Sustainability Statement November 2020

Birchington-on-Sea, Sustainability Statement

On behalf of Ptarmigan Land

Project Ref: 39862/3022 | V1 | Date: November 2020

Registered Office: Buckingham Court Kingsmead Business Park, London Road, High Wycombe, Buckinghamshire, HP11 1JU Office Address: Caversham Bridge House, Waterman Place, Reading, Berkshire RG1 8DN T: +44 (0)118 950 0761 E: [email protected] Sustainability Statement Birchington-on-Sea, Kent

Document Control Sheet

Project Name: Birchington-on-Sea, Kent Project Ref: 39862 Report Title: Sustainability Statement Doc Ref: V1 Date: November 2020

Name Position Signature Date

Assistant Francesca Prepared by: Environmental FP November 2020 Prestinoni Planner

Reviewed by: Richard Knight Associate RK November 2020

Director Energy and Approved by: Jonathan Riggall JR November 2020 Natural Resources

For and on behalf of Stantec UK Limited

Revision Date Description Prepared Reviewed Approved

October DRAFT Draft for comment FP RK JR 2020

November V1 Final Version FP RK JR 2020

This report has been prepared by Stantec UK Limited (‘Stantec’) on behalf of its client to whom this report is addressed (‘Client’) in connection with the project described in this report and takes into account the Client's particular instructions and requirements. This report was prepared in accordance with the professional services appointment under which Stantec was appointed by its Client. This report is not intended for and should not be relied on by any third party (i.e. parties other than the Client). Stantec accepts no duty or responsibility (including in negligence) to any party other than the Client and disclaims all liability of any nature whatsoever to any such party in respect of this report.

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Contents

1 Introduction ...... 1 1.1 Background ...... 1 1.2 Site Location and Description ...... 1 1.3 Development Proposals ...... 1 1.4 Purpose and Structure of this Statement ...... 1 2 Policy Review ...... 3 2.1 Introduction ...... 3 2.2 National Planning Policy ...... 3 2.3 Local Planning Policy ...... 4 2.4 Guidance ...... 6 2.5 Housing Standards Review ...... 7 2.6 Summary ...... 7 3 Socioeconomics ...... 8 3.1 Introduction ...... 8 3.2 Baseline Conditions – Existing Economic Assets ...... 8 3.3 Sustainable Business Growth ...... 8 3.4 Affordable Housing ...... 9 3.5 Low Carbon Economy ...... 9 3.6 Summary ...... 9 4 Cultural Heritage ...... 11 4.1 Introduction ...... 11 4.2 Baseline Conditions ...... 11 4.3 Mitigation Measures ...... 11 4.4 Summary ...... 12 5 Air Quality ...... 13 5.1 Introduction ...... 13 5.2 Existing Conditions ...... 13 5.3 Impacts on Air Quality ...... 13 5.4 Construction Mitigation Measures ...... 14 5.5 Operational Mitigation Measures ...... 14 5.6 Summary ...... 15 6 Biodiversity and Landscape ...... 16 6.1 Introduction ...... 16 6.2 Baseline Conditions ...... 16 6.3 Potential Effects ...... 18 6.4 Mitigation Measures ...... 18 6.5 Summary ...... 19 7 Waste Management & Materials ...... 20

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7.1 Introduction ...... 20 7.2 Waste Hierarchy ...... 20 7.3 Construction Waste ...... 20 7.4 Specification of Materials ...... 21 7.5 Construction Waste Management ...... 22 7.6 Operational Waste ...... 23 7.7 Summary ...... 23 8 Water Management ...... 24 8.1 Introduction ...... 24 8.3 Flood Risk ...... 25 8.4 Adaptation and Mitigation to Flood Risk ...... 26 8.5 Drainage Strategy...... 26 8.7 Summary ...... 27 9 Transport ...... 28 9.1 Introduction ...... 28 9.2 Baseline Conditions ...... 28 9.3 Measures ...... 29 9.4 Electric Vehicles ...... 29 9.5 Summary ...... 30 10 Energy and Climate Change ...... 31 10.1 Introduction ...... 31 10.2 Energy Strategy ...... 31 10.3 Design Principles to Reduce Energy Demand ...... 32 10.4 On Site Renewable Energy Generation ...... 33 10.5 Climate Change ...... 34 10.6 Summary ...... 35 11 Summary ...... 37

Figures

Figure 7.1: Waste Hierarchy ...... 20 Figure 10.1 The energy hierarchy in new development ...... 31

Tables

Table 10.1 UK Carbon Budgets for 2018-2032 ...... 34

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Appendices

Appendix A Parameter Plans Appendix B Pre-application Consultation between Stantec, Barton Willmore and TDC

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1 Introduction

1.1 Background

Stantec UK Limited (Stantec) has been appointed by Ptarmigan Land (the ‘Client’) to prepare a Sustainability Statement (the ‘Statement’) to support an outline planning application for a residential led development at south-west Birchington-on-Sea, Kent (herein the ‘proposed development’).

The Site is located within the administrative boundary of Council (TDC).

1.2 Site Location and Description

The Site covers an area of 78.35 hectares on what is currently working agricultural land. The Site forms a band across the southern fringes of south west Birchington-on-Sea and is intersected by the A28 Road. A Site Location Plan is provided in the Parameter Plans in Appendix A.

The Site is bounded to the north by the Network Rail railway line. Immediately north and east are the residential dwellings of Birchington-on-Sea. To the south and west of the Site are open agricultural fields.

1.3 Development Proposals

Outline planning application, with all matters reserved except for access, for a mixed-use urban extension comprising:

Up to 1,650 residential units (use class C3); residential care home (use class C2); two form entry primary school (use class F1); land for the expansion of the existing Birchington medical centre; mixed use centre (use class E, F1 and F2); and associated infrastructure including provision of a new strategic link road between Minnis Road and Manston Road, alterations to existing junctions and new access arrangements from Minnis Road, Park Lane, Canterbury Road and Manston Road/Acol Hill, a new recreational and leisure shared-use link between Minnis Road and Park Lane, green infrastructure including public open space and associated facilities, landscaping, formal and informal play areas, utilities (including drainage) and associated ancillary works and structures.

It is anticipated that the Proposed Development will be brought forward in 4 phases. Construction on the first phase is anticipated to commence in mid-2021, with the entire site to be completed in 2033.

The masterplan will evolve through ongoing community and stakeholder engagement, masterplanning opportunity and constraints analysis and collaboration with TDC as pre- application discussion progress.

1.4 Purpose and Structure of this Statement

The purpose of this sustainability statement is to highlight how the proposed development will meet the requirements of local, regional and national policies aligned with sustainability and their associated targets.

The approach adopted in this Statement is to review national and local development plan policies in relation to sustainable development, and establish a ‘sustainability framework’ for the proposed development that achieves both over-arching national sustainability goals and site-specific objectives.

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Consultation has been undertaken between Stantec, Barton Willmore and TDC to confirm the scope of the Sustainability Statement and the topics that should be addressed. Consultation took place between 9th December 2019 and 19th February 2020. This pre-application consultation is provided in Appendix B.

The Sustainability Statement has been structured following the policies that we should be addressing in ’s Local Plan 2006 and emerging Local Plan 2031.

The Statement is structured as follows:

 Section 2: Policy Context;

 Section 3: Socioeconomics;

 Section 4: Cultural Heritage;

 Section 5: Air Quality;

 Section 6: Biodiversity and Landscape;

 Section 7: Waste Management & Materials;

 Section 8: Water;

 Section 9: Transport;

 Section 10: Energy and Climate Change; and

 Section 11: Summary.

This Statement refers to a number of accompanying reports submitted as part of the planning application. These include:

 Landscape Environmental Statement (ES) Chapter– ETLA Studio;

 Air Quality ES Chapter – Stantec;

 Cultural Heritage report (Archaeology and Built Heritage) ES Chapter – Trium;

 Built Heritage Statement – RPS Group;

 Ecology & Biodiversity ES Chapter – Stantec;

 Flood Risk Assessment – Stantec;

 Socioeconomic ES Chapter – CBRE

 Outline Energy Statement – Stantec;

 Greenhouse Gas Emissions Assessment – Stantec; and

 Transport Assessment – TPA.

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2 Policy Review

2.1 Introduction

This section presents a summary of the main policies that are directly related to defining sustainable development in this area and highlight the key sustainability objectives that need to be met by the Proposed Development.

2.2 National Planning Policy

Climate Change Act 2008

Climate change is recognised as one of the most immediate global environmental challenges. In May 2019, the Committee on Climate Change published the Net Zero report, recommending that the UK Government introduce a target of at least a 100% reduction of greenhouse gas emissions by 2050.

In 2019, the Climate Change Act (CCA) 2008 was amended to include a revision of the previous aim of 80% reduction of GHG emissions compared to 1990 levels by 2050. The CCA 2008 now mandates a net zero target:

“the net UK carbon account for the year 2050 is at least 100% lower than the 1990 baseline.”

National Planning Policy Framework (2019)

The National Planning Policy Framework (NPPF), updated in February 2019, sets out the government’s planning policies for and how these are expected to be applied. The NPPF supports the role of the local plan process and maintains the “presumption in favour of sustainable development”.

The NPPF focuses on sustainable development, which is described as “meeting the needs of the present without compromising the ability of future generations to meet their own needs”. It sets out the three mutually dependent roles that the planning system needs to consider to deliver sustainable development. These are:

 An economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

 A social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and

 An environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

The NPPF sets out the following core land use planning principles, or ‘principles’ for delivering sustainable development – these form the framework against which the sustainability of new development or redevelopment is assessed:

 Building a strong, competitive economy;

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 Ensuring the vitality of town centres;

 Supporting a prosperous rural economy;

 Promoting sustainable transport;

 Supporting high quality communications infrastructure;

 Delivering a wide choice of high-quality homes;

 Requiring good design;

 Promoting healthy communities;

 Protecting Green Belt land;

 Meeting the challenge of climate change, flooding and coastal change;

 Conserving and enhancing the natural environment;

 Conserving and enhancing the historic environment; and

 Facilitating the sustainable use of minerals.

It is important that local planning policies are aligned to the sustainable development principles set out in the NPPF.

2.3 Local Planning Policy

The local planning authority for the proposed development is TDC. TDC’s planning policy is set out in a series of adopted and emerging documents. This section outlines the relevant policies in relation to the proposed development.

Local Plan 2031

The Thanet Local Plan 2031 was adopted on 9 July 2020. There are several core policies relating to sustainability that have guided the structure of this Sustainability Statement. These have been quoted and described below.

