Habitats Regulations Assessment – Screening of Likely Significant Effects Report

West Sussex Minerals & Waste Development Framework Habitats Regulations Assessment – Screening of Likely Significant Effects Report

For Issue March 2010

Prepared for

West Sussex County Council West Sussex Minerals & Waste Development Framework

Revision Schedule

HRA Screening Report March 2010

Rev Date Details Prepared by Reviewed by Approved by

01 February DRAFT Jamie Woollam Dr James Riley Dr James Riley 2010 Ecologist Principal Ecologist Principal Ecologist

02 March 2010 For issue Dr James Riley Principal Ecologist

Scott Wilson Scott House Alençon Link This document has been prepared in accordance with the scope of Scott Wilson's appointment with its client and is subject to the terms of that appointment. It is addressed Basingstoke to and for the sole and confidential use and reliance of Scott Wilson's client. Scott Wilson Hampshire accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. No person other than the client may RG21 7PP copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the Tel 01256 310200 context of the document as a whole. The contents of this document do not provide legal or tax advice or opinion. Fax 01256 310201

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Table of Contents

1 Introduction ...... 1 1.1 Legislation ...... 1 1.2 Scope and objectives ...... 2 2 Methodology ...... 3 2.1 Key principles ...... 3 2.2 Process ...... 3 2.3 Likely Significant Effects (LSE) ...... 5 2.4 Physical scope of the assessment ...... 5 3 Pathways of impact...... 7 3.1 Introduction...... 7 3.2 Atmospheric pollution ...... 7 3.3 Water quality and flows ...... 16 3.4 Predation ...... 17 3.5 Disturbance ...... 17 3.6 Direct landtake ...... 20 3.7 Coastal squeeze...... 21 3.8 Screening distance summary ...... 21 4 Screening Tables...... 22 5 Conclusions of Screening ...... 34 5.1 Minerals sites ...... 34 5.2 Waste sites...... 34 5.3 Waste and minerals Issues and Options...... 34 5.4 Next steps ...... 35 Appendix 1 - Background on European sites referenced in this document ...... 36 Appendix 2 - ‘Tiering’ in Habitat Regulations Assessment...... 40

West Sussex County Council West Sussex Minerals & Waste Development Framework

1 Introduction

1.1 Legislation

1.1.1 In October 2005, the European Court of Justice ruled that the UK had failed to correctly transpose the provisions of Articles 6(3) and (4) of Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora – the Habitats Directive – into national law. Specifically, the UK had failed to ensure that land use plans are subject to Appropriate Assessment where they might have a significant effect on a Natura 2000 site (Special Areas of Conservation, SACs and Special Protection Areas, SPAs). It is Government policy (as described in Planning Policy Statement 9: Biodiversity & Geological Conservation) for sites designated under the Convention on Wetlands of International Importance (Ramsar sites) to be treated as having equivalent status to Natura 2000 sites. As such, Appropriate Assessments should also cover these sites.

1.1.2 The need for Habitat Regulations Assessment is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British law by the Conservation (Natural Habitats &c) Regulations 1994 (as amended in 2007). The ultimate aim of HRA is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates to habitats and species, not the European sites themselves, although the sites have a significant role in delivering favourable conservation status.

1.1.3 The Habitats Directive applies the precautionary principle to protected areas; plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. This is in contrast to the SEA Directive which does not prescribe how plan or programme proponents should respond to the findings of an environmental assessment; it simply says that the assessment findings (as documented in the ‘environmental report’) should be ‘taken into account’ during preparation of the plan or programme. In the case of the Habitats Directive, plans and projects may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead. In such cases, compensation would be necessary to ensure the overall integrity of the site network.

1.1.4 In order to ascertain whether or not site integrity will be affected, an HRA should be undertaken of the plan or project in question:

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Box 1 The legislative basis for Habitat Regulations Assessment

Habitats Directive 1992

“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.” Article 6 (3)

Conservation (Natural Habitats &c. Regulations) 1994 (as amended)

“A competent authority, before deciding to … give any consent for a plan or project which is likely to have a significant effect on a European site … shall make an appropriate assessment of the implications for the site in view of that sites conservation objectives … The authority shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site”.

1.1.5 Following the European Court ruling, the former Office of the Deputy Prime Minister (ODPM; now CLG) indicated that the regulations implementing the Habitats Directive in the UK would be amended to ensure that HRA explicitly applies to land use plans1. Planning Policy Statement (PPS) 9 states that Ramsar sites (wetlands of international importance) should receive the same protection as designated SACs and SPAs.

1.2 Scope and objectives

1.2.1 The role of the Natura 2000 sites (SACs, SPAs, Ramsar) is to provide statutory protection for terrestrial and coastal sites that are of European and global importance as a result of habitats or species contained within them. Scott Wilson has been appointed by West Sussex County Council to assist in undertaking a Habitat Regulations Assessment (HRA) of the potential effects of the Minerals & Waste Development Framework (MWDF), on the Natura 2000 network.

1.2.2 The MWDF, alongside the Regional Spatial Strategy (RSS) for the South East, will supersede the West Sussex Minerals Local Plan and West Sussex Waste Local Plan (strategic planning framework for the protection of the environment, sustainable transport priorities, and the scale, pattern and location of waste and minerals development across West Sussex).

1.2.3 Chapter 2 explains the process by which the HRA process as a whole will be carried out, focussing on the screening (Likely Significant Effects) stage – the subject of this report. Chapter 3 explores the relevant pathways of impact and the criteria on which waste and minerals sites were screened in or out of assessment. Chapter 4 presents a series of tables covering the screening of each preferred option and site that will be contained within the MWDF. Chapter 5 then summarises the conclusions of screening.

1 The Government previously argued that HRA did not apply to development plans on the basis that “Development in this context does not include development plans, since the plan itself cannot authorize developments that would affect the site” (PPG9: Nature Conservation, 1994).

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2 Methodology

2.1 Key principles

2.1.1 This section sets out the basis of the methodology for the HRA. Scott Wilson has adhered to several key principles in developing the methodology – see Table 1.

Table 1 - Key principles underpinning the proposed methodology

Principle Rationale Use existing information We will use existing information to inform the assessment. This will include information gathered as part of the SA of the emerging LDF and information held by Natural England, the Environment Agency and others. Consult with Natural We will ensure continued consultation with both Natural England and England, the Environment the Environment Agency for the duration of the assessment. We will Agency and other ensure that we utilise information held by them and others and take stakeholders on board their comments on the assessment process and findings. Ensure a proportionate We will ensure that the level of detail addressed in the assessment assessment reflects the level of detail in the MWDF (i.e. that the assessment is proportionate). With this in mind, the assessment will focus on information and impacts considered appropriate to the local level. Keep the process simple We will endeavour to keep the process as simple as possible while as possible ensuring an objective and rigorous assessment in compliance with the Habitats Directive and emerging best practice. Ensure a clear audit trail We will ensure that the AA process and findings are clearly documented in order to ensure a clearly discernible audit trail.

2.2 Process

2.2.1 The HRA is being carried out in the absence of formal Government guidance. Communities and Local Government released a consultation paper on Appropriate Assessment of Plans in 20061. As yet, no further formal guidance has emerged.

2.2.2 Fig

2.2.3

2.2.4

1 CLG (2006) Planning for the Protection of European Sites, Consultation Paper

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2.2.5 Figure 1 below outlines the stages of HRA according to current draft CLG guidance. The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no significant adverse effects remain.

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Evidence Gathering – collecting information on relevant European sites, their conservation objectives and characteristics and other plans or projects.

AA Task 1: Likely significant effects (‘screening’) – identifying whether a plan is ‘likely to have a significant effect’ on a European site

AA Task 2: Ascertaining the effect on site integrity – assessing the effects of the plan on the conservation objectives of any European sites ‘screened in’ during AA Task 1

AA Task 3: Mitigation measures and alternative solutions – where adverse effects are identified at AA Task 2, the plan should be altered until adverse effects are cancelled out fully

Figure 1 - Four-Stage Approach to Habitat Regulations Assessment Source: CLG, 2006

2.3 Likely Significant Effects (LSE)

2.3.1 The first stage of any Habitat Regulations Assessment (AA Task 1) is a Likely Significant Effect (LSE) test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:

2.3.2 ”Is the Plan, either alone or in combination with other relevant projects and plans, likely to result in a significant effect upon European sites?”

2.3.3 The objective is to ‘screen out’ those plans and projects that can, without any detailed appraisal, be said to be unlikely to result in significant adverse effects upon European sites, usually because there is no mechanism for an adverse interaction with European sites.

2.3.4 That screening assessment is the purpose of this report.

2.4 Physical scope of the assessment

2.4.1 There is no pre-defined guidance that dictates the physical scope of an HRA of a land use plan. Therefore, in considering the physical scope of the assessment, we have been guided primarily by the identified impact pathways rather than by arbitrary ‘zones’. Current guidance suggests that the following European sites be included in the scope of assessment:

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 All sites within the authority’s boundary; and  Other sites shown to be linked to development within the authority’s boundary through a known ‘pathway’ (discussed below)

2.4.2 Briefly defined, pathways are routes by which a change in activity within West Sussex can lead to an effect upon a European site. In terms of the second category of European site listed above, CLG guidance states that the AA should be ‘proportionate to the geographical scope of the [plan policy]’. The scope of the HRA has been informed by initial screening work undertaken by West Sussex County Council in consultation with Natural England.

2.4.3 The following European sites lie, wholly or partially, within West Sussex:

 Kingley Vale SAC  Rook Clift SAC  Duncton to Bignor Escarpment SAC  Singleton and Cocking Tunnels SAC  The Mens SAC  Ebernoe Common SAC  Solent Maritime SAC (West Sussex/Hampshire)  Chichester and Langstone Harbours SPA/Ramsar (West Sussex/Hampshire)  Pagham Harbour SPA/European Marine Site/Ramsar  Arun Valley SPA/Ramsar  Wealden Heaths Phase II SAC (Hampshire/Surrey/West Sussex)

2.4.4 The Following European sites lie close to the borders of West Sussex:

 East Hampshire Hangers SAC (Hampshire)  Ashdown Forest SAC/SPA (East Sussex)

2.4.5 These European sites are all therefore automatically included with the scope of the HRA (at least at screening) and are subject to consideration within this document as to whether they have links with development within West Sussex via pathways as described in Chapter 3. At this stage no further sites outside West Sussex have been identified as being connected with waste and minerals development within the county by a relevant pathway.

