Preliminary Ecological Appraisal

Saxon Brickworks, Peterborough Road, Whittlesey

Project No: HSPCo04 Client: Johnsons Aggregates Date: 15/02/2021

HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

ISSUE RECORD

Client name Johnsons Aggregates

Project name Saxon Brickworks, Peterborough Road, Whittlesey

Project number HSPCo04

Report title Preliminary Ecological Appraisal

Issue number 1

Date 15/02/2021

Written by Jessica Eades BSc (Hons), MCIEEM Technical Director

Checked by Chloe Pritchard BSc (Hons) MCIEEM Principal Ecologist

Approved by Jonathan Brickland BSc (Hons) MSc CEnv MCIEEM Director

The information and advice contained in this report has been prepared and provided in accordance with the Chartered Institute of Ecology and Environmental Management’s Code of Professional Conduct. We confirm that the opinions expressed are our true and professional bona fide opinions.

Peak Ecology is accredited under ISO9001 and as such this report follows the styles and formatting template set out within our Quality Management Form

ISO9001 QMF 32 Issue 1 Reviewed 04/03/2016

Peak Ecology Limited Arden House Deepdale Business Park Bakewell Derbyshire DE45 1GT 01629 812511

www.peakecology.co.uk

Page i HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

EXECUTIVE SUMMARY

Overview

This report has been prepared by Peak Ecology Ltd on behalf of Johnsons Aggregates. Peak Ecology Limited was instructed on 28th January 2021 via HSP Consulting on behalf of Johnsons Aggregates to provide ecological advice after receiving a scoping opinion from Cambridgeshire County Council. The scoping opinion related to a planning application for the proposed importation, storage, processing (including use of trommel), picking and recycling of up to 500,000 Tonnes per annum (TPA) Of Incinerator Bottom Ash (IBA) and construction and demolition (C&D) waste, for exportation for use ss Incinerator Bottom Ash Secondary Aggregates (IBAA) at Saxon Brickworks, Peterborough Road, Whittlesey, Cambridgeshire, PE7 1PJ. The site comprises an approximately 5.10ha area of land situated between Peterborough and Whittlesey (central grid reference: TL 2546 9714) on the southern side of the A605 (Peterborough Road) in a former quarried area. Designated Sites

Three international designated sites fall within the 10km search radius around the study area. The study area falls within the Nene Washes SSSI Impact Risk Zone and also an area highlighted by Natural England as the Nene Washes Goose & Swan Functional Land Impact Risk Zone within City of Peterborough. Four non-statutory designated sites: County Wildlife Sites (CWS) have been identified within the 2km study area all situated to the north of the study area. The access road from the A605 into the proposed processing facility lies within a 200m buffer zone established for the Kings Dyke Nature Reserve. Habitats

Much of the study area is of low ecological value due to the extent of hardstanding, buildings and disturbed bare ground. However, the vegetated habitats as outlined below, offer moderate to good ecological value. All areas of woodland appear to be retained within the proposed development, whilst there will be a loss of scrub and tall ruderal habitat. The proposed development will result in the loss of approximately 0.47ha of ephemeral / short perennial vegetation considered highly likely to qualify as the UK BAP and local priority habitat “open mosaic habitat on previously disturbed ground”, although the wider area of this habitat will remain intact. At the time of writing, it is assumed that all ditches and associated marginal and inundation vegetation are to be retained within the proposed development.

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Protected Species

Vegetated areas of the site have the potential to support the following protected and priority species;

• Amphibians – including great crested newt; • Badger; • Water vole; • Breeding birds; and • Reptiles.

Impacts to bats were considered, but have been considered negligible for roosting, foraging and commuting habitats.

Implications and Recommendations

The proposals indicate no soft landscaping, so all habitat loss is assumed to be replaced with hard surfaces. There will be net loss of habitat associated with this proposed development. Increased vehicle movement associated with the proposals may have an adverse impact on woodland bird species along the access route from the A605 into the processing facility. Much of the development of the site will have negligible impact on ecology at the site level due to the dominance of hard standing, building and disturbed bare ground. This area in latter parts of the report is referred to as the Phase 1 development area, with vegetated areas with higher ecological value and likely to support protected and priority species referred to as the Phase 2 development area. A number of additional ecological surveys are recommended to further assess impacts of the proposed Phase 2 development area as outlined in Figure 8. These surveys are designed to further refine recommendations outlined later within this report;

• Great crested newt – eDNA survey;

• Water Vole Survey; and

• Biodiversity Net Gain Calculations.

A number of reasonable avoidance measures, mitigation and compensation measures have been included within the report and where appropriate, worst case scenarios have been outlined to inform an appropriate way forward to minimise impacts to protected and priority species and habitats.

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CONTENTS PAGE

1 INTRODUCTION ...... 1 1.1 Scope of Report ...... 1 1.2 Site Description ...... 1 1.3 Zone of Influence ...... 2 1.4 Planning Context ...... 2

2 METHODOLOGY ...... 4 2.1 Desk Study ...... 4 2.2 Phase 1 Habitat Survey ...... 4 2.3 Protected and Priority Species ...... 5 2.4 Limitations ...... 5

3 RESULTS ...... 8 3.1 Desk Study ...... 8 3.2 Phase 1 Habitat Survey ...... 18 3.3 Protected and Priority Species ...... 23

4 EVALUATION OF FEATURES WITHIN THE STUDY AREA ...... 31 4.1 Designated sites ...... 31 4.1 Habitats & Botanical Interest ...... 31 4.1 Protected and Priority Species ...... 33

5 ASSESSMENT OF IMPACTS ...... 36 5.1 Development Proposals ...... 36 5.2 Potential Impacts associated with the proposals ...... 36 5.1 Designated Sites ...... 38 5.2 Summary of study area assessment ...... 39 5.1 Habitats & Botanical Interest ...... 41 5.2 Protected and Priority Species ...... 41

6 RECOMMENDATIONS...... 46 6.1 Further Survey / assessment ...... 46 6.2 Mitigation/Compensation Measures and Reasonable Avoidance Measures ...... 47 6.3 Bats ...... 49 6.4 Badger ...... 49 6.5 Water vole ...... 50 6.6 Breeding birds ...... 50 6.7 Reptiles ...... 51

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6.8 Ecological Enhancement ...... 51

7 OUTLINE SUMMARY OF FURTHER WORKS REQUIRED ...... 52

8 REFERENCES ...... 53 APPENDIX A : Protected and Priority Species ...... 55 APPENDIX B : Relevant Legislation ...... 57 APPENDIX C : Methodologies ...... 62 APPENDIX D : Information to inform an Appropriate Assessment in respect of the proposed Saxon Brickworks development ...... 64 APPENDIX E : Site Photographs ...... 74 APPENDIX F : Target Notes ...... 79 APPENDIX G : Habitat Suitability Index ...... 81

LIST OF TABLES

Table 1: Designated sites identified during the desk study ...... 8 Table 2: Summary of protected and priority species records relevant to the site and/or proposals ..... 12 Table 3: Description of structures present within the study area and their potential to support roosting bats. ……………………………………………………………………………………………………………26 Table 4: Natural England Rapid Risk Assessment – accounting only for habitat suitable for amphibians ...... 42 Table 5: Outline summary of further works required ...... 52

LIST OF FIGURES

Figure 1: Location Map* ...... 2 Figure 2: International and National Designated Sites ...... 10 Figure 3: Local Designated Sites ...... 11 Figure 4: Ponds within the zone of influence with known great crested newt breeding populations .... 15 Figure 5: Natural England identified and mapped Priority Habitats in and around the study area ...... 17 Figure 6: Phase 1 habitat survey of the study area ...... 22 Figure 7: Ponds within the 250m and 500m zone of influence for great crested newts ...... 25 Figure 8: Proposed Ecological Phasing of the development ...... 40

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1 INTRODUCTION

1.1 Scope of Report This report has been prepared by Peak Ecology Ltd on behalf of Johnsons Aggregates. Peak Ecology Limited was instructed on 28th January 2021 via HSP Consulting on behalf of Johnsons Aggregates to provide ecological advice after receiving a scoping opinion from Cambridgeshire County Council. The scoping opinion related to a planning application for the proposed importation, storage, processing (including use of trommel), picking and recycling of up to 500,000 Tonnes per annum (TPA) Of Incinerator Bottom Ash (IBA) and construction and demolition (C&D) waste, for exportation for use ss Incinerator Bottom Ash Secondary Aggregates (IBAA) at Saxon Brickworks, Peterborough Road, Whittlesey, Cambridgeshire, PE7 1PJ. This report provides the results of a Preliminary Ecological Appraisal associated with the proposed development at Saxon Brickworks. The purpose of this report is to: • Describe the ecological baseline of the site, including existing habitats, scoping for the potential presence of protected and priority species (see Appendix A for description) and nearby designated sites;

• Highlight potential significant ecological impacts associated with the proposals;

• Identify suitable mitigation measures and how they will be secured;

• Assess the significance of any residual impacts;

• Highlight opportunities for ecological enhancement where appropriate; and

• Set out requirements for post-construction monitoring, where required.

In relation to planning and development, this report should be read in conjunction with the reports from other disciplines and any additional ecological surveys that are recommended as a result of the findings of this appraisal. This report has been used to highlight, to the client and the wider project team, ecological constraints associated with the proposed development. Latter parts of the report suggest the splitting of the site into two phases due to ecological constraints. The approach to this ecological appraisal follows best practice published by the Chartered Institute of Ecology and Environmental Management (CIEEM, 2013 & 2015) and the British Standards Institution (BSI, 2013). Details of individual survey methods and associated supporting information are provided in Section 2.

1.2 Site Description The site comprises an approximately 5.10ha area of land situated between Peterborough and Whittlesey (central grid reference: TL 2546 9714) on the southern side of the A605 (Peterborough Road) in a former quarried area. The site is the location of the former Saxon Brickworks, and a number of the original brickworks buildings, at least one of the chimney / kilns, was still present at the time of reporting. Following the cessation of the brickworks in

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November 2011 and a short period of dormancy, the site has then used as a Plastic Recovery Facility following a successful planning permission application in 2012. The survey boundary is as per the redline boundary provided by the HSP Consulting at the time of the preparation of the fee proposal. The site location is illustrated below.

Figure 1: Location Map*

Site

1.3 Zone of Influence The geographical extent of the potential impact of a proposed development is known as the Zone of Influence. The Zone is determined by the nature of the development and also in relation to individual species, depending on their habitat requirements, mobility and distances indicated in any best practice guideline.

1.4 Planning Context The National Planning Policy Framework 2019 requires that when assessing a planning application all Local Planning Authorities (LPAs) must consider potential impacts on biodiversity that may result from the proposals. In addition to this, county and borough councils typically have biodiversity policies within their Local Development Frameworks that they must also comply with. In practice, this means that potential impacts on designated sites, notable species and habitats such as those listed on the UK Post-2010 Biodiversity Framework (formerly the UK Biodiversity Action Plan) and species that receive legal direct protection (typically via the Conservation of Habitats and Species Regulations 2017 and/or the Wildlife and Countryside Act 1981 (as amended)) are all material planning considerations.

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In relation to European Protected Species, the LPA requires sufficient information about likely impacts and mitigation or compensatory measures to satisfy the three Habitats Directive tests, the most relevant to ecological reports being that which relates to the Favourable Conservation Status of the species in question. Appendix A provides a definition of “protected or priority species” for the purposes of this report, and Appendix B provides details on the legislation for species relevant to this site. The Cambridge and Peterborough Biodiversity Group website was reviewed to identify those priority species that have been highlighted as being locally present within the area, along with identifying 16 UK Priority Habitats found in Cambridge and Peterborough.

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2 METHODOLOGY

2.1 Desk Study The desk study comprised a review of existing information held regarding the site. The local biological records centre: Cambridgeshire and Peterborough Environmental Records Centre (CPERC) was contacted to provide existing records of protected or priority species within 2km of the site.

To support the field survey and compile existing baseline information relevant to the site, the online resource, Multi-Agency Geographic Information for the Countryside (MAGIC) website (www.magic.gov.uk) was consulted.

The search area of interest varied depending upon the likely significance and zone of influence of the bird data identified, as follows:

• A minimum of a 10km radius around the site was searched for sites with an international statutory designation; Special Area of Conservation (SAC), Special Protection Area (SPA) and Ramsar sites;

• A minimum of a 2km radius around the site for sites of national/regional importance with a statutory designation of Site of Special Scientific Importance (SSSI) or National Nature Reserve (NNR);

• Up to a 1km radius around the site for sites of local importance with statutory designation of Local Nature Reserve (LNR), or non-statutory designation of Site of Importance for Nature Conservation (SINC) or the equivalent Local Wildlife Site (LWS); and

• Review notable / protected bird species (i.e. including Species of Principal Importance under S41 of the Natural Environment and Rural Communities Act (NERC) 2006 and local biodiversity action plan species.

The desk study also comprised a review of Species of Principal Importance under S41 of the Natural Environment and Rural Communities Act (NERC) 2006 and local biodiversity action plan (LBAP) priority habitats and species.

2.2 Phase 1 Habitat Survey The survey was undertaken on 29th January 2021 by Technical Director, Jessica Eades BSc (Hons) MCIEEM. Jessica has been a professional ecologist for over 14 years and is experienced in the use of the Phase 1 Habitat Survey methodology, identification of vascular plants and scoping assessments for protected species. She is appropriately qualified for this type of survey based on the CIEEM competency framework (CIEEM, 2012). Following standard methodology (JNCC, 2010) the survey comprised a walkover of the site to classify and map the extent of individual habitat types, based on the identification of

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

individual plant species. Any evidence of invasive plants such as Japanese knotweed Fallopia japonica was also noted. Nomenclature for vascular plant species follows Stace (2010).

2.3 Protected and Priority Species The habitats present were assessed for their potential to support any legally protected or otherwise notable species and any incidental sightings or field signs discovered during the surveys were recorded. All British wildlife and countryside legislation, policy and guidance were taken into consideration including; • The Wildlife and Countryside Act 1981 (as amended);

• The Conservation of Habitats and Species Regulations 2017 (as amended);

• EC Council Directive on the Conservation of Wild Birds 79/409/EEC;

• The Protection of Badgers Act 1992;

• The Countryside and Rights of Way Act 2000;

• The Hedgerow Regulations 1997;

• The Natural Environment and Rural Communities Act 2006; and

• The UK Post-2010 Biodiversity Framework (formerly known as UK BAP).

Appendix B provides greater detail on the legislation context relevant to this site.

In the case of bats, specific assessment methods have been adopted as the industry standard and these were followed during the survey, see Appendix C for detailed methodologies. A Preliminary Bat Roost Assessment of all buildings and trees on site was undertaken at the same time as the Phase 1 Habitat Survey by Jessica, who is suitably experienced in the survey methodology. ecology and of UK bat species. Jessica is registered to use the Natural England Level 2 Class Licence WML-CL18 (registration number 2015-16543-CLS-CLS), and has extensive experience of evaluating impact to bats, preparing appropriate mitigation strategies and applying for Natural England mitigation (derogation) licences. Jessica is also a Registered Consultant able to register sites, when this is an appropriate approach to take, under the Natural England Bat Mitigation Class Licence (WML-CL21), formerly referred to as the Bat Low Impact Class Licence.

2.4 Limitations

3rd Party Data Desk study data obtained for this assessment is provided and validated by third parties therefore Peak Ecology have no control over any errors within the dataset. The data

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

represents the information available at the date of request and a lack of records for any particular species does not necessarily indicate absence from the local area as many species are under-recorded. Bat data from CPERC originating from the Cambridgeshire Bat Group had been degraded to 1km square resolution at the request of the bat group. Badger records from CPERC originating from the Cambridgeshire Mammal Group were also degraded (to 10km square resolution) at the request of the mammal group.