Policy QD01 – Sustainable Design

Policy QD01 details the requirements expected for developments to adhere to in order to achieve a sustainable design that can contribute in reducing greenhouse gas emissions and increasing the resilience of a development to function in a changing climate. All developments are required to:

 “1) Achieve a high standard of energy efficiency to the equivalent of Level 4 of the Code for Sustainable Homes (subject to HE05 where applicable). Where viability is an issue, it will be incumbent an on an applicant to demonstrate to the satisfaction of the Council why this standard cannot be achieved.

 2) Make the best use of solar energy passive heating and cooling, natural light, natural ventilation and landscaping.

 3) Provide safe and attractive cycling and walking opportunities to reduce the need to travel by car.

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All new buildings and conversions of existing buildings must be designed to use resources sustainably. This includes, but is not limited to:

 4) Re-using existing buildings and vacant floors wherever possible;

 5) Designing buildings flexibly from the outset to allow a wide variety of possible uses;

 6) Using sustainable materials wherever possible and making the most sustainable use of other materials;

 7) Minimising waste and promoting recycling, during both construction and occupation.”

Policy SP37 – Climate Change

Policy SP37 details how TDC expects all new developments to consider the need to respond to climate change. To do this the following measures must be applied:

 “1) by minimising vulnerability and providing resilience to the impacts of climate change through the use of up to date technologies, efficient design and appropriate siting and positioning of buildings;

 2) Mitigating against climate change by reducing emissions and energy demands through the use of up to date technologies;

 3) realise and make best use of available opportunities to reduce the impact of climate change on biodiversity and the natural environment by providing space for habitats and species to move through the landscape and for the operation of natural processes, particularly at the coast.”

Policy QD02 - General Design Principles

Policy QD02 emphasises the primary planning aim in all new development which is to promote or reinforce the local character of the area and provide high quality and inclusive design and be sustainable in all other respects. Developments must:

 “1) Relate to the surrounding development, form and layout and strengthen links to the adjacent areas.

 2) Be well designed, respect and enhance the character of the area paying particular attention to context and identity of its location, scale, massing, rhythm, density, layout and use of materials appropriate to the locality. The development itself must be compatible with neighbouring buildings and spaces and be inclusive in its design for all users.

 3) Incorporate a high degree of permeability for pedestrians and cyclists, provide safe and satisfactory access for pedestrians, public transport and other vehicles, ensuring provision for disabled access.

 4) Improve people's quality of life by creating safe and accessible environments, and promoting public safety and security by designing out crime.

External spaces, landscape, public realm, and boundary treatments must be designed as an integral part of new development proposals and coordinated with adjacent sites and phases. Development will be supported where it is demonstrated that:

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 5) Existing features including trees, natural habitats, boundary treatments and historic street furniture and/or surfaces that positively contribute to the quality and character of an area are should be retained, enhanced and protected where appropriate.

 6) An integrated approach is taken to surface water management as part of the overall design.

 7) A coordinated approach is taken to the design and siting of street furniture, boundary treatments, lighting, signage and public art to meet the needs of all users.

 8) Trees and other planting is incorporated appropriate to both the scale of buildings and the space available, to provide opportunities for increasing biodiversity interest and improving connectivity between nature conservation sites where appropriate.”

Other relevant key policies that are referenced throughout the report include, (not exclusive):

 Policy SP04 – Economic Growth;

 Policy SP13 – Housing Provision;

 Policy SP14 – General Housing Policy;

 Policy SP23 - Affordable Housing;

 Policy SP26 – Landscape Character Areas;

 Policy SP27 - Green Infrastructure;

 Policy SP30 - Biodiversity and Geodiversity Assets;

 Policy SP34 – Provisions of Accessible Natural and Semi-Natural Green Space, Parks, Gardens and Recreation Grounds;

 Policy SP36 – Conservation and Enhancement of Thanet's Historic Environment;

 Policy 41 – Primary and Secondary Schools;

 Policy SP43 - Safe and Sustainable Travel; and

 Policy CC04 – Renewable Energy.

2.4 Guidance

Kent Design Guide

TDC adopted the Kent Design Guide (KDG) as a Supplementary Planning Document (SPD) in December 2006.

The KDG is a document produced as a result of a partnership of Kent’s local authorities. The KDG aims to promote high standards in design and construction and encourage good design to reinforce Kent’s distinctive character.

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2.5 Housing Standards Review

Written Statement to Parliament – Planning Update (March 2015)

In March 2015, the Government released a written statement providing a Planning Update outlining their position on housing standards and confirming the adoption of optional new technical standards.

The Statement explains that, from the 26th March 2015, the Code for Sustainable Homes (CSH) has been withdrawn, aside from the management of legacy cases. New local plans and neighbourhood plans therefore may not refer to the Code.

Policy QD01 requires all new developments to “achieve a high standard of energy efficiency to the equivalent of Level 4 of the Code for Sustainable Homes.” Given the Code has been withdrawn, Code Level 4 is equivalent to a 19% improvement over Part L 2013.

2.6 Summary

In accordance with national and local planning policy and guidance, the proposed development at Birchington should:

▪ Design to reduce emissions and greenhouse gases through a high standard of energy efficiency, and orienting developments to make the best use of spatial and plot design.

▪ Potential to provide a proportion of the development’s energy supply by employing low carbon and renewable energy sources such as solar PV panels;

▪ Secure sustainable materials wherever possible, minimising waste and promoting recycling during construction and occupation.

▪ Provision of a water conservation strategy to outline measures which could be included within the proposed development to help achieve the per capita consumption of potable water target;

▪ Manage flood risk by incorporating SuDS to help manage surface water, and by identifying design features which may be included to increase the resilience of the development to impacts from flooding;

▪ Protecting local air quality and limiting noise and light pollution, by providing mitigation measures to limit potential polluting effects across the construction and operational phases;

▪ Maintain the landscape and cultural setting of the area by mitigating and enhancing the existing character of the development;

▪ Promote sustainable travel modes (including walking, cycling and public transport) as an alternative to private car use by providing routes which are safe and accessible, and providing secure cycle storage facilities in line with local guidance; and

▪ Retain, enhance and create new habitats to preserve the ecological setting of the site, through a number of measures including water attenuation, native tree planting.

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3 Socioeconomics

3.1 Introduction

This section explains how a sustainable low carbon economy will be encouraged and contributed to through providing opportunities for sustainable business growth and incorporating sustainable design principles.

This section outlines the socioeconomic considerations for the entire scheme at Birchington- on-Sea. It takes into account Policy SP04 ‘Economic Growth’, SP13 ‘Housing Provision’, SP23 ‘Affordable Housing’ and SP40 ‘Primary and Secondary Schools’ of the TDC Local Plan 2031 describes in Section 2.5.6.

A Socioeconomic Chapter (CBRE, 2020) has been prepared as part of the ES and should be read in conjunction with this section.

3.2 Baseline Conditions – Existing Economic Assets

The population of Thanet was estimated to be 134,186 in the 2011 census.

According to the 2018 mid-year population estimates from the Office for National Statistics (ONS), Thanet has a relatively older age profile. The population of TDC consists of 17.8% aged 15 years and under, 61% at working age and 21.1% are over 65 years old. This compares to the regional percentages in the South East of 17.7% at under 15 years, 65% at working age and 17.1% aged 65 and over which are similar to the national levels of 17.7%, 66% and 16.3% respectively.

The district is a combination of rural and urban areas. In 2011, the Birchington South Ward neighbourhood was recorded as having a density of 11.2 persons per hectare (pph). This is lower than the local authority population density (13 pph).

The neighbourhood’s economic activity rate of 72.7% is lower than both the local authority average (73.9%) and the national average (78.5%). In the Annual Survey of Hours and Earnings (ASHE) 2019 Provisional Results, the average income for the local authority is £30,562 compared to the regional average of £42,165 and the national average of £38,187. The average wage per week in the local authority is £599.10 compared to the regional average of £774.30 and the national average of £713.30.

Approximately five schools, including primary and secondary schools, are located within three miles of the site. The school in closest proximity to the Site is Birchington Church of England Primary School located approximately 0.45 miles to the east.

There are five GP surgeries located within three miles of the Site. The closest GP is the Birchington Medical Centre 0.2 miles from the Site.

In terms of deprivation, the Indices of Multiple Deprivation (IMD) data shows that the local site level ranges between the 30% most deprived and 20% least deprived Lower Super Output Area (LSOAs) nationally, with an IMD rank of between 8,581 and 23,340 (out of a total of 32,844).

3.3 Sustainable Business Growth

A convenience retail provision and community space has been proposed at Birchington-on- Sea application and will serve the residents of the Proposed Development and also those within the wider area. This element of the Proposed Development will comprise a mix of uses designed to offer flexibility, with a view to serving the local needs of the Proposed

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Development and meet the market demands to ensure the uses are viable in the long term. It includes the provision of a shop, co-working space, and a café space.

In line with Policy SP40, the Proposed Development will introduce new valuable assets to the wider areas. A 2FE primary school, the expansion of Birchington medical centre and a new retirement home are additional assets that the Proposed Development will bring to current and future residents of the wider area.

As stated in Section 3.2.2, Thanet is characterised by an ageing population, and therefore, the Proposed Development to satisfy the local needs through provision of more healthcare and retirement homes for the elderly.

The Proposed Development will create new full-time jobs both directly and indirectly related to the construction of the development. The socio-economic assessment undertaken estimates that the Proposed Development will create in the region of 103 full time equivalent (FTE) jobs for the total construction jobs. As well as the positive impact of job create, there will subsequently be positive indirect impacts upon the local economy.

3.4 Affordable Housing

The Proposed Developments supports Policies SP13 ‘Housing Provision’ and SP23 ‘Affordable Housing’ stated in Section 2.5.6.

The Proposed Development will assist in housing delivery by providing up to 1,650 dwellings. In addition, up to 30% of the proposed housing will be provided as affordable, subject to viability.

3.5 Low Carbon Economy

In context of this Sustainability Statement, a low carbon economy is considered to be growth that aims to be delivered in a low carbon way within the Proposed Development and the facilities it will provide.

Through the sustainable transport, energy, waste and materials procurement strategies, it is envisaged that the greenhouse emissions associated with the construction and operation of the Proposed Development will be reduced and low carbon economy will be promoted.

The Proposed Development has been, and will continue to be, designed in accordance with the energy hierarchy principles (Figure 10.1). The transport and energy strategies for the Proposed Development are discussed in more detail in Section 9 and Section 10 respectively.

3.6 Summary

The Proposed Development will increase the resident population within Thanet. This increase will create socio-economic benefits for the local area, including employment opportunities, increased use of local services and provision of new facilities that both current and future residents can utilise.

On-site provision of new retail and community space will provide retail and business space that complements the current economic assets in surrounding areas. Job opportunities will be created, and this will have positive knock-on impacts on the local economy.

