Marchfield (Strategic Land) Limited

Barnhorn Road, Bexhill-on-Sea

HABITAT REGULATIONS ASSESSMENT

January 2013 Habitat Regulaitons Assessment fpcr

FPCR Environment and Design Ltd Registered Office: Lockington Hall, Lockington, Derby DE74 2RH Company No. 07128076. [T] 01509 672772 [F] 01509 674565 [E] [email protected] [W] www.fpcr.co.uk

This report is the property of FPCR Environment and Design Ltd and is issued on the condition it is not reproduced, retained or disclosed to any unauthorised person, either wholly or in part without the written consent of FPCR Environment and Design Ltd. Ordnance Survey material is used with permission of The Controller of HMSO, Crown copyright 100018896.

Rev Issue Status Prepared / Date Approved/Date

- Draft MSWH / 28.11.12 SMM / 13.12.12 Final MSWH / 17.01.13

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CONTENTS

1.0 INTRODUCTION ...... 3

2.0 LEGISLATIVE & POLICY BACKGROUND ...... 4

3.0 LEVELS SAC / RAMSAR ...... 7

4.0 ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS...... 10

5.0 CONCLUSIONS ...... 19

FIGURES

Site Plan (Drawing Number CAUD 189963 001, July 2012)

Figure 1: Location of Pevensey Levels SAC / Ramsar & Air Quality Modelling Transects

Conceptual Drainage Strategy (Drawing Number 22421/003/001, 4th August 2011)

TABLES

Table 1: Pevensey Levels SAC / Ramsar

Table 2: Condition Assessment of Units 226 & 235 of the Pevensey Levels SSSI (June & July 2011)

Table 3: Critical Load of Nitrogen and Acid Deposition at Pevensey Levels SAC / Ramsar

APPENDICES

APPENDIX 1: SITE CITATIONS & CONSERVATION OBJECTIVES

APPENDIX 2: CORRESPONDANCE

APPENDIX 3: AIR QUALITY MODELLING ASSESSMENT

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1.0 INTRODUCTION

1.1 This report has been produced by FPCR Environment & Design Limited on behalf of Marchfield (Strategic Land). The report provides the results of a Habitat Regulations Assessment (HRA) screening in support of the allocation of a site for a proposed development at Barnhorn Green.

1.2 The Proposed Development covers 25.52ha that is located off Barnhorn Road on the north western fringe of Bexhill-on-Sea (grid reference TQ 708 081). Land within the Application site predominately supports well managed improved grassland, with a small area of hazel coppice to the east, established hedgerows, mature trees and a single stream along the northern boundary. Land within the surrounding area consists largely of open countryside, supporting arable farmland and pasture with hedgerows. To the east, residential properties extend away from boundary into the urban area of Bexhill-on-Sea.

1.3 Proposals for the site consist of the development of 275 residential dwellings, light industrial and office buildings, a nursing home, doctor’s surgery, primary school, 8.94ha of open space and associated infrastructure, including drainage and highways.

1.4 This report considers all available information to determine the potential for the proposed development to have any likely significant effect upon the Pevensy Levels Special Area of Conservation (SAC) / Ramsar. In assessing these potential effects the report herein makes reference to the baseline data provided in the separate Environmental Statement1, and therefore this report should be read in conjunction with that information. Natural England has been consulted throughout the HRA process.

1 JB Planning Associates (2012) Barnhorn Green: Environmental Statement A report produced on behalf of Marchfield (Strategic Land) Limited

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2.0 LEGISLATIVE & POLICY BACKGROUND

Habitats Directive

2.1 Article 6(3) of the European Habitats Directive requires an Appropriate Assessment of any plans that could affect Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar sites (jointly referred to as ‘European sites’).

Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of Paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.’

2.2 Article 6(4) of the Habitats Directive discusses alternative solutions, the test of “imperative reasons of overriding public interest” (IROPI) and compensatory measures:

If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of a social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted.

2.3 Plans and projects can only be permitted if it can be shown that they will have no significant adverse effect on the integrity of any European site, or if there are no alternatives to them and they are imperative. In determining the likelihood of a significant adverse effect the Habitats Directive requires the application of the precautionary principle.

2.4 A “likely significant effect” is defined as:

“Any effect that may reasonably be predicted...that may affect the conservation objectives of the features for which the site was designated, but excluding trivial or inconsequential effects.”

2.5 The integrity of a site is defined as:

“The coherence of its ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and / or the level of populations of the species for which it was classified.”

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The Appropriate Assessment Process

2.6 The Habitats Regulations Assessment (HRA) process may involve up to four separate stages, as follows:

• Stage 1 – Screening

• Stage 2 – Appropriate Assessment

• Stage 3 – Assessment of alternative solutions

• Stage 4 – Assessment where no alternative solutions remain and where adverse impacts remain

2.7 The report herein provides a Stage 1 Screening assessment that should enable the competent authority, Council (DC) “the Council”, to determine the likelihood of a significant effect on European Sites in relation to the development proposals at Barnhorn Green. In concluding its assessment it is anticipated that the Council will consult with Natural England.

Policy

National Planning Policy Framework

2.8 In reference to the protection of sites protected by the Habitats Directive the National Planning Policy Framework2 (NPPF) states:

The presumption in favour of sustainable development (Paragraph 14) does not apply where development requiring appropriate assessment under the Birds or Habitats Directives is being considered, planned or determined

Regional Spatial Strategy

2.9 In relation to European Sites Policy NRM5: Conservation and Improvement of Biodiversity of the South East Plan – The Regional Spatial Strategy for the South East states:

Local planning authorities and other bodies shall avoid a net loss of biodiversity, and actively pursue opportunities to achieve a net gain across the region.

i. They must give the highest level of protection to sites of international nature conservation importance (European sites). Plans or projects implementing policies in this RSS are subject to the Habitats Directive. Where a likely significant effect of a plan or project on European sites cannot be excluded, an appropriate assessment in line with the Habitats Directive and associated regulations will be required.

ii. If after completing an appropriate assessment of a plan or project local planning authorities and other bodies are unable to conclude that there will be no adverse effect on the integrity of any European sites, the plan or project will not be approved, irrespective of conformity with other policies in the RSS, unless otherwise in compliance with 6(4) of the Habitats Directive.

2 Department for Communities and Local Government (March 2012) National Planning Policy Framework

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Rother District Local Plan

2.10 With regard to general development considerations Policy GD1 of the Rother District Local Plan3 specifies a set of criteria that must be met by all developments, including:

(vii) It protects habitats of ecological value and incorporates, wherever practicable, features that enhance the ecological value of the site, with particular regard to wildlife refuges or corridors, or fully compensates for any necessary loss

Rother District Council Core Strategy

2.11 The Rother DC Core Strategy4is the key planning policy document that will guide the future pattern and form of development in the district up to 2028. At the time of writing the Core Strategy and 'Focused Amendments' had been submitted for consideration by the Secretary of State for Communities and Local Government.

2.12 In relation to the environment, Policy EN5 of the submitted Core Strategy lists a series of policies defining how developments should achieve the protection and enhancement of biodiversity and green space. These include the following:

(viii) require developers to integrate biodiversity into development schemes by avoiding adverse impacts from development on biodiversity or habitat, or where wholly unavoidable, provide appropriate mitigation against or compensation for any losses. In any event, developers will also be expected to consider and promote opportunities for the creation and/or restoration of habitats appropriate to local context.

3 Rother District Council (2006) Rother District Local Plan 4 Rother District Council (August 2011) Rother District Council Local Development Framework – Core Strategy (Proposed Submission)

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3.0 PEVENSEY LEVELS SAC / RAMSAR

3.1 The Pevensey Levels SAC / Ramsar is one of the largest and least fragmented lowland wet grassland systems in the southeast of England. The habitats associated with Pevensey Levels SAC / Ramsar support a range of important floral and faunal populations that are of national and international importance. The relevant citations for its international designations are provided in Appendix 1, and summary of the qualifying features of the Pevensey Levels SAC / Ramsar is presented in Table 1.

Table 1: Pevensey Levels SAC / Ramsar

Designation Justification / Interest Feature

Ramsar Qualifying Ramsar criteria consist of: • An outstanding assemblage of wetland plants and invertebrates, including many British Red Data Book species • 68% of vascular plant species in Great Britain that can be described as aquatic • It is probably the best site in Britain for freshwater molluscs, one of the five best sites for aquatic beetles and supports an outstanding assemblage of dragonflies

SAC Annex II species that are a primary reason for site selection • Little whorlpool ram’s horn Snail Anisus vorticulus

Vulnerability & Conservation Objectives

3.2 For Ramsar sites the main aim is ‘to promote the conservation of the wetland, to avoid deterioration of wetland habitats of Ramsar interest and to avoid significant disturbance of associated species’.

3.3 The wetland habitats Pevensey Levels Ramsar are vulnerable to on and off-site changes in hydrology and eutophication, i.e. nutrient enrichment, which may occur through surface run-off, other hydrological routes or aerial deposition. Such alterations in hydrology or nutrient status can have detrimental effects upon the composition and structure of habitats and the species they support. On this basis the key environmental considerations in supporting the integrity of the Pevensey Levels Ramsar / SAC are:

• Unpolluted water

• Low levels of nutrient enrichment

• Control of non-native species

• Maintenance of appropriate hydrological regime

• Control of recreational disturbance

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3.4 With regard to the qualifying habitats and species populations (Table 1), the conservation objectives of the Pevensey Levels SAC as described by Natural England5 are:

Avoid the deterioration of the qualifying natural habitats and the habitats of qualifying species, and the significant disturbance of those qualifying species, ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying features.

Subject to natural change, to maintain or restore:

• The extent and distribution of qualifying natural habitats and habitats of qualifying species;

• The structure and function (including typical species) of qualifying natural habitats and habitats of qualifying species;

• The supporting processes on which qualifying natural habitats and habitats of qualifying species rely;

• The populations of qualifying species;

• The distribution of qualifying species within the site

3.5 The Pevensey Levels SAC was designated in 2011 on the basis of the population of little whorlpool ram’s horn snail Anisus vorticulus that it supports (Table 1). In relation to the vulnerability of little whorlpool ram’s horn snail, the Natura 2000 data form (Appendix 1) states:

Anisus vorticulus is a species of the upper water levels of ditches, frequently amidst botanically- rich vascular plant assemblages in a mid to upper mid successional state. It favours alkaline waters although it appears tolerant of a relatively wide range of physio-chemical parameters. Appropriate ditch management is the key to the conservation of this species. Control of shade- inducing marginal vegetation is also important, as is maintaining access to the water’s edge for livestock. It is also important to ensure good water quality by instigating the appropriate safeguards. This is being implemented through good environmental management, Catchment Sensitive Farming, Environmental Stewardship and Environment Agency’s review of existing discharge and abstraction consents. A Water Level Management Plan, devised and managed by Environment Agency, is in place to control ditch levels. Environmental Stewardship schemes continue to encourage sensitive management, particularly of the ditches to address problems brought about by neglect.

3.6 A number of potential threats have also been identified on the ‘species fact sheet’ for little whorlpool ram’s horn snail6, including land reclamation and drying out, human induced changes in hydraulic conditions, silting up and the drying out / accumulation of organic material. Therefore, based upon the current understanding of this species distribution and vulnerability, any potential effect upon the integrity of the SAC population are also expected to occur through some the processes described in Paragraph 3.3, particularly in relation to alterations in hydrology and nutrient enrichment, which are addressed by the following assessment.

5 www.naturalengland.org.uk 6 http://jncc.defra.gov.uk/pdf/Article17/FCS2007-S4056-Final.pdf

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Appropriate Assessment of Rother District Council Core Strategy

3.7 A HRA Stage 1 screening identified the requirement for an Appropriate Assessment of the Rother DC Core Strategy (Rother District Council 2007 7). With regard to the Pevensey Levels Ramsar the screening report considered that the following factors required further consideration:

• Potential for impacts from housing provision and associated infrastructure on water quality and quantity that could affect the integrity of the site

• Potential for changes in pollution levels from increased traffic levels related to housing provision and associated infrastructure

3.8 On this basis an Appropriate Assessment was made of the Rother and Wealden Core Strategies (Rother District Council & Council 20108). The Appropriate Assessment made the following policy recommendations in order to avoid significant adverse effects upon the integrity of the Pevensey Levels Ramsar as a result of altered hydrology:

‘Any such policy should require Sustainable Drainage Systems (SuDS) to be incorporated on all development sites that create impermeable surfaces within the hydrological catchment area of the Pevensey Levels (irrespective of the size and type of development) where such a development will result in an increase in the volume and peak flow rate of surface water than rates prior to the proposed development.’

‘The current consent for the North and South Waste Water Treatment Works will not be increased. In order for the increased waste water from new development to be within acceptable environmental limits, the discharge must remain within the current consented capacity.’