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3 Pathways of impact

3.1 Introduction

3.1.1 This section of the report summarises the various impact pathways that can link Waste and minerals development in West Sussex with European sites.

3.2 Atmospheric pollution

3.2.1 Current levels of understanding of air quality effects on semi-natural habitats are not adequate to allow a rigorous assessment of the likelihood of significant effects on the integrity of key European sites.

3.2.2 The National Expert Group on Trans-boundary Air Pollution (2001)2 concluded that:

 In 1997, critical loads for acidification were exceeded in 71% of UK ecosystems. This was expected to decline to 47% by 2010.

 Reductions in SO2 concentrations over the last three decades have virtually eliminated the direct impact of sulphur on vegetation.  By 2010, deposited nitrogen was expected to be the major contributor to acidification,

replacing the reductions in SO2.  Current nitrogen deposition is probably already changing species composition in many nutrient-poor habitats, and these changes may not readily be reversed.  The effects of nitrogen deposition are likely to remain significant beyond 2010.  Current ozone concentrations threaten crops and forest production nationally. The effects of ozone deposition are likely to remain significant beyond 2010.  Reduced inputs of acidity and nitrogen from the atmosphere may provide the conditions in which chemical and biological recovery from previous air pollution impacts can begin, but the timescales of these processes are very long relative to the timescales of reductions in emissions.

3.2.3 Grice et al3 4 do however suggest that air quality in the UK will improve significantly over the next 15 years due primarily to reduced emissions from road transport and power stations.

3.2.4 Waste sites (particularly incinerators and landfill sites) can contribute substantially to the atmospheric pollution load through emission of the following pollutants:

2 National Expert Group on Transboundary Air Pollution (2001) Transboundary Air Pollution: Acidification, Eutrophication and Ground-Level Ozone in the UK 3 Grice, S., T. Bush, J. Stedman, K. Vincent, A. Kent, J. Targa and M. Hobson (2006) Baseline Projections of Air Quality in the UK for the 2006 Review of the Air Quality Strategy, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland. 4 Grice, S., J. Stedman, T. Murrells and M. Hobson (2007) Updated Projections of Air Quality in the UK for Base Case and Additional Measures for the Air Quality Strategy for England, Scotland, Wales and Northern Ireland 2007, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland.

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 Methane (CH4) - Methane is produced when organic matter is broken down in the absence of oxygen and large quantities are produced by livestock, the spreading of animal manure and landfill sites. Waste treatment, including landfill, released nearly 22% of the UK's methane emissions in 2003, about 2% of all greenhouse gas emissions (in terms of carbon equivalents)5.

 Carbon Dioxide (CO2) - Carbon dioxide is one of the major combustion products from burning fossil fuels. It is also produced in certain non-combustion chemical reactions, for instance in the manufacture of cement. Carbon dioxide is a long-lived pollutant and will remain in the atmosphere for between 50 and 200 years. Carbon dioxide contributes to the greenhouse effect6.  Oxides of Nitrogen (NOx) - Oxides of nitrogen are formed during high temperature combustion processes from the oxidation of nitrogen in the air. The principal source of oxides of nitrogen is road traffic, which is responsible for approximately half the emissions in Europe7. NOx concentrations are therefore greatest in urban areas where traffic is heaviest. An increase in the deposition of nitrogen from the atmosphere to soils is generally regarded to lead to an increase in soil fertility, which can have a serious deleterious effect on the quality of semi-natural, nitrogen-limited terrestrial habitats. High NOx levels can also have directly toxic effects on plants.

 Ammonia (NH3) – This is probably the major source of nitrogen deposition to many wildlife sites, and is primarily agricultural in origin8, although it is also produced through some industrial process and by the composting of organic matter on waste sites.

 Sulphur dioxide (SO2) – this is an acidic gas that combines with water vapour in the atmosphere to produce acid rain. Both wet and dry depositions have been implicated in the damage and destruction of vegetation and in the degradation of soils and watercourses. Major SO2 problems now only tend to occur in cities in which coal is still widely used for domestic heating, in heavy industry and in power stations9.

 Low-level ozone (O3) – this is unlike the other pollutants mentioned, in that it is not emitted directly into the atmosphere, but is a secondary pollutant produced by a complex reaction 10 between nitrogen dioxide (NO2), hydrocarbons and sunlight . Unlike the other pollutants, it cannot therefore be directly related to increases in housing, traffic etc. Although peak levels of ozone are generally reducing, annual average levels are generally increasing.  Hydrogen chloride and hydrogen fluoride (HCl and HF) – Both of these chemicals are produced in small amounts as a result of certain energy from waste facilities, principally incineration. HF is the most phytotoxic of all air pollutants. It accumulates in very high concentrations in the margins of leaves. In sensitive species this may lead to distortion of the leaf shape, chlorosis (yellowing), red colouration and, in extreme cases, death of

5 Environment Agency website 6 UK Air Pollution Information System www.apis.ac.uk 7 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 8Institute of Grassland and Environmental Research http://www.iger.bbsrc.ac.uk/Ammonia_Inventory/sources.htm 9 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 10 UK Air Pollution Information System www.apis.co.uk

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tissues. HCl can also have local, direct, effects on plants, but there is little information available about dose-response relations11.  Dioxins - These are long-lived organic compounds, which form when chlorinated substances in the waste, such as PVC plastic, are burnt and accumulate in the human food chain. Dioxin emissions to air from incinerators are thought to have decreased significantly in recent years. Four sources account for 74% of the total air emissions. These are legal municipal waste incineration (26%), sinter plants (18%), residential wood combustion (boilers, stoves, fireplaces, 16%) and incineration of hospital waste (14%). The incineration of hazardous industrial waste contributes less than 1%.12  Heavy metals – specifically Cadmium (Cd), which is a normal constituent of soil and water at low concentrations. The main sources of cadmium emissions are from waste incineration, and iron and steel manufacture13. Cadmium and other heavy metals are mainly present in the ash produced by incinerators, but some is released directly to atmosphere via the exhaust stack. Emissions of cadmium have declined substantially over recent years; this is mainly attributable to the decline in coal combustion to generate power. Environmentally, cadmium is dangerous because many plants and some animals absorb it easily and it becomes concentrated in tissues.

3.2.5 Migration of landfill gas outside the perimeter of landfill sites taking biodegradable waste can occur, but only where sites have been inadequately engineered. In such circumstances the gas will exclude oxygen from the soil and lead to the exposure and possible death of plants and soil fauna. Such effects are unlikely beyond a 0.5km radius14 in any case, but since they are a result of poor engineering design, and any current landfill sites will be required to conform to all modern authorisations, they are not considered further in this assessment.

3.2.6 For the following reasons, only NOx and ammonia are considered further as specific pollutants in this assessment:

 Despite the general association with nitrogen dioxide, ozone levels are not as high in urban areas (where high levels of nitrogen dioxide are emitted) as in rural areas. This is largely due to the long-range nature of this pollutant, which is sufficiently great that the source of emission and location of deposition often cross national boundaries. As such, low-level ozone can only be practically addressed at the national and international level.  Although methane and carbon dioxide are important greenhouse gases, it is not possible to relate quantities of these gases to particular effects on specific European sites. It is therefore not possible to consider these within the scope of this Appropriate Assessment other than by noting that increased emission of these chemicals will contribute at a global scale to accelerating rates of climate change.  Sulphur dioxide concentrations are overwhelmingly influenced (82% of emissions15) by the output of power stations and industrial processes that require the combustion of coal and oil.

11 ERM. 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council 12 Chlorine Online Information Resource website http://www.eurochlor.org/upload/documents/document57.pdf 13 National Atmospheric Emissions Inventory www.aeat.co.uk/netcen/airqual/naei/annreport/annrep96/sect6_3.htm 14 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf 15 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php

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None of these activities will be associated with developments under the Waste Development Framework and indeed the use of Energy from Waste technology will reduce reliance on

conventional power stations and therefore contribute to a reduction in SO2 emissions.  There is an enormous range in sensitivity to hydrogen chloride and hydrogen fluoride between species, and there are no commonly available critical levels for avoidance of visible injury to vegetation. Coupled with the fact that quantities emitted by incinerators will typically result in ground-level concentrations lower than the concentration that will harm vegetation16, these chemicals are not considered further in this assessment.  As with ozone, the distance from emission to deposition of dioxins can be many hundreds of miles, potentially crossing trans-national boundaries, and is dependent upon meteorological conditions. Most importantly, amounts of dioxins formed in incinerators do not depend on chlorine levels, but primarily on the design and operating temperatures of the facility17. It is therefore not possible to consider dioxin emissions in detail within this assessment. However, it is important to note that dioxins are only emitted by incineration and that incinerators are required by law to control their dioxin emissions below set thresholds.

3.2.7 Since ammonia is of relevance to European sites primarily through its effect upon nitrogen deposition, it is not considered independently of nitrogen deposition in this assessment. Since NOx can be directly toxic to plants, it is considered separately from its influence on nitrogen deposition in this assessment.

3.2.8 Eutrophication of sensitive habitats through atmospheric deposition is a widely acknowledged phenomenon, although it is extremely difficult to measure as its effects are often hidden by changes in local nutrients (i.e. via direct fertilisation) or changes in grazing pressure.

3.2.9 In well-managed sites, the effects of eutrophication may be to some extent counteracted through an increase in grazing pressure. Bobbink et al.18 suggest that sites with low intensity management may have lower critical thresholds than those in higher levels of management. Reintroducing grazing into ungrazed or under-grazed sites can help to counteract changes in vegetation due to nitrogen deposition; however increasing grazing on sites that are already well-grazed may have a direct adverse impact on the plants for which the site was designated.

3.2.10 Furthermore, air pollution can act synergistically with insufficient grazing to exacerbate management problems and lead to a coarser species-poor sward. A changing climate (i.e. rising temperatures and reduced summer rainfall) is further exacerbating the situation by putting sensitive habitats and species under increasing stress, in turn reducing their competitive ability and increasing susceptibility to pathogens.

Oxides of nitrogen and nitrogen deposition

3.2.11 The most acute impacts of NOx take place close to where they are emitted, but individual sources of pollution will also contribute to an increase in the general background levels of pollutants at a wider scale, as small amounts of NOx and other pollutants from the pollution source are dispersed more widely by the prevailing winds.