The Proposed Development will contribute with up to 30% of affordable housing (subject to viability considerations), out of the 1,650 dwelling provided.

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Through the sustainable transport, energy, waste and materials procurement strategies paired with design principles that adhere to the energy hierarchy, the Proposed Development will encourage low carbon growth.

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4 Cultural Heritage

4.1 Introduction

This section covers the cultural and heritage assets within the site, considering the likely significant effects the Proposed Development may have upon below-ground archaeological heritage assets on and near the site.

A Cultural Heritage (Built Heritage and Archaeology) Chapter (Trium, 2020) and Built Heritage Statement (RPS Group, 2020) has been prepared as part of the ES and should be read in conjunction with this section.

4.2 Baseline Conditions

Archaeology

The geophysical surveying of the site and the archaeological field evaluation carried out on site revealed the presence of a prehistoric ring ditch, a further four prehistoric enclosures of probable ritual/mortuary function and a possible prehistoric settlement site is confirmed. Additionally, at least seven medieval rectilinear enclosures, three of which contained sunken feature buildings are identified. In addition to these features a moderate quantity of finds were recovered from 19 of the 35 evaluation trenches.

Two Scheduled Monuments lie south of the site boundary:

 Group of ring ditches 400yds (360m) NW of Great Brooks End Farm (Historic England (HE) Ref. 1004207); and

 Ring ditches and enclosures 500yds (450m) ESE of College Farm (HE ref.1005489).

Built Heritage

The site does not include any designated or non-designated built heritage assets. However, as shown there are two Conservation Areas, 42 statutorily Listed Buildings, and one locally listed Historic Park and garden within 1 km of the site’s boundary.

4.3 Mitigation Measures

During demolition and construction stages of the Proposed Development the following mitigation measures were envisioned:

 Implementation of a 'clean site' policy with the principal contractors and its subcontractors expected to maintain a tidy site;

 Implementation of a Dust Management Plan;

 Use of directional lighting fitted with cowls to avoid light spill and glare to surrounding areas;

 Use of modular construction which would reduce construction time on the application site; and

 Use of hoarding with external graphics rather than a plain finish.

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Following the measures described in Section 4.3.1. no further measures are required during construction of the Proposed Development. Mitigation measures arising from construction management process will suffice to lessen the effects of noise and dust during construction.

To reduce the impacts of the Proposed Development on the build heritage assets during the operational stages, the following mitigation measures are proposed:

 A sympathetic landscaping scheme and other embedded design and layout measures, such as a significant buffer and open green spaces, to reduce impacts to the setting of the two Scheduled Monuments;

 Controlling the density and height of proposed dwellings located closely to the Grade II listed Upper Gore End Farmhouse and Gore End Barn, and the non-designated Quex Park; and

 Where nationally significant archaeological remains are present within the site, these will be preserved in situ as part of the Proposed Development’s landscape and open space provision.

The Built Heritage Statement (RPS Group, 2020) concludes that, with the implementation of the measures outlined above, the Proposed Development is considered to have a low level of less-than-substantial harm upon Upper Gore End Farmhouse and Gore End Barn, a low level of impact on the significance of the non-designated Quex Park, and no harm on the significance of Great Brooksend Farmhouse (Grade II).

4.4 Summary

The Proposed development will take appropriate consideration of cultural and archaeological heritage assets located within the site and in close proximity in order to mitigate any significant effects that the new Proposed Development may incur.

The NPPF identifies the need for sustainable development, and states that where a proposed development will lead to less than substantial harm to a designated heritage asset, “this harm should be weighted against the public benefits of the proposal” (Paragraph 196). There is a need to weigh the impacts of the Proposed Development upon the built heritage against the overall benefits provided as outlined within this Sustainability Statement.

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5 Air Quality

5.1 Introduction

This section presents the current condition of the site in relation to air pollution and identifies sources of pollution that may be introduced during the construction and operation of the Proposed Development and measures that have been identified to mitigate potential adverse effects.

An Air Quality Chapter (Stantec, 2020) has been prepared as part of the ES and should be read in conjunction with this section. It is in line with Policy QD01 and QD02.

5.2 Existing Conditions

The site is bounded to the west and south by farmland and by an existing residential area to the east and north. The A28 Canterbury Road runs east to west through the site.

The Thanet Air Quality Management Area (AQMA) was declared by TDC in 2011 as a result of exceedances of the annual mean air quality objective (AQO) for nitrogen dioxide (NO2) and covers the urban area of Thanet. The AQMA borders the site to the north and east, with a small part of the northern extent of the site within the AQMA.

The AQ Chapter states that the study area does not contain any predicted exceedances of an EU Limit Values in the ‘current’ year (2017). As there are no Automatic Urban and Rural Network (AURN) monitoring sites located within the Study Area, no exceedances of the EU Limit Values have been measured.

Measured annual mean concentrations in 2018 were below the annual mean NO2 NAQO at all monitoring sites. Concentrations above the annual mean were measured from 2014 to 2017 at site located in The Square, Birchington. Automatic monitoring site at The Square, did not measure any exceedances of the 1-hour mean NO2 NAQO from 2014 to 2018. Furthermore, as all annual mean concentrations measured by diffusion tubes between 2014 and 2018 were below 60 μg/m3, it is unlikely that the 1-hour mean NAQO was exceeded at any of these locations either.

The results of the PM10 monitoring at automatic monitoring site at The Square site demonstrate no exceedances of either the annual mean or the 24-hour mean PM10 NAQO have been measured from 2014 to 2018. There is a weak trend of increasing concentrations at The Square site over this time period.

TDC has not undertaken any monitoring of PM2.5 concentrations within 1 km of the site.

5.3 Impacts on Air Quality

There are a number of existing sensitive human receptors located within 350 m of the site boundary and / or within 50 m of the routes that will be used by enabling and construction vehicles.

The construction traffic generated by the Proposed Development will pass either via Acol Hill, followed by Crispe Road then southwards along Canterbury Road (A28) or directly southwards from the site via Canterbury Road (A28). There are approximately 12 residential properties located within 20 m of roads which may be affected by trackout. However, the potential impacts as a result of construction vehicle movements are considered to be temporary, and will be managed by a Construction Environmental Management Plan (CEMP).

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The Proposed Development is anticipated to generate operational traffic flows above the EPUK / IAQM screening criteria. Emissions of pollutants (NO2, PM10 and PM2.5) from operational phase traffic generated by the Proposed Development will not cause further exceedances of the NAQOs, either within or outside the nearby AQMA, and impacts at worst- case existing sensitive locations will be ‘negligible’ according to the EPUK / IAQM guidance approach and ‘Low / Imperceptible’ according to the Kent and Medway Air Quality Planning Guidance approach.

The potential effects of emissions from the nearby railway lines have been screened out as ‘not significant’, and predicted concentrations of pollutants (NO2, PM10 and PM2.5) at worst- case sensitive locations within the Proposed Development will be well below the relevant NAQOs. As such, new residents and users of the Proposed Development will experience acceptable air quality.

5.4 Construction Mitigation Measures

In order to reduce the potential air pollutants arising from construction, the principle contractor will implement construction management practices during the construction phase, including:

 Watering of roads (dust suppression) within the construction site;

 Locating machinery and dust causing activities furthest from sensitive receptors where possible;

 Erect barriers and screens to prevent dust leaving the site;

 Ensure all on road vehicles comply with the London Low Emission Zone;

 Turn off vehicle engines when stationery;

 Only use cutting, grinding and sawing equipment with dust suppression equipment;

 Cover stockpiles of loose building materials such as sand and ballast; and

 Minimise drop heights for deliveries.

The approach to managing these impacts will be formed within a CEMP by the principal contractor. In line with TDC policy, these measures help to reduce emissions associated with the construction and operation of the Proposed Development and reduce the extent of air quality deterioration.

5.5 Operational Mitigation Measures

During operation, the main impacts on air quality are likely to be caused by vehicle emissions associated with travel to and from the site.

The proposed development has been designed to support the use of non-motorised forms of transport for employees, such as walking and cycling. By creating a development which encourages walking and cycling it can help reduce the number of vehicle trips generated and therefore the proposed developments impact on air quality.

The Air Quality Assessment (Stantec, 2020) demonstrates that the predicted pollutant concentrations within the site are below the relevant National Air Quality Objectives (NAQO). The site is therefore considered suitable for the proposed development without the need for specific mitigation in relation to air quality.

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5.6 Summary

An initial review of the current baseline situation of the site in regard to air pollution has been undertaken. Sources of air pollution arising from the Proposed Development have been identified. A number of potential mitigation measures have also been identified in relation to air pollution during the construction phase which could be implemented by the contractor through the provision of a Site Environmental Management Plan (or equivalent). This section demonstrates how AQ has been considered in line with Policy QD01.

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6 Biodiversity and Landscape

6.1 Introduction

This section considers how the Proposed Development aims to protect and enhance biodiversity on site by understanding the ecological nature of the site; identifying habitats and species which could be adversely impacted by the proposal; and appropriate mitigation measures.

A Biodiversity Chapter (Stantec, 2020) and a Landscape Chapter (ETLA Studio, 2020) have been prepared as part of the ES and should be read in conjunction with this section. It takes into account Policies QD02, SP26, SP27, SP30, SP34 and SP36.

6.2 Baseline Conditions

Biodiversity

The site is located within the wider landscape of the North Kent Plain National Character Area set in an open, gently undulating landform with fine loam soils over thin chalk deposits. The landscape is characterised by large arable/horticultural fields with regular patterns and rectangular shapes with a sparse hedgerow pattern and limited shelter-belt planting around settlements, farmsteads, orchards and horticultural crops. The site predominantly comprises a series of arable fields with narrow field margins.

The site is located within the Zone of Influence of a number of European Sites designated for Nature Conservation; including Thanet Coast & Sandwich Bay Special Protection Area (SPA) and RAMSAR; Sandwich Bay Special Area of Conservation (SAC); Outer Thames Estuary SPA; Thanet Coast Marine Conservation Zone (MCZ); and Thanet Coast Site of Special Scientific Interest (SSSI) are of which all located approximately 570 m to the north. There are no non-statutory sites within 2km of the Proposed Development.

The ecology & biodiversity baseline has been informed by desk study, Extended Phase 1 Habitat, and secondary specific-specific undertaken between 2016-2019. Baseline surveys have recorded the site as supporting the following habitat types of largely low ecological value, common in the local area, along with two native species-rich hedgerows. The presence of a number of protected/notable species/species groups, including wintering birds (including golden plover associated with the European Sites), breeding birds including species of conservation concern associated with farmland habitats and to a lesser extent foraging and communing bats, reptiles, botanical species.