Survey Methods Habitats: Based on the identification of individual plant species, the Phase 1 Habitat Survey provides sufficient information to enable classification of broad habitat types; however, it does not constitute a detailed botanical survey. Plant species lists compiled by this type of survey should not be considered definitive as not all species will be apparent at all times of year. Protected and Priority Species: No significant survey limitations were encountered, however, it should be noted that surveys only provide a snapshot of the activity on a site within the time spent on site, surveys are therefore designed to provide as best an indication of the site’s function for protected and priority species as possible based on the data gathered/available.

Access All of the site was accessible during the surveys, however, the redline boundary of the development was slightly altered since the Phase 1 habitat survey was undertaken. The largest, notable difference was the inclusion of the access road from the A605 leading south into the main area of the development in to the redline boundary. As such, some habitats that are located outside of the redline boundary were not fully assessed to establish a full species list or habitat condition. These areas are highlighted within the text under the relevant habitat classification. All habitats within the redline boundary as it stood at the time of the survey were fully assessed, and suitable habitat classifications could be made of those habitats immediately outside the redline boundary. The above was not considered to be a significant limitation to the survey.

Survey Timing and Conditions Whilst January is outside of the main plant growing season, due to the highly disturbed nature of the existing operational site, it was considered that habitats could be identified accurately within the JNCC habitat categories. Those habitats that have been considered to potentially have higher ecological and botanical value have been highlighted within the report for recommending additional survey effort. During January 2021 nationwide flooding events were experienced. Whilst the conditions on the day of the survey were cool, dry and sunny with mild to moderate winds, there were two areas of localised surface flooding. The flooding was associated with on-site drainage ditches and had a water to a depth of around 30cm. These areas have been highlighted within mapping associated with the Phase 1 Habitat Survey Map. Smaller, shallow areas of

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surface water were encountered throughout the site, however these were not mapped as it was felt that these were a result of the overnight rainfall, rather than prolonged periods of rain in the weeks preceding the site visit. Ditches were observed from a slight distance using binoculars to assess habitats and botanical species identification due to health and safety concerns regarding the depth of water and loose bank material as a result of the high water levels.

Lifespan of Data The results and recommendations contained within this report are considered to be valid for up to two years from the date of survey, assuming that there are no significant changes to the site condition or management within this period. After this period, or should the site conditions change, an update may be required in order to inform ecological constraints to development proposals and/or accompany a planning submission.

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3 RESULTS

3.1 Desk Study

Designated Sites Three international designated sites fall within the 10km search radius around the study area. Nene Washes Special Area of Conservation (SAC) follows the route of Morton’s Lean drain, with the multi-designated Nene Washes Ramsar Site, Special Protection Area (SPA) and Site of Special Scientific Interest (SSSI), which forms a larger area to the north of the SAC designated area. Orton Pit SAC falls within the outer limit of the 10km search radius.

The study area falls within the Nene Washes SSSI Impact Risk Zone which are used to make a rapid assessment of the potential risks posed by development to SSSIs, SACs, SPAs and Ramsar sites. They define zones around each site which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts.

The study area also falls within an area highlighted by Natural England as the Nene Washes Goose & Swan Functional Land Impact Risk Zone within City of Peterborough (Peterborough City Council, 2019). This area highlights land outside of the adjacent SPA designed area which may have a functional link to the SPA qualifying goose and swan species.

Four non-statutory designated sites: County Wildlife Sites (CWS) have been identified within the 2km study area all situated to the north of the study area.

The access road from the A605 into the proposed processing facility lies within a 200m buffer zone established for the Kings Dyke Nature Reserve.

Table 1 provides a brief summary of the reasons for each designation, and the distance these sites are from the study area.

Table 1: Designated sites identified during the desk study Approximate distance & Name Status Reason for Designation direction from site Statutory Designated Sites – International, National The Nene Washes is one of the country’s few remaining areas of washland habitat. The site is notable for the diversity of plant and associated Nene Washes SAC animal life within its network of dykes. Moreton’s 1.0km N Leam, a large drainage channel running along the eastern flank of the washes, contains a high density of spined loach Cobitis taenia.

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Approximate distance & Name Status Reason for Designation direction from site The site is a large site, over 1500ha. This site represents one of the country’s few remaining areas of washland habitat which is Ramsar / Nene Washes essential to the survival of Nationally and 1.1km N SPA / SSSI Internationally Important populations of wildfowl and waders. The site is additionally notable for the diversity of plant and associated animal life within its network of dykes. Orton Pit’s extensive pond system, occupying the disused ridge-and-furrow created as a result of clay extraction for the brick-making industry, Orton Pit SAC contains alkaline water low in nutrients. The site 7.8km W supports Nationally Scarce plant assemblages and a known large population of great crested newt. Non-Statutory Designated Sites – Regional, Local Approximately 40ha with known large population CWS / of great crested newts, important assemblages regionally Kings Dyke of stoneworts, nationally scarce vascular plants. important 0.2km N Nature Reserve A mosaic habitat with areas of topogenous fen. geological This site is geologically important due to its site Jurassic exposures. Approximately 30ha site supporting mature Common Wash CWS 0.8km NNE pollard willows. Wash Road A small site consisting of semi-natural habitats CWS 1.7km NE Pollard Willows with a number of mature pollard willows. Northey Gravel Approximately 5ha site supporting at least three CWS 1.9km NNW Pit species of Potamogeton.

Figures 2 and 3 show where these designated sites are in the context of the study area and the wider area. Further details related to the designated features of both international and nationally designated sites and impacts can be found within Appendix D of this document. Discussions were held with the Kings Dyke Nature Reserve manager, Philip Parker, to get a better understanding of the features of this designated site given the close proximity to the study area.

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515000 520000 525000 530000 535000 Map Legend

Site boundary

Site boundary - 10km search buffer International Statutory Designation Special Area of Conservation (SAC) Ramsar & Special Protection Area (SPA) 305000

Nene Washes

300000 Ramsar / SPA

Nene Washes SAC 295000 Orton Pit SAC

01 2 4 km

290000 Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

Project Saxon Brickworks, Peterborough Road, Whittlesey [HSPCo04]

Figure 2 – Desk study -International designated Sites

Client Johnsons Aggregates

Date Reviewer Version Scale Size 11/02/21 MP 1.2 1:72,000 A3 523000 523500 524000 524500 525000 525500 526000 526500 527000 527500 Map Legend

Site boundary

Site boundary - 2km search buffer Statutory Designation Northey Gravel 299000 Pit CWS County Wildlife Sites (CWS) Site of Special Scientific Interest (SSSI)

Nene Washes SSSI 298500

Common Wash CWS

298000 Kings Dyke Nature Reserve CWS Wash Road Pollard WillowsCWS 297500 297000 296500

296000 0100 200 400 600 800 m

Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

Project Saxon Brickworks, Peterborough

295500 Road, Whittlesey [HSPCo04]

Figure 3 – Desk study -local designed sites

Client Johnsons Aggregates

Date Reviewer Version Scale Size 11/02/21 MP 1.1 1:15,000 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Protected / Notable Species The table below provides a summary of the species records from the past ten years within a 2km search radius of the study area, received from CPERC, that are considered most relevant to the site and/or proposals. The full dataset is not included here but is available on request.

Table 2: Summary of protected and priority species records relevant to the site and/or proposals Total Approximate location of Approximate location of Number Species closest record and date most recent record and of of record date of record Records Amphibians and Reptiles Great crested newt 0.39km NW 2016 1.81km WNW 2017 3 Triturus cristatus Common frog 1.9km E 2013 3 Rana temporaria Grass snake 0.39km NW 2016 2 Natrix helvetica Common Lizard 0.39km NW 2016 4 Zootoca vivipara

Mammals

Eurasian Badger Within the search area* Meles meles European Otter 0.74km SW 2016 1.83km WSW 2017 3 Lutra lutra European Water vole 1.1km SE 2015 1.98km SSE 2019 4 Arvicola amphibius Common pipistrelle 0.39km NW 2016 0.5km WSW 2017 4 Pipistrellus pipistrellus Soprano pipistrelle 0.39km NW 2016 1.49km W 2017 4 Pipistrellus pygmaeus Pipistrelle Species 0.5km WSW 2010 1.44km E 2012 4 Pipistrellus sp. Noctule bat 0.39km NW 2016 4 Nyctalus noctula Brown long-eared bat 1.43km E 2012 2 Plecotus auritus West European Hedgehog 0.7km NE 2010 1 Erinaceus europaeus Red List Birds Black redstart 1.49km W 2012 3 Phoenicurus ochruros

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Total Approximate location of Approximate location of Number Species closest record and date most recent record and of of record date of record Records Black-tailed Godwit 1.53km E 2013 6 Limosa limosa Corn Bunting 1.96km S 2013 5 Emberiza calandra Corncrake 1.01km NE 2012 1 Crex crex Cuckoo 0.5km WSW 2011 1.53km E 2013 50 Cuculus canorus Curlew 1.01km NE 2013 5 Numenius arquata Fieldfare 0.5km WSW 2013 60 Turdus pilaris Grasshopper Warbler 0.5km WSW 2011 3 Locustella naevia Grey wagtail 0.5km WSW 2013 4 Motacilla cinerea House sparrow 0.5km WSW 2011 1.49km W 2012 14 Passer domesticus Lapwing 0.5km WSW 2011 1.93km NNW 2013 50 Vanellus vanellus Linnet 0.5km WSW 2011 5 Linaria cannabina Merlin 1.89km SE 2011 1 Falco columbarius Mistle Thrush 0.5km WSW 2011 11 Turdus viscivorus Pochard 0.5km WSW 2011 1.49km W 2012 65 Aythya ferina Redwing 0.5km WSW 2011 1.49km W 2012 41 Turdus iliacus Ring Ouzel 0.57km N 2010 1 Turdus torquatus Ringed Plover 0.5km WSW 2011 1 Charadrius hiaticula Shag 1.49km W 2012 1 Phalacrocorax aristotelis Skylark 0.5km WSW 2011 3 Alauda arvensis Song Thrush 0.5km WSW 2013 61 Turdus philomelos

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Total Approximate location of Approximate location of Number Species closest record and date most recent record and of of record date of record Records Spotted Flycatcher 1.49km W 2012 2 Muscicapa striata Starling 0.5km WSW 2011 33 Sturnus vulgaris Turtle dove 0.5km WSW 2011 31 Streptopelia turtur Whinchat 1.01km NE 2012 2 Saxicola rubetra Woodcock 0.5km WSW 2013 30 Scolopax rusticola Yellow wagtail 0.5km WSW 2011 1.01km NE 2012 3 Motacilla flava Yellowhammer 0.5km WSW 2011 1 Emberiza citrinella *NB. Due to high risk of persecution of this species, badger records remain confidential at the request of the records centre.

Over 11,800 records of Red and Amber listed Birds of Conservation Concern were returned within 2km of the study area including barn owl Tyto alba, gargeney Anas querquedula and red kite Milvus milvus (these are Schedule 1 birds protected by the Wildlife and Countryside Act 1981). The majority of these birds are found in the statutory sites, Kings Dyke Nature Reserve (CWS) and the Nene Washes (SAC/SPA/Ramsar/SSSI).

Through discussions with Kings Dyke Nature Reserve manager, and a review of nearby planning permissions, a number of confirmed breeding ponds for great crested newt (GCN) Triturus cristatus were identified within the zone of influence for GCN. Ponds with confirmed GCN were identified within the Kings Dyke Nature Reserve, and the nearby “A605 Kings Dyke Improvements Scheme” situated to the west of the study area which is currently undergoing site works under an active European Protected Species Licence. These ponds and their associated population size classes are illustrated on Figure 4. This figure also shows those ponds that were surveyed, but returned a negative result with regards to the “A605 Kings Dyke Improvements Scheme”.

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524800 524900 525000 525100 525200 525300 525400 525500 525600 525700 525800 525900 526000 526100 526200 Map Legend

Site boundary

P1 Kings Dyke Nature Reserve (CWS) P2

297700 P3 Pond - large GCN population P4 Pond - small GCN population Pond - GCN absent (eDNA survey) Pond - not surveyed for GCN

297600 P6 P5 GCN pond - 250m buffer GCN pond - 500m buffer P7 Ditch - not surveyed for GCN 297500

297400 P8

D1 297300

D3 297200 P9 P10 D4 P11 P12

P13 297100 D5 P14 P16 P17 P15 P18 P19

D6 D7 297000 296900

D8 D9 050 100 200 m 296800

D10 D11

P20 Head Office: Arden House, Deepdale Business Park,

296700 Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

D12 P21 Project Saxon Brickworks, Peterborough Road, Whittlesey [HSPCo04] D13 D14 Figure 4 – Desk study -Known GCN D15 populations 296600 Client Johnsons Aggregates D16 Date Reviewer Version Scale Size 11/02/21 MP 1.2 1:4,400 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

A review of the MAGIC website revealed that the study area also lies within an area highlighted as Priority Species habitat for corn bunting, lapwing, redshank and snipe. These areas are highlighted as Priority areas for Countryside Stewardship measures to address habitat issued for these species.

The area has been highlighted as supporting an Arable Assemblage Farming Birds of 5 and a Grassland Assemblage Farming Birds of 4. This information is derived by the Bird Conservation Targeting Project (BCTP) which produces breeding distribution maps for a suite of rare and declining farmland and/or woodland birds. The maps can be used to guide the prescription of land management advice based on the species already breeding in an area, or for allocating funding towards sites known to be important for birds.

Priority Habitats Areas within the study area and immediate boundaries have been highlighted as Open Mosaic Habitat. These are verified sites, and have therefore been confirmed by a competent authority.

An area to the immediate north and west of the study area is highlighted as both Deciduous Woodland Priority Habitat and mapped on the National Forest Inventory as being broadleaved woodland.

Other priority habitats are found within the wider area. All priority habitat areas are illustrated in Figure 5 to show their location and extent relative to the study area.

Other desk study information The study area and the wider area south of the A605 lies within a Nitrate Vulnerable Zone (NVZs) which was identified within 2017 and later updated in 2021. Nitrate Vulnerable Zones are areas designated as being at risk from agricultural nitrate pollution. The designations are made in accordance with the Nitrate Pollution Prevention Regulations 2015. Waters are defined within the Nitrates Directive as polluted if they contain or could contain, if preventative action is not taken, nitrate concentrations greater than 50mg/l.

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524800 524900 525000 525100 525200 525300 525400 525500 525600 525700 525800 525900 526000 526100 Map Legend

Site boundary Priority Habitat Inventory Habitat - NE 297700

Deciduous woodland Coastal and floodplain grazing marsh Lowland fens

Open mosaic habitat (draft) 297600 297500 297400 297300 297200 297100 297000

296900 rights reserved. Licence number 0100031673.

025 50 100 150 200 m 296800

Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

Project Saxon Brickworks, Peterborough Road, Whittlesey [HSPCo04]

Figure

296700 5 – Desk study – Priority habitats

Client Johnsons Aggregates

Date Reviewer Version Scale Size 11/02/21 MP 1.1 1:4,000 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

3.2 Phase 1 Habitat Survey The individual habitat types recorded within the study area are described under the sub- headings below, with the location and extent of each illustrated on the Phase 1 Habitat Map in Figure 6. Some areas of habitat adjacent to and outside of the redline boundary are shown to provide context where habitat within the boundary extends beyond. This is particularly relevant, where no defined feature on the ground denotes the development redline boundary. Representative photographs of the site are provided in Appendix E with target notes detailed within Appendix F and within the legend of Figure 6. The site is largely split into two areas, referred to within Section 5 Assessment of Impacts below, as Phase 1 and Phase 2 areas, each with very different characteristics, which can be clearly seen on Figure 6. Phase 1 encompasses the current, active and operational, Plastic Recovery Facility which is dominated by hard standing, bare ground and buildings. The green habitat areas to the western edge of the study area and to the immediate north of the proposed development boundary is referred to as Phase 2. The following habitats were identified on site or along its boundaries; • Buildings, hardstanding and bare ground; • Broadleaved plantation woodland; • Scrub; • Ditch and Marginal / Inundation vegetation; • Ephemeral / short perennial; • Tall ruderal; and • Boundary features.