16 ERM. January 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council 17 Chlorine Online Information Resource website. http://www.eurochlor.org/upload/documents/document57.pdf 18 Bobbink, Ashmore, Braun, Fluckiger and Vanden Wyngaert. 2002. Work on critical loads for natural and semi- natural systems (“Empirical nitrogen critical loads for natural and semi-natural ecosystems 2002 update”)

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3.2.12 The main sources of NOx in the UK are19:

 Road and other transport (approximately 47%; greater in urban areas);  Public power generation using fossil fuels (22%).  Combustion in industrial processes20 (14%).  Domestic and commercial sources (4%), e.g. commercial boilers in schools, hospitals etc.

3.2.13 Therefore, when considering the ecologically relevant impacts of the Waste Development Framework, by far the largest contribution to NOx will generally be made by the associated road traffic.

3.2.14 The following air pollution limit value applies for the protection of vegetation and ecosystems from NOx:

 World Health Organisation 30 μgm-3 annual average; EU Air Quality Framework Directive 30 μgm-3 annual average away from areas close to main roads, built up areas or major industrial sites; Natural England policy in agreement with the Environment Agency in their Review of Consents process is that the 30 μgm-3 threshold should apply to all designated sites, due to the sensitivity of the habitats within the sites.

Transport exhaust emissions

3.2.15 In an appropriate assessment of potential impacts of proposed waste facility sites in Surrey, a dispersion model was used to quantify the effects of emissions from operational vehicles travelling to and from a theoretical incinerator. It was shown that at distances greater than 55 metres from the kerbside, ground level concentrations of NOx represent less than 1% of the critical level21. Inevitably however, the distance to which the pollutants will disperse depends upon the parameters of the model and prevailing meteorological conditions. Moreover, it is clear from other research that there is no such thing as a ‘typical’ waste site.

 The actual scale of heavy vehicle movement associated with waste facilities is entirely dependent upon both the type and scale of the facility, neither of which can be prescribed by the Waste Development Framework except at the broadest scale. It is therefore impossible to give meaningful “typical” values for waste sites. A review of a number of waste schemes22 identified that:  A Household Waste Recycling Centre may have very small numbers of heavy vehicle movements (4 per day) but can have a very large number of car movements associated with the general public bringing waste to the site – 150 cars per day at the site considered in the cited example;  Thermal Treatment and Energy from Waste facilities will generally have a much greater number of heavy vehicle movements (perhaps 100 to 200 per day) due to their generally large size, but will also have a much smaller number of cars travelling to the site, as they do not accept waste from the general public and are heavily automated;

19 Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 20 Combustion of coal and oil, some refinery processes and the production of sulphuric acid and other chemicals 21 1% being the level defined in the EU Habitats Directive Handbook at which emissions are not likely to have a significant effect alone or in combination, irrespective of background levels 22 ERM. January 2007. Appropriate Assessment of the Surrey Waste Development Framework. Surrey County Council

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 Most other forms of waste treatment (including landfill) fall between these two extremes depending as much upon their size as their type;  The situation can become considerably more complex if various forms of waste treatment facility are co-located on the same site. The ERM (2007) study gathered data from one site that combined a Waste Transfer Station with a Household Waste Recycling Centre, which as a result showed both higher numbers of HGV traffic (66 per day) and public car traffic (up to 1,000 per day at peak times of the year) than either form of waste facility might be expected to attract individually.

3.2.16 It is clear from the above that the situation regarding vehicular exhaust emissions associated with waste treatment sites is considerably more complex than it might appear at face value. The only general conclusion that can be safely drawn is that all new waste sites are likely to result in a local increase in vehicle movements and that this increase may be greater where multiple types of waste treatment facility are provided in the same location. It is also true that the distance vehicles travel may be as important as the numbers or type of vehicle in contributing to deteriorating atmospheric deposition of European sites, if the route leads the traffic within close proximity of multiple European sites.

3.2.17 According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant” 23.

Figure 2 – Traffic contribution to concentrations of pollutants at different distances from a road (Source: DfT)

3.2.18 Given the difficulties in accurately determining and modelling likely scales of vehicle usage on sites for which all parameters must necessarily at this stage be wholly theoretical, it seems more in line with the precautionary principle to utilise the more cautious 200 m figure, rather than smaller figures that may have been derived from site-specific theoretical models.

3.2.19 This is therefore the distance that has been used throughout this screening report in order to determine whether European sites are likely to be significantly affected by development under the MWDF. There are seven European sites within the scope of this assessment that lie within 200m of a main road that could serve as a transport route for waste or minerals traffic:

 Chichester and Langstone Harbours SPA/Ramsar and Solent Maritime SAC lie within 200m of the A27;

23 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf

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 The Mens SAC lies within 200m of the A272 for a considerable distance.  Ebernoe Common SAC lies within 200m of the A283 for a short distance.  Singleton and Cocking Tunnels SAC lies within 200m of the A286 for a considerable distance.  Ashdown Forest lies within 200m of the A22 for a considerable distance.  Duncton and Bignor Escarpment SAC lies within 200m of the A285 for a short distance.  Wealden Heaths Phase II SAC is bisected by the A3 for a considerable distance.

3.2.20 The issue of cumulative vehicle exhaust emissions is clearly a collective one and no single quarry or landfill site can be identified as being ‘responsible’. As such, the approach we have taken in this screening exercise is to assume that air quality issues arising from vehicle exhaust emissions are relevant to the MWDF preferred options covering the whole county, and not to individual waste or minerals sites.

Energy from Waste

3.2.21 While traffic makes the largest overall contribution to NOx, some individual point sources can also result in substantial increases in the local NOx concentration. Of those point sources associated with waste treatment, thermal treatment / Energy from Waste facilities24 have the potential to emit the greatest amounts, as any form of thermal treatment involves the emission of exhaust gases.

3.2.22 For the purposes of this assessment we have not tried to model the emissions of a particular form of thermal treatment in order to estimate possible NOx emissions, for the following reasons:

 It is not known at this stage which sites might support a thermal treatment facility;  Incineration (mass burn) is currently the only thermal treatment technology that can be accurately modelled. Use of this technology can emit large quantities of NOx, but the NOx emissions of any form of incinerator, and their distances to deposition, are entirely dependent upon specific parameters of the facility (e.g. stack height). Since any incinerator modelled for this HRA would at this stage be based on entirely hypothetical parameters, the resulting model may in fact bear little relation to actual emissions from an incinerator at a given location;  More importantly, while incineration is currently the most common form of Energy from Waste technology, the international drive to reduce pollutant emissions has resulted in the development of numerous alternative technologies (such as pyrolysis or gasification), which produce relatively little NOx25 26. At this stage it is unknown which technology will be utilised

24 Energy from Waste (or Waste to Energy) refers to those types of thermal treatment that incorporate energy recovery technology. 25 “For a given secondary material, emission levels of SOx, NOx, and particulates from gasification systems are reduced significantly compared to incineration systems… Data for repowering of coal-fired electric utilities with IGCC technology has shown that emissions of SOx, NOx, and particulates are reduced by one to two orders of magnitude” Radian International LLC. 2000 A Comparison of Gasification and Incineration of Hazardous Wastes. Report produced for US Department of Energy National Energy Technology Laboratory. http://www.netl.doe.gov/publications/others/techrpts/igcc_wp.pdf 26 Some manufacturers of gasification technology claim the potential to reduce NOx emissions to <10 ppm. “The SOx, NOx, mercury, volatile metals, and particle emissions from a Solena IPGCC plant constitute a small fraction of those

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at the chosen site as this cannot be specified by the Minerals and Waste Development Framework. However, given that the Minerals and Waste Development Framework covers the period until 2025, it is possible that the form of technology adopted for the chosen site will involve gasification, pyrolysis or similar technology, rather than mass burn. Any modelling based upon conventional incineration technology would therefore be potentially unrepresentative.  Therefore, we have concluded that detailed modelling should await greater certainty about the nature of the proposed facility. This may therefore more logically undertaken as part of the project-level Appropriate Assessment for any Energy from Waste Facility as the Waste and Minerals Core Strategy will not identify a specific site for EfW but only a range of sites that are of sufficient size to be suitable for larger facilities (which would include EfW).  The Environment Agency guidance on screening point-source pollution emitters for more detailed assessment27 lists the presence of a SSSI or Natura 2000 site within 10km as one of the indicators that detailed assessment (i.e. dispersion-modelling) may be required for a planning application/IPCC consent. The implication of this is that the emissions of a point- source can normally be considered effectively inconsequential on sites located more than 10km distant. While this would not apply to major emitters such as large power stations, refineries and steel works, it would apply to smaller ones such as thermal waste treatment facilities.  For this screening exercise, we have therefore used the 10km figure as a basis on which to screen sites in and out of assessment regarding their possible use as a location for an Energy from Waste facility. If sites that may be suitable for EfW are located within 10km of a European site, they have been screened in for further consideration.

Landfill

3.2.23 A landfill gas flare (or utilisation engine) will produce an emission of exhaust gases such as sulphur dioxide, NOx, unburnt hydrocarbons, carbon monoxide and hydrogen chloride. However, the volume of exhaust gases is likely to be small in comparison to other combustion facilities and at a distance of >1km from the European site may well be inconsequential28. We have therefore used the 1km figure throughout this screening report as a basis on which to screen landfill sites in or out of assessment with regard to air quality issues.

Other types of waste facility

3.2.24 Atmospheric emissions of NOx from other types of facility are negligible. For example, anaerobic digestion29 does result in the generation of biogas but not NOx. The emissions to the air are well controlled; some emissions may arise from biogas under positive pressure in the tank, but under normal operating conditions biogas is not released direct to air30. Equally,

emissions from a … incinerator waste-to-energy plant.” Solena Group website www.solenagroup.com/html/images/fuelflexible.pdf 27 Environment Agency. 2003. Integrated Pollution Prevention and Control - Environmental Assessment and Appraisal of BAT. Horizontal Guidance Note IPPC H1 28 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance. http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf 29 The biological treatment of biodegradable organic waste in the absence of oxygen, utilising microbial activity to break down the waste in a controlled environment 30 Defra. 2004. Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes. Defra Publication, London, UK

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waste transfer stations31 and mechanical biological treatment32 plant can incorporate a number of different processes in a variety of combinations and can be built for various purposes, but air emissions and health impacts are most likely to be linked to traffic movements. In general therefore, the view has been taken in this screening report that waste sites other than landfill and Energy from Waste facilities are unlikely to have a significant air quality effect on European sites (other than through associated vehicle exhaust emissions).