Landscape

The site comprises an area of arable farmland on a south-west facing slope on the southern and western edges of the village of Birchington, on the . The site is a Strategic Site within the Thanet Local Plan 2020 and lies immediately adjacent to existing residential development at the edge of the village. This existing development forms the north-east boundary to the site. The other boundaries coincide with existing field boundaries, though not all of these are clearly demarcated on the ground. A railway line lies to the north of the site.

Landscape Character Area

Landscape character influences are provided by a combination of existing residential development immediately adjacent to the site and gently undulating open arable farmland to the south and west.

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Tree cover within the local area is generally limited to belts of trees surrounding farmsteads, with a higher proportion of woodland at Quex Park to the east of the site. There are a number of reservoirs to the south-west of the site, providing irrigation water, and a number of substantial glasshouses as part of Thanet Earth on the north-east facing side of the valley across from the site. The Wade Marshes lie to the west of the site, this area of land lies within the Lower Stour Wetlands Biodiversity Opportunity Area.

The site lies within National Character Area (NCA) 113: North Kent Plain. At the county-level the site lies within the Thanet Landscape Character Area (LCA. The LCA is considered to be in poor condition and of very high sensitivity.

At the district level the site lies within the Undulating Chalk Farmland Landscape Character Type (LCT), specifically the Central Thanet Undulating Chalk Farmland LCA. The Wade Marshes LCA, within the Marshes LCT, lies to the south-west of the site, and partially separates the Central Thanet Undulating Chalk Farmland LCA from the St Nicholas at Wade Undulating Chalk Farmland LCA and may also be considered in the LVIA where appropriate.

The Assessment of Local Landscape Character identifies that site lies outside of any national/statutory or local/non-statutory landscape designations, and is unlikely to be discernible in views from any such designations. There are no Conservation Areas within or adjoining the site. The site comprises actively managed arable farmland on the edge of Birchington, with an abrupt transition to the urban area. The very limited field boundary vegetation, combined with modern intensive agricultural practices and the proximity of the historically expanding settlement-edge of Birchington, the railway line to the north, and the A28 Canterbury Road crossing the site mean that the historic landscape pattern is no longer intact. The gently undulating topography of the site is not atypical for the local area and is therefore considered to be low value.

Landscape Designations

The site lies outside of any national/statutory or local/non-statutory landscape designations, nor are there any such designations within the environs of the Application Site.

Public Rights of Way (PRoWs)

There are three PRoWs which cross the site:

 Footpath TM37 runs from the corner of Devon Gardens and Essex Gardens north-west towards the western part of Birchington, crossing the railway via an unmanned pedestrian crossing;

 Footpath TM32 runs from the end of Mill Row south-west towards Great Brooksend Farm at Brooks End; and

 Footpath TM31 runs from Acol Hill Farm west towards Brooks End.

Public Highways

The site is crossed by three existing roads:

 A28 Canterbury Road;

 Park Lane; and

 Manston Road

It should be noted that the latter two roads only cross the north-eastern corner of the site.

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Visual

The western part of the site generally slopes from south to north (approx. 23m AOD down to 10m AOD). The eastern parcel slopes from east to west (approx. 32m AOD down to 24m AOD). As a result, the visual envelope extends predominantly to the south and west, with visibility restricted to the north and east by existing development within Birchington and tree cover in and around Quex Park respectively.

6.3 Potential Effects

As described in the Ecology ES Chapter (Stantec, 2020), Key Ecological Receptors have been identified. Of these European sites could potentially be affected as a result of construction and operations of the Proposed Development, namely Thanet Coast and Sandwich Bay SPA; Thanet Cost and Sandwich Ramsar; Outer Thames Estuary SPA; and Sandwich Bay SAC. Other Key Ecological Receptors include two native species-rich hedgerows, the overwintering population of golden plover located in functionally linked habitat associated with the SPA adjacent to the site, and the assemblage of breeding birds including farmland species of conservation concern.

Embedded and primary mitigation includes avoidance of major construction activities close to sensitive receptors, and measure to minimise effects including hoarding, structural planting, dog-proof fencing, provision of arable field margin habitat during the construction phase and measures within the CEMP. These measures will reduce the potential significant effects on ecology. Taking into account a series of primary and embedded mitigation measures, the potential effects considered in the Ecology & Biodiversity Chapter include:

 Loss of habitat due to disturbance and recreational pressure of Thanet Coast and Sandwich Bay SPA at the coastal and associated functionally linked habitats for golden plover;

 Loss of dune habitat due to recreational pressure for Sandwich Bay SAC;

 Loss of habitat due to disturbance and recreational pressure of Outer Thames Estuary SPA coastal habitats;

 Disturbance and recreational pressure on Thanet Coast SSS and Thanet Coast MCZ;

 Loss of parts of two native species-rich hedgerow identified as Habitats of Principal Importance;

 Loss of habitat and disturbance of over-wintering golden plover; and

 Loss of habitat for Breeding bird assemblage, including species of conservation concern associated specifically with open farmland habitats.

6.4 Mitigation Measures

The Ecology ES Chapter (Stantec, 2020) proposes mitigation measures for any significant effects that remain once embedded and primary mitigation is taking into account for both Construction and Operation stages of the Proposed development. These secondary ecological mitigation measures, such as the provision of a Landscape and Ecology Management Plan (LEMP) will further reduce the potential significant effects on ecology.

The mitigation measures for identified ecological impacts, which have been embedded within the Proposed Development, will reduce or remove identified operational impacts. These include, financial contribution to the Strategic Access Management and Monitoring SAMM Plan (to manage recreational pressure on the coastal European Sites), provision on site of

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public open space, linked circular footpaths and a range of measures to create a reliable alternative to daily dog walking activities, boundary treatment in the south-west of the site including bird hides and planting measures to provide visual screening.

In addition, habitat creation and species enhancement measures will be provided for policy and legislative compliance.

6.5 Summary

A range of surveys have been carried out to understand the ecological nature of the site and identify habitats and species which could be adversely impacted by the proposal. Due consideration has been given to the potential impacts of the development on biodiversity and a number of measures to protect and enhance existing habitats and species have been proposed. This addressed Policies QD02, SP26, SP27, SP30, SP34 and SP36.

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7 Waste Management & Materials

7.1 Introduction

This section will cover the management of waste arisings from the construction and operation of the Proposed Development, detailing how it will be managed in accordance with local and national policy. This section is in line with Policy QD01 of the TDC Local Plan 2031.

7.2 Waste Hierarchy

Waste arising from the construction and operation of the Proposed Development will be managed in accordance with local and national policy and guidance, and shall be managed in accordance with the waste hierarchy in Figure 7.1 in order to reduce the volume of material being sent to landfill and the negative environmental impacts associated with this method of disposal.

Figure 7.1: Waste Hierarchy

During the construction process and the occupation of the development, the waste strategy should follow the principles of the waste hierarchy – “eliminate, reduce, reuse and recycle” – to minimise waste sent to landfill and to ensure that the environmental, social and economic risks from waste are minimised and, where possible, turned into opportunities.

7.3 Construction Waste

The hierarchy of waste management will be adopted, in accordance with national and local policy requirements. The waste management methods in order of preference are as follows:

 Waste Prevention – Through good design and procurement mechanisms.

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 Preparation for Reuse – To provide design features to the Project to use materials in their current state and form, this can occur either on or off site.

 Material Recovery – By using waste materials found on site and recycling / recovering them into an alternative form that can be used for construction purposes.

 Other Recovery – Energy recovery from biodegradable or combustible materials.

 Disposal – The least preferred option where the waste stream would be subject to a final disposal route, such as landfill

In accordance with the above objective, the Proposed Development should adhere to sustainable waste management principles with the objective of reducing and recycling materials either on or off site as far as practicable

Recycled and Responsibly Sourced Materials

Materials that reduce the use of resources and come from sustainable sources will be used where appropriate in order to reduce the environmental impact of the proposed development.

Low impact building materials are extremely important for implementing a sustainable development.

Building materials could be procured through the development partners’ sustainable supply chain framework. A sustainable supply chain framework relates to the procurement of materials from 3rd party suppliers with environmental certification. This framework would be prepared and adopted by the future developer prior to the construction phase.

The framework could include a range of materials covered by a range of certification standards such as:

 FSC or PEFC for timber;

 ISO 14001 Environmental Management Systems; and

 BES 6001 for quarried products such as bricks and concrete.

In addition, policies will be specified to procure materials locally where possible. All timber and other materials such as window units, bricks, aggregate and minerals will be legally sourced, and a significant proportion will come from sustainable sources.

7.4 Specification of Materials

Materials that reduce the use of resources, are from sustainable sources and that provide a healthy environment for users of the buildings should be used where appropriate in order to reduce the environmental impact of the proposed development.

To sustainably source products one must:

 Know how to procure and identify responsibly sourced materials (FSC/PEFC and responsibly sourced products e.g. BES6001) and healthy materials (e.g. low VOC products);

 Gain information on a wide range of commonly used building materials and their associated environmental profiles which are based on factors such as climate change, mineral extraction and waste disposal;

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 Understand the principles of embodied carbon and other issues such as resource depletion, reuse and recycling potential waste; and

 Understand the principles of the circular economy.

The industry is moving towards the use of Life Cycle Assessment (LCA) in order to understand the environmental impacts from construction products and materials.

LCA is used to appraise a range of different design options with the aim of improving the construction product related environmental performance of the building. The results of the LCA are presented in an environmental product declaration (EPD) in order to provide the cases for assessing buildings and identify those which cause less stress to the environment.

The proposed development at Birchington could use, at an early design stage, the LCA tool to identify what are the most sustainable materials suitable for the proposed development.

Materials used should be responsibly sourced in accordance with any national and local policy such as the UK Government’s Timber Procurement Policy.

Where appropriate local suppliers should be used in order to reduce emissions relating to the transportation of materials and equipment to and from site.

7.5 Construction Waste Management

During the construction process and the occupation of the development, the waste strategy should follow the principles of the waste hierarchy – “eliminate, reduce, reuse and recycle” – to reduce waste sent to landfill and to allow that the environmental, social and economic risks from waste are reduced and, where possible, turned into opportunities.

The principal contractor will be charged with responsibility for the management and coordination of all waste streams during each stage of the construction of the houses.

In order to facilitate this a Site Waste Management Plan (SWMP) could be prepared post planning, prior to construction. This would ensure waste is reduced and managed in accordance with the ‘waste hierarchy’. The waste hierarchy underpins all waste management policy in the UK.

The production of a SWMP is no longer a legal obligation but is still considered to be best practice and valuable to both the environment and the development. The future developer should register the site as part of the Considerate Constructors Scheme.

The SWMP will highlight the commitments and targets the design team must deliver, to ensure waste arisings are reduced and that site activities are compliant with legislative requirements.