Buildings, hardstanding and bare ground The study area is dominated as a whole by buildings, hard standing and bare ground with a lack of vegetation evident due to the disturbed nature created by frequent vehicle movements. Buildings were a mixture of designs and construction materials including: • Modern, steel framed, metal cladded agricultural/industrial style buildings being used frequently for the storage of materials; • Modern, sealed, metal container units used for storage arranged in rows/terraces; • Red brick, open fronted bike/smoking shed with sloping metal roof; and • Red brick chimney. The buildings will be described in greater detail in Section 3.3.2.1 and Section 3.3.5 of this report in terms of their potential to support roosting bats and breeding birds. There were two areas of spoil which appeared to largely comprise earth and aggregate. These areas ware denoted by Target Notes 4 and 5.

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Broadleaved plantation woodland A narrow, isolated strip of immature to semi-mature broadleaved plantation woodland was situated near the eastern boundary of the study area surrounded by bare ground and hardstanding. This woodland acts as a shelter belt and has clearly been planted as tree protection guards remain on many of the trees. The canopy height ranged from approximately 5m to 12m depending of the age and species of tree. The botanical species assemblage of the canopy was varied with no dominating species evident. Species comprised hawthorn Crataegus monogyna, blackthorn Prunus spinosa, Leyland cypress Cupressus × leylandii, hazel Corylus avellana, goat willow Salix caprea, silver birch Betula pendula, elder Sambucus nigra and holly Ilex aquifolium. There was a minimal shrub layer present which was dominated by bramble Rubus fruticosus agg. and a garden escape rose hybrid Rosa sp. No ground flora was evident at the time of the survey, showing only leaf litter. Broadleaved woodland was also located immediately outside of the study area to the north of the access road from the A605 into the wider study area. At the time of the survey the access track lay outside of the redline boundary and therefore detailed assessment of this woodland area was not undertaken.

Scrub Three distinct areas of scrub were located within the study area and its immediate boundaries. The easternmost area inside of the redline boundary and northernmost area, which lies immediately outside of the redline boundary (south of the access road from the A605) were dominated by low lying hawthorn, blackthorn and elder scrub which had a canopy height of approximately 5m. Bramble, common nettle Urtica dioica and dock species Rumex sp. made up the ground flora present in these areas. The westernmost area of scrub was dominated by butterfly-bush Buddleja davidii, with bramble, teasel Dipsacus fullonum, cow parsley Anthriscus sylvestris, smooth sow-thistle Sonchus oleraceus, dandelion Taraxacum officinale agg., Yorkshire fog Holcus lanatus and perennial rye grass Lolium perenne recorded frequently throughout the area.

Ditch and Marginal / Inundation vegetation Six ditches were present within or immediately adjacent to the study area, all of which were functional and designed to actively move collected surface waters to attenuation ponds located outside of the study area. Each ditch was highlighted with a reference number to aid in future locating. Ditch numbers can be found on Figure 7. All of these ditches were at maximum capacity for water volume, or over-spilling into the wider area. This was considered unusual for the site and time of year given the vegetation present within the ditch and considered only a result of the recent nationwide flooding events that had been experienced on the build up to the survey. Flooded areas of the site are denoted by Target Notes 1 and 3.

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All ditches were approximately 1-1.5m wide at base, 3-4m wide at bank top, steep sided and appeared to be at least 1m in depth. Water appeared to be relatively clear and flowing at the time of the surveys. The two easternmost ditches (Ditches 3 and 4) which are positioned in an approximate north-south orientation are connected via a buried culvert. Ditches 2, 3, 5 and 6 had areas of reed canary grass Phalaris arundinacea, soft rush Juncus effusus, hard rush J. inflexus and sedge species Carex sp. present along the ditch banks. Banks appeared to be reasonably well vegetated given the time of year and from what could be seen from emergent vegetation where water levels overtopped the bank top. Ditch 4 was noted to be relatively dry however, with bank side vegetation almost absent apart from small areas of bramble which appeared to encroach from the neighbouring scrub vegetation. The banks of Ditch 4 showed evidence of recent scraping (last 12-24months), considered likely to be as part of routine maintenance. These ditches are described further in relation to their potential to support protected and priority species as detailed in Section 3.3.4 of this report.

Ephemeral / short perennial This habitat type appears present in two distinct areas within the study area. A narrow strip along the northern boundary of the main proposed development area parallel with Ditch 2 and a much larger area which extended outside of the redline boundary to the west.

This habitat type comprises areas of bare ground, some of which appeared to have been relatively recently colonised by sparse, low growing vegetation. Vegetation near to Ditch 2 was present on sparse soils mostly consisting of fine to medium sized aggregate. Those areas on the western side of the site largely appeared present on relatively recently disturbed, made ground. This ground appeared to have more of a soil content, but appeared clay rich resulting in more areas of shallow waterlogged ground. This habitat appeared to be in a transient successional state, in that as the vegetation establishes, it usually develops fairly quickly into some kind of grassland and/or scrub, unless maintained by ongoing disturbance or heavy grazing by rabbits Oryctolagus cuniculus, for example.

Typical species within this habitat included common ragwort, creeping thistle Cirsium arvense, common mouse-ear Cerastium fontanum, bush-vetch, white dead-nettle Lamium album, common hogweed Heracleum sphondylium and common cat’s-ear Hypochaeris radicata, Yorkshire fog and perennial rye grass. It is considered that many more species will be evident within this area if re-surveyed during the botanical growing season as many species typical of this type of habitat die back in winter leaving no dead stems above ground.

Much of this area appears to be heavily grazed by rabbits with vegetation height ranging from 5-35cm. Forbs dominate the species composition with grasses occurring rarely in this habitat, although this may vary within the botanical growing season.

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Tall ruderal Areas of tall ruderal were located within the northern and eastern sections of the study area adjacent to Ditch 2 and the broadleaved plantation on the eastern side of the study area. Each area was dominated by bramble, rosebay willowherb Chamaenerion angustifolium, common nettle and frequent to occasional grasses such as Yorkshire fog and perennial rye- grass.

Boundary features The proposed development boundary had no defined boundary features such as walls or fences. Many of the boundaries were defined by transitions in habitats such as hardstanding to woodland, bare ground to building etc. There is no defined boundary on the western side of the redline boundary. At the time of survey, the client had denoted the extent of the proposed boundary using hazard tape, but it was understood that this was the base of the new proposed embankment, and as the angle of the proposed slope was unknown at the time, a wider area atop the existing embankment was surveyed to ensure this area was suitably covered.

Invasive Species No invasive botanical species were recorded across the study area or its immediate boundaries.

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525100 525200 525300 525400 525500 525600 525700 Map Legend

Site boundary

Broadleaved woodland Broadleaved plantation woodland Scrub 297400 Pond Inundation vegetation Tall ruderal Ephemeral / short perennial Bare ground Hardstanding Residential garden - not accessed Building

297300 Target note - extent

Ditch Fence

Target note Target Notes:

4 B2 [1] Flooded area 3 [2] Possible open mosaic habitat [3] Flooded area [4] Spoil heap [5] Spoil heap

297200 [6] Known peregrine feeding post/perch (chimney) [7] Known kestrel nesting

B5 B3 B7 6 5

297100 2 B8

1 7 B4

010 20 40 60 80 m 297000

Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

Project Saxon Brickworks, Peterborough Road, Whittlesey [HSPCo04]

Figure 6 – Phase 1 habitat map

Client Johnsons Aggregates

296900 Date Reviewer Version Scale Size 12/02/21 MP 1.4 1:2,000 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

3.3 Protected and Priority Species

Amphibians

3.3.1.1 Aquatic habitats There are no ponds or static water bodies present within the study area, however there are a number of functional ditches, which at the time of the survey had slow flowing water within them. The surveyor was informed by the client, that during a typical year, these ditches are predominantly dry and only have water from the surface run-off of the site after periods of rain. Should these ponds retain water throughout the year, or at least the typical breeding season for amphibians, then there is opportunity for these ditches to be used as breeding habitat, if the flow of water is slow. A review of Ordnance Survey mapping and aerial photography identified a number of ponds and other ditches which can be found within 500m from the proposed redline boundary (see Figure 7), some are closer, within 250m. Of these ponds, some have already been identified as supporting breeding populations of great crested newts (Pond 9 and all ponds within the Kings Dyke Nature Reserve CWS) as detailed within the earlier desk study section. A number of small ponds lie very close (approximately 30m) to the western edge of the proposed redline boundary (Ponds 13, 14, 16, 17, 18, and 19). These ponds appear to have been created rather than a natural feature of the land. It is possible that they have been created as mitigation ponds for impacts from previous development nearby. They are all relatively circular in shape, with a diameter of less than 6m, with a bunded edge sitting proud of the surrounding land. All retained water at the time of the survey had a depth of at least 50cm with many showing signs of retaining water frequently due to the presence of reed canary grass, sedges, rushes and bullrush Typha sp. Water quality appeared to be relatively good to moderate with invertebrates noted within the water column. A Habitat Suitability Index (HSI) assessment was undertaken on these ponds and found that they returned a HSI score of “0.55 Below Average”. The breakdown of the score can be found within Appendix G. It should be noted that this score did not change if water quality was highlighted as either “good” or “moderate”. It is possible that the terrestrial habitat surrounding the ponds was not accurately represented due to the season in which the survey was undertaken, and that this habitat may improve as the seasons progress and vegetation begins to grow. Taking this into account, when the terrestrial habitat indices was elevated to “good” this increases the HSI Score to “0.60 Average”. Pond 15 is a large, square pond with a perimeter security fence standing approximately 2m from the bank top. Bank sides of the pond were very steep and well vegetated with grasses, although no apparent emergent or marginal vegetation was present, with the exception of reed canary grass. Two domesticated ducks were present on and around the water’s edge, both appearing to be a cross form of Indian runner duck Anas platyrhynchos domesticus based on body form and colouring. Ponds 8, 11 and 12 were not seen during the site visit, having only been identified from a review of aerial photography after the survey visit. All other waterbodies lay outside of the landownership and were not accessed due to the limited timeframe to arrange access between instruction and the site visit.

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3.3.1.2 Terrestrial habitats Due to the dominance of bare ground, hard standing and building within the proposed redline boundary, and the highly disturbed nature of the areas, much of the of the study area provides negligible potential for foraging and resting amphibians. Broadleaved plantation woodland and scrub are usually considered to provide optimal terrestrial habitat for amphibians, however, these habitats on the eastern side of the site were considered to provide moderate potential only, due to the isolated location, being surrounded by bare ground or hard standing. It’s only connection to suitable areas in the wider habitat being the ditch network. Vegetated habitats along the northern boundary adjacent to Ditch 2 and those to the west of Ditch 5 have good potential to support amphibians as they provide connectively to wider habitats and provide opportunities for resting places and hibernation potential. The area west of Ditch 5 was considered to predominantly provide resting places during the spring – autumn months with a reduced likelihood of providing hibernation potential due to the waterlogged nature of the clay rich substrate. All hibernation opportunities were identified adjacent to Ditch 2.

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524600 524700 524800 524900 525000 525100 525200 525300 525400 525500 525600 525700 525800 525900 526000 526100 Map Legend 297900

Site boundary

Site boundary - 250m buffer Site boundary - 500m buffer 297800

Kings Dyke Nature Reserve (CWS)

Pond P1 P2 Ditch 297700 P3 P4

P6 297600 P5

P7 297500

297400 P8

D1 297300

297200 P9 P10 D4 P11 P12

P13 297100 D5 P14 P16 P17 P15 P18 P19

D6 D7 297000

050 100 200 m

D8 D9 296800 P20 D10 D11

Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511.

296700 Project Saxon Brickworks, Peterborough D12 P21 Road, Whittlesey [HSPCo04] D13 D14 Figure 7 – Ponds within 250m and 500m D15 Client

296600 Johnsons Aggregates

D16 Date Reviewer Version Scale Size 11/02/21 MP 1.2 1:4,750 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Bats

3.3.2.1 Roosting potential for bats No trees present on site provided potential roosting features which could be used by roosting bats. A total of seven buildings were identified within the study area. It should be noted that building B3, the red brick chimney, was not assessed during this site visit for its potential to support roosting bats as the surveyor was made aware by the client that this structure was scheduled to be demolished during the active bat season (May to September) under a separate planning application. This building has already been subject to assessment for bats, and therefore no additional disturbance was considered necessary or appropriate during the bat hibernation period. The table below provides a more detailed description of the buildings present within the study area, going beyond those descriptions outlined in Section 3.2.1 earlier within the report. This table also outlines the potential for these buildings to support roosting bats.

Table 3: Description of buildings present within the study area and their potential to support roosting bats. Bat Building Description roosting reference potential Large metal framed and metal clad building with shallow pitched metal roof. Polycarbonate windows on east and west sides and in the roof. Gable end to north and south with large open doorways (doors missing) at each end comprising approximately 1/3 of the gable walls. B1 No roof void or lining present. Very bright internally, with breeze felt Negligible throughout the building. This building was in current use with frequent vehicle movement within the interior. No evidence of bats internally or externally and no potential roosting features identified.

Metal framed structure with shallow pitched metal roof. Metal cladding between wall plate and roof. No roof void and no lining present. Two full length wall lights along with polycarbonate sheets on east and west sides mean that the interior of the structure is very bright. B2 Negligible Large vehicle sized roller door was open on the southern gable end, which appeared to remain open. The building was still in use, used for storage of materials and appeared to be accessed frequently. No evidence of bats internally or externally and no potential roosting features identified.

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Bat Building Description roosting reference potential Red brick chimney /kiln- Decommissioned in 2012 and formerly part of a larger building which had already been demolished prior to the survey (date unknown). The base of the structure was square, approximately 10m x 10m with arches/tunnels on all four sides which Not appeared to allow access into the interior. The square structure soon assessed - changed to a circular chimney which reached approximately 30m covered high. Metal staging was apparent in a number of places going up the under B3 exterior of the chimney. Numerous cracks and crevices apparent on separate the exterior of the structure. This structure was not accessed granted internally as the surveyor was aware that this building had already planning been surveyed for bats for surveys associated with a separate permission planning application. Large spoil heaps were present at the base of this structure, being added to during the survey. It is our understanding that these spoils were being positioned in readiness for the future demolition of the structure. Metal framed and metal clad building with moderate metal pitched roof. No roof void or lining present with polycarbonate windows meant that the interior of the building was relatively bright. This building was in current use and appeared to have machinery associated with the Plastic Recovery Site housed within. Whilst machinery was not operational at the time of the survey, it was B4 assumed, given the nature of the machinery, that considerable noise Negligible and potentially heat would be generated when this machinery is in operation. This would mean that internal conditions of the structure would vary greatly. Large, vehicle sized doorway appeared to remain permanently open on the northern side of the structure. Further allowing internal conditions to fluctuate greatly as weather conditions external change. Two "terraces" or rows of modern, sealed metal shipping container units. Containers appeared to be connected side to side with no apparent gap between units. Each unit had a single roller door which appeared tight to the frame and allowed no apparent gap for a potential roosting feature. No evidence of bats externally. No internal B5 and access was possible as each unit was separately locked, however it is Negligible B6 assumed that the structure offers no potential roosting features internally other than perhaps any items stored within. As no access points were identified, it is considered negligible, unless a sustained period of time lapsed with a unit door left open. All units were closed at the time of the survey.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Bat Building Description roosting reference potential Small, red brick building with shallow sloped corrugated metal roof used as a smoking shed. This structure was open on the northern aspect to allow pedestrian access meaning it was very open to the B7 elements. The interior walls and sections of the underside of the roof Negligible appeared to be damp which highlighted that rain could penetrate into the interior of the structure. No evidence of bats internally or externally and no potential roosting features identified.

3.3.2.2 Foraging and commuting potential of habitats for bats

The study area offers negligible potential to support foraging and commuting bats due to the extent of bare ground and buildings creating a void of vegetation within the landscape. It is unknown if there is any overnight lighting. The vegetated areas around the outer extent of the study area and the wider landscape does offer moderate to good potential for both foraging and commuting bats with particular note, the broadleaved woodland areas and linear ditch networks and ponds and lakes which would offer varying foraging opportunities for all species of bats present within the wider area.

Badger Much of the study area was flat and, due to its dominance of building, hard standing and disturbed bare ground, there were negligible opportunities for badger Meles meles sett building. Sett building opportunities were found within the embankments associated with the broadleaved plantation woodland to the eastern edge of the study area and the embankment to the western edge of the study area.

No evidence of sett building was identified within the study area or within 30m from the edge of the study area.

The broadleaved plantation woodland and ephemeral / short perennial vegetation areas offer at least low potential to support foraging badger, however the wider landscape offers much greater potential for food resource. There is a chance that badgers will move through the study area to gain access to better quality food resources in the wider area if there are setts within the wider landscape.

Water vole The ditches present within the study area may offer potential to support water vole. Botanical species present may be used by water voles for food resources. Due to the flooded condition of the ditches at the time of the survey it was not appropriate to further assess them for evidence of water voles. It was considered likely that any feeding stations and or latrines would have been washed away. In addition, the water level in many of the ditches was considered high for a typical year and any burrows present would likely have been underwater and therefore not evident.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

It should be noted that Ditch 4 had lower water levels, and an assessment for burrows was made using binoculars, which revealed no burrows present. The lack of vegetation on the ditch banks may indicate recent vegetation removal which may have obscured burrow entrances if ground was broken during the vegetation removal.

Breeding birds The study area provides limited suitable habitat for nesting birds due to the disturbed nature of much of the current active site and limited extent and/or lack of suitable structures such as trees and shrubs. Much of the study area is unsuitable for ground nesting birds due to the extent of vehicle movement across the base of the site, however un-disturbed areas of ephemeral / short perennial vegetation do have the potential to support ground nesting farmland birds. Buildings present on site offer opportunities for nesting birds due to the ledges present within the metal framing of the building and the to a lesser extent the shallow pitched or sloping roofs present. Two feral pigeon Columba livia domestica were recorded loafing internally within Building 2 using the ledges associated with the framing of the structure. No evidence of nesting within any of the buildings was evident at the time of the survey, however a review of previous planning application documentation for this site identified the following: • Kestrel Falco tinnunculus was known to nest on top of tubing associated with Building 4 leading to externally stored silos present on the western gable end of this building; and • Peregrine falcon Falco peregrinus are known to use the chimney /kiln (Building 3) as a feeding perch and are also known to use the chimneys at the Kings Dyke brick works located to the north-west of the study area. The small area of broadleaved plantation woodland to the eastern side of the study area provides good quality nesting habitat for woodland / hedgerow birds. At least five old nests were identified along the eastern edge of the woodland, however more were considered likely within the Leyland cypress. A number of bird species including robin Erithacus rubecula, chaffinch Fringilla coelebs, wren Troglodytes troglodytes, great tit Parus major and blackbird Turdus merula were noted within this woodland area during the survey. Carrion crow Corvus corone and black-headed gull Chroicocephalus ridibundus were also identified flying over the site, with six red-legged partridge Alectoris rufa and at least two snipe Gallinago gallinago noted within the wider area of ephemeral / short perennial vegetation to the west outside the study area.

Reptiles Generally, the study area provides very limited habitat for reptile species due to its dominance of building, hard standing and disturbed bare ground, however the ephemeral / short perennial vegetation areas to the west and north of the study area and to a lesser extent the scrub areas offer both basking and resting places for common reptile species. The ditch areas offer additional potential to support grass snake.

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Other Protected and/or Notable Species The site generally is unsuitable for many faunal species due to the dominance of building, hard standing and disturbed bare ground present within the study area and the level of vehicle disturbance across much of the site. The vegetated sections of woodland, scrub, tall ruderal and ephemeral / short perennial habitats offer potential for foraging and commuting hedgehog Erinaceus europaeus. Hedgehogs are listed as Priority Species under UK Post-2010 Biodiversity Framework. Due to a lack of suitable habitats, the site is not considered likely to support any other protected or notable species.

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4 EVALUATION OF FEATURES WITHIN THE STUDY AREA

The below paragraphs evaluate the value of the site in terms of its habitats and ability to support protected and priority species.

4.1 Designated sites The study area alone does not contain in full or in part any statutory or non-statutory designed sites, however a number of international, national and local designed sites are located within close proximity to the study area.

The study area falls within the Impact Risk Zone for the Nene Washes SSSI, with the development type being highlighted as a possible risk type, and therefore evaluation of potential impacts to this site have been included within Appendix D which outlines impacts to international and national designated sites.

The study area also falls within an area highlighted by Natural England as the Nene Washes Goose & Swan Functional Land Impact Risk Zone within City of Peterborough (Peterborough City Council, 2019). This area highlights land outside of the adjacent SPA designated area which may have a functional link to the SPA qualifying goose and swan species.

The assessment of habitats within the study area would indicate that the vegetated habitats within the study area are unsuitable to support geese or swan species due to the limited extent and sloping nature of much of the available green habitat present on site. Ditches present within and near the proposed redline boundary are considered too minor to support such species, although larger water bodies in the wider area including Pond 15 are likely to support them.

The remaining hardstanding, buildings and disturbed bare ground are not appropriate for such species to be present.

4.1 Habitats & Botanical Interest Much of the study area is of low ecological value due to the extent of hardstanding, buildings and disturbed bare ground present. However, vegetated habitats as outlined below, offer moderate to good ecological value.

Whilst no rare or notable botanical species were recorded during the field survey, it should be noted that the timing of the survey was not conducive to collating an extensive or exhaustive botanical species list. No invasive botanical species were identified as being present.

Sixteen of the UK Priority Habitats are found in Cambridgeshire and Peterborough (the area covering the proposed development). A number of these priority habitats have already been highlighted by Natural England on the UK Priority Habitat Inventory as shown on Figure 5 as being either present within or immediately adjacent to the study area.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Open mosaic habitat on previously disturbed ground All areas noted as ephemeral / short perennial vegetation within and outside of the redline boundary should be considered as having the potential to qualify as the UK BAP and local priority habitat “open mosaic habitat on previously disturbed ground” and further site survey should be undertaken to fully confirm this. This is further justified as all these areas have been mapped as the priority habitat by Natural England, although it should be noted that such mapping is only considered to be draft at the time of writing. The ephemeral / short perennial vegetation areas within the redline boundary (totalling approximately 0.47ha) by their nature formed a mosaic of hard ground and short sward vegetation. The areas within the redline boundary form part of a wider habitat connection, as this habitat extends outside of the boundary to the west. Much of these areas were over loose or frequently disturbed substrates, with areas to the west providing areas of shallow pooled water (although this may not be typical of a usual occurrence, and only the result of recent heavy rains). On review of the history of the site, it is likely these substrates are either imported or a remnant of the former quarrying operations of the site, as such, even without an extensive botanical species list (given the time of year), these areas are considered highly likely to fulfil the criteria for these habitats to qualify as the UK BAP and local priority habitat. Further survey is recommended to full assess this habitat further. Habitat quality within this area is considered to be at least moderate due to the botanical assemblage, lack of apparent management and extent of bare ground present.

Woodland and scrub All woodland areas lie outside, but immediately adjacent to the redline boundary. The area of broadleaved plantation woodland to the eastern edge of the site, is surrounded by the proposed boundary. Botanically, this area of woodland has a species rich canopy as a result of its planting, however the potential functionality and ecological value is reduced due to its isolated nature within the landscape. As this is a plantation woodland, this habitat does not fulfil any of the requirements to be considered as either a UK Biodiversity Action Plan (BAP) habitat or a local priority habitat. The area of semi-natural broadleaved woodland north of the access road was originally considered to be outside of the redline boundary when the Phase 1 habitat survey was undertaken. Whilst this habitat could be mapped based on knowledge gained from the survey visit it is not appropriate for an assessment of the quality of this woodland to be made, as it was not fully assessed in the field. This area of woodland is an extensive and continuous section of woodland however and is considered likely to provide moderate to good quality habitat from a floristic value, and increased value for faunal species as its connects the wider landscape and may offer value to other UK BAP species such as bats and great crested newts. As this area is already mapped as the priority habitat by Natural England, it must be assumed that this area qualifies as both the UK Biodiversity Action Plan (BAP) habitat or a local priority habitat. Scrub areas were considered to offer moderate habitat quality due to the botanical assemblage present and the association of this habitat with adjacent communities.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Ditches Habitat quality of all ditches within the site was considered to be of poor to moderate quality due to the lack of, or limited, botanical interest evident during the survey. All ditches were of man-made origin in their construction.

Functional ditches such as those encountered on site are not considered to be UK BAP or local priority habitats.

4.1 Protected and Priority Species

Amphibians There are no ponds or static water bodies present within the study area, however there are a number of functional ditches present.

There are also a large number of ponds within the zone of influence considered for great crested newts which is illustrated in Figure 7, and at least two known breeding populations of GCN, the closest being within the Kings Dyke Nature Reserve approximately 200m from the access point on the A605 from the development boundary. In 2018, Pond 9 was identified as supporting a small population of GCN, whilst the Kings Dyke Nature Reserve is known to support a large population of GCN. These two areas might be considered to form a single large metapopulation, or could be considered as separate metapopulations given their short distance from each other and being separated by the A605, a relatively busy single carriage way.

Whilst terrestrial vegetation suitable for amphibians, including GCN, was considered to be minimal (approximately 0.72ha) within the study area, the close proximity of ponds to the redline boundary and the connectivity of habitat means that the site does offer good opportunities for amphibians. The presence of known populations of GCN in the area make it likely that GCN may be present in close proximity to the study area, and further survey should be undertaken to further inform their presence or likely absence.

Much of the site however was found to offer negligible potential to support any amphibian species due to the extent of hard standing, building and disturbed bare ground.

Bats Both the buildings and the habitats present with the study area offer negligible potential to support roosting and foraging or commuting bats.

Discussion with the Kings Dyke reserve manager, Philip Parker whom has worked extensively in the local area, including the study area and so has a strong understanding of the ecology of the local area, suggested that bat activity was comparatively low in the area, with few common UK bat species (i.e. common and soprano pipistrelle, noctule & brown long eared bats) recorded on an occasional basis.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

Badger No evidence of sett building was identified within the study area, or within 30m from the edge of the study area. The study area only offers at least low potential to support foraging badger in the broadleaved plantation woodland and ephemeral / short perennial vegetation areas.

Water vole The ditches present within the study area may offer potential to support water vole, and further survey of these features is recommended as desk study data reveals that they are present in the wider area. A project Peak Ecology have recently been involved with, at the nearby Star Pit (Pond 20), identified a water vole population closer to the study area than indicated from the desk study. In addition, Philip Parker confirmed that water vole translocations are happening in the wider area which may have resulted in translocated animals being moved closer the study area. Translocated animals may be looking to disperse from the areas they were released to and may occupy lesser quality habitat for periods following translocation. This may elevate the likelihood of their presence on site and therefore further survey is recommended.

Breeding birds The study area provides limited suitable habitat for nesting birds due to the limited extent of nesting habitat and disturbed nature of much of the current active site. Much of the study area is unsuitable for ground nesting birds due to the extent of vehicle movement across the base of the site, however un-disturbed areas of ephemeral / short perennial vegetation do have the potential to support ground nesting farmland birds. Buildings present on site offer opportunities for nesting birds due to the ledges present within the metal framing of the buildings and the to a lesser extent the shallow pitched or sloping roofs present. The small area of broadleaved plantation woodland to the eastern side of the study area provides good quality nesting habitat for woodland / hedgerow birds. Of the bird species recorded within the study area at the time of the survey, and those species already known to use the site, the following birds are categorised as Birds of Conservation Concern (Eaton et al, 2015); • Black-headed gull (amber); • Kestrel (amber); and • Snipe (amber). Birds listed as Amber have shown signs of a “moderate breeding population decline over 25 years/longer term”. All other bird species noted were not currently considered to be of conservation concern. Peregrine falcon, noted to be previously within the study area, are listed as green under the Birds of Conservation Concern, however they are Schedule 1 listed species under The Wildlife and Countryside Act, which affords them added protection whilst nesting and

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preparing to breed. The birds previously recorded on site have not been known to breed, merely using building B3 as a feeding perch to eat prey caught whilst hunting. It is considered unlikely that black-headed gull and snipe will use the proposed development area for nesting. Many of the bird species recorded within the broadleaved plantation woodland are considered to be woodland specialists.

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HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

5 ASSESSMENT OF IMPACTS

The below paragraphs assess the likely impacts the proposals will have on any habitats and protected or priority habitats. Impacts can be either direct or in-direct and be a result of construction or operational phases of the proposed development.

5.1 Development Proposals It is proposed to modify the existing works on-site, to facilitate the construction of a proposed industrial plant which will undertake the following processes: “Proposed importation, storage, processing including use of trommel, picking and recycling of incinerator bottom ash (IBA) and construction and demolition (C&D) waste, for exportation for use as incinerator bottom ash secondary aggregates (IBAA)”

It is proposed for the recycling of the IBA and C&D waste to be undertaken using the existing, retained buildings on-site, with the surrounding hardstanding landscape being used for the storage of IBA that is to be unloaded by HGV vehicles on-site. The IBA waste is a non-hazardous aggregate like material produced through the incineration of waste process and is imported direct from the producer. The main outputs are IBAA (manufactured secondary aggregate) and recovered materials. The recycling process which is to occur on-site is as follows:

i. Unprocessed IBA will be imported to the site and stored outside before undergoing a colling and ‘ageing’ process;

ii. The IBA will then go through vibrating screens and magnetic metal separation removing ferrous and non-ferrous metals and producing different sized fractions of Incineration Bottom Ash Aggregate;

iii. Construction and demolition (C&D) and other waste materials will be crushed and screened dependent on the customers’ requirements.

iv. Incinerator bottom ash secondary aggregates (IBAA) will be prepared and exported for recycling at an appropriate facility.

v. Any additional material unsuitable for recovery will be sent to an appropriately authorised facility.

5.2 Potential Impacts associated with the proposals Whilst proposals will, in part, alter the current layout of the site, the impacts of the site operation in terms of ecology are considered to be similar to that of the current, granted Plastic Recovery Facility. The materials handled will change and the location of the storage of materials and processing areas will change, but noise and on-site disturbance levels are considered to largely remain the same.

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However, the number of vehicle movements both in and out of the study area will be increasing as the volume of processed material is a significant increase from the current granted Plastic Recovery Facility. Vehicle movement into the processing area from the A605 will utilise the existing access road.

Impacts from the proposed development are likely to take a number of forms and are considered to be the follow including:

• Noise and vibration disturbance from increased vehicle movement in and out of the site (construction and operational phase);

• Visual disturbance from increased vehicle movement in and out of the site (construction and operational phase); and

• Increased potential for water pollution (construction and operational phase);

• Reduced air quality through increased emissions (construction and operational phase); and

• Direct habitat loss (construction phase).

It has been calculated that there would be an increase in traffic volume associated with the study area once the site is operational compared to the current traffic volumes associated with the Plastic Recovery Facility, please refer to the Annual Average Daily Traffic (AADT) stated with the Transport documents accompanying this planning submission. Vehicles will predominantly be Heavy Goods Vehicles (HGV’s) used for transporting goods to and from the proposed processing facility and to a much lesser extent, cars associated with the workforce.

The additional traffic generation is considered to be negligible on the local road network (A605 and all transport links to the A1(M) and this is demonstrated by the AADT flows supplied by the Transport team associated with the project.