Quarries and minerals sites

3.2.25 Atmospheric pollutants generated by minerals sites are more straightforward than with waste sites and generally resolve themselves into dust and traffic exhaust emissions. Vehicle exhaust emissions have already been discussed. Effects of dust will depend on the prevailing wind direction and the transport distance is related to particle size; large particles (>30um) will mostly deposit within 100m of the source, intermediate particles (10-30um) are likely to travel up to 200 - 500m. Smaller particles (<10um) can travel up to 1km from the source33. With regard to the interest features of European sites, it is likely to be the large and intermediate size particles that are of most interest since if present in sufficient quantities they can smother vegetation, preventing light penetration to the chloroplasts and blocking stomata thus interrupting photosynthesis and transpiration. In prolonged cases, death can result.

3.2.26 Dust impacts will be considered further in this assessment, but cannot be quantified beyond the broad potential distances identified above for different particle sizes. For the purposes of screening, those minerals sites that lie more than 500m from a European site have been ‘screened out’ as being unlikely to contribute significant dust impacts even without special mitigation such as ‘wetting’.

Diffuse air pollution

3.2.27 In addition to the contribution to local air quality issues, development can also contribute cumulatively to an overall deterioration in background air quality across an entire region. In July 2006, when this issue was raised by Runnymede District Council in the South East, Natural England advised that their Local Development Framework ‘can only be concerned with locally emitted and short range locally acting pollutants’ 34 as this is the only scale which falls within a local authority remit. It is understood that this guidance was not intended to set a precedent, but it inevitably does so since (as far as we are aware) it is the only formal guidance that has been issued to a Local Authority from any Natural England office on this issue.

3.2.28 In the light of this and our own knowledge and experience, it is considered reasonable to conclude that diffuse pan-authority air quality impacts are the responsibility of Regional Spatial Strategies, both since they relate to the overall quantum of development within a region (over which individual districts have little control), and since this issue is best addressed at the highest pan-authority level. Diffuse air quality issues will not therefore be considered further within this HRA but is considered in the South East Regional Spatial Strategy.

31 In which waste is transported from waste producers (industry, commerce and the general public) to be treated, recycled and/or disposed 32 A generic term for an integration of several processes commonly found in other waste management technologies, such as Materials Recovery Facilities, sorting and composting plant 33 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf 34 English Nature (16 May 2006) letter to Runnymede Borough Council, ‘Conservation (Natural Habitats &c.) Regulations 1994, Runnymede Borough Council Local Development Framework’.

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3.3 Water quality and flows

3.3.1 The quality of the water that feeds European sites is an important determinant of the nature of their habitats and the species they support. Poor water quality can have a range of environmental impacts:

 At high levels, toxic chemicals and metals can result in immediate death of aquatic life, and can have detrimental effects even at lower levels, including increased vulnerability to disease and changes in wildlife behaviour.  Eutrophication, the enrichment of plant nutrients in water, increases plant growth and consequently results in oxygen depletion. Algal blooms, which commonly result from eutrophication, increase turbidity and decrease light penetration. The decomposition of organic wastes that often accompanies eutrophication deoxygenates water further, augmenting the oxygen depleting effects of eutrophication. In the marine environment, nitrogen is the limiting plant nutrient and so eutrophication is associated with discharges containing available nitrogen.  Some pesticides, industrial chemicals, and components of sewage effluent are suspected to interfere with the functioning of the endocrine system, possibly having negative effects on the reproduction and development of aquatic life.

3.3.2 Water quality may be adversely affected by waste sites through:

 Pollution through water runoff from hard surfaces carrying oils, heavy metals and/or de-icing compounds. While these effects can be dispersed throughout the downstream water catchment, they will be most visibly manifested within tens of metres to a few hundred metres of the site35; and  Discharges of leachate from landfill sites can add ammonia, other nutrients and chemical pollutants to surface water bodies. Leachate can also penetrate groundwater. Leachate can escape from landfill sites by leakage through a barrier / containment system, break out through a cap, or overtopping containment.

3.3.3 There are several ways in which quarrying / mining can affect water quality/resources:

 Quarries and mines that are below the water table will require dewatering on a regular basis. Dewatering36 can lead to a reduction in the water table and “draw down” from hydraulically linked groundwater dependent habitats (including streams and rivers);  The physical presence of a new quarry in the unsaturated zone (i.e. above the water table) can increase the possibility of aquifer contamination and result in a direct reduction in temporary groundwater storage capacity;  If the water that is pumped from a quarry as a result of dewatering has a high proportion of clays and suspended particles, or is contaminated with metals, it can reduce water quality within those watercourses that receive the water; and

35 Scottish Environment Protection Agency. 2003. Technical Guidance Note - Habitats Regulations & The Landfill Regulations Guidance. http://www.sepa.org.uk/pdf/guidance/landfill_directive/habitats_landfill_regulations_guidance.pdf 36 Dewatering is most commonly carried out by intermittent pumping from a sump located in the deepest part of the quarry, to keep pace with the inflow of groundwater.

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 Backfilling a dormant quarry with overburden or imported fill may cause changes to groundwater levels, quality and flow paths in adjoining areas.

3.3.4 In or near West Sussex there are four European sites that have a particular hydrological sensitivity (with the exception of Arun Valley, this is essentially associated with maintaining high quality flows of freshwater into the estuarine sites):

 Solent Maritime SAC  Chichester and Langstone Harbours SPA/Ramsar;  Pagham Harbour SPA/European Marine Site/Ramsar; and  Arun Valley SPA/Ramsar

3.4 Predation

3.4.1 In addition to disturbance due to activities taking place on site, landfill sites can attract large numbers of gulls and corvids (members of the crow family) and rats, which can disturb and prey on the young of bird species for which Special Protection Areas and/or Ramsar sites have been designated. In the case of East Sussex, this is of relevance to two sites, both of which were designated in part for their populations of breeding little tern:

 Chichester & Langstone Harbours SPA and Ramsar site; and  Pagham Harbour SPA/European Marine Site/Ramsar

3.4.2 Environment Agency and Scottish Environmental Protection Agency guidance indicate that 5km is the limit within which gull predation associated with landfill sites may be an issue for designated sites with breeding birds (particularly ground nesting species). As such, for this screening report, landfill site locations have been screened in for further assessment if they lie within 5km of Chichester & Langstone Harbours SPA and Ramsar site or Pagham Harbour SPA, European Marine Site and Ramsar site.

3.5 Disturbance

3.5.1 Waste sites can share many noise and visual disturbance issues (e.g. heavy vehicle movements and loud machinery) with other industrial operations. Birds are the faunal group that is most often considered in relation to disturbance, largely as this is the group on which disturbance impacts have been most studied.

3.5.2 Concern regarding the effects of disturbance on birds stems from the fact that they are expending energy unnecessarily and the time they spend responding to disturbance is time that is not spent feeding37. Disturbance therefore risks increasing energetic output while reducing energetic input, which can adversely affect the ‘condition’ and ultimately survival of the birds In addition, displacement of birds from one feeding site to others can increase the pressure on the resources available within the remaining sites, as they have to sustain a greater number of

37 Riddington, R. et al. 1996. The impact of disturbance on the behaviour and energy budgets of Brent geese. Bird Study 43:269-279

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birds.38 Moreover, the more time a breeding bird spends disturbed from its nest, the more its eggs are likely to cool and the more vulnerable they are to predators.

3.5.3 Human activity can affect birds either directly (e.g. through causing them to flee) or indirectly (e.g. through damaging their habitat). The most obvious direct effect is that of immediate mortality such as death by shooting, but human activity can also lead to behavioural changes (e.g. alterations in feeding behaviour, avoidance of certain areas etc.) and physiological changes (e.g. an increase in heart rate) that, although less noticeable, may ultimately result in major population-level effects by altering the balance between immigration/birth and emigration/death.39

3.5.4 The degree of impact that varying levels of noise will have on different species of bird is poorly understood except that a number of studies have found that an increase in traffic levels on roads does lead to a reduction in the bird abundance within adjacent hedgerows - Reijnen et al (1995) examined the distribution of 43 passerine species (i.e. ‘songbirds’), of which 60% had a lower density closer to the roadside than further away. By controlling vehicle usage they also found that the density generally was lower along busier roads than quieter roads40.

3.5.5 Activity will often result in a flight response (flying, diving, swimming or running) from the animal that is being disturbed. This carries an energetic cost that requires a greater food intake. Relatively little detailed research has been conducted concerning the energetic cost to wildlife of disturbance, but such evidence as exists indicates a significant negative effect.

3.5.6 Quarrying and mining share many noise and visual disturbance issues (e.g. heavy vehicle movements and loud machinery) with other industrial operations; however, quarrying can also result in disturbance through the controlled blasting of rock in order to extract it for processing. This can result in ground vibration that can be perceived a considerable distance from the point of blasting. In addition, the shockwaves will travel through the air (known as overpressure) and, if the blasting takes place near water, the shockwaves can be perceived at even greater distances.

3.5.7 Disturbing activities are on a continuum. The most disturbing activities are likely to be those that involve irregular, infrequent, unpredictable loud noise events, movement or vibration of long duration. Birds are least likely to be disturbed by activities that involve regular, frequent, predictable, quiet patterns of sound or movement or minimal vibration. The further any activity is from the birds, the less likely it is to result in disturbance.

3.5.8 The factors that influence a species response to a disturbance are numerous, but the three key factors are species sensitivity, proximity of disturbance sources and timing/duration of the potentially disturbing activity.

Sensitivity of species (birds)

3.5.9 The distance at which a species takes flight when approached by a disturbing stimulus is known as the ‘tolerance distance’ (also called the ‘escape flight distance’) and differs between species to the same stimulus and within a species to different stimuli. No data could be sourced

38 Gill, J.A., Sutherland, W.J. & Norris, K. 1998. The consequences of human disturbance for estuarine birds. RSPB Conservation Review 12: 67-72 39 Riley, J. 2003. Review of Recreational Disturbance Research on Selected Wildlife in Scotland. Scottish Natural Heritage. 40 Reijnen, R. et al. 1995. The effects of car traffic on breeding bird populations in woodland. III. Reduction of density in relation to the proximity of main roads. Journal of Applied Ecology 32: 187-202

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on the tolerance distances of birds in response to waste site specifically. However, distances for shoveler have been recorded. These are given in

3.5.10 Table 2, which compiles ‘tolerance distances’ from across the literature. It is reasonable to assume from this that disturbance is unlikely to be experienced more than a few hundred metres from the birds in question. In addition, the regular mechanized noise that is associated with waste sites is likely to be less disturbing that the presence of visible human activity in areas in which the birds are not used to observing such activity.