The preparation of a SWMP is still considered important to ensure that building materials are managed efficiently; waste is disposed of legally, fly tipping is reduced; and materials reuse, recovery and recycling is increased.

The key to good on-site waste minimisation and legal compliance management is to develop a flexible Construction Environmental Management Plan (CEMP). An CEMP would be developed for this site and would inform later construction phase CEMP(s). The CEMP(s) would allow the Principal Contractor to use a toolbox of information to manage a wide set of environmental requirements including waste legal compliance. A construction phase SWMP can form part of a construction phase CEMP document.

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As part of the CEMP, a Resource Management Plan (RMP) could be developed covering the non-hazardous waste related to on-site construction and dedicated off-site manufacture or fabrication generated by the buildings design and construction.

Potential construction waste generation can also be designed-out through good design practices or via off-site fabrication. In addition, the use of materials with some form of recycled content would help reduce the net waste generation in the project.

7.6 Operational Waste

The Proposed Development will provide sufficient measures for the storage of waste, including recycling waste bins, which are integrated into the scheme in order to minimise visual impact. The waste storage requirements will align with TDC collection practices. This will be developed further during the design stages.

7.7 Summary

The Proposed Development will aim to incorporate sustainably sourced material in line with national and local policy and, where appropriate, will utilise adequate speciation to reduce the environmental impacts of the development.

Waste generated through the construction process will be reduced and managed in accordance with the waste hierarchy. A SWMP could be developed, prior to construction, to promote effective management of construction waste.

Operational waste will be managed is accordance to TDC collection practices. Appropriate internal and external storage will be provided to facilitate moving waste up the waste hierarchy. The development’s road layout will allow for appropriate access and servicing by TDC’s waste collection team.

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8 Water Management

8.1 Introduction

This section focuses on the efficient management of water resources. There is need for developments to be more water efficient and limit their water demand. Water consumption can be reduced through installing water efficient features in dwellings and incorporating green infrastructure which can survive on precipitation alone.

A Flood Risk Assessment (FRA) and Outline Surface Water and Foul Sewage Drainage Strategy (Stantec, 2020) has been prepared for the proposed development and should be read in conjunction with this Statement.

8.2 Water Conservation Strategy

Reducing Water Consumption During Construction

During the construction phase of the development measures should be incorporated to reduce the demand for water on site in line with the recommended Waste & Resource Action Program (WRAP) water efficiency construction measures. These may include:

 Collecting and storing rainwater on site for use instead of mains water;

 Using water efficient equipment on site; and

 Preventing problems arising that may need water use to control e.g. minimise dust emissions to reduce the need for dampening down surfaces.

Reducing Internal Potable Water Consumption

The development will be designed to reduce mains water usage following to Building Regulations Part G requirements. This involves the potential water consumption by residents living in new dwellings should not exceed 110 litres per person per day.

A range of water saving measures will be employed to reduce water demand, this may include the following:

 Flow restrictors to reduce the flow rate of kitchen sink and bathroom basin taps;

 Low-flow showers;

 Small capacity baths;

 Dual-flush toilets with appropriate controls;

 Water efficient appliances such as dishwashers and washing machines (where provided);

 Leak detection systems to notify facilities teams of any leaks;

 Pulsed water meters to allow users to actively monitor consumption;

 Installation of solenoid valves to automatically turn of the water when the area is not occupied; and

 Water harvesting for irrigation purposes, such as rainwater butts on individual properties.

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Landscaping

The landscape comprises approximately 27.1 ha of open space. A network of landscape corridors and neighbourhood greens are proposed which will provide a range of functions, including providing attractive routes for pedestrian and cycling movement, recreational and educational space, and habitat for biodiversity to flourish. The landscaping will also provide opportunities for the incorporation of Sustainable Urban Drainage Systems,

The landscaping proposals include the creation of a band of green infrastructure, including woodlands, grasslands, orchards, play areas and walking and cycling routes. In addition to the health and wellbeing and biodiversity benefits, these proposals will assist in the water management regime by provided unsealed surfaces in which rainwater can be captured and soak away, reducing run-off rates and reducing the impact of diffuse pollution.

The proposed seasonal wetland basins strategically placed throughout the Site can support the established drainage networks during periods of heavier rainfall during the winter months. These basins have been designed to provide sufficient surface water storage up to and including the 1 in 100 (1%) Annual Probability plus 40% climate change event. These multipurpose open spaces are seamlessly embedded within the masterplan design.

8.3 Flood Risk

Baseline Conditions

The online flood map for the area shows that the site is located within Flood Zone 1 (less than 0.1% chance of flooding in any year, a 1 in 1,000-year chance of flooding) and therefore is at low risk from flooding from fluvial and tidal sources.

The online Risk of Flooding from Surface Water map shows much of the site is considered as being at a ‘Very Low’ susceptibility to surface water flooding. This is defined as having less than a 1 in 1000 (0.1%) chance of flooding.

There is an existing surface water flow path located within the northwest corner of the site and flows along the north and east of the site. This flow path is considered as being at a ‘Low’ and ‘High’ susceptibility to surface water flooding. A ‘High’ susceptibility to surface water flooding is defined as having greater than a 1 in 30 (3.3%) chance of flooding. The online maps indicate that flood depths may exceed 900mm in the northwest corner of the site.

There is an area located along the southern boundary of the site which is considered as being at a ‘Low’ susceptibility to surface water flooding. This is defined as having between a 1 in 1000 and 1 in 100 (0.1% - 1%) chance of flooding. Flood depths may range from 300mm to 900mm in this area. A review of OS mapping suggests that this area of surface water risk is associated with the network of land drains located to the south of the site and therefore, it is likely this represents the floodplain associated with these watercourses.

The online Risk of Flooding from Reservoirs Map indicates the risk of flooding in the event of a breach from reservoirs, based only on large reservoirs (over 25,000 cubic metres of water). The maps indicate that the site is not located within an area which is considered at risk in the event of a reservoir breach.

The Thanet District Council Strategic Flood Risk Assessment (SFRA) states that groundwater flooding is not considered to be of strategic concern and that groundwater is generally at significant depths below the ground surface.

There are no historic British Geological Society (BGS) boreholes located within the vicinity of the site. However, the intrusive ground investigations already undertaken at the site indicate that no groundwater was encountered at the time of the investigation.

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Correspondence with the Lead Local Flood Authority (LLFA) (Thanet District Council) has confirmed that there are recorded incidents of flooding in the vicinity of the site, located along Devon Gardens, Essex Gardens (located towards to the east of the site adjacent to the A28) and along Gordon Square and Minnis Road (located within the northern corner of the site). Most of these incidences are attributed to highways flooding, with the incidences at Minnis Road attributed to constriction of surface water flows by the railway bridge.

Drainage

There are no known surface water drainage features or water bodies at the site.

A review of Ordnance Survey (OS) maps show Brooksend Stream is located approximately 450m to the southwest of the site and flows in a north west direction. There are a series of land drains located within agricultural land also located to the south of the site. OS mapping indicates that these land drains are in hydraulic connectivity with Brooksend Stream. OS mapping also show the presence of several reservoirs approximately 450m south of the site.

There are no surface water sewers within the site or its vicinity. The asset plans from Southern Water do not show any surface water sewers within the general location of the site.

A review of Southern Water asset plans shows there is a 250mm diameter foul rising main located within the northern corner of the site, and a 225mm diameter foul sewer located within the southeast corner of the site. There is also a pumping station located within the northern corner of the site.

8.4 Adaptation and Mitigation to Flood Risk

The site drainage design will need to consider the impacts of climate change over the lifetime of the development and will need to ensure that surface water flows can be attenuated up to the 1 in 100 year plus climate change flows.

The SUDs soakaway system is designed to attenuate a 1 in 100-year storm event plus a 40% allowance for climate change without flooding and will be retained within the site development boundaries.

Finished floor levels to new housing will be elevated above exceedance routes for overland flows. Fences, walls and other potential obstructions would make provision to allow exceedance flows to continue above the ground unhindered during extreme rainfall events.

8.5 Drainage Strategy

The following drainage infrastructure is proposed:

 Separate foul and surface water systems within the site boundary;

 Foul water to be discharged into the adopted Thames Water Public Sewer local to the site boundary;

 Surface water to incorporate Sustainable Urban Drainage System (SUDs) measures.

It is recommended that “source control” SUDS techniques (dealing with water when and where it falls) are installed across the Proposed Development, including rainwater harvesting, followed by conveyance control (routing water from impermeable areas towards discharge controls) and discharge controls (management of runoff from site before discharging to watercourses).

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The ground permeability at the site is suitable for the use of SUDS infiltration systems and therefore soakaways and swales would be the preferred surface water runoff discharge method at this site.

The drive parking areas to the front of the properties will have permeable paving, which will allow surface water to percolate through to the clean stone sub-base where it can be stored and discharge through pipes to the sewer.

8.6 Climate Change Adaptation

The proposed development will incorporate design features that plan for and adapt to anticipated levels of climate change. This will include consideration of the climate within proposed surface water drainage design for the site (which are designed to accommodate climate change as part of the surface water attenuation proposals, designed in accordance with the Lead Local Flood Authority (LLFA) requirements), the landscaping strategy and building design.

8.7 Summary

Water consumption targets have been identified in line with the Building Regulations Part G requirements. The proposed development at Birchington-on-Sea will aim to reduce water consumption to a maximum 110 litres per person per day through water reduction measures.

A number of measures have been identified to increase the water efficiency of the development and help reduce pressure on local water resources. The landscaping strategy will consider potential impacts of climate change and will incorporate species that rely on seasonal precipitation.

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9 Transport

9.1 Introduction

This section describes the suitable infrastructure and measures needed to support and promote walking, cycling and public transport, as these are integral to creating a sustainable development. The Proposed Development aims to contribute towards sustainable transport objectives set in Policy SP43 and QD02 from TDC’s Local Plan 2031.

A Transport Assessment (TPA, 2020) has been prepared detailing how the Proposed Development is designed to promote sustainable transport. This document should be read in conjunction with this section.

9.2 Baseline Conditions

The site is located on the south-western edge of Birchington-on-Sea and is dived into two parcels by the A28 Canterbury Road. The site is located within 1km of Station Road, which functions as the village centre providing a range services and facilities. In addition, the Station Road / A28 Canterbury Road mini-roundabout forms the focal point of the transport and road network within the village. At the southeast of the site is Quex Park, which is a 250-acre area of parkland, the Powell-Cotton Museum, the Waterloo Tower and a range of leisure and tourist attractions.

Accessibility for Pedestrian and Cyclists

Birchington-on-Sea has a network of continuous and lit footways throughout the village providing residents with the opportunity to walking to local services and amenities. There are no formal crossing points along the site frontages; however, a number of informal crossings can be found within the local vicinity. Most crossing points benefit from either tactile paving or dropped kerbs. There are a range of pedestrian facilities within Birchington-on-Sea, providing safe passage through the village for pedestrians and helping to connect local services and residential dwellings.

In addition, a number PRoW’s and cycleways accessible in and around Birchington-on-Sea, providing local connections throughout the local area. In particular, a continuous cycle path provides a link starting from a point circa 50m west of the Brooksend Service Station on Canterbury Road (the A28) to the local employment opportunities at Manston Airfield, Columbus Avenue, and Thanet Earth. The local access to Viking Coastal Trail and the presence of cycle parking facilities within the village provides opportunities for residents to travel around the district on bicycle.

Public Transport

The site currently has good access to public transport services with a range of bus services available within the vicinity of the site. The bus services through Birchington-on-Sea are consistent with other villages of similar sizes, including Canterbury, and . The majority of local bus services are operated by Stagecoach South East. There are nine bus stops located in close proximity of the site and are considered key to the accessibility of the site. The site also benefits from access to long distance coach services towards London and Ramsgate (bus services for route 22).

Birchington-on-Sea also benefits from having its own Railway Station, which is located around 300m from the site, to northern edge of the village centre along Station Road. The station is situated on the Chatham Main Line which runs between London and Ramsgate. The station provides services to local and regional destinations including: London Victoria, London St. Pancras, Chatham, Ebbsfleet, Ashford, Margate, Ramsgate, Dover, and Deal.

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Vehicular Access

Within Birchington-on-Sea, the link road will consist of connecting Minnis Road with Canterbury Road and connecting Canterbury Road with Manston Road with the aim of reducing traffic delay at the Station Road / Canterbury Road mini-roundabout in the centre of the village.

9.3 Measures

This section highlights the measures proposed within the Transport Framework Plan so to be considered for the future of Travel Plans. These include:

 Introduce and implement a communal noticeboard to display relevant travel information such as green travel initiatives and relevant public transport timetables;

 Provide new footways, footpaths and crossing points to provide access throughout the site and to the existing pedestrian networks, within Birchington-on-Sea;

 Advertise and provide plans showing the local walking routes within Birchington-on-Sea and Minnis Bay;

 Provide shared surface foot and cycleway along link road and new Quex to Coast cycle route to connect the Site to the existing National Cycle Route accessible from Minnis Bay;

 Provide details and plans showing the location of, and routes of the local cycle network and any key services along the routes, safe cycling corridors and local events such as ‘bike week’ through information provided at the Communal Noticeboard and in the Travel Information Packs. ;

 Provide cycle parking in line with the Standards outlined in the Thanet Local Plan;

 Divert the some of the local bus services (routes 34 and 48) through the site, to provide residents with access to bus services;

 Provide plans showing the location of, and distance to the nearest bus stops and railway stations in relation to the site and the services that are provided by each. Promote the use of public transport at the Communal Noticeboard;

 Provide information on how car sharing works, who can take part, a list of how obstacles (such as the need to drop children off at school or safety concerns) can be overcome and advertise the benefits that can be gained through car sharing;

 Review the viability of providing a car club spaces within the local area; and

 Ensure that all buildings, including the residential dwellings, the office, school and care home are provided with broadband ports, which can facilitate homeworking, online grocery shopping and online journey planning. This will help reduce reliance on private vehicle and reduce the need for travel.

9.4 Electric Vehicles

In line with Policy SP14, the Proposed Development will provide charging points as per local requirements. The provision of EV charging points that has been envisioned involves 1 charging point for every 10 spaces in communal areas or 1 point for every new dwelling with parking provision within its curtilage. The uptake of EV by future users of the Proposed Development will help to reduce the GHG emissions associated with transport.

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9.5 Summary

The proposed development aims to encourage the use of more sustainable modes of transport by integrating with, and enhancing, existing routes to improve the accessibility of the surrounding area for existing local residents and future site users. The detail of the cycle and pedestrian provision within the site will be developed with key stakeholders and consultees through the planning process.

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10 Energy and Climate Change

10.1 Introduction

This section covers how the Proposed Development will aim to improve the energy efficiency of buildings, reducing energy demands and incorporating renewable energy technologies are key practices, which can improve the sustainability of a development by reducing the volume of carbon dioxide (CO2) emitted and its associated contribution to climate change.

The main energy requirement for the Proposed Development will be compliance with Building Regulations Part L (subject to changes in national requirements); incorporating measures to reduce energy use and supply energy efficiently in line with the national energy hierarchy; securing the proposed development’s expected energy demand from decentralised energy sources, in accordance with TDC’s Local Plan 2031 Policies SP37, CC04, and CC05. In particular, Policy QD01 requires all new developments to “achieve a high standard of energy efficiency to the equivalent of Level 4 of the Code for Sustainable Homes.” Given the Code has been withdrawn, Code Level 4 is equivalent to a 19% improvement over Part L 2013.

A Greenhouse Gas Assessment (Stantec, 2020) and an Outline Energy Statement (Stantec, 2020) have been prepared and should be read in conjunction with this section.

10.2 Energy Strategy

The Proposed Development will adopt the nationally and locally recognised energy hierarchy (Figure 10.1) of reducing energy demand in the first instance, using energy efficiently and, only then, providing renewable and low carbon energy generation technologies where it is appropriate to do so.

Figure 10.1 The energy hierarchy in new development

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The Energy Statement considers the anticipated shift towards electric-led heating strategies (rather than gas) in the coming years. It is assumed that the development will be electric led from 2025; earlier phases may still utilise gas heating. The heating fuel for each phase should be reassessed at the RMA stage to ensure it aligns with national regulations and to offer the most sustainable solution.

Projected decarbonisation of the National Grid and the use of electrical heating technologies after 2025 shows that CO2 emissions arising from the Proposed Development are expected to decrease by circa 54% within the predicted scenario compared to the baseline of Part L 2013. This is in line with the Future Homes Standard expectation of carbon emission reductions over the next decade.

10.3 Design Principles to Reduce Energy Demand

There are a series of design principles that can be adopted in masterplans to passively reduce the energy demands of a development.

The Proposed Development is set within is a comprehensive green infrastructure network with significant areas of open space. Open spaces provides evaporative cooling at night, helping to reduce the heat island effect1. The permeability of green spaces throughout the Proposed Development, as well as the selection of plot layout and building location, will help to facilitate air movement and enhance natural ventilation. The retention and creation of vegetation and tree planted areas will help provide shading and local cooling of the microclimate.

In accordance with the energy hierarchy, the Proposed Development will seek to adopt a “fabric-first” approach to building design (enhancing the performance of the components and materials that make up the building fabric itself, such as improving insulation and reducing cold bridging).

Passive Measures

The following ‘passive’ design measures will be considered in the detailed design of buildings to reduce energy requirements:

 Designing the external fabric (walls, floors and roofs) to have low U-values2 to reduce thermal heat loss (i.e. by providing high efficiency insulation);

 Reducing the air permeability and thermal bridging coefficient of the building envelope to the lowest practical level to reduce uncontrolled heat loss;

 Incorporating building materials with high (and, where appropriate, exposed) thermal mass to help keep the internal building temperatures stable;

 Providing larger windows on south-facing aspects, where appropriate in the context of wider design considerations (such as residents’ amenity), to allow natural daylighting and passive solar gains;

 Locating plant rooms away from southern elevations to avoid excessive heat gain and to encourage higher plant efficiency; and

1 The term ‘heat island’ describes built up areas that are hotter than nearby rural areas. This is partly caused by the replacement of natural surface by built surfaces, which absorb a higher proportion of incident radiation, which is then released as heat. 2 U values, otherwise known as thermal transmittance values, measure the thermal performance of a building fabric in terms of heat loss. The better insulated a structure is, the lower the U-value will be.

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 Using architectural features that deflect sunlight to reduce excess heat gain in buildings (e.g. brise soleil and blinds).

Active Measures

The following ‘active’ design measures will be considered in the mechanical and electrical elements of the buildings:

 Using Mechanical Ventilation with Heat Recovery (MVHR) systems where appropriate;

 Adopting water efficiency measures such as leak detection systems, flow control devices and pulsed water meters, to reduce the energy demands associated with water heating;

 Using controls to optimise and compensate for heating variations;

 Using zonal heating controls (e.g. through the use of Building Management Systems, BMS, where appropriate);

 Fitting variable speed drives fitted to appropriate pumps and fans to allow greater control of energy-consuming equipment;

 Installing 100% low energy lighting and using lighting-efficiency systems (e.g. daylight cut-off and Passive Infra-Red, PIR, lights);

 Selecting highly efficient white goods for any kitchen or welfare areas;

 Installing energy display devices to promote user behavioural change;

 Issuing residents with a Home User Guide that contains manuals for fitted appliances to promote and encourage user behavioural change; similar Building User Guides should be provided to non-domestic uses such as the school; and

 Complying with Chartered Institution of Building Services Engineers (CIBSE) commissioning requirements, with training provided to any facilities management teams and building operatives.

10.4 On Site Renewable Energy Generation

There are several ‘multi-plot’ renewable/ low carbon energy generation solutions that should be explored further as the scheme progresses. A battery project could potentially be deployed to reduce peak electrical demands and support an electric led heating approach after 2025. Furthermore, centralised electric air/ ground source heat pumps could potentially be suitable for later electric phases (particularly where/ if higher density flatted development is provided and for non-domestic uses such as the medical centre and care homes).

In accordance with Policy CC05 ‘District Heating’, a preliminary assessment of district heating feasibility has been undertaken. There are no known established district heat networks (DHN) in the immediate vicinity of the Site. A site-wide district heat network is not deemed appropriate given the low density of development and resulting anticipated heat losses. Gas CHP and biomass district heating are not deemed feasible.

There is also a ‘suite’ of ‘building-specific’ technologies that could potentially be deployed at the Proposed Development. At this stage, the most suitable technologies are anticipated to be roof-mounted photovoltaic solar panels (PV), solar water heating systems (or solar thermal) and heat recovery technologies (e.g. wastewater and air heat recovery). Air source heat pumps are likely to feature prominently in any electric led heating strategy from 2025.

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Opportunities for incorporating emerging technologies to actively manage the generation and use of energy, including active network management and broader ‘smart’ energy concepts have been considered. Several solar PV developments have also been identified within 10 km of the Site, which could potentially be connected to for a ‘smart grid’ approach.

10.5 Climate Change

The Greenhouse Gas Assessment (Stantec, 2020) estimated a total of 542.3 ktCO2 arising Thanet’s domestic, transport, industry and commercial sectors (Scope 2 emissions).

