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

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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.
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