Table 2 - Tolerance distances of 21 water bird species to various forms of recreational disturbance, as described in the literature. All distances are in metres. Single figures are mean distances; when means are not published, ranges are given. 1 Tydeman (1978), 2 Keller (1989), 3 Van der Meer (1985), 4 Wolff et al (1982), 5 Blankestijn et al (1986), 6 Cook (1980).41

Type of disturbance

Species Rowing boats/kayak Sailing boats Walking Little grebe 60 – 100 1

Great crested grebe 50 – 100 2 20 – 400 1 Mute swan 3 – 30 1 Teal 0 – 400 1 Mallard 10 – 100 1 Shoveler 200 – 400 1 Pochard 60 – 400 1 Tufted duck 60 – 400 1 Goldeneye 100 – 400 1 Smew 0 – 400 1 Moorhen 100 – 400 1 Coot 5 – 50 1 Curlew 211 3; 339 4; 213 5 Shelduck 148 3; 250 4 Grey plover 124 3 Ringed plover 121 3 Bar-tailed godwit 107 3; 219 4 Brent goose 105 3

41 Tydeman, C.F. 1978. Gravel Pits as conservation areas for breeding bird communities. PhD thesis. Bedford College Keller, V. 1989. Variations in the response of Great Crested Grebes Podiceps cristatus to human disturbance - a sign of adaptation? Biological Conservation 49:31-45 Van der Meer, J. 1985. De verstoring van vogels op de slikken van de Oosterschelde. Report 85.09 Deltadienst Milieu en Inrichting, Middelburg. 37 pp. Wolf, W.J., Reijenders, P.J.H. & Smit, C.J. 1982. The effects of recreation on the Wadden Sea ecosystem: many questions but few answers. In: G. Luck & H. Michaelis (Eds.), Schriftenreihe M.E.L.F., Reihe A: Agnew. Wissensch 275: 85-107 Blankestijn, S. et al. 1986. Seizoensverbreding in de recreatie en verstoring van Wulp en Scholkester op hoogwatervluchplaatsen op Terschelling. Report Projectgroep Wadden, L.H. Wageningen. 261pp. Cooke, A.S. 1980. Observation on how close certain passerine species will tolerate an approaching human in rural and suburban areas. Biological Conservation 18: 85-88

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Type of disturbance

Species Rowing boats/kayak Sailing boats Walking Oystercatcher 85 3; 136 4; 82 5 Dunlin 71 3; 163 2

3.5.11 Three European sites in or near West Sussex have been designated at least in part for their bird interest:

 Chichester and Langstone Harbours SPA/Ramsar;  Pagham Harbour SPA/European Marine site/Ramsar; and  Arun Valley SPA/Ramsar

3.5.12 For the purposes of screening we have used the precautionary distance of 1km as a basis on which to screen waste and minerals sites in or out of consideration with regard to the potential for disturbance (i.e. noise and visual) impacts.

3.6 Direct landtake

3.6.1 Issues of direct landtake from terrestrial European sites generally relate to existing permissions (often associated with mineral extraction) that were granted prior to the designation of the site and which have not yet reached completion. In some cases, the process of mineral extraction can be partly responsible for creating the interest of the European site in the first place. This is partly the case with Dungeness SAC and Dungeness to Pett Level SPA and Ramsar site in East Sussex where former mineral workings now form important lagoon habitat. At this stage we have not identified any European sites that may be subject to direct landtake as a result of minerals operations in West Sussex.

3.6.2 In addition to direct landtake from European sites, those sites which are designated for highly mobile species can also be adversely affected by loss of habitat (or in the case of bats disruption of commuting routes). In West Sussex, this applies principally to Ebernoe Common SAC and The Mens SAC.

3.6.3 Ebernoe common is an exceptional site for barbastelle bats. Most of what is known about the foraging behaviour of barbastelle bats has been derived by studies carried out over the past ten years, and the studies are able to give detailed information on flight lines surrounding Ebernoe Common of the barbastelle bat:

 Greenaway, F. (2004) Advice for the management of flightlines and foraging habitats of the barbastelle bat Barbastellus barbastellus. English Nature Research Report, Number 657.  Greenaway, F. (2008) Barbastelle bats in the Sussex West Weald 1997 - 2008

3.6.4 These reports have identified that:

 The barbastelles of The Mens SAC forage to the east of the SAC, principally on the floodplain of the river Arun from close to Horsham in the north to Parham in the south. They also cross to the Adur floodplain. In some cases the bats travelled up to 7km to visit foraging areas;

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 The barbastelles at Ebernoe Common SAC had flightlines that followed watercourses, particularly the river Kird, and woodland cover for distances of typically 5km. Flightlines outside the SAC are particularly to the south (the Petworth and Tillington area) but also to the west, north and east.

3.7 Coastal squeeze

3.7.1 Rising sea levels can be expected to cause intertidal habitats (principally saltmarsh and mudflats) to migrate landwards. However, in built-up areas, such landward retreat is often rendered impossible due the presence of the sea wall and other flood defences.

3.7.2 In addition, development frequently takes place immediately behind the sea wall, so that the flood defences cannot be moved landwards to accommodate managed retreat of threatened habitats. The net result of this is that the quantity of saltmarsh and mudflat adjacent to built-up areas will progressively decrease as sea levels rise. This process is known as ‘coastal squeeze’. In areas where sediment availability is reduced, the 'squeeze' also includes an increasingly steep beach profile and foreshortening of the seaward zones.

3.7.3 Waste and minerals sites (particularly landfill) can contribute to coastal squeeze as much as any other development by restricting opportunities for managing realignment. Solent Maritime SAC, Chichester & Langstone Harbours SPA/Ramsar and Pagham Harbour SPA/European Marine Site/Ramsar are the only European sites in West Sussex for which this impact would be relevant.

3.8 Screening distance summary

3.8.1 The table below summarises the screening distances used for each source of impact.

Table 3 – Screening distances used for each source of impact Pathway Screening distance Air quality – vehicle exhaust emissions 200m from European site Air quality – Energy from Waste 10km from European site Air quality – landfill gas flares 1km from European site Air quality - dust 500m from European site Water quality and flows No standard distance – use Source/Pathway/Receptor approach Disturbance (noise/visual) 1km from European site supporting disturbance sensitive species/populations Gull/corvid predation (non-inert landfill only) 5km from European site supporting sensitive ground-nesting breeding species (e.g. terns) Coastal squeeze No standard distance – evaluate on case by case basis Direct landtake 5km from The Mens SAC or 7km from Ebernoe Common SAC and suitable habitat for foraging barbastelles present on site

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4 Screening Tables

4.1.1 The following tables present the screening assessments for each site and preferred option that have been put forward for consideration. There are 4 tables – minerals sites, non-disposal waste sites, land disposal (landfill) sites and preferred options. For all tables, green shading in the final column indicates a site or policy option that has been screened out of further consideration due to the absence of any mechanism for an adverse effect on European sites.

Table 4 – Screening assessment for each minerals site put forward for consideration Site Site name Location Mineral Status HRA Screening (green= screened out, number amber =screened in for Appropriate on Assessment) Figure 3a 27 Woodmancote Chichester Sharp sand and gravel Inactive These four sites all lie approximately 3km (concreting aggregate) (part of from Kingley Vale SAC, Solent Maritime site has SAC and, Chichester and Langstone been Harbours SPA/Ramsar. worked) There is no scope for adverse impacts on 4 Common Road Chichester Sharp sand and gravel Inactive Kingley Vale SAC. However it is assumed West (not yet quarry traffic will use the A27 which lies worked) within 200m of Solent Maritime SAC and 3 Common Road Chichester Sharp sand and gravel Inactive Chichester and Langstone Harbours East (concreting aggregate) (not yet SPA/Ramsar. worked) Although brent geese (for which the 22 Slades Field Chichester Sharp sand and gravel Inactive SPA/Ramsar is designated) use land (concreting aggregate) (not yet immediately adjacent to the A27 as a high worked) tide roost this land is already subject to considerable vehicle movements and it is unlikely that additional traffic from the working of this minerals site would significantly alter the disturbance to which the geese are exposed.

The possibility of adverse effects due to exhaust emissions requires investigation and should be informed by estimates of the likely increase in vehicle movements on the A27 as a result of the waste and minerals development covered in the Core Strategy. 6 Densworth North Chichester Sharp sand and gravel Inactive (not yet worked) 24 West Stoke Chichester Sharp sand and gravel Inactive These four sites all lie approximately 2km Road East (not yet from Kingley Vale SAC. However, there is worked) no scope for adverse impacts on that SAC and no pathway connecting with any other 25 West Stoke Chichester Sharp sand and gravel Inactive European sites. Road West (not yet worked) 12 Huntersrace Chichester Sharp sand and gravel Inactive Land North (not yet worked)

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Site Site name Location Mineral Status HRA Screening (green= screened out, number amber =screened in for Appropriate on Assessment) Figure 3a 8 Land Adjacent to Chichester Sharp sand and gravel Inactive Valdoe Quarry (not yet (East Lavant) worked) 5 Copse Farm Chichester Sharp sand and gravel Inactive (concreting aggregate) (not yet worked) These seven sites lie approximately 4km 18 Shopwyke North Chichester Sharp sand and gravel Inactive from Solent Maritime SAC and Chichester (concreting aggregate) (not yet and Langstone Harbours SPA/Ramsar, and worked) Kingley Vale SAC. There is no scope for 19 Shopwyke South Chichester Sharp sand and gravel Inactive adverse impacts on these or any other (concreting aggregate) (not yet European sites. worked)

15 Madams Green Chichester Sharp sand and gravel Inactive Farm West (concreting aggregate) (not yet worked) 26 Withies Farm Chichester Sharp sand and gravel Inactive West (not yet worked) 1 Brick Kiln Farm Chichester Sharp sand and gravel Inactive (concreting aggregate) (not yet worked) 14 Land at Redvins Chichester Sharp sand and gravel Inactive This site lies approximately 7km from (not yet Solent Maritime SAC and Chichester and worked) Langstone Harbours SPA/Ramsar. There is no scope for adverse impacts on this site and no pathway connecting with any other European sites. 23 West Heath Chichester Soft sand (building Inactive These two sites lie approximately 6km from Common sand) (not yet Wealden Heaths Phase II SPA and East Extension worked) Hampshire Hangers SAC.