The current and future UK Carbon Budgets are set out below in Table 10.1. The carbon budgets are legally binding and UK GHG emissions will need to be reduced to meet them.

Table 10.1 UK Carbon Budgets for 2018-2032

Budget Carbon budget level Reduction below 1990 levels 3rd carbon budget (2018 to 2,544 MtCO2e 37% by 2020 2022) 4th carbon budget (2023 to 1,950 MtCO2e 51% by 2025 2027) 5th carbon budget (2028 to 1,725 MtCO2e 57% by 2030 2032)

The Proposed development has been designed with different characteristics which aim to mitigate the effects of climate change. Some of these measures include:

 Several pedestrian and cycle routes connecting the Proposed Development internally and to the surrounding area;

 Provision of EV charging points with 1 charging point for every 10 spaces in communal areas or 1 point for every new dwelling with parking provision within its curtilage. The uptake of EV by future users of the Proposed Development will help to reduce the GHG emissions associated with transport;

 Adopted a “fabric-first” approach to building design (enhancing the performance of the components and materials that make up the building fabric itself, such as improving insulation and reducing cold bridging), before considering the use of mechanical or electrical services systems and renewable.

 Retained green infrastructure around Birchington Medical Centre, Pocket park, nature and heritage park and introduction of tree planting;

 Target the higher water efficiency standard outlined in Building Regulations Part G, which is 110 litres/person/day; and

 Provide sufficient space and capacity, in accordance with national and TDC policy, for recycling storage and collection.

Construction

The main sources of direct GHG emissions during construction relate to the burning of fossil fuels during the transportation of building materials and waste by HGVs to and from the Site. Further sources of GHG emissions include the burning of fossil fuels on Site to power the plant engines and equipment.

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Construction of the Proposed Development will cause an increase in indirect GHG emissions such as embodied carbon and emissions from waste. It is noted that large proportion of GHG emissions from a development may be accounted for within Scope 3 embodied carbon.

The embodied carbon associated with the Proposed Development will be heavily influenced by the type and amount of material required to construct the Proposed Development. Extraction and production processes can be carbon intensive, particularly for materials such as concrete. It is noted that the embodied carbon associated with the Proposed Development is also heavily influenced by available materials and supply chains in the local and wider areas. In addition, construction waste will need to be treated, either through landfill or recycling methods. This will result in GHG emissions, although these will inevitably be in the control of the organisation that manages these processes.

Overall, the residual effect of the Proposed Development on climate change during construction remains as minor adverse, which is considered to be significant.

Operation

The GHG Assessment (Stantec, 2020) estimated total Scope 1 and Scope 2 GHG emissions arising during operation of the Proposed Development is 22,613 tCO2e/year.

Overall, the residual effect of the Proposed Development on climate change during operation remains as minor adverse, which is considered to be significant

Further mitigation measures have been proposed to address the GHG emissions arising from both construction and operation stages of the Proposed Development include:

 Prepare and implement a Construction Environmental Management Plan (CEMP) during construction stage of the Proposed Development;

 Develop and adhere to both a Materials Management Plan (MMP) and a Sustainable Procurement Plan (SPP) during construction of the Proposed Development;

 Install renewable and low carbon technologies as identified within the Energy Statement. These technologies would reduce the GHG emissions associated with energy use during operation of the Proposed Development;

 Reduce water demand and increase water efficiency in line with Building Regulations Part G to provide GHG emissions savings during operation of the Proposed Development; and

 Implement the Landscape Ecological Management Plan (LEMP) to retain and enhance habitats. The LEMP sets out measures for ongoing management, maintenance and monitoring of habitats on site, which would consequently increase the potential for carbon sequestration.

10.6 Summary

This section summarises how the Proposed Development is likely to impact climate change based on its potential to emit GHG emissions by estimating that Scope 1 and Scope 2 emissions emitted during the construction and operation of the Proposed Development. It also summarises the integrated approach to low carbon design principles and considers opportunities for energy efficiency in site layout, building design and contribution to CO2 reduction from decentralised and low carbon and/or renewable technologies.

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A series of design principles could be adopted within the masterplan to passively reduce the energy demand of the development. A combination of passive and active measures have been proposed.

This section proposed several mitigation measures to aggress GHG emissions arising from the construction and operation of the development. These include the provision of cycle and pedestrian routes, energy efficiency measures and green infrastructure, along with further mitigation that will be brought forward at detailed design.

The most suitable onsite renewable energy technologies identified for the Proposed Development included roof-mounted photovoltaic solar panels (PV), solar water heating systems (or solar thermal) and heat recovery technologies (e.g. wastewater and air heat recovery). These have been considered in the future in order to meet renewable energy targets in line with Policies SP37, CC04, CC05 of TDC’s Local Plan 2031.

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11 Summary

Stantec UK Limited (Stantec) has been appointed by Ptarmigan Land (the ‘Client’) to prepare a Sustainability Statement (the ‘Statement’) to support an outline planning application for a residential led development at south-west Birchington-on-Sea, Kent (herein the ‘proposed development’).

Ptarmigan Land is submitting an outline planning application for a Proposed Development that will comprise of

 Up to 1,650 homes;

 A 2-Form Entry (2FE) primary school – approximately 20,510 sqm;

 A retirement home – approximately 5,750 sqm;

 Land for the expansion of Birchington medical centre – approximately 970 sqm;

 Convenience retail provision (i.e. shop, co-working and café space) and community space – approximately 4,020 sqm;

 Strategic open space and landscaping including the provision for sustainable drainage systems (SuDS); and

 Supporting transport and utility infrastructure including creation of a new link road between Minnis Road and the A28 and the A28 and B2050 Manston Road.

This Sustainability Statement demonstrates that the proposed development meets a range of local sustainability objectives, as defined by TDC’s Local Plan 2031. The proposed development will be characterised by the following design features and objectives:

 Optimise energy demand where possible, through using the nationally recognised energy hierarchy principles, and through masterplan design principles including orientation of buildings and the incorporation of open spaces;

 Potential to provide a proportion of the development’s energy supply by employing low carbon and renewable energy sources such as solar PV panels following a review at the detailed design stage;

 Provision of a water conservation strategy to outline measures which could be included within the proposed development to help achieve the per capita consumption of potable water target;

 Manage flood risk by incorporating SuDS to help manage surface water, and by identifying design features which may be included to increase the resilience of the development to impacts from flooding;

 Appropriate management of construction waste by incorporating sustainably source material and implementation of a SWMP and managing operational waste in line with TDC waste collection requirements;

 Protecting local air quality, by providing mitigation measures to limit potential polluting effects across the construction and operational phases;

 Maintain the landscape and cultural setting of the area by mitigating and enhancing the existing character of the development;

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 Promote sustainable travel modes (including walking, cycling and public transport) as an alternative to private car use by providing routes which are safe and accessible, and providing secure cycle storage facilities in line with local guidance; and

 Retain, enhance and create new habitats to preserve the ecological setting of the site, through a number of measures including water attenuation, native tree planting.

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Appendix A Parameter Plans

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Ejector Station Minnis Road Alpha Road

Station Road

Rutland Gardens

Kent Gardens

All Saints Church

Devon Gardens Lancaster Gardens Park Road

Essex Gardens

Mill Row LAND USES

C3 dwelling houses including access roads, private garden space, car parking areas,

Track incidental open space and landscaping, children's play areas and Sustainable Drainage Park Avenue Systems (SuDS) Mixed-use community hub (C3, E, F1 & F2)

F1 two-form primary school site (2.05 Ha) King Edward RoadQuex View Road Broadley Avenue Quex Park C2 residential institutions A28 Canterbury Road

Potential expansion for Birchington Medical Centre car parking

Strategic link road corridor Brunswick Road Lane Park

Existing highway road infrastructure

Green infrastructure including strategic public open space and associated facilities, sustainable drainage, public art, secondary access roads, dog proof fencing, a potential skate park, and children's play spaces

Application boundary 78.35 Ha

0 metres 250 N Manston Road (1:5,000)

Project South West Birchington-on-Sea

Drawing Title Land Use Parameter Plan Acol Hill

Date Scale Drawn by Check by 04/09/2020 1:5,000 at A2 ML/RNM SR

Project No Drawing No Revision 1009 020C J

Mosaic Sustainability Statement Birchington-on-Sea, Kent

Appendix B Pre-application Consultation between Stantec, Barton Willmore and TDC

\\cbh-vfil-001\cbh\Projects\39862 Birchington\Energy and Sustainability\Sustainability\39862 - 3022 Birchington Sustainability Statement 09112020.docx From: Cottey, Roxanne To: [email protected] Subject: Birchington-on-Sea Sustainability Statement Date: 09 December 2019 09:55:00 Attachments: image001.png

Good morning Iain,

I’m contacting you regarding the proposed developments at Birchington-on-Sea.

We are preparing the Sustainability Statement to support the application, and would be very grateful if you could confirm the policies that we should be addressing in Thanet District Council’s Local Plan 2006 and emerging Local Plan 2031.

From the Local Plan 2006, we are proposing to respond to:

Policy D1 – Design Principles

From the emerging Local Plan 2031, we are proposing to respond to:

Policy 35 – Climate Change Policy QD01 – Sustainable Design Policy QD02 – General Design Principles

Additionally, the Sustainability Statement will cover several technical disciplines such as energy, transport, water, ecology, air quality and noise. Through these sections we will also be addressing:

Policy SP27 Biodiversity and Geodiversity Assets Policy SP31 Provision of Accessible Natural and Semi Natural Green Space Policy SP41 Safe and Sustainable Travel Policy CC01 Fluvial and Tidal Flooding Policy CC02 Surface Water Management Policy CC05 District Heating Policy SE05 Air Quality Policy SE06 Noise Pollution

Please let me know if there are any additional policies that should be addressed in the Sustainability Statement, or any other comments you may have.

Many thanks, and I look forward to hearing from you. Kind regards, Roxanne Cottey Graduate Environmental Planner Direct: 01189 520244 [email protected] http://www.stantec.com/uk

PBA has joined the Stantec family, find out more at peterbrett.com.

From: Soderberg, Asa To: Dinnage, Caroline; Dray, Michael; Cottey, Roxanne Cc: Ainslee Burley; Joshua Mellor Subject: FW: Birchington - Outstanding matters Date: 24 February 2020 14:26:12 Attachments: image007.jpg image001.png image002.png image003.png image006.jpg image008.png SW Birchington EIA Scoping Opinion - Conference Call .msg FW Birchington-on-Sea Sustainability Statement.msg Birchington.msg image009.png image016.png image017.png image018.png image019.png image020.jpg

Good afternoon, Please find below email from Joshua at Barton Willmore confirming that the council has approved our methodologies for your ES chapter/report.

Kind regards,

Åsa Söderberg Associate Direct: +44 1223 380 2911 Mobile: +44 7469 118 527 [email protected] Cambridge

3rd Floor, 50-60 Station Road, Cambridge, CB1 2JH Main Tel: 01223 882000

The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately.

Please consider the environment before printing this email.

From: Joshua Mellor Sent: 24 February 2020 14:16 To: Soderberg, Asa ; Ainslee Burley Cc: James Finn ; 'Birchington' ; 'Rachel Naylor' Subject: FW: Birchington - Outstanding matters

Hi Asa/Ainslee,

The Council has said they are happy with the GHG Chapter and Sustainability Statement methodologies. Let me know if you need anything further on either of these.

Regards

​ Joshua Mellor Instagram LinkedIn Twitter Planning Associate

Barton Willmore DDI: 01322 374 668 W: www.bartonwillmore.co.uk The Observatory, Castle Hill Drive, Castle Hill, ​Ebbsfleet Valley, Kent, DA10 1EE Consider the Environment, Do you really need to print this email? The information contained in this e-mail (and any attachments) is confidential and may be privileged. It may be read, copied and used only by the addressee, Barton Willmore accepts no liability for any subsequent alterations or additions incorporated by the addressee or a third party to the body text of this e-mail or any attachments. Barton Willmore accepts no responsibility for staff non-compliance with our IT Acceptable Use Policy.

From: Joshua Mellor Sent: 19 February 2020 09:39 To: Iain Livingstone ; Emma Fibbens Cc: Birchington ; James Finn Subject: Birchington - Outstanding matters

Morning Iain/Emma,

We have a couple of outstanding matters which we were awaiting response on you from. As we haven’t had a response from you I think we need to move ahead on the basis of what we proposed, to avoid this delaying submission. If you do have any comments on the methodologies of the GHG chapter and Sustainability Report, and the location of and approach to the illustrative visual (all relevant emails re-attached) then please let me know by COP Friday, otherwise we will proceed on the basis set out.

Regards

Instagram LinkedIn Twitter Joshua Mellor​ Planning Associate

Barton Willmore DDI: 01322 374 668 W: www.bartonwillmore.co.uk The Observatory, Castle Hill Drive, Castle Hill, ​Ebbsfleet Valley, Kent, DA10 1EE Consider the Environment, Do you really need to print this email? The information contained in this e-mail (and any attachments) is confidential and may be privileged. It may be read, copied and used only by the addressee, Barton Willmore accepts no liability for any subsequent alterations or additions incorporated by the addressee or a third party to the body text of this e-mail or any attachments. Barton Willmore accepts no responsibility for staff non-compliance with our IT Acceptable Use Policy.

From: Cottey, Roxanne To: "[email protected]"; "[email protected]" Subject: FW: Sustainability Statement for Birchington Strategic Site Date: 25 September 2019 15:27:00 Attachments: image001.png

Good afternoon,

As per the email below, we are preparing a Sustainability Statement in support of a planning application for Birchington and would like to clarify how best to structure the statement for Thanet’s consideration. We would ideally structure as follows: Ecology Waste Water (particularly sustainable drainage systems) Energy Noise Lighting Air Quality Transport

Please advise on any further technical areas to be covered or any that aren’t necessary. We would appreciate advice on this before Wednesday 2nd of October.

Kind regards, Roxanne Cottey Graduate Environmental Planner

Direct: 01189 520244 [email protected] http://www.peterbrett.com/locations/reading/

PBA has joined the Stantec family, find out more at peterbrett.com.

From: Cottey, Roxanne Sent: 19 September 2019 16:08 To: [email protected] Cc: Dray, Michael Subject: Sustainability Statement for Birchington Strategic Site

Good afternoon,

Peter Brett Associates is composing a Sustainability Statement in support of the planning application for the proposed development at Birchington.

We have reviewed the Thanet District Council Draft Local Plan 2031, validation checklists and Kent Design Guide SPD, and would appreciate further clarification as to how best structure our Sustainability Statement for Thanet to consider.

Based on your Local Plan, we have identified the following areas to be potentially included in the Sustainability Statement: Ecology Waste Water (particularly sustainable drainage systems) Energy Noise Lighting Air Quality Transport

Please could you advise on any further technical areas that must be covered to support the planning application, or highlight any that aren’t necessary. When convenient, please call me on 01189 520244 to discuss further.

Kind regards, Roxanne Cottey Graduate Environmental Planner

Direct: 01189 520244 [email protected] http://www.peterbrett.com/locations/reading/

PBA has joined the Stantec family, find out more at peterbrett.com.

From: Joshua Mellor To: Cottey, Roxanne Cc: Dray, Michael; James Finn; [email protected]; Soderberg, Asa Subject: RE: Birchington-on-Sea Sustainability Statement Date: 05 February 2020 09:35:33 Attachments: image007.png image008.png image009.png image010.png image011.jpg image012.png image013.jpg image014.jpg image015.png image001.png image002.png image003.png image004.jpg image006.png

Hi Roxanne,

No, we have pushed them at the meeting last week.

However as noted in email of 21 January to Asa, we should proceed on the basis of the methodologies we have proposed as we don’t envisage any major changes.

Instagram LinkedIn Twitter Joshua Mellor​ Planning Associate

Barton Willmore DDI: 01322 374 668 W: www.bartonwillmore.co.uk The Observatory, Castle Hill Drive, Castle Hill, ​Ebbsfleet Valley, Kent, DA10 1EE Consider the Environment, Do you really need to print this email? The information contained in this e-mail (and any attachments) is confidential and may be privileged. It may be read, copied and used only by the addressee, Barton Willmore accepts no liability for any subsequent alterations or additions incorporated by the addressee or a third party to the body text of this e-mail or any attachments. Barton Willmore accepts no responsibility for staff non-compliance with our IT Acceptable Use Policy.

From: Cottey, Roxanne Sent: 05 February 2020 09:32 To: Joshua Mellor Cc: Dray, Michael ; James Finn ; [email protected]; Soderberg, Asa Subject: RE: Birchington-on-Sea Sustainability Statement

Hi Joshua,

Further to the below, have you received any comments from Iain or Emma regarding the structure of our sustainability statement? Many thanks!

Kind regards,

Roxanne Cottey Graduate Environmental Planner Reading Direct: 07789 520244 [email protected]

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From: Joshua Mellor Sent: 17 January 2020 16:26 To: Iain Livingstone ; Emma Fibbens Cc: James Finn ; Birchington ; Dray, Michael ; Soderberg, Asa Subject: FW: Birchington-on-Sea Sustainability Statement Importance: High

Hi Iain/Emma,

Please see below from the Sustainability consultants for Birchington.

Could you please confirm you are happy for the Scope of the Sustainability Statement to be structured in line with the Plan’s sustainability appraisal objectives – as set out in the second email below?

We can then press on with getting this produced.

Keen to avoid any delay in this work starting so a quick yes would be greatly appreciated.

Regards

Instagram LinkedIn Twitter Joshua Mellor​ Planning Associate

Barton Willmore DDI: 01322 374 668 W: www.bartonwillmore.co.uk The Observatory, Castle Hill Drive, Castle Hill, ​Ebbsfleet Valley, Kent, DA10 1EE Consider the Environment, Do you really need to print this email? The information contained in this e-mail (and any attachments) is confidential and may be privileged. It may be read, copied and used only by the addressee, Barton Willmore accepts no liability for any subsequent alterations or additions incorporated by the addressee or a third party to the body text of this e-mail or any attachments. Barton Willmore accepts no responsibility for staff non-compliance with our IT Acceptable Use Policy.

From: Dray, Michael Sent: 17 January 2020 16:18 To: Joshua Mellor Cc: Soderberg, Asa ; [email protected] Subject: FW: Birchington-on-Sea Sustainability Statement

Hi Joshua,

Further to our phone conversation yesterday, please see below my colleague, Roxanne’s, email to Iain Livingstone at Thanet DC trying to clarifying the scope / policies that should be covered in the Sustainability Statement. To date we haven’t had any luck with feedback.

Since this email to Iain (on 9 December) we are now proposing to structure the report using the emerging Local Plan’s sustainability appraisal objectives (an approach we often use when a council is ‘between plans’). Please could you forward this onto the case officer to confirm whether or not this is acceptable?

Kind regards,

Michael

Michael Dray Caversham Bridge House, Waterman Place, Reading, UK, RG1 8DN Direct: +44 1189523114 [email protected]

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From: Cottey, Roxanne Sent: 16 January 2020 17:43 To: Dray, Michael Subject: FW: Birchington-on-Sea Sustainability Statement

Hi Mike,

Please find below one of my emails to Thanet District Council regarding agreeing the scope of the Sustainability Statement. Since then, I’ve created a proposed structure to the Statement. This was based on the emerging Local Plan’s sustainability appraisal, which has the following headings as key sustainability concerns for the area:

§ Economic

o Employment

o Wealth Creation

§ Social

o Health, Safety and Security

o Housing

o Facilities and Services

o Education and Skills

§ Environmental

o Landscape Character

o Cultural and Historic Heritage

o Air Quality

o Biodiversity

o Waste Management

o Water o Climate Change

o Energy Sources

Let me know if you have any questions. Many thanks!

Kind regards,

Roxanne Cottey Graduate Environmental Planner Reading Direct: 07789 520244 [email protected]

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From: Cottey, Roxanne Sent: 09 December 2019 09:56 To: [email protected] Subject: Birchington-on-Sea Sustainability Statement

Good morning Iain,

I’m contacting you regarding the proposed developments at Birchington-on-Sea.

We are preparing the Sustainability Statement to support the application, and would be very grateful if you could confirm the policies that we should be addressing in Thanet District Council’s Local Plan 2006 and emerging Local Plan 2031.

From the Local Plan 2006, we are proposing to respond to:

Policy D1 – Design Principles

From the emerging Local Plan 2031, we are proposing to respond to:

Policy 35 – Climate Change Policy QD01 – Sustainable Design Policy QD02 – General Design Principles

Additionally, the Sustainability Statement will cover several technical disciplines such as energy, transport, water, ecology, air quality and noise. Through these sections we will also be addressing:

Policy SP27 Biodiversity and Geodiversity Assets Policy SP31 Provision of Accessible Natural and Semi Natural Green Space Policy SP41 Safe and Sustainable Travel Policy CC01 Fluvial and Tidal Flooding Policy CC02 Surface Water Management Policy CC05 District Heating Policy SE05 Air Quality Policy SE06 Noise Pollution

Please let me know if there are any additional policies that should be addressed in the Sustainability Statement, or any other comments you may have.

Many thanks, and I look forward to hearing from you. Kind regards, Roxanne Cottey Graduate Environmental Planner Direct: 01189 520244 [email protected] http://www.stantec.com/uk

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