landscape scale. This could involve working with the operators of the existing sand extraction sites to review the permissions for restoration on these sites to restore at least a part of these sites to heathland, grassland with woodland connections where appropriate. We feel it would be appropriate from an ecological point of view to provide a policy that covered all sites and that operators work together to devise a common management and monitoring strategy that will achieve landscape scale enhancement in the long term. Appropriate funding for habitat management should be secured at a policy level to ensure the restored habitats are maintained in the long term. (See individual comments below regarding site specific issues)

5.3 Landscape Scale Enhancement within and adjacent to the Medway and Low Weald Wetlands and Grasslands BOA

The Trust is very concerned regarding the impact of Sites 2, 17, 49, and 71 on the LWSs incorporated within the Medway and Low Weald Wetlands and Grasslands BOA. There may also be a residual impact on the BOA from Site 1 when viewed in-combination with the sites above. Four LWSs are likely to be affected Hale Street Ponds and Pastures LWS, East Peckham Ponds LWS, East Tonbridge Copse, Dykes and River Medway LWS and Stoneham and The Lees LWS. All these sites have interconnecting water systems which reach into the development sites and there is likely to be a cumulative pressure from the quarrying proposed. There are also threats to other designated sites within the BOA if water currently feeding into the wetlands and rivers are diverted.

The Medway and Low Weald Wetlands and Grasslands BOA has been identified as it contains an important river, wetland and woodland complex with the stretches and tributaries of the rivers Medway, Eden and Sherway running through the BOA. Associated habitats of species rich neutral and floodplain meadows, fens and ponds support a diverse flora and invertebrate community which are reliant on the wetland habitats. Relevant targets for restoration could include:-

1 Pursue opportunities for creation of wider river floodplains with riparian corridors around natural drainage channels.

2 Pursue opportunities for the establishment, by 2020, of a new, landscape-scale, freshwater wetland complex, including fen, wet woodland, reed bed and wet grassland, in which successional processes are allowed to proceed. In this context, a ‘landscape-scale’ complex should be considered as extending over at least 1000 hectares.

8 Maintain, restore, recreate and buffer ponds, particularly to establish networks of sites to support great crested newt.

We therefore welcome the proposed restoration to wetland habitats, grassland and woodlands as this will enhance the area in the long term. However we would recommend that a study be undertake regarding the activities that would be feasible within the area without causing irreparable damage to the wetland complex already present.

We would appreciate the opportunity to work with Kent County Council and the applicants of the Minerals sites to agree restoration plans that both mitigates impact on the adjacent Local Wildlife Sites and provide positive gains for wildlife by creating connected wetland habitat. Opportunities should be explored where possible to link up the restored and existing habitats on a landscape scale. This could involve working with the operators of the existing extraction sites to review the permissions for restoration on these sites to restore at least a part of these sites to wetland where appropriate. We feel it would be appropriate from an ecological point of view to provide a policy that covered all sites within and adjoining the BOA and that all operators work together to devise a common management and monitoring strategy that will achieve landscape scale enhancement in the long term. Appropriate funding for habitat management should be secured at a policy level to ensure the restored habitats are maintained in the long term. (See individual comments below regarding site specific issues)

Stonecastle Farm Quarry We note that site 49 and 17 are proposed as extensions to the existing Stonecastle quarry and there are opportunities to incorporate any restoration of this site to be completed within the proposed landscape scale project. We understand that as a permitted project this could not be required but we would urge Kent County Council to work with the operators to review the planned restoration to improve landscape scale benefits within and adjacent to the BOA.

5.4 Landscape Scale Enhancement of the North Kent Marshes BOA

There are a number of brickearth sites site 98, 101 and 102 respectively and sites 22 and 51 that are situated within or adjacent to this BOA. Irrespective of whether the sites contain supporting habitats at present there are significant opportunities to create supporting habitats within the restoration plans for these sites. The North Kent Marshes BOA is identified for its diversity of habitats including grazing marsh. The BOA comprises predominantly international and national sites and is important for its wintering and breeding bird species. The target for the BOA that could be of relevance to the restoration of the above sites is:-

2. Recreate grazing marsh on arable land and improved grassland in order to extend and connect existing habitats. This should include …restoration or recreation of at least 100ha of grazing marsh on the Swale, adjoining The Swale SSSI.

We would value the opportunity to discuss a landscape scale project with respect to these sites to extend the habitats present within the BOA.

5.5 Landscape Scale enhancement within the Lower Stour Wetland BOA

The Lower Stour Wetland BOA has been identified as it contains some of Kent’s most extensive water and wetland habitats including parts of Sandwich and Pegwell Bay SSSI and Stodmarsh. Two Minerals sites and three Waste sites are present within the BOA all of which have the potential to have a significant impact on the international and national sites present within the locality. In respect of restoration there are a number of targets that could be relevant to increase biodiversity, however before allocation of any of these sites a rigorous assessment is required to ensure they have no impact on the Natura 2000 network either alone or in- combination with other sites within the Minerals and Waste LDF and Local Authority LDFs. Once this assessment is completed, if it is felt impact can be mitigated, we would appreciate the opportunity to discuss a landscape scale enhancement project incorporating all sites to provide stepping stones of priority habitats in the form of green infrastructure and green roofs.

We would value an opportunity to discuss our concerns with you and look forward to hearing from you.

Yours sincerely

Debbie Salmon (Conservation Officer, Policy and Planning}