Assuming quarry traffic uses the A3 via A272, there is potential for an impact pathway via traffic emissions to the Wealden Heaths Phase II SPA so this site 21 East of West Chichester Soft sand (building Inactive has been screened in for further Heath Common sand) (not yet consideration. worked)

Furthermore both sites lies adjacent to a watercourse that drains to the river Rother and ultimately into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment to impact this European site. 16 Minsted West Chichester Soft sand Inactive This site lies approximately 6km from (not yet Singleton and Cocking Tunnel SAC. There worked) is no scope for adverse impacts on this European site.

However, the site does lie adjacent to a

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Site Site name Location Mineral Status HRA Screening (green= screened out, number amber =screened in for Appropriate on Assessment) Figure 3a watercourse that drains to the river Rother and ultimately into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment impacts so this site has been screened in for further consideration. 10 Hawkhurst Farm Chichester Soft sand (building Inactive This site lies approximately 7km from and coarse sand) (not yet Duncton to Bignor Escarpment SAC, Rook worked) Clift SAC, and Kingley Vale SAC. There is no scope for adverse impacts on these European sites. The site is also approximately 2.5km from Singleton and Cocking Tunnel SAC. It is assumed that site traffic will use A285 road which runs perpendicular to the tunnels. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels. 7 Duncton Chichester Soft sand (concrete Inactive This site lies approximately 2.3km from Common and building sand) (not yet Dunction to Bignor Escarpment SAC. worked) However, there is no pathway connecting this site to the SAC.

The site also lies approximately 8km from the Mens SAC and 9km from Ebernoe Common SAC. Whilst the site contains large amounts of woodland it lies outside of the key foraging distance of Barbastelle bats from these European sites and therefore is not screened in for this pathway of impact.

A watercourse adjacent to the site drains into River Rother and into Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment to impact this European site. 11 Horncroft Chichester Soft sand Inactive This site lies approximately 2km from Arun (not yet Valley SPA/Ramsar and 3km from worked) Dunction to Bignor Escarpment SAC.

A watercourse running through to the site drains into River Rother and into Arun Valley SPA/Ramsar. There is therefore a potential pathway for sediment to impact this European site. 2 Chantry Lane Horsham Soft Sand Inactive This site lies approximately 5km from Arun Extension (not yet Valley SPA/Ramsar. A watercourse worked) adjacent to the site drains into River Stor and into this European site. There is therefore a potential pathway for sediment

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Site Site name Location Mineral Status HRA Screening (green= screened out, number amber =screened in for Appropriate on Assessment) Figure 3a to impact this European site. 9 Ham Farm Horsham Soft Sand Inactive No European site within 10km of this site. (not yet There is no scope for pathways connecting worked) any European sites. 20 Shoreham Horsham Chalk for the Dormant No European site within 10km of this site. Cement Works manufacture of There is no scope for pathways connecting cement any European sites. 13 Land Adjacent to Mid Wadhurst Clay Inactive This site lies approximately 2km from West Hoathly Sussex (not yet Ashdown Forest SPA/SAC. It is assumed Brickworks worked) that site traffic will use the A22 Road which bisects this SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site. 17 Philpots Mid Architectural/building Inactive This site lies approximately 2km from Extension Sussex sandstone (not yet Ashdown Forest SPA/SAC. It is assumed worked) that site traffic will use the A22 Road which bisects this SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site.

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Table 5 – Screening assessment for each waste site put forward for consideration Site Site Authority Type of facility HRA screening (green = screened out, amber = number (name/address) screened in for Appropriate Assessment) on Figure 3b 32 Shoreham Harbour Adur Built waste No European site within 10km of this site. There is no facility scope for pathways connecting any European sites. 33 Slindon Bottom Pit Arun Inert landfill This site lies approximately 9km from Arun Valley SPA/Ramsar, 5km from Duncton to Bignor Escarpment SAC and 9.4km from Singleton and Cocking Tunnels SAC. This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 37 Yard Adjacent to Arun Built waste No European site within 10km of this site. There is no Sewage Works, facility scope for pathways connecting any European sites. Ford 11 Ford Airfield Arun Built waste No European site within 10km of this site. There is no facility scope for pathways connecting any European sites. 16 Hobbs Barn Arun Built waste No European site within 10km of this site. There is no facility or scope for pathways connecting any European sites. composting 1 Blue Prince Arun Built waste This site lies approximately 8km from Arun Valley Mushroom Site facility or SPA/Ramsar and 10km from Duncton to Bignor composting Escarpment SAC.

This site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of two European sites, it is considered that it should be screened in for further consideration on this basis. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out. 23 Land South of Chichester Composting This site lies approximately 7km from Pagham Harbour Strettington Flyover SPA/European Marine Site/Ramsar, 6km from Chichester and Langstone Harbours SPA/Ramsar, 8km from Singleton and Cocking Tunnels SAC, 6km from Solent Maritime SAC and 8km from Kingley Vale SAC.

This site is considered for open air composting. As such and given the distances involved there are no pathways linking this site with European sites. 30 Portfield Chichester Built waste These five sites lie approximately 7km from Pagham facility, inert Harbour SPA/European Marine Site/Ramsar, 6km from landfill or inert Chichester and Langstone Harbours SPA/Ramsar, 8km recycling from Singleton and Cocking Tunnels SAC, 6km from Solent Maritime SAC and 8km from Kingley Vale SAC. 13 Fuel Depot, Bognor Chichester Built waste Road facility These sites are considered potentially suitable for an 21 Land East of Chichester Built waste Energy from Waste facility and, since it lies within 10km Tangmere Airfield facility of five European sites, it is considered that it should be screened in for further consideration on this basis. If 34 South East Corner Chichester Built waste subsequent investigation considers the site to be of Tangmere facility or unsuitable for an Energy from Waste facility the site Airfield composting could be screened out. 36 Woodhorn Farm Chichester Built waste facility

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Site Site Authority Type of facility HRA screening (green = screened out, amber = number (name/address) screened in for Appropriate Assessment) on Figure 3b (Anaerobic Digestion) 29 Pendean Chichester Inert landfill This site lies approximately 8km from Duncton to Bignor Escarpment SAC, 3km from Singleton and Cocking Tunnels SAC, 7km from Rook Clift SAC, 9km from Kingley Vale SAC and 10km from Ebernoe Common SAC.

It is assumed that site traffic will use A285 road which runs perpendicular to Singleton & Cocking Tunnels SAC. However, since this road is already well-used it is considered unlikely that additional vehicles associated with the working of this site would cause disturbance of hibernating bats in the tunnels.

This site is considered for inert landfill. As such and given the distances involved there are no other pathways linking this site with European sites. 3 Boxgrove Gravel Pit Chichester Inert landfill This site lies approximately 9km from Pagham Harbour SPA/European Marine Site/Ramsar, 9km from Chichester and Langstone Harbours SPA/Ramsar, 7km from Singleton and Cocking Tunnels SAC, 9km from Solent Maritime SAC and 7km from Duncton to Bignor Escarpment SAC.

This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 2 Bognor Common Chichester Inert landfill This site lies approximately 5km from Ebernoe Common Stone Quarry SAC, 1km from The Mens SAC, 6km to Arun Valley SPA and 7km Duncton to Bignor Escarpment SAC.

This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 10 Duncton Quarry Chichester Inert landfill This site lies approximately 1km from Duncton to Bignor Escarpment SAC, 8km from Singleton and Cocking Tunnels SAC, 7km from Arun Valley SPA, 10km from Ebernoe Common SAC and 9km from The Mens SAC.

This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 28 Old Lime Works Chichester Inert recycling This site lies approximately 8km from Duncton to Bignor Escarpment SAC, 1km from Singleton and Cocking Tunnels SAC, 6km from Kingley Vale SAC and 6km from Rook Clift SAC.

Habitats Regulations Assessment – Screening of Likely Significant Effects Report March 2010 27 West Sussex County Council West Sussex Minerals & Waste Development Framework

Site Site Authority Type of facility HRA screening (green = screened out, amber = number (name/address) screened in for Appropriate Assessment) on Figure 3b hibernating bats in the tunnels.

This site is considered for inert recyling. As such and given the distances involved there are no other pathways linking this site with European sites. 8 Cocking Chalkpit Chichester Inert landfill This site lies approximately 7.5km from Duncton to Bignor Escarpment SAC, 1km from Singleton and Cocking Tunnels SAC, 6.1km from Kingley Vale SAC and 6km from Rook Clift SAC.

This site is considered for inert landfill. As such and given the distances involved there are no pathways linking this site with European sites. 31 Shoreham Cement Horsham Built waste No European site within 10km of this site. There is no Works facility scope for pathways connecting any European sites. 27 Nowhurst Business Horsham Built waste No European site within 10km of this site. There is no Centre facility or inert scope for pathways connecting any European sites. recycling 5 Brookhurst Wood Horsham Built waste No European site within 10km of this site. There is no facility or non- scope for pathways connecting any European sites. inert landfill 24 Langhurstwood Horsham Non-inert landfill No European site within 10km of this site. There is no Brickworks scope for pathways connecting any European sites. 25 Laybrook Horsham Non-inert landfill This site lies approximately 6km from Arun Valley SAC Brickworks and 10km from The Mens SAC. This site is considered for non-inert landfill. Given the designation of the closest sites and the distances involved there are no pathways linking this site with European sites 7 Chantry Lane Sand Horsham Inert landfill This site lies approximately 5km from Arun Valley Pit SPA/Ramsar.

The site lies adjacent to a watercourse that drains to the river Stor and into the Arun Valley SPA/Ramsar. There is therefore a potential pathway for discharged leachate to impact this European site.

This site is considered for inert landfill. As such and given the distances involved there are no other pathways linking this site with European sites. 35 Star Road Trading Horsham Built waste No European site within 10km of this site. There is no Estate facility scope for pathways connecting any European sites. 14 Golding Barn Horsham Inert landfill No European site within 10km of this site. There is no scope for pathways connecting any European sites.

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Site Site Authority Type of facility HRA screening (green = screened out, amber = number (name/address) screened in for Appropriate Assessment) on Figure 3b 4 Broadbridge farm Horsham Composting This site lies approximately 8km from Arun Valley SPA/Ramsar. This site is considered for open air composting. As such and given the distances involved there are no other pathways linking this site with European sites. 20 Land at North Farm Horsham Built waste This site lies approximately 8km from Arun Valley facility SPA/Ramsar.