It should also be noted that the proposed development (and the wider site overall) will generate less trips to that of the previous operation as a Brickworks prior to 2012.

Therefore, impacts as a result of increased vehicle movement are considered to be low due to the historic disturbed nature of the study area.

Impacts from increased dust levels have not been included as it is already understood that prior to dispatch from an incinerator facility, the IBA is heavily doused with water to both reduce its temperature and minimise the risk of air borne particles arising from its transport and deposit. Upon delivery to the site via HGV’s the IBA is tipped into bays within the identified IBA reception and storage area, where it is doused again to create a crust on the stockpile to prevent dust generation and allow it to mature.

Due to the topography of the site, situated in the former quarry, no additional construction or operational, visual or noise disturbance is anticipated once vehicles have entered the base of the quarry where the processing facility will be situated, as such things already occur through the current operations on site.

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From the bullet points above, construction phase also refers to the demolition phase of any existing buildings on site that are to be lost / demolished as a result of the development. The likely impacts on dust, noise and emissions are not fully understood at the time of writing, therefore this report should be read in conjunction with reports specifically related to these disciplines. Water pollution is also covered by separate specialists. This report indicates the potential impacts to ecology only.

5.1 Designated Sites The proposed development does not fall within the boundary of any designated sites.

Potential impacts to the nearby International designated sites have been collated separately within Appendix D of this report. The study area falls within the Nene Washes SSSI Impact Risk Zone, and it is considered that the proposed development would fall potentially within the risk category which identifies “any industrial/agricultural development that could cause air pollution”, therefore the air quality reports associated with this planning application should be read in conjunction with this report. Impacts on the SSSI have been included alongside the review of impacts to the International designed sites found within Appendix D.

Kings Dyke Nature Reserve The proposed development will not result in the direct loss of habitat or geological features within the site, nor will it result in increased visitor numbers which may cause added pressure to a site.

The Kings Dyke Nature Reserve is designated for its known large population of great crested newts with the nearest pond being 200m to the north, separated from the proposed development by the A605. The access road currently used by the Plastic Recovery Facility will continue to be used as part of this proposal. The road is hardstanding with kerbs and is suitable to take the vehicles anticipated with this proposal. No alterations to the road layout are proposed, and therefore no land take or impact to the population of GCN is anticipated. Areas of the proposed development habitat loss will occur are over 400m from the nearest pond on the Nature Reserve. Any GCN from the Kings Dyke Nature Reserve population is unlikely to be encountered on site given the distance and potential barriers (A605) the individual must overcome. The Nature Reserve also supports important assemblages of stoneworts, nationally scarce vascular plants and a mosaic habitat with areas of topogenous fen. Impacts related to dust, emissions and water quality have all been scoped out by the relevant specialist’s disciplines associated with this project, and therefore the relevant independent reports should be read in conjunction with this report. The access road from the A605 into the proposed processing facility lies within a 200m buffer zone established for the Kings Dyke Nature Reserve. This buffer covers the access

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road that shall be used from the A605 which will remain in its current state with no proposed works, however the buffer does not extend to the wider proposed development area.

Other County Wildlife Sites Common Wash (CWS) and Wash Road Pollard Willows (CWS) will remain unaffected by the proposals as they are at least 800m to the NE of the proposed development, with no traffic movement leaving the site to the east. All traffic movement into and out of the proposed development will enter the site from the west, with all HGV traffic coming from the A1(M).

Northey Gravel Pit (CWS) lies beyond the Nene Washes SAC/SPA/Ramsar/SSSI from the proposed development. As no impacts are envisaged at Nene Washes, then it is considered, no impacts will occur at Northey Gravel Pit. It is highly unlikely that there is hydrological connectivity between the proposed development and Northey Gravel Pit which would impact the designated features of this site.

5.2 Summary of study area assessment For the purposes of the ecology assessment the site can been split into two phases of works. Phase 1 being the footprint of the existing Plastic Recovery Facility dominated by the hardstanding, buildings and disturbed bare ground for which there is negligible ecological interest. Works to develop this area of the site pose little to no risk to ecology due to the existing use and disturbance of the site. Phase 2 however, are those areas of vegetated habitat at the edges of the proposed development which will result in habitat loss, significant earth movement and potential to impact on both protected and priority species and habitats. Development of the site into this area requires additional survey effort to further inform and refine the impact assessment. Worst case scenarios are provided where relevant. It is understood that the site could become operational without expansion into the proposed Phase 2 area, however it cannot reach full capacity without this expansion. Therefore, it is recommended that should the local authority be minded to grant planning, that any works occurring within the proposed Phase 2 area are conditioned based on the recommendations outlined within this report to allow a refinement of the impact assessment provided within this report. Figure 8 shows the suggest boundaries of these Phase 1 and Phase 2 areas.

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525100 525200 525300 525400 525500 525600 525700 Map Legend

Site boundary

Proposed ecological phasing - phase 1 Proposed ecological phasing - phase 2 297400 297300 297200 297100

010 20 40 60 80 m 297000

Head Office: Arden House, Deepdale Business Park, Bakewell, Derbyshire. DE45 1GT. T: 01629 812511. Saxon Brickworks, Peterborough Project Road, Whittlesey [HSPCo04]

Figure 8 - Proposed Ecological Phasing of the development

Client Johnsons Aggregates

296900 Date Reviewer Version Scale Size 12/02/21 MP 1.0 1:2,000 A3 HSPCo04 / Saxon Brickworks, Peterborough Road, Whittlesey Preliminary Ecological Appraisal, Issue 1

5.1 Habitats & Botanical Interest Much of the proposed development makes use of the existing expanse of hard standing, building and disturbed bare ground. The proposed development will result in the loss / demolition of buildings B2, B3 (to be demolished under a separate planning permission), and B7 with the removal of buildings B5 and B6 from within the development boundary which appear to be replaced by new hard standing. All areas of woodland appear to be retained within the proposed development, whilst there will be a loss of scrub and tall ruderal habitat. All woodland retained throughout works should be adequately protected during the works in line with BS5837:2012 Trees in relation to design, demolition and construction. The proposed development will result in the loss of approximately 0.47ha of ephemeral / short perennial vegetation considered highly likely to qualify as the UK BAP and local priority habitat “open mosaic habitat on previously disturbed ground”. The area within the proposed development is likely to qualify in its own right as well are the wider extension of this habitat to the west also qualify in its own right. The wider area of this habitat outside of the proposed development will remain intact. Ditches and therefore associated marginal and inundation vegetation within them both within and adjacent to the proposals are, at the time of writing, assumed to be retained. The proposals indicate no soft landscaping, so all habitat loss is assumed to be replaced with hard surfaces. There will be net loss of habitat associated with this proposed development.

5.2 Protected and Priority Species

Amphibians Much of the site is found to offer negligible potential to support any amphibian species, due to the lack of waterbodies and proportion of the site comprising hard standing, building and disturbed bare ground. Works in these areas are unlikely to encounter amphibians. However, vegetated areas of the site do offer potential to support amphibians and therefore habitat loss in these areas will have a likely impact on amphibians. The close proximity of ponds (approximately 30m from the development boundary), and the presence of known large populations of GCN indicate that the likelihood of encountering amphibians including GCN during the works is high. Great crested newt is a European Protected Species (EPS) protected through Schedule 5 of the Wildlife and Countryside Act 1981 (as amended), through the Conservation of Habitats and Species Regulations 2017 (as amended) and is a priority habitat species. Both known breeding populations of GCN are situated over 250m away from the areas where impacts resulting from breaking of ground will occur, however GCN have been recorded as travelling up to 500m+ from known breeding ponds, and as such there is still potential for them to be using the habitat in the wider area, away from their breeding ponds.

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There are a number of ponds in close proximity to the study area for which no data is historically known, therefore further survey is required to establish presence / likely absence of GCN. The purposes of the remainder of this report with respect to impacts to GCN, the worst case scenario is outlined to inform suitable recommendations until such a time that survey data can be used to further inform the impact assessment.

5.2.1.1 Worst case scenario The worst case scenario is based on the assumption that those ponds closest to the study area (Ponds 11, 12, 13, and 16) support breeding populations of GCN.

The proposed development will involve significant excavations and earth movement on the western side of the study area adjacent to Ponds 13 and 16 for which the vegetation is suitable to support GCN. This means that any such earth movement has the potential to kill, injure, disturb, and/or destroy any place used for rest or shelter by this species and therefore trigger all the above offences as outlined in the legislation.

The Natural England Raid Risk Assessment tool was used to assess likely impacts from the development with regards to GCN. The table below outlines the worst case scenario with extent of habitat areas only showing those areas that offer suitable habitat for GCN (i.e. this spatial areas exclude areas of hardstanding, building and disturbed bare ground that were assessed as unsuitable for GCN).

The Rapid Risk Assessment tool is a simplistic guide which returns a traffic light system result:

• Green: offence highly unlikely; • Amber: offence likely; or • Red: offence highly likely.

Table 4: Natural England Rapid Risk Assessment – accounting only for habitat suitable for amphibians Component Likely effect (select one for each component; Notional select the most harmful option if more than one is offence likely; lists are in order of harm, top to bottom) probability score

Great crested newt breeding pond(s) No effect 0

Land within 100m of any breeding pond(s) 0.1 - 0.5 ha lost or damaged 0.5

Land 100-250m from any breeding pond(s) 0.1 - 0.5 ha lost or damaged 0.1

Land >250m from any breeding pond(s) No effect 0

Individual great crested newts Significant disturbance of newts 0.8

Maximum: 0.8

Rapid risk assessment result: RED: OFFENCE HIGHLY LIKELY

The table above returns a "Red: offence highly likely" result which indicates that the development activities are of such a type, scale and location that an offence is highly likely.

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Due to the nature of the proposed development, it is highly unlikely that the project designs can be altered sufficiently to reduce the likelihood of an offence occurring, and therefore a European Protected Species Licence from Natural England will likely be required to derogate against any offences which occur should the local authority be minded to grant conditional planning permission.

It should be noted that if no further GCN populations are recorded closer to the site, the Rapid Risk Assessment tool still returns an "Amber: offence likely" result which indicates that the development activities are of such a type, scale and location that an offence is likely. In this case, measures such as sensitive timing of works and minimised the duration of impacting works may sometimes be sufficient so that the effects are minimised. Should this be the case, works may be able to proceed under a non-licenced method statement.

Section 6.2 outlines appropriate mitigation measures which can be deliverable on site based on the worst case scenario. It should be noted that these recommendations should be reviewed and amended once presence / likely absence data for those ponds in closer proximity to the study area is available.

Bats The study area does not support any suitable potential roosting features (PRFs) for bats therefore there will be no offences caused under Wildlife Legislation. The loss of vegetated areas associated with the proposals will be minimal in respect to foraging and commuting bats, with the wider, good quality habitats outside of the site boundary being retained. According to the review of the Scoping Opinion issued by Cambridgeshire County Council (dated 14th January 2021) the proposed development, once operational, would operate 24/7 from 6am on Mondays through to 6pm the following Saturday. No operations are proposed to take place between 6pm on Saturday through to 6am on Monday other than maintenance and repairs. Should the installation of lights to provide night-time lighting be included within the proposals, then further recommendations with respect to lighting have been included within Section 6.3 of this report.

Badger Badgers are protected under The Protection of Badgers Act 1992, which means that it is an offence to “wilfully kill, injure, take, or cruelly ill-treat a badger, or attempt to do so”, and “Intentionally or recklessly interfere with a sett by disturbing badgers whilst they are occupying a sett, damaging or destroying a sett, causing a dog to enter a sett, or obstructing access to it.”. As no badger setts have been encountered within and adjacent to the study area, then it is considered that the potential impacts to badger are negligible. Section 6.4 of this report outlines best practice measures to ensure that no badgers are injured during the construction phase of the works.

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Water vole Water vole are protected through Schedule 5 of the Wildlife and Countryside Act 1981 (as amended) and are a priority species. The legislation means that it is an offence to deliberately capture, injure or kill; and or to disturb a water vole whilst it is in its breeding or resting place; and/or to damage, destroy or obstruct a water vole’s breeding or resting place.

At the time of writing the proposals indicate that all ditches present within the study will be retained. Many of the ditches are situated outside of the redline boundary, and are already subject to disturbance from the existing Plastic Recovery Facility. It is understood that the ditches are functional at draining surface water away from the study area, and as such receive routine maintenance occurring at an unknown frequency. Given the extent of the vegetation witnessed within the ditches, routine maintenance had not occurred for at least two years with the exception of Ditch 4, which appears more recently cleared.

Impacts to water vole could not be fully assessed during the survey visit. This species is known to be in the wider area and as such could be present on site using the ditch network and in particular the Ditches 2 and 5 which area located nearest the area anticipated to receive the greatest level of disturbance. Further survey is recommended to inform the assessment of this species. Section 6.5 of this report outlines best practice measures to ensure that water voles are injured during the construction and operational phase of the works.

Breeding Birds All wild birds, their nests and eggs are protected under the Wildlife and Countryside Act 1981 (as amended). Woodland habitats which are likely to support the greatest and richest bird assemblage are to be retained within and adjacent to the study area, however there will be the loss of habitat to support ground nesting birds through the loss of the ephemeral / short perennial habitat loss. The historic kestrel nest located on structure B4 is to be retained, as is the large metal structure B1, which retains perching opportunities for birds. Noise generated by traffic has been well documented to impact upon the function of adjacent habitats for birds. Studies have found that traffic noise can impact on bird’s ability to find a mate and hold territory, and detect predators, causing increase stress levels and lower success in breeding attempts as a consequence. The distribution of territories can also be affected by the presence of a road, with varying distances from the road avoided by different species. Studies have found that a high proportion of woodland birds, for which accounted much of the bird assemblage recorded during the survey visit are affected by traffic noise, with reduced densities of up to 30% for most species, and 100% for some species, between 50- 1500m from a road carrying 10,000 vehicles a day (Reijnen and Foppen, 1997). Disturbance affects are shown to increase with the number of vehicles, up to 2,800m from roads carrying 50,000 vehicles a day.

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Given the current research, it can be safely assumed that the increase in traffic will result in further reaching disturbance effects on the site’s woodland, and retained habitats beyond this. The speed limit on the A605 may minimise noise disturbance, however, heavy goods vehicles moving to and from the site from the A605 are likely to create more disturbance than regular vehicles. Whilst the traffic volumes will increase from the current Plastic Recovery Facility, they will be less that those previously experienced on the site from the prior Brickworks operations pre- 2012 which had been operational for many years, thus returning the site to a previous state of permitted disturbance in terms of traffic volumes.

Reptiles Common reptile species, including grass snake Natrix natrix, slow worm Anguis fragilis, adder Vipera berus and viviparous lizard Zootoca vivipara are protected under the Wildlife and Countryside Act 1981 (as amended). This legislation makes it an offence to kill, injure or trade these species.

Other reptile species, including sand lizard Lacerta agilis and smooth snake Coronella austriaca, are afforded additional protection, although these species have a restricted distribution and their presence on this site is considered extremely unlikely.

All native UK reptiles are listed on the UK Post-2010 Biodiversity Framework (formerly the UK biodiversity Action Plan).

The site supports habitat suitable for reptiles with areas both suitable for basking and shelter.

The potential impacts the proposed development may have on reptiles is the accidental injury, disturbance or killing of reptiles on site. The phase that is most likely to affect reptiles is the initial vegetation clearance that will take place prior to construction.

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6 RECOMMENDATIONS

Below are recommendations to allow a greater understanding of specific ecological features associated with the site, and/or outline mitigation, compensation or reasonable avoidance measures to reduce impacts on ecology as a result of the proposed development.

6.1 Further Survey / assessment A number of additional ecological surveys are recommended to further assess impacts of the proposed phase 2 area as outlined in Figure 8. These surveys are designed to further refine recommendations outlined later within this report.

Great crested newt – Presence / likely absence survey In the first instance, presence/ likely absence of GCN should be confirmed of ponds within 250m from the proposed development.

Two methods for establishing presence / likely absence are available:

• eDNA survey (one survey visit carried out between mid-April and end-June); or

• Conventional survey technique (four survey visits carried out between mid-March and mid-June, with at least two visits occurring between mid-April and mid-May).

If the presence of GCN is confirmed in any ponds or ditches within the study area, additional survey effort will be required to establish a population size class assessment. If eDNA is undertaken to establish presence, then a six-visit conventional survey technique will be required, however, if conventional methods were used to establish presence, then as additional two survey visits will be required.

Conventional survey technique would follow standard guidance (English Nature, 2001) and would comprise three of the following techniques per visit; bottle trapping, torchlight survey, egg-searching and netting. These surveys can only be conducted between mid-March and mid-June, with half of the surveys completed between the optimal period mid-April to mid- May for presence / likely absence and at least three visits occurring between mid-April and mid-May for a population size class estimate.

A combination of both conventional survey and eDNA can be used for efficiency of time and money.

If GCN are found to be present, appropriate mitigation will be required to ensure that GCN are not harmed by the proposals and the favourable conservation status of the species is maintained.

Water vole survey Surveys should be undertaken between April and October by an ecologist experienced in water vole ecology. The survey will involve the surveyor closely examining the waterway and ditch banks, up to at least 2 metres from the water. Evidence searched for will include: faeces, latrines, feeding stations, burrows, footprints and runs or pathways.

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The survey should aim to gather information on the size and extent of any population identified on and adjacent the development site to further inform mitigation and avoidance measures.

Biodiversity Net Gain calculations The current proposals show no retention of green habitat within the development boundary with the exception of the existing ditches and associated marginal and inundation vegetation. There will be net loss of habitat associated with this proposed development. As such, it is recommended that the baseline survey data as outlined earlier in this report and the site proposals are used to inform a Biodiversity Net Gain calculation such as that of “The Biodiversity Metric 2.0” or similar which provides a way of measuring and accounting for biodiversity losses and gains resulting from development or land management change. The metric is a habitat based approach to determining a proxy biodiversity value. This will inform the local authority of the extent of biodiversity loss and allow for suitable and appropriate compensation to be outlined between the developer and the local authority.

Legislation changes proposed in the new Environment Bill include a mandatory Biodiversity Net Gain of 10% for most developments. Any gains not achievable on site, can be off-set using additional land owned by the developer, neighbouring land owners or through agreement of a compensation payment to the local authority so that suitable habitat can be created or enhanced as part of a wider national or regional strategy.

6.2 Mitigation/Compensation Measures and Reasonable Avoidance Measures

Habitats

6.2.1.1 Open mosaic habitat Should planning be granted, at the earliest opportunity prior to commencement of works the extent of the build area and working area should be denoted on site and suitable fencing installed along the western edge of the development to prevent construction works from straying outside of the consented boundary into the continuation of the open mosaic habitat area. Due to the loss of this priority habitat, agreement should be made between the developer and the local authority over suitable compensation for the loss of this habitat from the site. This may take the form of a financial payment to offset the loss as calculated using Biodiversity Net Gain calculations to attribute and quantify the number of credits and to establish a proportionate compensation payment, or by way of a translocation of this habitat to an appropriate receptor site to be agreed between the ecologist, developer and the local authority.

6.2.1.2 General habitats In order to minimise the effect of the proposals on existing, retained habitats, storage of materials and machinery should be away from the boundary features and must avoid the root protection zone of trees. Any trees that will be unaffected should be adequately protected during the construction works, in line with BS5837:2012 Trees in relation to

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design, demolition and construction – recommendations. No materials should be stored under the canopy of the trees during construction works, unless existing hard standing is present and all Root Protection Areas (RPA) should be marked out prior to commencement of work, should any excavations need to occur near these areas. General good practice guidelines, including those outlined in Pollution Prevention Guideline 5 (Environment Agency, 2007) should be adhered to at all times e.g. any potentially harmful chemicals, solutions or machinery associated with the works should not be stored within 5m of a ditch to prevent leaking of such chemicals into the water system.

Any materials that require storing during the construction should be stored on existing bare ground, hard standing areas of the site. Any stored materials during construction should ideally be raised off the ground on pallets when needing to be stored in areas near to ponds and ditches unless a significant barrier such as a wall is present to disperse any amphibians away.

Great crested newts

Assuming the presence of a large metapopulation of great crested newts occupying ponds adjacent to the development boundary, an EPS licence from Natural England would be required prior to work, or Natural England’s District Licencing be used to mitigate impacts. This shall be informed by appropriate survey effort as outlined within Section 6.1.1 of this report.

Any EPS licence application shall include a method statement which will fully outline the impacts of the proposed development and detail safe working practices to reduce to a minimum impact to great crested newts. Such measures would include;

• Ring fencing areas of suitable GCN habitat with Temporary Amphibian Fencing (TAF) which will be impacted by the works; • Internal drift fencing to split the larger extent of the ring fenced area into smaller compartments; • Installation of pitfall traps and carpet tiles around the interior of ring fencing and both sides of drift fencing; • Commencement of a capture period commensurate with the identified metapopulation of GCN (small population = 30 days trapping, medium = 60 days, large = 90 days trapping); • Designated receptor area for captured GCN and other amphibians to be translocated to; • Habitat creation and/or enhancement to compensate for the loss of suitable GCN habitat; and • Post development monitoring commensurate to the population size class and level of impact. Other documents would accompany the method statement such as the application form, works schedule and reasoned statement (where required).

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Should the local authority be minded to grant planning permission, a copy of any proposed licenced, or non-licenced method statement can be issued to the local authority prior to commencement of works. Irrespective of if proposed works are undertaken under a licenced or non-licenced method statement, the following measures will be enforced; • Ground preparation works should see a gradual, graded reduction in vegetation height;

• Safe guarded areas, such as the site boundary features should be marked on the ground to prevent accidental disturbance;

• A suitably experienced and licenced ECoW (or accredited agent) will be present at times where potentially sensitive works may occur, such as the stripping of vegetation or removal of areas deemed as suitable refugia;

• All vegetation removal and initial breaking of ground should be undertaken in as short a time as possible, at a time to be least impacting to GCN.

Common Amphibians If common amphibians are found during works then they should be carefully moved to a safe place off site, in an area that will be unaffected by works and ideally of a similar habitat type.

6.3 Bats Should additional night-time lighting be required as part of the proposals, then a sensitive lighting scheme should be designed and submitted to the planners to show that sensitive retained habitats such as the retained areas of woodland and pond and ditch areas remain as dark as possible. The use of shielding and directional lighting should be used for high- traffic areas to ensure areas outside of the working areas remain in darkness, and for low- traffic pedestrian areas, low level bollard lighting could be used. Automated and timer lighter can be used to ensure light is only provided when required, and avoid lighting throughout the whole night wherever possible.

6.4 Badger As the time between submitting a planning application and starting works once a permission is granted can be some time, it is recommended that prior to any works occurring on site, a site check for any recent excavations by badger in vegetated areas of embankment shall be undertaken. Sufficient time prior to works should be included in the unlikely event badgers have decided to create a sett, although this is considered to be unlikely, to identify if the sett is in current occupation by badgers. It should be noted, that if a badger sett is identified that is in current use and will be impacted by the proposed works, this will require an exclusion licence from Natural England. Exclusions can only be carried out between July and November (inclusive) of each year.

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To safeguard badgers and other small mammals which may travel through the site, any excavations/pipes that shall be used throughout the duration of works across the whole site should be covered overnight or have an escape incorporated into them, for example, a stepped or sloping end; and the concrete pad/headwalls or overflow spillway sections should be poured early in the day so as not to be ‘wet’ overnight; alternatively it should be fenced off to exclude badgers and other wildlife whilst the concrete sets.

6.5 Water vole Avoidance methods will be implemented which will prevent works encroaching within at least 5m of the bank top of retained ditches, where water vole have been identified as being present through the recommended additional survey effort. No further habitat fragmentation, loss or culverting of ditches should occur where water voles have been found to be present on the ditch network associated with the study area. Any routine maintenance required on ditches that was found to support water vole shall limit the extent of damage to water vole habitat and where appropriate submit a method statement to the local authority outlining appropriate works required supported by survey data.

6.6 Breeding birds Due to the relatively small scale loss of habitat suitable for nesting birds on site (scrub, ephemeral / short perennial vegetation and tall ruderal), and the retention of good quality habitat (woodland), it is considered that breeding bird surveys are not required to inform this planning submission as there requirement would be disproportionate to the level of impact anticipated. It is recommended that any vegetation removal is undertaken outside of the main breeding bird season, which is generally considered to be March to September (inclusive), to minimise the risk of damaging active nests. If this is not possible, a suitably experienced ecologist should search all areas for active nests prior to vegetation removal, preferably immediately prior to, and no more than 48 hours before removal. Any identified active nests must be protected from disturbance until the nest is complete, using suitable barriers where necessary. Demolition of any buildings on site should also be undertaken outside of the main breeding bird season, however contractors should remain vigilant throughout the year as some species such as feral pigeon are known to breed year-round, in particular in urban areas or sites with buildings. Checks should be made for nesting birds prior to any demolition works irrespective of the time of year. Vehicle movement using the access road from the A605 down into the processing facility should be reduced to a suitable operational speed for HGV to minimise noise and vibration disturbance to birds within woodland areas adjacent to the access road.

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6.7 Reptiles Any works should be undertaken following a reasonable avoidance measures method statement which would outline safe working practice to avoid impacts to reptiles. This would include any vegetation clearance from the interior hardstanding areas of the site moving slowly towards outer extremities of the site to allow for any reptiles that may be basking in bare ground areas to move off site into areas of more suitable habitat.

Due to the presence of the known GCN populations, many of the measures outlined within Section 6.2.2 would still be relevant and appropriate with regards to reptiles.

Contractors should remain vigilant during vegetation clearance and stop works if reptiles are encountered and an ecologist contacted for appropriate advice on how best to proceed.

6.8 Ecological Enhancement National planning policy recommends that all developments incorporate ecological enhancement in order to “pursue opportunities for securing measurable net gains for biodiversity” (NPPF, 2019), therefore consideration should be given to the following suggestions. • Provide a variety of invertebrate refugia in to soft landscaped areas, this could include partially buried log piles, “bug hotels”, bumblebee boxes, wildlife paving stones, butterfly hibernation boxes and general nesting aids. See https://www.livingwithbirds.com/search?sw=bumble%20bees&sf=species:bumble%2 0bee,species:earwig,species:lacewing,species:ladybird,species:wasp for examples.

• It is important that any new fencing or walls installed as part of the development do not create a barrier to dispersal for wildlife using existing green habitats. It is recommended that suitable holes are incorporated at the base of boundary structures to allow wildlife to commute through the site, such as specific “hedgehog holes” which are 13 x 13cm in size.

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7 OUTLINE SUMMARY OF FURTHER WORKS REQUIRED

A number of additional ecological surveys are recommended to further assess impacts of the proposed phase 2 area as outlined in Figure 8. These surveys are designed to further refine recommendations outlined later within this report.

Table 5: Outline summary of further works required Species Survey type and reasoning Great crested newts Presence / likely absence survey of water bodies within 250m that have not already undergone previous testing as indicated in Figure 4. This will inform population size class surveys and requirement for EPS licence and refine a method statement approach (either licenced or non-licenced).

Water vole Assessment of ditches for presence of water vole – to inform reasonable avoidance measures and future maintenance programmes

Biodiversity Net To quantify the extent of biodiversity lost on the site allowing Gain Calculations suitable compensation to be made by way of either off-site habitat creation or payment proportionate to the extent of lost credits.

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8 REFERENCES

British Standards Institution (2013) BS42020:2013 Biodiversity – code of practice for planning and development. BSI Standards Ltd, London Chartered Institute of Ecology and Environmental Management (2013) Competencies for Species Surveys in Britain and Ireland; Overview. CIEEM, Winchester. Online [Available at] http://www.cieem.net/competencies-for-species-survey-css- Chartered Institute of Ecology and Environmental Management (2013) Guidelines for Preliminary Ecological Appraisal. CIEEM, Winchester Collins J. (ed) (2016) Bat Surveys For Professional Ecologists: Good Practice Guidelines (3rd Edition). Bat Conservation Trust, London. Department for Communities and Local Government (2012) The National Planning Policy Framework. http://www.communities.gov.uk/publications/planningandbuilding/nppf

Eaton et al. (2015) Birds of conservation concern 4: the population status of birds in the UK, Channel Islands and Isle of Man. British Birds 108: 708-746. IUCN (2012) IUCN Red List Categories and Criteria. Version 3.1. Second edition. IUCN, Gland. IUCN (2012) Guidelines for Application of IUCN Red List Criteria at Regional and National Levels. Version 4.0. IUCN, Gland. IUCN (2016) Guidelines for Appropriate Uses of IUCN Red List Data. Version 3.0. Adopted by the IUCN Red List Committee. IUCN (2017) Guidelines for Using the IUCN Red List Categories and Criteria. Version 13. Prepared by the Standards and Petitions Subcommittee. Joint Nature Conservation Committee (2010) Handbook for Phase 1 Habitat Survey: a technique for environmental audit. JNCC, Peterborough. Multi-Agency Geographic Information for the Countryside Website. http://www.magic.gov.uk/ Natural England (2017) European Site Conservation Objectives: Supplementary Advice on Conserving and Restoring Site Features. Upper Nene Valley Gravel Pits Special Protection Area (SPA) Site Code: UK9020296 Oldham R.S., Keeble J., Swan M.J.S. & Jeffcote M. (2000). Evaluating the suitability of habitat for the Great Crested Newt (Triturus cristatus). Herpetological Journal, 10 (4), 143- 155. Peterborough City Council (2019) Peterborough Local Plan 2016 – 2036 (Adopted 24 July 2019) https://drive.google.com/file/d/1NMAZKc0AcA8ibplwB_2raMVjtVojH6r0/view Eaton, M. A., Aebischer, N., Brown, A., Hearn, R., Lock, L., Musgrove, A., Noble, D., Stroud, D., and Gregory, R. 2015. Birds of Conservation Concern 4: the population status of birds in the UK, Channel Islands and Isle of Man. British Birds. 108: 708–746 Stace, C.S. (2010) New Flora of the British Isles, 3rd edition. University Press, Cambridge.

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APPENDICES

APPENDIX A : Protected and Priority Species ...... 55 APPENDIX B : Relevant Legislation ...... 57 APPENDIX C : Methodologies ...... 62 APPENDIX D : Information to inform an Appropriate Assessment in respect of the proposed Saxon Brickworks development ...... 64 APPENDIX E : Site Photographs ...... 74 APPENDIX F : Target Notes ...... 79 APPENDIX G : Habitat Suitability Index ...... 81

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APPENDIX A : Protected and Priority Species

Legal protection is afforded to particular habitats and species (as well as designated sites), see Appendix B. The legislation, and the habitats and species listed, vary between the different jurisdictions. Certain habitats and species are also considered to have some level of nature conservation importance, due to factors such as their rarity, vulnerability or declining population/status. This document uses the term ‘priority habitats’ and ‘priority species’, as they are those which should be considered as priorities for conservation (it should not be confused with priority habitats and species as listed in the EU Habitats Directive). Priority habitats and species are defined as those which are: 1) listed as a national priority for conservation (such as those listed as habitats and species of principal importance for the conservation of biodiversity); 2) listed as a local priority for conservation, for example in the relevant local Biodiversity Action Plan (BAP); 3) Red Listed using International Union for the Conservation of Nature (IUCN) criteria (e.g. in an all-Ireland Red List, in one of the UK Species Status Project reviews, in the Species of Conservation Concern Red List, Birds of Conservation Concern in Wales, or BWI/ RSPB Red List for Ireland and Northern Ireland (Birds of Conservation Concern in Ireland 2014 to 2019) or, where a more recent assessment of the taxonomic group has not yet been undertaken, listed in a Red Data Book); 4) listed as Near Threatened or Amber Listed e.g. in an all-Ireland Red List, in one of the UK Species Status Project reviews, in Birds of Conservation Concern in Wales, in the Species of Conservation Concern Amber List or BirdWatch Ireland (BWI)/RSPB Amber List for Ireland and Northern Ireland (Birds of Conservation Concern in Ireland 2014 to 2019); 5) listed as a Nationally Rare or Nationally Scarce species (e.g. in one of the Species Status Project reviews) or listed as a Nationally Notable species where a more recent assessment of the taxonomic group has not yet been undertaken; and/or 6) endemic to a country or geographic location (it is appropriate to recognise endemic sub-species, phenotypes, or cultural behaviours of a population that are unique to a particular place). Most protected species are also considered to be priority species, although there are some exceptions. There are numerous priority habitats and species which do not receive any legal protection. Note that the terms ‘priority habitat’ and ‘priority species’ used in this document differ from the following uses of the same terms: a) These terms were previously used to denote those habitats and species afforded the highest level of priority for conservation under the UK BAP; this has been superseded by the lists of habitats and species of principal importance for the conservation of biodiversity in England under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006, Section 7 of the Environment (Wales) Act 2016, or their equivalents in Scotland (Nature Conservation (Scotland) Act 2004, Scotland’s

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Biodiversity Strategy and the Scottish Biodiversity List15) and Ireland (Actions for Biodiversity – Ireland’s National Biodiversity Plan 2017 -202116; and Valuing Nature – A Biodiversity Strategy for Northern Ireland to 2020). b) The terms ‘Priority Natural Habitat Type’ and ‘Priority Species’ are used to denote specific lists of habitats and species under The Conservation of Habitats and Species Regulations 2017; these are defined in Articles 1(d) and 1(h) respectively of the Habitats Directive.

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APPENDIX B : Relevant Legislation

The following text provides information on the key legislation, which is applicable to this survey.

The main wildlife legislation in the UK is as follows:

European Legislation The relevant sections of the EC Directives and international conventions are summarised below:

• EC Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora (Habitat Directive 1992) as amended (92/43/EEC)

The Directive requires Member States to introduce a range of measures including the protection of species listed in the Annexes. The 189 habitats listed in Annex I of the Directive and the 788 species listed in Annex II, are to be protected by means of a network of sites. Once adopted, these are designated by Member States as Special Areas of Conservation (SACs), and along with Special Protection Areas (SPAs) classified under the EC Birds Directive. The Habitats Directive introduces the precautionary principle; that disturbance to the designated sites can only be permitted having ascertained no adverse effect on the integrity of the site.

• EC Directive on the Conservation of Wild Birds (Birds Directive 1979) as amended (79/409/EEC)

The main provisions of the Directive includes; the maintenance of the favourable conservation status of all wild bird species across their distributional range.

• Bern Convention on the Conservation of European Wildlife and Natural Habitats (1979)

The Convention imposes legal obligations on contracting parties, protecting over 500 wild plant species and more than 1000 wild animal species.

UK Legislation The sections of UK legislation considered to be of relevance include:

• The Conservation (Natural Habitats, and c.) Regulations 2017 (as amended)

This transposes the Habitats Directive into national law. The Regulations provide for the designation and protection of ‘European sites’, and the protection of ‘European protected species.

• The Wildlife and Countryside Act 1981 (as amended) (WCA)

This consolidates and amends existing national legislation to implement the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) and Council Directive 79/409/EEC on the Conservation of Wild Birds (Birds Directive) in Great Britain.

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• The Countryside and Rights of Way Act 2000 (CroW)

This act strengthens wildlife enforcement legislation.

• The Protection of Badgers Act 1992

Species-Specific Legislation Species specific legislation is provided in the Table below:

Species-Specific Wildlife Legislation

Feature/Species Legislation It is an offence to: • Pick;

• Uproot; Sch. 8 Wildlife and Countryside Plants • Trade; Act 1981 (as amended) • Possess (for trade)

Any wild plant listed.

Invasive weeds – Japanese Sch. 9 Wildlife and Countryside • Allow to spread. knotweed, Himalayan balsam, Act 1981 (as amended) Outlines a number of criteria for designation of ‘important’ hedgerows. Hedgerows Hedgerow Regulations 1997. ‘Important’ hedgerows cannot be removed without notifying the relevant body.

• Kill;

• Injure; Wildlife and Countryside Act 1981 (as amended). Breeding birds • Take; Countryside and Rights of Way Act 2000. any wild bird, their eggs or nest (with the exception of those on Sch. 2).

As above but includes: Sch. 1 Wildlife and Countryside Specially protected birds • Disturbing birds at their Act 1981 (as amended). nest, or their dependent young.

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Feature/Species Legislation It is an offence to: • Wilfully kill, injure, take, or cruelly ill-treat a badger, or attempt to do so;

• Possess any dead badger or any part of, or anything derived from, a dead badger;

• Intentionally or recklessly interfere with a sett by disturbing badgers whilst The Protection of Badgers Act Badgers they are occupying a sett, 1992 damaging or destroying a sett, causing a dog to enter a sett, or obstructing access to it.

A badger sett is defined in the legislation as “any structure or place, which displays signs indicating current use by a badger”.

• Intentionally or deliberately kill, inure or capture (or take) bats:

Sch. 5 Wildlife and Countryside • Deliberately disturb bats Act 1981 (as amended). (whether in a roost or not); Bats Conservation of Habitats and Species Regulations 2010 (as • Recklessly disturb roosting amended). bats or obstruct access to their roosts;

• Damage or destroy bat roosts.

Deliberate or reckless: Sch. 5 Wildlife and Countryside • Killing; Act 1981 (as amended). Common reptiles Countryside and Rights of Way • Injuring Act 2000. • Sale.

Sch. 5 and Sch. 9 Wildlife and Countryside Act 1981 (as • Sell; Common amphibians amended). • Transport; and Countryside and Rights of Way • Advertise for sale. Act 2000.

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Feature/Species Legislation It is an offence to: • Kill; Sch. 5 Wildlife and Countryside • Injure; Act 1981 (as amended). Great crested newt Conservation of Habitats and • Disturb Species Regulations 2017 (as amended). • Destroy any place used for rest or shelter.

• Deliberately capture, injure or kill; • Disturb a water vole whilst it Sch. 5 Wildlife and Countryside is in its breeding or resting Water vole Act 1981 (as amended). place; • Damage, destroy or obstruct a water vole’s breeding or resting place.

In addition, species and habitats listed on the UK Post-2010 Biodiversity Framework (formally the UK BAP) are also considered. Details on these species and habitats can be found at: http://jncc.defra.gov.uk/page-5705.

Protected Sites A network of protected sites, at varying levels, have been put in place across the UK. Further details are provided below;

International importance • Natura 2000

Natura 2000 is the name of the European Union-wide network of nature conservation sites established under the EC Habitats and Birds Directives. This network will comprise Special Areas of Conservation (SACs) and Special Protection Areas (SPAs).

• Special Areas of Conservation (SAC)

SACs are designated under the EC Habitats Directive. The Directive applies to the UK and the overseas territory of Gibraltar. SACs are areas which have been identified as best representing the range and variety within the European Union of habitats and (non-bird) species listed on Annexes I and II to the Directive. SACs in terrestrial areas and territorial marine waters out to 12 nautical miles are designated under the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended). New and/or amended Habitats Regulations are shortly to be introduced to provide a mechanism for the designation of SACs and SPAs in UK offshore waters (from 12-200 nm).

National importance • Sites of Special Scientific Interest (SSSI)

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The SSSI series has developed since 1949 as the national suite of sites providing statutory protection for the best examples of the UK’s flora, fauna, or geological or physiographical features. Most SSSIs are privately-owned or managed; others are owned or managed by public bodies or non-government organisations. The SSSIs designation may extend into intertidal areas out to the jurisdictional limit of local authorities, generally Mean Low Water in England and Northern Ireland; Mean Low Water of Spring tides in Scotland. In Wales, the limit is Mean Low Water for SSSIs notified before 2002, and, for more recent notifications, the limit of Lowest Astronomical Tides, where the features of interest extend down to LAT. There is no provision for marine SSSIs beyond low water mark. Originally notified under the National Parks and Access to the Countryside Act 1949, SSSIs have been renotified under the Wildlife and Countryside Act 1981. Improved provisions for the protection and management of SSSIs were introduced by the Countryside and Rights of Way Act 2000 (in England and Wales) and the Nature Conservation (Scotland) Act 2004.

Regional/local importance • Wildlife Sites

Local authorities for any given area may designate certain areas as being of local conservation interest. The criteria for inclusion, and the level of protection provided, if any, may vary between areas. Most individual counties have a similar scheme, although they do vary. These sites, which may be given various titles such as ‘Listed Wildlife Sites’ (LWS), ‘County Wildlife Sites’ (CWS), ‘Local Nature Conservation Sites’ (LNCS), ‘Sites of Importance for Nature Conservation’ (SINCs), or Sites of Nature Conservation Importance’ (SNCIs), together with statutory designations, are defined in local and structure plans under the Town and Country Planning system and are a material consideration when planning applications are being determined.

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APPENDIX C : Methodologies

Assessment Method for Bats

Following current good practice guidelines (Collins (ed) 2016), the assessment comprised a visual inspection of each of the trees and built structures, for the latter including any internal areas such as roof voids or cellars. For ease of reference, each structure was numbered B1, B2, B3 etc and trees were numbered T1, T2, T3 etc. The location and description of any features such as holes, crevices or internal voids that could potentially be used by roosting bats was recorded and a search was made for any evidence of bat presence such as droppings or feeding remains. Binoculars, ladders, high powered torches and endoscopes were used where necessary to facilitate more detailed inspection of individual features. Based on the number, location and type of any potential roost features, structures and trees were categorised as having negligible, low, moderate or high potential for roosting bats, or confirmed roost where direct evidence of bat presence was encountered. Evaluation of roost potential is necessarily subjective and relies on the professional judgment of the surveyor; however, the table below provides a useful guide to how this is informed.

Examples of characteristics that inform assessment of roost potential

Status Typical characteristics • Modern construction / immature trees

Negligible • Lack of access points for bats potential • Situated within very poor quality foraging habitat • High levels of external lighting

• Small number of minor hole / crevice features suitable for opportunistic roosting • Lack of roof voids or small cluttered roof spaces Low • Features obscured by dense cobwebs potential • Unlikely to support breeding or hibernating bats • Situated within poor quality foraging habitat

• One or more hole / crevice features suitable for roosting, e.g. damaged soffits, uneven roof tiles Moderate • Access into large, dark internal spaces such as roof voids potential • Trees with small fissures and crevices in dead wood suitable for day roosting • Situated within or near to moderate/good quality foraging habitat

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Status Typical characteristics • Old buildings / mature or veteran trees • Trees with woodpecker holes or deep fissures and crevices in dead wood • Structures with large, uncluttered roof voids • Traditional brick, stone or timber framed barns High • Features suitable for large numbers of bats and/or several different species potential • Types of structure suitable for hibernation, e.g. caves, tunnels, ice houses etc • Low level of disturbance by humans • Little / no external lighting • Situated within good quality foraging habitat

Bats seen or heard within the roost feature during the survey Confirmed Bat droppings, particularly if piled rather than scattered Roost Feeding remains such as moth wings Existing record of roost at that location

Guidance for assessing the overall value of potential development sites for bats (Collins (ed), 2016)

Site Status Description • No features likely to be used by bats • Small number of potential roost sites but unlikely to be suitable for maternity roosts or hibernacula • Isolated habitat that could be used by foraging bats • Isolated site not connected by prominent linear features to suitable other/adjacent foraging habitats • Several potential roost sites in buildings, trees or other structures • Habitat suitable for foraging bats (e.g. trees, water, scrub, grassland present) • Site is connected with the wider landscape by features that could be used by foraging/commuting bats (e.g. gardens backed by scrub or line of trees) • Buildings, trees or other structures (e.g. caves or underground structures) of particular significance for roosting bats • Site includes high quality foraging habitat (e.g. broadleaved woodland, tree-lined watercourses, parkland with mature trees and rough grass) • Site is connected with the wider landscape by strong linear features that could be used by commuting bats (e.g. hedgerows, river valleys)

• Site is close to known roosts Increasing site value for bats bats for value site Increasing • Bats recorded or observed using an area for foraging or commuting close to a potential roost

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APPENDIX D : Information to inform an Appropriate Assessment in respect of the proposed Saxon Brickworks development Introduction

This Appendix provides the information to enable Cambridgeshire County Council, the Competent Authority under the Habitat Regulations, to make a decision on whether or not the proposed development at Saxon Brickworks will adversely affect the integrity of the European Sites that are within range of the potential effects arising from the proposed development. The Legal and Policy Background

The Birds Directive

The EU Directive on the Conservation of Wild Birds, also known as the Birds Directive, provides a framework for the conservation and management of wild birds in Europe. The relevant provisions of the Directive are the identification and classification of Special Protection Areas (SPA) for rare or vulnerable species listed in Annex I of the Directive and for all regularly occurring migratory species (required by Article 4). The Directive requires national Governments to establish SPAs and to have in place mechanisms to protect and manage them. The SPA protection procedures originally set out in Article 4 of the Birds Directive have been replaced by the Article 6 provisions of the Habitats Directive. The Habitats Directive

The EU Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora, also known as the Habitats Directive, provides a framework for the conservation and management of natural habitats, wild fauna (except birds) and flora in Europe. Its aim is to maintain or restore natural habitats and wild species at a favourable conservation status. The relevant provisions of the Directive are the identification and classification of Special Areas of Conservation (SAC) (Article 4) and procedures for the protection of SACs and SPAs (Article 6). SACs are identified based on the presence of natural habitat types listed in Annex I and populations of the species listed in Annex II. The Directive requires national Governments to establish SACs and to have in place mechanisms to protect and manage them. Article 6(3) of Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive) requires that:

“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.”

It then requires with respect to agreeing to that project:

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“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.”

The Conservation of Habitats and Species Regulations 2017

The Conservation of Habitats and Species Regulations 2017, (referred to here as the ‘Conservation Regulations’) transposes the Birds Directive and the Habitats Directive into national law, operating in conjunction with the Wildlife and Countryside Act 1981. The Conservation Regulations place an obligation on ‘competent authorities’ to carry out an appropriate assessment of any proposal likely to affect a SAC or SPA, to see advice from Natural England and not to approve an application that would have an adverse effect on a SAC or SPA except under very tightly constrained conditions that involve the decisions by the Secretary of State. Competent authorities are defined in the Regulations as “any minister, government department, public or statutory undertaker, public body of any description or person holding a public office”. The most relevant part is Regulation 61:

“(1)

A competent authority, before deciding to undertake, or give any consent, permission or other authorisation for, a plan or project which —

(a) is likely to have a significant effect on a European site or a European offshore marine site (either alone or in combination with other plans or projects), and

(b) is not directly connected with or necessary to the management of that site, must make an appropriate assessment of the implications for that site in view of that site’s conservation objectives.

(5)

In the light of the conclusions of the assessment, and subject to regulation 62 (considerations of overriding public interest), the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site or the European offshore marine site (as the case may be).”

Circular Accompanying PPS9

Although the government policy statement on biodiversity and geological conservation, PPS9 (ODPM 2005a) has since been superseded by the National planning Policy Framework (2012), the accompanying Circular (ODPM 2005b) for the former guidance

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(which presently remains an active document) provides administrative guidance on the application of the law relating to planning and nature conservation as it applies in England. Part 1 of the Circular includes a description of the process that a local planning authority, as a Competent Authority under the Conservation Regulations, is required to go through in relation to development proposals and European and Ramsar sites. As a matter of UK Government policy Ramsar sites are afforded the same protection as SPAs and SACs and are expected to be treated in decision making processes in the same way as European sites. Potential Effect of the Proposed Development

In accordance with the requirement to take a precautionary approach to assessing potential effects on European or Ramsar sites, a very wide ranging consideration has been given to the potential sources of effects that may arise from the development. This initial consideration has been given without taking account of any mitigation actions. These potential sources of effects are set out below, sub-divided into the manner by which they might manifest at the European or Ramsar site, should a pathway exist.

Habitat Loss

The loss of habitat of value to the interest features of European or Ramsar sites can occur in two ways:

• The direct loss of land within the designated site due to the development footprint; and/or • The loss of land outside of the designated site that is used by species that are interest features of European or Ramsar sites.

Habitat Degradation

Habitat degradation within a designated site could result from a number of effects arising as a result of the Proposed Development:

• Emissions of compounds to the air from the combustion processes proposed in the development and from vehicle movements associated with the development;

• Emissions of pollutants direct to watercourses or groundwater or indirectly to watercourses after discharge to the sewerage system and treatment at a waste water treatment works;

• Rain water runoff from hard surfaces carrying with it polluting matter;

• Abstraction of water direct from ground or surface waters; and/or

• Interruption to groundwater movements through foundation structures.

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Effects on Species not Mediated Through Habitat

As well as the effects on habitats identified above that affect species utilising that habitat, there are also potential effects that affect species directly. Those that might arise as a result of the Proposed Development are:

• Noise causing disturbance to species;

• Lighting causing disturbance to species;

• Movement of people and vehicles on the proposed development site causing disturbance to species;

• Vehicle movements generating noise and light along routes to the proposed development site causing disturbance to species;

• Recreational access to adjacent land by workers at the proposed development site causing disturbance to species;

• Recreational access by the public to adjacent land, enabled by car parking at the proposed development site, causing disturbance to species;

• Predatory/scavenging animals attracted by food sources at the proposed development site that then predate animals in the adjacent area; and/or

• Domestic pets (dogs/cats) kept by workers at the proposed development site that then access adjacent land and predate or disturb species.

The European and Ramsar Sites Potentially Subject to Significant Effects

The SPA, SAC and Ramsar sites that are within 10km of the Application Site with their interest features are set out below. Those sites considered are as follows:

• Nene Washes SAC, SPA, Ramsar

• Orton Pit SAC

Nene Washes

Introduction

This site lies approximately 1 km to the north of the proposed development site. It represents one of the country’s few remaining areas of washland habitat which is essential to the survival nationally and internationally of populations of wildfowl and waders. The site is additionally notable for the diversity of plant and associated animal life within its network of dykes. The washlands are used for the seasonal uptake of floodwaters and, traditionally, for cattle grazing in the summer months. The mosaic of rough grassland and wet pasture provide a variety of sward structure and herbs of importance respectively for bird nesting habitat and feeding. Additional winter feeding is provided by remains of arable cropping on small areas.

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These washlands play an additional role in relation to the nearby Ouse Washes in that they accommodate wildfowl populations displaced from the Ouse Washes when deep floodwaters prevent their feeding. The site is favoured by large numbers of wintering wildfowl and particularly the dabbling ducks wigeon Anas penelope, teal Anas crecca, pintail A. acuta and Bewick’s swan Cygnus bewickii. Wetland birds such as snipe Gallinago gallinago and redshank Tringa tetanus regularly breed and during passage periods there is often a large movement of waders and raptors through the area. Many of the ditches hold a rich flora that includes such uncommon species as frogbit Hydrocharis morsus-ranae, water violet Hottonia palustris and flowering rush Butomus umbellatus.

Features of European Interest

The site is designated as an SPA for supporting:

• During the breeding season

o Ruff Philomachus pugnax - 1 individual representing at least 9.1% of the breeding population

o Spotted Crake Porzana porzana, 5 individuals representing at least 10.0% of the breeding population

• Over winter

o Bewick's Swan Cygnus columbianus bewickii, 1,718 individuals representing at least 24.5% of the wintering population

o Ruff Philomachus pugnax, 91 individuals representing at least 13.0% of the wintering population

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European importance of the following migratory species:

• During the breeding season

o Black-tailed Godwit Limosa limosa, 16 pairs representing <0.1% of the breeding population

• Over winter

o Pintail Anas acuta, 1,435 individuals representing at least 2.4% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6)

o Shoveler Anas clypeata, 413 individuals representing at least 1.0% of the wintering Northwestern/Central Europe population

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The site qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting 25,437 waterfowl including: Black-tailed Godwit Limosa limosa islandica, Lapwing Vanellus vanellus, Pochard Aythya ferina, Teal Anas crecca, Gadwall Anas strepera, Wigeon Anas penelope, Shoveler Anas clypeata, Pintail Anas acuta, Ruff Philomachus pugnax and Bewick's Swan Cygnus columbianus bewickii.

As well as its bird assemblage, the Nene Washes are designated as a Ramsar site for supporting several nationally scarce plants, and two vulnerable and two rare British Red Data Book invertebrate species have been recorded.

The site is designated as an SAC for its populations of:

• Spined loach Cobitis taenia

Orton Pit

Introduction

Orton Pit’s extensive pond system, occupying the disused ridge-and-furrow created as a result of clay extraction for the brick-making industry, contains alkaline water low in nutrients.

The site supports a total of ten species of charophyte including one of the main English populations of bearded stonewort Chara canescens. C. canescens is an early coloniser of ponds at the site and is rarely found in ponds over 25 years old. It favours brackish conditions, which at Orton Pit are thought to be provided by the release of salts out of the top few millimetres of the clay that becomes oxidised over a period of time. Other nationally scarce stonewort species present include Chara aspera, C. contraria, C. pedunculata and Tolypella glomerata. The distribution of Chara species across the site varies according to the age and stage of succession of the ponds, with few being found in ponds greater than 25 years old.

Orton Pit supports a large population of great crested newts Triturus cristatus. The range of habitats found throughout the site, including the extensive pond systems at various successional stages, as well as surrounding areas of grassland and scrub, provide good conditions for breeding, feeding and sheltering newts.

Features of European Interest

The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:

• Hard oligo-mesotrophic waters with benthic vegetation of Chara spp. (Calcium-rich nutrient-poor lakes, lochs and pools)

Qualifying species: The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:

• Great crested newt Triturus cristatus

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Scoping Out of Particular Effects

A number of potential effects have been considered and scoped out from more detailed consideration in this report to inform the appropriate assessment.

These potential effects and why they have been scoped out from more detailed consideration are presented below:

Direct Land Take of a European or Ramsar Site

The application site is not within the boundary of any European or Ramsar site, nor is it immediately adjacent to or close to such a site.

The application site is situated 1km to the north of the Nene Washes SAC and 7.8km to the east of Orton Pit SAC, separated by built-up areas of Whittlesey, arable land and the Kings Dyke active brickworks and nature reserve area.

Domestic Pets as Predators

The proposed development contains no domestic or residential elements and as such there will be no people permanently living on site. Also, the site is distant from the Nene Washes and more so from Orton Pit and as such even if there were an increase in local pets this would not be significant on the distant feature. As a result it can be concluded that this particular effect relevant to the proposed development can been screened out from more detailed assessment.

Predators and Scavengers

The proposed development is a change of use of the site to facilitate from a waste processing area for plastic recovery and recycling to the processing of Incinerator Bottom Ash (IBA) and Construction and Demolition (C&D) Waste, and as such will not attract scavengers to the site. As a result it can be concluded that this particular effect relevant to the proposed development can been screened out from more detailed consideration.

Lighting Causing Disturbances to Species

At the time of writing it is understood that the proposed development does not include any significant lighting schemes that would impact on the distant Nene Washes. The proposed core working hours are 06:00 to 18:00 and as such significant night-time disturbances associated with artificial lighting are not anticipated.

Land Take of Land Used by an Interest Feature When Outside the Protected Site

There will be a very small area of land-take associated with the proposed development comprising areas of scrub and ephemeral / short perennial habitats which the latter has been highlighted as likely qualifying as the priority habitat “open mosaic habitat on previously disturbed ground”. However, these areas are small in their nature, adjacent to areas of existing high disturbance from the current use of the site and to an extent on steeply sloping ground.

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Habitats which are lost are considered unsuitable to support any of the interest Features of the European sites.

The site is dominated by existing hard standing, buildings and disturbed bare ground associated with the current Plastic Recovery Facility and the former brickworks.

The site does not support habitats suitable for the breeding or wintering requirements of those species of interest cited above, with the exception of great crested newts. However, as this species is associated with Orton Pit which lies 7.8km it is considered that whilst the habitat on site may support this species (as a large population of great crested newt are noted on the Kings Dyke Nature Reserve), the distance from Orton Pit means that there is no functional connection between this site and the proposed development.

There are no significant habitat features (e.g. large open lagoons, extensive marshland etc) nearby that would be subject to indirect disturbances.

As such there are no anticipated impacts on land that may be used by an interest feature outside of the protected site.

Potentially Polluting Emissions to Water/Hydrogeology

The proposed development is a change of use and as such only local pollution control measures are required. No features link the site to the Protected Site and there will be no groundwater impacts.

Surface water run-off from the existing site is collected by a series of ditches around the base of the pit, which in turn convey water to a settling lagoon. From the settling lagoon, surface water is pumped into the Kings Dyke, with an existing discharge consent with the Middle Levels Commissioners.

Proposals for the site do not seek to inherently change the surface water regime. Existing surfacing and gradients are to be maintained as much as possible, with existing buildings retained for re-use. As such, the surface water drainage regime from the majority of the application area will remain unchanged. The only area where this will differ is the area on which the imported IBA will be stored. Whilst considered non-hazardous, the nature of the material can be detrimental to surface water drainage/water bodies due to the high fines content. As such, it is a requirement that this material is stored on an impermeable surface with an isolated surface water drainage strategy. The IBA storage area is graded to ensure that all run-off is directed towards a wedge pit/sump in the north east corner of the slab. Through a combination of proposed gradients and a watertight perimeter wall, all surface water run-off up to a 100 year return period storm event with a 20% allowance for climate change is contained within this isolated area. Water from the wedge pit is then re- used/recycled where possible as part of the processing and for dust suppression, with any surplus water being removed via tanker to an appropriately licensed waste receiver.

Further information related to water/hydrology of the site can be found thawing the Drainage Strategy which will accompany the planning application.

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Effects Scoped In for More Detailed Consideration in this Report

The potential effects of the proposed development that were considered most likely to give rise to significant effects on the interest features of the Nene Washes and Orton Pit and hence would be considered in more detail for potential adverse impact on the integrity of the European designations are set out below.

Air/Dust Pollution and noise

There is potential for airborne dust to reach the Protected Site if adequate protection measures are not in place during the operational phase of the development.

Impacts from increased dust levels are considered not to pose an effect on protected sites as a method has already been identified to negate this from becoming an issue.

Prior to dispatch from an incinerator facility, the IBA is heavily doused with water to both reduce its temperature and minimise the risk of air borne particles arising from its transport and deposit. Upon delivery to the site via HGV’s the IBA is tipped into bays within the identified IBA reception and storage area, where it is doused again to create a crust on the stockpile to prevent dust generation and allow it to mature.

Once at the proposed development area for processing, the topography of the land is also conducive to the prevention of dusk travelling from the site to a Protected Site due to the processing occurring in the base of the former quarry area.

With protection measures in place to both the incinerator facility and at the proposed development and the fact that the site is situated within former brickworks long distant dust travel is not anticipated.

In order to determine the requirement for further consideration of impacts at the Protected Sites, reference was made to the Air Pollution Information System (APIS) online resource. This indicated that Critical Loads for nitrogen deposition have not been assigned to the SAC and SSSI designated features for either Nene Washes or Orton Pit. As such, the designations are not considered sensitive to changes in air quality as a result of the proposed development and further assessment was not undertaken. For further information relating to air quality and noise, please refer to the independent reports issued with this planning submission.

No distant noise impacts are anticipated and generally the works would be low level operations that would not have far reaching impacts on the Nene Washes or the wider Orton Pit.

Summary of the Detailed Assessment

It can be concluded that there will be no adverse effects on the interest features of the nearby protected sites.

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No adverse effects on the integrity of any features of the European sites have been identified and as a result there is no need to consider further mitigation measures above and beyond those that are set out in the ecological baseline study and other technical documentation in support of this application.

These measures include minimising the footprint of the development to predominately existing hard standing and buildings of low ecological value and minimising pollution risks such as water, ground water, lighting and dust through best practice construction and operational procedures.

Conclusion

This assessment has followed guidance published by the UK Government and the European Commission and in accordance with the relevant legislation.

This report, to inform the Appropriate Assessment, has assessed and identified the potential effects of the proposed develop during construction and operational phases.

Baseline data has been collated through desk study and site survey. Further survey effort is recommended at the site level to further refine mitigation, enhancement and compensation measures, however such further survey will not alter the finding of this assessment of impacts on protected sites.

The assessment identified no significant adverse effects on the interest features of the European site during the construction/demolition and operational phase of the proposed scheme and it is considered that this proposed development will not affect the integrity of the Nene Washes SAC/SPA/Ramsar/SSSI or Orton Pit SAC/SSSI.

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APPENDIX E : Site Photographs

No. Description Photograph

Typical view of the buildings (B3), 1 hard standing the disturbed bare ground present

Eastern edge of Broadleaved 2 plantation woodland

Typical views of disturbed bare 3 ground located on the western side of the study area

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No. Description Photograph

Ephemeral / short perennial 4 vegetation

5 Northern section of Ditch 5

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No. Description Photograph

Ditch 3 looking south showing the 6 – extent of flooding in this area

Disturbed bare ground to east of 7 broadleaved plantation woodland

8 Ditch 4

9 Building B1

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No. Description Photograph

10 Building B2

11 Buildings B5 and B6

12 Building B7

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No. Description Photograph

Example of the ponds (13, 14, 16, 13 17, 18 and 19) to the west of the development area.

14 Looking west along Ditch 2

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APPENDIX F : Target Notes

No. Description Photograph

Flooded area around Ditch 5 to 1 side of building B1(western area)

Open mosaic habitat (photo is of the slightly larger area immediately 2 off site, but shows the similar composition to that found on site).

Flooded area around Ditch 3 3 (eastern area)

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No. Description Photograph

4 Spoil heap (to rear of building B2)

Spoil heap (around base of 5 chimney, building B3)

6 Known peregrine feeding perch / post on the chimney, building B3

7 Known nesting site for kestrel (on building B4)

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APPENDIX G : Habitat Suitability Index

Pond Number 13, 14, 16, 17, 18, and 19

SI1 – Location A 1.0 2 SI2 – Pond Area (m ) 28 0.056

SI3 – Pond Drying Sometimes dries 0.5

SI4 - Water Quality Moderate 0.67

SI5 - Shoreline Shade (1m from the shore) (%) 0 1

SI6 - Fowl Absent 1

SI7 - Fish Possible 0.67

SI8 - Pond Count 12+ 1

SI9 - Terrestrial habitat Moderate 0.67

SI10 - Macrophytes (% of the pond surface area occupied by macrophyte cover) 0 0.3 Habitat Suitability Index (HSI Score) 0.55 Pond Suitability Below average

Pond Number 15

SI1 - Location A 1.0 2 SI2 - Pond Area (m ) 2444 0

SI3 - Pond Drying Never dries 0.9

SI4 - Water Quality Moderate 0.67

SI5 - Shoreline Shade (1m from the shore) (%) 0 1

SI6 - Fowl Minor 0.67

SI7 - Fish Possible 0.67

SI8 - Pond Count 12+ 1

SI9 - Terrestrial habitat Poor 0.33

SI10 - Macrophytes (% of the pond surface area occupied by macrophyte cover) 0 0.3 Habitat Suitability Index (HSI Score) 0.67 Pond Suitability Average

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