3.9 There were no adverse effects as a result of altered abstraction because ‘No further abstraction for public water supply will be permitted in the Pevensey Levels.’ Therefore, water abstraction is not considered further as part of this assessment.

3.10 Policy SRM2 Water Management of the submitted Core Strategy takes account of these recommendations by promoting the use of sustainable drainage and regulating discharge of waste water.

3.11 An Appropriate Assessment was also carried out to determine the potential adverse effects of altered air quality upon the integrity of the Pevensey Levels Ramsar as a consequence of the combined effects of development across four local authorities, including Rother DC (Scott Wilson 20099). This assessment applied traffic modelling to concluded that there will be no adverse effect upon the integrity of the Pevensey Levels Ramsar. In agreement with this conclusion Natural England stated:

‘(Natutal England) would concur with the conclusion that while there is likely to be an increase in

nitrogen deposition and NOx concentrations these will still be below the Critical Levels applicable to Pevensey Levels and therefore there is unlikely to be a significant effect on the Ramsar site from the proposed levels of housing from these pollutants’

7 Rother District Council (2007) Rother District Council Local Development Framework - Core Strategy Development Plan Document Appropriate Assessment Screening Report 8 Rother District Council & Wealden District Council (September 2010) Wealden & Rother Core Strategies Appropriate Assessment - Hydrology Local to the Pevensey Levels 9 Scott Wilson (June 2009) Appropriate Assessment and Air Quality Local to the Pevensey Levels Ramsar Site - A Report to Support the Appropriate Assessment for Rother, Wealden, and Eastbourne Core Strategies

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4.0 ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS

4.1 The following assessment has made reference to the Site Plan (Drawing Number CAUD 189963 001, July 2012) and Design and Access Statement10 for the Proposed Development. The proposals consist of the development of 275 residential dwellings, light industrial and office buildings, a nursing home, doctor’s surgery, primary school, 8.94ha of open space and associated infrastructure, including drainage and highways.

4.2 As described in Paragraphs 3.7 – 3.11, an Appropriate Assessment at a strategic level had concluded that there would be no adverse effects upon the integrity of the Pevensey Levels SAC / Ramsar as a consequence of the Rother DC Core Strategy. However, it has been agreed with Natural England that further assessment of the proposals was still required to determine that there would be no significant adverse effect upon the integrity of this European Site at a project level.

Potential Effects

4.3 The Proposed Development is situated approximately 600m north of the boundary of the Pevensey Levels SAC / Ramsar, and will therefore not lead to any direct effects upon habitats within the boundary of this designated site. The Proposed Development will not result in a lack of management at this European Site as their management will not be connected in any way. However, it is acknowledged that the Proposed Development will have the potential to have indirect effects upon the interest features of this European Site.

4.4 In consultation with Natural England it has been agreed that the factors that do have the potential to result in impacts upon the sensitive habitats of the Pevensey Levels SAC / Ramsar are considered to be :

• Altered water quality or water quantity

• Altered air quality

4.5 Both impacts have the potential to result in the deterioration of habitats supporting notable flora and fauna, e.g. through nutrient enrichment and altered habitat structure.

4.6 Where appropriate the assessment takes account of the mitigation measures that have been included to ameliorate potential adverse effects upon the Pevensey Levels SAC / Ramsar. These include, but are not limited to, the use of best working practice and sensitive design.

4.7 The assessment provided in the following section establishes that it is likely that there will be no significant effect as a result of the proposals, either alone or in combination, upon the integrity of the interest features of the Pevensey Levels SAC / Ramsar.

10 Savills (September 2012) Barnhorn Green Design & Access Statement

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Altered Hydrology

4.8 The Appropriate Assessment of the Rother and Wealden Core Strategies (Rother District Council & Wealden District Council), identifies the following three routes through which altered hydrology may affect the sensitive habitats and features of the Pevensey Levels SAC / Ramsar:

• Increase in impermeable surfaces – leading to altered volume and rates of run-off;

• Volume of wastewater discharges – altered quality and quantity of water discharged to the Pevensey Levels SAC / Ramsar through connected water treatment works connected; and

• Water abstraction – increased abstraction from the Pevensey Levels may have adverse effects upon its habitats is not permitted during low flows

4.9 Picknell Green Stream and a land drain lie on the north and west boundaries of the Proposed Development, respectively. The land drain merges with Picknall Green Stream and flows west into Waller’s Haven, which is one of three main river systems that supply water to the Pevensey Levels SAC / Ramsar. The proposals are therefore hydrologically linked to the Pevensey Levels SAC / Ramsar through Picknall Green Stream, and alterations to the hydrology of this stream during either construction or operation has the potential to affect the European Site.

4.10 A detailed assessment of the hydrological effects throughout the lifetime of the Proposed Development and recommended mitigation measures are provided in Chapter 12: Water (by Peter Brett Associates) of the Barnhorn Green Environmental Statement (JB Planning Associates 2012) and the Flood Risk Assessment (Peter Brett Associates 2012) 11. The following evaluates the likelihood of significant adverse effects upon the Pevensey Levels in the context of the mitigation proposed by those assessments.

Potential Effect of Altered Water Quantity & Quality During Construction

4.11 Potential routes for adverse hydrological (water quantity or water quality) effects during construction include the following:

• Increased volume and rates of run-off from hard-standing;

• Increased sedimentation in the western land drain or Picknall Green as a result of increased run-off or generation of dust; and

• Leakage of temporary waste water system during construction

4.12 Management of surface water and the risk of any contamination will be achieved through a ‘temporary drainage scheme’. This scheme will manage run-off to minimise the risk of on-site flooding while also protecting sensitive downstream receptors, i.e. the Pevensey Levels SAC / Ramsar. This will include the adoption of good management practices, including briefing of construction workers and all relevant measures as described in the Environment Agency's Pollution Prevention Guidelines 5: Works or Maintenance in or Near Water and Pollution Prevention Guideline 6: Working at Construction and Demolition Sites. It is expected that this scheme would be delivered as part of a Code of Construction Practice or similar, which would be secured through an appropriately worded planning condition.

11 Peter Brett Associates (2012) Barnhorn Green – Flood Risk Assessment A report produced on behalf of Marchfield (Strategic Land) Ltd

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4.13 Waste water from contractor facilities will be controlled and directed either to a new connection to the Southern Water public foul water sewer network, or make use of a temporary septic tank or cess pit. A regular maintenance regime must be carried out on the temporary sewerage infrastructure to minimise the risk of breakage or leakage. Other measures to minimise the risk of contamination from waste water will include a 10m stand-off between contractor washing/ showering/ toilet facilities and Picknall Green Stream and the use of impermeable bunds around any storage tanks that may contain potentially damaging pollutants.

4.14 Through the stringent protection of local watercourses, the implementation of these measures would be considered sufficient to minimise the risk that any alterations in water quality or quantity during construction would impact upon downstream receptors, including the Pevensey Levels SAC / Ramsar. It is therefore considered that there would not be any significant adverse effects upon the integrity of the Pevensey Levels SAC / Ramsar as a result of hydrological effects duri ng the construction phase of the Proposed Development.

Potential Effect of Altered Water Quantity & Quality during Operation

4.15 The potential routes for adverse hydrological (water quantity and water quality) effects following construction, i.e. the operation lifetime of the Proposed Development, include the following:

• Increased volume and rate of water run-off from hard-standing;

• Run-off of pollutants, such as vehicle hydrocarbons, from hard-standing surfaces; and

• Increase in foul sewage

4.16 The following section considers the measures designed into the Proposed Development to address these issues and ensure that any hydrological effects are maintained within acceptable limits.

Water Quantity

4.17 The volume and rate of water run-off from the Proposed Development will be regulated through the implementation of the Conceptual Drainage Strategy (Drawing Number 22421/003/001, 4th August 2011). The strategy maintains current Greenfield surface water run-off from the Proposed Development through the use of surface water attenuation measures and Sustainable Urban Drainage Systems (SuDS). The design of this strategy has been developed in consultation with the Environment Agency (Appendix 2) and accords with national policy, guidance, including CIRIA C697 (2007) ‘The SuDS Manual’, and recommendations of the Rother District Council (2008) Strategic Flood Risk Assessment.

4.18 A range of measures will be implemented as recommended in the Flood Risk Assessment (Peter Brett Associates 2012), and together these will limit the rate of discharge into Picknall Green Stream to mimic existing conditions as far as practically possible. Assessment of the SuDS capacity demonstrates that the total storage volume provided by the development is designed to accommodate the 1% (1 in 100) year rainfall event plus a 30% allowance for climate change (Peter Brett Associates 2012). Modelling in accordance with Environment Agency guidance has also demonstrated that the use of a controlled outlet will ensure that the rate of run-off from will be limited to Greenfield Run-off Rates, i.e. the pre-developed rate of run-off. The calculated velocity expected at the outfall for any given event probability is very low, and is therefore not likely to cause scour of the bed of the Picknill Green Stream (Peter Brett Associates 2012). This

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is specifically addressed by the proposed linear wetland strip that lies parallel to parts of the Picknall Green Stream.

4.19 The implementation of the measures described above are considered sufficient to ensure that the amount and rate of water run-off throughout the life time of the Proposed Development is not sufficient to adversely affect downstream receptors, including the Pevensey Levels SAC / Ramsar.

Water Quality

4.20 The following section details the measures implemented to regulate the quality of surface and foul water from the Proposed Development.

Surface Water

4.21 The above ground storage in ponds, sub-base storage, catch-pit manholes, trapped gullies and oil interceptors in car parking areas implemented as part of the SuDS strategy will serve to trap / remove pollutants / sediment at source before disposal to receiving waterbodies. Specific measures that will be implemented and shall also assist in managing water quality further, include the following:

• Suspended debris upstream of the discharge outfall will be arrested through a series of catch- pit chambers upstream of the outfall to the attenuation ponds and downstream of the outfall flow control device;

• Source control devices will be installed, including trapped gullies & permeable paving;

• Oil interceptors within parking areas greater than 800m2.

4.22 Betterment in water quality will continue as planted vegetation becomes established. Consideration will also be given to facilitating the further improvement of water quality through the excavation of basins within some sections of the cascading ditch, which will aid the removal of sediments and contaminants. Therefore, the water quality of downstream receptors, including the Pevensey Levels SAC / Ramsar, will be protected and the risk of pollution incidents in the future will be reduced.

Foul water treatment

4.23 A new foul water rising main and pumping station will be installed, which will receive foul flows from the Proposed Development and discharge these to the public sewerage system. The flows would ultimately discharge to the Bexhill Waste Water Treatment Works (WwTW). In order to satisfy the requirements of The Water Industry Act 1991, a Section 104 and Section 106 agreement will be entered into with Southern Water, who will then adopt management of the foul waste. Southern Water has not advised any difficulty with accommodating the additional flows as part of an assessment of WwTW capacity, and this has been dealt with through a capacity assessment undertaken by Southern Water.

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4.24 As described in Paragraph 3.8, the Appropriate Assessment of the Rother Core Strategy recommended the avoidance of increases in development directing foul sewage to the Hailsham North and South WwTW (Rother District Council & Wealden District Council 2010). The Proposed Development clearly avoids this by directing waste water to the Bexhill WwTW. Furthermore, discharge from the development will be within the consented capacity of Bexhill WwTW. This is sufficient to conclude that there will be no significant alterations in water quality as a consequence of foul sewage discharged from the proposals. Therefore, in this context the foul sewage from the Proposed Development is not expected to result in an adverse effect upon the integrity of the Pevensey Levels SAC / Ramsar.

Summary

4.25 In accordance with recommendations of the Rother Core Strategy Appropriate Assessment and Policy SRM2 of the Core Strategy (Paragraphs 3.8 to 3.10), the Proposed Development will implement SuDS12 and the discharge of foul sewage away from the Hailsham WwTW. As described in the above assessment, this strategy is considered sufficient to ensure that the proposals will not result in any significant hydrological effects. Therefore, this is considered sufficient to conclude that there will be no adverse effects upon the integrity of Pevensey Levels SAC / Ramsar as a result of altered water quality or water quantity.

Altered Air Quality

4.26 Increases in traffic movements have the potential to alter air quality, and may lead to altered adverse effects upon habitats through the toxic effects of aerial pollutants and / or altered rates of nutrient deposition. As described in Volume 11 HA 207/07 of the Highways Agency’s Design Manual for Roads & Bridges, the potential effects of altered air quality associated with increased traffic movements should be considered along roads that fall within 200m of a European site. Increases in vehicle movements to and from the Proposed Development within 200m of the Pevensey Levels SAC / Ramsar will occur along the A259 / Barnhorn Road. Aerial emissions as a result of increased traffic movements has been made along three separate transects that each cover a distance up to 200m from the A259 (Figure 1). Emissions were modelled for receptors located at the following distance along each of the transects; 0m, 5m, 15m, 50m, 100m, 150m and 200m. The detailed results of air quality assessment upon the Pevensey Levels SAC / Ramsar are provided in Appendix 3.

4.27 The following details the likelihood of effects upon the Pevensey Levels SAC / Ramsar as a result of emissions from increased traffic along the A259. The analysis covers the effects of oxides of nitrogen and associated increases in nitrogen and acid deposition.

12 Appropriate design of the SuDS scheme will also provide benefits for local biodiversity and these are considered separately within relevant chapters of the Environmental Statement (JB Planning Associates 2012)

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Oxides of Nitrogen

4.28 Oxides of nitrogen may have toxic effects upon vegetation, particularly bryophytes, but the main effect upon vegetation of any increase in concentration is to contribute to the rate of nitrogen deposition (Hall et al 200613).The critical level for assessing the effects of oxides of nitrogen upon habitats is 30mg/m3 14. Modelling the changes in the background concentration of oxides of nitrogen over the period 2011 to 202215 illustrates that the critical level is exceeded up to 15m from the road in 2011 and up to a distance of 5m in 2022. Therefore, without the Proposed Development there is a reduction on the area exceeding the critical level for oxides of nitrogen. With the development this reduction continues to occur at Transects 1 and 2, but not at Transect 3 (Appendix 3). The maximum contribution of the Proposed Development to the concentration of oxides of nitrogen is 13.4% immediately adjacent to the road (transect 3). The magnitude of this contribution should be considered against its very limited extent and the continuing fall in the overall area that exceeds the critical level over the period investigated. Therefore, at worst the change in the concentration of oxides of nitrogen is considered to be neutral and is not considered to affect the integrity of the Pevensey Levels SAC / Ramsar.

Nitrogen & Acid Deposition

Critical Load of Pevensey Levels SAC / Ramsar

4.29 There are no critical loads for the Pevensey Levels SAC / Ramsar available on the Air Pollution Information System (APIS16). Analysis has therefore been based upon the available data for the corresponding units of the Pevensey Levels Site of Special Scientific Interest (SSSI), the designated boundary of which corresponds to the SAC / Ramsar. At the point closest to the development the A259 road corridor lies adjacent to units 226 and 235 of the Pevensey Levels SSSI. The condition assessment of these SSSI units is considered sufficient to indicate indicates the current status of the corresponding area of the Pevensey Levels SAC / Ramsar. Table 2 provides the most up-to-date condition assessment, which has classified both units 226 and 235 as ‘unfavourable recovering’. No specific reason for the status of these units is available, however, both are known to be under positive management, i.e. agri-environment schemes.

13 Hall, J., Bealey, B. & Wadsworth, R. (2006) Assessing the risks of air pollution impacts to the condition of Areas/Sites of Special Scientific Interest in the UK JNCC Report No. 387 14 This critical level is normally applied only to locations more than 20km from an agglomeration (~250,000 people) or more than 5km from industrial sources, motorways and built up areas of more than 5,000 people. However, a precautionary approach that applies the critical level to all European Sites is preferred by Natural England 15 Data not shown 16 www.apis.ac.uk

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Table 2: Condition Assessment of Units 226 & 235 of the Pevensey Levels SSSI (June & July 2011)

Unit Size Habitat Condition Comment 226 95ha Fen, marsh & Unfavourable Significant area of unit in agri-environment swamp Recovering scheme therefore appropriate management in place. Water levels will be addressed through implementation of the Water Level Management Plan. Alien species present will be addressed through invasive weed strategy

235 100ha Fen, marsh & Unfavourable Significant area of unit in agri-environment swamp Recovering scheme therefore appropriate management in place. Water levels will be addressed through implementation of the Water Level Management Plan. Alien species present will be addressed through invasive weed strategy

4.30 The habitats within the Pevensey Levels SSSI units 226 and 235 have been classified as the Broad Habitat type ‘fen, marsh and swamp’ (Table 2). This covers a range of habitat types, including ‘coastal & flood plain grazing marsh’, which is the dominant Priority Habitat within these units17. APIS indicates that nitrogen deposition is the key concern for the ‘fen, marsh and swamp’ and ‘coastal & flood plain grazing marsh’ habitats. High rates of nitrogen deposition may result in the dominance of common, nutrient tolerant grasses and sedges at the expense of more sensitive floral species. This may have adverse effects upon the status of notable habitats through an alteration in community composition and structure. APIS acknowledges that information is limited concerning the sensitivity of these habitat types to nitrogen deposition. However, a precautionary approach has been adopted and the most sensitive critical load for nitrogen deposition has been selected for analysis (Table 3). Therefore, in the following analysis the critical load for nitrogen and acid deposition are taken to be 10kgN/ha/yr and 0.807keqN/ha/yr18.

Table 3: Critical Load of Nitrogen and Acid Deposition at Pevensey Levels SAC / Ramsar

Habitat Critical Load Nitrogen Deposition Acid Deposition (kgN/ha/yr) (keqN/ha/yr) Fen, Marsh & Swamp 10-15 0.807 Coastal & Floodplain Grazing 20-30 Not sensitive Marsh

17 www.natureonthemap.naturalengland.org.uk 18 There are no emissions thresholds for open water habitats, including ditches, which are an interest feature of the Pevensey Levels SAC / Ramsar

Barnhorn Green HRA 17 01 13 16 Habitat Regulaitons Assessment fpcr

Nitrogen Deposition

4.31 Air quality modelling has demonstrated that the existing background rate of nitrogen deposition exceeds the critical load for fen, marsh and swamp habitats. The critical load is exceeded across all three transects, i.e. up to 200m from the road, with a peak rate of 17.42kgN/ha/year at the road edge on Transect 3 (Appendix 3). When the background levels of deposition exceed the critical load a European Sites habitats, a significant adverse effect may be caused by any additional emissions from the process under investigation (the Process Contribution) that equal 1% or more of the critical load. Modelling demonstrates that Process Contribution is 1% or more of the critical road at the road edge for Transects 1 and 2, and up to 5m from the road at Transect 319 (Appendix 3). All other receptors along each transect receive less than 1% of the critical load for nitrogen deposition as a result of increased emissions along the A259, i.e. they will not result in an adverse effect upon the habitats.

4.32 Air quality modelling of nitrogen deposition has therefore indicated that the Proposed Development may lead to a significant Process Contribution up to a maximum distance of 5m from the road edge. The majority of habitats within this distance are associated with the road verge, comprising rough grassland, hedgerows and scrub. Fen, marsh and swamp habitats are therefore either not expected to lie within 5m of the road edge or are extremely limited in extent, particularly when considered against the combined size of these units 226 & 235, which equals 195ha. During consultation Natural England requested that it should be established if any roadside ditches fall within 5m of the road edge. If present such roadside ditches could connect to the sensitive habitats of the Pevensey Levels SAC / Ramsar. It is important to make clear that the air quality modelling uses the edge of the hard-standing surface of the road as the 0m point for each transect. An investigation was made of upon the section of A259 between transect 3 (x 567372, y 107905) and the roundabout where the A259 and A27 meet (x 565086, y 105104). Mastermap Ordinance Survey data in this area confirms that none of the roadside ditches lie within 5m of the road edge. Therefore, the ditches lie outside the area where the process contribution exceeds the threshold for significance. Furthermore, although the condition of units 226 & 235 have been assessed as ‘unfavourable recovering20, the units are subject to appropriate management that is expected to restore their status over time. Appropriate management across these units, and the wider area of the Pevensey Levels SAC / Ramsar, is expected to be more than sufficient to ameliorate the very limited potential effects resulting from altered aerial emissions. It should also be noted that in any event the final Predicted Environmental Concentration of nitrogen deposition does not exceed the critical load for coastal or floodplain grazing marsh. This is in agreement with the Appropriate Assessment of the Core Strategy, which applied the critical load of this Priority Habitat (Scott Wilson 2009). Therefore, alterations in the rate of nitrogen deposition as a result of the Proposed Development will not lead to a significant adverse effect upon the integrity of the Pevensey Levels SAC / Ramsar.

19 The same results are obtained in scenarios with or without the link road (Appendix 3) 20 ‘Unfavourable recovering’ is are SSSI habitats that are ‘not yet fully conserved but all the necessary management measures are in place. Provided that the recovery work is sustained, the SSSI will reach favourable condition in time’ www.naturalengland.org.uk

Barnhorn Green HRA 17 01 13 17 Habitat Regulaitons Assessment fpcr

Acid Deposition

4.33 Nitrogen may contribute to the acidification of habitats, which can lead to the leaching of essential plant nutrients or increases in the concentration of toxic metal ions, such as aluminium, within the soil (Hall et al 2006). In some situations this may affect nutrient sensitive plants, leading to detrimental effects upon plant community structure. Typically coastal and floodplain grazing marsh is not considered to be sensitive to the effects of acidification (Table 3)15. However, a precautionary approach to analysis was adopted using the critical level of 0.807keqN/ha/year for fen, marsh and swamp. Analysis indicates that the background rate of acid deposition exceeds the critical load, with a peak of 1.24 keqN/ha/year at the road edge on transect 3 (Appendix 3). As discussed in Paragraph 4.31, when the background rate exceeds the critical load a significant adverse effect may be caused by a Process Contribution equalling 1% or more of the critical load. As for nitrogen deposition, modelling has demonstrated that the Process Contribution is 1% or more of the critical load at the road edge for Transects 1 and 2, and up to 5m from the road at Transect 317, 20 (Appendix 3). All other receptors along each transect receive less than 1% of the critical load for acid deposition as a result of increased emissions, i.e. they will not result in an adverse effect upon the habitats. Consequently, as described for nitrogen deposition (Paragraph 4.32), the final extent of habitat that is subject to this increase is likely to fall within the habitats of the road verge or be extremely limited in overall extent. Therefore, in this context the alterations in the rate of acid deposition as a result of the Proposed Development will not lead to a significant adverse effect upon the integrity of the Pevensey Levels Ramsar.

Summary

4.34 Therefore, the effect of altered air quality (nitrogen and acid deposition) upon the Pevensey Levels SAC / Ramsar as a result of the Proposed Development is considered to be of negligible significance. This is considered to be sufficient to conclude that there will be no adverse effect upon the integrity of these European Sites as a result of altered air quality.

Effects In-combination

4.35 No specific projects have been identified which, in-combination with the Proposed Development, are likely to affect the integrity of the Pevensey Levels SAC / Ramsar. It is expected that all other projects will also be required to comply with the relevant policies of the Rother DC Core Strategy, including those informed by Appropriate Assessment. As such other projects would not be expected to achieve consent unless they comply with policy and can demonstrate that there will be no adverse effects upon the Pevensey levels SAC / Ramsar. In this context the proposals are not expected to have adverse effect in-combination with other projects upon the integrity of the Pevensy Levels SAC / Ramsar.

Summary

4.36 In summary, the assessment provided herein has used all available information to make a detailed investigation the potential effects of the Proposed Development upon the Pevensey Levels SAC / Ramsar. The effects considered in detail have included alterations in water quantity, water quality and air quality. The assessment has concluded that the Proposed Development, either alone or in-combination, will not result in any significant adverse effects upon the integrity of the habitats or habitats of species within the Pevensey SAC / Ramsar.

Barnhorn Green HRA 17 01 13 18 Habitat Regulaitons Assessment fpcr

5.0 CONCLUSIONS

5.1 This report sets out a review of the potential effects of the proposed development at Barnhorn Road, Bexhill-on-Sea, upon the Pevensey Levels SAC / Ramsar. Using all sources of available information the assessment concludes that the Proposed Development, either alone or in- combination with other projects or plans, will not lead to significant adverse effects upon the integrity of the Pevensey Levels SAC / Ramsar. A summary of each element of the assessment is provided below.

5.2 The proposals will not lead to the direct loss of habitat within the boundary of the Pevensey Levels SAC / Ramsar

5.3 The implementation of surface water drainage through a Code of Construction Practice, which would be delivered as a part of a planning condition, and the control and maintenance of waste water, would be sufficient to ensure that there are no adverse effects upon the integrity of the Pevensey Levels SAC / Ramsar during construction.

5.4 The implementation of a SuDS and discharge of water to the Bexhill WwTW (i.e. away from the Hailsham WwTW), will ensure that following construction the proposals will not lead to a significant adverse effects upon the integrity of the Pevensey Levels SAC / Ramsar as a result of altered water quality or quantity.

5.5 Assessment of air quality modelling has demonstrated that changes in the concentration of the oxides of nitrogen are neutral and are not considered to affect the integrity of the Pevensey Levels SAC / Ramsar.

5.6 An investigation using precautionary thresholds has demonstrated that increases in nitrogen and acid deposition as a result of the proposals are predicted to exceed 1% threshold of the Critical Load of the Pevensey Levels SAC / Ramsar. Consideration is given to mitigating factors, particularly the very limited overall extent of this effect, i.e. no more than 5m from the road edge. On this basis of the evidence presented it is concluded that there will be no adverse effect upon the integrity of Pevensey Levels SAC / Ramsar as a result of altered air quality.

5.7 There are no in-combination effects with other projects or plans.

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. .   

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Ordinance Survey material is used with the permission of The Controller of HMSO, Crown copyright 100018896

224 225

Application Boundary Ramsar Special Area of Conservation (SAC) 1 SSSI Unit (labelled) 3 Air Quality Modelling Transect

TG1 6 4 5

7

TG2 2 226 1 3 235 223

236 227 234

Marchfield (Strategic Land) Limited 237 Pevensey Levels SAC / Ramsar Barnhorn Road, Bexhill-on-Sea 228 232 LOCATION OF PEVENSEY LEVELS 230 fpcr SAC / RAMSAR & AIR QUALITY MODELLING TRANSECTS 233 1:25,883 MSH / KH 11.12.12 229 231 Figure 1 Habitat Regulations Assessment FPCR Environment and Design Ltd, Lockington Hall, Lockington, Derby, DE74 2RH t: 01509 672772 f: 01509 674565 e: [email protected] w: www.fpcr.co.uk masterplanning environmental assessment landscape design urban design ecology architecture arboriculture J:\4600\4664\Plans\Figure001 ± FPOND LAYOUT REVISED FOLLOWING PLANNER COMMENTSWSW25.09.12TH

SITE BOUNDARY AND DEVELOPMENT AREAS UPDATED TO SUITE REVISED E PARAMETERS PLAN WSW 24.09.12 TH

D STRATEGY UPDATED TO SUI TE REVISED PARAMETERS PLAN WSW 31.05.12 TH

CSITE BOUNDARY AND DEVELOPMENT AREAS REVISED KM16.05.12TH

BLOCATIONS OF ATTENUATION PONDS REVISED WSW 09.09.11 TH

ASTRATEGY AND AREAS UPDATED WSW 15.08.11 TH

Mark Revision Drawn Date Chkd

SCALI NG NOTE: Do not scale from this drawing. I f in doubt , ask. UTILITIES NOTE: The position of any existing public or private sewers, utility services, plant or apparatus shown on this drawing is believed t o be correct, but no warranty to this is expressed or implied. Other such plant or apparatus may also be present but not shown. The Contractor is therefore advised to undertake his own invest igation where the presence of any existing sewers, services, plant or apparatus may af fect his operations. Drawing Issue Status PLANNING LAND AT WEST BEXHILL

CONCEPT DRAINAGE STRATEGY

Client THE FAIRFIELD PARTNERSHIP

Date of 1st Issue Drawn by 04.08.2011 KM A1 Scale Checked by 1:1250 TH

Reproduced from/based upon Ordnance Survey material with the permission of Ordnance Survey Drawing Number Revision on behalf of The Controller of Her Majesty's St ationery Of fice. Crown Copyright. Unauthorised reproduction infringes Crown Copyright and may lead to prosecution or civil proceedings. Licence No. 010003131673 Year of Publication 2010 O wner/ Purchaser of Mapping PETER BRETT ASSOCIATES LLP 22421/003/001 F Habitat Regulaitons Assessment fpcr

APPENDIX 1: SITE CITATIONS & CONSERVATION OBJECTIVES

Barnhorn Green HRA 17 01 13 23 UK SAC data form

NATURA 2000 STANDARD DATA FORM FOR SPECIAL PROTECTION AREAS (SPA) FOR SITES ELIGIBLE FOR IDENTIFICATION AS SITES OF COMMUNITY IMPORTANCE (SCI) AND FOR SPECIAL AREAS OF CONSERVATION (SAC)

1. Site identification:

1.1 Type B 1.2 Site code UK0030367

1.3 Compilation date 201102 1.4 Update

1.5 Relationship with other Natura 2000 sites

1.6 Respondent(s) International Designations, JNCC, Peterborough

1.7 Site name Pevensey Levels

1.8 Site indication and designation classification dates date site proposed as eligible as SCI 201102 date confirmed as SCI date site classified as SPA date site designated as SAC

2. Site location: 2.1 Site centre location longitude latitude 00 21 02 E 50 51 09 N

2.2 Site area (ha) 3585.38 2.3 Site length (km)

2.5 Administrative region NUTS code Region name % cover

UKJ22 East CC 100.00%

2.6 Biogeographic region X Alpine Atlantic Boreal Continental Macaronesia Mediterranean 3. Ecological information:

3.1 Annex I habitats Habitat types present on the site and the site assessment for them:

Annex I habitat % cover Representati Relative Conservation Global vity surface status assessment

Pevensey Levels Natura 2000 Data Form Produced by JNCC., 27/07/11 Page 1 UK SAC data form

3.2 Annex II species Population Site assessment Resident Migratory Species name Breed Winter Stage Population Conservation Isolation Global Commo Anisus vorticulus - - - A A C A n

4. Site description

4.1 General site character Habitat classes % cover Marine areas. Sea inlets Tidal rivers. Estuaries. Mud flats. Sand flats. Lagoons (including saltwork basins) Salt marshes. Salt pastures. Salt steppes Coastal sand dunes. Sand beaches. Machair Shingle. Sea cliffs. Islets Inland water bodies (standing water, running water) 2.5 Bogs. Marshes. Water fringed vegetation. Fens Heath. Scrub. Maquis and garrigue. Phygrana Dry grassland. Steppes Humid grassland. Mesophile grassland 97.5 Alpine and sub-alpine grassland Improved grassland Other arable land Broad-leaved deciduous woodland Coniferous woodland Evergreen woodland Mixed woodland Non-forest areas cultivated with woody plants (including orchards, groves, vineyards, dehesas) Inland rocks. Screes. Sands. Permanent snow and ice Other land (including towns, villages, roads, waste places, mines, industrial sites) Total habitat cover 100% 4.1 Other site characteristics

Soil & geology: Alluvium, Basic, Clay, Mud, Nutrient-poor, Peat, Sand, Sedimentary, Shingle Geomorphology & landscape: Coastal, Floodplain, Lowland

4.2 Quality and importance Anisus vorticulus • for which this is considered to be one of the best areas in the United Kingdom.

Pevensey Levels Natura 2000 Data Form Produced by JNCC., 27/07/11 Page 2 UK SAC data form

4.3 Vulnerability Anisus vorticulus is a species of the upper water levels of ditches, frequently amidst botanically-rich vascular plant assemblages in a mid to upper mid successional state. It favours alkaline waters although it appears tolerant of a relatively wide range of physio-chemical parameters. Appropriate ditch management is the key to the conservation of this species. Control of shade-inducing marginal vegetation is also important, as is maintaining access to the water’s edge for livestock. It is also important to ensure good water quality by instigating the appropriate safeguards. This is being implemented through good environmental management, Catchment Sensitive Farming, Environmental Stewardship and Environment Agency’s review of existing discharge and abstraction consents. A Water Level Management Plan, devised and managed by Environment Agency, is in place to control ditch levels. Environmental Stewardship schemes continue to encourage sensitive management, particularly of the ditches to address problems brought about by neglect.

5. Site protection status and relation with CORINE biotopes:

5.1 Designation types at national and regional level Code % cover UK01 (NNR) 5.1 UK04 (SSSI/ASSI) 100.0

Pevensey Levels Natura 2000 Data Form Produced by JNCC., 27/07/11 Page 3

European Site Conservation Objectives for Pevensey Levels Special Area of Conservation Site code: UK0030367

With regard to the natural habitats and/or species for which the site has been designated („the Qualifying Features‟ listed below);

Avoid the deterioration of the qualifying natural habitats and the habitats of qualifying species, and the significant disturbance of those qualifying species, ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying features.

Subject to natural change, to maintain or restore:  The extent and distribution of qualifying natural habitats and habitats of qualifying species;  The structure and function (including typical species) of qualifying natural habitats and habitats of qualifying species;  The supporting processes on which qualifying natural habitats and habitats of qualifying species rely;  The populations of qualifying species;  The distribution of qualifying species within the site.

Qualifying Features:

S4056. Anisus vorticulus; Little whorlpool ram's-horn snail

Explanatory Notes: European Site Conservation Objectives

European Site Conservation Objectives are those referred to in the Conservation of Habitats and Species Regulations 2010 (the “Habitats Regulations”) and Article 6(3) of the Habitats Directive 1992. They are for use when either the appropriate nature conservation body or competent authority is required to make an Appropriate Assessment under the relevant parts of the respective legislation.

These conservation objectives are set for each habitat or species of a Special Area of Conservation (SAC). Where the objectives are met, the site can be said to demonstrate a high degree of integrity and the site itself makes a full contribution to achieving favourable conservation status for those features.

This document is also intended for those who are preparing information to be used for an appropriate assessment by either the appropriate nature conservation body or a competent authority. As such this document cannot be definitive in how the impacts of a project can be determined. Links to selected sources of information, data and guidance which may be helpful can be found on Natural England‟s website. This list is far from exhaustive.

European Community Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora (92/43/EEC)

Second Report by the United Kingdom under Article 17 on the implementation of the Directive from January 2001 to December 2006

Conservation status assessment for Species: S4056 - Anisus vorticulus - Little ramshorn whirlpool snail

The information in this assessment corresponds to the “species fact sheet” submitted by the UK to the European Union in February 2008 (second and final submission). Please note that this is a section of the UK’s report. For the complete report visit http://www.jncc.gov.uk/article17 Please cite as: Joint Nature Conservation Committee. 2007. Second Report by the UK under Article 17 on the implementation of the Habitats Directive from January 2001 to December 2006. Peterborough: JNCC. Available from: www.jncc.gov.uk/article17 Species Name: Anisus vorticulus

1. National level Species Code S4056 Member State United Kingdom Biogeographic regions concerned ATL within the Member state 1.1 Range map

1.2 Distribution map

2. Biogeographic level 2.1 Biogeographic region ATL 2.2 Published sources and/or ABRAHAM, F., ALLEN, S., HODGE, P. and WILLING, M.J. 1998. A websites survey of the flora and selected invertebrate groups of the ditches of the Lower Arun Valley. Arun Valley Countryside Project, Bognor Regis: Arun District Council, (unpublished report)

CURSON, S., FREED, T., GREENAWAY T., HODGE, P., RYLAND, K. & WILLING, M.J. 2003 Baseline Biological Survey of the Lower Ouse Valley (Tarring Neville, Southease & ). Sussex Record Centre Survey Unit. .

DOLPHIN ECOLOGICAL SURVEYS et al. 2002. Baseline Biological Survey of the Lower Ouse Valley. Report to English Nature, Lewes.

HICKLIN, A.J. 1986. An evaluation of the nature conservation status of the drainage system, . Wye Nature Conservancy Council.

HINGLEY, M.R. 1979. The colonisation of newly dredged drainage channels on the Pevensey level (East Sussex) with special reference to gastropods. London: Journal of Conchology. 30: 105 - 22.

HMSO, 1995a. Biodiversity: The UK Steering Group Report - Volume II: Action Plans. HMSO, London.

KERNEY, M. 1999. Atlas of the land and freshwater molluscs of Britain and Ireland. Harley Books.

KILLEEN, I.J. 2005. A Survey to determine the present status of Anisus vorticulus at sites in Suffolk and Norfolk. Report for Environment Agency.

KILLEEN, I.J. & WILLING, M.J. 1997. Survey of Ditches in East Anglia and South East England for the Freshwater Snails Segmentina nitida and Anisus vorticulus English Nature Research Report 229.

NIGGEBRUGGE, K., DURANCE, I., WATSON, A.M., LEUVEN, R.S.E.W. & ORMEROD, S.J. 2006. Dispersal and distribution in uncommon wetland gastropods: snail-trail or critical path? Unpublished.

WATSON, A. 2002. The Ecology of Four Scarce Wetland Molluscs – University of Wales, Cardiff PhD study Environment Agency R&D Project W1-038PR.

WATSON, A.M. & ORMEROD S.J. 2004a. The distribution of three uncommon freshwater gastropods in the drainage ditches of British grazing marshes.

WATSON, A.M. & ORMEROD S.J. 2004b. The microdistribution of three uncommon freshwater gastropods in the drainage ditches of British grazing marshes.

WILLING, M.J. & KILLEEN, I.J. 1998. The freshwater snail Anisus vorticulus in ditches in Suffolk, Norfolk and West Sussex. English Nature Research Reports, No. 287. Peterborough: English Nature.

WILLING, M.J. & KILLEEN, I.J. 1999. Anisus vorticulus – a rare & threatened water snail. British Wildlife, 10:6, pp 412-418.

WILLING, M.J. 1999. Monitoring populations of Anisus vorticulus the little whirlpool ramshorn snail in West Sussex, May - November 1998. English Nature Research Reports 310. Peterborough: English Nature.

WILLING, M.J. 2000a. A baseline molluscan survey of the RSPB Pulborough Brooks Reserve. Unpublished report for the Environment Agency, Worthing.

WILLING, M.J. 2000b. A molluscan survey of: 1. ditches adjacent to the middle River Arun & lower River Rother, West Sussex & 2. a monitoring ditch on Amberley Wildbrooks. Unpublished report for the Environment Agency, Worthing.

WILLING, M.J. 2001. Molluscan monitoring of two ditches on Amberley Wildbrooks, 2000. Unpublished report for the Environment Agency, Worthing.

WILLING, M.J. 2004. Monitoring populations of the little whirlpool ram’s- horn snail Anisus vorticulus (the little whirlpool ramshorn snail) at Pulborough Brooks and Amberley Wildbrooks June – September 2004. Unpublished report to the RSPB & Environment Agency (Worthing).

WILLING, M.J. 2005. Monitoring populations of Anisus vorticulus (the little whirlpool ramshorn snail) at Pulborough Brooks & Amberley Wildbrooks June – September 2004. An unpublished report to the RSPB and Environment Agency (Worthing).

WILLING, M.J. 2006. Monitoring, survey and translocation of populations of the little whirlpool ram’s-horn snail Anisus vorticulus at Pulborough Brooks, Amberley Wildbrooks and North Stoke June – November 2005. An unpublished report to the RSPB and Environment Agency (Worthing).

WILLING, M.J. 2006. A survey for the Little Whirlepool Ram’s-horn snail Anisus vortiulus and other freshwater Mollusca at North Stoke: June 2006 Unpublished report to DEFRA Guildfords and North Stoke Farm.

WILLING. M.J. 2007. The Survey & Monitoring of populations of the Little Whirlepool Ram’s-horn Snail on (a) the SWT Pevensey Levels Reserve and (b) Amberley Wildbrooks and Pulborough Brooks: May – June 2006. Sussex Biodiversity Records Centre Survey Unit. Woodsmill, Henfield.

WILLING, M.J. 2007. Monitoring populations of the Little Whirlpool Ram’s-horn Snail on Pevensey Levels April 2006. Environment Agency, Worthing.

Map Data Sources

Conchological Society - Mollusc (non-marine) data for Great Britain and Ireland; Natural England - Invertebrate Site Register (via the NBN Gateway).

Data from KILLEEN, I.J. 2005. A survey to determine the present status of Anisus vorticulus (Gastropoda: Planorbiidae) at sites in Suffolk and Norfolk. Unpublished report for the Environment Agency.

KILLEEN I.J. 1999. EN Species Recovery Programme: The freshwater snail Anisus vorticulus: 1998 monitoring survey of ditches in East Anglia. English Nature Research Reports No.311. Peterborough: English Nature.

KILLEEN, I.J. & WILLING, M.J. 1997. Survey of Ditches in East Anglia and South East England for the Freshwater Snails Segmentina nitida and Anisus vorticulus English Nature Research Report 229.

Natural England (A. Watson, pers. comm) compiled in 2000. 2.3 Range of species in the biogeographic region or marine region 2.3.1 Surface range of the species 967 (sq km) 2.3.2 Date of range determination 1998-2005 2.3.3 Quality of data concerning Moderate range 2.3.4 Range trend Stable (=) 2.3.5 Range trend magnitude (%) Not applicable 2.3.6 Range trend period 1994-2005 2.3.7 Reasons for reported trend Not applicable 2.4 Population 2.4.1 Population size estimation Minimum 7 Maximum 7 Units Other Occupied 10-km squares 2.4.2 Date of population 2002-2006 estimation 2.4.3 Method used for population 3 - From comprehensive inventory estimation 2.4.4 Quality of population data Good 2.4.5 Population trend Decreasing (-) 2.4.6 Population trend magnitude Unknown (%) 2.4.7 Population trend period 2002-2005 2.4.8 Reasons for reported trend 3 - Direct human influence; 5 - Natural processes; 2.4.9 Justification of % thresholds Not applicable for trends (optional) 2.4.10 Main pressures 802 - reclamation of land from sea, estuary or marsh; 804 - ; 910 - Silting up; 951 - drying out / accumulation of organic material; 2.4.11 Threats 141 - Abandonment of pastoral systems; 800 - Landfill, land reclamation and drying out, general; 802 - reclamation of land from sea, estuary or marsh; 804 - ; 830 - Canalisation; 890 - Other human induced changes in hydraulic conditions; 910 - Silting up; 951 - drying out / accumulation of organic material; 2.5 Habitat for the species in the biogeographic region or marine region 2.5 Habitats for the species Anisus vorticulus has only been found in the UK within grazing marshes which are drained by ditches, rhymes, dykes etc. It occurs in the unpolluted, calcareous waters of well-vegetated marsh drains and is occasionally found with other uncommon or vulnerable molluscs such as Valvata macrostoma and Pisidium pseudosphaerium and often found floating on the surface amongst duckweed (Lemna spp.). It also shows preference for ditches or channels of >3m in width and >1m in depth with a diverse flora but with a moderate emergent vegetative cover, and often occurs in ditches in wet fields that flood in winter, as this may be important in enabling young snails to colonise new ditches. 2.5.2 Area estimation (sq km) Unknown 2.5.3 Date of estimation 05/2007 2.5.4 Quality of data Poor 2.5.5 Trend of the habitat Decreasing (-) 2.5.6 Trend period 2002-2005 2.5.7 Reasons for reported trend 3 - Direct human influence; 2.6 Future prospects 2.6 Future prospects for the Poor prospects_Species likely to struggle unless conditions change species 2.7 Complementary information 2.7.1 Favourable reference range 967 (sq km) 2.7.2 Favourable reference 9 population 2.7.3 Suitable Habitat for the Unknown species 2.7.4 Other relevant information 2.8 Conclusions (assessment of conservation status at end of reporting period) (2.3) Range (FV) - Favourable (2.4) Population (U1-) - Inadequate and deteriorating (2.5) Habitat for the species (U1-) - Inadequate and deteriorating (2.6) Future prospects (U1) - Inadequate Overall assessment (U1-) - Inadequate and deteriorating

Information Sheet on Ramsar Wetlands (RIS) Categories approved by Recommendation 4.7 (1990), as amended by Resolution VIII.13 of the 8th Conference of the Contracting Parties (2002) and Resolutions IX.1 Annex B, IX.6, IX.21 and IX. 22 of the 9th Conference of the Contracting Parties (2005).

Notes for compilers: 1. The RIS should be completed in accordance with the attached Explanatory Notes and Guidelines for completing the Information Sheet on Ramsar Wetlands. Compilers are strongly advised to read this guidance before filling in the RIS.

2. Further information and guidance in support of Ramsar site designations are provided in the Strategic Framework for the future development of the List of Wetlands of International Importance (Ramsar Wise Use Handbook 7, 2nd edition, as amended by COP9 Resolution IX.1 Annex B). A 3rd edition of the Handbook, incorporating these amendments, is in preparation and will be available in 2006.

3. Once completed, the RIS (and accompanying map(s)) should be submitted to the Ramsar Secretariat. Compilers should provide an electronic (MS Word) copy of the RIS and, where possible, digital copies of all maps.

1. Name and address of the compiler of this form: FOR OFFICE USE ONLY. DD MM YY

Joint Nature Conservation Committee Monkstone House City Road Designation date Site Reference Number Peterborough Cambridgeshire PE1 1JY UK Telephone/Fax: +44 (0)1733 – 562 626 / +44 (0)1733 – 555 948 Email: [email protected]

2. Date this sheet was completed/updated: Designated: 02 February 1999 3. Country: UK (England) 4. Name of the Ramsar site: Pevensey Levels

5. Designation of new Ramsar site or update of existing site:

This RIS is for: Updated information on an existing Ramsar site

6. For RIS updates only, changes to the site since its designation or earlier update: a) Site boundary and area:

** Important note: If the boundary and/or area of the designated site is being restricted/reduced, the Contracting Party should have followed the procedures established by the Conference of the Parties in the Annex to COP9 Resolution IX.6 and provided a report in line with paragraph 28 of that Annex, prior to the submission of an updated RIS. b) Describe briefly any major changes to the ecological character of the Ramsar site, including in the application of the Criteria, since the previous RIS for the site:

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7. Map of site included: Refer to Annex III of the Explanatory Notes and Guidelines, for detailed guidance on provision of suitable maps, including digital maps. a) A map of the site, with clearly delineated boundaries, is included as: i) hard copy (required for inclusion of site in the Ramsar List): yes 9 -or- no ; ii) an electronic format (e.g. a JPEG or ArcView image) Yes iii) a GIS file providing geo-referenced site boundary vectors and attribute tables yes 9 -or- no ; b) Describe briefly the type of boundary delineation applied: e.g. the boundary is the same as an existing protected area (nature reserve, national park etc.), or follows a catchment boundary, or follows a geopolitical boundary such as a local government jurisdiction, follows physical boundaries such as roads, follows the shoreline of a waterbody, etc. The site boundary is the same as, or falls within, an existing protected area.

For precise boundary details, please refer to paper map provided at designation 8. Geographical coordinates (latitude/longitude): 50 50 30 N 00 20 32 E 9. General location: Include in which part of the country and which large administrative region(s), and the location of the nearest large town. Nearest town/city: Eastbourne Pevensey Levels is located on the Sussex coast between Eastbourne and Hastings. Administrative region: East Sussex

10. Elevation (average and/or max. & min.) (metres): 11. Area (hectares): 3577.71 Min. 1 Max. 5 Mean 3 12. General overview of the site: Provide a short paragraph giving a summary description of the principal ecological characteristics and importance of the wetland. Pevensey Levels is one of the largest and least-fragmented lowland wet grassland systems in south- east England. The low-lying grazing meadows are intersected by a complex system of ditches which support a variety of important wetland communities, including nationally rare and scarce aquatic plants and invertebrates. The site also supports a notable assemblage of breeding and wintering wildfowl. A small area of shingle and intertidal muds and sands is included within the site.

13. Ramsar Criteria: Circle or underline each Criterion applied to the designation of the Ramsar site. See Annex II of the Explanatory Notes and Guidelines for the Criteria and guidelines for their application (adopted by Resolution VII.11). 2, 3

14. Justification for the application of each Criterion listed in 13 above: Provide justification for each Criterion in turn, clearly identifying to which Criterion the justification applies (see Annex II for guidance on acceptable forms of justification). Ramsar criterion 2 The site supports an outstanding assemblage of wetland plants and invertebrates including many British Red Data Book species.

Ramsar criterion 3

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The site supports 68% of vascular plant species in Great Britain that can be described as aquatic. It is probably the best site in Britain for freshwater molluscs, one of the five best sites for aquatic beetles Coleoptera and supports an outstanding assemblage of dragonflies Odonata.

See Sections 21/22 for details of noteworthy species

15. Biogeography (required when Criteria 1 and/or 3 and /or certain applications of Criterion 2 are applied to the designation): Name the relevant biogeographic region that includes the Ramsar site, and identify the biogeographic regionalisation system that has been applied. a) biogeographic region: Atlantic b) biogeographic regionalisation scheme (include reference citation): Council Directive 92/43/EEC

16. Physical features of the site: Describe, as appropriate, the geology, geomorphology; origins - natural or artificial; hydrology; soil type; water quality; water depth, water permanence; fluctuations in water level; tidal variations; downstream area; general climate, etc.

Soil & geology basic, shingle, sand, mud, clay, alluvium, peat, nutrient- poor, sedimentary Geomorphology and landscape lowland, coastal, floodplain, shingle bar, open coast (including bay) Nutrient status eutrophic, mesotrophic pH circumneutral Salinity fresh Soil mainly mineral Water permanence usually permanent, usually seasonal / intermittent Summary of main climatic features Annual averages (Eastbourne, 1971–2000) (www.metoffice.com/climate/uk/averages/19712000/sites /eastbourne.html) Max. daily temperature: 13.7° C Min. daily temperature: 8.3° C Days of air frost: 15.9 Rainfall: 789.7 mm Hrs. of sunshine: 1848.6

General description of the Physical Features: No information available

17. Physical features of the catchment area: Describe the surface area, general geology and geomorphological features, general soil types, general land use, and climate (including climate type). No information available

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18. Hydrological values: Describe the functions and values of the wetland in groundwater recharge, flood control, sediment trapping, shoreline stabilization, etc. Shoreline stabilisation and dissipation of erosive forces, Recharge and discharge of groundwater, Flood water storage / desynchronisation of flood peaks, Maintenance of water quality (removal of nutrients) 19. Wetland types: Inland wetland, Marine/coastal wetland Code Name % Area Other Other 83.4 4 Seasonally flooded agricultural land 14 9 Canals and drainage channels 1.4 6 Reservoirs / barrages / dams 0.9 O Freshwater lakes: permanent 0.2 E Sand / shingle shores (including dune systems) 0.1

20. General ecological features: Provide further description, as appropriate, of the main habitats, vegetation types, plant and animal communities present in the Ramsar site, and the ecosystem services of the site and the benefits derived from them. Pevensey Levels supports a range of important communities of wetland flora and fauna. Various stages of succession are present in the ditches. Floating and submerged aquatic plants such as duckweeds Lemna spp., pondweeds Potamogeton spp. or water fern Azolla spp. represent the pioneer stages. These are followed by larger floating or emergent plants such as frogbit Hydrocharis morsus- ranae, bur-reed Sparganium erectum and arrow-head Sagittaria sagittifolia. Finally, common reed Phragmites australis or hawthorn Crataegus monogyna becomes dominant. Left undredged, the ditches lose their diversity and varied structure. A rich bankside flora is also present on site. An area of shingle and intertidal muds and sands is another important component of the site. Some flora associated with the shingle is present. For example, yellow horned-poppy Glaucium flavum and sea campion Silene uniflora.

The site supports outstanding invertebrate populations and is a top site for Mollusca and aquatic Coleoptera. Over 15 species of dragonfly (Odonata) have been recorded, including several scarce species. One of Britain's largest and rarest spiders, the fen raft spider Dolomides plantarius has its stronghold at Pevensey.

The lowland wet grassland supports a variety of bird species. For example, wintering lapwing and snipe. Breeding bird species include sedge warblers, reed warblers which nest in the scrub and reeds in the ditches respectively. Ecosystem services

21. Noteworthy flora: Provide additional information on particular species and why they are noteworthy (expanding as necessary on information provided in 12. Justification for the application of the Criteria) indicating, e.g. which species/communities are unique, rare, endangered or biogeographically important, etc. Do not include here taxonomic lists of species present – these may be supplied as supplementary information to the RIS. Nationally important species occurring on the site. Higher Plants.

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Althaea officinalis, Ceratophyllum submersum, Crambe maritima, Potamogeton acutifolius, Potamogeton friesii, Potamogeton trichoides, Sium latifolium, Stratiotes aloides 22. Noteworthy fauna: Provide additional information on particular species and why they are noteworthy (expanding as necessary on information provided in 12. Justification for the application of the Criteria) indicating, e.g. which species/communities are unique, rare, endangered or biogeographically important, etc., including count data. Do not include here taxonomic lists of species present – these may be supplied as supplementary information to the RIS. Birds

Species Information Nationally important species occurring on the site. Invertebrates. Segmentina nitida, Anisus vorticulus, Valvata macrostoma, Hydrophilus piceus, Gyrinus suffriani, Elmatophilus brevicollis, Bagous puncticollis, Dolomedes plantarius, Atylotus rusticus, Odontomyia ornata, Pherbellia argyra, Psacadina zernyi, Limophalia pictipennis, Tipula marginata, Placobdella costata

Assemblage of International importance The site supports an appreciable assemblage of rare, vulnerable or endangered species or sub- species of plant or animal. Pevensey Levels is probably one of the best sites in Great Britain for freshwater molluscs, one of the very best sites for aquatic Coleoptera and also supports an outstanding assemblage of Odonata.

23. Social and cultural values: Describe if the site has any general social and/or cultural values e.g. fisheries production, forestry, religious importance, archaeological sites, social relations with the wetland, etc. Distinguish between historical/archaeological/religious significance and current socio-economic values. Aesthetic Aquatic vegetation (e.g. reeds, willows, seaweed) Archaeological/historical site Environmental education/ interpretation Livestock grazing Non-consumptive recreation Scientific research Sport fishing Sport hunting Tourism Traditional cultural b) Is the site considered of international importance for holding, in addition to relevant ecological values, examples of significant cultural values, whether material or non-material, linked to its origin, conservation and/or ecological functioning? No

If Yes, describe this importance under one or more of the following categories: i) sites which provide a model of wetland wise use, demonstrating the application of traditional knowledge and methods of management and use that maintain the ecological character of the wetland: ii) sites which have exceptional cultural traditions or records of former civilizations that have influenced the ecological character of the wetland:

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iii) sites where the ecological character of the wetland depends on the interaction with local communities or indigenous peoples:

iv) sites where relevant non-material values such as sacred sites are present and their existence is strongly linked with the maintenance of the ecological character of the wetland:

24. Land tenure/ownership: Ownership category On-site Off-site Non-governmental organisation + (NGO) Local authority, municipality etc. + + Private + + Public/communal + +

25. Current land (including water) use: Activity On-site Off-site Nature conservation + + Tourism + + Recreation + Current scientific research + Fishing: recreational/sport + + Arable agriculture (unspecified) + + Permanent arable agriculture + + Permanent pastoral agriculture + + Hay meadows + + Hunting: recreational/sport + + Sewage treatment/disposal + + Flood control + Domestic water supply + +

26. Factors (past, present or potential) adversely affecting the site’s ecological character, including changes in land (including water) use and development projects:

Explanation of reporting category: 1. Those factors that are still operating, but it is unclear if they are under control, as there is a lag in showing the management or regulatory regime to be successful. 2. Those factors that are not currently being managed, or where the regulatory regime appears to have been ineffective so far.

NA = Not Applicable because no factors have been reported. Adverse Factor Category Description of the problem (Newly reported Factors only) Reporting Category On-Site Off-Site Major Impact? Introduction/invasion of 2 + + non-native plant species Pollution – domestic 2 + + sewage

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For category 2 factors only. What measures have been taken / are planned / regulatory processes invoked, to mitigate the effect of these factors? Introduction/invasion of non-native plant species - Floating pennywort Hydrocotyle ranunculoides: Strategy being worked up and research conducted into chemical treatment. Effective solution has not yet been found Crassula Crassula helmsii: Work currently being undertaken (October 2004) to remove Crassula by mechanical diggers.

Pollution – domestic sewage - Sewage Treatment Works: Phosphate-stripping has been introduced. Further study of pollution likely under the water company's Asset Management Plan AMP4.

Is the site subject to adverse ecological change? NO

27. Conservation measures taken: List national category and legal status of protected areas, including boundary relationships with the Ramsar site; management practices; whether an officially approved management plan exists and whether it is being implemented.

Conservation measure On-site Off-site Site/ Area of Special Scientific Interest + (SSSI/ASSI) National Nature Reserve (NNR) + Land owned by a non-governmental organisation + for nature conservation Management agreement + + Site management statement/plan implemented +

b) Describe any other current management practices: The management of Ramsar sites in the UK is determined by either a formal management plan or through other management planning processes, and is overseen by the relevant statutory conservation agency. Details of the precise management practises are given in these documents. 28. Conservation measures proposed but not yet implemented: e.g. management plan in preparation; official proposal as a legally protected area, etc. No information available 29. Current scientific research and facilities: e.g. details of current research projects, including biodiversity monitoring; existence of a field research station, etc. Contemporary.

A survey of Dolomedes plantarius is shortly to be undertaken, repeating the one done in 1990 (Jones 1990), to monitor its status. The National Nature Reserve is comprehensively monitored by English Nature and the . Completed.

Surveys of ditch flora, invertebrates, Odonata, Mollusca and Coleoptera have been carried out, as have routine river corridor surveys. Overwintering and breeding bird surveys have also been done by the RSPB. All these are likely to be repeated from time to time to monitor any changes.

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30. Current communications, education and public awareness (CEPA) activities related to or benefiting the site: e.g. visitor centre, observation hides and nature trails, information booklets, facilities for school visits, etc. The National Nature Reserve Site Managers lead guided walks on the NNRs, and teach students from local Universities and Schools. East Sussex County Council also have programmes for site visits by the general public. There are a few interpretive panels at Pevensey Castle. Future activities: There are proposals for a nature trail and further interpretive panels on the less sensitive parts of the NNR. In the long term, an interpretive centre may be set up. 31. Current recreation and tourism: State if the wetland is used for recreation/tourism; indicate type(s) and their frequency/intensity. Activities and facilities provided. Land-based recreation: Walking (including dog walking) and horse riding occur on the many public footpaths and bridleways. There is a golf course on the south-east corner. The roads within the site are used for recreational cycling. Two fields are used for the flying of radio-controlled model aircraft under time-limited conditions. Water based recreation: The Wallers Haven is occasionally used for rowing training by a local school. All the major Havens are used for angling. Hunting: There is a beagle pack located on the site which regularly hunts hares. The site is also used for occasional fox hunting and by bloodhounds. Illegal hunting of hare, and taking of eels also go on. A few owners have licences to shoot wildfowl. Facilities provided. The coastal area to the South of the Site has caravan parks and is used as a beach resort. Seasonality. Mainly during the summer months. Shooting is over winter. 32. Jurisdiction: Include territorial, e.g. state/region, and functional/sectoral, e.g. Dept. of Agriculture/Dept. of Environment, etc. Head, Natura 2000 and Ramsar Team, Department for Environment, Food and Rural Affairs, European Wildlife Division, Zone 1/07, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6EB 33. Management authority: Provide the name and address of the local office(s) of the agency(ies) or organisation(s) directly responsible for managing the wetland. Wherever possible provide also the title and/or name of the person or persons in this office with responsibility for the wetland. Site Designations Manager, English Nature, Sites and Surveillance Team, Northminster House, Northminster Road, Peterborough, PE1 1UA, UK 34. Bibliographical references: Scientific/technical references only. If biogeographic regionalisation scheme applied (see 15 above), list full reference citation for the scheme. Site-relevant references

Belden, P (1987) Pevensey Levels dragonflies. Nature Conservancy Council, Peterborough Bratton, JH (ed.) (1991) British Red Data Books: 3. Invertebrates other than insects. Joint Nature Conservation Committee, Peterborough Carr, R (1983) A survey of the aquatic Coleoptera of the Pevensey Levels. Nature Conservancy Council, Peterborough Clark, J & Murdoch, J (1997) Local knowledge and the precarious extension of scientific networks: a reflection on three case studies. Sociologia Ruralis, 37(1), 38-60

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Drake, M (1991) Ephemeroptera and Plecoptera in freshwater and brackish ditch systems on British grazing marshes. Entomologists Gazette, 42, 45-59 Dulley, AJF (1966) The Level and Port of Pevensey in the Middle Ages. Sussex Archaeological Collections, 104, 26-45 Environment Agency (1996) A fisheries management strategy for the Pevensey Levels. Environment Agency Southern Region Glading, PR (1986) A botanical survey of ditches on the Pevensey Levels. Nature Conservancy Council, Peterborough Hart, C & Douglas, S (1993) Nature conservation and the management of a drainage system habitat. Proceedings of the ICOLE Conference 1993 Hingley, MR (1979) The colonisation of newly-dredged drainage channels on the Pevensey Levels (East Sussex), with special reference to gastropods. Journal of Conchology, 30, 105-122 Hole, M (1998) Comment – What future in farming for wildlife? A farmer’s view from the Pevensey Levels. British Wildlife, 10(1), 9-11 Jones, E (1990) The status of Dolomedes plantarius on Pevensey Levels in August 1990. Nature Conservancy Council, Peterborough Keymer, RJ, Blake, C & Drake, M (1989) Pevensey Levels - final report: proposed boundary for renotification. Nature Conservancy Council, Peterborough Killeen, IJ (1994) A survey of the freshwater Mollusca of the Pevensey Levels East Sussex English Nature Research Report, No 124, Peterborough Lindsey, BI (1993) English Nature’s Pevensey Levels Wildlife Enhancement Scheme. Sussex Ornithological Newsletter, No. 125 (Summer 1993) Munday, R (1993) Pevensey Levels ditch survey. Sussex Wildlife Trust/Environment Agency, Worthing National Rivers Authority (1995) Pevensey Levels biological survey Summer 1994. National Rivers Authority (S) Science Group O'Neil, P & Beebee, TJC (2005) The great silver water beetle in Britain: a cry for help British Wildlife, 16(4), 265-269 Palmer, M (1984) A comparison of the flora and invertebrate fauna of watercourses in old pasture and arable land in the Pevensey Levels, Sussex. Nature Conservancy Council, Peterborough Palmer, M (1986) The impact of a change from permanent pasture to cereal farming on the flora and invertebrate fauna of watercourses in the Pevensey Levels, Sussex Proceedings of the EWRS/AAB Symposium on Aquatic Weeds Ratcliffe, DA (ed.) (1977) A Nature Conservation Review. The selection of biological sites of national importance to nature conservation in Britain. Cambridge University Press (for the Natural Environment Research Council and the Nature Conservancy Council), Cambridge (2 vols.) Rowland, S & Burges, D (1993) Pevensey Levels wintering bird surveys 1993. RSPB/English Nature/Environment Agency, Shoreham Salzmann, LF (1910) The inning of Pevensey Levels. Sussex Archaeological Collections, 53, 30-60 Shirt, DB (ed.) (1987) British Red Data Books: 2. Insects. Nature Conservancy Council, Peterborough Steel, C (1976) The ecology of Pevensey Levels in relation to the drainage system. Unpublished M.Sc dissertation, University of London Stewart, A, Pearman, DA & Preston, CD (eds.) (1994) Scarce plants in Britain. Joint Nature Conservation Committee, Peterborough Watson, AM & Ormerod, SJ (2004) The distribution of three uncommon freshwater gastropods in the drainage ditches of British grazing marshes. Biological Conservation, 118(4), 455–466 Wiggington, M (1999) British Red Data Books. 1. Vascular plants. 3rd edn. Joint Nature Conservation Committee, Peterborough Willis, J (1995) A contingent valuation study of the Pevensey Levels. English Nature, Peterborough Willis, J, Garrod, GD, Benson, JF & Carter, M (1996) Benefits and costs of the Wildlife Enhancement Scheme: A case study of the Pevensey Levels. Journal of Environmental Planning and Management, 39(3), 387-401

Please return to: Ramsar Secretariat, Rue Mauverney 28, CH-1196 Gland, Switzerland Telephone: +41 22 999 0170 • Fax: +41 22 999 0169 • email: [email protected]

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APPENDIX 2: CORRESPONDANCE

Barnhorn Green HRA 17 01 13 25 From: Marlow, Angela (NE) [mailto:[email protected]] Sent: 21 November 2012 12:25 To: Suzanne Mansfield Subject: Rother mixed development RR2012 1978 P

Dear Suzanne

Please find below our response regarding air quality, water quality and water levels in relation to Pevensey Levels and the proposed development:

Given the sensitivity of the site and the spatial scale of the impact Natural England would agree with the conclusion of the air quality assessment that there will be no adverse impact on the integrity of the Pevensey Levels SAC and Ramsar Site. However, we would make the following observations:

• The layout of the assessment did not make it easy to follow. It would be useful to have a table that clearly shows the Background, Process Contribution (PC), Predicted Environmental Contribution (PEC), Critical Level/Load (CL), PC as a % of CL.

• The use of footprint/contour maps would make it easier to assess the habitats impacted

• We would recommend the use of the acidity critical load function

• There is no mention of the Pevensey Levels Special Area of Conservation (SAC)”

The summary document for the application states that the impacts are scoped out in the ES and therefore there is no requirement for AA this is not correct given the existing critical levels and the contribution from the proposal is over 1% therefore there is a need for AA which is stated in the air quality chapter, and the test is then on whether the impact affects the integrity of the site. This assessment has been carried out and the conclusion is no effect which we agree on the conclusion however we have concerns with layout to enable the LA to follow the process that was untaken so that they can reach their conclusion.

Water quality and levels

I have spoken to both Jane Birch and Les Norman at EA, Les assures me that the scheme can allow the water levels and water quality that runs off from the development can be maintained at current levels and perhaps improve quality.

I believe he is going to supply you with conditions on this what we need to see in the AA is a summary of the SUDS scheme/ conditions etc that will reassurance us that this can be delivered, also including how potential issues during construction are to be addressed and how the SUDS scheme will be maintained through the life of the development. I hope this provides you with sufficient information please get back to me if you require any further input

Kind regards

Angela

This email and any attachments is intended for the named recipient only. If you have received it in error you have no authority to use, disclose, store or copy any of its contents and you should destroy it and inform the sender. Nothing in the email amounts to a legal commitment on our part unless confirmed by a signed communication. Whilst this email and associated attachments will have been checked for known viruses whilst within the Natural England systems, we can accept no responsibility once it has left our systems. Communications on Natural England systems may be monitored and/or recorded to secure the effective operation of the system and for other lawful purposes.

Marcus S. Wainwright-Hicks

Subject: FW: Bexhill development Attachments: Natural England Consultation Feedback_pub_0001.pdf

From: Marlow, Angela (NE) [mailto:[email protected]] Sent: 16 January 2013 09:28 To: Marcus S. Wainwright-Hicks Cc: Suzanne Mansfield Subject: RE: Bexhill development

Dear Marcus

Thank you for your email below which includes all the information that we require and we agree with the conclusions reached (Senior Advisor, and Land Management officer). Can I ask that the paragraph in the email below is added to the HRA in the air quality section so that the LA can see this and there is a complete record in the HRA as to why the conclusion of no affect on integrity was reached, as we are likely to see the HRA again from the LA for consultation it would be good to have a complete record.

I hope this is sufficient please let me know if you require anything in additional. Attached is our customer feedback if you have time we welcome your comments to help to improve the service you received.

Kind regards Angela

Angela Marlow Lead Advisor Sustainable Land Use Operations Natural England Guildbourne House, Chatsworth Road, Worthing, West Sussex BN11 1LD Tel: 0300 060 3893 Mob:07867 614451

Working hours Mon-Thurs.

Ways you can help us improve our service https://www.naturalengland.org.uk/

We are here to secure a healthy natural environment for people to enjoy, where wildlife is protected and England’s traditional landscapes are safeguarded for future generations.

In an effort to reduce Natural England's carbon footprint, I will, wherever possible, avoid travelling to meetings and attend via audio, video or web conferencing.

From: Marcus S. Wainwright-Hicks [mailto:[email protected]] Sent: 11 January 2013 15:36 To: Marlow, Angela (NE) Cc: Suzanne Mansfield Subject: RE: Bexhill development

Dear Angela,

1

Further to your recent query I have looked in more detail at the location of ditches adjacent to the A259.

As you point out the AQM demonstrated that the threshold for significance (1% of the critical load) was exceeded to a depth of 5m from the road. It is important to make clear that the air quality modelling (AQM) presented in the Habitat Regulations Assessment (HRA) uses the edge of the hard-standing surface of the road as the 0m point for each transect. On this basis I have investigated whether any ditches fall within 5m of the road edge. This has focused upon the section of A259 between transect 3 (x 567372, y 107905) and the roundabout where the A259 and A27 meet (x 565086, y 105104). Mastermap Ordinance Survey data in this area confirms that none of the roadside ditches lie within 5m of the road edge. Therefore, the ditches lie outside the area where the process contribution exceeds the threshold for significance. This is consistent with paragraphs 4.32 and 4.33 of the report, which highlight that the roadside habitats within 5m of the verge consist of rough grassland, scrub and hedgerows, rather than fen or grazing marsh. We therefore consider that the discussion presented in the HRA remains sufficient to conclude that there will be no adverse effect upon the integrity of the Pevensey Levels SAC / Ramsar as a result of altered nitrogen or acid deposition. Should you require I would be happy to make the minor amendments to the HRA report that are necessary to include the analysis presented above.

I trust this provides the clarification you require and would be grateful if you could confirm that the conclusions of the HRA are acceptable to Natural England. I should mention that our client is expecting to meet with the LPA on the 22nd January regarding this development. Therefore, should either yourself or the relevant land management officer have further queries then I would be very grateful if you could send them in advance of that date.

Regards,

Marcus

Marcus Wainwright-Hicks Senior Ecologist t: 01509 672772 m: 07800 856 282

From: Marlow, Angela (NE) [mailto:[email protected]] Sent: 09 January 2013 09:17 To: Marcus S. Wainwright-Hicks Subject: re: Bexhill development

Dear Marcus

A further clarification is required please see below:

This is easier to follow and makes better reading especially the tables.

In effect the critical load for nitrogen deposition is exceeded to a depth of 5m from the road. The road passes approx 5km through the designated site (most of it both sides of the road) so there is 5 ha that will have the CL for N deposition exceeded (5m x 2 x 5KM / 10,000). This is 2.5% of the 2 units in question (195 ha). Which is not insignificant.

However, the calculation have been based this on the most sensitive habitat – fen/swamp. Whereas much of this is likely to be grazing marsh and thus less sensitive. Looking at the map of the road it seems that there are drainage ditches alongside the road for most of its length, especially to the south. It is difficult to tell from webmap but it seems that these tend to be greater than 5m from the road. If this is the case then we would agree with your conclusions. If on the other hand the ditches are within this area where the CL is exceeded we would expect further comment.

2 I will also be following this up with our land management officer for their comments

Kind regards

Angela

Angela Marlow Lead Advisor Sustainable Land Use Operations Natural England

Guildbourne House,

Chatsworth Road,

Worthing,

West Sussex BN11 1LD Tel: 0300 060 3893 Mob:07867 614451

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3

Our ref: KT/2012/115340/01-L03 Rother District Council Your ref: RR/2012/1978/P Development Control Town Hall London Road Date: 30 November 2012 Bexhill-on-Sea East Sussex TN39 3JX

Dear Sir/Madam

MIXED-USE DEVELOPMENT COMPRISING 275 DWELLINGS, UP TO 3500 SQ M OF EMPLOYMENT FLOORSPACE COMPRISING UP TO 2750 SQ M OF B1(A) OFFICE AND UP TO 750 SQ M OF B1(C) LIGHT INDUSTRIAL, A NURSING HOME (USE CLASS C2) OF UP TO 60 BEDS, A DOCTORS SURGERY (USE CLASS D1) FOR UP TO 10 GPS, AND A ONE FORM ENTRY PRIMARY SCHOOL, TOGETHER WITH ASSOCIATED LANDSCAPING, DRAINAGE AND HIGHWAY INFRASTRUCTURE WORKS.

LAND NORTH OF BARNHORN ROAD & LAND WEST OF WILLOW DRIVE, BEXHILL

Thank you for your letter dated 22 October 2012. Please accept our apologies for the delayed response. I understand, however, that this application has not yet been determined. We have no objection to the proposal provided that the condition/s within this letter are imposed on any planning permission granted:

Conditions 1. No development shall take place until a surface water drainage scheme for the site, based on sustainable drainage principles and an assessment of the hydrological and hydrogeological context of the development, has been submitted to and approved in writing by the local planning authority.

The scheme shall also include: • details of how the scheme shall be maintained and managed after completion. • details of specific measures to minimise the risk of deterioration in water quality of receiving watercourses and waterbodies downstream (for both the construction and operational phases of the development).

The scheme shall subsequently be implemented in accordance with the

Environment Agency Orchard House (Endeavour Park) London Road, Addington, West Malling, ME19 5SH. Customer services line: 03708 506 506 www.environment-agency.gov.uk End

approved details before the development is completed.

Reason To reduce the risk of flooding, both on and off site, to improve and protect the water quality and improve habitat and amenity.

2. The development proposed shall only be carried out in accordance with the approved Environmental Statement (JB Planning Associates, 2012) and the following mitigation and enhancement measured detailed. Particular reference should be paid to the following section: • Paragraphs 8.162, 8.163 and 8.164 with reference to the ecological enhancement of attenuation ponds, and biodiversity gain. • Paragraphs 8.146 & 8.145 protecting the SSSI and Ramsar site Pevensey Levels. • Paragraph 8.166 with reference to a buffer zone around Picknell Green Stream. As detailed this should be a minimum of 5m and free from built development including, domestic gardens and formal landscaping. • Paragraph 8.212 highlighting the mitigation measures of habitats. • Paragraph 8.216 detailing a biodiversity management plan, and 8.168 detailing the Construction Environment Management Plan. Reason: This condition is supported by the National Planning Policy Framework (NPPF), paragraph 109 which recognises that the planning system should aim to conserve and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. Paragraph 118 of the NPPF also states that opportunities to incorporate biodiversity in and around developments should be encouraged. This is further supported in the Rother District LDF Policy EN5: Biodiversity and Green Space, which specifies that developments retain, protect and enhance ecological interests, including ancient woodland, water features and hedgerows.

Supporting text Flood Risk The drainage strategy should demonstrate the surface water run-off generated up to and including the 1 in 100 year critical storm (including an allowance for climate change) will not exceed the run-off from the undeveloped site following the corresponding rainfall event.

The site incorporates/is bounded by the Picknel Green Stream, a main river under our jurisdiction. Any works whatsoever in, over, or under the channel of this watercourse on its banks within 8 metres from the top of the channel, would require the prior consent from us under Section 109 of the Water Resources Act 1991 and/or Byelaws (known as Flood Defence Consent).

The flood defence consent will control works in, over, under or adjacent to main rivers (including any culverting). Any consent application must demonstrate that:

• there is no increase in flood risk either upstream or downstream • access to the main river network and sea/tidal defences for maintenance and improvement is not prejudiced. • works are carried out in such a way as to avoid unnecessary environmental End 2

damage. • Mitigation is likely to be required to control off site flood risk

We will not be able to issue our consent until this has been demonstrated.

Biodiversity The Natural Environment and Rural Communities Act requires Local Authorities to have regard to nature conservation and article 10 of the Habitats Directive which stresses the importance of natural networks of linked corridors to allow movement of species between suitable habitats, and promote the expansion of biodiversity.

The Pevensey Levels are a SSSI and Ramsar Site and therefore need to be protected. Under section 40 of the Natural Environment and Rural Communities (NERC) Act 2006 local planning authorities must have regard to purpose of conserving biodiversity.

Under the Wildlife and Countryside Act 1981 LPAs should take reasonable steps to further the conservation and enhancement of the flora, fauna or geological or physiographical features by reason of which the site is of special scientific interest.

NOTE: Special attention will be required to the water quality and ecological elements of the SUDS design to protect the downstream Pevensey Levels SSSI and Ramsar Site. The detailed design shall be in accordance with the approved Flood Risk Assessment, in particular Paragraph 5.5.2 "Water Quality and Ecological Measures".

DECISION NOTICE: Please forward a copy of the full decision notice to this office, quoting our reference number.

Please feel free to contact me if you have any further questions

Yours faithfully

Mr Pieter De Villiers Senior Planning Liaison Officer

Direct dial 01732 223246 Direct fax 01732 223289 Direct e-mail [email protected]

End 3

Habitat Regulaitons Assessment fpcr

APPENDIX 2: AIR QUALITY ASSESSMENT

Barnhorn Green HRA 17 01 13 27 Habitat Regulaitons Assessment fpcr

Analysis Without Link Road

The following provides relevant information of air quality modelling from Chapter 9 Air Quality and associated appendices of the Barnhorn Green Environmental statement (JB Planning Associates 2012).

Table 4: Oxides of Nitrogen Concentration

Distance Critical Grid Reference PC as % from Background PC PEC Level (X, Y) Cl Road (Cl)

Transect 1

0m 568724.7 107982.3 49.447 3.147 52.593 30.000 10.489

5m 568721.6 107978.2 36.846 2.175 39.021 30.000 7.250

15m 568715.7 107970.5 27.126 1.428 28.554 30.000 4.759

50m 568694.3 107942.2 17.758 0.694 18.452 30.000 2.315

100m 568664.2 107902.7 14.515 0.425 14.941 30.000 1.418

150m 568634.6 107863.6 13.184 0.310 13.494 30.000 1.032

200m 568603.7 107823.1 12.425 0.242 12.667 30.000 0.807

Transect 2

0m 567361.2 107914.2 50.837 3.373 54.209 30.000 11.243

5m 567357.4 107917.2 36.499 2.230 38.729 30.000 7.434

15m 567349.5 107923 25.654 1.355 27.010 30.000 4.518

50m 567321.4 107944.3 16.233 0.578 16.811 30.000 1.926

100m 567281.1 107974.5 13.217 0.317 13.534 30.000 1.057

150m 567240.8 108005.1 12.068 0.214 12.282 30.000 0.714

200m 567200.9 108035.3 11.480 0.161 11.641 30.000 0.537

Transect 3

0m 567372.6 107905.6 61.816 4.009 65.825 30.000 13.364

5m 567377.3 107902 43.901 2.680 46.580 30.000 8.933

15m 567389.0 107893.2 28.860 1.554 30.414 30.000 5.179

50m 567413.1 107875.0 20.359 0.906 21.265 30.000 3.019

100m 567452.8 107845.0 16.152 0.568 16.720 30.000 1.893

150m 567492.6 107815.2 14.376 0.416 14.792 30.000 1.386

200m 567532.2 107785.0 13.369 0.327 13.696 30.000 1.089

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Level Italics indicates a Process Contribution greater than 1% of the critical level

Barnhorn Green HRA 17 01 13 28 Habitat Regulaitons Assessment fpcr

Table 5: Rate of Nitrogen Deposition

Distance Critical PC as % Grid Reference from Background PC PEC Load of min (X, Y) Road (CL) CL

Transect 1

0m 568724.7 107982.3 16.955 0.125 17.080 10.000 1.247

5m 568721.6 107978.2 16.435 0.092 16.527 10.000 0.918

15m 568715.7 107970.5 16.013 0.063 16.076 10.000 0.632

50m 568694.3 107942.2 15.587 0.032 15.619 10.000 0.320

100m 568664.2 107902.7 15.435 0.020 15.455 10.000 0.199

150m 568634.6 107863.6 15.372 0.015 15.386 10.000 0.147

200m 568603.7 107823.1 15.335 0.012 15.347 10.000 0.121

Transect 2

0m 567361.2 107914.2 16.994 0.133 17.126 10.000 1.325

5m 567357.4 107917.2 16.405 0.094 16.499 10.000 0.944

15m 567349.5 107923 15.931 0.061 15.992 10.000 0.606

50m 567321.4 107944.3 15.500 0.027 15.527 10.000 0.269

100m 567281.1 107974.5 15.358 0.015 15.373 10.000 0.147

150m 567240.8 108005.1 15.305 0.010 15.315 10.000 0.095

200m 567200.9 108035.3 15.277 0.008 15.285 10.000 0.078

Transect 3

0m 567372.6 107905.6 17.418 0.150 17.568 10.000 1.498

5m 567377.3 107902 16.714 0.109 16.823 10.000 1.091

15m 567389 107893.2 16.075 0.068 16.142 10.000 0.676

50m 567413.1 107875 15.691 0.042 15.733 10.000 0.416

100m 567452.8 107845 15.496 0.027 15.523 10.000 0.269

150m 567492.6 107815.2 15.413 0.020 15.433 10.000 0.199

200m 567532.2 107785 15.365 0.016 15.381 10.000 0.156

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Load Italics indicates a Process Contribution greater than 1% of the Critical Load

Barnhorn Green HRA 17 01 13 29 Habitat Regulaitons Assessment fpcr

Table 6: Rate of Acid Deposition

Distance Critial PC as % Grid Reference from Background PC PEC Load of min (X, Y) Road (CL) CL

Transect 1

0m 568724.7 107982.3 1.211 0.009 1.220 0.807 1.104

5m 568721.6 107978.2 1.174 0.007 1.181 0.807 0.813

15m 568715.7 107970.5 1.144 0.005 1.148 0.807 0.560

50m 568694.3 107942.2 1.113 0.002 1.116 0.807 0.284

100m 568664.2 107902.7 1.102 0.001 1.104 0.807 0.176

150m 568634.6 107863.6 1.098 0.001 1.099 0.807 0.130

200m 568603.7 107823.1 1.095 0.001 1.096 0.807 0.107

Transect 2

0m 567361.2 107914.2 1.214 0.009 1.223 0.807 1.173

5m 567357.4 107917.2 1.172 0.007 1.179 0.807 0.836

15m 567349.5 107923.0 1.138 0.004 1.142 0.807 0.537

50m 567321.4 107944.3 1.107 0.002 1.109 0.807 0.238

100m 567281.1 107974.5 1.097 0.001 1.098 0.807 0.130

150m 567240.8 108005.1 1.093 0.001 1.094 0.807 0.084

200m 567200.9 108035.3 1.091 0.001 1.092 0.807 0.069

Transect 3

0m 567372.6 107905.6 1.244 0.011 1.255 0.807 1.326

5m 567377.3 107902.0 1.194 0.008 1.202 0.807 0.966

15m 567389 107893.2 1.148 0.005 1.153 0.807 0.598

50m 567413.1 107875.0 1.121 0.003 1.124 0.807 0.368

100m 567452.8 107845.0 1.107 0.002 1.109 0.807 0.238

150m 567492.6 107815.2 1.101 0.001 1.102 0.807 0.176

200m 567532.2 107785.0 1.098 0.001 1.099 0.807 0.138

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Load Italics indicates a Process Contribution greater than 1% of the Critical Load

Barnhorn Green HRA 17 01 13 30 Habitat Regulaitons Assessment fpcr

Analysis with Link Road

Table 7: Oxides of Nitrogen Concentration

Distance Critical Grid Reference PC as % from Background PC PEC Level (X. Y) CL Road (CL)

Transect 1

0m 568725 107982 49.412 3.334 52.746 30.000 11.112

5m 568722 107978 36.822 2.304 39.126 30.000 7.682

15m 568716 107970 27.110 1.513 28.623 30.000 5.044

50m 568694 107942 17.750 0.736 18.486 30.000 2.454

100m 568664 107903 14.510 0.451 14.961 30.000 1.504

150m 568635 107864 13.181 0.329 13.509 30.000 1.096

200m 568604 107823 12.422 0.257 12.679 30.000 0.857

Transect 2

0m 567361 107914 50.800 3.573 54.373 30.000 11.911

5m 567357 107917 36.475 2.363 38.837 30.000 7.876

15m 567350 107923 25.639 1.436 27.076 30.000 4.788

50m 567321 107944 16.227 0.612 16.839 30.000 2.041

100m 567281 107974 13.213 0.336 13.549 30.000 1.121

150m 567241 108005 12.065 0.227 12.292 30.000 0.757

200m 567201 108035 11.478 0.171 11.649 30.000 0.569

Transect 3

0m 567373 107906 61.773 4.246 66.019 30.000 14.155

5m 567377 107902 43.871 2.839 46.710 30.000 9.464

15m 567389 107893 28.843 1.646 30.490 30.000 5.488

50m 567413 107875 20.349 0.960 21.309 30.000 3.199

100m 567453 107845 16.145 0.602 16.747 30.000 2.006

150m 567493 107815 14.371 0.441 14.812 30.000 1.470

200m 567532 107785 13.365 0.346 13.712 30.000 1.155

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Level Italics indicates a Process Contribution greater than 1% of the Critical Level

Barnhorn Green HRA 17 01 13 31 Habitat Regulaitons Assessment fpcr

Table 8: Rate of Nitrogen Deposition

Distance Critical PC as % Grid Reference from Background PC PEC Load of min (X, Y) Road (CL) CL

Transect 1

0m 568725 107982 16.954 0.132 17.086 10.000 1.317

5m 568722 107978 16.435 0.098 16.532 10.000 0.979

15m 568716 107970 16.012 0.068 16.079 10.000 0.676

50m 568694 107942 15.586 0.035 15.620 10.000 0.346

100m 568664 107903 15.434 0.022 15.456 10.000 0.217

150m 568635 107864 15.372 0.016 15.387 10.000 0.156

200m 568604 107823 15.335 0.012 15.347 10.000 0.121

Transect 2

0m 567361 107914 16.992 0.141 17.133 10.000 1.412

5m 567357 107917 16.404 0.100 16.503 10.000 0.996

15m 567350 107923 15.931 0.064 15.995 10.000 0.641

50m 567321 107944 15.500 0.029 15.528 10.000 0.286

100m 567281 107974 15.358 0.016 15.374 10.000 0.156

150m 567241 108005 15.305 0.010 15.316 10.000 0.104

200m 567201 108035 15.277 0.009 15.285 10.000 0.087

Transect 3

0m 567373 107906 17.416 0.159 17.575 10.000 1.585

5m 567377 107902 16.713 0.115 16.828 10.000 1.152

15m 567389 107893 16.074 0.072 16.146 10.000 0.719

50m 567413 107875 15.691 0.043 15.734 10.000 0.433

100m 567453 107845 15.496 0.028 15.524 10.000 0.277

150m 567493 107815 15.413 0.021 15.434 10.000 0.208

200m 567532 107785 15.365 0.016 15.382 10.000 0.165

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Load Italics indicates a Process Contribution greater than 1% of the Critical Load

Barnhorn Green HRA 17 01 13 32 Habitat Regulaitons Assessment fpcr

Table 9: Rate of Acid Deposition

PC as % Distance Critial of min from X Y Background / Existing PC PEC Load critical Road (CL) load

Transect 1

0a 568725 107982 1.211 0.009 1.220 0.807 1.165

5a 568722 107978 1.174 0.007 1.181 0.807 0.866

15a 568716 107970 1.144 0.005 1.149 0.807 0.598

50a 568694 107942 1.113 0.002 1.116 0.807 0.307

100a 568664 107903 1.102 0.002 1.104 0.807 0.192

150a 568635 107864 1.098 0.001 1.099 0.807 0.138

200a 568604 107823 1.095 0.001 1.096 0.807 0.107

Transect 2

0b 567361 107914 1.214 0.010 1.224 0.807 1.250

5b 567357 107917 1.172 0.007 1.179 0.807 0.882

15b 567350 107923 1.138 0.005 1.143 0.807 0.567

50b 567321 107944 1.107 0.002 1.109 0.807 0.253

100b 567281 107974 1.097 0.001 1.098 0.807 0.138

150b 567241 108005 1.093 0.001 1.094 0.807 0.092

200b 567201 108035 1.091 0.001 1.092 0.807 0.077

Transect 3

0c 567373 107906 1.244 0.011 1.255 0.807 1.403

5c 567377 107902 1.194 0.008 1.202 0.807 1.020

15c 567389 107893 1.148 0.005 1.153 0.807 0.636

50c 567413 107875 1.121 0.003 1.124 0.807 0.383

100c 567453 107845 1.107 0.002 1.109 0.807 0.245

150c 567493 107815 1.101 0.001 1.102 0.807 0.184

200c 567532 107785 1.098 0.001 1.099 0.807 0.146

PC, Process Contribution, the amount contributed by the proposals PEC; Predicted Environmental Concentration, equal to background level plus the Process Contribution Bold text indicates exceedence above the Critical Load Italics indicates a Process Contribution greater than 1% of the Critical Load

Barnhorn Green HRA 17 01 13 33