The site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis. 15 Hampers Lane Horsham Built waste This site lies approximately 6km from Arun Valley Engineering Works facility or inert SPA/Ramsar recycling This site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis. 6 Burleigh Oaks Farm Mid Built waste This site lies approximately 6km from Ashdown Forest Sussex facility SPA/SAC.

This site is considered potentially suitable for an Energy from Waste facility and, since it lies within 10km of this European site, it is considered that it should be screened in for further consideration. If subsequent investigation considers the site to be unsuitable for an Energy from Waste facility the site could be screened out on this basis. 12 Freshfield Lane Mid Inert landfill This site lies approximately 4km from Ashdown Forest Brickworks Sussex SPA/SAC. It is assumed that site traffic will use the A275 Road which bisects this SPA/SAC. This site is therefore screened in for potential emissions and disturbance to the European site.

Although the site lies within 5km of Ashdown Forest SPA it is identified for potential inert landfill rather than putrescible waste and is therefore unlikely to attract gulls and corvids. As such it is considered that it can be screened out as not representing a predation risk to the ground-nesting birds of the SPA. 22 Land Rear of Mid Built waste No European site within 10km of this site. There is no Ricebridge Sussex facility scope for pathways connecting any European sites. Industrial Estate 19 Land at Hickstead Mid Built waste No European site within 10km of this site. There is no Sussex facility scope for pathways connecting any European sites.

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Site Site Authority Type of facility HRA screening (green = screened out, amber = number (name/address) screened in for Appropriate Assessment) on Figure 3b 17 Land Adjacent to Mid Built waste No European site within 10km of this site. There is no Sewage Works, Sussex facility scope for pathways connecting any European sites. Cuckfield 18 Land Adjacent to Mid Built waste No European site within 10km of this site. There is no Goddards Green Sussex facility scope for pathways connecting any European sites. WWTW 26 Newtimber Chalk Mid Inert waste No European site within 10km of this site. There is no Pit Sussex recycling scope for pathways connecting any European sites. 9 Decoy Farm, East Worthing Built waste No European site within 10km of this site. There is no Worthing facility scope for pathways connecting any European sites.

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Table 6 – Screening assessment for each Option put forward for consideration Issue Options Screening (green = screened out, amber = screened in for appropriate assessment) Minerals MA: Options for Safeguarding Soft MA1, MA2, MB1, MB2, MB3, MB4, These options do not ‘promote’ Sand and Sharp Sand and Gravel; MC1, MC2, MC3, MC4, MD1, MD2, minerals development, but safeguard MB: Options for Safeguarding Clay MD3, MD4 and ME1 existing minerals resources in order to MC: Options for Safeguarding prevent them from being sterilised by Sandstone; MD: Options for alternative development. Safeguarding Chalk and; ME: Options ‘Safeguarding’ a minerals area (as for Safeguarding Oil and Gas distinct from allocating sites) carries no presumption that it will be worked but is essentially a development control tool. As such, it is considered that this policy can be screened out of the HRA. MF: Options for a Split between Soft MF1, MF2,MF3, MG1, MG2, MG3 These options have been screened in Sand and Sharp Sand and Gravel; MH1: MH2: MH3 for Appropriate Assessment on a MG: Options for Including a Safety precautionary basis. While they do not Margin for Sharp Sand and Gravel; ‘promote’ development, the options do MH: Options for Calculating the dictate the scale of minerals Landbank; development.

MI: Options for Providing Flexibility to MI1: Identify specific sites to meet the Both of these options promote Meet the Apportionment apportionment (including a safety particular spatial strategies for margin where appropriate) and have minerals development and as such additional site(s) or preferred both have been screened in for areas/areas of search in reserve to Appropriate Assessment. bring forward as necessary.

MI2: Identify specific sites to meet the apportionment (including a safety margin where appropriate) and have a criteria based policy to allow sites to come forward if required.

MK: Options for Meeting the Need for MK1, MK2, MK3, MM1, MM2, MM3, All of these options promote minerals Clay; MM: Options for Meeting the MO1, MO2, and MO3 development (to meet demand) and as Need for Sandstone; MO: Options for such all have been screened in for Meeting the Need for Chalk Appropriate Assessment.

MJ: Spatial Strategy Options for Soft MJ1, MJ2, ML1, MN1, MP1, MP2 These options promote a particular Sand and Sharp Sand and Gravel spatial strategy for minerals Sites; ML: Spatial Strategy Options for development and as such has been Clay; MN: Spatial Strategy Options for screened in for Appropriate Sandstone; MP: Spatial Strategy Assessment. Options for Chalk

MQ: Options for Meeting the Need for MQ1: Include criteria based policy for Depending on the locations that such Oil small scale oil and gas sites to come development might take place, oil and forward as required. gas exploration could potentially lead to adverse effects on European sites. As such this preferred option and its

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Issue Options Screening (green = screened out, amber = screened in for appropriate assessment) associated policy have been screened in for further consideration at Appropriate Assessment. MR: Options for Promoting the Use of MR1: Include a policy to encourage This option has been screened out as Secondary and Recycled Aggregates the use of Secondary and Recycled it is intended to reduce the amount of Aggregates in construction. primary aggregate extraction and maximise recycling and re-use. There is thus no mechanism for an adverse effect on European sites. Waste WA: Options for safeguarding existing WA1: Assess all existing waste This option does not ‘promote’ waste waste management sites management sites, safeguarding the development, but safeguards existing most appropriate facilities (including a sites in order to prevent them from buffer zone around the site) and being prejudiced by alternative develop a policy to guide future development. ‘Safeguarding’ a site is decisions regarding safeguarded and essentially a development control tool. non-safeguarded sites. As such, it is considered that this policy can be screened out of the HRA. WA2: Assess only permanent waste This option does not ‘promote’ waste management sites, safeguarding the development, but safeguards existing most appropriate facilities (including a sites in order to prevent them from buffer zone around the site) and being prejudiced by alternative develop a policy to guide future development. ‘Safeguarding’ a site is decisions regarding safeguarded and essentially a development control tool. non-safeguarded sites, including those As such, it is considered that this with temporary permissions. policy can be screened out of the HRA. WB: Options for meeting the recycling WB1, WB2, WB3, WC1, WC2, WC4, These options direct the spatial and composting capacity shortfall for WI1, WI2,WI3, WJ1, WK1, WN1, WN2, location of waste development. While C&I waste; WC: Options for meeting WN3, WO1 and WO2 much of that is already covered by the the recycling capacity shortfall for inert waste sites which will be identified in waste; WI: Options for meeting the the MWDF, there may be potential for treatment capacity shortfall for C&I unallocated sites to come forward waste; WJ: Options for meeting the under this option/policy in the future. treatment capacity shortfall for C&D On this basis, it has at this stage been waste; WK: Options for meeting the screened in for Appropriate treatment capacity shortfall for Assessment. wastewater; WN: Options for meeting the capacity shortfall for non-inert landfill; WO: Options for meeting the capacity shortfall for inert landfill WD: Spatial strategy options for open- WD1: Develop a policy to enable These options direct the spatial windrow composting small-scale, on-farm, open-windrow location of waste development. Whilst facilities (with a capacity of approx. much of that is already covered by the 5,000tpa) to come forward in rural waste sites which will be identified in areas, over 250m from sensitive uses. the MWDF, there may be potential for Sites may be within the AONB or unallocated sites to come forward National Park as they are small-scale under this option/policy in the future. and have a low height profile. On this basis, it has at this stage been screened in for Appropriate Assessment. Whilst option WD1 could WD2: Identify between two and four potentially result in only very small suitable sites for larger-scale open-

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Issue Options Screening (green = screened out, amber = screened in for appropriate assessment) windrow facilities (with a capacity of scale impact at each ‘farm’, it could approx. 25,000tpa) in rural areas with potentially result in a cumulative good access to the ALR (with a impact on European sites. preference for sites close to the SLR) and over 250m from sensitive uses. The sites will not be located within the AONB or National Park, unless a suitable previously developed site is available. WD3: Combination of Options 1 and 2. WE: Spatial strategy options for in- WE1, WE2, WF1, WF2, WF3 WF4, These options direct the spatial vessel composting (IVC); WF: Spatial WG1, WG2, WG3, WG4 WL1, WL2, location of waste development. While strategy options for recycling facilities; WL3, WM1, WP1, WP2, WP3, WP4, much of that is already covered by the WG Spatial strategy options for inert WQ1, WQ2 and WQ3 waste sites which will be identified in waste recycling; WL: Spatial strategy the MWDF, there may be potential for options for C&I waste treatment; WM: unallocated sites to come forward Spatial strategy options for wastewater . under this option/policy in the future. treatment; WP: Spatial strategy On this basis, it has at this stage been options for non-inert disposal to land; screened in for Appropriate WQ: Spatial strategy options for inert Assessment. disposal to land.

WH: Option for meeting the treatment WH1: Centralised MBT with AD plant = This option directs the spatial location capacity shortfall for MSW waste 0.25 – 0.32mtpa. of waste development. Whilst it is suggested capacity shortfall for MSW can be met by a site in development, there may be potential for other sites to come forward to meet shortfall. On this basis, it has at this stage been screened in for Appropriate Assessment.

Transport of Minerals and Waste TA : Options for Safeguarding TA1, TA2, TA3, TA4, TA5, TA6, TB1, These options do not ‘promote’ Railheads; TB: Options for TB2, TB3, TB4 and TB5 wharves and railheads development, Safeguarding Wharves but safeguards existing sites in order to prevent them from being prejudiced by alternative development. ‘Safeguarding’ a site (as distinct from allocating sites) is essentially a development control tool. As such, it is considered that this policy can be screened out of the HRA.

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5 Conclusions of Screening

5.1 Minerals sites

5.1.1 It can be seen from the preceding tables that 15 minerals sites can be screened out as having no mechanism for an adverse effect on European sites. The 12 sites that have been screened in for Appropriate Assessment are as follows.

Table 7 – Minerals sites screened in for Appropriate Assessment Site name Woodmancote East of West Heath Common Common Road West Minsted West Common Road East Duncton Common Slades Field Chantry Lane Extension West Heath Common Extension Land Adjacent to West Hoathly Brickworks Philpots Extension Horncroft

5.2 Waste sites

5.2.1 It can be seen from the preceding tables that 26 waste sites can be screened out as having no mechanism for an adverse effect on European sites. The 11 sites that have been screened in for Appropriate Assessment are listed below. This list is long due to the precautionary approach we have taken at this screening stage; this mainly stems from the number of sites which are potentially suitable for Energy from Waste facilities and which lie within 10km of European sites. It is entirely possible that we will be able to conclude no adverse effects from many of these sites following the Appropriate Assessment.

Table 8 – Waste sites screened in for Appropriate Assessment Site Portfield Land at North Farm Blue Prince Mushroom Site Hampers Lane Engineering Works Fuel Depot, Bognor Road Burleigh Oaks Farm Land East of Tangmere Airfield Freshfield Lane Brickworks South East Corner of Tangmere Airfield Chantry Lane Sand Pit Woodhorn Farm

5.3 Waste and minerals Issues and Options

5.3.1 It can be seen from the preceding tables that 27 of the issues (encompassing 62 Options) have been screened in for Appropriate Assessment. The reason for this is that these are the policies that either promote or direct the scale and spatial distribution of waste and minerals development within West Sussex. They will be of particular relevance with regard to any unallocated sites that come forward during the life of the MWDF.

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5.4 Next steps

5.4.1 Following consultation with the Natural England over the sites and preferred options selected for Appropriate Assessment, the Appropriate Assessment will commence.

Habitats Regulations Assessment – Screening of Likely Significant Effects Report March 2010 35 West Sussex County Council West Sussex Minerals & Waste Development Framework Appendix 1 - Background on European sites referenced in this document

Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Kingley Vale SAC 208.05  Yew-dominated woodland  Maintenance of grazing  Dry grasslands and scrublands  The long-term conservation of the yew forest requires the on chalk or limestone maintenance of nurse scrub habitat and the regulation of numbers of resident deer.  Minimal air pollution – nitrogen deposition may cause reduction in diversity, sulphur deposition can cause acidification  Absence of direct fertilisation  The site is vulnerable to spray-drift (i.e. eutrophication) from surrounding intensive arable land.  Low recreational pressure. Rook Clift SAC 10.82  Mixed woodland on base-rich soils  Appropriate woodland management associated with rocky slopes  Deer grazing needs to be controlled  Planting inside the woodland needs to be tightly controlled. Duncton to Bignor 214.47  Mixed woodland on base-rich  Minimal atmospheric pollution - may increase the susceptibility of Escarpment soils associated with rocky slopes beech trees to disease SAC  Appropriate woodland management Singleton and 2.45  Hibernating barbastelle bat  Absence of disturbance. Tunnel entrances are covered by bat grill Cocking Tunnels  Hibernating Bechstein’s bat to prevent disturbance. SAC  Barbastelles require a constant humidity around their roosts; any manipulation of the shrub layer must be carefully considered. The Mens SAC 203.28  Beech forests on acid soil  Appropriate woodland management.  Barbastelle bat  Low recreational pressure (because management is minimum intervention and Bridleway degradation by horse riding is a recurring threat)  Minimal air pollution - may increase the susceptibility of beech trees to disease and alter epiphytic communities.  Barbastelles require a constant humidity around their roosts; any manipulation of the shrub layer must be carefully considered.

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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Ebernoe Common 133.94  Atlantic acidophilous beech  Appropriate management. SAC forests with Ilex and sometimes  Minimal atmospheric pollution - may increase the susceptibility of also Taxus in the shrublayer beech trees to disease and alter epiphytic communities.Absence  Barbastelle bat of disturbance.  Bechstein’s bat  In a wider context, bats require good connectivity of landscape features to allow foraging and commuting.  Both bat species have close association with woodland. Areas of undesignated woodland adjacent to SAC may be of most importance to population  Barbastelles require a constant humidity around their roosts; any manipulation of the shrub layer must be carefully considered. Solent Maritime SAC 11325.09  Estuaries  Sufficient space between the site and development to allow for  Cord grass swards managed retreat of intertidal habitats and avoid coastal squeeze.  Atlantic salt meadows  No dredging or land-claim of coastal habitats.  Subtidal sandbanks  Unpolluted water and high oxygenation.  Intertidal mudflats and sandflats  Absence of nutrient enrichment.  Lagoons  Absence of non-native species.  Annual vegetation of drift lines  Maintenance of freshwater inputs.  Coastal shingle vegetation  Balance of saline and non-saline conditions. outside the reach of waves  Maintenance of grazing  Glasswort and other annuals colonising mud and sand  Shifting dunes with marram  Desmoulin’s whorl snail

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Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Chichester and 5810.03  Internationally important wintering  Sufficient space between the site and development to allow for Langstone Harbours populations of Brent goose, managed retreat of intertidal habitats and avoid coastal squeeze. SPA/Ramsar shelduck, pintail, shoveler, red-  Unpolluted water. breasted merganser, ringed  Absence of nutrient enrichment of water. plover, grey plover, dunlin, bar-  Minimal recreational and other disturbance tailed godwit, curlew, redshank  Absence of non-native species e.g. from shipping activity. and breeding population of little  Maintenance of appropriate hydrological regime, e.g. freshwater tern flows at heads of channels are important for birds to preen, drink  Over winter the area regularly and feed. supports 93230 waterfowl (5 year  Short grasslands surrounding the site are essential to maintaining peak mean 01/04/1998) interest features as they are now the key foraging resource for  Internationally important Brent goose. population of wintering waterfowl (Ramsar)  Internationally important populations of ringed plover, black-tailed godwit, common redshank, dark-bellied brent goose, common shelduck, grey plover, dunlin, little tern (Ramsar) Pagham Harbour 636.68  Internationally important wintering  Sufficient space between the site and development to allow for SPA/European populations of ruff and pintail managed retreat of intertidal habitats and avoid coastal squeeze. Marine Site/Ramsar  Internationally important breeding  Unpolluted water. population of little tern  Minimal recreational and other disturbance  Absence of nutrient enrichment of water.  Absence of non-native species.  Maintenance of appropriate hydrological regime.  Maintenance of isolated, open, non-vegetated sand and shingle beaches and spits for nesting.  Maintenance of suitable feeding areas in estuarine habitats and inland grazing marshes  Maintenance of suitable feeding areas with winter wheat/grass close to Pagham Harbour

Habitats Regulations Assessment – Screening of Likely Significant Effects Report March 2010 38 West Sussex County Council West Sussex Minerals & Waste Development Framework

Site Area (ha) Qualifying Features Key Environmental Conditions to Support Site Integrity Arun Valley 528.62  Supports nationally important  Appropriate grazing management SPA/Ramsar wintering population of 27241  Sympathetic management of lowland wet grassland/grazing waterfowl (5 year peak mean marsh (including water level management). 30/06/1999) including tundra  Minimal disturbance swan  Management of the hydrology of the area important. For  The Arun Valley consists of three example, the impact of water abstraction, river maintenance, and component Sites of Special ensuring that winter flooding can continue as part of the existing Scientific Interest. management of the site.  The neutral wet grassland  Ditches support rich aquatic flora and invertebrate fauna.  The area is of outstanding ornithological importance notably for wintering wildfowl and breeding waders.

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Appendix 2 - ‘Tiering’ in Habitat Regulations Assessment

The South East Plan AA

Increasing Sub-Regional Strategies AA specificity in terms of evidence base, impact evaluation, mitigation, consideration of Waste and minerals AA alternatives etc. Development Frameworks

Individual projects/planning applications AA

Habitats Regulations Assessment – Screening of Likely Significant Effects Report March 2010 40 THIS DOCUMENT HAS BEEN PREPARED IN ACCORDANCE WITH THE SCOPE OF SCOTT WILSON'S APPOINTMENT WITH ITS CLIENT AND IS SUBJECT TO THE TERMS OF THAT APPOINTMENT. SCOTT WILSON ACCEPTS NO LIABILITY FOR ANY USE OF THIS DOCUMENT OTHER THAN BY ITS CLIENT AND ONLY FOR THE PURPOSES FOR WHICH IT WAS PREPARED AND PROVIDED.

Thursley & Ockley Bogs NOTES Thursley, Hankley & Frensham Commons Mineral Sites Counties Ramsar SPA Shortheath Common SAC

ID Site Name 1 Brick Kiln Farm 2 Chantry Lane CFS 2009 3 Common Road East 4 Common Road West Wealden Heaths Phase II 13 Woolmer Forest 17 5 Copse Farm 6 Densworth North Ashdown Forest 7 Duncton Common Ashdown Forest 8 East Lavant 9 Ham Farm 10 Hawkhurst Farm 11 Horncroft East Hampshire Hangers 12 Huntersrace Lane North 13 Land adjacent to West Hoathly Brickworks Ebernoe Common 14 Land at Redvins 15 Madam Green Farm West 16 Minsted West 17 Philpots Extension 18 Shopwyke North 19 Shopwyke South 20 Shoreham Cement Works The Mens 21 Site East of West Heath 23 22 Slades Field 21 23 West Heath Extension Revised 24 West Stoke Road East 25 West Stoke Road West 16 26 Withies Farm West West Sussex 27 Woodmancote 10 Rook Clift 7 Copyright Reproduced from Ordnance Survey digital map data © Crown copyright 2010. All rights reserved. Licence number 0100031673. 11 © Natural England material is reproduced with Singleton and Cocking Tunnels Arun Valley the permission of Natural England 2010 Arun Valley Source: 2001 Census, Output Area Boundaries. Crown copyright 2003. Crown copyright material 2 is reproduced with the permission of the Controller of HMSO Duncton to Bignor Escarpment 9

Kingley Vale Lewes Downs

8 20 27 4 3 6 24 14 Revision Details By Date Suffix Check 12 Drawing Status 22 25 5 Castle Hill FINAL Job Title 18 19 WEST SUSSEX 15 MINERALS 1 26 & WASTE CORE STRATEGY HRA Drawing TitleMINERAL SITES

Chichester and Langstone Harbours SITES WITHIN AND Chichester and Langstone Harbours AROUND WEST SUSSEX Scale at A3 Pagham Harbour 1:200,000 Pagham Harbour Drawn AH Approved JR

Stage 1 check Stage 2 check Originated Date

Scott Wilson Scott House Alençon Link, Basingstoke 54 Hampshire, RG21 7PP Telephone (01256) 310200 Fax (01256) 310201 www.scottwilson.com

Drawing Number Rev FIGURE 3a Date: 25th2010 March Date: sitessussex.mxd around- west within and Mineral3a Sussex Waste\ArcGIS\MXDs\Figure Minerals I:\5004 Information Systems\D_West and - Filepath: