Sea Change Sussex
Bexhill Enterprise Park
Environmental Statement Volume 1: Main Report
Project Ref: 27511
October 2013
Peter Brett Associates LLP 10 Queen Square Bristol BS1 4NT T: 0117 9281560 F: 0117 9281570 E: [email protected] Bexhill Enterprise Park Environmental Statement Volume 1: Main Report
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Document Control Sheet
Project Name: Bexhill Enterprise Park Project Ref: 27511 Report Title: Environmental Statement Volume 1: Main Report Date: October 2013
Name Position Signature Date
Various Prepared by:
Stefan Boss Associate 17 October 2013 Reviewed by:
David Walker LLP Director 17 October 2013 Approved by:
For and on behalf of Peter Brett Associates LLP
Revision Date Description Prepared Reviewed Approved
00 17/10/13 Planning Application SB SB DW
Peter Brett Associates LLP disclaims any responsibility to the Client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the Contract with the Client and generally in accordance with the appropriate ACE Agreement and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the Client. This report is confidential to the Client and Peter Brett Associates LLP accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.
© Peter Brett Associates LLP 2013
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Contents
1 Introduction ...... 1 1.1 The Proposed Development ...... 1 1.2 The Bexhill to Hastings Link Road and North East Bexhill Gateway Road ...... 1 1.3 Policy Position ...... 2 1.4 Terms and Definitions ...... 3 1.5 The EIA and Related Documents ...... 3 1.6 Stakeholder Consultation ...... 4 1.7 Project Team ...... 4 1.8 Structure of the Environment Statement ...... 4 2 Site and Surrounding Area ...... 6 2.1 The Site and Surrounding Area ...... 6 2.2 History of the Site...... 7 3 The Proposed Development ...... 8 3.1 Description of Proposed Development ...... 8 3.2 Utilities ...... 10 3.3 Incorporated Mitigation ...... 11 3.4 Consideration of Alternatives ...... 12 4 Construction and Site Management ...... 15 4.1 Introduction ...... 15 4.2 Construction Works and Programme...... 15 4.3 Construction Management ...... 15 4.4 Waste ...... 17 5 Assessment Method ...... 18 5.1 Introduction ...... 18 5.2 EIA Regulations ...... 18 5.3 The EIA Process ...... 18 5.4 Screening and Scoping ...... 18 5.5 Consultations ...... 19 5.6 Committed Developments ...... 20 5.7 Assessment Assumptions ...... 21 5.8 Assessing Effects...... 21 5.9 Mitigation of Adverse Effects ...... 23 5.10 Residual Effects ...... 23 5.11 Uncertainty ...... 24 5.12 Significance Criteria ...... 24 5.13 Impact Interactions...... 25 6 Planning and Policy Context ...... 26 6.1 Introduction ...... 26 6.2 National Planning Policy ...... 26 6.3 Regional Planning Guidance ...... 31 6.4 Local Development Plans ...... 31 6.5 Other Documentation ...... 33 6.6 The Changing Policy Context ...... 35 7 Economic Impacts ...... 36 7.1 Introduction ...... 36 7.2 Policy Context ...... 36 7.3 Baseline Conditions ...... 41 7.4 Assessment of Construction Effects ...... 48 7.5 Assessment of Operational Effects...... 48 7.6 Assessment of Cumulative Effects ...... 49
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7.7 Summary ...... 51 7.8 References ...... 52 8 Transport and Access ...... 53 8.1 Introduction ...... 53 8.2 Policy Context ...... 53 8.3 Methodology ...... 54 8.4 Baseline Conditions ...... 57 8.5 Assessment and Mitigation of Construction Effects ...... 59 8.6 Assessment and Mitigation of Operation Effects ...... 60 8.7 Summary of Residual Effects ...... 64 8.8 Summary ...... 64 8.9 References ...... 64 9 Noise & Vibration ...... 65 9.1 Introduction ...... 65 9.2 Policy Context ...... 65 9.3 Methodology ...... 69 9.4 Baseline Conditions ...... 73 9.5 Assessment and Mitigation of Construction Effects ...... 74 9.6 Assessment and Mitigation of Operational Effects ...... 76 9.7 Summary of Residual Effects ...... 77 9.8 Summary ...... 77 9.9 References ...... 78 10 Air Quality ...... 79 10.1 Introduction ...... 79 10.2 Policy Context ...... 79 10.3 Methodology ...... 81 10.4 Baseline Conditions ...... 88 10.5 Assessment and Mitigation of Construction Effects ...... 90 10.6 Assessment and Mitigation of Operation Effects ...... 92 10.7 Summary ...... 95 10.8 References ...... 96 11 Ecology and Nature Conservation ...... 97 11.1 Introduction ...... 97 11.2 Policy Context ...... 97 11.3 Methodology ...... 100 11.4 Baseline Conditions ...... 105 11.5 Assessment and Mitigation of Construction Effects ...... 111 11.6 Assessment and Mitigation of Operation Effects ...... 116 11.7 Summary of Residual Effects ...... 117 11.8 Summary ...... 117 11.9 References ...... 118 12 Landscape and Visual ...... 120 12.1 Introduction ...... 120 12.2 Policy Context ...... 121 12.3 Methodology ...... 124 12.4 Baseline Conditions ...... 133 12.5 Assessment and Mitigation of Construction Effects ...... 145 12.6 Assessment and Mitigation of Operation Effects ...... 154 12.7 Assessment and Mitigation of Cumulative Effects ...... 162 12.8 Summary of Residual Effects ...... 164 12.9 Summary ...... 167 12.10 References ...... 167 13 Ground Conditions ...... 169 13.1 Introduction ...... 169
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13.2 Policy Context ...... 170 13.3 Methodology ...... 173 13.4 Baseline Conditions ...... 178 13.5 Assessment and Mitigation of Construction Effects ...... 183 13.6 Assessment and Mitigation of Operational Effects ...... 185 13.7 Assessment and Mitigation of Cumulative Effects ...... 187 13.8 Summary of Residual Effects ...... 188 13.9 Summary ...... 190 13.10 References ...... 191 14 Water Quality and Drainage ...... 192 14.1 Introduction ...... 192 14.2 Policy Context ...... 192 14.3 Methodology ...... 197 14.4 Baseline Conditions ...... 200 14.5 Assessment and Mitigation of Construction Effects ...... 203 14.6 Assessment and Mitigation of Operational Effects ...... 206 14.7 Assessment and Mitigation of Cumulative Effects ...... 209 14.8 Summary of Residual Effects ...... 209 14.9 Summary ...... 209 14.10 References ...... 210 15 Cultural Heritage ...... 211 15.1 Introduction ...... 211 15.2 Policy Context ...... 211 15.3 Methodology ...... 213 15.4 Baseline Conditions ...... 214 15.5 Assessment and Mitigation of Construction Effects ...... 217 15.6 Assessment and Mitigation of Operation Effects ...... 218 15.7 Summary of Residual Effects ...... 218 15.8 Summary ...... 218 15.9 References ...... 219 16 Summary & Impact Interactions ...... 221 16.1 Introduction ...... 221 16.2 Methodology ...... 221 16.3 Construction Effects ...... 222 16.4 Operation Effects ...... 222 17 Glossary ...... 224
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1 Introduction
1.1 The Proposed Development
1.1.1 This Environmental Statement (ES) has been prepared in respect of an outline planning application by Sea Change Sussex for the Bexhill Enterprise Park. Sea Change Sussex is a not-for-profit economic development company for the county.
1.1.2 An outline application is one which seeks permission for the principle of development, and the parameters for that development, and for which subsequent reserved matters application(s) will be required to agree the detail of the development.
1.1.3 The planning application comprises:
° An outline planning application, with all matters reserved except for access, for the demolition of existing buildings and development of 15,000m 2 (net internal area) of employment space (within use classes B1a, B1b and B1c) and associated uses including plant, pedestrian and vehicle circulation, car parking, cycle parking, landscaping, and utilities at North East Bexhill.
1.2 The Bexhill to Hastings Link Road and North East Bexhill Gateway Road
1.2.1 The Bexhill Enterprise Park will be accessed from and be adjacent to the junction of the Bexhill to Hastings Link Road (BHLR) and the North East Bexhill Gateway Road (NEBGR).
1.2.2 The BHLR is a single carriageway road that will link the outskirts of Bexhill and Hastings (see Appendix A.1 ). The BHLR will be 5.6km long and starting at the A259 in Bexhill, it will run along the line of the disused Bexhill to Crowhurst railway line and then pass around the northern side of the Combe Haven Site of Special Scientific Interest (SSSI). Crossing Crowhurst Road and the Hastings to London railway line, it goes round the southern edge of the Marline Valley Woods SSSI before joining Queensway just north of Crowhurst Road.
1.2.3 The planning application for the BHLR was submitted in April 2007. An ES (East Sussex County Council, 2007) was prepared in relation to the BHLR and submitted with the planning application. An area to be subject to Compulsory Purchase Orders was identified within the planning application; this land is to be acquired by East Sussex County Council (ESCC) for the purposes of constructing the BHLR. Planning permission was granted in July 2009. Provisional funding for the NEBGR was secured from the Department for Transport (DfT) in March 2012, which was confirmed in February 2013.
1.2.4 The NEBGR will be a single carriageway road of approximately 850m, connecting Wrestwood Road with the shortly to be constructed Bexhill to Hastings Link Road (BHLR) (see Appendix A.1 ). The NEBGR will provide a footway for pedestrians and cyclists, along with junctions for forthcoming employment and residential development. A planning
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application for the NEBGR was submitted by Sea Change Sussex in May 2013 and planning permission was granted in September 2013 (reference: RR/2013/899/P).
1.2.5 It is understood that the construction of both roads will be complete by 2015 and that they will open in mid-2015.
1.2.6 On the basis of the planning position in relation to the BHLR and the NEBGR and that both routes will provide access to the Bexhill Enterprise Park, this ES has considered the BHLR and NEBGR to be committed development. The BHLR and NEBGR have therefore been considered to form part of the baseline against which the Bexhill Enterprise Park has been considered, while the potential for significant cumulative effects as result of the two roads and the Enterprise Park has also been considered.
1.3 Policy Position
1.3.1 The National Planning Policy Framework (NPPF) was published in 2012 and sets out the Government’s policy for planning and to promote development. The NPPF is a key part of the national Government reforms to make the planning system less complex and more accessible, to protect the environment and to promote sustainable growth; the NPPF includes the presumption in favour of sustainable development.
1.3.2 The requirement for employment land in Rother and Hastings is well established. The Hastings and Rother Employment Strategy and Land Review Update (August 2011) identifies that 163,000m 2 of employment land is required in the boroughs in the period to 2028. It is anticipated that approximately one third of this space will be provided at North East Bexhill, with the intention that 22,000m 2 to the south of the BHLR being delivered first. This is of note as the mix of employment uses proposed as the Bexhill Enterprise Park has a greater employment density (i.e. number of jobs per m 2) than the employment uses to the north of the BHLR.
1.3.3 The Rother District Local Plan 2006-2011 was adopted in July 2006, and although dated remains the most relevant local policy document in the borough. Policy BX2 sets out the development parameters for an allocated site known as North East of Bexhill, south of the BHLR. The allocation provides for at least 980 dwellings, 22,000m2 of employment uses and a Countryside Park. The new development is to be accessed from a new road (the NEBGR), which benefits from an extant planning permission and should be open prior to the occupation of the wider development.
1.3.4 The North East Bexhill Supplementary Planning Document (SPD) was adopted in June 2009. This maintains the principle of the BX2 allocation and provides further guidance on the illustrative form and layout of development in the area (including good access from the BHLR and the landscaped NEBGR, and well-designed buildings providing office space and clean manufacturing within an attractive environment).
1.3.5 The employment allocation is split between two areas, one close to the junction of the NEBGR and the BHLR and one close to Wrestwood Road. The outline planning application relates to employment area close to the junction of the NEBGR and BHLR. Given that the NEBGR and BHLR are committed developments, consideration has been given in this ES to
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the likely significant cumulative effects of the Bexhill Enterprise Park, BHLR and NEBGR. Consideration has also been given to the likely significant environmental effects of the Bexhill Enterprise Park in the context of the wider allocation. Although the cumulative impacts have been considered, no details have yet been put forward in respect of the wider development of BX2 for residential development and this ES has therefore proceeded on the basis of the guidance in the SPD, which was subject to a sustainability appraisal (Rother District Council 2007).
1.3.6 The Local Plan and the SPD therefore provide the key policy context for development at North East Bexhill. Further information on these documents and the wider policy context is provided in Chapter 6 .
1.4 Terms and Definitions
1.4.1 For ease of reference the following terms have been used in this ES:
° North East Bexhill Gateway Road (NEBGR): The name of the road which benefits from an extant planning permission (ref: RR/2013/899/P); to be considered as committed developments for the purposes of the EIA.
° Bexhill to Hastings Link Road (BHLR): The new road to be constructed between Bexhill and Hastings and which benefits from an extant planning permission and funding; to be considered as committed developments for the purposes of the EIA.
° The site: The area within the planning application boundary for the Bexhill Enterprise Park planning application (see Figure 2 in Appendix A.2).
° The proposed development: Bexhill Enterprise Park.
1.5 The EIA and Related Documents
1.5.1 This Environmental Statement presents the findings of an Environmental Impact Assessment (EIA) undertaken in accordance with The Town and Country Planning (Environmental Impact Assessment) Regulations 2011, referred to as the ‘EIA Regulations’.
1.5.2 Running concurrently with the design process, the EIA has sought to identify appropriate design and construction measures and good practice to mitigate potential adverse environmental effects and maximise environmental opportunities which might arise as a consequence of the construction and operation of the proposed development as well as determining the residual environmental effects remaining after mitigation has been incorporated.
1.5.3 The ES comprises the following separate volumes:
° Volume 1: Main Report;
° Volume 2: Appendices; and
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° Non-Technical Summary.
1.5.4 The other principal documents to be submitted as part of the planning application are:
° Planning, Design and Access Statement;
° Energy Statement;
° Transport Assessment; and
° Community Engagement Report.
1.6 Stakeholder Consultation
1.6.1 A comprehensive programme of consultation has been undertaken to inform the design of the development and the EIA. Consultation has been undertaken with statutory and non- statutory consultees (including the RDC, ESCC, Environment Agency and Natural England) to discuss and agree the details of the proposals and the assessment work.
1.6.2 In addition, a comprehensive programme of public consultation has been undertaken. This included two drop-in sessions to which approximately 600-700 residents, business people, councillors and council officers attended to discuss the proposals and provide comments; a consultation meeting with anti-BHLR groups; separate sessions with various business groups; publication of the proposals on Sea Change Sussex’s web site, accompanied by a comment mechanism; media activity to raise further awareness of the proposals and encourage additional comment; plus analysis of 90 written submissions. The programme is documented in a Community Engagement Report submitted with the planning application. The input of all consultees is gratefully acknowledged.
1.7 Project Team
1.7.1 The project team is as follows:
° Applied Ecology: Ecology & Nature Conservation;
° CgMs: Archaeology;
° Influence CLA: Landscape Architect;
° Peter Brett Associates LLP: Engineers, EIA Coordination, Transport, Ground Conditions, Water Quality and Drainage, Noise and Air Quality;
° Proctor and Matthews: Architects;
° Regenecon: Economics; and
° TK Associates: Consultation.
1.8 Structure of the Environment Statement
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1.8.1 The ES is structured as follows:
° Chapter 2 : Describes the site and the surrounding area;
° Chapter 3 : Describes the proposed development, including the consideration of alternatives;
° Chapter 4 : Describes the construction works;
° Chapter 5 : Describes the methodology adopted to undertake the EIA;
° Chapter 6 : Summarises the planning and policy context to the proposed development;
° Chapters 7 to 15 : Comprise the technical assessment chapters;
° Chapter 16 : Assesses impact interactions and provides a summary; and
° Chapter 17: Provides a glossary of terms.
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2 Site and Surrounding Area
2.1 The Site and Surrounding Area
2.1.1 The following description of the site and surroundings should be read in conjunction with the following plans provided in Appendix A.2:
° Figure 1 : Site Location Plan;
° Figure 2 : Planning Application Boundary Plan;
° Figure 3 : Site and Surrounding Area Plan; and
° Figure 4 : Site Photographs Plan.
2.1.2 The site is located on the northern fringe of Bexhill, located approximately at National Grid Reference 574814;109444 and comprises approximately 10 hectares.
2.1.3 The site predominantly comprises pasture land. The fields are broken by tracks, a watercourse and hedgerows. The western area of the site comprises the farmhouse and associated outbuildings of Glover’s Farm, accessed from the west via Glover’s Lane.
2.1.4 The site includes a shallow valley (ghyll) caused by erosion from surface water emanating from groundwater seepages a short way to the south of the site. Water during recent site surveys was observed to be a steady flow and of approximately 25-50mm in depth. The ghyll ultimately flows into the Combe Haven stream.
2.1.5 The site slopes down from south to north, from approximately 30m above ordnance datum (AOD) to 20mAOD at the disused railway line.
2.1.6 33 kV High Voltage Electricity Pylons traverse the site from south east to north west.
2.1.7 The northern boundary of the site comprises a disused railway line. The former railway corridor is at grade with the site within the site boundary, but extends in a cutting to the south west and on an embankment towards the east. The railway corridor is extensively tree lined; however some trees have recently been removed to accommodate the forthcoming BHLR. The BHLR will utilise the railway corridor to the south west of the site, before swinging to the north immediately to the north of the site. The NEBGR will bisect the site from south east to north east.
2.1.8 The eastern boundary of the site, and eastern part of the southern boundary, comprises a mature field edge of hedgerow and trees. The remainder of the southern boundary of the site comprises a track associated with Glover’s Farm.
2.1.9 The nearest dwellings to the site are approximately 100m to the south west on St James’ Crescent. Upper Worsham Farm is located approximately 400m to the south east of the site and there are further dwellings to the south on Wrestwood Road and adjacent roads.
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Generally the site is well screened from local dwellings as a result of The Mount (a small wooded hill immediately to the south of the site containing an underground reservoir, belonging to Southern Water), the undulating topography of the area, existing vegetation and vegetation to be planted adjacent to the St James’ Crescent dwellings as part of the NEBGR.
2.2 History of the Site
2.2.1 A review has been undertaken of historical ordnance survey (OS) maps of the site.
2.2.2 The site is shown to be part of a field system in 1875, the earliest edition OS map available. A footpath/track is shown to cross close to the southern boundary of the site with a further track crossing the northern part of the site in the vicinity of Glover’s Farm. The surrounding area is also predominantly agricultural, with Glovers Farm identified.
2.2.3 The railway line and embankment at the northern site boundary (Bexhill Branch) is shown to be present on the 1909 map. The railway is shown in cutting where it passes through the residential area to the west of the site, under Glovers Lane, adjacent to Glovers Farm moving to embankment as the topography changes to the east. The track is shown to have been removed at some time prior to 1968 at which time the line is labelled as dismantled.
2.2.4 A reservoir and filter beds are shown to be located to the south of Wrestwood Road on the 1899 map as part of the ‘Bexhill Water Works’ with a well and pumping station shown to the east of this location.
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3 The Proposed Development
3.1 Description of Proposed Development
Introduction
3.1.1 The planning application is an outline application. The description of the outline proposals should be read in conjunction with the following drawings (which are provided in Appendix A.3 ):
° Parameters Plan; and
° Illustrative Master Plan.
3.1.2 The Bexhill Enterprise Park will provide 15,000m 2 (net internal area) of employment space (within use classes B1a, B1b and B1c). A range of uses (offices, research and development, and light industry) are proposed to allow flexibility in how the enterprise park is delivered based around the requirements of occupiers.
3.1.3 The planning application is based on a parameters plan. This identifies the location of the three development plots which are to be provided, two to the east of the NEBGR and one to the west of the NEBGR. The development plots will be occupied by the employment buildings, car parking and landscaping.
3.1.4 While the buildings will be designed around the specific requirements of future occupiers, it is intended that the buildings will be of a rural vernacular, utilising many of the architectural features of barns within the area (a description of the proposed design intentions is provided in the Planning, Design and Access Statement submitted with the planning application). It is anticipated that buildings will generally be two to three storeys, although single storey buildings may also be provided. For the purposes of the EIA it has been assumed that the buildings will not exceed 18.4m, to ensure that the development is sensitive to the surrounding environment.
3.1.5 Car parking will be provided adjacent to each building, such that occupiers will have defined and proximate parking. It is therefore anticipated that a series of car parking courts will be provided across the development plots, set within landscaping. It is anticipated that the courts will be lit with low level lighting during hours of operation.
3.1.6 An illustrative masterplan has been prepared to indicate how the parameters plan may be implemented. Although not a drawing that will be approved by the planning permission, the illustrative masterplan indicates the thinking of the design team with regards to the layout of the development. In particular, the illustrative masterplan indicates how it is intended that the car parking courts are to be orientated to sit across the contours of the site, in response to the slopes on the site, and how the development is intended to fit within the wider landscape context.
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3.1.7 It is anticipated at this stage that existing ground levels will be retained where possible, except where earthworks are required to provide accesses and suitable gradients for parking areas, footways, etc. It is therefore intended that cut and fill at the site will be balanced.
Access & Highway Works
3.1.8 The Bexhill Enterprise Park will be accessed from a 4-arm roundabout on the NEBGR. The roundabout is to be provided as part of the construction of the NEBGR.
3.1.9 The eastern arm of the roundabout will provide access to the eastern half of the enterprise park. A second, smaller, roundabout is to be provided shortly to the east of the roundabout on the NEBGR. The second roundabout provides access to a circulatory road, from which the development plots can be accessed.
3.1.10 The western arm of the roundabout provides access to a short road giving access to the western half of the Enterprise Park.
3.1.11 The western access road and eastern circulatory road are to be built to adoptable standards and it is therefore anticipated that they will be lit, although this will need to be agreed with ESCC.
3.1.12 Pedestrian and cycle routes will be provided through the site connecting to the public rights of way which come into the site from the north and the west, and also the footway and cycleway to be provided along the southern section of the NEBGR. The pedestrian and cycle routes have been designed to provide connectivity through the site and to provide access to each of the buildings within the Enterprise Park. The pedestrian and cycle routes will connect with the segregated crossing of the NEBGR.
Landscaping
3.1.13 The proposed development will include a comprehensive landscape scheme. For the operational Bexhill Enterprise Park, restoration of landscape lost as a result of construction activities and on-site planting would serve both landscape and ecological purposes. The landscape scheme for the operational development is shown on the Illustrative Masterplan (see Appendix A.3 ), based on the overall vision set by Policy BX2.
Sustainability & Energy
3.1.14 The proposed development is to be built to high standards of sustainability, giving consideration to minimising energy use, maximising natural ventilation, minimising private car use. Further details on the sustainability credentials of the proposed development are provided in the Planning, Design and Access Statement.
3.1.15 The energy strategy for the Enterprise Park will be developed in parallel with the designs of each building, tailored to the requirements of occupiers. It is anticipated however that the utilisation of low and zero carbon energy sources, along with maximising energy efficiency, will remain a fundamental part of the development.
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3.2 Utilities
Introduction
3.2.1 This section summarises the current utility services at and in the vicinity of the site and the utility works proposed as part of the development.
Utility Provision
3.2.2 The following services are present within the vicinity of the site:
° 33kV High voltage (HV) overhead electrical supplies;
° Low voltage (LV) underground electrical supplies;
° Medium pressure gas mains;
° Low pressure gas mains;
° Potable water supplies; and
° BT overhead lines.
Summary of Existing Utilities Provision
3.2.3 Electricity – UK Power Networks drawings show 2 No. 33kV HV overhead cables crossing diagonally through the site to the south of the NEBGR, and continuing to cross through the proposed junction of the NEBGR and the BHLR.
3.2.4 There are further HV and LV cables located to the south of the site within the footways and carriageways of Wrestwood Road, and existing LV services are shown running within Glovers Lane within the western site boundary to serve the existing buildings within the site.
3.2.5 Gas – records from Southern Gas Networks show low pressure and medium pressure mains located to the south of the site within the footways and carriageways of Wrestwood Road in the vicinity of the NEBGR junction.
3.2.6 Mains Water Supplies – record drawings received from South East Water show cast iron (CI) and ductile iron (DI) mains of varying diameter located to the south of the site within the footways and carriageways of Wrestwood Road in the vicinity of the NEBGR junction. There are two mains shown crossing the designated employment land to the south of the site from Wrestwood Road to serve ‘The Mount’ (1 x 400mm ductile iron (DI), and 1 x 315mm high- strength polyethylene (HSPE)).
3.2.7 Data and Telecom Supplies – BT Openreach records show existing overhead apparatus located to the south of the site in the vicinity of the NEBGR junction. There is a further overhead line shown serving the existing properties off Glovers Lane.
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3.2.8 Sewers – Southern Water record drawings show the nearest sewers to the site to be a 225mm vitrified clay (VC) foul water sewer to the south of the site in Wrestwood Road, and a 450mm pre-cast concrete (CP) surface water sewer to the south-east of the site.
Anticipated Utility Works
3.2.9 In order to provide services to the site, strategic mains will be installed within the NEBGR to connect on to the existing utility infrastructure located within Wrestwood Road to the south. As outlined in the planning application for the NEBGR; a bank of ducts is to be laid within the footway/cycleway and below the NEBGR for use by statutory undertakers to provide connections to the employment and residential development that is proposed to be accessed from the road. The duct bank provides for new gas, water, electricity and telecommunications supplies. Spurs for connections to the future development sites, and to BX3, were also included within the proposals.
3.2.10 Alterations to some of the existing utility networks are also anticipated.
3.2.11 Electricity – It is anticipated that the overhead 33kV cables crossing the site will require undergrounding. A total demand of approximately 1,500 kVA is anticipated for the proposed development.
3.2.12 UK Power Networks no longer provide services into buildings requiring a supply over 400 amps, and therefore private cables will need to be installed from a new substation or substations to the building intake position.
3.2.13 Gas – An approximate peak demand of 2,250 kWh is anticipated for the site. A response from Southern Gas Networks is awaited for their budget estimate and proposals of how best to serve the site.
3.2.14 Water – The Bexhill Enterprise Park will require an approximate peak flow of 5.2 l/s. A response from South East Water is awaited for their budget estimate and proposals for new supplies.
3.2.15 Data and Telecoms – New telecom and broadband supplies will be provided to each unit. Sea Change Sussex will work with the local Internet Service Provider (ISP) and other third parties to ensure high quality telecom and broadband supplies will be provided to each unit.
3.2.16 It is anticipated that new mains / cables for each of the above services will connect to the spurs off of the NEBGR to run within service corridors within the site access roads; thus allowing for individual service connections to be made to each unit as and when required.
3.3 Incorporated Mitigation
3.3.1 The iterative nature of the EIA process has resulted in the incorporation of a number of mitigation and enhancement measures during the design phase. These are explained in detail in the topic chapters of this ES. The following summarises some of the key mitigation measures incorporated into the proposed development to ameliorate potentially significant environmental effects and provide environmental enhancements:
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° Comprehensive landscape strategy to set the proposed development into the site, ensure the development is screened from sensitive receptors and that the site is consistent with RDC’s requirements for the adjacent Countryside Park and setting of the NEBGR;
° Comprehensive SuDS to attenuate surface water drainage, while also providing ecological and amenity benefits;
° Provision of ecology mitigation to provide new and replacement habitats;
° Promotion of sustainable travel through provision for pedestrian and cyclists and use of a Travel Plan;
° Sensitive design of the proposed development, including maximum building heights which limit the visibility of the development; and
° Commitment to further archaeological investigation / evaluation to ensure that any affected is identified and recorded as appropriate.
3.4 Consideration of Alternatives
Introduction
3.4.1 The EIA Regulations require an ES to include an outline of the main alternatives considered by the applicant, indicating the main reasons for the choice made, taking into account the environmental effects.
3.4.2 This legal requirement is expressed in very general and high-level terms, requiring only the inclusion of an "outline" of "main" alternatives and an "indication" of "main" reasons. Although a full description of alternatives and a full assessment of their likely environmental effects are not required, sufficient detail should be provided to allow for a meaningful comparison between the alternatives and the proposed development.
3.4.3 It is a matter for the applicant to decide which alternatives it intends to consider. The EIA Regulations do not expressly require that an applicant considers alternatives, although it is widely encouraged at the policy level, both European and domestic, and is a feature of EIA best practice.
3.4.4 Paragraph 83 of Circular 02/99 provides the following national policy guidance on the consideration of alternatives in EIA: "...consideration of alternatives (including alternative sites, choice of process, and the phasing of construction) is widely regarded as good practice, and resulting in a more robust application for planning permission. Ideally, EIA should start at the stage of site and process selection, so that the environmental merits of practicable alternatives can be properly considered." This policy guidance has been taken into account when preparing this ES.
3.4.5 Alternatives should only be considered where they are feasible, realistic and genuine. This may depend on various factors, including planning policy, land ownership, financial viability,
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technical feasibility and design quality. Options which are unlikely to be acceptable or deliverable are not realistic alternatives and so do not need to be considered.
3.4.6 Whilst environmental effects are relevant when choosing between alternatives, other factors are also relevant. The main selection criteria which the applicant has used when choosing between the alternatives which it has considered include: planning policy, viability, design quality, market requirements, site constraints and opportunities and environmental effects.
3.4.7 The following provides an outline of the main alternatives considered in relation to the proposed development and the main reasons for choosing the proposed development in preference to them.
No Development & Alternative Sites
3.4.8 As detailed in Chapter 6 , local planning policy allocates North East Bexhill for development including employment development in the area immediately to the south of the BHLR/NEBGR junction. As a result of this, and the local requirement for employment space (see Chapter 8 ) the principle of employment development at this location has already been established and therefore no development is not a viable alternative.
3.4.9 The North East Bexhill SPD identifies a triangular area for employment development immediately to the south of the BHLR/NENGR. The north eastern boundary of the identified area is located in the centre of an existing field. The northern and eastern boundaries of this field comprise mature hedgerows and trees that would effectively screen development and also provide a natural edge to development. As a result the proposed development includes the development of this field to ensure that the required landscape screening is provided and avoid a less natural development boundary.
Nature of the Planning Application
3.4.10 Consideration has been given to submitting details for an initial phase of development, as part of a hybrid planning application. This alternative was discounted as Sea Change Sussex to ensure that flexibility is provided across the development in how the development can be brought forward in accordance with the requirements of future occupiers.
3.4.11 The buildings within the development will be brought forward to meet the specific requirements of future occupiers, hence the flexibility in the application in seeking permission for B1a, B1b and B1c uses. The approach ensures that occupiers can have premises tailored to their requirements. Reserved matters applications will therefore be submitted as occupiers are secured.
Layout of the Proposed Development
3.4.12 The parameters plan and points of access have been informed by the indicative master plan. Market advice has also influenced the parameters plan. Buildings of between 2,500m 2 to 3,000m 2 net lettable areas have been considered with floor plates of approximately 5,000m 2. Car parking has been considered at a ratio of one space per 250sqft of floor space.
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3.4.13 These requirements coupled with the topography and contour profiles of the existing ground have informed the indicative layouts and the parameters plan on both the east and west of the approved NEBGR.
3.4.14 The indicative master plan suggests barn like buildings set at two and three stories set along the contours to allow structures to sit into the existing topography. Informal parking courts are also set along the contours and allow for planting and green way links.
3.4.15 Two principal landscape characters inform the illustrative master plan and the parameters plan. A larger natural parkland landscape (which is part of and an extension of the countryside park) forms the ‘gateway setting’ to North East Bexhill where the NEBGR meets the BHLR. A clearly defined landscape and built form edge provides the transition to a more ‘woodland’ setting in which the buildings and car parking will be provided. This landscape character will be used to inform further reserved matters applications as they come forward.
Conclusion
3.4.16 The design of the proposed development has been based initially on the requirements of planning policy. Key design issues have then been worked through, drawing in the information from and opinions of consultees, to provide a scheme that responds to the various constraints and opportunities of the site. It is therefore considered that the proposed development provides the best possible response to the constraints and opportunities to meet the requirements of planning policy while minimising potential adverse environmental effects.
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4 Construction and Site Management
4.1 Introduction
4.1.1 This chapter provides information on the construction of the proposed development and the management of the construction site.
4.1.2 An important element in the control of potential adverse environmental effects during the construction phase will be in the implementation of a Construction Environmental Management Plan (CEMP). This will outline the arrangements and management practices to be adopted to minimise the environmental effects of construction and which will be agreed with (RDC) prior to the commencement of construction.
4.1.3 Topic areas for the CEMP are presented in Section 4.3 below.
4.2 Construction Works and Programme
4.2.1 It is anticipated that the first phase of the development will be completed and ready to open in 2015 in parallel with the opening of the BHLR and NEBGR, although this will be dependent on the requirements and demand of occupiers. The other buildings will be completed based on demand.
4.2.2 A contractor has not yet been appointed. As a result detailed construction practices are not yet known. It is however expected that the construction of the Bexhill Enterprise Park will entail the following, the likely significant environmental effects of which have been considered in this ES:
° Establishing the construction compound;
° Earthworks and land profiling;
° Implementation of the car parking areas and access road;
° Provision of pedestrian and cycling facilities, including the Green Way;
° Construction of foundations, building structures, cladding and internal fit out;
° Drainage works, including SuDS; and
° Installation of utilities.
4.3 Construction Management
4.3.1 All of the construction operations carry with them a range of issues to be dealt with in their design, preparation and execution. Best practice in construction management will be required to minimise the environmental effects and disruption that could be caused by the construction works. This will minimise disruption to the local community.
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4.3.2 It is proposed to utilise a Construction Environmental Management Plan (CEMP) to manage the impacts of construction. The CEMP will identify a range of measures to be utilised during the construction of the proposed development avoiding impacts such as noise and vibration, dust and air pollution, contaminated land, ecology, water resources and archaeology.
4.3.3 The format of the CEMP will need to be reviewed once the construction techniques and methodologies to be employed in the various stages of the project are confirmed once a contractor has been appointed. The CEMP will identify the responsibilities of all parties involved in the design, management and construction of the development. It is anticipated that matters a CEMP would address include the following, as well as the construction mitigation and enhancement measures identified in each of the topic chapters of this ES:
Table 4.1: CEMP Areas to Address
Site Constraints and Conditions Key Duties and Deliverables Contractors’ competence and procurement Method statements and risk assessments Contractor communication and liaison Health & safety Performance monitoring and measurement Personal Protective Equipment (PPE) standards Accident reporting Compliance with Environment Agency Pollution Prevention Guidance Contaminated Land Method statements for fuel storage and transfer Personal Protective Equipment (PPE) standards Selection of appropriate plant Preventative & mitigation measures Noise & vibration Hours of operation Monitoring Complaints procedure Preventative & mitigation measures Monitoring Dust & air quality Remediation Complaints procedure Storage and treatment Reduction Waste minimisation & management Re-use
Recovery Disposal (in accordance with the Duty of Care legislation) Archaeology & Heritage Archaeological investigation Preservation by record Appropriate surveys Obtaining licences where required Ecology Protection of key features Sensitive timing Implementing measures to protect badgers, including ramps in deep excavations and capping open pipes at night Protection of resources Water Resources Storage of materials away from water features
Information to contractors on required mitigation Incident recognition Emergency planning & incident Emergency planning control Incident control and reporting Safety & security Site logistics Site Logistics & Operations Working hours Maintaining access
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Site Constraints and Conditions Key Duties and Deliverables General site layout, including: access, offices, routes, demarcation, lighting, deliveries, storage & setdown, welfare facilities. Security Plant & equipment Construction traffic Designated access route Liaison meetings Community liaison Telephone helpline Designated point of contact
4.3.4 It is proposed that the requirement for such a CEMP be secured through an appropriate planning condition.
4.3.5 In addition it is anticipated that the construction works will be signed up to the Considerate Constructor’s Scheme, a recognised system to drive and judge the effectiveness of construction management.
4.4 Waste
4.4.1 The contractor will be required to implement a Site Waste Management Plan (SWMP; in accordance with the requirements of the Site Waste Management Plan Regulations 2008 and best practice guidance) to minimise and control the waste to be disposed of. The main aims of the SWMP will be to ensure compliance with waste legislation and to move waste up the hierarchy, avoiding waste during construction, diverting as much waste as possible from final disposal to more sustainable waste management option, i.e.:
° Reduction;
° Re-use;
° Recovery (i.e. recycling); and
° Disposal (i.e. landfill/incineration).
4.4.2 The SWMP will need to be consistent with the CEMP.
4.4.3 As part of detailed design stages a cut and fill budget will be prepared to identify cut and fill requirements and to review how these can be balanced across the site.
4.4.4 Topsoil stripped can either be re-used on site, as part of the proposed landscaping or sold to nearby users, such as for use in the BHLR landscaping. Final disposal to landfill should not be necessary.
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5 Assessment Method
5.1 Introduction
5.1.1 This chapter describes the process by which the EIA was carried out. It includes a discussion of the relevant Regulations, the EIA process, consultations, and the assessment method.
5.2 EIA Regulations
5.2.1 Procedures relating to the assessment of the environmental effects of development are described in The Town and Country Planning (Environmental Impact Assessment) Regulations 2011. These implement EC Directive 85/337/EEC, as amended, into domestic legislation. The initial Directive and its three amendments have been codified by Directive 2011/92/EU. The Regulations set out the procedures for undertaking an EIA and the information which is required in an Environmental Statement (ES). Formal guidance on procedures under the EIA Regulations was issued in Circular 02/99 and the Government has also published a booklet entitled ‘Environmental Impact Assessment: A Guide to Procedures’ (November 2000).
5.3 The EIA Process
5.3.1 In general terms the main stages in the EIA are as follows:
° Screening: Determining the need for EIA;
° Scoping: Identifying significant issues, determining the scope of the EIA;
° Data Review: Drawing together and review available data;
° Baseline Surveys: Undertaking baseline surveys and monitoring;
° Assessment & Iteration: Assessing likely significant effects of development, evaluating alternatives, providing feedback to design team on potential adverse impacts, modifying development or imposing parameters, incorporating mitigation (including monitoring and long-term management), assessing effects of mitigated development; and
° Preparation of the ES.
5.3.2 It should also be noted that, as summarised in Section 5.5 , consultation with relevant stakeholders has been undertaken throughout the EIA process.
5.4 Screening and Scoping
5.4.1 Sea Change Sussex has undertaken extensive pre-application discussions with RDC with regards to the Bexhill Enterprise Park. This included consideration as to whether the Bexhill Enterprise Park constitutes EIA development. It was agreed that the Bexhill Enterprise Park
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was likely to constitute EIA development and that this needed to be confirmed through formal EIA screening.
5.4.2 An EIA screening and scoping exercise was then undertaken to identify the nature of the site, the characteristics of the Bexhill Enterprise Park, the potentially significant environmental issues relating to the proposed development and the likelihood of significant cumulative effects. Appropriate methods for the assessment of the likely significant environmental effects were also considered.
5.4.3 The screening and scoping exercise involved reviewing the Bexhill Enterprise Park in relation to existing site conditions, the team’s experience of other projects of a similar nature, potentially significant issues, perceived by the team, the means by which they would be assessed and the potential for cumulative effects with other developments. The screening and scoping exercise was also informed by the EIA work undertaken in relation to the NEBGR.
5.4.4 On the basis of this review, a combined EIA Screening and Scoping Opinion Request was submitted on 14 March 2013 (provided in Appendix A.4). This identified that an EIA was likely to be required and identified the proposed scope and approach of the EIA.
5.4.5 RDC provided their EIA Screening and Scoping Opinion on 10 May 2013, this is included in Appendix A.5.
5.4.6 This ES has been prepared to document the assessment undertaken in accordance with the EIA Screening and Scoping Opinion Request and the Screening and Scoping Opinion.
5.5 Consultations
5.5.1 A comprehensive programme of consultations has been undertaken with statutory and non- statutory organisations as well as a community engagement programme. Such consultations have been to undertaken to inform the emerging design and EIA.
5.5.2 As part of the EIA process the following consultees have been consulted to agree the scope of the assessment, to provide information, to discuss assessment methods and findings, and agree mitigation measures and design responses:
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° Rother District Council (RDC);
° East Sussex County Council (ESCC);
° Environment Agency;
° Natural England;
° English Heritage; and
° Southern Water.
5.5.3 The EIA has been undertaken to fulfil the requirements of the consultees and the assistance of these consultees is gratefully acknowledged.
5.5.4 In addition, a comprehensive programme of public consultation has been undertaken. This is summarised in Section 1.6 drawing upon the Community Engagement Report submitted with the planning application.
5.6 Committed Developments
5.6.1 As identified in Section 1.2 , the BHLR benefits from an extant planning permission and secured funding from the DfT. The BHLR is a single carriageway 5.6km long road that will link the outskirts of Bexhill and Hastings. On the basis of the BHLR having an extant planning permission and secured funding, this ES has considered the BHLR to be committed development.
5.6.2 Also as explained in Section 1.2 , a planning application was submitted in May 2013 for the NEBGR and which received planning permission in September 2013. The NEBGR will be a single carriageway road of approximately 850m, connecting Wrestwood Road with the BHLR. The NEBGR will provide a footway for pedestrians and cyclists, along with junctions for employment and residential development. The NEBGR will form the access to the Bexhill Enterprise Park.
5.6.3 The BHLR and NEBGR have therefore been considered to form part of the baseline against which the Bexhill Enterprise Park has been assessed. The potential for significant cumulative effects as result of the two roads and the enterprise park has also been considered.
5.6.4 Consultation with RDC has established that there are no other extant local developments or developments for which a planning application has been submitted that have the potential to lead to significant cumulative effects when considered with the Bexhill Enterprise Park.
5.6.5 It is recognised however that the Bexhill Enterprise Park forms part of the BX2 allocation in local planning policy. Policy BX2 identifies that the allocation should provide at least 980 dwellings, a further 7,000m2 of employment space, a local centre and countryside park. While it is not for the EIA process to assess the environmental effects of policy (indeed planning policy documents have been subject to Sustainability Appraisal), it has been agreed
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with RDC through the pre-application discussions that consideration needs to the wider BX2 allocation in assessing effects. This has been based on information available in local planning policy, in the absence of further details on the wider allocations.
5.6.6 It should also be noted that the scope and approach of the Transport Assessment has been agreed with ESCC, as the local highways authority. This included agreeing the schedule of committed developments to be included in the modelling of transport effects.
5.7 Assessment Assumptions
5.7.1 The following assumptions have been used to ensure that the EIA has undertaken an assessment of reasonable worst case effects (unless otherwise specified in each of the technical chapters) has been undertaken:
° The construction of the BHLR and NEBGR will commence in 2013 and be complete and open in 2015;
° The first phase of the Bexhill Enterprise Park will be complete and open in 2015, with the remainder of the Bexhill Enterprise Park to be delivered based on the requirements of occupiers;
° Baseline conditions are generally considered to be current conditions at the site and surrounding area, except as a result of the implementation of the BHLR and NEBGR. Such changes are identified as appropriate within each topic chapter;
° For the purposes of the assessment of transport and economic effects it has been assumed that the entire development will be B1a. This is based on agent advice identifying that this is the most sought after space. B1a is also the highest generator of road traffic for developments B1a, B1b and B1c;
° The proposed development will be built out in full and to the maximum parameters identified on the parameters plan;
° The wider BX2 allocation will be built out in accordance with the North East Bexhill SPD; and
° Traffic data used by the EIA has been based on the Transport Assessment, the scope of which was agreed with ESCC, specific details are presented in Chapter 8 .
5.8 Assessing Effects
Introduction
5.8.1 The assessment of likely significant environmental effects assesses the likely effects of the proposed development against baseline conditions in the same year (i.e. providing an assessment of ‘do something’ and ‘do nothing’). Cumulative effects have also been assessed that include proposed employment development, with consideration of the wider development to be delivered under local planning policy BX2.
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Establishing Baseline Condition
5.8.2 A range of surveys and data collection exercises have been used to identify environmental conditions at the site. The surveys undertaken are reported in each of the topic chapters.
5.8.3 Baseline conditions are typically considered to be current conditions. However, to set a realistic baseline for assessing the effects of development the completed BHLR and NEBGR are included in the baseline conditions. The approach to how the BHLR and NEBGR have been considered within the identification of baseline conditions is included as appropriate within each topic chapter.
5.8.4 The identification of baseline conditions has been based on technical surveys and assessments, the reporting of which is frequently too detailed and lengthy for full incorporation into Volume 1 of this ES. In such instances the technical survey and assessment reports are provided in full as an appendix to this ES (Volume 2), with a relevant summary and the reference for the full survey or assessment provided in Volume 1.
Assessing Construction Effects
5.8.5 The EIA has assessed the likely significant environmental effects that could occur during the construction phase. These effects will vary substantially during the construction process therefore judgements have been made to ensure that reasonable worst case effects are identified through consideration of the processes most likely to lead to significant effects.
5.8.6 The EIA has considered the construction effects of the proposed development of the Bexhill Enterprise Park. The potentially significant the cumulative construction effects of the Bexhill Enterprise Park, NEBGR and BHLR have been assessed as appropriate.
5.8.7 Most construction effects will be temporary, although site clearance could lead to permanent effects on the landscape or ecology. Construction effects could also be intermittent, i.e. they will not occur at one place throughout the duration of the construction works. The potential duration and intermittency of effects is identified as appropriate in the relevant topic chapters.
5.8.8 In judging the significance of construction effects it has been assumed that the construction mitigation measures identified and the proposed CEMP are fully implemented (as it is expected would be required by a suitable planning condition).
Assessing Operational Effects
5.8.9 To provide a robust assessment and one that is generally consistent between topic chapters, the EIA has focused on assessing the environmental effects of the full, completed development. Therefore, the assessment of operational effects only includes what is covered by this planning application, which is the Bexhill Enterprise Park.
5.8.10 The Transport and Access chapter of the ES has been based on the Transport Assessment (TA) prepared for the NEBGR as this included consideration of Bexhill Enterprise Park and wider BX2 allocation. The TA has been prepared in accordance with Department for
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Transport (Guidance on Transport Assessment, 2007) guidelines. This assessment has included a notional design year of 2028. Similarly, to full assess the impacts on the landscape an operational year 1 (opening year) and operational year 15 are assessed, to allow for any landscape planting to become established, such that long term effect can be identified.
5.8.11 The assessment of transport related effects (i.e. transport and access, noise and air quality) has been based on traffic data generated for the ES prepared in relation to the BHLR. The approach to the utilisation of this data is set out as appropriate within the transport and access, noise and air quality chapters of this ES, but typically ensures that a worst case, cumulative assessment has been undertaken of the NEBGR and the wider BX2 allocation in relation to the transport related effects.
Assessing Cumulative Impacts
5.8.12 To be able to satisfactorily identify and understand the impacts of the proposed development, it is essential that the assessment of effects take into consideration other nearby development that is committed or has relative certainty of delivery. As a result an assessment of likely significant cumulative effects of the Bexhill Enterprise Park, BHLR, NEBGR and wider BX2 allocation has been undertaken. The assessment of the cumulative effects of the wider BX2 allocation has been based on the information identified in planning policy as detailed proposals are not yet available.
5.9 Mitigation of Adverse Effects
5.9.1 The incorporation of mitigation measures; that is measures to avoid minimise or compensate for adverse effects, is an integral part of the design and related EIA process. A description and the significance of any potential residual effect, namely that which remains after established mitigation has been incorporated, is presented in each topic chapter.
5.9.2 Key mitigation measures that have been incorporated into the proposals as a result of the EIA are identified in Section 3.3 .
5.10 Residual Effects
5.10.1 Residual effects are the environmental effects that will remain after the incorporation of mitigation measures.
5.10.2 It is these residual effects which should be considered when assessing the significance of the proposed development, rather than the unmitigated effects as unmitigated effects will not occur. For example the development will increase the impermeable area of the site and therefore, without mitigation, would increase surface water drainage from the site. However mitigation is proposed to manage surface water drainage such that there would not be a significant residual effect.
5.10.3 To provide an objective assessment of residual effects the significance of residual effects has been determined and is identified in the ES. This allows for comparison of effects between topics and also strengthens the assessment of impact interactions.
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5.11 Uncertainty
5.11.1 The prediction of future effects inevitably involves a degree of uncertainty. Where necessary, the topic chapters describe the principal factors giving rise to uncertainty in the prediction of environmental effects and the degree of the uncertainty.
5.11.2 Confidence in predictions has been engendered by employing accepted assessment methodologies, e.g. Design Manual for Roads and Bridges and the Guidelines for Ecological Impact Assessment in the UK. Uncertainty inherent within the prediction has been described. As a general principle the ES has described credible, worst case foreseeable events and their effects.
5.11.3 Uncertainty also applies to the success or otherwise of measures to mitigate adverse environmental effects. Where the success of a mitigation measure is uncertain, where necessary the extent of the uncertainty has been identified in the ES and a suitable response identified.
5.12 Significance Criteria
5.12.1 The two principal criteria for determining significance of an environmental effect are the magnitude of the effect and the sensitivity of the receptor; in addition the likelihood of the effect occurring is also considered as appropriate. The approach to assessing and assigning significance to an environmental effect will rely upon such factors as; consideration of the EIA Regulations, guidelines, standards or codes of practice, the advice and views of statutory consultees and other interested parties, and expert judgment. The following questions are relevant in evaluating the significance of potential environmental effects:
° Which risk groups are affected and in what way?
° Is the effect reversible or irreversible?
° Does the effect occur over the short, medium or long term?
° Is the effect permanent or temporary?
° Does the effect increase or decrease with time?
° Is the effect of local, regional, national or international importance?
° Is it a positive, neutral or adverse effect?
° Are health standards or environmental objectives threatened?
° Are mitigating measures available and is it reasonable to require these?
5.12.2 Specific significance criteria will be prepared for each specialist topic, based on the generic criteria, for adverse and beneficial effects, set out in Table 5.1 .
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Table 5.1: Generic Significance Criteria
Significance Level Criteria Only adverse effects are assigned this level of importance as they represent key factors in the decision-making process. These effects are generally, but not Severe exclusively, associated with sites and features of international, national or regional importance. A change at a regional or borough scale site or feature may also enter this category. These effects are likely to be important considerations at a local or borough Major scale but, if adverse, are potential concerns to the project and may become key factors in the decision-making process. These effects, if adverse, while important at a local scale, are not likely to be key decision-making issues. Nevertheless, the cumulative effect of such issues may Moderate lead to an increase in the overall effects on a particular area or on a particular resource. These effects may be raised as local issues but are unlikely to be of importance Minor in the decision-making process. No effect or effect which is beneath the level of perception, within normal Not Significant bounds of variation or within the margin of forecasting error.
5.13 Impact Interactions
5.13.1 Chapter 16 of the ES provides the assessment of impact interactions, i.e. receptors being affected by more than one environmental effect and therefore potentially being subject to a more significant combined effect than the individual effects reported in each of the topic chapters.
5.13.2 The approach adopted to the assessment is in accordance with the methodology set out above, with further details provided in Chapter 16 .
5.13.3 Chapter 16 therefore provides an overall summary of the effects of the proposed development during construction and operation, and provides an overall judgement on the beneficial or adverse environmental effect of the development.
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6 Planning and Policy Context
6.1 Introduction
6.1.1 This chapter provides a review of the planning policy context against which the development proposals will be assessed.
6.1.2 The review considers the relevant planning policies from national to local level including statutory policies.
6.2 National Planning Policy
6.2.1 The UK planning system is a plan led approach as imbedded in Section 38 (6) of the Planning and Compulsory Purchase Act 2004. This requires planning applications to be determined in accordance with the development plan and unless material considerations indicate otherwise. Thus the planning policy context is important in assessing the current and future development potential of any site and is defined by the National Planning Policy Framework (NPPF).
6.2.2 The NPPF is a key part of the national Government reforms to make the planning system less complex and more accessible, to protect the environment and to promote sustainable growth. The NPPF document replaces virtually all previous Planning Policy Statements (PPS) and Planning Policy Guidance (PPG) thereby condensing over 1,000 pages of previous planning guidance into just over 50. The framework is designed to provide guidance on plan making and application decisions.
6.2.3 The NPPF therefore constitutes guidance which planning authorities and developers must take into account in the preparation of local and neighbourhood plans and is a material consideration in planning decisions.
6.2.4 The NPPF does not change the statutory status for the development plan as the starting point for decision making. Proposed development that accords with an up to date local plan should be approved and proposed development which conflicts should be refused unless other material considerations indicate otherwise (Paragraph 12).
6.2.5 The document identifies that the purpose of planning is to help achieve sustainable development, with ‘sustainable’ meaning ensuring that better lives for ourselves don’t mean worse lives for future generations and ‘development’ meaning growth. The key objectives within the guidance that are relevant to the current development proposals are summarised as:
° A presumption in favour of sustainable development;
° Building a strong and competitive economy;
° Promoting sustainable transport;
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° Climate change, flooding and coastal change;
° Conserve and enhance the natural environment;
° Conserve and enhance the historic environment;
° Positive decision taking; and
° Localism.
The Presumption in Favour of Sustainable Development
6.2.6 The NPPF identifies that at the heart of the planning system there is a presumption in favour of sustainable development which should be seen as the golden thread running through plan making and decision making.
6.2.7 The presumption means “decision takers at every level should approve development proposals that accord with the development plan without delay.” (Paragraph 14)
6.2.8 In the absence of an up-to-date local plan that conforms with the NPPF (or absent or silent plan), the focus should be on the test in Paragraph 14, which says that planning permission should be granted unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the NPPF.
6.2.9 The three dimensions of sustainable development that give rise to the need for the planning system to perform a number of roles are identified in Paragraph 7 as:
° An economic role: Contributing to building a strong, responsive and competitive economy by ensuring sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and co-ordinating development requirements, including the provision of infrastructure;
° A social role: Supporting strong vibrant and healthy communities providing the supply of housing required to meet the needs of the present and future generations; and by creating a high quality built environment, with accessible local services that reflect community needs and support and its health, social and cultural wellbeing; and
° An environmental role: Contributing to protecting and enhancing the natural built and historic environment and as part of this helping to improve biodiversity, use natural resources prudential, minimise waste and pollution and mitigate and adapt climate change including moving to a lower carbon economy.
6.2.10 In achieving sustainable development the NPPF sets out the core land use planning principles underpinning both plan making and decision taking. These principles set out in Paragraph 12 include: Pro-actively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made to identify and meet the housing, business
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and other developing needs of an area and respond positively to wider opportunities for growth.
Building a Strong Competitive Economy
6.2.11 The NPPF supports the growth agenda with the Government committed to securing economic growth in order to create jobs and prosperity and meet the challenges of global competition and of a low carbon agenda. The focus on economic growth has been one of the major drivers of the planning reforms in delivering an economic recovery.
6.2.12 The guidance states that “planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.” (Paragraph 19)
Promoting Sustainable Transport
6.2.13 The guidance identifies that the transport system needs to be balanced in favour of sustainable transport modes giving people a real choice about the way they travel. However the government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas (Paragraph 29).
6.2.14 In preparing local plans local authorities should therefore support a pattern of development which, where reasonable, facilitates the use of sustainable modes of travel.
6.2.15 The NPPF acknowledges that development which generates significant amounts of movement should be supported by a Transport Assessment or Statement (Paragraph 32) and a Travel Plan (Paragraph 36).
Requiring Good Design
6.2.16 It is important to plan positively for the achievement of high quality and inclusive design for all development, including individual buildings, public and private spaces and wider development schemes. Local authorities should aim to ensure that developments :
° Will function well and add to the overall quality of the area, not just for the short term but for the lifetime of the development;
° Establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit;
° Optimise the potential of the site to accommodate development;
° Respond to local character and history, and reflect the identity of local surroundings and materials;
° Create safe and accessible environments; and
° Are visually attractive as a result of good architecture and appropriate landscaping.
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Climate Change, Flooding and Coastal Change
6.2.17 The NPPF recognises that planning plays a key role in reducing greenhouse gas, emissions, minimising the impacts of climatic change and supporting the delivery of renewable and low carbon energy and associated infrastructure.
6.2.18 New development is also required to be planned to avoid increased vulnerability to a range of impacts arising from climate change (including factors such as flood risk, water supply and changes to biodiversity and landscape). New developments brought forward in areas which are vulnerable, therefore should ensure the risks can be managed through suitable adaption measures, including the planning of green infrastructure.
6.2.19 In relation to flood risk, the NPPF identifies that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk but where development is necessary, making it safe without increasing flood risk elsewhere.
6.2.20 When determining applications, local authorities should ensure that the flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where, informed by site specific flood risk assessment following the sequential test and, if required, the exception of test (Paragraph 103).
Conserve and Enhance the Natural Environment
6.2.21 The guidance sets out that the planning system should contribute to and enhance the natural and local environment by:
° Protecting and enhancing valued landscapes;
° Recognising the wider benefits of the eco-system services; and
° Minimising impact on biodiversity and providing net gains and biodiversity where possible.
6.2.22 Areas of land designated as part of the Green Belt, Sites of Special Scientific Interest, National Parks and other protected sites will not be overridden by the presumption. The NPPF contains a provision to recognise the “intrinsic character and beauty of the countryside” , whether designated or otherwise.
6.2.23 The NPPF identifies that planning policies and decisions should also ensure that any site is suitable for the new use taking into account of ground conditions and land instability, including natural hazard and mitigated accordingly.
6.2.24 Similarly, planning policies and decisions should aim to avoid noise from giving rise to significant adverse effects and mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise and new development including through the use of conditions.
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Conserving and Enhancing the Historic Environment
6.2.25 In determining applications the local planning authorities should require an applicant to describe the significance that any heritage assets affected including any contribution made to their setting. The guidance highlights that the level of detail should be proportionate to the assets importance in no more than is sufficient to understand the potential impact of the proposal on their significance (Paragraph 128).
Positive Decision Taking
6.2.26 Reflecting the pro-growth agenda, the NPPF emphasises that local planning authorities should approach decision taking in a positive way to foster the development of sustainable developments (Paragraph 186). Furthermore local planning authorities should look for solutions rather than problems and decision takers at every level should seek to approve applications for sustainable development where possible. Local Planning Authorities should work proactively with applicants to ensure developments that improve the economic, social and environmental conditions of the area (Paragraph 187).
6.2.27 Paragraph 204 sets out that planning obligations should only be sought where they meet all the following tests:
° Necessary to make the development acceptable in planning terms;
° Directly related to the development; and
° Fairly and reasonably related in scale and kind to the development.
Localism
6.2.28 The NPPF aims to strengthen local decision making and reinforce the importance of up to date plans.
6.2.29 Developers are expected to work closely with those directly affected by the proposals to take account of the views of communities. Proposals which demonstrate good engagement with the community should be looked upon more favourably (Paragraph 66).
Technical Guidance
6.2.30 In March 2012 the Government published technical guidance for the NPPF to provide additional guidance to the Local Authority to ensure the effect of implementation of planning policy in areas of risk of flooding and in relation to mineral extraction.
6.2.31 The guidance retains key elements of Planning Policy Statement 25 of the existing minerals policy statements and mineral planning guidance notes. The retention of this guidance is in an interim measure pending a wider review of guidance to support planning policy.
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6.3 Regional Planning Guidance
6.3.1 The South East Regional Spatial Strategy (RSS) provided an additional regional tier of the Development Plan for Rother. However, on 25 th March 2013 ‘The Regional Strategy for the South East (Partial Revocation) Order 2013’ came into force. This removes all regional tier policies that relate to the Rother area. The only regional policy left in place deals with residential development near the Thames Basin Heaths Special Area of Protection (NM6), as well the retention of certain saved policies of the Oxfordshire Structure Plan 2016.
6.3.2 Therefore, the NPPF and the Local Plan remain the only extant planning policy covering the Rother area.
6.4 Local Development Plans
Rother Local Plan
6.4.1 The Rother District Local Plan 2006-2011 was adopted in July 2006. The Local Plan is the statutory ‘development plan’ for Rother. All the Local Plan policies have been ‘saved’ by the Secretary of State and have, apart from Policy DS6 (Managing Housing Release), been deemed to be compliant with the NPPF by the Cabinet in July 2012.
6.4.2 Bexhill, as the largest town in the district, is identified as being the focus for much of the housing and employment growth over the plan period. Paragraph 4.36 states that “North East Bexhill is still appropriate for major growth” as it is the “least environmentally constrained and is well related to the urban fabric and to employment opportunities in Bexhill and Hastings.”
6.4.3 Policy BX1 sets out that proposals for development and change in Bexhill should help to develop its residential, employment, shopping and service centre functions. They should also provide for both the growth of local firms and appropriate inward investment, as well as significantly improving accessibility both within the town and to important employment centres.
6.4.4 Policy BX2 sets out the development parameters for the North East of Bexhill allocation. It outlines plans for a mix of housing, business and related uses. Land to the north of the development will be incorporated into a Countryside Park and remain undeveloped.
6.4.5 The 22,000m2 of employment uses on site will be offices, research and development and/or light manufacturing. The policy goes on to state that this business development will be of high quality, with “high specification, prestige buildings in prominent and ‘landmark’ locations, combined with a generous framework.”
6.4.6 No development at this location shall be occupied until the Link Road (the BHLR) and associated infrastructure is constructed and open, unless demonstrated by a Transport Assessment that the impact upon the main road network is acceptable and in accordance with an agreed phasing plan.
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6.4.7 Policy GD1 sets out the general principles that all developments must comply with. These criteria include:
° It meets the needs of future occupiers;
° It is in keeping with and does not unreasonably harm the amenities of adjoining properties;
° It provides for adequate and safe access by all relevant modes of transport and does not result in unacceptable traffic or transport conditions;
° It respects the topography, important views to and from the site and retains features that contribute to the character or amenities of the area;
° It protects habitats of ecological value and incorporates, wherever practicable, features that enhance the ecological value of the site, with particular regard to wildlife refuges or corridors, or fully compensates for any loss;
° It does not prejudice the character, appearance or setting of heritage features;
° The infrastructure and facilities necessary to serve the development are available, or suitable provision is made as part of the development;
° It provides adequate and appropriate means for foul and surface water drainage, with suitable alleviation and mitigation measures where necessary and does not prejudice water quality; and
° It takes account of flood risk and the areas of flood risk.
6.4.8 In determining whether development is appropriate to a particular location, Policy DS1 states that proposals should accord with the following principles (in summary): ° It ensures a sufficient continuing supply of employment sites and premises to foster economic regeneration;
° It ensures a good level of accessibility to a range of services and jobs by public transport;
° Best use is made of existing infrastructure, including transport, community facilities and mains drainage;
° It avoids prejudicing the character and qualities of the environment, particularly the High Weald Area of Outstanding Natural Beauty and undeveloped coastline;
° It protects sites of recognised nature conservation importance;
° It protects historic parks and gardens;
° It respects the importance of the countryside in terms of its distinct landscape character, natural resources, woodland and agriculture;
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° It protects ancient woodland from development that would prejudice its ecological and landscape value; and
° It ensures that development is safe from flooding, including by restricting development in flood risk areas and not increasing such risk elsewhere.
6.5 Other Documentation
North East Bexhill Supplementary Planning Document
6.5.1 The North East Bexhill SPD, adopted in June 2009, provides further guidance on the form and layout of development (as described in Policy BX2 of the Local Plan).
6.5.2 The landscape of the area is currently described as being north facing sloping land which is highly visible from parts of Combe Haven and the adjoining slopes of the Battle-Hastings ridge to the north. The mount contains an underground reservoir as well as a telecommunications mast. Glovers farmhouse is described as having some architectural interest and visual merit.
6.5.3 With regard to ecology, the document suggests the presence of ancient species-rich hedgerows in the area, some with specimen trees. These provide habitats for a wide range of birds, small mammals and invertebrates, as well as flight lines and feeding routes for bats. As well as bats there are other protected species, notably badgers, as well as dormice in the area.
6.5.4 The main characteristics of employment uses in the area will be the overall high quality of development. The employment allocation is described as being in a “pivotal position at the gateway to the town and adjacent to the junction with the new link road, and should therefore make a positive statement about the economic vibrancy of Bexhill.” The area is considered to be most suitable for office and clean manufacturing uses. The following principles should be observed:
° The business land should be developed as early as possible;
° The release of business land should parallel that for housing;
° Business land should be serviced;
° Plots should (through combination) allow a broad range of unit types and sizes of 200m2 up to at least 1,000m2;
° Within the overall mix of business (Class B) uses, there will be flexibility in the types of activity allowed, subject to locational factors, although the majority of floorspace should be for light industry, with a significant office element;
° Office areas should be distinct from general industrial areas;
° Development should accord with the sustainability objectives for the area;
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° The form and appearance of new development should be of a high quality, with only the highest standards allowed at the northern ‘gateway’ to the town;
° Flexibility in building design to suit a range of uses is encouraged; and
° Commercial uses benefitting from passing trade may be accommodated on primary traffic route frontages, subject to siting and design considerations.
East Sussex Economic Development Strategy (2012)
6.5.5 The vision for the Economic Development Strategy is that “by 2021, East Sussex will have a stronger, more resilient, inclusive and balanced economy, built on an expanded private sector base in a county recognised for its distinctive character and excellent connectivity.”
6.5.6 Underlying the vision are seven strategic priorities:
° Strategic Priority 1: Create the right environment to attract new businesses, retain existing ones and foster enterprise, job creation and innovation – encouraging and supporting entrepreneurship, business growth and R&D activities;
° Strategic Priority 2: Enhance the skills base – raise aspirations, help tackle worklessness and exclusion by raising aspirations, including entrepreneurship, and skills as a barrier to work/vocational progression;
° Strategic Priority 3: Improve connectivity - rail, road and broadband connectivity and speed improvements are critical for East Sussex to take advantage of its privileged location;
° Strategic Priority 4: Upgrade the provision of commercial premises – ensure workspace is sufficient, appropriate, sustainable and flexible for business needs, contributing to attracting and retaining businesses and jobs;
° Strategic Priority 5: Improve housing choice and availability;
° Strategic Priority 6: Move towards a low carbon economy; and
° Strategic Priority 7: Build the East Sussex visitor profile – its identity, and enhance the quality of offer to become a key destination for visitors.
6.5.7 The delivery of employment land along the BHLR, at the gateway to Bexhill, is identified as a key action under Priority 4.1. Priority 4.1 is aimed at identifying and supporting the appropriate development of key commercial premises, upgrades and development sites both for local growth and inward investment. As a result, it is hoped that appropriate incubator space and move on premises will be provided to allow for ‘property escalation’ to encourage business growth.
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6.6 The Changing Policy Context
Rother Core Strategy Proposed Submission Document
6.6.1 The ‘saved policies’ of the Local Plan remain part of the statutory development plan until they are replaced by relevant policies in the new local plan (2011-2028). The Core Strategy will be the key policy document within the new Local Plan. It sets out the overall vision and objectives that will guide the future pattern and form of development in the district to 2028. The Proposed Submission Core Strategy has been submitted to the Secretary of State for Examination.
6.6.2 Policy BX1 states that the overall strategy for Bexhill is, among other things, to promote the economic growth of the town, and wider area, including through encouraging growth in new and established local firms, especially in high value added sectors, prioritising development for employment purposes, increasing the supply of land and premises and promoting efficient infrastructure.
6.6.3 Policy BX3 states that employment development will contribute to the overall strategy for Bexhill through the provision of approximately 60,000m2 of new business space between 2011 and 2028. Much of this growth will be achieved on the north east fringes of Bexhill.
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7 Economic Impacts
7.1 Introduction
7.1.1 The provision of the Bexhill Enterprise Park (Bexhill Enterprise Park) is a direct response to the persistent socio-economic challenges facing the Bexhill and Hastings communities. The development of the site, situated in North East Bexhill, East Sussex, is being enabled by the construction of the Bexhill Hastings Link Road. A range of national and sub-national economic public policy objectives are currently in place which seek to address these issues and which the proposed development seeks to deliver. The development of the business park will provide new employment, and will serve the needs of local communities and wider East Sussex economy.
7.1.2 The economic effects of the Bexhill Enterprise Park have therefore been assessed in terms of direct construction-related economic effects and the operational economic effects arising from the occupation of new employment floorspace. The proposed area of study has been defined by the assumed area of impact.
7.1.3 The study area has been defined as the 2001 Travel to Work Area (TTWA) boundary for Hastings, as this area is likely to see the greatest employment effects. The TTWA area includes the towns of Hastings and Bexhill, as well as the Bexhill Enterprise Park site. To understand local area dynamics and local variations in baseline conditions, much of the baseline concentrates on two local authority areas, Hastings and Rother, which combined include the TTWA. To provide comparisons for the data, to place it in wider economic context, the baseline compares data at the local level with that of East Sussex and the UK.
7.1.4 The assessment of economic impacts has been based on the assumption that the Bexhill Enterprise Park will be entirely B1a. It is recognised that the planning application is also for B1b and B1c uses, however agent advice indicates that B1a is in the greatest demand. As a result the above represents a reasonable assumption on which to assess the likely significant effects of the proposed development.
7.2 Policy Context
7.2.1 The following national, sub-national and local economic development policy objectives are relevant to the Bexhill Enterprise Park and form the background to the development.
National Policy Recognition of the Strategic Importance of the North East Bexhill
7.2.2 The Government’s ‘Plan for Growth’ published by HM Treasury and the Department for Business Innovation and Skills (BIS) in March 2011 sets out the policy framework for delivering national economic recovery and improved competitiveness. As part of the Growth Plan the Government is promoting a more balanced and sustainable pattern of employment growth, seeking to reduce dependency on public sector employment through private sector employment growth, particularly in areas with high levels of public sector dependency, such as Hastings and Bexhill.
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7.2.3 The 2012 Budget Report confirmed the strategic national government support for economic growth in this part of the South East. It makes specific reference to the Government's intention to provide “£56m of funding support to enable the delivery of the Bexhill Hastings Link Road (BHLR), to facilitate economic regeneration in a deprived area of the South East." The development of the BHLR unlocks employment land to the north east of Bexhill; the location of the planned Bexhill Enterprise Park development. As such, the Bexhill Enterprise Park forms an important aspect of the abovementioned regeneration.
South East Local Enterprise Partnership (SELEP) Growth Agendas
Fit with SELEP Vision
7.2.4 The SELEP has been established to drive forward local economic growth in the South East, comprising three sub-areas: Kent and Medway, Greater Essex, and East Sussex. The SELEP has a mission statement to “create the most enterprising economy in England.” Within the next 20 years the LEP is aiming to have achieved the following:
° The creation of additional 250,000 - 300,000 new jobs by established and new businesses;
° All coastal and rural communities matching the prosperity of the small cities and market towns;
° Formerly deprived areas making significant progress towards becoming thriving communities; and
° Unemployment to be below the average for other prosperous regions.
7.2.5 The North East Bexhill strategic employment area has the potential to contribute towards all of the above objectives by delivering high quality workspace to enable the growth of high value employment opportunities in a priority location in the SELEP area.
Fit with SELEP Strategic Objectives and Business Plan
7.2.6 The SELEP has identified the coastal agenda as a strategic ‘cross cutting’ theme for the LEP and has defined four strategic objectives. The development at North East Bexhill is directly aligned with Objective 2 – ‘Promote Investment in our Coastal Communities’. The LEP recognises the acute levels of deprivation faced by some of its coastal communities, but also the considerable unrealised potential for significant economic growth. In 2011, the SELEP commissioned Sheffield Hallam University to undertake research into developing an evidence base to understand the dynamics of coastal communities within the LEP area. The evidence base also seeks to help SELEP identify strategic priorities for coastal communities and to inform the prioritisation of future investment and activities.
7.2.7 The LEP strategy identifies key strategic growth opportunities in low carbon technologies, creative and cultural industries, manufacturing, engineering and business services and points to North East Bexhill as an important location for investment as part of this
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opportunity. As a key aspect of this development, the Bexhill Enterprise Park will assist in stimulating growth in these key sectors.
7.2.8 In 2011, SELEP outlined its vision, strategic objectives and workstream priorities into its 2012-2015 Business Plan; which outlines SELEP's key deliverables that will be prioritised over the period. These were developed around two clear priorities; to explore and create opportunities for enterprise while addressing the barriers to growth.
7.2.9 The agreed key areas of focus would fit with the LEP’s area of focus for the coming years; particularly its area of focus that includes “Creating an Environment for Growth – creating the best possible environment for new and existing businesses to grow and flourish.”
Local Planning Policy
7.2.10 The North East Bexhill site is recognised in both Hastings and Rother economic development and planning policies as being the critical land supply which will drive economic growth in both districts. The Rother District Local Plan (2006) recognises the strategic importance of North East Bexhill as an employment area and establishes the principle of development, and the overall scale, mix and general disposition of uses.
7.2.11 The Rother District Local Plan (2006) outlines the case for new developments, stating that:
“It is a clear priority of the business community that new sites and buildings are provided as soon as possible to allow firms to expand… Allocating sufficient land for business and other employment activities is essential to develop and broaden the economic base.”
7.2.12 With specific regard to North East Bexhill, two main policy strands relating to the Bexhill Enterprise Park development were Policy BX 2 and Policy BX 3. These were developed to provide the basis for sustainable long-term growth insofar as they planned for:
“High quality business sites, with good connections to the urban area as well as to the transport network, which should meet employment and regeneration needs for the foreseeable future.”
7.2.13 To realise this ambition for Bexhill, the plan identifies some 100 hectares of land for a major urban extension to the north east of Bexhill. This is provided for through two mixed-use development allocations which seek to provide in excess of 1,100 homes (and associated local services) and some 48,000 m2 of business space. A summary of Policy BX 2 and Policy BX 3 is as follows:
° Policy BX2 relates to land south of the proposed Link Road (covering the area of land for the planned Bexhill Enterprise Park development) and allocates land for housing (and associated facilities), although also with significant provision for business land closer to the Link Road. The plan outlines that Policy BX2 should include:
- At least 980 dwellings;
- Some 22,000m2 of business floorspace; and
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- A neighbourhood centre.
° Policy BX3 relates to and north of Sidley land is allocated predominantly for employment development, with a smaller area of housing in its south-western corner. The plan outlines that Policy BX 3 should include:
- Some 26,000m2 of business floorspace;
- At least 130 dwellings; and
- Structural open spaces, landscape and woodland belts.
7.2.14 As Phase 1 of the development, the Bexhill Enterprise Park would provide 15,000m2 of business floorspace and would therefore make a major contribution to the delivery of Policy BX2.
7.2.15 Specific policy has been adopted in relation to North East Bexhill, the North East Bexhill Supplementary Planning Document (2009). This identifies the critical opportunity that this area presents to create significant job growth in Bexhill, stating that the employment land should be developed "as early as possible" , following the opening of the North East Bexhill Gateway Road (NEBGR), which will enable access to the site. This is a response to the limited supply of business sites and premises locally which is felt to be holding back not only indigenous business growth, but also inward investment opportunities.
7.2.16 Following on from the 2006 Local Plan, the Rother District Local Plan (2011-2028) is currently being prepared and as such, has not been formally adopted. The policies of the Local Plan adopted in 2006 have been 'saved' and they remain part of the statutory 'development plan'.
7.2.17 As a part of this plan, the emerging Rother Core Strategy (2013) plans for some 100,000m2 of business floorspace delivered between 2011 and 2028 (in line with the target contained in the joint Employment Strategy outlined below), of which some 60,000m2 is in Bexhill. This was reiterated in the Rother Core Strategy Position Statement: BHLR Update and Core Strategy relationship, July 2012.
7.2.18 In 2008, Rother and Hastings Borough Councils carried out a joint Employment Strategy and Land Review which highlighted the need for a ‘step change’ in economic performance, as well as a need to significantly increase the supply of business accommodation to meet pent up and future potential demand. The review concluded that 163,000m2 of business floorspace would be required within the Hastings Travel to Work Area by 2028 in order to meet employment demands over the coming years. The report concluded that an additional 100,000m2 of business floorspace would be an appropriate target to improve the balance between homes and jobs and meet economic objectives.
7.2.19 This study was updated in May 2010 with the Employment Strategy and Land Update, which reviewed the earlier Study in the context of significant changes to the wider national and global economic picture. The findings of the study concluded that the Hastings / Bexhill area remains one of areas of greatest need for regeneration, and that, in the absence of some
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previously planned significant rail or trunk road transport improvements, economic activity needs to be strongly fostered in order to achieve future prosperity. It also concludes that an increase in economic activity rates are likely, with the consequence that the previously recommended scale of business land release, of some 100,000m 2 across the district, which would support of the order of 2,500 jobs, is still broadly appropriate.
7.2.20 The future economic growth of the area is therefore heavily dependent upon the delivery of the North East Bexhill employment area, of which the Bexhill Enterprise Park forms a substantial element.
East Sussex Economic Development Strategy, April 2012
7.2.21 The East Sussex Economic Development Strategy sets the following Vision:
“By 2021, East Sussex will have a stronger, more resilient, inclusive and balanced economy, built on an expanded private sector base in a county recognised for its distinctive character and excellent connectivity.”
7.2.22 The Strategy identifies seven strategic priorities to deliver the Vision. Strategic Priorities 1 and 4 are particularly relevant to the North East Bexhill strategic employment area and the Bexhill Enterprise Park, as follows:
° Strategic Priority 1: Right environment to attract new businesses, retain existing ones and foster enterprise, job creation and innovation – The strategy recognises the need to encourage further business investment and growth, suggesting that the County should build on existing businesses whilst also encouraging higher-value added sectors which could help boost productivity in the county if further developed e.g. finance and business services, advanced manufacturing and engineering, and environmental technologies.
° Strategic Priority 4: Upgrade the provision of commercial premises – ensure workspace is sufficient, appropriate, sustainable and flexible – The strategy identifies that new space for business is key to attracting, retaining and growing businesses and jobs. It identifies the potential to explore the use of alternative / innovative funding mechanisms where there are viability issues with a development. It suggests a need to provide business appropriate incubator space and move on premises to allow for ‘property escalation’ to encourage business growth and to increase the potential for attracting higher growth and high value-add businesses to the area. In terms of a spatial focus, it points to key development sites across East Sussex, in particular Sovereign Harbour, Hastings town centre, the A21 corridor (Enviro 21), North East Bexhill (following the construction of the BHLR); Newhaven and Eastbourne / South Wealden.
7.2.23 The Strategy recognises the County’s potential for business growth but highlights that there is an insufficient supply of business premises and many of those that do exist are not appropriate to the needs of businesses. The Bexhill Enterprise Park will directly contribute to addressing this policy imperative.
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Hastings & Bexhill Economic Development and Inclusion Strategy 2008 - 2013 (Hastings & Bexhill Task Force)
7.2.24 The Strategy sets the strategic objective of creating “an inclusive, successful and sustainable economy in Hastings and Bexhill” by increasing business activity and creating employment opportunities, providing a range of local job opportunities and increasing average earnings, raising skills and aspirations and achieving and maintaining environmentally-sustainable prosperity. It recognises that Hastings is still the most deprived town in the South East and is the 29th most deprived area in the country.
7.2.25 The Strategy points to the progress being made with the development of new offices in Hastings town centre and business parks on the outskirts, including North East Bexhill. It highlights a target of one million square feet of education and commercial space. The development of the Bexhill Enterprise Park relates directly to Aim 1.1.2, which seeks to expand the provision of business accommodation, affordable and high quality premises, start-up and move-on accommodation and managed workspace.
Sea Change Sussex Business Plan 2012-2017
7.2.26 Sea Change Sussex (SCS) is the delivery vehicle for major capital development projects leading the economic regeneration and growth of Hastings, Bexhill and East Sussex. It is a not for profit company whose members include the business community, voluntary sector, local authorities and the University of Brighton. The initial focus of Sea Change Sussex has been to progress new employment-related premises and infrastructure focused on the Priory Quarter Central Business District in Hastings and strategic employment sites in Queensway (north Hastings employment area) and North East Bexhill.
7.2.27 The North East Bexhill strategic employment area is identified within the SCS Business Plan as a key flagship initiative which seeks to capitalise upon the opportunities presented by the Link Road, to provide much needed sites and premises for business growth, such as the Bexhill Enterprise Park.
7.3 Baseline Conditions
Economy
7.3.1 The population of East Sussex was 527,200 in 2011, and of these 90,200 lived in Hastings and 90,700 lived in Rother. There were 108,400 people of working age (16-64) across the two local authorities and, at 26,000, there was a significantly higher proportion of people aged over 65 1.
7.3.2 East Sussex contributed £7.5bn to the UK economy in 2011. Historically, East Sussex has lagged behind the regional and national averages; annual figures for East Sussex’s Gross Value Added (GVA) per head of the population (£14,371 in 2011) have not been above 70% of the UK average this century 2.
1 ONS, Mid-year population estimates, 2012. 2 ONS, Sub-national GVA estimates 2012, NUTS-3.
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7.3.3 This is largely due to a strong presence of low-value added sectors in the area’s sector profile, combined with a weak presence of high-value added sectors. Employment levels in high value-added sectors (Finance, IT, Other Business Services) is significantly below averages for the South East and the UK; in 2012, total employment in these combined sectors was 14.5%, which is 8.5 percentage points below UK averages and 10 percentage points below the average for the South East 3.
7.3.4 In real terms, to achieve employment levels equivalent to the UK average would require an additional 24,350 additional jobs in East Sussex in these sectors, which represents a real challenge for policy makers. The creation of grade A quality office space is an important factor for growth in these high value added sectors.
7.3.5 A low proportion of employment in these sectors means that the overall contribution to GVA is lower than the UK averages. These three sectors contributed 26.4% (£1.9bn) in 2012 to the areas overall output. A quarter of East Sussex’s output is therefore generated by a 6th of its workforce. In output terms, it is growth in these areas which will generate more value for UK PLC.
Growth Forecasts
7.3.6 Produced by Oxford Economics, the scope of the East of England Forecasting Model (EEFM) was extended in 2011 to include forecast projections for geographies outside of the East of England, including forecasts for East Sussex and its constituent authorities.
7.3.7 The model projects a net increase of 1,550 jobs in Rother between 2012 and 2020 and forecasts a small net decrease of 210 jobs in Hastings between these years. The projected fall in overall employment in Hastings is due to a projected loss of 900 jobs in the public sector over the period, in part balanced by projected growth in the private sector. Ensuring this private sector growth is realized will be critical to bolstering the labour market of both Rother and Hastings over the coming years. The Bexhill Enterprise Park can be seen as a key enabler of such growth.
7.3.8 Table 7.1 highlights those sectors which are forecast to see employment gains or losses in Hastings and Rother between 2012 and 2020. The majority of the sectors forecast for growth between the years will be in office based jobs and so accommodating this growth will require added investment in office space in Hastings and Rother, and across the county.
Table 7.1: Highest Projected Employment Gains and Losses in Hastings and Rother, 2012-2020 Hastings Rother 5 Highest Employment Gains Professional Services +490 Business Services +580 Business Services +160 Professional Services +510 Arts and Entertainment +150 Construction +340 Hotels and Restaurants +120 Retail +190 Employment Activities +90 Hotels and Restaurants +150 5 Highest Employment Losses Education -370 Education -220 Health and Care -270 Agriculture -200
3 ONS, Annual Business inquiry, employee analysis, 2012.
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Public Administration -250 Public Administration -90 Chemicals -130 General Manufacturing -70 General Manufacturing -110 Health and Care -50 Net Change -210 Net Change +1,550
Provision of Office Space
7.3.9 One of the critical issues for policy makers in East Sussex, and Hastings and Bexhill, is the quality of the available business floorspace. There is a very low percentage (between 1% and 3%) of office and industrial stock recently completed of grade A quality in East Sussex, compared to neighbouring West Sussex, where over 41% (of a larger stock size) was recently completed grade A stock. Hastings and Rother have consistently been shown to conform to the East Sussex pattern or even poorer. Major industrial sites in the area, particularly in Hastings, have continued to show a high level of occupancy (circa 90%) despite the recession and the opportunities for growing businesses to expand into larger sites are very limited. The experience of local partners and Sea Change Sussex is that new space has consistently achieved 80% occupancy within two years.
7.3.10 Since 2008, the planning authorities in Rother and Hastings have collaborated in monitoring future land requirements. The local planning authorities jointly produced, in 2008, an ‘Employment Strategy and Land Review’ and subsequently an ‘Employment Strategy and Land Review Update’ in August 2011. This study assessed future land requirements for the Hastings Travel to Work Area (TTWA, 2001), and so directly corresponds to the area of employment effects for this study.
7.3.11 The revised Hastings and Rother Employment Strategy and Land Review Update August 2011 shows the floorspace requirement to 2028 as follows.
Table 7.2: Employment Land / Floorspace Requirements in Hastings and Bexhill, 2008 – 2028
Employment Land / Floorspace Requirements 2008-2028 Rother / Hastings & Hastings Bexhill Bexhill Workforce projections (with increases in economic activity) +2,268 +3,356 +5,625 Jobs requirement (also with increases in self-sufficiency) +5,127 +6,469 +11,596 Net business floorspace requirement 67,676 m 2 68,571 m 2 136,247 m 2 Gross business floorspace requirement, with choice of 2 2 2 81,211 m 82,285 m 163,496 m sites Total 81,000 m 2 82,000 m 2 163,000 m 2
7.3.12 The need for business land supply at North East Bexhill was highlighted in the 2011 ‘Employment Strategy and Land Review Update’ Paragraph 6.38, “the Study Area will benefit from the strategic employment site proposed to the north east of Bexhill.” The development of the Bexhill Enterprise Park would meet some of the employment needs arising in Bexhill.
7.3.13 It also states:
“In terms of business completions in Rother since the previous ESLR 2008 (which presented data up to 2006/07), there has been a further 15,551 m² built in the last 4 years (2007/08- 2010/11).
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Just over 18,000m (18,138m²) of employment floorspace has been completed in Hastings in the last 4 years (2007/08-2010/11). This includes a major new office development in Hastings town centre which forms part of the Priory Quarter development.”
Employment and Occupations
7.3.14 The employment rate of East Sussex was 71.4% in 2012 which was above the average for the UK (70.9%), but both Hastings (65.6%) and Rother (67.5%) had below average employment rates4.
7.3.15 Public sector employment in East Sussex was 21.3% in 2012, below the UK average of 23.6% over the same period; but this masks differences at the local level. Hastings has a significantly higher proportion of public sector employment, at 28.9%; the only greater levels of public sector employment recorded in the South East are in Oxford and Cambridge, because of the very high level of academic employment. Conversely, equivalent figures for Rother show low levels of public sector employment at 16.0%. 16,400 people were employed in the public sector across the two local authorities in 2012. Over the coming years, public sector employment is forecast to fall and rebalancing the economy with private sector employment is a high priority of the coalition government.
7.3.16 Occupation data for East Sussex also indicates there is a shortfall in high-end occupations. At 16.0% in 2012, there is a shortfall of 3.4 percentage points for those employed in professional occupations in East Sussex, compared to averages for the UK. In real terms, to reach national levels of employment, East Sussex would require an additional 7,650 jobs in professional occupations. In contrast to this, East Sussex has a significantly higher proportion of skilled trades and caring, leisure and other services occupations; equating to 24.9% of occupations, compared to 19.6% in the UK 5. East Sussex therefore has 11,950 more people employed in these occupations compared to national levels of employment in these occupations.
7.3.17 Figure 7.1 outlines the share of occupations in East Sussex and the UK in 2012.
4 ONS, Annual Population Survey 2012. 5 ONS, Annual Population Survey, 2012.
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Figure 7.1: Occupations: Percentage Employment by Occupation, East Sussex and UK Comparisons, 2012
0 5 10 15 20
managers, directors and senior officials 10.5 10.1 16.0 professional 19.4 14.5 associate prof & tech 14.1 11.2 administrative and secretarial 10.9 13.2 skilled trades 10.6 11.7 caring, leisure and other service 9.0 sales and customer service 7.5 8.2 process, plant and machine 4.8 6.3 East Sussex elementary 10.1 UK 10.8
Source: ONS, Annual Population Survey 2012
7.3.18 Lower levels of employment in higher paid professional occupations in East Sussex, and higher levels of employment in lower paid employment in East Sussex reflects in the earnings of the area’s residents. In 2012, annual earnings in East Sussex were £23,246, a shortfall of £3,220 compared to the average UK earnings (£26,462) 6.
Unemployment and Deprivation
7.3.19 Unemployment is significantly higher in both local authorities; the unemployment rate in Hastings was 8.5% in 2012, and 10.3% in Rother, compared to an unemployment rate of 7.4% across East Sussex and 8.0% for the UK 7. For Rother and Hastings, the addition of a critical mass of business space could provide a significant boost to employment growth and reduce unemployment in the local authorities.
7.3.20 In April 2013, 9,100 people claimed Job Seekers Allowance (JSA) in East Sussex, which gives a rate of 2.9%. This was below the averages for the UK (3.8%), but the proportion of those who claimed JSA in Hastings was significantly above county and national levels at 5.3%. Indeed, Claimants in Hastings accounted for a third of all claimants across the county. 2.6% of residents claimed unemployment benefits in Rother over the period.
7.3.21 Youth unemployment has been a particular concern in recent years and in line with the national trend, youth unemployment across East Sussex has increased since the onset of recession in 2008. JSA Claimant Count data indicates that in April 2013, 25.5% of people aged between 18 and 24 were unemployed in East Sussex and 9.7% of all people aged 18 to 24 had been unemployment for at least 6 months. At local authority level, youth unemployment in Hastings (23.9%) and Rother (27.4%) is on par with figures for East Sussex and the UK 8.
6 ONS, Annual Survey of Hours and Earnings (ASHE, 2012). 7 ONS, Annual Population Survey, 2012. 8 ONS, Claimant Counts 2013, residence based analysis.
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7.3.22 The Local Economic Assessment (LEA) 9 by ESCC identified significant polarisation between the more deprived areas – particularly in coastal towns, for example in Hastings – and the rest of East Sussex, poor levels of connectivity (road, rail and broadband speed) and a heavy reliance on the public sector for employment. The LEA also highlighted that levels of deprivation are high in both Hastings and Rother, with some wards, notably in Bexhill, in the worst 5% nationally in the Index of Multiple Deprivation 10 .
7.3.23 The Cities Outlook 2012, prepared by the Centre for Cities, confirmed that Hastings ranks as the most deprived local authority in the South East and the 19th of all 326 English local authorities for local concentration of deprivation. This makes local economic underperformance comparable with recognised unemployment blackspots in the North and Wales.
Workforce Skills
7.3.24 Investment in modern employment space is not the sole intervention to achieve regeneration and economic growth in Bexhill and Hastings. The initial focus has been on improving skills and education qualifications at all levels. Higher education has been provided through the establishment of University Centre Hastings managed by the University of Brighton and which is able to accommodate over 1,000 higher education degree students since the completion of its second phase, in summer 2012.
7.3.25 ESCC has invested in a Schools Improvement Programme which has now been followed by the establishment of two new Academies, the sponsors being British Telecom, University of Brighton and ESCC. A review of Post 16 Education resulted in a multi agency investment of £100 million in a new Sussex Coast College providing a sixth form for A level students along with further education, vocational skills and apprenticeship training.
7.3.26 The current skill profile of East Sussex is similar to that of the UK, but there is a significantly lower proportion of those qualified to NVQ Level 4 or above (equivalent to a first degree). The area was 5.4 percentage points below the average for the UK, and Hastings (6.3% below) and Rother (6.4% below) were also significantly below national levels for high level skills. Rother in particular has a significantly higher proportion of those qualified to NVQ Levels 1 and 2, compared to averages elsewhere. This may represent aggregated data for those with trade apprenticeships or with no qualifications in the local authority, being added to data NVQ 1 and 2. Totals for those qualification levels in the local authority are too small to be statistically reliable and are thus unreported.
9 East Sussex Local Economic Assessment, East Sussex County Council, March 2011. 10 English Indices of Deprivation, 2010.
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Figure 7.2: Percentage of Those Un/Qualified and in Employment, 2012
45 40 35
30 25 20 15
10 5 0 Hastings Rother East Sussex UK NVQ 4+ NVQ 3 NVQ 2 NVQ 1 Trade Apprenticeships Other qualifications No qualifications
Notes: Data for Rother is suppressed as numbers of trade apprenticeships and data for those unqualified is too low to be statistically reliable. Source: ONS, Annual Population Survey 2012.
7.3.27 Given high levels of youth unemployment in Bexhill and Hastings and the lower proportion of high level skills amongst both areas workforces, the focus on improving the skill levels across the spectrum of education qualifications will allow a new generation to exploit opportunities for employment growth.
Property Market Dynamics
7.3.28 Property market analysis has provided a decade of evidence, which has identified key constraints that have been holding back economic growth, including the size of the employment space stock, its quality and levels of occupancy.
7.3.29 The low level of business space provision in East Sussex was identified by a comparison with West Sussex in 2007 in the ‘Priority Sites Strategy’ report for East Sussex Economic Partnership. This benchmarking report revealed 3,184,000m² of industrial floorspace in West Sussex compared to 1,638,000m² of industrial floorspace in East Sussex, whereas both have a broadly comparable population size of c.500,000. The size of the industrial stock in Hastings in 2011 was 191,000m² and the warehouse stock was 114,000m². The total Hastings office stock (of units over 500m²) is 53,000m² including recently completed space. Only 3,875m² of the older space is unlet and 1,175m² of the modern space is unlet (identified in a November 2011 report to East Sussex Energy, Infrastructure and Development (ESEID) by Dyer and Hobbis, Cluttons and DTZ).
The Site and Proposed Employment Uses
7.3.30 At present the site at proposed for development for the Bexhill Enterprise Park is in agricultural use. The economic impact of this existing activity is negligible in employment terms. Thus, the proposals to introduce commercial development onto the site will not displace any significant existing employment use. In considering the economic effect of the
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proposed development, all impacts can be considered as net additional over and above any existing economic contribution made by the site.
7.4 Assessment of Construction Effects
7.4.1 The principal economic impacts arising from the construction of the Bexhill Enterprise Park will be in terms of local employment effects in the construction sector. The assessment of employment effects is based on established labour co-efficients for construction activity relating to infrastructure (expressed as construction job years per £m of construction expenditure, including supply-chain – OffPAT/DCLG 2009), which are applied to capital expenditure estimates for the proposed works. The estimated employment effects arising from construction activity for the Bexhill Enterprise Park is set out below:
Table 7.3: Estimated Employment Effects from Construction Labour Co -Efficient Job Years and Full (Job Years per £m Time Equivalents Construction Activity Cost Estimate (£m) Construction) – (Based on 10 Job Source: OffPAT / Years per FTE) DCLG 2009 Bexhill Enterprise Park 30.0 14.8 444 (45 FTE) construction
7.4.2 It is therefore estimated that the construction of the Bexhill Enterprise Park will generate up to 45 full time equivalent (FTE) jobs, many of which could be taken by local residents.
7.5 Assessment of Operational Effects
Employment Effects
7.5.1 The principal economic impacts arising from the operation of the Bexhill Enterprise Park is the creation of commercial floorspace, providing incentives for businesses taking up occupation and creating new employment.
7.5.2 The Bexhill Enterprise Park will create 15,000m2 of allocated employment floorspace, assumed for the purposes of this assessment to be B1a office use. The assessment of gross operational employment effects is based on established floorspace per job benchmarks (produced by the Homes & Communities Agency, 2010) for the employment uses anticipated to occupy the allocated development. Net additional jobs impact is derived by making adjustments to reflect the fact that some jobs will be relocations from within the local economy (displacement effects) and some jobs will be taken by people living outside of the Bexhill and Hastings local area (leakage effects). A prudent adjustment of 25% has been made for displacement and leakage effects. The estimated employment effects arising from the new commercial floorspace is set out below:
Table 7.4: Estimated Employment Effects from New Commercial Floorspace Floorspace by Use Floorspace per FTE Class (Gross Internal Job Benchmark Gross Jobs Estimate Net Jobs Estimate Area) (Source: HCA) B1a – 15,000 m 2 10 m 2 GIA per job 1,500 1,125
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7.5.3 Estimated economic impact from operational effects is therefore 1,500 gross (1,125 net) FTE jobs. In addition, the new jobs will generate downstream employment effects through the indirect and induced effects of additional wages and supply-chain impacts (multiplier effects). Allowing for a prudent multiplier of 1.4, the overall operational employment effect is estimated to be in the order of 1,575 net additional FTE jobs.
GVA Effects
7.5.4 As the allocated employment floorspace is occupied the new jobs will generate additional value in the local economy, measured by Gross Value Added (GVA). Based on data from the East Sussex Local Economic Assessment, annual GVA per job for service sector activities occupying the B1a office space is estimated to be in the order of £50,000 per job. On this basis the annual GVA for the local economy generated by the allocated net additional employment (presuming full occupation) will be as follows:
Table 7.5: Annual GVA for Local Economy Generated by Net Additional Employment Net Additional Jobs Estimated GVA per Job Total Annual GVA Impact (Excluding Multiplier Effects) B1a (service sector) 1,125 £50,000 £56.3m
7.5.5 The estimated total annual GVA impact of the jobs generated by the Bexhill Enterprise Park is £56.3m. The timing of this impact is subject to the delivery profile of the Bexhill Enterprise Park development. For the above assessment, we have assumed full occupancy of the Bexhill Enterprise Park.
7.6 Assessment of Cumulative Effects
7.6.1 Cumulative impacts arise from the result of the combined impacts of multiple developments. The Bexhill Enterprise Park is one part of the wider development at North East Bexhill outlined in Policy BX 2 and Policy BX 3 of the Local Plan (2006). As well as the Bexhill Enterprise Park, the following developments are also planned:
° Bexhill to Hastings Link Road;
° North East Bexhill Gateway Road;
° A further 33,000m2 of employment floorspace, giving a total of 48,000m2;
° 1,110 dwellings;
° A neighbourhood centre; and
° Open spaces, landscapes and woodland belt.
7.6.2 As with the operational impact of the first phase of Bexhill Enterprise Park of 15,000m2, the assessment of cumulative operational employment effects for the wider development including the total of 48,000m2 of employment space is based on established floorspace per job benchmarks for the employment uses anticipated to occupy the development. Net additional jobs impact is derived by making adjustments to reflect the fact that some jobs will
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be relocations from within the local economy (displacement effects) and some jobs will be taken by people living outside of the Hastings Travel to Work Area (leakage effects). A prudent adjustment of 25% has been made for displacement and leakage effects. The estimated operational employment effects arising from the total new employment floorspace proposed at North East Bexhill is set out below:
Table 7.6: Estimated Operational Employment Effects Arising from New Employment Floorspace Use C lass Floorspace Floorspace per FTE Gross Jobs (Gross Net Jobs Estimate (sqm) Job Benchmark Estimate Internal Area) B1a office use 24,000m2 10m2 GIA per job 2,400 1,800 B1c light industrial use; and 14,400m2 48m2 GIA per job 11 300 225 B2 general industrial use
B8 storage 2 2 9,600m 70m GEA per job 137 103 use
Total 48,000m2 2,837 2,128
7.6.3 In addition, the construction activity associated with the new commercial floorspace will generate further employment effects. The assessment of employment effects is based on established labour co-efficients for construction activity (expressed as construction job years per £m of construction expenditure) relating to buildings, which are applied to capital expenditure estimates for the proposed works. The estimated employment effects arising from construction activity for the commercial floorspace for B1a development is set out below:
Table 7.7: Estimated Employment Effects Arising from Construction Activity Labour Co -Efficient Job Years and Full (Job Years per £m 12 Time Equivalents Construction Activity Cost Estimate (£m) Construction) – (Based on 10 Job Source: OffPAT / Years per FTE) DCLG 2009 Floorspace construction 79.0 17.6 1,390 (139 FTE)
7.6.4 Estimated economic impact from cumulative operational effects of the wider employment development at North East Bexhill is therefore 2,837 gross (2,128 net) FTE jobs plus 139 FTE construction jobs. In addition, the new cumulative operational jobs will generate downstream employment effects through the indirect and induced effects of additional wages and supply-chain impacts (multiplier effects). Allowing for a prudent multiplier of 1.4, the operational employment effect is estimated to be in the order of 2,980 net additional FTE jobs, plus 195 FTE construction jobs, a total of 3,175 FTE jobs overall.
11 Blended ratio based on HCA guidance for B1c light industrial and B2 general industry 12 Based on estimated construction costs of £2,200 per sqm for B1 and £1,100 per sqm for B2/B8
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7.7 Summary
7.7.1 The Bexhill Enterprise Park will generate substantial economic benefits through direct construction jobs and, most significantly, by delivering commercial development capacity which will attract firms to locate and grow in North East Bexhill. The development of the Bexhill Enterprise Park, as part of the wider development at North East Bexhill, will create major new employment opportunities for the Hastings and Bexhill communities.
7.7.2 The economic case for new employment growth in this location is supported in economic development terms by the Government, the South East Local Enterprise Partnership, East Sussex County Council and local agencies. As a part of a wider development plan, the Bexhill Enterprise Park will therefore make an important contribution to the delivery of established economic and regeneration policy.
7.7.3 Hastings and Bexhill are recognised priorities for economic development and regeneration, given persistent under-performance on a range of socio-economic indicators. However, business growth and associated new employment opportunities are currently constrained by a demonstrable shortage of development land and commercial floorspace capable of meeting identified levels of demand. By delivering 15,000m2 of new floorspace, the Bexhill Enterprise Park has the potential to have a major impact on local economic growth prospects and the delivery of new local employment.
7.7.4 Once operational, the estimated economic impact of the Bexhill Enterprise Park will be the creation of 1,500 gross (1,125 net) full time equivalent (FTE) jobs and a similar level through downstream multiplier effects and major consequential impacts in terms of additional GVA, which will strengthen local economic competitiveness. The Bexhill Enterprise Park forms an important part of the wider development at North East Bexhill which could support over 3,000 net additional FTE jobs (operational and construction), and deliver a substantial boost to the local economy.
7.7.5 Overall, the economic impact of the project is considered to be major and beneficial given the scale of employment generation and the important role of North East Bexhill in supporting both local and sub-regional economic growth.
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7.8 References
South East Local Enterprise Partnership – Economic Vision
‘Plan for Growth’ - HM Treasury and BIS March 2011
East Sussex Economic Development Strategy, April 2012
Rother District Local Plan, 2006
Rother Core Strategy, 2013
Rother Core Strategy Position Statement: BHLR Update and Core Strategy relationship, July 2012
North East Bexhill Supplementary Planning Document, 2009
Hastings & Bexhill Economic Development and Inclusion Strategy 2008 -2013
Sea Change Sussex Business Plan 2012-2017
Hastings and Rother Employment Strategy and Land Review Update - August 2011
Construction sector labour coefficients – OffPAT / DCLG 2009
Employment Densities Guide – Homes & Communities Agency – 2010
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8 Transport and Access
8.1 Introduction
8.1.1 This chapter considers the likely effects of the Bexhill Enterprise Park (Bexhill Enterprise Park) with respect to transport and access. It summarises the technical work that has been undertaken to assess the environmental effects of the development related to transport and access.
8.2 Policy Context
National Planning Policy Framework
8.2.1 Section 4 of the NPPF (2012) sets policies on providing sustainable transport as part of developments.
8.2.2 NPPF advises in paragraph 32 that: “All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment” and that “development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.”
East Sussex Local Transport Plan 3
8.2.3 The East Sussex Local Transport Plan 3 was adopted in 2011 and sets out the County Council’s vision and objectives up to 2026.
8.2.4 One specific transport objective includes the following:
° Improve access to jobs, services and leisure.
Rother District Local Plan Saved Policies
8.2.5 The Rother District Local Plan (2006) identifies the need for sustainable transport provision to serve new developments, stating:
° “It is recognised that the amount of new development that takes place in any year is small in comparison to the scale of existing development. It is important, therefore that the measures required of new development are properly integrated with those measures being undertaken to promote sustainable transport generally.”
North East Bexhill Supplementary Planning Document (SPD)
8.2.6 The ‘Access and Movement’ chapter of the SPD (2009) identifies the following within the over-arching accessibility principles for development:
° “Occupation of development – residential and business – will be tied to the opening of the Bexhill to Hastings Link Road (BHLR)” ; and
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° The existing public rights of way network should be retained and enhanced to meet additional demands.
8.3 Methodology
Scoping and Consultation
8.3.1 PBA has undertaken discussions with RDC and ESCC with regard to the development of the Bexhill Enterprise Park. This process has involved meetings and dialogue over a number of months to agree the scope and methodology.
8.3.2 The agreed methodology includes for the extant development of the BHLR and takes into account the North East Bexhill Gateway Road (NEBGR) as part of the baseline for the assessment. During discussions regarding the methodology for the Bexhill Enterprise Park application, it has been agreed that the Transport Assessment Report (TAR) submitted for the NEBGR would also be submitted in support of the Bexhill Enterprise Park proposals. This is because the TAR, as well as the design of the NEBGR, takes into consideration the Bexhill Enterprise Park development as part of the BX2 policy allocation site.
8.3.3 As a result this chapter of the ES has been based on the TAR that has previously been prepared, but is specifically focused on the likely significant transport and access effects of the Bexhill Enterprise Park. This chapter therefore utilises traffic data generated by the TAR, but it should be recognised that the TAR considers the impact of all BX2 and BX3 policy allocation developments together. It has therefore been necessary to calculate within this ES the trips generated by the Bexhill Enterprise Park site in isolation from the wider allocation. The methodology adopted for this is set out below.
Baseline Data Collection
8.3.4 Traffic data has been provided by Mott MacDonald (the transport consultant appointed to undertake the strategic modelling as part of the BHLR study undertaken over recent years) for the BHLR and the proposed junction with the NEBGR, and for the proposed junction between the NEBGR and Wrestwood Road.
8.3.5 The traffic flows provided represent a 2028 ‘base case’ scenario and a 2028 ‘with development’ scenario. As the BHLR is an extant development, and the NEBGR is subject to a planning application, these form part of the baseline for this assessment. The flows received have been provided from the BHLR study undertaken by Mott MacDonald in 2009, which have therefore been tested and agreed in public.
Construction Assessment
8.3.6 The assessment of the environmental effects of the traffic associated with the construction has been based on an estimation of construction traffic. The estimation of construction traffic has been undertaken by PBA based on PBA’s experience of comparable developments.
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Completed Development Assessment
8.3.7 The analysis within this transport chapter has been prepared in accordance with the ‘Guidelines for the Environmental Assessment of Road Traffic’ (Institute of Environmental Assessment, 1993), based upon information from the TAR.
8.3.8 The following junctions have been identified for assessment in liaison with RDC and ESCC:
° NEBGR / BHLR;
° NEBGR / Wrestwood Road; and
° Access junctions on the NEBGR (including the roundabout providing access to the Bexhill Enterprise Park).
Significance Criteria
8.3.9 The methodology and transport significance criteria utilised in this chapter reflects that contained within the ‘Guidelines for Environmental Assessment of Road Traffic’ (Institute of Environmental Assessment, 1993). In accordance with the Guidelines, consideration has been given to effects in relation to severance, fear and intimidation, driver delay, pedestrian and cyclist delay and pedestrian and cyclist amenity. The approach to assigning significance in relation to each of these effects is outlined below.
8.3.10 The significance criteria adopted for potential transport and access effects is based on the magnitude (or scale) of the change as well as the sensitivity (or importance) of the receptor affected.
8.3.11 Categories of receptor sensitivity have been defined from the principles set out in the ‘Guidelines for the Environmental Assessment of Road Traffic’ (Institute of Environmental Assessment, 1993).
8.3.12 High sensitivity receptors include:
° Schools, colleges and other educational institutions;
° Retirement/care homes for the elderly or infirm;
° Roads with no footway that may be used by pedestrians; and
° Accident black spots.
8.3.13 Medium sensitivity receptors include:
° Hospitals, surgeries and clinics;
° Parks and recreation areas;
° Shopping areas; and
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° Roads with narrow footway that may be used by pedestrians.
8.3.14 Low sensitivity receptors include:
° Open spaces;
° Roads with wide footways;
° Tourist/visitor attractions;
° Historical buildings; and
° Churches and other places of worship.
8.3.15 Although not specifically identified within the guidelines as being sensitive for these categories it has been assumed that residential areas have ‘medium’ sensitivity.
8.3.16 Severance – The measurement for assessing severance is difficult to predict as “the correlation between the extent of severance and the physical barrier of a road is not clear and there are no predictive formulae which give simple relationships between traffic factors and levels of severance.” (‘Guidelines for the Environmental Assessment of Road Traffic’ , 1993) However, a range of indicators set out by Guidelines can be used to determine the significance of severance effects. These indicators have therefore been used to assist in determining severance as set out in Table 8.1 below and are based on the change in total traffic flow with consideration also given to the provision of crossing facilities, junction layouts and methods of control.
Table 8.1: Indicators for the Significant Relief from Severance Indicator Change in Traffic Flow Negligible < 30% Slight 30% - 60% Moderate 60% - 90% Substantial > 90%
8.3.17 Fear and Intimidation – For the assessment of fear and intimidation the thresholds summarised in Table 8.2 below have been adopted. The thresholds are based upon the conclusions of the 1981 study by Crompton and Gilbert entitled ‘Pedestrian Delays, Annoyance and Risk’ .
Table 8.2: Fear and Intimidation Thresholds Degree of Average Traffic Flow Over 18 Total 18 Hour HGV Average Speed Over 18 Hazard Speed Hour Day Vehicles / Hour Flow Hour Day Miles / Hour Extreme 1800+ 3000+ 20+ Great 1200 - 1800 2000 - 3000 15 - 20 Moderate 600 - 1200 1000 - 2000 10 - 15
8.3.18 Driver Delay – The assessment of driver delay has been based upon junction capacity assessments (as junctions rather than the roads themselves are the typical cause of delays) using appropriate junction modelling software – Junctions 8 and LinSig. Junctions 8 is a computer modelling programme that allows the performance of priority roundabouts and
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priority junctions to be assessed, whilst LinSig is a computer modelling program that allows the performance of signalised junctions to be assessed.
8.3.19 Where the junction capacity results show the junction is anticipated to operate within capacity during the ‘With Development’ scenario, the impact of driver delay has been classed as ‘negligible’. Where the junction capacity results show the junction is anticipated to operate over capacity during both the ‘2028 Base’ and ‘2028 With Development’ scenarios, the impact of driver delay has been classed as ‘minor’. Where the junction capacity results show the junction is anticipated to operate within capacity during the ‘2028 Base’ scenario, but over capacity during the ‘2028 With Development’ scenario, the impact of driver delay has been classed as ‘Major’.
8.3.20 Pedestrian and Cyclist Delay – It is advised in the guidance that assessors use professional judgement to determine whether there is a significant impact to pedestrian delay. The guidance highlights changes in the volume, composition or speed of traffic may affect the ability of people to cross roads and use public rights of way.
8.3.21 Pedestrian and Cyclist Amenity – This topic is described in the guidance as ‘relative pleasantness of a journey’. The guidelines suggest that the significance of changes in pedestrian and cyclist amenity would be where the traffic flow (or its lorry component) is halved or doubled. Consideration has also been given the wider amenity considerations (e.g. the attractiveness of the route).
8.3.22 The magnitude of effects and receptor sensitivity has been compared to estimate the significance of the effect. As there are no published standard criteria, Table 8.3 below includes a range of criteria to allow the specific characteristics of each effect to be considered on an individual basis based on professional judgement.
Table 8.3: Significance Criteria Sensitivity of Receptor Magnitude High Medium Low Major Major Major / Moderate Moderate Moderate Major / Moderate Moderate Minor Minor Moderate Minor Minor / Not Significant Negligible Minor Minor / Not Significant Not Significant
8.4 Baseline Conditions
8.4.1 The following describes the existing transport and access situation at and within the vicinity of the site, including the extant BHLR and the NEBGR.
Walking and Cycling
8.4.2 There is an existing footpath which passes through the site. This provides a link east towards Hasting and west towards Sidley.
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Public Transport – Bus
8.4.3 Currently the nearest bus stop to the site is provided on the A269 Hollier’s Hill approximately 800m west of the site. This stop provides access to seven bus services serving Bexhill, Eastbourne, Sidley, Little Common and Hastings.
Public Transport – Rail
8.4.4 The nearest rail station to the site is Bexhill rail station, located approximately 2.1km south of the site.
8.4.5 This rail station is located on the East Coastway Line and provides services to London, Brighton and Ashford International, which provides links to London via the High Speed services operated by South Eastern Railways.
Highway Network
8.4.6 The extant BHLR will take the form of a single carriageway road with one lane in either direction and be subject to a speed limit varying from 40mph to the National Speed Limit. The road will run along the line of the disused rail cutting from the A259 within Bexhill, north east across existing open fields towards Hastings. The BHLR will therefore be aligned with existing residential dwellings and recreational facilities between the A259 and Glovers Lane to the north east. Once beyond Glovers Lane the BHLR crosses existing open space before connecting onto the B2092 Crowhurst Road on the outskirts of Hastings.
8.4.7 The northern section of the extant NEBGR provides an approximate carriageway width of 7.3m as per Table 1 of the ESCC Design Standards for Industrial Roads and has been designed to serve the northernmost commercial development areas, including the Bexhill Enterprise Park. The remaining section of the NEBGR from the internal roundabout southwards to the junction with Wrestwood Road will be provided at an approximate width of 5.5m to serve the remainder of the policy development lands. The alignment of the NEBGR follows the curved alignment set out in the SPD as far as is practically possible. It is proposed that the route will be subject to a 30mph speed limit.
8.4.8 Wrestwood Road is a single carriageway road with one lane in either direction and is subject to a 30mph speed limit. Wrestwood Road is predominantly fronted by residential dwellings on both sides of the carriageway but is also fronted by St. Mary’s School, located on the southern side of the road. Wrestwood Road is also fronted by an area of open space opposite St. Mary’s School comprised of open fields and farmland.
Receptors
8.4.9 The receptors that have been identified adjacent to the proposed site are summarised below in Table 8.4 .
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Table 8.4: Receptors adjacent to Bexhill Enterprise Park Link No. Link Name Receptor Sensitivity of receptor 1 BHLR Residential Medium Recreational Facilities Medium School Low Open Space High 2 Wrestwood Road Residential Medium School High Open Space Low
8.4.10 The receptors associated the with the BHLR are as follows:
° BHLR:
- Residential: Residential units adjacent to the proposed alignment of the BHLR including those on Glovers Lane, Stevens Close, Meadow Crescent, St. James’ Avenue, St. James’ Crescent and St James’ Road;
- Recreational facilities: Sidley sport club;
- School: Sidley Community and Nursery School; and
- Open Space: Farmland and public footpaths on lands adjacent to the proposed BHLR alignment and Bexhill Enterprise Park site.
° Wrestwood Road:
- Residential: Residential units located alongside Wrestwood Road;
- School: St Marys School; and
- Open Space: Farmland to the north of Wrestwood Road.
8.5 Assessment and Mitigation of Construction Effects
8.5.1 Given the scale of development proposed at the Bexhill Enterprise Park, it is considered that the operation of the Bexhill Enterprise Park will generate more trips than the construction phase of the development. It is considered that the peak arrival and departure profile of the Bexhill Enterprise Park will represent a worst case scenario in comparison to the profile of construction trips.
8.5.2 It is noted that this assessment is only an estimation of the likely construction movements based on information currently available. A Construction Environmental Management Plan (CEMP) will also be prepared, and secured through a suitable planning condition, setting out the measures to be adopted to minimise the environmental effects of construction.
8.5.3 Severance – The construction of the development will cause some temporary severance to the existing footpath crossing the site as some diversions would be necessary, although the route will be maintained. On the basis of these diversions and that the footpath will be located in close proximity to construction works it is anticipated that there will be a minor
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adverse effect on the open space adjacent to the proposed BHLR in relation to severance during construction. The junction between the NEBGR and Wrestwood Road has been designed to accommodate pedestrian facilities through the signal controls so these would not be adversely affected. This receptor is of medium importance and therefore has a minor magnitude of change.
8.5.4 Fear and Intimidation – The level of construction traffic is considered to represent fewer vehicle trips than the resulting trip generation associated with the Bexhill Enterprise Park. However traffic will be introduced, including heavy vehicles transporting materials, to the area and the construction activities will be undertaken in close proximity to the existing footpath. The anticipated effect is therefore a minor magnitude of change on the open space receptor associated with the BHLR due to the impact on local open space and footpaths.
8.5.5 Driver Delay – The level of construction traffic is considered to represent fewer vehicle trips than the resulting trip generation associated with the Bexhill Enterprise Park. It is therefore considered that the construction traffic would have a minor effect on the school receptors due to the importance of the receptor and the negligible magnitude of the effect. The Bexhill Enterprise Park is considered to have a not significant impact on driver delay associated with the residential areas or recreational facilities due to the negligible magnitude of the traffic and the minor importance of the receptors
8.5.6 Pedestrian and Cyclist Delay – With the diversion of the public footpath through the Bexhill Enterprise Park site during construction it is possible that journey times would be slightly extended for pedestrians utilising the public footpath, though significant delay would not be incurred and it is considered that the public footpath is used for social walk rather than commuting. With the level of construction traffic considered to represent fewer vehicle trips than the resulting trip generation associated with the Bexhill Enterprise Park, it is considered that the construction traffic would have a not significant impact on pedestrian and cyclist delay.
8.5.7 Pedestrian and Cyclist Amenity – Construction activities will be undertaken in close proximity to the existing footpath and will also use the BHLR to access the Bexhill Enterprise Park site. Due to the lower number of vehicles predicted than during the operation of the Bexhill Enterprise Park, it is considered that the impact on the residential, recreational and school receptors would be not significant. It is considered however that due to the impact on the local footpath a minor adverse effect is anticipated on the open space receptors associated with the BHLR due to the importance of the footpath.
8.6 Assessment and Mitigation of Operation Effects
8.6.1 The assessment and mitigation of the operational effects of the Bexhill Enterprise Park is based around a trip generation exercise for the proposals based on the following development quantum:
° 15,000m² B1a Office.
8.6.2 For the purposes of this ES chapter and the TAR a development quantum of B1a has been assumed as this is the higher generating land use in comparison to B1b or B1c. This
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therefore represents a conservative and robust assessment case in terms of the transport effects.
Trip Generation
8.6.3 The trip generation calculations undertaken for the Bexhill Enterprise Park has been based on trip rates received from Mott MacDonald as these were used for the BHLR assessment and have therefore been tested and agreed in public. These trip rates are identified in Table 8.5 below:
Table 8.5: Trip Generation Rates AM and PM Peak Hours AM (08:00 - 09:00) PM (17:00 -18:00) Land Use In Out 2-Way In Out 2-Way B1 Office (per 100 m 2) 1.44 0.11 1.51 0.12 1.09 1.21
8.6.4 To understand the impact of the Bexhill Enterprise Park on severance and fear and intimidation, it has also been necessary to calculate the 18 hour and 24 hour trip generation from the site. These trip rates are identified in Table 8.6 below:
Table 8.6: Trip Generation Rates 18 and 24 Hours 18 Hour (06:00 - 24 :00) 24 Hour (00:00 -24:00) Land Use In Out 2-Way In Out 2-Way B1 Office (per 100 m 2) 4.54 5.06 9.60 4.56 5.19 9.75
8.6.5 The above trip rates have been combined with the development quanta set out above to provide the total trip generation for Bexhill Enterprise Park site. The trip generation totals for the Bexhill Enterprise Park site is displayed in Tables 8.7 and 8.8 below.
Table 8.7: Trip Generation Bexhill Enterprise Park Peak Hours AM (08:00 - 09:00) PM (17:00 -18:00) Land Use In Out 2-Way In Out 2-Way B1 Office 210 17 227 18 164 182
Table 8.8: Trip Generation 18 and 24 Hours 18 Hour (06:00 - 24:00) 24 Hour (00:00 -24:00) Land Use In Out 2-Way In Out 2-Way B1 Office (per 100 m 2) 681 759 1440 684 779 1463
8.6.6 Severance – The Bexhill Enterprise Park will add trips to the NEBGR, approximately 1,463, across a 24 hour period as set out in Table 8.8 above. This represents an increase of 50% in comparison to the traffic flows received from Mott MacDonald on the NEBGR, an increase of 2% on the BHLR and an increase of 6% on Wrestwood Road. The Bexhill Enterprise Park therefore represents a minor adverse impact on the open spaces and footpaths adjacent to the BHLR and Wrestwood Road due to the level of change in traffic flow and the importance of the receptors considered medium.
8.6.7 However, the NEBGR is designed to accommodate the traffic predicted from the Bexhill Enterprise Park and also associated with the remaining BX2 and BX3 policy allocation lands.
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The baseline assessment of the NEBGR includes only for diverted traffic using the new link and therefore doesn’t provide a realistic baseline for this assessment.
8.6.8 The effect of the Bexhill Enterprise Park on the severance of the public footpaths and open space will therefore be mitigated through the design of the NEBGR. The speed limit of 30 mph has been proposed to allow pedestrian and cyclists to cross the NEBGR safely, reducing severance. The 2028 ‘baseline’ flows and trip generation data is provided in Appendix C.1 . As a result the effect of the Bexhill Enterprise Park in relation to severance of the open space is considered to be minor adverse due to the medium importance of the receptor and the low levels of traffic and therefore magnitude of the effect.
8.6.9 The effects on the schools and residential areas adjacent to both the BHLR and Wrestwood Road are considered minor for the schools and not significant for the residential areas due to the low level of change in traffic and therefore negligible magnitude of the effect. This is considerate of the provision of pedestrian crossing points along the NEBGR and at the junction between the NEBGR and Wrestwood Road to the south.
8.6.10 Fear and Intimidation – The methodology used to assess the effect of the proposed development on the fear and intimidation criteria is the same as that used for assessing Severance above.
8.6.11 Table 8.8 above shows that the predicted increase in traffic resulting from the Bexhill enterprise Park is approximately 1,463 vehicles across a 24 hour period. This represents an increase of 50% in comparison to the traffic flows received from Mott MacDonald on the NEBGR. Consideration has been given to the provision of pedestrian facilities on the NEBGR and Wrestwood Road which provides a dedicated phase for pedestrians.
8.6.12 The Bexhill Enterprise Park will also generate an increase in vehicles of 2% on the BHLR and 6% on Wrestwood Road. The Bexhill Enterprise Park therefore represents a minor adverse impact on the open spaces and footpaths adjacent to the BHLR and Wrestwood Road due to the level of change in traffic flow and the importance of the receptors considered to be medium.
8.6.13 The design of the NEBGR takes into consideration the potential the traffic generated by the Bexhill Enterprise Park along with traffic associated with the remaining BX2 and BX3 policy allocation lands. The baseline assessment of the NEBGR includes only for diverted traffic using the new link and therefore doesn’t provide a realistic baseline for this assessment.
8.6.14 The effect of the Bexhill Enterprise Park on the fear and intimidation of the public footpaths and open space will therefore be mitigated through the design of the NEBGR. The speed limit of 30mph has been proposed to allow pedestrian and cyclists to cross the NEBGR safely, reducing fear and intimidation. The 2028 ‘baseline’ flows and trip generation data is provided in Appendix C.1 .
8.6.15 As a result the effect of the Bexhill Enterprise Park in relation to fear and intimidation on the open spaces is considered to be minor adverse due to the medium importance of the receptor and the low levels of traffic and therefore magnitude of the effect. The effect on the schools is considered minor due to the high importance but low magnitude of the effect. The
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effect on the residential areas is considered not significant due to the medium importance of the receptor and the negligible magnitude of the impact.
8.6.16 Driver Delay –The junction capacity results for the BHLR / NEBGR roundabout identify that the junction will operate within capacity during the 2028 ‘with development’ scenario for both AM and PM peak periods. The impact on driver delay is therefore considered to be not significant for the residential and recreational receptors, but a minor effect on the schools.
8.6.17 The junction capacity results for the NEBGR / Wrestwood Road junction also predict that the junction will operate within capacity during the 2028 ‘with development’ scenario for both AM and PM peak periods. The impact on driver delay is therefore considered to be not significant for the residential and recreational receptors, but a minor effect on the schools.
8.6.18 The junction capacity results for the Bexhill Enterprise Park site access junction predict that the junction will operate within capacity during the 2028 ‘with development’ scenario for both AM and PM peak periods. The impact on driver delay is considered to be not significant for the residential and recreational receptors, but a minor effect on the schools.
8.6.19 In terms of the remaining simple priority junctions located along the length of the NEBGR to serve the BX2 allocation lands, all are predicted to operate within capacity during the 2028 ‘with development’ scenario. This impact on driver delay is therefore considered not significant for the residential and recreational receptors, but a minor effect on the schools.
8.6.20 The consideration of all not significant effects on the residential receptors and the recreational facilities is based on the medium importance of the receptors and the negligible magnitude of the effect.
8.6.21 The design of the NEBGR, including the associated junctions, has been provided to keep driver delay to a minimum. The junctions have been designed to provide adequate capacity to serve the potential developments of BX2 and BX3 policy lands.
8.6.22 The provision of the NEGBR and associated junctions will provide mitigation to driver delays by increasing accessibility to the BHLR. This is likely to decrease congestion on unsuitable local roads, reducing driver delays on the wider highway network.
8.6.23 Pedestrian and Cyclist Delay – The provision of crossing points along the NEBGR will help to minimise pedestrian and cyclist delays as a result of the development. The increase in traffic resulting from the Bexhill Enterprise Park development will cause some delays to cyclists and pedestrians as vehicle flows increase.
8.6.24 The Bexhill Enterprise Park has been designed to encourage pedestrian and cycle movements, with routes to be provided through the site connecting the existing footpath with the route to be provided adjacent to the NEBGR. As a result there will be better local pedestrian and cyclist connectivity and therefore there is a not significant effect in relation pedestrian and cyclist delay with a medium importance considered for the open space receptor and a minor change in magnitude.
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8.6.25 Pedestrian and Cyclist Amenity – The Bexhill Enterprise Park will change the amenity of the site area for pedestrians and cyclists due to the introduction of new footways and cycle ways on the site. The Bexhill Enterprise Park will therefore improve accessibility for both pedestrians and cyclists to local employment. It is therefore considered that the overall effect of the development on pedestrian and cyclist amenity is not significant with a low magnitude of effect on the medium sensitivity of the open space receptor.
8.7 Summary of Residual Effects
8.7.1 The residual effects of the development of the Bexhill Enterprise Park are the increases on traffic along the NEBGR. However, as the NEBGR has been designed and assessed to allow for this increase in flows over a baseline assessment, the effects are considered not significant.
8.8 Summary
8.8.1 PBA has undertaken extensive discussions with RDC and ESCC with regard to the provision of the Bexhill Enterprise Park.
8.8.2 The agreed methodology includes for the submission of the same TAR created for the NEBGR as this considers the BHLR and the policy allocations sites BX2 and BX3. For the purposes of this ES where standalone effects of the Bexhill Enterprise Park are reviewed, it has been agreed that the BHLR and the NEBGR will for part of the baseline assessment.
8.8.3 Traffic data has been provided by Mott MacDonald for the BHLR and the proposed junction with the NEBGR, and for the proposed junction between the NEBGR and Wrestwood Road.
8.8.4 The assessment of the environmental effects of the traffic associated with the construction has been based on the assumption that the construction traffic generation will comprise fewer vehicles than the operations of the Bexhill Enterprise Park when constructed. It is however considered that the construction traffic will bring heavy vehicles in close proximity to footpaths. It is therefore considered that the impact of construction traffic as a result of the Bexhill Enterprise Park construction would be minor adverse effect on severance and fear and intimidation. The effects on driver delay are considered to be minor for the school receptors but not significant for the residential and recreational receptors. The effects are considered not significant for pedestrian and cyclist delay and pedestrian and cyclist amenity.
8.9 References Institute of Environmental Assessment, 1993, ‘Guidelines for the Environmental Assessment of Road Traffic’ .
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9 Noise & Vibration
9.1 Introduction
9.1.1 This chapter presents the noise and vibration assessment for the proposed Bexhill Enterprise Park development. It has been prepared by Peter Brett Associates LLP (PBA).
9.1.2 This chapter documents the baseline noise climate. It describes the potential noise impacts arising during the construction and operational phases of the development. Consideration is also given to the cumulative impact of the proposed development alongside other committed development, the North East Bexhill Gateway Road (NEBGR) and the Bexhill to Hastings Link Road (BHLR). Where significant impacts are identified, suitable mitigation measures are proposed.
9.1.3 No significant sources of vibration have been identified for the operational phase of the proposed development. The potential impact of vibration has therefore only been considered as part of the construction activities.
9.1.4 The technical terminology presented within this chapter is defined in a glossary of terms in Appendix D.1 .
9.2 Policy Context
9.2.1 General planning policy is provided in Chapter 6 of this ES. Planning policy and guidance relating to noise is provided below.
National Policy
National Planning Policy Framework (NPPF)
9.2.2 The NPPF was published in March 2012. In respect of noise, the document states that:
“The planning system should contribute to and enhance the natural and local environment by … preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of … noise pollution.”
9.2.3 The NPPF goes on to advise that:
“Planning policies and decisions should aim to:
° Avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development;
° Mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions;
° Recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable
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restrictions put on them because of changes in nearby land uses since they were established; and
° Identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.”
9.2.4 The NPPF indicates that the Noise Policy Statement for England (NPSE) should be used to define the “significant adverse impacts” . A summary of the NPSE is provided below, and it is understood that DEFRA is currently undertaking research to quantify the “significant observed effect levels of noise” , although no formal guidance on this has been published at the time of writing.
Noise Policy Statement for England (NPSE)
9.2.5 The NPSE was published in March 2010. The document seeks to clarify the underlying principles and aims in existing policy documents, legislation and guidance that relate to noise. It also sets out the long term vision of Government noise policy: “to promote good health and a good quality of life through the effective management of noise within the context of Government policy on sustainable development.”
9.2.6 The NPSE clarifies that noise should not be considered in isolation of the wider benefits of a scheme or development, and that the intention is to minimise noise and noise effects as far as is reasonably practicable having regard to the underlying principles of sustainable development.
Local Policy
9.2.7 Planning decisions are guided by policies contained within the Rother District Local Plan, adopted 2006.
9.2.8 Paragraph 5.7 of the Rother District Local Plan (2006) states:
“The amenity of neighbouring properties needs to be protected. Hence, the impact of development needs to be carefully considered in relation to issues such as loss of light and privacy, avoiding an overbearing presence and otherwise causing intrusion such as through noise, activity at unsocial hours, lighting, etc.”
9.2.9 Policy GD1 of the Local Plan states that:
“All development should … [be] in keeping with and does not unreasonably harm the amenities of adjoining properties.”
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Noise Guidance
British Standard 8233: 1999 Sound Insulation and Noise Reduction for Buildings – Code of Practice
9.2.10 BS 8233 sets out the recommended indoor noise levels in habitable rooms for dwellings such as living rooms and bedrooms, when they are unoccupied. These recommended levels are presented in Table 9.1 .
Table 9.1: Recommended Internal Ambient Levels Design Range L dB Criterion Typical Situation Aeq,T Good Reasonable Reasonable resting / Living rooms 30 40 sleeping conditions Bedrooms 1 30 35 1For a reasonable standard in bedrooms at night, individual noise events (measured with F time-weighting) should not normally exceed 45dB LAmax.
9.2.11 BS 8233 also recommends design criteria for intrusive external noise. In gardens and
balconies it is desirable that the steady noise level does not exceed 50 LA eq,T dB and 55
LA eq,T dB should be regarded as the upper limit.
9.2.12 This standard has been included to assess the proposed residential development as part of the wider BX2 allocation. It has also been used to set noise limits for fixed plant associated with the employment uses.
British Standard 5228: 2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites
9.2.13 For construction noise, BS 5228: 2009 ‘Code of Practice for Noise and Vibration Control on Construction and Open Sites’ (British Standards Institution, 2009) gives recommendations for basic methods of noise and vibration control relating to construction and open sites where work activities / operations generate significant noise and/or vibration levels.
Control of Pollution Act 1974: Implementation of part III – Noise
9.2.14 Within the Control of Pollution Act 1974 (Department of the Environment, 1974), under Noise from Construction and Demolition Sites, Section 60 gives local authorities the power to serve a notice imposing requirements as to the way which construction works are to be carried out. Section 61 gives a person who intends to carry out works the opportunity to determine the local authority’s requirements by seeking their consent for the proposed methods of works and mitigation measures.
World Health Organisation – Guidelines for Community Noise, 1999
9.2.15 This document is a review of the medical and scientific knowledge on health impacts of community noise, and provides guidance to health authorities and professionals dealing with the effect of noise in non-industrial environments.
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9.2.16 It presents, in Table 1, the guideline values for community noise in specific environments. In dwellings, the effect of noise is typically sleep disturbance, annoyance and speech interference.
9.2.17 It identifies that to protect the majority of the people from being seriously annoyed during the
daytime, the outdoor noise level from steady, continuous noise should not exceed 55dB LA eq on balconies, terraces and outdoor living areas. To protect people from being moderately
annoyed during daytime, the noise level should not exceed 50dB LA eq .
Noise Assessment Methodologies
British Standard 7445: Part 1:2003 ‘Description and Measurement of Environmental Noise. Guide to Quantities and Procedures’
9.2.18 BS 7445-1 describes methods and procedures for measuring noise from all sources which contribute to the total noise climate of a community environment, individually and in combination. The results are expressed as equivalent continuous A-weighted sound
pressure levels, LA eq,T .
9.2.19 BS 7445-1 states that sound level meters that are used should conform to Class 1 (or Class 2 as a minimum) as described in BS EN 61672:2003 and should be calibrated according to the instructions of the manufacturer and field calibration should be undertaken at least before and after each series of measurements.
Calculation of Road Traffic Noise (CRTN): 1998
9.2.20 CRTN is a Department for Transport (DfT) memorandum that describes the procedure to calculate the road traffic noise at a given receptor location.
9.2.21 Section III (The Measurement Method) describes the shortened measurement procedure to be undertaken within 3 consecutive hours between 10.00 and 17.00hrs. A formula is
presented to calculate the noise level dB LA10,18h based on these measurements.
Method for Converting the UK Road Traffic Noise Index LA 10,18h to the EU Noise Indices for Road Noise Mapping: 2006
9.2.22 This report was prepared by the Transport Research Laboratory and Casella Stanger on behalf of the Department for Environment, Food and Rural Affairs (Defra) in January 2006.
9.2.23 It presents a methodology to convert the noise index for traffic noise derived from CRTN,
LA 10,18h , into the noise indicators required by the Environmental Noise Directive (EU Noise
Indices) L den and L night . For road traffic noise, supplementary noise indicators are also
presented LAeq,12h (07:00-19:00), known as L day , LA eq,4h (19:00-23:00), known as L evening and
LA eq,16h (07:00-23:00).
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British Standard 4142: 1997 Method for Rating Industrial Noise Affecting Mixed Residential and Industrial Sites
9.2.24 Fixed plant associated with the development has been assessed against BS 4142.
9.2.25 BS 4142 (British Standards Institution, 1997) sets out methods for determining, at the outside of a residential building:
° Noise levels from factories, industrial premises, fixed installation of sources of an industrial nature in commercial properties;
° Background noise level (background noise levels below 30 dB are considered to be ‘very low’ and are considered to be outside the scope of BS 4142) and;
° Assessing whether the noise referred to above is likely to give rise to complaints from people residing in the building considered.
9.2.26 The method subtracts the background noise level LA 90,T (that which is exceeded for 90% of a
given duration) from the ‘rating level’, LA rTr , which is calculated by adjusting the noise source for a character correction, if required. Table 9.2 shows the assessment levels and advice.
Table 9.2: BS4142 Assessment Levels
LAr.Tr – LA80,T (dB) Advice +10 Complaints Likely +5 Marginal Significance -10 Complaints Unlikely
9.3 Methodology
Baseline Noise Survey
9.3.1 A baseline noise survey was undertaken between 12th and 13th February 2013 at existing dwellings in proximity to the site, in accordance with BS7445.
9.3.2 The purpose of the survey was to establish the existing noise climate at the existing receptors surrounding the site. The results of the noise survey have also been used to validate the road traffic noise model.
9.3.3 Noise readings were carried out at locations representative of the nearest noise-sensitive receptors. These are shown in Figure 9.1 of Appendix D.2 .
Table 9.3: Baseline Noise Survey Locations Location Description Dominant Noise Source 1 Adjacent to Glovers Lane Distant road traffic and birdsong 2 Adjacent to St James’ Crescent Distant road traffic and birdsong 3 Adjacent to St James’ Avenue Distant road traffic and birdsong 4 Adjacent to Wrestwood Road Road traffic along Wrestwood Road
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9.3.4 Short sample measurements were taken at locations 1 – 3. Three series of fifteen minute readings were taken between 14:00 and 17:00 for the daytime measurements. During the night-time, two series of measurements were taken between 04:00 and 06:00 hours.
9.3.5 At Location 4 a continuous 3 hour measurement was undertaken during the day between 14:00 and 17:00 in accordance with the shortened measurement procedure in CRTN.
Instrumentation
9.3.6 Two type 1 sound level meters were used for the survey. Each was mounted at 1.5m above the ground and at a minimum of 3m away from any reflective surface.
9.3.7 The noise instrumentation had valid laboratory certification, which is available upon request. Field calibrations were performed before and after the measurements with no significant fluctuation recorded. The instrumentation used in the noise monitoring is listed in Table 9.4 .
Table 9.4: Baseline Noise Survey Locations Laboratory Item Type Manufacturer Serial Number Calibration Date Sound Calibrator 4321 Bruel & Kjaer 2619374 18/01/2013 2626232 Hand Held Analyser 2250 Bruel & Kjaer 23/01/2012 2626233 Prepolarized Free-Field ½” 2621211 4189 Bruel & Kjaer 20/01/2012 Microphone 2621212
Assessment
Construction Noise and Vibration
9.3.8 Noise and vibration generated during the construction phase of the development have been assessed qualitatively. This is in accordance with advice provided on using the best practicable means to minimise the noise and vibration impact of construction activities on nearby receptors, as stated in BS 5228:2009 Parts 1 and 2. These are considered in more detail in the mitigation section of this chapter.
9.3.9 Annex E of BS 5228-1:2009 provides useful guidance on the significance of noise effects and examples of noise limits for construction noise based on the pre-existing noise climate (i.e. the pre-construction baseline), although it is not afforded the same level of authority as the British Standard itself. Day, evening and night-time periods are defined in the Annex, with limits provided as shown in Table 9.5 .
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Table 9.5: BS 5228 Recommended Construction Noise Limits
Assessment Category and Threshold Value, in Decibels (L Aeq T ) (dB) Threshold Value Period Category A A Category B B Category C C Night-time (23.00−07.00) 45 50 55 Evenings and weekends D) 55 60 65 Daytime (07.00−19.00) and 65 70 75 Saturdays (07.00−13.00) NOTE 1 A significant effect has been deemed to occur if the total LAeq noise level, including construction, exceeds the threshold level for the Category appropriate to the ambient noise level. NOTE 2 If the ambient noise level exceeds the threshold values given in the table (i.e. the ambient noise level is higher than the above values), then a significant effect is deemed to occur if the total LAeq noise level for the period increases by more than 3 dB due to construction activity. NOTE 3 Applied to residential receptors only. A) Category A: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are less than these values. B) Category B: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are the same as category A values. C) Category C: threshold values to use when ambient noise levels (when rounded to the nearest 5 dB) are higher than category A values. D) 19.00–23.00 weekdays, 13.00–23.00 Saturdays and 07.00–23.00 Sundays.
9.3.10 The recommended limits are defined as the ‘threshold of significance’. Noise Survey measurements undertaken at nearby noise-sensitive receptors have been considered to determine the above limits.
Operational Noise
9.3.11 A noise model has been prepared using the computer software SoundPLAN version 7.1 to assess the impact from the development.
9.3.12 18hr traffic flows, the proportions of Heavy Duty Vehicles (HDVs), and traffic speeds for each assessment scenario were provided by the project Transport Consultants (PBA). These flows have been determined from data used in the BHLR study; the BHLR ES included flows associated with the BX2 and BX3 allocations (i.e. including the Bexhill Enterprise Park, and also the NEBGR, in order to ensure adequate capacity, and to assess the cumulative impacts.
9.3.13 Topographical information has been obtained from site specific spot heights complemented with 5m grid resolutions contours.
9.3.14 Validation of the noise model has been undertaken against the survey results and this is detailed in Appendix D.3 . The difference between the measured and predicted noise levels does not exceed 3dB, indicating a good correlation.
9.3.15 The road traffic noise model has been used to predict the noise impact due to the proposed development traffic upon the nearest noise sensitive receptors.
Employment Use
9.3.16 The noise impacts associated with the increase in road traffic have been assessed between with and without development scenarios. Assessments have been made for the daytime and
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night-time noise parameters LA eq,16h and LA eq,8h respectively to assess the impact due to employment traffic on nearby receptors.
9.3.17 The road traffic noise was predicted following guidance in the CRTN. The ‘Method for
Converting the UK Road Traffic Noise Index LA 10,18h to the EU Noise Indices for Road Noise Mapping: 2006’ was used to convert the predicted noise levels to the daytime (16 hours) and night-time (8 hours) periods.
Plant
9.3.18 Fixed plant associated with the development could impact upon nearby dwellings. Fixed plant is usually assessed against BS 4142. However, background noise survey data measured was below 30 dB (A) and it is therefore outside the scope of BS 4142. Limits have been set for fixed plant to meet the ‘good’ internal noise levels from BS 8233:1999 at nearby dwellings. These limits have been set in the mitigation section of the operational impacts.
BX2 Allocation
9.3.19 Within the Local Plan and North East Bexhill Supplementary Planning Document (2009), land is allocated for housing near to the proposed NEBGR. However, no detail is available on this with no planning application having been made or a preliminary masterplan drawn up.
9.3.20 To ensure a thorough assessment of potential effects, within the noise model a receptor has been placed in the land allocated for housing to determine the likely noise levels experienced by the future receptors. Mitigation measures have also been provided to meet internal noise levels to ensure that potential future residents are not adversely affected by the proposed development.
Significance Criteria
9.3.21 The significance of residual effects has been assessed in accordance with the generic significance criteria provided in Table 5.1 . Tables 9.6 – 9.8 define the sensitivity of the receptor and the magnitude of the effect which together determine the level of significance.
Table 9.6: Sensitivity of Receptors Sensitivity Description High Dwellings Medium Schools, hospitals, quiet recreation areas Low Offices, cafes/bars with external areas Non Sensitive Industrial, retail
9.3.22 When considering noise changes from a road traffic source, a comparison is made between the ‘with development’ and ‘without development’ scenarios. These changes can potentially increase or decrease noise levels.
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9.3.23 When considering the significance of internal or external noise levels for a specific proposed use (such as internal noise levels for dwellings, or construction noise) a comparison is made between the predicted noise levels and the relevant guideline or policy level.
9.3.24 A change of 3 dB is the minimum perceptible under normal conditions, and a change of 10 dB corresponds roughly to halving or doubling the loudness of sound.
Table 9.7: Table of Magnitude
dB Change Compared with Baseline Magnitude or Difference in Predicted Level Description Compared to Guideline Level Not perceptible to human ear, within margins Negligible <3 dB of error of measurement. Perceptible but less than a doubling/halving of Small 3 – 4.9 dB sound energy. Medium 5 - 9.9 dB Up to a doubling/halving of loudness. Large >10 dB Over a doubling of loudness.
9.3.25 Table 9.8 sets out how the sensitivity of the receptors and the magnitude of the impact have been combined to determine the significance criteria. The criteria range from not significant to severe.
Table 9.8: Significance Criteria
Sensitivity
Non Sensitive Low Medium High Negligible Not significant Not significant Not significant Not significant Small Not significant Not significant Minor Moderate Medium Not significant Minor Moderate Major Magnitude Large Minor Moderate Major Severe
9.3.26 An increase in noise level is described as adverse and a decrease in noise level as beneficial.
9.4 Baseline Conditions
9.4.1 The noise climate at the site was observed to be dominated by traffic along the A2036 Wrestwood Road at Location 4. Traffic was only audible as distant traffic noise at Locations 1-3.
9.4.2 Tables 9.9 to 9.11 present a summary of the baseline noise survey results. A detailed version of the results is presented in Appendix D.3 .
Table 9.9: Summary Table of Daytime Short Term Measurements
Location Period Duration (mins) dB LAeq,T dB LA90,T dB LA10,T 1 Daytime 45 48 30 44 2 Daytime 45 47 30 44 3 Daytime 45 45 32 44
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Table 9.10: Summary Table of Night-Time Short Measurements
Location Period Duration (mins) dB LAeq,T dB LA90,T dB LA10,T dB LAFmax 1 Night-time 30 32 23 29 64 2 Night-time 30 43 21 30 73 3 Night-time 30 31 24 34 50
Table 9.11: Summary Table of CRTN Measurements
Location Period Duration (mins) dB LAeq,T dB LA90,T dB LA10,T 1 Daytime 45 70 54 73
9.4.3 Low background noise levels were recorded during the survey. From Location 2, it can be
seen that LA 90,T as low as 21 dB was measured. Due to low background noise levels BS 4142 assessments cannot be undertaken for the fixed plant associated with the employment uses.
9.5 Assessment and Mitigation of Construction Effects
Construction Noise and Vibration
9.5.1 Construction noise from the development could potentially increase the ambient noise levels at existing noise sensitive receptors.
9.5.2 BS 5228:2009 Annex E (Informative) states that noise predictions should be undertaken to determine eligibility for noise insulation or temporary re-housing. However, the informative also states that these assessments should be undertaken when a contractor has been appointed and detailed method statements on the construction programme and plant to be used are available. Therefore, a quantitative assessment of the construction phase may be required when such information is available. At this stage noise categories have been determined for nearby receptors which state the noise levels to be achieved from construction noise.
9.5.3 The baseline noise levels LA eq,T at the nearest noise sensitive receptors potentially affected by construction noise have been used to determine the construction noise categories below.
9.5.4 Table 9.12 provides the construction noise categories in accordance with the threshold values presented in Table 9.5 .
Table 9.12: Baseline Noise Level at Construction Noise Sensitive Receptor
Location LAeq,T dB BS5228 Category Dwellings along Glovers Lane 48 A Dwellings along St.James’ Crescent 47 A Dwellings along St.James’ Avenue 45 A Dwellings along Wrestwood Road 70 C
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9.5.5 Ground-borne vibration is often a cause for concern to occupants of buildings, particularly in relation to construction. Sources of vibration may include piling activities. Any construction phases that include driven piling should be considered to be the most likely to produce perceptible levels of vibration and therefore the most likely to cause concern to nearby residents. This will be considered in more detail once the construction phasing and methodology is known.
9.5.6 There could be an impact due to the cumulative construction associated with the development and other committed development (NEBGR and BHLR). Construction activities could run concurrently for the schemes.
9.5.7 Noise and vibration levels as a result of the construction works will be minimised by implementing the mitigation methods advised in BS 5228:2009 via the CEMP. We would also anticipate that the BHLR and NEBGR would have CEMPs in place to minimise the noise impact at nearby dwellings.
Mitigation
9.5.8 The following mitigation measures are based on the guidance provided in BS 5228 and will be applied to minimise the noise breakout generated by the construction activities affecting noise sensitive receptors:
° Ensuring the use of quiet working methods, the most suitable plant and reasonable hours of working for noisy operations, where reasonably practicable;
° Locating noisy plant and equipment as far away from dwellings as reasonably possible, and where practical, carry out loading and unloading in these areas;
° Screening plant to reduce noise which cannot be reduced by increasing the distance between the source and the receiver (i.e. by installing noisy plant and equipment behind large site buildings);
° Shutting down any machines that work intermittently or throttling them back to a minimum;
° Orientating plant that is known to emit noise strongly in one direction so that the noise is directed away from dwellings, where possible;
° Closing acoustic covers to engines when they are in use or idling; and
° Lowering materials slowly, whenever practicable, and not dropping them.
9.5.9 The main source of vibration typically associated with the construction process is piling. The use of alternative methods such as continuous flight auger injected piles or auger bored piles will be considered, depending in the ground conditions to be encountered.
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9.5.10 A CEMP will be agreed with the local planning authority prior to commencement of construction. The CEMP could form the basis of the agreed working methods with the Local Authorities under Section 61 of the Control of Pollution Act 1974.
9.5.11 With mitigation, it is expected that the adverse effect of the construction phase of the proposed development would be considered moderate and adverse.
9.6 Assessment and Mitigation of Operational Effects
9.6.1 The noise impact due to the operation of the employment uses has been modelled for 2028, based on the availability of traffic modelling data. The difference in noise levels between the ‘with development’ and ‘without development’ scenarios for the daytime and night-time is presented in Figures 9.2 and 9.3 , Appendix D.2.
9.6.2 It can be seen from the figures that the existing dwellings would experience a noise level increase of less than 3dB which is not perceptible to the human ear. This impact is described as not significant in accordance with the significance criteria described in Table 9.8 of this chapter. Therefore, further mitigation measures are not necessary for the increase in road traffic noise.
Mitigation
9.6.3 To reduce the impact from the employment uses, fixed plant noise limits have been specified.
9.6.4 RDC has stated that noise from building services plant, should not exceed the ‘good’ internal noise levels at nearby dwellings. Assuming a 15dB reduction due to an open window 13 , the external noise levels should not exceed 45dB(A) from fixed plant.
9.6.5 The proposed limits are defined at 1 metre from the façade of the receptors. The limits are deemed to apply to the total noise emissions level from all plant during the day and night so individual plant items may need to be designed to a lower limit to take account of the cumulative effects of noise.
9.6.6 With the proposed mitigation in place, the proposed development will have a not significant effect in relation to plant noise.
BX2 Allocation – Residential Use
9.6.7 As part of the wider BX2 allocation, land adjacent to the development has been allocated for residential use. A receptor was incorporated into the 2028 noise model scenario to determine the noise levels for future dwellings resulting from the operational use of the proposed development and additional committed development.
9.6.8 During the daytime dwellings at the receptor location would be exposed to noise levels of up to 59dB(A) and 54dB(A) during the night-time period, predominantly from road traffic. These
13 WHO states that it assumes a 15dB reduction for a partly open window.
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noise levels are not considered to be significantly high but would require double glazing with a specified acoustic performance to meet internal noise level criteria from BS 8233:1999.
9.6.9 For future dwellings which face directly into the NEBGR it is considered that double glazing
with a weighted sound reduction index, R w, of at least 35dB(A) is installed. This can be met, for example, with a double glazed unit such as 10/12/4 (glass width / air gap width / glass width, in mm). This would ensure that ‘good’ internal noise levels identified in BS 8233:1999 would be met during the daytime and night-time.
9.6.10 Furthermore, it is recommended that garden areas do not front directly onto the NEBGR and are screened by the dwellings from the road source. This would ensure garden areas during the daytime would not exceed 55dB(A) which is the external criteria set in BS 8233:1999 and WHO.
9.7 Summary of Residual Effects
9.7.1 Noise and vibration levels resulting from construction works will be minimised by implementing the mitigation methods advised in BS 5228:2009 via the CEMP.
9.7.2 With mitigation, it is expected that the adverse effect of the construction phase of the proposed development and other committed development would be considered moderate and adverse but of short term duration.
Operational Noise
9.7.3 Noise impacts from traffic and fixed plant associated with the proposed development would not be significant.
9.7.4 Impact on future receptors associated with the BX2 residential development would be considered to be negligible with mitigation measures incorporated.
9.8 Summary
9.8.1 A noise and vibration assessment has been undertaken to determine the likely impacts arising from the construction and operational phases of the proposed development.
9.8.2 A baseline noise survey was undertaken at the nearest receptors (i.e. dwellings) to the development. The purpose of this survey was to establish the existing noise climate in proximity to the site.
9.8.3 A computer noise model was prepared using the software SoundPLAN version 7.1. The model incorporates the noise generating aspects of the proposed development including the traffic generated by the proposed development.
9.8.4 Noise and vibration levels resulting from construction works could impact on nearby receptors. However, these will be minimised by implementing the mitigation methods advised in BS 5228:2009 via the CEMP.
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9.8.5 With mitigation, it is expected that the adverse effect of the construction phase of the proposed development and other committed development would be considered moderate and adverse but of short term duration.
9.8.6 Operational noise has been assessed for the development. These include noise due to fixed plant and increase in road traffic noise due to the development. Noise limits have been set for fixed plant associated with the development to minimise the impact at the nearest receptors. Increase in road traffic noise at existing dwellings would have a negligible impact.
9.9 References
British Standards Institution, 1997. BS 4142:1997 Rating industrial noise affecting mixed residential and industrial areas. London: BSI.
British Standards Institution, 2009. BS 5228-1:2009 Code of practice for noise and vibration control on construction and open sites Part 1 Noise. London: BSI.
British Standards Institution, 2009. BS 5228-2:2009 Code of practice for noise and vibration control on construction and open sites Part 2 Vibration. London: BSI.
British Standards Institution, 1999. BS 8233:1999 Sound insulation and noise reduction for buildings – Code of Practice. London: BSI.
Department of the Environment, 1974. Control of Pollution Act 1974 Implementation of Part III Noise. London: TSO.
Department for Environment, Food and Rural Affairs, 2006. Method For Converting The UK Road Traffic Noise Index LA10,18h To The EU Noise Indices For Road Noise Mapping. Wokingham: TRL, London: Casella Stanger.
Department of Transport Welsh Office, 1988. Calculation of Road Traffic Noise. London: HMSO.
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10 Air Quality
10.1 Introduction
10.1.1 This chapter, prepared by Peter Brett Associates LLP, assesses the impacts of the proposed development on local air quality. It describes the methods used to assess the impacts, the baseline conditions currently existing at the site and in the surrounding area, the potential impacts of the development arising from construction and operation, and cumulatively with associated development, the mitigation measures required to prevent, reduce, or offset the impacts, and the residual effects.
Scope
10.1.2 This assessment describes existing air quality within the study area, and considers the likelihood of significant air quality impacts at sensitive locations. Traffic data provided for the assessment are those utilised in the Environmental Statement (2007) prepared for the BHLR. The study area has been defined as an area within 200m of the site. The Bexhill Enterprise Park forms part of the BX2 allocated site.
10.1.3 Both construction phase and potential operational phase impacts are considered. Construction phase impacts will be associated with dust deposition and spoiling of surfaces. The main pollutants of concern related to construction activities are dust and particulate
matter (PM 10 ).
10.1.4 As the traffic data which has been used to inform the assessment is based on that prepared for the BHLR ES, the operational phase impacts assessed are those associated with emissions from road traffic associated with the development proposals; the predicted impacts represent the cumulative impacts of the NEBGR, BHLR, and the BX2 and BX3 allocations areas due to the source of the traffic data. The main air pollutants of concern
related to traffic are nitrogen dioxide (NO 2) and fine particulate matter (PM 10 and PM 2.5 ).
10.1.5 This assessment has been prepared taking into account all relevant local and national guidance and regulations.
10.2 Policy Context
The Air Quality Strategy
10.2.1 The Air Quality Strategy (2007) establishes the policy framework for ambient air quality management and assessment in the UK. The primary objective is to ensure that everyone can enjoy a level of ambient air quality which poses no significant risk to health or quality of life. The Strategy sets out the National Air Quality Objectives (NAQOs) and government policy on achieving these objectives.
10.2.2 Part IV of the Environment Act 1995 introduced a system of Local Air Quality Management (LAQM). This requires local authorities to regularly and systematically review and assess air quality within their boundary, and appraise development and transport plans against these
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assessments. The relevant NAQOs for LAQM are prescribed in the Air Quality (England) Regulations 2000 and the Air Quality (Amendment) (England) Regulations 2002.
10.2.3 Where an objective is unlikely to be met, the local authority must designate an Air Quality Management Area (AQMA) and draw up an Air Quality Action Plan (AQAP) setting out the measures it intends to introduce in pursuit of the objectives within its AQMA.
10.2.4 The Local Air Quality Management Technical Guidance 2009 (LAQM.TG(09)) 14 issued by the Department for Environment, Food and Rural Affairs (Defra) for Local Authorities provides advice as to where the NAQOs apply. These include outdoor locations where members of the public are likely to be regularly present for the averaging period of the objective (which vary from 15 minutes to a year). Thus, for example, annual mean objectives apply at the façades of residential properties, whilst the 24-hour objective (for
PM 10 ) would also apply within garden areas. They do not apply to occupational, indoor or in- vehicle exposure.
EU Limit Values
10.2.5 The Air Quality Standards Regulations 2010 implement the European Union’s Directive on
ambient air quality and cleaner air for Europe (2008/50/EC), and include limit values for NO 2. These limit values are numerically the same as the NAQO values but differ in terms of compliance dates, locations where they apply and the legal responsibility for ensuring that
they are complied with. The compliance date for the NO 2 EU Limit Value is 1 January 2010 which is five years later than the date for the NAQO.
10.2.6 Directive 2008/50/EC consolidated the previous framework directive on ambient air quality assessment and management and its first three daughter directives. The limit values remained unchanged, but it now allows Member States a time extension for compliance, subject to European Commission (EC) approval.
10.2.7 The Directive limit values are applicable at all locations except:
° Where members of the public do not have access and there is no fixed habitation;
° On factory premises or at industrial installations to which all relevant provisions concerning health and safety at work apply; and
° On the carriageway of roads; and on the central reservations of roads except where there is normally pedestrian access.
10.2.8 The limit values are mandatory whereas there is no legal obligation to meet the NAQOs. Therefore, the limit values carry more weight than the NAQOs.
14 Defra, 2009, Local Air Quality Management Technical Guidance LAQM.TG(09).
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Planning Policy
National
10.2.9 The National Planning Policy Framework (NPPF) was published in March 2012. This sets out the Government’s planning policies for England and how they are expected to be applied. In relation to conserving and enhancing the natural environment, Paragraph 17 states that:
“Within the overarching roles that the planning system ought to play, a set of core land-use planning principles should underpin both plan-making and decision-taking. These 12 principles are that planning should…contribute to conserving and enhancing the natural environment and reducing pollution.”
10.2.10 Paragraph 109 states that:
“The planning system should contribute to and enhance the natural and local environment by…preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability.”
10.2.11 Paragraph 124 states that:
“Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in Air Quality Management Areas is consistent with the local air quality action plan.”
Local
10.2.12 The Rother District Local Plan (adopted July 2006) does not contain any policies related to air quality. When adopted, the Core Strategy will replace the Local Plan. Policy OSS4 in the Proposed Submission Core Strategy states:
“In assessing the suitability of a particular location for development, when both allocating land for development and determining planning applications, sites and/or proposals should accord with the relevant policies of this Core Strategy and in the context of:… (viii) any constraints relating to land stability, contamination, air quality, agricultural land quality and coastal erosion, and the ability to satisfactorily address these.”
10.3 Methodology
Baseline Conditions
10.3.1 Information on existing air quality has been obtained by collating the results of monitoring carried out by RDC and Hastings Borough Council (HBC). Background concentrations for
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the site have been defined using the national pollution maps published by Defra. These maps cover the whole country on a 1x1km grid 15 .
Construction Effects
10.3.2 During demolition and construction the main potential effects are dust annoyance and locally
elevated concentrations of PM 10 . The suspension of particles in the air is dependent on surface characteristics, weather conditions and on-site activities. Impacts have the potential to occur when dust generating activities coincide with dry, windy conditions, and where sensitive receptors are located downwind of the dust source.
10.3.3 Separation distance is also an important factor. Large dust particles (greater than 30 µm), responsible for most dust annoyance, will largely deposit within 100m of sources. Intermediate particles (10-30 µm) can travel 200-500m. Consequently, significant dust annoyance is usually limited to within a few hundred metres of its source. Smaller particles (less than 10 µm) are deposited slowly and may travel up to 1km, however, the impact on the
short-term concentrations of PM 10 occurs over a shorter distance. This is due to the rapid decrease in concentrations with distance from the source due to dispersion.
10.3.4 The Greater London Authority (GLA, 2006) provides guidelines to determine the likely level
of risk construction and demolition impacts will have on local dust complaints and PM 10 concentrations, which can be applied here. Sites are categorised into low, medium and high risk (Table 10.1 ) based on the size of the development, and potential for impacts at sensitive receptors, and the appropriate level of mitigation consequently required. By applying the recommended mitigation, the site is reduced to a low risk site.
Table 10.1: Risk Criteria for Control of Dust and Emissions from Construction Risk Criteria Development of over 15,000 square metres High Development of over 150 properties Potential for emissions and dust to have significant impact on sensitive receptors Development of between 1,000 and 15,000 square metres Development of between 10 to 150 properties Medium Potential for emissions and dust to have an intermittent or likely impact on sensitive receptors Development of up to 1,000 square metres Development of one property and up to a maximum of ten Low Potential for emissions and dust to have an infrequent impact on sensitive receptors
10.3.5 The sensitivity of the study area to construction dust impacts is defined based on the examples provided within the Institute of Air Quality Management (IAQM, 2012) guidance (Table 10.2 ), taking into account professional judgement.
15 http://laqm.defra.gov.uk/maps/maps2010.html.
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Table 10.2: Area Sensitivity Definitions Sensitivity Health Receptors Ecological Recept ors More than 100 dwellings within 20m PM 10 concentrations exceed the daily mean objective Contamination present Very High European designated site Very sensitive receptors (schools / hospitals) Construction activities in one area for more than one year 10 – 100 dwellings within 20m High Nationally designated site PM 10 concentrations approach the daily mean objective Less than 10 dwellings within 20m Medium Locally designated site PM 10 concentrations below the daily mean objective No dwellings within 20m Low PM 10 concentrations well below the daily mean No designation objective
10.3.6 Consideration was also given to wind and rainfall data. A wind rose from Shoreham weather station for 2012 was used along with average rainfall data (1981-2010) obtained from the Met Office website.
Significance Criteria
10.3.7 The construction impact significance criteria are based on:
° Guidance on the Assessment of the Impacts of Construction on Air Quality and the Determination of their Significance, IAQM 2012;
° The control of dust and emissions from construction and demolition Best Practice Guidance, GLA 2006;
° Particulate Matter in the United Kingdom, Air Quality Expert Group, 2005; and
° Air Quality (England) Regulations, 2000 and Air Quality (England) (Amendment) Regulations 2002.
10.3.8 The significance criteria take account of the risk of impact and the likely magnitude (taking into account the scale and nature of the works, the proximity of sensitive receptors, and existing conditions in the area) and the sensitivity of the receptors (as defined by the IAQM guidance). The significance criteria also assume that mitigation appropriate to the level of risk (defined in the mitigation section, based on the GLA 2006 guidance) is put into place.
10.3.9 Table 10.3 presents the significance criteria used to assess the construction impacts.
Table 10.3: Construction Phase Significance Criteria Sensitivity of Risk of Site Giving Rise to Dust Effects Area High Medium Low Without Mitigation Very High Major Adverse Moderate Adverse Moderate Adverse High Moderate Adverse Moderate Adverse Minor Adverse Medium Moderate Adverse Minor Adverse Not Significant Low Minor Adverse Not Significant Not Significant
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Sensitivity of Risk of Site Giving Rise to Dust Effects Area High Medium Low With Mitigation Very High Minor Adverse Minor Adverse Not Significant High Minor Adverse Not Significant Not Significant Medium Not Significant Not Significant Not Significant Low Not Significant Not Significant Not Significant
Operational Effects
Sensitive Locations
10.3.10 Relevant sensitive locations are places where members of the public might be expected to be regularly present over the averaging period of the objectives. For this assessment, this includes existing residential properties.
10.3.11 Nitrogen dioxide, PM 10 and PM 2.5 concentrations were predicted at three receptors representing residential properties adjacent to the road network affected by the proposed development, consistent with previous assessments (for the BHLR and NEBGR). As Glover’s Farm lies within the site, and will be removed by the development, two additional receptors have been chosen representing the closest residential properties to the BHLR and the site. The locations are described in Table 10.4 and shown in Figure 10.1 (Appendix E.1 ). Concentrations were predicted at a height of 1.5m, representing exposure at the ground floor.
Table 10.4: Description of Receptor Locations Receptor Description R1 Glover’s Farm R2 91 Wrestwood Road R3 St Mary’s School R4 33 St James Crescent R5 Bridgend, Glovers Lane
10.3.12 Receptors representing future residential properties within the BX2 allocation area have not been explicitly considered. This is due to their locations being as yet unknown. However, receptors R1 – R3 represent worst-case exposure to road traffic emissions due to higher traffic levels on Wrestwood Road and the BHLR in relation to the NEBGR; concentrations within the BX2 allocation area are unlikely to be higher than those predicted for receptors R1 – R3.
Impact Predictions
10.3.13 Predictions of nitrogen dioxide, PM 10 and PM 2.5 concentrations have been carried out for 2015 and 2028 (based on the opening year of the NEBGR and the availability of modelled traffic data), both with and without the development in place. For both assessment years, emission factors and background concentrations for 2012 have been utilised in order to remove the uncertainty associated with future year emission factors. This is considered a
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conservative approach, as emissions are expected to reduce in future as a result of tighter controls on emissions, albeit initially at a slower rate than currently predicted.
10.3.14 In addition, concentrations have been predicted at the De La Warr and Bulverhythe continuous monitors in 2012, in order to verify the modelled results (see Appendix E.2 for further details on the verification method).
10.3.15 Predictions have been carried out using the ADMS-Roads dispersion model (v3.1.4). The model requires the user to provide various input data, including the emissions for each section of road, and road characteristics (including road width, height above ground level, and street canyon height, where applicable). It also requires meteorological data; the model has been run using meteorological data from the Shoreham monitoring station (2012), which is considered suitable for this area.
10.3.16 Annual Average Daily Traffic (AADT) flows, the proportions of Heavy Duty Vehicles (HDVs), and traffic speeds for each assessment scenario were provided by the project Transport Consultants (PBA). These data have been determined from data used in the preparation of the ES for the BHLR; the BHLR ES included flows associated with the BX2 and BX3 allocations, and also the NEBGR in order to ensure adequate capacity, and to assess the cumulative impacts.
10.3.17 The data utilised in this assessment are consistent with the BHLR ES. The baseline traffic flows assume existing conditions (i.e. without the BHLR) as the traffic modelling with the BHLR also included the employment uses and it was not practicable to accurately re-assign trips. The assessment presented in this chapter therefore represents a cumulative assessment of the BHLR, NEBGR, and the BX2 / BX3 allocations. This represents a worst- case cumulative scenario in relation to air quality, and is thus considered appropriate. Traffic data used in this assessment are summarised in Appendix E.3 .
10.3.18 Emissions were calculated using the Emission Factor Toolkit (EFT) v5.1.3, which utilises
NO x emission factors taken from the European Environment Agency COPERT 4 (v8.1) emission calculation tool. The traffic data were entered into the EFT, along with speed data, to provide emission rates for each of the road links entered into the model.
Assessment Criteria
10.3.19 The NAQOs for NO 2 and PM 10 , set out in the Air Quality Regulations (England) 2000 and the Air Quality (England) (Amendment) Regulations 2002, are shown in Table 10.5 .
Table 10.5: NO 2 and PM 10 Objectives
Pollutant Time Period Objective
3 Nitrogen dioxide 1-hour mean 200µg/m not to be exceeded more than 18 times a year (NO 2) Annual mean 40µg/m 3
3 Particulate matter 24-hour mean 50µg/m not to be exceeded more than 35 times a year (PM 10 ) Annual mean 40µg/m 3
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10.3.20 The objectives for NO 2 and PM 10 were to have been achieved by 2005 and 2004, respectively, and continue to apply in all future years thereafter. Analysis of long term 3 monitoring data suggests that if the annual mean NO2 concentration is less than 60µg/m then the one-hour mean objective is unlikely to be exceeded where road transport is the main source of pollution. This concentration has been used to screen whether the one-hour mean objective is likely to be achieved 16 .
10.3.21 The Air Quality Strategy (2007) includes an exposure reduction target for smaller particles 3 known as PM 2.5 . These are an annual mean target of 25µg/m by 2020 and an average urban background exposure reduction target of 15% between 2010 and 2020.
10.3.22 A new air quality directive (2008/50/EC) was adopted in May 2008, and includes a national
exposure reduction target, a target value and a limit value for PM 2.5 , shown in Table 10.6 . The UK Government transposed this new directive into national legislation in June 2010 (Stationery Office, 2010).
Table 10.6: PM 2.5 Air Quality Criteria Time Period Objective/Obligation To be Achieved by Annual mean 25µg/m 3 2020 UK 3 year running 15% reduction in concentrations measured Between 2010 and objectives annual mean at urban background sites 2020 Annual mean Target value of 25µg/m 3 2010 Annual mean Limit value of 25µg/m 3 2015 Annual mean Stage 2 indicative Limit value of 20µg/m 3 2020 Exposure reduction target relative to the 3 year Average European AEI depending on the 2010 value of the 3 Exposure 2020 obligations a year AEI (ranging from a 0% to a 20% Indicator (AEI) reduction) 3 year Average Exposure concentration obligation of Exposure 3 2015 a 20µg/m Indicator (AEI) a The 3 year annual mean or AEI is calculated from the PM 2.5 concentration averaged across all urban background monitoring locations in the UK e.g. the AEI for 2010 is the mean concentration measured over 2008, 2009 and 2010.
Significance Criteria
10.3.23 There is no official guidance in the UK on how to describe the nature of air quality impacts, nor to assess their significance. The approach developed by the Institute of Air Quality Management (IAQM), subsequently incorporated into the EPUK 2010 guidance, has therefore been used within this assessment to assist in describing the air quality impacts associated with the proposed development with regard to road traffic impacts.
10.3.24 The guidance sets out three stages: determining the magnitude of change at each receptor, describing the impact, and assessing the overall significance. Impact magnitude relates to the change in pollutant concentration; the impact description relates this change to the air quality objective (or limit value).
10.3.25 Table 10.7 sets out the impact magnitude descriptors, whilst Table 10.8 sets out the impact descriptors.
16 Defra, 2009. Local Air Quality Management Technical Guidance LAQM.TG(09).
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Table 10.7: Impact Magnitude for Changes in Ambient Pollutant Concentrations
Annual mean NO 2 Number of days PM 10 Magnitude Annual mean PM 2.5 3 and PM 10 >50µg/m Large ≥ 4µg/m 3 ≥ 2.5µg/m 3 ≥ 4 days
Medium 2 – <4µg/m 3 >1.25 – 2.5µg/m 3 3 – 4 days
Small 0.4 – <2µg/m 3 >0.25 – 1.25µg/m 3 1 – 2 days
Imperceptible < 0.4µg/m 3 < 0.25µg/m 3 < 1 day
Table 10.8: Impact Descriptor for Changes in Concentration at a Receptor Absolute concentration with the development Change in concentration in relation to Objective / Limit Value Small Medium Large Above objective/limit value (a) Minor Moderate Major
Just below objective/limit value (b) Minor Moderate Moderate
Below objective/limit value (c) Negligible Minor Minor
Well below objective/limit value (d) Negligible Negligible Minor Where there is an increase in concentrations, the absolute concentration relates to the ‘with development’ air quality. Where there is a decrease in concentrations, the absolute concentration relates to the ‘without development’ air quality. Where concentrations increase the impact is described as adverse and where it decreases as beneficial. Where the impact magnitude is imperceptible (Table 10.7), the impact descriptor is not significant. 3 3 3 (a) Above: >40µg/m annual mean NO 2 or PM 10 , or >25µg/m annual mean PM 2.5 , or >35 days PM 10 >50µg/m 3 3 (b) Just below: 36 – 40µg/m annual mean NO 2 or PM 10 , or 22.5 – 25µg/m annual mean PM 2.5 , or 32 – 35 days 3 PM 10 > 50µg/m 3 3 (c) Below: 30 – <36µg/m annual mean NO 2 or PM 10 , or 18.75 – <22.5µg/m of annual mean PM 2.5 , or 26 – <32 days 3 PM 10 > 50µg/m 3 3 (d) Well below: < 30µg/m annual mean NO 2 or PM 10 , or <18.75µg/m annual mean PM 2.5 , or < 26 days PM 10 >50µg/m 3
10.3.26 The guidance states that the assessment of significance should be based on professional judgement, taking into account the following factors, with the overall air quality impact on the scheme described as either ‘negligible’, ‘minor’, ‘moderate’ or ‘major’:
° Number of properties affected by minor, moderate or major air quality impacts and a judgement on the overall balance;
° The magnitude of the changes and the descriptions of the impacts at the receptors i.e. Tables 10.7 and 10.8 findings;
° Whether or not an exceedence of an objective or limit value is predicted to arise in the study area where none existed before or an exceedence area is substantially increased;
° Whether or not the study area exceeds an objective or limit value and this exceedence is removed or the exceedence area is reduced;
° Uncertainty, including the extent to which worst-case assumptions have been made; and
° The extent to which an objective or limit value is exceeded.
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10.4 Baseline Conditions
Local Air Quality Management
10.4.1 RDC has investigated air quality within its area as part of its responsibilities under the LAQM regime. To date no Air Quality Management Areas have been declared.
Monitoring
10.4.2 RDC operates an automatic monitoring station approximately 1km southeast of the site. HBC also operates an automatic analyser approximately 2.6km to the east. Data from these sites are presented in Table 10.9 .
Table 10.9: Measured Annual Mean NO 2 Concentrations, 2008 - 2012 3 Annual Mean NO 2 Concentration (µg/m ) Location Type 2008 2009 2010 2011 2012
De La Warr R 26.4 21.3 24.8 22.2 25.5 Bulverhythe R 23.9 21.9 24.5 21.7 21.5 Objective 40 R = Roadside Data from the Sussex-air website (www.sussex-air.net/)
10.4.3 Measured nitrogen dioxide concentrations at both roadside automatic monitors have been well below the annual mean objective during the 2008 to 2012 period. There is no particular trend in the concentrations over this period.
10.4.4 Both analysers also monitor PM 10 concentrations; data for the last five years are presented in Table 10.10 . Measured concentrations have been well below the objectives for the last five years, and have remained fairly constant over the period.
10.4.5 There is no local monitoring of PM 2.5 concentrations.
Table 10.10: Measured PM 10 Concentrations, 2008- 2012
3 Number of Days Site Year Annual Mean (µg/m ) 3 >50µg/m 2008 23.6 5 2009 22.5 5 De La Warr Road 2010 22.6 0 2011 24.3 12 2012 24.3 7 2008 26.4 9 2009 27.8 15 Bulverhythe 2010 25.9 8 2011 23.0 21 2012 26.2 10 Objectives 40 35 Reference equivalent data from the Sussex-air website (www.sussex-air.net/)
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Background Concentrations
10.4.6 In addition to these measured and predicted concentrations, estimated background concentrations for the study area in 2012 have been obtained from the national maps provided by Defra (Table 10.11 ). The predicted background concentrations are well below the relevant objectives.
Table 10.11: Estimated Annual Mean Background Concentrations (µg/m 3).
Year NO x NO 2 PM 10 PM 2.5 2012 13.7 – 19.9 10.6 – 14.9 13.6 – 14.7 9.5 – 10.0
Objectives - 40 40 25
Predicted Baseline Concentrations
10.4.7 The ADMS-Roads model has been run to predict baseline nitrogen dioxide, PM 10 and PM 2.5 concentrations at each of the receptor locations identified in Table 10.4 . Table 10.12 sets out the results for the future year baseline scenarios, which have been modelled assuming that the emissions do not reduce in future (2012 emission factors and backgrounds).
10.4.8 The predicted baseline concentrations for all pollutants are well below the relevant objectives at all receptors in 2015 and 2028 without the development. There are no predicted annual mean nitrogen dioxide concentrations which exceed 60µg/m 3, and therefore there are unlikely to be any exceedences of the hourly mean objective at these locations.
Table 10.12: Predicted Baseline Concentrations of NO 2, PM 10 and PM 2.5
NO 2 PM 10 PM 2.5 Annual Mean Annual Mean Number of Days Annual Mean Receptor 3) 3 3 a 3) (µg/m (µg/m ) >50 µg/m (µg/m 2015 2028 2015 2028 2015 2028 2015 2028
R1 12.0 12.1 14.8 14.8 0 0 9.9 9.9
R2 20.3 20.4 19.3 19.4 3 3 13.3 13.4
R3 19.6 19.7 19.2 19.4 3 3 13.2 13.4
R4 12.6 12.6 15.2 15.3 0 0 10.1 10.2
R5 12.3 12.3 15.0 15.0 0 0 10.0 10.0
Objectives 40 40 40 40 35 35 25 b 25 b
a 3 The number of days with PM 10 concentrations greater than 50µg/m have been estimated from the relationship with the annual mean concentration described in Defra, 2009. b The European Union Limit Value of 25µg/m 3 is to be met by 2015.
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10.5 Assessment and Mitigation of Construction Effects
10.5.1 The main potential effects during construction are dust deposition and elevated PM 10 concentrations. The following activities have the potential to cause emissions of dust:
° Site preparation, including erection of fences and barriers;
° Earthworks including foundations and landscaping;
° Materials handling such as storage of material in stockpiles and spillage;
° Movement of construction traffic including haulage, vehicles and plant movements;
° Construction and fabrication of infrastructure and structures; and
° Disposal of waste materials off-site.
10.5.2 Typically the main cause of unmitigated dust generation on construction sites is from demolition and vehicles using unpaved haul roads, and off-site from the suspension of dust from mud deposited on local roads by construction traffic. A small amount of demolition will be required in the westernmost corner of the site to remove the Glover’s Farm buildings.
10.5.3 The main determinants of unmitigated dust annoyance are the weather and the distance to the nearest receptor. Based on the GLA criteria ( Table 10.1 ), the site is classified as medium risk. Overall, the study area is considered to be of low sensitivity ( Table 10.2 ), as there are no residential properties within 20m of the site boundary, there are no designated
sites within close proximity to the site and background concentrations of PM 10 are well below the objective. Based on Table 10.3 , the likely impact of construction dust is not significant, even without mitigation in place.
10.5.4 The wind rose for Shoreham weather station for 2012 (Figure 10.2 , Appendix E.1 ), shows that the dominant wind directions are from the west-southwest. Winds from this direction occur for approximately 14% of the time. There are also significant components from the west, southwest and north.
10.5.5 Wind speeds of moderate strength (3m/s) or greater are required to suspend dust in the air. For approximately 24% of the time the wind speed was less than moderate, below which dust is unlikely to become suspended in the air.
10.5.6 Properties close to the site downwind of the dominant winds are most likely to be affected by construction dust impacts. There are no properties within close proximity downwind of the dominant winds; the closest properties are over 100m upwind of the site and are unlikely to be significantly affected.
10.5.7 A daily rainfall of 0.2mm is considered sufficient to prevent fugitive dust generation. Analysis of rainfall data for the area around the site shows that, over the 30 year period from 1981 to 2010, an average of 41 – 44% of days were ‘wet days’ when there will be natural dust suppression.
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10.5.8 For the majority of the time there will be little potential for dust generation even with no mitigation in place because:
° On approximately 41 - 44% of days the rainfall is greater than 0.2mm when there will be natural dust suppression to minimise emissions of dust;
° In winter months surfaces tend to stay damp for significant periods of time; and
° 24% of the time winds are typically less than moderate strength and would not suspend dust in the air from stockpile and open surfaces.
10.5.9 There may, however, be periods when sufficient dust is generated and crosses the site boundary. This is more likely in the summer months, when higher temperatures evaporate surface moisture more readily.
10.5.10 Predicted baseline PM 10 concentrations at each of the receptors are well below the annual mean objective, with a maximum of three predicted daily mean exceedences of 50µg/m 3 (compared to the permitted 35). As predicted baseline concentrations are low, it is unlikely that the construction activities would cause any exceedence of the objectives.
Mitigation
10.5.11 The likelihood of construction effects can be further minimised through use of the recommended mitigation measures outlined below. The mitigation measures will be included within a Construction Environmental Management Plan (CEMP) to be agreed with the local authority.
10.5.12 Dust control measures should be rigorously applied close to the westernmost site boundary, adjacent to the demolition works and where residential exposure exists within approximately
100m, to reduce the risk of dust complaints and public exposure to elevated PM 10 concentrations. The relevant mitigation measures for medium risk sites from the GLA Best Practice Guidance (GLA, 2006) should be implemented:
Site Preparation:
° No bonfires on site;
° Plan site layout – machinery and dust causing activities should be located away from sensitive receptors; and
° Identify responsible person in charge.
Construction Traffic:
° All vehicle engines should be switched off when not in use;
° Effective vehicle cleaning on leaving site and damping down of haul routes;
° All loads entering and leaving the site should be covered;
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° There should be no runoff of water or mud from the site;
° On-road vehicles should comply with set emission standards;
° All non-road mobile machinery to use ultra-low sulphur tax exempt diesel where available;
° Minimise movement of construction traffic around the site; and
° Impose an appropriate site speed limit.
Demolition Works:
° Use water as dust suppressant;
° Cover skips and minimise drop heights; and
° Wrap buildings to be demolished.
Site Activities:
° Minimise dust generating activities;
° Cover stockpiles to prevent wind generating dust; and
° The local authority must be notified of the use of a concrete crusher and a permit to allow operation must be provided.
Residual Effects
10.5.13 The construction dust impacts are considered not significant.
10.6 Assessment and Mitigation of Operation Effects
10.6.1 Predicted concentrations of NO 2, PM 10 and PM 2.5 in 2015 and 2028, both with and without the proposed development in place (where the development includes the BHLR, NEBGR and all development associated with the BX2 and BX3 allocations), are presented in Tables 10.13 and 10.14 .
10.6.2 Predicted concentrations of all pollutants remain below the objective in both 2015 and 2028, whether the development proceeds or not. This is based on a conservative assessment, whereby it has been assumed that emissions do not reduce in future years (2012 emission factors and backgrounds), and represents a cumulative assessment of the permitted BHLR, the proposed NEBGR, and potential development associated with the BX2 and BX3 allocation sites.
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Table 10.13: Predicted Concentrations of NO 2, PM 10 and PM 2.5 at Existing Receptors in 2015
2015 Baseline 2015 With Development Receptor NO 2 PM 10 PM 2.5 NO 2 PM 10 PM 2.5 Annual Annual a Annual Annual Annual a Annual Days Days Mean Mean Mean Mean Mean Mean R1 12.0 14.8 0 9.9 14.7 18.1 1 12.0 R2 20.3 19.3 3 13.3 20.3 19.2 2 13.3 R3 19.6 19.2 3 13.2 19.6 19.6 3 13.4 R4 12.6 15.2 0 10.1 15.8 19.7 3 13.0 R5 12.3 15.0 0 10.0 14.9 18.5 2 12.2 Objectives 40 40 35 25 b 40 40 35 25 b Annual mean (µg/m 3) and number of days >50 µg/m 3. a 3 The number of days with PM 10 concentrations greater than 50µg/m have been estimated from the relationship with the annual mean concentration described in Defra, 2009. b The European Union Limit Value of 25µg/m 3 is to be met by 2015.
Table 10.14: Predicted Concentrations of NO 2, PM 10 and PM 2.5 at Existing Receptors in 2028
2028 Baseline 2028 With Development Receptor NO 2 PM 10 PM 2.5 NO 2 PM 10 PM 2.5 Annual Annual a Annual Annual Annual a Annual Days Days Mean Mean Mean Mean Mean Mean R1 12.1 14.8 0 9.9 15.3 18.7 2 12.3 R2 20.4 19.4 3 13.4 20.3 19.2 2 13.3 R3 19.7 19.4 3 13.4 19.6 19.6 3 13.4 R4 12.6 15.3 0 10.2 16.2 20.1 4 13.2 R5 12.3 15.0 0 10.0 15.3 18.9 2 12.5 Objectives 40 40 35 25 b 40 40 35 25 b Annual mean (µg/m 3) and number of days >50 µg/m 3. a 3 The number of days with PM 10 concentrations greater than 50µg/m have been estimated from the relationship with the annual mean concentration described in Defra, 2009. b The European Union Limit Value of 25µg/m 3 is to be met by 2015.
10.6.3 The changes in annual mean concentrations and the number of days with PM 10 concentrations greater than 50µg/m 3 are presented in Tables 10.15 and 10.16 . Based on the impact magnitude descriptors presented in Table 10.7 , the changes in concentrations range from imperceptible to medium. Using the criteria set out in Table 10.8 , the impacts
are described as negligible or slight adverse (for annual mean concentrations of PM 10 and
PM 2.5 at R4 in both 2015 and 2028, and PM 2.5 at R5 in 2028).
Table 10.15: Change in Predicted Concentrations Brought about by the Development in 2015
NO 2 PM 10 PM 2.5 Receptor Annual Mean Annual Mean Number of Days Annual Mean (µg/m 3) (µg/m 3) >50µg/m 3 (µg/m 3) R1 2.7 3.3 1 2.1 R2 0.1 -0.1 0 0.0 R3 0.1 0.4 0 0.2 R4 3.3 4.4 3 2.8 R5 2.6 3.5 2 2.2 Changes based on unrounded values.
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Table 10.16: Change in Predicted Concentrations Brought about by the Development in 2028
NO 2 PM 10 PM 2.5 Receptor Annual Mean Annual Mean Number of Days Annual Mean (µg/m 3) (µg/m 3) >50µg/m 3 (µg/m 3) R1 3.2 3.8 2 2.5 R2 0.0 -0.3 0 -0.2 R3 -0.1 0.1 0 0.1 R4 3.6 4.8 3 3.1 R5 3.0 3.9 2 2.5 Changes based on unrounded values.
10.6.4 Overall, the operational impacts of the proposed development are judged to be not significant. This judgement is made in accordance with the guidance set out in paragraph 10.3.26, and takes account of the criteria set out in Tables 10.7 and 10.8 , in particular that the impact of the development on all pollutants is negligible or slight adverse when a conservative assessment is made, assuming no reductions in emissions in future years, and that the proposed development does not give rise to any exceedences of the objectives with concentrations remaining well below the relevant objectives.
Mitigation
10.6.5 The impact of the proposed development is considered to be not significant, therefore mitigation measures for the operational phase of the development are not considered necessary.
Uncertainty
10.6.6 The model used in this assessment is dependent upon the traffic data that have been input which will have inherent uncertainties associated with them. There is then additional uncertainty as the model is required to simplify real-world conditions into a series of algorithms.
10.6.7 A disparity between the road transport emission projections and measured annual mean 17 concentrations of nitrogen oxides and NO 2 has recently been identified . Whilst projections
suggest that both annual mean nitrogen oxides and NO 2 concentrations should have fallen by around 15-25% over the past 6 to 8 years, at many monitoring sites levels have remained relatively stable, or have even shown a slight increase. This is evident in the monitoring data presented in Table 10.9 .
10.6.8 Model uncertainty can be reduced through model verification, in which model outputs are compared with measured concentrations. As the model has been verified and adjusted against 2012 monitoring data, there can be reasonable confidence in the predicted concentrations.
10.6.9 Modelling for 2015 and 2028 has been undertaken assuming emission factors and background concentrations for 2012. This removes the uncertainty associated with future
17 Carslaw, D, Beevers, S, Westmoreland, E and Williams, M, 2011. Trends in NO x and NO 2 emissions and ambient measurements in the UK. Available at: http://uk-air.defra.gov.uk/library/reports?report_id=645.
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year emissions and is likely to lead to an over-prediction of future concentrations and impacts, as improvements in vehicle emissions is likely to occur at some point in the future.
10.7 Summary
10.7.1 The air quality impacts associated with the construction and operation of the proposed Bexhill Enterprise Park have been assessed. RDC has not declared any Air Quality Management Areas and predicted baseline air quality in the area is good.
10.7.2 The construction works have the potential to create dust. Due to the size of the works, and the distance to sensitive receptors, the likelihood of impacts as a result of construction works is considered to be not significant. A range of best practice mitigation measures is, however, proposed to further reduce the likelihood of effects. The residual impacts during construction are judged to be not significant.
10.7.3 The operational impacts of traffic emissions arising from the proposed Bexhill Enterprise Park have been assessed. Traffic data utilised within the assessment include the NEBGR, BHLR, and the BX2 and BX3 allocated sites; consequently the assessment carried out represents an assessment of the cumulative impacts. Concentrations of nitrogen dioxide,
PM 10 and PM 2.5 (very fine particulate matter) have been predicted at five receptors, representing existing residential properties and schools where impacts are expected to be the greatest.
10.7.4 Predicted concentrations of all pollutants are well below the relevant air quality objectives or limit values in 2015 and 2028, whether the proposed development proceeds or not. The impact is judged to be negligible or slight adverse at all receptors, when a conservative assessment is carried out, and overall the impacts are considered not significant. It is concluded that air quality does not provide any constraints to the proposed development.
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10.8 References
Carslaw, D., Beevers, S., Westmoreland, E. and Williams, M. (2011). Trends in NO x and NO 2 emissions and ambient measurements in the UK. Available: http://uk- air.defra.gov.uk/library/reports?report_id=645.
Department of the Environment, Food and Rural Affairs (Defra) (2008). 2010 Based
Background Maps for NO x, NO 2, PM 10 and PM 2.5 . Available: http://laqm.defra.gov.uk/maps/maps2010.html.
Department of the Environment, Food and Rural Affairs (Defra) in partnership with the Scottish Executive, The National Assembly for Wales and the Department of the Environment for Northern Ireland (2009). Local Air Quality Management Technical Guidance, LAQM.TG(09). HMSO, London.
Department of the Environment, Transport and the Regions (DETR, 2007) in Partnership with the Welsh Office, Scottish Office and Department of the Environment for Northern Ireland (2007). The Air Quality Strategy for England, Scotland, Wales, Northern Ireland , HMSO, London.
Environmental Act 1995, Part IV.
Greater London Authority (2006). Best Practice Guidance: The control of dust and emissions from construction and demolition, GLA, London.
Institute of Air Quality Management (2012). Guidance on the Assessment of the Impacts of Construction on Air Quality and the Determination of their Significance .
Statutory Instrument 2000, No 921, The Air Quality (England) Regulations 2000, HMSO, London.
Statutory Instrument 2002, No 3034, The Air Quality (England) (Amendment) Regulations 2002, HMSO, London.
Statutory Instrument 2007, No. 64, The Air Quality Standards Regulations 2007, HMSO, London.
Statutory Instrument 2010, No 1001. The Air Quality Standards Regulations 2010 , HMSO, London
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11 Ecology and Nature Conservation
11.1 Introduction
11.1.1 This chapter has been prepared by Applied Ecology Ltd (AEL) and provides an Ecological Impact Assessment (EcIA) of Bexhill Enterprise Park (BEP). The EcIA has been informed by the findings of ecological baseline survey work undertaken by AEL in 2013, together with a review of existing biological records provided by Sussex Biological Records Centre (SxBRC) and relevant ecological data gathered by other consultants in association with the Bexhill to Hastings Link road (BHLR).
11.1.2 Full details of the 2013 ecology baseline are given in the Phase 1 Ecology Report and Protected Species Survey Report, which are provided in Appendices F.1 and F.2 , respectively. For contextual reasons, the ecology baseline describes a wider area of land than the BEP application site alone and is referred to in this chapter as the ‘ecology study area’. The baseline conditions that specifically relate to the BEP are highlighted where necessary, and have been used as the basis for this assessment.
11.1.3 The habitat baseline used for this EcIA is based on the assumption that land within the BEP that is coincident with the BHLR and/or the North East Bexhill Gateway Road (NEBGR) application areas will be in a post-development condition at the start of BEP construction. Adjustments to the 2013 Phase 1 habitat survey baseline presented in Section 11.4 have therefore been made to reflect the agreed landscape works for the BHLR Landscape and Ecology Management Plan (LEMP; Jacobs, March 2013) and the NEBGR Planting Strategy Plans. It is of note that no BEP development is proposed within the BHLR CPO area and therefore the habitat creation and mitigation outlined in the agreed LEMP will not be compromised. Habitat areas for land within the BEP site but beyond the BHLR and / or NEBGR application areas are based on the results of the 2013 Phase 1 habitat survey.
11.2 Policy Context
International Policy
11.2.1 In May 1992, the UK and other European Union governments adopted legislation to protect Europe’s most important habitats and species. The so called ‘Habitats Directive’ compliments the earlier ‘Birds Directive’ adopted in 1979. At the heart of both Directives is the creation of a Europe-wide network of protected sites, known as Natura 2000. The Birds Directive requires the establishment of Special Protection Areas (SPAs) of ornithological importance, and the Habitats Directive requires Special Areas of Conservation (SACs) to be designated for other animal species, and habitats. Together, both SPAs and SACs make up the Natura 2000 series.
11.2.2 The Habitats Directive was adopted into national legislation in 1994 in the form of the Conservation (Natural Habitats etc.) Regulations 1994. In the UK, all terrestrial Natura 2000 sites are already notified as Sites of Special Scientific Interest (SSSIs). The Conservation of Habitats and Species Regulations 2010 consolidate all the various amendments made to the Conservation (Natural Habitats, &c.) Regulations 1994 in respect of England and Wales.
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National Policy
11.2.3 The Wildlife and Countryside Act 1981 (as amended) provides the main legal framework for nature conservation and species protection in the UK. The Site of Special Scientific Interest (SSSI) is the main statutory nature conservation designation in the UK. Such sites are notable for their plants, or animals, or habitats, their geology or landforms, or a combination of these. Natural England is the key statutory agency in England for advising Government, and for acting as the Government’s agent in the delivery of statutory nature conservation designations.
11.2.4 Designation of a SSSI is a legal process, by which sites are notified under the Wildlife and Countryside Act 1981. The 1981 Act makes provision for the protection of sites from the effects of changes in land management, and owners and occupiers receive formal notification specifying why the land is of special scientific interest, and listing any operations likely to damage the special interest.
11.2.5 The Countryside and Rights of Way Act 2000, and The Natural Environment and Rural Communities (NERC) Act 2006, provide supplementary protected species legislation. Specific protection for badgers is provided by the Protection of Badgers Act 1992.
National Planning Policy
11.2.6 The National Planning Policy Framework (NPPF) was published in March 2012 and replaces previous planning policy guidance (PPS 9) on biodiversity. NPPF states in Chapter 9 paragraph 118 the following in relation to biodiversity and planning:
“When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:
° If significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
° Proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest;
° Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;
° Opportunities to incorporate biodiversity in and around developments should be encouraged;
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° Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss; and the following wildlife sites should be given the same protection as European sites:
° Potential Special Protection Areas and possible Special Areas of Conservation; listed or proposed Ramsar sites; and
° Sites identified, or required, as compensatory measures for adverse effects on European sites, potential Special Protection Areas, possible Special Areas of Conservation, and listed or proposed Ramsar sites.
The presumption in favour of sustainable development does not apply where development requiring appropriate assessment under the Birds or Habitats Directives is being considered, planned or determined .”
Local Planning Policy
11.2.7 The Rother District Local Plan 2006-2011 was adopted in July 2006. All the Local Plan policies have been ‘saved’ by the Secretary of State and will continue to be applied for the purposes of development management until rescinded as and when relevant policies in the new Local Plan (2011-2028) are adopted. All policies apart from Policy DS6 (Managing Housing Release), have been deemed to be compliant with the National Planning Policy Framework by the Cabinet in July 2012. Of these saved policies, the following are of relevance to the proposed development in relation to ecology:
Policy DS1
“In determining whether development is appropriate in a particular location, proposals should accord with the following principles [only those specific policies relevant to nature conservation and biodiversity are listed below]:
(vi) it avoids prejudicing the character and qualities of the environment, particularly the High Weald Area of Outstanding Natural Beauty and undeveloped coastline;
(vii) it protects sites of recognised nature conservation importance, particularly of internationally and nationally important sites, as defined on the Proposals Map;
(ix) it respects the importance of the countryside in terms of its distinct landscape character, natural resources, woodland and agriculture;
(x) it protects ancient woodland from development that would prejudice its ecological and landscape value;
(xii) it protects vulnerable countryside gaps between settlements, as elaborated upon by Policy DS5.”
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Policy GD1
“All development should meet the following criteria [only those specific policies relevant to nature conservation and biodiversity are listed below]:
(vii) It protects habitats of ecological value and incorporates, wherever practicable, features that enhance the ecological value of the site, with particular regard to wildlife refuges or corridors, or fully compensates for any necessary loss.”
11.3 Methodology
Biological Records
11.3.1 Information on statutory and non-statutory wildlife sites, and records of rare and protected species, for land within the BEP and its surrounding area (1km around the study areas centre point and including species records within Ordnance Survey grid squares TQ7308- TQ7509 and TQ7410-TQ7510) were provided by the SxBRC in February 2013.
11.3.2 Surveys have been carried out by other ecological consultants over the period 2005-2012 to inform the BHLR planning application, subsequent licences and to meet monitoring commitments. In some instances these reports include results for land within and/or close to the BEP site and are of relevance to this EcIA. A number of BHLR ecology reports are publicly available on the Rother District Council Planning Portal 18 and further information has been made directly available by the BHLR project team. The relevant findings of these reports in relation to protected species including badger, dormouse, great crested newt and bats have been reviewed and are summarised in the Phase 1 Ecology Report (Appendix F.1) .
Approach to Ecological Impact Assessment
11.3.3 Ecological Impact Assessment (EcIA) is based on a number of factors, primarily consideration of the value of a site or feature being assessed, and the anticipated magnitude of the resulting impact. The Chartered Institute of Ecology and Environmental Management (CIEEM) has produced guidelines to assist with ecological evaluation and impact assessment which have been adapted by AEL and are used only as a general guide in this assessment. The IEEM (2006) guidelines have no legal standing and are not a substitute for professional judgement and interpretation, particularly where the ecological value of a site and/or impact magnitudes are not clear or are borderline.
Valuing Ecological Receptors
11.3.4 Ecological receptors are normally valued according to specific ‘biodiversity benefits’ that they provide to the environment, people or wider society. These benefits can include the conservation of genetic diversity, people’s enjoyment or understanding of biodiversity, or the health benefits of biodiversity. A summary of an approach to valuing ecological receptors is
18 http://www.eastsussex.gov.uk/environment/planning/applications/register/Detail.aspx?appno=RR/ 2474/CC(EIA)&typ=dmw_ planning.
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presented in Table 11.1 . The table shows how ecological value can be ascertained using a combination of statutory measures (legally protected sites and species) and non-statutory but widely accepted measures, such as the presence of notable habitats and species listed in Biodiversity Action Plans (BAP).
11.3.5 Use can also be made of the Ratcliffe assessment criteria which provide a standardised way of assessing and selecting sites with nature conservation value. The method assesses value according to ten attributes, namely size, diversity, naturalness, rarity, fragility, typicality, recorded history, position in an ecological / geographical unit, potential value and intrinsic appeal. All these criteria can vary at different geographical scales.
Table 11.1: An Approach to Valuing Ecological Receptors Level of V alue Examples An internationally designated site or candidate site (SPA, pSPA, SAC, cSAC, pSAC, Ramsar site, Biogenetic Reserve) or an area which NE has determined meets the published selection criteria for such designations, irrespective of whether or not it has yet been notified. International A viable area of a habitat type listed in Annex 1 of the Habitats Directive, or smaller areas of such habitat that are essential to maintain the viability of that ecological resource. Any regularly occurring population of an internationally important species, i.e. those listed in Annex 1, 2 or 4 of the Habitats Directive. A nationally designated site (SSSI, NNR, Marine Nature Reserve) or a discrete area which NE has determined meets the published selection criteria for national designation irrespective of whether or not it has yet been notified. A viable area of a Priority Habitat identified in the UK BAP, of smaller areas of such habitat which are essential to maintain the viability of that ecological National resource. A regularly occurring population of a nationally important species i.e. a priority species listed in the UK BAP and/or Schedules 1, 5 (S9 (1, 4a, 4b)) or 8 of the Wildlife and Countryside Act. A regularly occurring and viable population of a UK Red Data Book species. Viable areas of key habitat identified in local/county BAPs or smaller areas of such habitats that are essential to maintain the viability of that ecological resource. Any regularly occurring, locally significant population of a species listed as being County nationally scarce (occurring in 16-100 10km squares in the UK) or in a relevant local/county BAP on account of its rarity or localisation. Non-statutory designated wildlife sites (e.g. SNCIs, SINCs, WHSs and BHSs), including semi-natural ancient woodland greater than 0.25ha. Network of species-rich hedgerows. Local sites and other sites which the designating authority has determined meet the published ecological selection criteria for designation, e.g. Local Nature Reserves. Local Semi-natural ancient woodland smaller than 0.25ha. Sites/features that are scarce within the district or which appreciably enrich the district habitat resource. Commonplace and widespread semi-natural habitats e.g. scrub, poor semi- Neighbourhood improved grassland, coniferous plantation woodland, intensive arable farmland etc. Less than Habitats of little or no ecological value e.g. amenity grassland or hard standing. neighbourhood
Magnitude of Effect
11.3.6 Effect magnitude refers to changes in the extent and integrity of an ecological receptor. There are many definitions of ecological integrity but the term is used here in the context of
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the definition adopted by the Office of the Deputy Prime Minister Circular 06/2005 on Biodiversity and Geological Conservation whereby designated site integrity refers to “…coherence of ecological structure and function…that enables it to sustain the habitat, complex of habitats and/or levels of populations of species for which it was classified. ” The Circular does not define integrity in relation to non-designated areas, but the principles can equally be applied to such areas. Therefore, for the purpose of this assessment, integrity for non-designated areas is defined as follows: “ the coherence of ecological structure and function, that enables it [the site, habitat or population] to maintain the habitats, complex of habitats and/or levels of populations of species in its/their pre-development condition.” Simplified criteria for describing impact magnitude are summarised in Table 11.2 .
Table 11.2: Simplified Criteria for Describing Impact Magnitude Impact M agnitude Description A large-scale permanent change in the ecological receptor and changes in its High overall integrity. A permanent change in the ecological receptor but no permanent change in its Medium overall integrity. A small-scale permanent change or mid-term temporary change in the Low ecological receptor but its overall integrity is not permanently affected. Neutral No change in the ecological receptor.
Significance of Effects
11.3.7 The predicted significance of the effect is determined through a standard method of assessment based on professional judgement, considering both receptor value and magnitude of change. Combining ecological value, or sensitivity, and effect magnitude gives ecological effect significance. Effects judged to be of major or moderate significance are considered to be ‘significant’ effects in context of the EIA Regulations and would usually require some form of mitigation or compensation. In some cases, such as protected species, there may also be a legal obligation to provide such mitigation.
11.3.8 A matrix for determining the significance of ecological impacts is provided in Table 11.3 . However, the matrix is intended as a guide only and should not to be used without professional judgment to test and refine ratings of significance.
Table 11.3: Matrix for Determining Significance of Ecological Effects Impact Significance Magnitud e of I mpact
Level High Medium Low Neutral International Major Major Moderate No impact National Major Moderate Moderate No impact County Moderate Moderate Minor No impact Local Moderate Minor Minor No impact Neighbourhood Minor Minor Negligible No impact eceptor cological Less than neighbourhood Negligible Negligible Negligible No impact Value of E R
Field Survey
Habitat and Walkover Survey
11.3.9 A Phase 1 habitat mapping survey of the ecology study area was undertaken by AEL on the 7 February 2013. All habitats present were classified and mapped according to standard
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Phase 1 Habitat survey categories (JNCC, 1993). Frequent botanical target notes were made of a representative range of habitats and, where appropriate, a list of the plant species present and an estimate of their individual relative abundance was recorded. Numbered target notes were used to record land areas of typical and unique botanical character, and areas or features too small to map accurately in the field. The habitat map was digitised and presented using a Geographical Information System (ArcView GIS).
11.3.10 In conjunction with the Phase 1 survey, all field boundaries and woodland areas were walked by a second ecologist to record field evidence and incidental sightings of animal species with high levels of conservation importance (by virtue of being protected by wildlife law or subject to Biodiversity Action Plan initiatives) or habitat features of significant potential value in this respect. An initial external inspection of all buildings within the ecology study area was also undertaken to assess their potential suitability for roosting bats.
11.3.11 In the absence of animal field evidence or sightings, a professional judgement assessment of the potential value for animal species was made on the basis of the biological record information, the types of habitat present and their extent, condition and ecological connectivity to the wider landscape.
Reptiles
11.3.12 A seven ‐visit reptile presence / absence survey was completed by AEL over the period 4 April – 5 June 2013 in-line with guidelines provided by the Herpetofauna Groups of Britain and Ireland (HGBI, 1998), as per the current recommendation provided on the Natural England website, as well as advice provided in the more recent Advice Sheet produced by Froglife (1999). A figure showing the reptile survey locations is provided in Appendix F.2 (Figure 2.1 ).
11.3.13 Sixty-six reptile tins were placed out in five areas of rank grass / scrub on 4 April 2013. The refuges were left in situ for one week and were subsequently checked on the 11, 22 and 23 April, 9, 15 and 16 May, and 5 June 2013.
Great Crested Newt
11.3.14 An assessment of all known water-bodies (12 no. in total) located within 500m of the ecology study area has been completed, including a review of existing survey information, combined with visual assessment, Habitat Suitability Index (HSI) calculations and full GCN presence / absence survey, as necessary. A figure showing the locations of these water-bodies is provided in Appendix F.2 (Figure 3.1 ).
11.3.15 Three water-bodies (WB1-3) considered to be suitable for breeding GCN are within the ecology study area (with two of these within the BEP site itself) and have been subject to a four-night GCN presence/absence survey (funnel-trapping, torch survey and egg search) over the period 4 April - 16 May 2013 in accordance with English Nature’s (now Natural England’s) Great Crested Newt Mitigation Guidelines (EN, 2001). These surveys were completed on 4/5 April, 11/12 April and 15/16 April, and 15/16 May 2013.
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11.3.16 Visual inspections, HSI calculations and a single GCN verification trapping visit (if required) was undertaken by AEL on 11/12 April 2013 of four further water-bodies (WB4-7) that are located within 250m of the BEP site. The single verification survey undertaken by AEL in 2013 is considered more than adequate given these water-bodies were discounted from specific survey in 2012 by other ecological consultants (and with Natural England agreement) due to their low Habitat Suitability Index (HSI) scores. The 2013 visual assessment and HSI calculations confirmed the continued low value of these water-bodies.
11.3.17 The remaining ponds (WB8-12) were either found by AEL to be dry and unsuitable for GCN in 2013, or were sufficiently distant (>250m away) from the development to not pose a significant potential risk to GCN, were they to be present.
Breeding Birds
11.3.18 A three-visit breeding bird survey has been completed during the bird breeding season with visits taking place on 24 April, 8 May and 5 July 2013.
11.3.19 No set route was followed during the survey, but all parts of the study area and its boundaries were investigated. The more complex habitats, such as hedges, woodlands, farm buildings and gardens (where bird density and species diversity was likely to be relatively high) were approached closely, generally to within less than 10m. Open field areas, where species typical of these habitats (such as foraging starlings and magpies, and territorial skylarks) could easily be seen from a distance, were walked around their boundaries and viewed with binoculars.
11.3.20 The positions of all bird species seen or heard were marked on large scale field maps, so that after three visits, the numbers, location and extent of species’ territories could be fairly accurately interpreted.
Bats
Roosting Bats
11.3.21 Preliminary visual building inspections of all buildings and structures within the study area were undertaken as part of the initial Phase 1 habitat and walkover survey on the 7 February 2013, with follow-up internal inspections of the Farm House and Hay Barn at Glovers Farm completed on 21 February 2013. An internal inspection of the Hay Barn was also completed on 16 May 2013.
11.3.22 The Farm House and Hay Barn were identified by AEL as being of high bat roost potential, on the basis of their possessing multiple potential bat roost features and the internal presence of bat roosting evidence (i.e. feeding remains and/or bat droppings). Both buildings were surveyed by other consultants in 2012, which confirmed the roost of a single soprano pipistrelle in the Farm House on 13 September 2012 and one common pipistrelle on 26 September 2012. The same surveyors recorded the emergence of three common pipistrelle bats from the Hay Barn on 26 September 2012. The surveyors did not survey either building during the recognised maternity period of May to August.
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11.3.23 The Farm House and Hay Barn at Glover’s Farm have each been subject to three separate after-dark bat emergence and/or return activity surveys during the bat active period (May to September) in 2013 - in accordance with BCT guidelines - in order to confirm the presence/absence of roosting bats, the species concerned and their numbers.
General Bat Activity
11.3.24 Three walking transect surveys have been completed in 2013 with one transect survey undertaken per season in spring (15 May), summer (9 July) and autumn (30 September) to assess levels of bat activity across the study area and build a picture of the habitats that are of greatest value to foraging and commuting bats in relation to proposed development. All three transect surveys were supplemented by the use of nine tripod-mounted bat detectors (Anabat SD2 models) set out in different locations across the study area and set to record over-night during the May and July visits, and for two hours after sunset on the September visit ( Appendix F.2 , Figure 5.2 ).
Dormouse
11.3.25 Fifty dormice nest-tubes were installed in suitable habitat areas across the ecology study area in April 2013 in order to assess dormouse presence / absence. A figure showing the locations of dormice nest-tubes is provided in Appendix F.2 (Figure 6.1) . Checks of the dormouse tubes have been made by AEL on the following dates: 5 June, 5 July, 8 August, 2 September and 4 October 2013.
Badger
11.3.26 An initial badger sett and activity survey of land within the ecology study area was undertaken by AEL on the 20 February 2013, with a site wide badger bait-marking study of five suspected badger groups completed over the period 2-16 April 2013.
11.4 Baseline Conditions
Statutory Wildlife Sites
11.4.1 A figure showing the location of statutory wildlife sites in relation to the ecology study area is provided in the Phase 1 Ecology Report in Appendix F.1 (Figure 3.1 ).
11.4.2 In summary, the closest statutory wildlife site is Combe Haven Site of Special Scientific Interest (SSSI), which is located 550m to the north-east of the ecology study area and 585m to the north-east of the BEP at its closest point. Combe Haven SSSI is a 156.1ha reserve that supports a range of important habitats, including species-rich alluvial meadows, ancient woodland and reed-bed, notably Filsham reed-bed, which is the largest reed-bed in East Sussex .
Non-Statutory Wildlife Sites
11.4.3 A figure showing the location of non-statutory wildlife sites and Ancient Woodland in relation to the ecology study area is provided in Appendix F.1 (Figure 3.2 ). Two non-statutory Sites
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of Nature Conservation Importance (SNCIs) are present within 1km, namely the Disused Railway, Bexhill SNCI (part of which forms the northern boundary to the BEP site), and the Woodland Complex at Buckholt Farm SNCI, which is located 580m north of the ecology study area and 655m north of the Bexhill Enterprise Park.
11.4.4 The Disused Railway, Bexhill SNCI consists of a linear, largely wooded disused railway line, and includes an area of ancient woodland known as Combes Wood. The track bed, cuttings and embankments support a variety of habitats, including secondary woodland, scrub, grassland and tall herb.
Habitats
11.4.5 The Phase 1 Habitat survey map is provided in Appendix F.1 (Figure 4.1 ). A breakdown of the habitat types, their value and coverage is provided in Table 11.4 , and habitat target notes are provided in Appendix F.1 (Appendix 2) .
11.4.6 The ecology study area is dominated by agricultural land (85.5%) of improved grassland (55.7%) and arable land (29.8%). As indicated by Table 11.4 , the majority of the habitats present are of “Neighbourhood” or “Less than Neighbourhood” value. By definition, neighbourhood value habitats are commonplace and widespread semi-natural habitats that may have some, albeit limited, ecological value. They can however provide habitat conditions that are suitable for species with high individual levels of importance by virtue of being subject to Biodiversity Action Plan (BAP) initiatives or legal importance. Habitats defined as less than neighbourhood value typically have little or no ecological value.
Table 11.4: Habitat Types, Value and Coverage within the Ecology Study Area % of Study Habitat Type Value Area (ha) Area Amenity grassland Less than Neighbourhood 0.03 0.1 Arable Neighbourhood 9.80 29.8 Bare ground Less than Neighbourhood 0.21 0.6 Broad-leaved plantation woodland Neighbourhood 0.16 0.5 Broad-leaved semi-natural woodland County 1.67 5.1 Building Less than Neighbourhood 0.47 1.4 Dense bracken Neighbourhood 0.13 0.4 Dense scrub Neighbourhood 0.23 0.7 Improved grassland Neighbourhood 18.30 55.7 Introduced shrubs Neighbourhood 0.01 0.0 Felled plantation woodland Neighbourhood 0.06 0.2 Roads, tracks and hard-standing Less than Neighbourhood 0.99 3.0 Semi-improved neutral grassland Neighbourhood 0.44 1.3 Standing water Neighbourhood 0.02 0.1 Swamp Neighbourhood 0.02 0.1 Tall ruderal Neighbourhood 0.19 0.6 Tall ruderal/dense scrub mosaic Neighbourhood 0.14 0.4 Grand total 32.87 100%
11.4.7 A single habitat type within the ecology study area, broad-leaved semi-natural woodland, has been valued as being of County value on the basis that a large proportion is designated as a non-statutory SNCI, and areas that are not designated are similar in habitat terms and are likely to play a role in the integrity of the SNCI woodland and its associated wildlife.
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11.4.8 The majority of the field boundaries possess relatively intact hedgerows classified and mapped as species-rich hedgerows, including examples both with and without trees. They are typically intact mixed hawthorn Crataegus monogyna and blackthorn Prunus spinosa hedgerows, with some hazel Corylus avellana , elder Sambucus nigra , dog-rose Rosa canina and field maple Acer campestre , and locally mature standard trees of oak Quercus robur.
11.4.9 Dry drainage ditches are present locally in association with hedgerows. A single narrow, wet, un-shaded and spring fed north-south orientated drainage ditch is present in the northern half of the study area.
Invasive Plants
11.4.10 A single patch of the invasive alien plant Japanese knotweed Fallopia japonica is present on the southern boundary of the ecology study area on the northern-side of Wrestwood Road.
Animal Species
11.4.11 The majority of the ecology study area is improved grassland and arable land of limited value to animal species of high individual nature conservation and biodiversity importance. A summary of the desk-top and field survey results relating to protected animal species is provided below. Full details of are provided by the Protected Species Survey Report in Appendix F.2 .
Reptiles
11.4.12 The reptile survey has confirmed the presence of common lizard and slow-worm from three separate locations, two of which (Locations 1 and 2) are located along the southern edge of the disused rail-line and the third (Location 4) is a rank unmanaged area of grassland around agricultural buildings at Glover’s Farm.
11.4.13 Maximum counts for each of these locations were as follows: Location 1 – 6 common lizards and 5 slow-worms; Location 2 – 1 common lizard and 1 slow-worm; and Location 4 – 3 common lizards and 4 slow-worms. Using the combined results, and using standard population size categories, the site supports ‘good’ populations of both common lizard and slow-worm.
11.4.14 It is also of note that a single juvenile grass snake was captured in a funnel-trap in Location 5 on the 15 May during the GCN survey.
Great Crested Newt
11.4.15 The GCN assessment has found no evidence of GCN presence, and this species is considered to be absent from the study area.
Breeding Birds
11.4.16 Forty-two bird species have been recorded within or foraging over the study area. Of these, 37 were either confirmed or thought likely (on the basis of their behaviour) to be breeding
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within the study area in 2013 breeding season. Of those species recorded, but judged not to have bred, whinchat and common redstart were likely to have been passage migrants only; nuthatch appeared to use mature trees beyond the study area’s southern boundary for nesting; rook used the study area only for foraging, and house martin, swallow and common swift hunted in the study area’s airspace.
11.4.17 The species found were entirely common and widespread urban fringe, farmland, hedgerow and woodland birds, typical of the habitats present within and adjacent to the study area.
11.4.18 No unexpected breeding species were found, nor evidence of the presence of rarer species for which the habitats may be judged suitable, such as, for instance, lesser spotted woodpecker, willow and marsh tit, turtle dove, spotted flycatcher and tree sparrow. These species were searched for with special care because of their increasing importance in conservation terms as their UK populations continue to fall sharply.
11.4.19 The only likely Schedule 1 species for which the study area provides suitable and attractive breeding habitat is hobby. This too, was searched and listened for with particular care, but it was not present in 2013.
11.4.20 Barn owl, a Schedule 1 species for which the study area’s buildings were potentially suitable as nesting locations was, nevertheless, considered unlikely to be present owing to the small amount of attractive foraging habitat available. No evidence, past or present, of nesting or roosting barn owl was recorded in any of the buildings at Glover’s Farm during the breeding bird survey or during other ecological surveys. Also, no evidence of the species’ presence in the wider study area was recorded during the breeding bird survey or during the dawn and dusk bat surveys – all undertaken at a time when barn owl would be expected to be seen if present.
11.4.21 The habitats present within the study area are dominated by improved pasture and arable land; both habitats of low relative value to hunting barn owl owing to their unsuitability for abundant small mammals, which form the main prey for barn owl. The study area is therefore considered to be of limited potential value to this species.
11.4.22 No schedule 1 species were recorded during the three survey visits. Seven Species of Principal Importance in England (SPI) / BAP species were recorded with confirmed, probable or possible breeding territories within the survey area. These were:
° Skylark - a single singing bird on territory in arable ground in the south-east of survey area in April. However, very little suitable habitat for nesting skylark was present and it is likely that the speed of growth of the crop, and its height rendered the field unsuitable for nesting skylark in 2013.
° House sparrow – up to 15 pairs were estimated associated with farm buildings and gardens at Glover’s Farm. Twelve pairs were estimated to breed in association with housing along the southern boundary of the survey area. Although the nests of these birds would have been off-site, it was clear that the mature crops nearby within the study area were of high foraging value, with house sparrows observed frequently commuting between the two areas.
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° Dunnock – At least eight territories across the study area, the majority close to Glover’s Farm and along the southern boundary.
° Bullfinch – One territory along a mature hedgerow in the north-east of the study area, and adults attending a nest in tall scrub in the centre of the study area.
° Starling - not confirmed holding breeding territories, but up to two territories likely within the Glover’s Farm buildings complex. Grassland in the study area provided forage for starlings breeding off-site.
° Song thrush – five territories widely spaced within the study area, along the northern and eastern boundaries, and close to Glover’s Farm buildings.
° Linnet – This species was observed frequently in flight but good evidence of breeding was lacking. However, given the scrub and hedgerow habitat present, and the frequency of observation, especially in the southern third of the study area, it was estimated that a large territory holding up to 5 pairs of this species was present in this area.
11.4.23 All species listed as SPI above, are also Red-listed species, apart from dunnock and bullfinch. No other Red-listed species were recorded.
11.4.24 None of the key species found were considered to be of particular significance, all being widespread and still relatively common, notwithstanding their designation as Birds of Conservation Concern, or BAP species.
Bats
Roosting Bats
11.4.25 The Farm House and Hay Barn at Glover’s Farm were considered to be of high potential value for roosting bats, with all other agricultural buildings and structures within the study area being of low value in this respect.
11.4.26 A total of 10 old bat droppings were present as scattered individual droppings on the floor at the western end of the main roof void of the Farm House, along with the discarded wing remains of three tortoiseshell butterflies and two yellow under-wing moths. A total of two old similarly sized bat droppings were present in the accessible east-west oriented roof void at the east end of the same building. The DNA of a representative bat dropping from the roof of the Farm House was analysed by Dr Robin Allaby (University of Warwick) and has verified that it was produced by a brown long-eared bat Plecotus auritus – a common building roosting species of bat known to occur in the local area.
11.4.27 Four fresh bat droppings (also confirmed as BLE by DNA analysis) and a three tortoiseshell butterfly wings were present on a mezzanine floor immediately below the ridge-line within the southern end of Glover’s Farm Hay Barn on 16 May 2013.
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11.4.28 The three repeat emergent and/or return surveys completed at the Farm House and Hay Barn by AEL in 2013 found no evidence of current day roosting bat use at either building. The combined findings of the building inspections and emergence / return surveys confirm very minor historic roosting activity by a brown long-eared bat inside the roof space of the Farm House, and current occasional use of the Hay Barn as a night/feeding roost by an individual brown long-eared bat.
General Bat Activity
11.4.29 The results of the three bat activity transect surveys each show a similar pattern of bat species use and activity with individual commuting and foraging common pipistrelle bats being recorded along both transects, together occasional passes of individual soprano pipistrelle bats. The observed and recorded bat activity was confined to linear habitat features including hedgerows, ditches and woodland edge habitat.
11.4.30 A total of five bat species were recorded by the nine automated detectors during the May survey, with six species recorded in July and September. The species and levels of bat activity are summarised in Table 11.5.
Table 11.5: Results of Automated Bat Detector Surveys Sets of bat calls and proportion of total Bat species May 2013 July 2013 September 2013 (over-night) (over-night) (two-hours after sunset) Common pipistrelle 739 (97.6%) 486 (95.1%) 53 (64.6%) Soprano pipistrelle 14 (1.8%) 9 (1.8%) 13 (15.9%) Myotis species 2 (0.4%) 1 (0.2%) 1 (1.2%) Brown long-eared bat 1 (0.1%) 12 (2.3%) 6 (7.3%) Nathusius’s pipistrelle 1 (0.1%) - 5 (6.1%) Nyctalus species - 2 (0.4%) 4 (4.9%) Serotine bat - 1 (0.2%) -
11.4.31 In summary, the majority of the activity was attributable to common pipistrelle bats followed, by soprano pipistrelles and brown long-eared bat. The most bat activity was typically recorded in association with detectors located close to hedgerows and broad-leaved woodland – a finding consistent with surveyors observation during the transect surveys.
Dormouse
11.4.32 A single unoccupied dormouse nest was recorded in nest-tube no. 24 on the 2 September 2013. This nest-tube is located within an area of broadleaved woodland surrounding the covered reservoir towards the centre of the study area.
11.4.33 No evidence of dormouse presence has been found in any of the hedgerows within the study area or around its boundary.
Badger
11.4.34 The following provides a brief summary of the badger survey findings and does not include confidential information relating to the specific locations of badger setts. The full badger survey results and territory mapping information have been issued and reviewed by Natural
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England as part of a badger sett closure licence application for the NEGBR that has been granted (September 2013).
11.4.35 The results of the badger bait-marking study confirm that two of the suspected main setts (that are located in very close proximity to each other) are actually used by a single badger group and therefore four badger groups (not five) occupy land within the study area. Details of the total territory areas and a summary of the badger setts belonging to each group is provided in Table 11.5 .
Table 11.5: Summary of Badger Survey Findings Badger G roup Total Territory Number and Status of Setts (with Number of associated Area (ha) Entrance Holes) Group A 11.56 Main (30+), Annex (30+), Annex (6), Subsidiary (9), Subsidiary (4), Outlier (1) and a closed sett. Group B 16.85 Main (9), Subsidiary (8+), Subsidiary (5), Subsidiary (4), Subsidiary (4), Outlier (3), Outlier (3), Outlier (2), Outlier (1) and Outlier (1). Group C 15.53 Main (30+), Annex (4), Subsidiary (15), Subsidiary (8), Subsidiary (8), Subsidiary (3), Outlier (1) and Outlier (1). Group D 25.89 Outlier (3), Outlier (3) and Outlier (1).
11.4.36 In summary, the study area supports a high density of badger setts, with all land appearing to be utilised by badgers for foraging. The study area is dominated by improved grassland and arable land, which are considered to be of moderate value as forage habitat, together with arable field margins and track edges which appear to be favoured badger foraging grounds. It is also of note that badgers were being artificially fed by a number of adjoining residential properties, and were seen feeding on sheep finisher pellets stored in agricultural barns at Glover Farm.
11.5 Assessment and Mitigation of Construction Effects
Statutory and Non-Statutory Wildlife Sites
11.5.1 Appropriate drainage and attenuation proposals have been incorporated into the BEP design (see Chapter 14: Water Quality and Drainage) and no direct or indirect adverse effects on Combe Haven SSSI resulting from the construction and operation are predicted.
11.5.2 No direct adverse impacts on the Disused Railway, Bexhill SNCI will occur as a result of the BEP development. However, appropriate permanent barrier fencing will be installed along the northern boundary of the development site where in abuts the disused rail-line SNCI in order to prevent accidental damage during construction (and operational use).
Habitats
11.5.3 BEP construction will result in the loss, damage and disturbance of surface habitats as summarised in Table 11.6. As stated in the introduction, baseline habitat conditions assume that land within the BEP application area that is coincident with the BHLR and NEBGR schemes will be in a post-development and landscaping condition.
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Table 11.6: Habitat Loss Resulting from the BEP Source of B aseline Habitat Loss Proportion of BEP Habitat Type Information due to BEP (ha) Area (%) Phase 1 habitat survey Amenity grassland (AEL 2013) 0.03 0.30 Bare ground As above 0.01 0.10 Building, roads, tracks and hard- As above standing 0.51 5.11 Dense bracken As above 0.03 0.30 Improved grassland As above 6.32 63.26 Introduced shrubs As above 0.01 0.10 Semi-improved neutral grassland As above 0.03 0.30 Swamp As above 0.01 0.10 Tall ruderal As above 0.04 0.40 Rough grassland NEBGR - Planting Plan 0.32 3.20 Grass mix A and B As above 0.01 0.10 Total area of habitat loss - 7.32 73.3 Area of unaffected habitat - 2.67 26.7 Total area of BEP site - 9.99 100
11.5.4 In habitat loss terms, the BEP would result in the loss of 7.32ha of existing / proposed habitat or 73.3% of the total habitat area within the BEP site. The remaining 2.67ha or 26.7% of the BEP site will be unaffected by BEP development and includes land within the BHLR CPO area (1.11ha) and land within the NEBGR application area (1.56ha).
11.5.5 This majority of the habitat loss will be of improved sheep grazed pasture grassland (6.32ha or 86.3% of the total area lost), which is a habitat of Neighbourhood value. All habitats to be directly impacted are valued at Neighbourhood or less than neighbourhood value, and their permanent loss is assessed as a high magnitude impact of negligible to minor adverse significance in overall habitat loss terms.
11.5.6 Mitigation (compensation) for the loss of habitats will comprise new habitat creation as part the of the BEP landscaping works. Details of the landscape proposals are not presented as part of the outlined application, but areas of new landscaping within the BEP development are likely to include species-rich grassland, woodland, and attenuation ponds, and will cover a total area of 1.25ha. If designed to meet ecological objectives, the landscape master-plan for the scheme could result in a minor beneficial residual impact in habitat terms in the long-term.
Invasive Plants
11.5.7 The stand of Japanese knotweed is located well beyond the BEP site and will not be affected by the development. This invasive plant species is not considered further by this assessment.
Animal Species
Reptiles
11.5.8 Reptile survey location 2, which is located along the southern edge of the disused rail corridor immediately north of Glover’s Farm was found to support common lizard (maximum
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count 1 individual) and slow-worm (maximum count 1 individual) and is within the BEP application area. However, it is also within BHLR CPO land area where no BEP development will take place. It will not therefore be affected by BEP development. All other locations within the ecology study area found to support reptiles are outside the BEP application area.
Great Crested Newt
11.5.9 GCN are absent from the BEP and this species is not considered further by this assessment.
Breeding Birds
11.5.10 The assemblage of breeding birds present within the ecology study area (37 breeding species) is assessed as being of Local value using a standard assessment method (Fuller, 1980). The BEP development would result in the loss of mainly improved short sheep grazed pasture which lacks breeding bird interest. The majority of the breeding birds recorded from the Farm Character Area, which is largely coincident with the BEP development site, (see Figure 4.1 , Appendix F.2 ) were associated with Glover’s Farm buildings and surrounds, and hedgerow and woodland boundary habitats and included three SPI / BAP species, namely House sparrow (12 territories), Dunnock (3 territories) and Song thrush (1 territory). The boundary habitats will not be directly affected by the BEP development, but buildings at Glover’s Farm will be lost and will result in a reduction in THE number of associated breeding birds.
11.5.11 The loss of improved grazing pasture and the Glover’s Farm complex as a result of the BEP represents a medium magnitude impact on breeding birds of minor adverse significance .
11.5.12 Mitigation will include timing of habitat removal to ensure it takes place outside the bird nesting season, and would be implemented under the auspices of the CEMP. Compensation in the form of new habitat creation amounting to 1.25ha in total extent, and the provision of bird nest boxes (House sparrow and Swift boxes) on new buildings. These measures would ensure a neutral residual impact on breeding birds.
Badger
11.5.13 The BEP development would result in the direct loss of one nine-hole subsidiary badger sett located at the north-western end of Glover’s Farm. There is also a risk of significant construction related disturbance / partial loss affecting a number of other badger setts that occur close to the BEP boundary. This includes a main badger sett along the southern hedgerow boundary of the BEP. The overall effect of sett loss and disturbance to badger (Local value) represents a medium magnitude impact of minor adverse significance .
11.5.14 Construction of the BEP would also result in a net loss of badger forage habitat as a result of the loss of improved grassland to new buildings and hard-standing. Badger territory loss resulting from BEP can be summarised as follows:
° Group A – Total territory area 11.56ha. Area to be lost 3.24ha (28.0% loss).
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° Group B – Total territory area 16.85ha. Area to be lost 0.01ha (0.1% loss).
° Group C – Total territory area 15.53ha. Area to be lost 6.55ha (42.2% loss).
° Group D – Total territory area 25.89ha. Area to be lost 0.18ha (0.7% loss).
11.5.15 The overall effect of habitat loss on badger Groups A and C in terms of foraging loss (28.0% and 42.2% loss respectively) is considered to be a high magnitude impact of moderate adverse significance . The importance of artificial food sources to badger Groups A and C it difficult to assess, but it is clear that badgers are regularly feeding from an agricultural food store of sheep finisher pellets at Glover’s Farm (they were seen inside the barn feeding on several occasions during the after-dark bat surveys) and are being fed by residents of a number of neighbouring houses. The loss of natural foraging habitat may not therefore result in a high magnitude impact given these alternative food sources.
11.5.16 The effect of habitat loss on Groups B and D (0.1% and 0.7% loss respectively) is not considered significant.
11.5.17 Mitigation , involving the exclusion of badgers from the subsidiary sett north of Glover’s Farm would be undertaken under the auspices of Natural England badger exclusion licence. This would be undertaken over the period July to November, when setts are unlikely to be occupied by dependent young. Construction methods would be adopted to minimise disturbance to setts located beyond but close to the BEP boundary and appropriate stand- offs will be enforced, where appropriate. Any potentially disturbing operations will be supervised under badger disturbance licence, and additional sett closure licences will be applied for and implemented, if necessary.
11.5.18 The CEMP will set out mitigation measures in relation to working in close proximity of badgers and will highlight the fact that all deep excavations would be ramped and any exposed pipework capped during the hours of darkness to minimise the risk of badgers becoming trapped within the construction site.
11.5.19 By closing badger setts under licence in advance of construction, and reducing and managing construction related disturbance and entrapment by adopting appropriate mitigation measures as part of the CEMP, the residual impact of construction on badger could be reduced to one of neutral – minor adverse significance .
11.5.20 Badgers will be prevented from gaining access to the BHLR and NEBGR carriageways through a coordinated badger fencing and tunnel system that will include provision of safe access routes to areas of grassland and woodland within the BEP. Landscape proposals will be developed specifically to maximise the value of new habitat for badger foraging through the creation of predominantly high value short grassland, including valuable edge habitat along new hedgerows, small woodland copses and wetland areas. The residual impact of construction on commuting and foraging badger could be reduced to one of minor adverse significance .
Bats
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11.5.21 The Farm House and agricultural buildings at Glover’s Farm will be demolished as part of the BEP development. The 2013 building inspections and return / emergence surveys have found no evidence of day roosting bats in these buildings or other buildings within the BEP site (or the wider ecology study area). The surveys did confirm the historic use of the Farm House by brown-long eared (BLE) through DNA analysis of old bat droppings in the roof void, and current occasional use of the Hay Barn as a night/feeding roost by an individual BLE bat.
11.5.22 On the basis of the survey results adverse impacts on roosting bats are not anticipated and a European Protected Species (EPS) development licence is not considered necessary. However, given evidence of historic bat use of the Farm House, it is recommended that a precautionary approach to building demolition is adopted, as outline below.
11.5.23 The results of the bat activity transect and automated surveys confirm that the majority of bat activity is confined to hedgerows and woodland edges, with activity dominated by small number of common bat species (Common and Soprano pipistrelles). Using a standard assessment method (Wray et al , 2010) the ecology study area is assessed as being of District, Local or Parish value for commuting and foraging bats.
11.5.24 The BEP development will result in the loss of mainly improved sheep grazed pasture of low relative value for foraging and commuting bats. The hedgerows and woodland, which are of greatest value in this respect, located around the perimeter of the BEP will be retained and protected during construction. However, indirect effects of after-dark lighting of perimeter hedgerows and woodland, together with construction associated noise and dust, could result in a medium magnitude impact of minor adverse significance on commuting and foraging bats.
11.5.25 Mitigation – As highlight above, the demolition of the Farm House and Hay Barn at Glover’s Farm does not need to be completed under the auspices of an EPS licence. However, given the evidence of historic bat use a precautionary approach to demolition of the Farm House will be adopted, including the careful hand removal of all tiles and ridge tiles in advance of demolition. Work would stop immediately if bat(s) are present and advice would be sought from a licenced bat worker.
11.5.26 Alternative roosting opportunities for crevice roosting bats will be provided on new business park buildings either as external bat box units or through integral bespoke design, and /or placement on mature perimeter trees. The value of the BEP site for roosting bats can be enhanced post-development, and the residual impact on roosting bats is assessed as being of minor beneficial significance .
11.5.27 Appropriate mitigation measures, including unlit road sections with bat hop-overs, have been proposed as part of the NEBGR scheme to reduce the negative effects of habitat fragmentation resulting from road construction on commuting and foraging bats. The BEP will result in the loss mainly of improved open grassland pasture (a habitat of low relative value to commuting and foraging bats) and will not result in additional significant habitat fragmentation through severance of linear hedgerow and woodland areas.
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11.5.28 The construction of the proposed development would be carried out during normal working hours from Monday to Saturday. No construction works would be carried out during night- time, therefore lighting impacts during construction would be negligible. Additional measures will however be adopted as part of the CEMP to ensure that construction activity does not affect the value of perimeter habitats for commuting and foraging bats.
11.5.29 In the long-term mitigation in the form of new habitat creation, for example surface water attenuation ponds, new hedgerows and woodland planting will be provided. The residual impact on commuting and foraging bats is considered to be a minor beneficial impact in the medium-term .
Dormice
11.5.30 No habitat of potential value to dormouse is present within the BEP site, and no impacts on this species are anticipated. Dormouse is not considered further by this assessment.
11.6 Assessment and Mitigation of Operation Effects
11.6.1 The potentially significant operational effects resulting from the BEP are: 1) habitat fragmentation 2) increased risk of wildlife (but particularly badger) mortality and injury as a result of collision with road traffic; and 3) disturbance to wildlife through increased light and noise pollution.
11.6.2 The potential operational effects described above could result in moderate adverse effects on wildlife.
11.6.3 Mitigation measures to address the effects habitat fragmentation (i.e. wildlife tunnels, dormouse bridges and bat hop-overs) are proposed as part of the agreed NEBGR and will connect BEP land parcels across the NEBGR.
11.6.4 The increased risk of killing and/or injuring badgers through road traffic collision will be managed by the provision of badger fencing and tunnels to provide safe road crossing points across the Gateway Road for badgers and other wildlife. One-way badger gates will also be provided at regular intervals along the badger fence on both sides of the NEBGR carriageway in order to provide a means of safe escape for any badgers entrapped within the carriageway enclosure.
11.6.5 Additional below ground tunnel crossing points will not be required along the minor roads within the BEP as these will represent a low risk from a badger collisions perspective. However, tunnels and fencing around the BEP roundabout will be designed to ensure badgers are provided with safe crossing points in this location.
11.6.6 A nocturnal wildlife friendly lighting strategy will also be delivered to minimise general adverse impacts on nocturnal wildlife at key locations, in particular along hedgerow and woodland edges, within the BEP. This will include, for example, an appropriate lighting strategy that maintains flight and commuting areas as dark corridors, and reduces noise and dust in sensitive locations.
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11.6.7 The implementation of the above mitigation should result in an overall neutral residual operational effect on wildlife in the long-term.
11.7 Summary of Residual Effects
11.7.1 The BEP would result in 7.32ha of habitat loss constituting mainly improved sheep grazed pasture grassland. This grassland and all other habitats to be directly impacted are valued at Neighbourhood or Less than Neighbourhood value. Compensation for the loss of these low value habitats by new habitat creation (1.25ha in total) could result in a minor beneficial residual impact in habitat terms in the long-term if the landscape master-plan is designed to meet ecological objectives and implemented successfully.
11.7.2 It is important to note that no development is proposed within the area of the BEP site that is coincident within the BHLR CPO land area and therefore the BEP development will not affect the habitat creation and mitigation proposals that are outlined in the BHLR LEMP.
11.7.3 No habitat areas that support reptiles, great crested newt and/or dormice will be affected by the BEP development. Subject to the implementation of suggested and appropriate mitigation and compensation measures, the residual impacts on protected species can be summarised as follows:
° Breeding birds - neutral significance;
° Badger (setts) - neutral – minor adverse significance;
° Badger (commuting and foraging) badger - minor adverse significance;
° Bats (roosting, commuting and foraging) - minor beneficial significance.
11.8 Summary
11.8.1 A 2103 ecology baseline for land incorporating the BEP site has been established through desk-top and comprehensive field surveys, including surveys of habitats, reptiles, great crested newt, breeding birds, bats (roosting and general activity), dormouse and badger (setts and territory mapping).
11.8.2 No impacts on statutory of non-statutory sites are predicted as a result of the BEP development.
11.8.3 The BEP site (9.99ha) is dominated by improved pasture grassland of low habitat and botanical value. Habitat loss resulting from the BEP will amount to 7.32ha, of which 86.3% is improved pasture. All habitats to be lost are assessed as Neighbourhood or Less than Neighbourhood value. The unaffected land area within the BEP site (2.67ha or 26.7%) is land within the BHLR CPO area (1.11ha) and land within the NEBGR application area (1.56ha). It is important to note that no BEP development is proposed within the BHLR CPO area and therefore the habitat creation and mitigation outlined in the agreed LEMP will not be compromised.
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11.8.4 Full details of the landscape proposals are not presented as part of the outlined application, but areas of new landscaping (1.25ha in total) could provide a minor beneficial residual impact in habitat terms in the long-term if designed to meet ecological objectives.
11.8.5 No habitat areas that support reptiles, great crested newt and/or dormice will be affected by the BEP development.
11.8.6 The loss of improved grazing pasture and the Glover’s Farm complex as a result of the BEP represents an impact on breeding birds of minor adverse significance , which can be reduced to a neutral residual impact through appropriate mitigation and compensation measures, including timing of site clearance and provision of nest boxes on trees and buildings.
11.8.7 A single subsidiary badger sett would be lost to BEP, with a risk of construction related disturbance / partial loss potentially affecting a number of other nearby setts. This impact is assessed as being of minor adverse significance , but could be reduced to one of neutral – minor adverse significance by implementing licenced sett closure and a range of appropriate construction related working methods under the CEMP. The loss of badger foraging habitat is assessed as an impact of moderate adverse significance on badger Groups A and C, but could be reduced through appropriate habitat compensation to one of minor adverse significance .
11.8.8 Adverse impacts on roosting bats are not anticipated but a precautionary approach to demolition of the Farm House at Glover’s Farm will be adopted, and new roosting opportunities will be provided as part of future building design. The BEP development will result in the loss of mainly improved sheep grazed pasture of low relative value for foraging and commuting bats, but indirect effects of after-dark lighting of perimeter hedgerows and woodland, together with construction associated noise and dust, could result in an impact of minor adverse significance on commuting and foraging bats. Mitigation to reduce fragmentation has already been proposed as part of the agreed NEBGR, but additional measures (i.e. sensitive lighting strategy and habitat creation) will be adopted as part of the BEP landscape strategy and the CEMP to ensure that the value of perimeter habitats for commuting and foraging bats is enhanced in the long-term.
11.9 References
English Nature (2001) Great Crested Newt Mitigation Guidelines . ISBN 1 85716 568 3.
Froglife (1999) Reptile survey: an introduction to planning, conducting and interpreting surveys for snake and lizard conservation. Froglife Advice Sheet 10. Froglife, Halesworth.
Herpetofauna Groups of Britain and Ireland (1998). Evaluating local mitigation/translocation programmes: Maintaining best practice and lawful standards . HGBI advisory notes for Amphibian and Reptile Groups (ARGs). HGBI, c/o Froglife, Halesworth. Unpubl.
IEEM (2006) Guidelines for Ecological Impact Assessment in the United Kingdom . Approved Version 26 June 2006.
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Jacobs (March, 2013) East Sussex County Council Bexhill to Hastings Link Road – Landscape and Ecological Management Plan . Revision 9, B1297001-PH2/3000.06a/0004.
JNCC (1993) Handbook for Phase 1 Habitat Survey – a technique for environmental audit . JNCC.
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12 Landscape and Visual
12.1 Introduction
12.1.1 This chapter contains a Landscape and Visual Impact Assessment (LVIA) of the Bexhill Enterprise Park. The LVIA was prepared by Influence-cla Limited, a chartered landscape architecture and environmental planning practice.
12.1.2 The scope of this assessment has been determined through Environmental Impact Assessment (EIA) scoping undertaken with the Rother District Council (RDC). It has also been informed by consultation with the statutory consultees, including the RDC and Natural England.
12.1.3 The location of the proposed development is shown in Figure 12.1 , Appendix G.1 of the ES.
Chapter Structure
12.1.4 Section 12.2 identifies and describes legislation, policy and guidance of relevance to the assessment of potential landscape and visual impacts associated with the construction and operational phases of the proposed development.
12.1.5 The assessment of landscape and visual impacts has been undertaken adopting the methodology described in Section 12.3 .
12.1.6 The existing baseline conditions, against which the likely environmental impacts of the proposed development are assessed, are described in Section 12.4 .
12.1.7 Section 12.5 assesses landscape and visual impacts associated with the construction of the proposed development in isolation and the cumulative effect with the construction of the BHLR and NEBGR, and identifies the appropriate mitigation measures aimed at preventing, reducing or off-setting potential adverse impacts during the construction phase.
12.1.8 Section 12.6 assesses landscape and visual impacts associated with the operation of the proposed development and identifies the appropriate mitigation measures aimed at preventing, reducing or off-setting potential adverse impacts during the operational phase.
12.1.9 Cumulative impacts arising from the proposed development in combination with other relevant developments are identified and assessed in Section 12.7 .
12.1.10 Section 12.8 provides a summary of residual effects followed by a general summary of the LVIA in Section 12.9 .
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12.2 Policy Context
12.2.1 A summary of general planning policy relevant to the proposed development is provided in Chapter 6 of this ES. This section focusses on legislation, planning policy and guidance related to the LVIA. The relevant designations and policy allocations are shown in Figure 12.3 , Appendix G.1 of the ES. Full citations of the policies relevant to this LVIA can be found in Appendix G.2 .
International Legislation
12.2.2 The European Landscape Convention (ELC), which was signed by the UK in February 2006 and became binding in 2007, is the first international convention to focus specifically on landscape issues and aims to protect, manage and plan landscapes in Europe. The ELC “highlights the importance of developing landscape policies dedicated to the protection, management and creation of landscapes, and establishing procedures for the general public and other stakeholders to participate in policy creation and implementation.” (CoE, 2004)
12.2.3 The ELC defines landscape as “an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors.” (CoE, 2004)
National Legislation
12.2.4 This LVIA takes into account the legislation and policy relevant to landscape and visual amenity, ecology and cultural heritage as stated in Guidelines for Landscape and Visual Assessment (GLVIA):
“It is important for landscape assessments to consider the ecological, historical or cultural associations that contribute to the character and importance of a landscape”; and
“Planning policies for nature conservation and landscape are generally linked through a common approach to land use….there are also numerous interrelationships between landscape and cultural heritage and it is important that these links are not overlooked.” (LI and IEMA, 2002)
12.2.5 In accordance with best practice guidance, this assessment takes into account legislation and policy relevant to landscape and visual amenity, ecology, cultural heritage and transport matters. Reference should also be made to Chapter 8 (Transport and Access), Chapter 11 (Ecology and Nature Conservation) and Chapter 15 (Cultural Heritage) for details on policies related to ecological, transport and historic assets.
Countryside and Rights of Way (CRoW) Act 2000
12.2.6 The CRoW Act (UK Parliament, 2000) provides a statutory framework for Areas of Outstanding Natural Beauty (AONB), provides further measures to protect the AONBs, and clarifies the role of local authorities which now includes the preparation of Management Plans to set out how they will care for their AONBs.
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National Parks and Access to the Countryside Act 1949 as Amended by the Environment Act 1995
12.2.7 Areas of Outstanding Natural Beauty (AONB) are designated under the provisions of the 1949 National Parks and Access to the Countryside Act (UK Parliament, 1949), in order to secure their permanent protection against development that would damage their special qualities. AONBs are designated solely for their landscape qualities, for the purpose of conserving and enhancing their natural beauty.
Hedgerow Regulations 1997
12.2.8 The Hedgerow Regulations (UK Parliament, 1997) aim to protect hedgerows, which play an important role in supporting and enhancing biodiversity, as well as defining the character of English countryside.
12.2.9 According to the regulations, a hedgerow is important if it has existed for 30 years or more and it satisfies various wildlife, landscape or historical criteria specified in the regulations.
National Policy
12.2.10 The Government published the National Planning Policy Framework (NPPF) on 27 th March 2012. The NPPF has been created in order to replace Planning Policy Statements (PPS) and Planning Policy Guidance (PPG) documents. The NPPF condenses and clarifies the Governments previous Planning Policies and provides a legislative framework for promoting sustainable development in local communities.
12.2.11 LPAs should seek to achieve each of the economic, social and environmental dimensions of sustainable development. The NPPF defines the environmental dimension as: “contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, pollution, and mitigate and adapt to climate change including moving to a low carbon economy.” (DCLG, 2012)
12.2.12 The NPPF proposes that development that accords with an up-to-date Local Plan and is sustainable should be approved and development that conflicts with the Local Plan or is not sustainable should be refused unless other material considerations indicate otherwise.
12.2.13 The NPPF sets out 12 core planning principles that should underpin both plan-making and decision-taking. The NPPF emphasises that the planning system should take account of the differing roles and character of areas and recognise the intrinsic character and beauty of the countryside to support a thriving rural community. It also stresses the importance of high quality design and providing good standard of amenity, contributing to conserving and enhancing the natural environment, and promoting mixed use developments.
12.2.14 A summary of the key objectives of the NPPF is set out in Chapter 6 of the ES.
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Local Policy
12.2.15 The proposed development is subject to policies within the Rother District Local Plan Adopted in 2006.
12.2.16 This LVIA takes account of the following Rother District Local Plan policies:
° Policy DS1: Development Strategy – this policy requires developments to: protect the character and qualities of the environment, in particular the High Weald AONB, protect sites of recognised nature conservation importance as shown on the Proposals Map, respect the importance of the countryside in terms of its distinct landscape character, natural resources, woodland and agriculture, and protect ancient woodland from development that would prejudice its ecological and landscape value;
° Policy GD1: General Development – this overarching development policy requires that all development should: respect and do not detract from the character and appearance of the locality, including heritage assets, be compatible with the conservation of the AONB, respect the topography, important views to and from the site, retain site features that contribute to the character or amenities of the area, and protect and enhance habitats of ecological value;
° Policy BX1: Bexhill – proposals for development in Bexhill should maintain and enhance the town’s distinctive character, identity and amenities;
° Policy BX2: Bexhill – this policy states that land north of Pebsham, including Worsham Farm and Glovers Farm, as defined on the Proposals Map, is allocated for a mix of housing, business and related uses. The development should be contained within a generous landscape framework, and a local distributor road shall form the northern edge of built development and shall be laid out as a wide “country avenue”, contained to the north by a strong landscape tree belt;
° Policy BX3: Bexhill – proposals for structural open spaces, landscape and woodland belts shall be developed and implemented as an integral part of development proposals, the proposed local distributor road should be integrated into the Green Links shown on the Proposals Map; and
° Policy BX4: Bexhill – this policy states that within the area shown as Countryside Park on the Proposals Map, proper conservation and, where appropriate, management of the Site of Special Scientific Interest (SSSI) and the Site of Nature Conservation Importance (SNCI) should be provided.
12.2.17 Full citations of the above policies are provided in Appendix G.2 .
12.2.18 The ‘saved policies’ of the Local Plan remain material consideration for this application until they are replaced by relevant policies in the new local plan (2011-2028). The Core Strategy will be the key policy document within the new Local Plan. It sets out the overall vision and objectives that will guide the future pattern and form of development in the district to 2028.
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The Proposed Submission Core Strategy has been submitted to the Secretary of State for Examination.
Other Documentation
12.2.19 The North East Bexhill Supplementary Planning Document (SPD) (RDC, 2009) provides planning guidance on the development in North East Bexhill. It sets the planning context for the future development, provides site analysis, including local landscape character, sets out objectives and principles for the development, and identifies the implementation programme.
12.2.20 The SPD sets out the key design principles that should apply for the new development within BX2 and BX3 allocations:
° To create an identifiable sense of place – i.e. by responding to site topography, retaining long public views, protecting and adding to the significant pockets of woodland (especially in elevated, ridge locations), retaining hedges/tree lines, framing development areas, incorporating significant distinctive “green space” and allowing easy access to development with a well-defined, landscaped northern urban edge;
° To integrate with its wider environment – i.e. by maintaining and improving access to the countryside in conjunction with development of the Countryside Park; and
° To develop a contemporary, sustainable and safe place – i.e. by enhancing existing habitats, notably ecologically rich woods, hedgerows and ponds, and assessing design approaches in terms of: character and landscape design.
Relevant Guidance
12.2.21 The Department for Communities and Local Government (DCLG) and the former Countryside Commission (CC) guidance on lighting, ‘Lighting in the Countryside: Towards Good Practice’ (DCLG and CC, 1997) provides advice on developing lighting mitigation strategies, lighting design and how to mitigate adverse impacts associated with lighting on landscape and visual amenity.
12.2.22 Guidance relevance to the landscape and visual impact assessment and landscape character assessment is referred to in Section 12.3 , below.
12.3 Methodology
12.3.1 The LVIA and supporting studies were undertaken for both construction and operational phases of the development, in accordance with the principles set by the Landscape Institute and Institute of Environmental Management and Assessment in the ‘Guidelines for Landscape and Visual Impact Assessment’ (LI and IEMA, 2002) and guidance on Landscape Character Assessment produced by the Countryside Agency (now Natural England) and Scottish Natural Heritage (CA and SNH, 2002). The LVIA conforms with the guidance and recommendations set out in the 3 rd Edition of the GLVIA published in April 2013 (LI and IEMA, 2013).
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12.3.2 Viewpoint photographs have been prepared in accordance with the LI’s Advice Note 01/11 ‘Photography and photomontage in landscape and visual impact assessment’ (LI, 2011).
Study Area
12.3.3 The LVIA study area defines the geographic extent of the landscape and visual impact assessment of the proposed development.
12.3.4 The LVIA study area has been defined through a staged process which has included desk study, Zone of Theoretical Visibility (ZTV) analysis, modelling and field survey, including verification and refinement of ZTV results. Consultation has also been undertaken with the RDC on the extents of the LVIA study area.
12.3.5 The ZTV analysis was initially undertaken at 15km radius from each the proposed buildings (cumulative analysis) within the site to identify all areas of potential (theoretical) visibility of the proposed development. Following the analysis of Ordnance Survey (OS) mapping at a range of scales, field surveys and consultation, this area was refined to exclude areas from where the proposed development would not be visible or was judged not to have a potential to cause significant landscape and visual impacts - due to the screening provided by landform, vegetation or urban form, or distance from the proposed development, or combination of some of these factors.
12.3.6 The final LVIA study area identified for the purpose of this LVIA is shown in Figure 12.2 , Appendix G.1 of the ES. It extends to roads A259 and B2182 in the south covering north- east fringes of the Bexhill urban area and in the west it is set along Watermill Lane. To the north, it contains the southernmost edge of the High Weald Area of Outstanding Natural Beauty (AONB) defined by Ballards Hill Road, south of the village of Crowhurst. In the east, the LVIA study area extends to A259 and a railway line running along the urban edge of Hastings.
12.3.7 It should be noted that an assessment of landscape and visual impacts typically requires a study area that is larger than the one for other environmental disciplines, as it is defined by the potential visibility of a scheme, which can cover areas extending many miles away.
Landscape Baseline
12.3.8 The landscape resource within the LVIA study area has been assessed and principal features and characteristics have been identified through both desk study and field work. Key activities during the landscape baseline data collection included:
° Desk study of landscape designations and relevant nature and heritage designations;
° Desk study of national landscape character to understand the broad landscape context for the proposed development;
° Desk study of local character assessments to gain a detailed understanding of the landscape character and quality context and to identify local character areas to be brought forward for the assessment;
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° Field work to verify the desk study of national and local landscape character assessment and to confirm the physical components, key elements and structure of the landscape within the site and its surroundings up to 0.5km of the site boundary; and
° Assessment of sensitivity of the relevant landscape receptors.
Landscape Sensitivity
12.3.9 The determination of landscape sensitivity is an important part of the landscape and visual impact assessment process. Sensitivity combined with the potential magnitude of impact allows assessment of the overall significance of the landscape impacts to be made.
12.3.10 According to the GLVIA, the sensitivity of the landscape resource is described as “The degree to which a particular landscape type or area can accommodate change arising from a particular development without detrimental effects on its character.” (LI and IEMA, 2002) The overall sensitivity of the existing landscape resource depends on:
“Existing land use;
The pattern and scale of the landscape;
Visual enclosure/ openness of the views, and distribution of visual receptors;
The scope for mitigation, which would be in character with the existing landscape; and
The value placed on the landscape.” (LI and IEMA, 2002)
12.3.11 In addition to the above list of considerations, GLVIA also considers that sensitivity of the landscape resource is based on evaluation of factors such as quality, value, contribution to landscape character and degree to which elements can be replaced or substituted.
12.3.12 The quality of a landscape receptor is determined using the criteria defined in Table 12.1 .
Table 12.1: Landscape Quality Quality Description Distinctive, unique or outstanding natural landscape character, including significant degrees of amenity and tranquillity. - Strong landscape structure, characteristic patterns and balanced combination of landform and land cover. Exceptional Appropriate management for land use and land cover. Distinct features worthy of conservation. No detracting features. Sense of place. Internationally or Nationally recognised e.g. all or great majority of World Heritage Site and/or National Park and/or AONB. Strong landscape structure, characteristic patterns and balanced combination of landform and land cover. Appropriate management for land use and land cover, but potentially scope to improve. High Distinct features worthy of conservation. Occasional detracting features. Sense of place. Nationally recognised e.g. localised areas within National Park and/or AONB.
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Quality Description Strong landscape structure, characteristic patterns and balanced combination of landform and land cover. Appropriate management for land use and land cover, but potentially scope to improve. Good Distinct features worthy of conservation. Occasional detracting features. Sense of place. Nationally recognised e.g. localised areas within National Park and/or AONB. Distinguishable landscape structure, characteristic patterns and combinations of landform and land cover often masked by land use. Ordinary Scope to improve management for land use and cover. Some features worthy of conservation. Prominent detracting features. Weak or degraded landscape structure, characteristic patterns of landform and land cover often masked by land use. Poor Mixed or single land use dominates and/or is evident. Lack of management and intervention has resulted in degradation and disturbed or derelict land which could require treatment.
12.3.13 Evaluation of value or importance often refers to policy or designations as an indicator. Importance relates to the contribution of the landscape elements/features, character or views within the local area and is a factor of its scenic quality, condition, sense of place, visibility, accessibility and special qualities such as remoteness. Not all characteristics are uniformly spread throughout designated landscapes so the importance of the site is considered within the designated area.
12.3.14 For assessment purposes, the sensitivity of a landscape receptor is based on the application of the above criteria, informed by existing landscape character assessment studies, field surveys undertaken by landscape professionals, professional judgement of the assessor and consultation.
12.3.15 Table 12.2 describes the criteria used to establish the potential sensitivity of landscape receptors categorised as high, medium or low.
Table 12.2: Landscape Sensitivity Sensitivity Criteria A landscape of particularly distinctive character and high or exceptional scenic quality. High Nationally and regionally designated landscape for its scenic quality and character, such as an AONB or National Park. A landscape of moderately distinctive character and scenic quality. Medium Locally designated landscape for its scenic quality and character. A landscape of no distinctive character and scenic quality or is damaged, neglected Low or poor character and lacking scenic quality. A landscape not subject to any form of landscape designation.
12.3.16 By way of an example, a landscape that is nationally designated, such as an AONB, is regarded as being the most sensitive to change. A landscape that is relatively intact, of some scenic quality, and locally designated would be judged to be of medium sensitivity. A landscape that is neglected and damaged, or lacking scenic quality, such as a brownfield site, might be judged to be of low or very low sensitivity.
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Visual Baseline
12.3.17 Key activities during the visual baseline data collection included:
° Preparation of a ZTV, an area from which part or all of the proposed development is theoretically visible;
° Desk study to identify visual receptors within the LVIA study area relevant to the assessment and potential representative viewpoints locations;
° Field survey to review the theoretical visibility and establish the actual visibility, relevant visual receptors, and a selection of representative viewpoints to gain a detailed understanding of the visual context for the proposed development; and
° Assessment of sensitivity of the relevant visual receptors.
12.3.18 Representative viewpoints have been selected on the basis of locations that represent various receptor types (such as a group of residential properties) in close proximity to each other. To ensure that selected viewpoints represent the ‘worst-case scenario’ view for a given receptor, viewpoints were selected which provide the clearest views of the proposed development (e.g. because of their proximity to the proposed development or the absence of visual barriers between the viewpoint and the proposed development) and which are also the most accessible to the public.
12.3.19 A total of 10 representative viewpoints were selected as shown in Figure 12.7 , Appendix G.1 of the ES. Initial baseline photographs illustrating views from a series of viewpoints were taken using a Nikon D3100 digital camera, set to the equivalent of a 35mm focal length, which is the equivalent of 50mm film camera lens (equivalent of human eye). Where viewpoints consisted of more than one frame, the relevant frames were merged together using Photovista photo-stitching software (version 2.0).
12.3.20 For the purpose of the assessment two viewpoints were selected to illustrate night views and existing baseline lighting conditions within the LVIA study area.
12.3.21 The viewpoint panoramas were scaled according to the Advice Note 01/11 from the Landscape Institute, Photography and Photomontage in Landscape and Visual Impact Assessment (LI, 2011). The photographs have been reproduced in Figures 12.8.1 – 12.8.10 , Appendix G.1 of the ES.
12.3.22 The photographs were taken in winter and show the ‘worst-case scenario’ (views with minimal foliage). The representative viewpoints illustrating the potential visibility of the proposed development were selected from the views agreed with the RDC for the NEBGR application submitted in May 2013.
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Visual Sensitivity
12.3.23 Visual sensitivity is established in relation to visual receptors. Visual receptors are interest or viewer groups that may experience an effect arising from the proposed development. According to GLVIA, the sensitivity of visual receptors depends on:
“The location and context of the viewpoint;
The expectations and occupation or activity of the receptor; and,
The importance of the view (which may be determined with respect to its popularity or numbers of people affected, its appearance in guidebooks, on tourist maps, and in the facilities provided for its enjoyment and references to it in literature or art).” (LI and IEMA, 2002)
12.3.24 The sensitivity of each viewpoint is categorised as high, medium or low, as described in Table 12.3 .
Table 12.3 Visual Sensitivity Sensitivity level Criteria Viewers with a proprietary interest, specific interest in the view and prolonged viewing opportunities. Examples include occupiers of residential properties, visitors to tourist attractions, people using recreational facilities such as High National Cycle Routes or National Trails, and designated long distance footpaths, users of PRoWs or viewpoints in nationally or locally designated landscapes. Viewers with a moderate interest in their surroundings such as users of Medium schools, users of outdoor recreational facilities where landscape appreciation is unlikely to be a primary motive, local viewpoints, users of local PRoW. Viewers with a passing interest in their surroundings such as road or other Low transport users, people at their place of work.
12.3.25 By way of an example residential receptors are generally considered to be the most sensitive receptor group owing to their propriety interest and their prolonged exposure. Recreational receptors such as people engaged in outdoor sports are considered of medium sensitivity although recreational receptors whose attention or interest is focused on the landscape may also be considered to be highly sensitive.
12.3.26 The least sensitive groups are those with no interest in their surroundings or those that are already affected by similar types of visual impact to that arising from the proposed development or those who have only a passing interest in the surroundings, such as motorists on a busy motorway.
12.3.27 For each of the representative visual receptors used in the assessment, a range of visual receptor types may be represented. In all cases the highest sensitivity will be taken forward to the assessment of significance.
12.3.28 For assessment purposes, the sensitivity of representative visual receptors is based on the application of the above criteria, informed by field surveys undertaken by landscape professionals and based on the professional judgement of the assessor.
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Assessment of Landscape and Visual Impacts
12.3.29 The approach to assessing and describing the impacts on landscape and visual receptors is similar to that used for other environmental topics in this ES and is based on determining impact significance through consideration of the potential magnitude of change in relation to the sensitivity of a particular receptor. As such, this LVIA is similar to the overall assessment approach set out in Chapter 5 of the ES.
12.3.30 According to GLVIA, the magnitude of impacts is a “combination of the scale, extent and duration of an effect.” (LI and IEMA, 2002) The magnitude of landscape and visual impacts are judged separately using the criteria set out below.
Magnitude of Landscape Impacts
12.3.31 The potential magnitude of the landscape impacts is assessed taking into account each phase of the development and any proposed mitigation. The magnitude of the landscape impact depends upon the following factors:
° The scale of degree of change to the existing landscape resource;
° The nature of the change caused by the proposed development (beneficial or adverse); and
° The timescale or phasing of the proposed development.
12.3.32 Table 12.4 describes the criteria used in the assessment of magnitude of landscape change.
Table 12.4: Landscape Impact Magnitude Magnitude Criteria The proposed development would form a prominent landscape element, or High would result in a substantial alteration to key landscape characteristics. The proposed development would form a conspicuous landscape element, or would result in a partial loss of or alteration to key landscape characteristics. Medium The cumulative effect of such issues may lead to an increase in the overall effects on a particular area or receptor. The proposed development would be a barely perceptible landscape element, Low or would result in a very minor alteration to landscape characteristics. The proposed development would be barely perceptible landscape element, Negligible or is appropriate in its context.
Magnitude of Visual Impacts
12.3.33 For each of the viewpoints the potential magnitude of the residual visual impact is assessed, taking into account each phase of the development and proposed mitigation. The magnitude of visual impacts depends on the following factors:
° The scale of change or proportion of the existing view that would change as a result of the proposed development;
° The loss or addition of features or elements within the view;
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° The degree of contrast or integration of the proposed development with the existing or remaining landscape elements and characteristics within the view;
° The nature and duration of the impact and whether it is temporary or permanent, continuous or intermittent;
° The angle of the view in relation to the main activity of the receptor; and
° The distance of the viewpoint from the proposed development.
12.3.34 The magnitude of impact is categorised as high, medium, low or negligible, as described in Table 12.5 .
Table 12.5: Visual Impact Magnitude Magnitude Criteria The development would form a prominent element within the view, resulting in High a prominent change to the quality and character of the view. Standing out, striking. The development would form a conspicuous element within the view, resulting Medium in a conspicuous change to the quality and character of the view. Noticeable, distinct, clearly visible, well defined. The development would form an apparent small element within the view, Low without significantly affecting the overall quality and / or character of the view. The development would result in a barely perceptible change in the view, or Negligible would cause a ‘no change’ situation to the existing view. Weak, not legible, near limit of acuity of human eye.
Nature and Duration of Impacts
12.3.35 The nature of impacts contributes to the assessment of magnitude of landscape and visual impacts.
12.3.36 The LVIA considers whether the landscape and visual changes that would arise as a result of the proposed development would be beneficial or adverse. An adverse impact is one that introduces a new, discordant or intrusive element to the landscape character or view. A beneficial impact would be from an overall improvement to the view through the removal of existing discordant features and replacement with features of similar scale to those in the surrounding landscape or view.
12.3.37 With regard to the duration of landscape and visual impacts, short to medium-term impacts are normally considered to be temporary and associated with the construction of the proposed development, and long-term impacts are normally associated with a fully occupied and operational scheme. Permanent impacts are those which result in an irreversible change to baseline conditions or will last for the foreseeable future.
12.3.38 The duration of landscape and visual impacts is typically categorised as follows:
° Short-term – Up to 5 years;
° Medium-term – 5 years to 15 years;
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° Long-term – Greater than 15 years;
° Temporary – Impacts usually associated with construction activities and with an early operational scheme, when proposed landscaping has not established yet; and
° Permanent – Impacts associated with a fully operational scheme (including established planting).
12.3.39 For more details on types of impacts (direct, indirect primary, secondary, cumulative and residual) assessed in this LVIA see Chapter 5 of the ES.
Assessment of Significance
12.3.40 Impact assessment refers to the change that is predicted to take place to the existing condition of the environment as a result of the proposed development.
12.3.41 The potential significance of landscape and visual impacts is determined by a combination of the magnitude of the potential impact and the sensitivity of the landscape and visual setting to change. These two variables can be correlated as illustrated in Table 12.6 .
Table 12.6: Principles of Assessing Significance of Landscape and Visual Effect Impact Magnitude Significance High Moderate Major Severe Medium Minor Moderate Major Low Not Significant Minor Moderate Negligible Not Significant Not Significant Not Significant Low Medium High
Receptor Sensitivity
12.3.42 The assessment of significance ultimately relies on professional judgement and interpretation, particularly when sensitivity or impact magnitude levels are not clear or are borderline between categories, although comparing the extent of the impact with criteria and standards specific to the landscape and visual resource can guide this judgement.
12.3.43 Table 12.7 provides a brief definition of the significance criteria which are specific to landscape and visual impact assessment and are in accordance with the overall EIA sensitivity criteria outline in Chapter 5 of the ES.
Table 12.7: Landscape and Visual Significance Criteria Significance Criteria Long-term or irreversible change of high magnitude in landscapes of national Severe or regional importance of exceptional value, or in views within such areas. Very important or substantial change in landscapes of local or district Major importance, or views experienced by sensitive visual receptors. Moderate Noteworthy or medium change in local landscape and visual conditions. Minor Inconsiderable or small change in local landscape and visual conditions. No discernible change in landscape and visual conditions. No effect or effect Not Significant which is beneath the level of perception, within normal bounds of variation or within the margin of forecasting error.
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12.3.44 When it is determined that the construction activities or proposed development will not actually be visible from a particular view there will be no significance. The result of combining the sensitivity with magnitude will, therefore, be ‘no impact’.
Cumulative Impacts
12.3.45 This LVIA assesses cumulative impacts on landscape and visual receptors as a result of the proposed development and other consented developments within the LVIA study area.
Assumptions and Limitations
12.3.46 Key assumptions and limitations for this LVIA are summarised below:
° Landscape and visual baseline surveys that form the basis of this assessment were carried out in March 2013.
° Both the BHLR and NEBGR are treated as committed developments for the purposes of the EIA. The construction of both roads is assumed to commence in 2013 and complete in 2015.
° The assessment of construction impacts is based on up to 2 years construction programme for the proposals (phased delivery subject to subsequent reserved matters applications).
° The effects of the operation of the Bexhill Enterprise Park are assessed based on the assumption that it is fully occupied and that the proposed planting has begun to mature and its height has been estimated at approximately 6m (woodland planting) to 8m (pre- grown specimen trees).
° The assessment of operational and cumulative effects assumes the construction of the BHLR and NEBGR is complete, and therefore both proposed roads are included in the landscape and visual baseline for these scenarios.
° It is assumed that any future development on the land allocated under BX2 and assessed in cumulative section would follow the principles of good design and would contain their own landscape and visual mitigation strategies, consistent with the requirements set out in the Local Plan and North East Bexhill SPD.
12.4 Baseline Conditions
Introduction
12.4.1 This section describes the landscape and visual baseline environmental conditions within the LVIA study area. All relevant designations are shown in Figure 12.3 , Appendix G.1 of the ES.
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Landscape Baseline
Designations
12.4.2 There are no national or local landscape designations within the site. However, the LVIA study area falls within a narrow strip of the southern fringe of High Weald AONB, which is a national landscape designation.
12.4.3 A Site of Special Scientific Interest (SSSI), which is a nationally designated area of nature interest, is located approximately 0.6km to the north-east of the site and extends farther to the east. There are no other nationally designated landscape, nature or heritage designations within the LVIA study area.
12.4.4 There are several local policy designations within the LVIA study area which are shown on the Proposals Map of the Adopted Rother District Local Plan 2006. They include:
° Proposed Countryside Park – located north of the dismantled railway embankment adjacent to the northern site boundary. The park covers the eastern part of the site and extends farther to the east.
° Proposed Open Space – a relatively small area located adjacent to the dismantled railway embankment to the north of the site.
° A local Site of Nature Conservation Importance (SNCI) running along the dismantled railway and partially located within the northern part of the site.
° Local Nature Reserve (LNR) located adjacent to the Hastings urban area in the eastern part of the LVIA study area.
° Pockets of Ancient Woodland within the LVIA study area (no Ancient Woodland within the site).
° Existing and Proposed Landscape Belts located partially within the site and in the surrounding local landscape.
° Proposed Green Links located north-west of the site.
° Proposed Country Avenue crossing the site and running from Preston Hall to Little Worsham Farm.
° Locally listed buildings are located within the LVIA study area. There are no listed buildings within the site.
° Tree Preservation Orders (TPO) are located within the LVIA study area. There are no TPOs within the site.
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Regional Landscape Character
12.4.5 At the regional level landscape character assessment is defined by the broad landscape character areas identified by the Countryside Agency in ‘Countryside Character, Volume 7: South East and London’ (CA, 1999). This document identifies the entire LVIA study area as falling within the National Character Area (NCA) 122 High Weald.
12.4.6 Figure 12.5 , Appendix G.1 of the ES shows that the NCA 122 High Weald occupies the entire LVIA study area. National Character Area (NCA) Key Facts and Data documents have been created by Natural England (NE, 2011) for each of the NCAs. The document provides a summary of environmental data collated from the best available national data sets. They are intended to help guide those making decisions that may affect the local environment.
12.4.7 The High Weald NCA has the following key characteristics which are relevant to the LVIA study area (CA, 1999):
° A well-wooded landscape rising above the Low Weald and deeply incised in many places to give a complex pattern of ridges and steep stream valleys.
° Distinctive and scattered sandstone outcrops or ‘bluffs’ rise above the farmland and woodland.
° Main roads and settlements are sited along prominent ridge-lines with a dense network of small, narrow, and winding lanes linking scattered villages, hamlets and farms.
° Extensive areas of coppice woodland and the characteristic ‘hammer ponds’, a legacy of early iron industry.
° High forest, small woods and copses, and a network of hedges and shaws link small, irregular fields created from cleared woodland. Flower rich meadows bordered by species-rich hedgerows. Heavy clay soils. A quiet pastoral landscape with mixed farming predominating.
° The cultivation of fruit and hops, together with the associated distinctive oast houses and the seasonal appearance of hop poles.
° Distinctive red tile, brick, local stone and timber building materials, often including hung tiles and white weatherboarding, are characteristic of the historic settlements, farms and cottages. Local building materials characterise the area but recent ‘suburbanisation’ of farmstead buildings is eroding the distinctive local style in many places.
12.4.8 The document also sets out the relevant forces for change in the section Changing Countryside. The key forces for change are:
“Development around built-up areas throughout the region, but particularly in the north and west related to the location of railway lines and stations and on the ridges between the Low and High Weald areas.
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Loss of characteristic landscape features such as hedgerows, meadows, wooded ghylls, hammer ponds and parklands due to inappropriate management.
Traditional buildings reflect the use of local materials, such as redbrick and tiles.
Fragmentation of agricultural holdings due to the marginal nature of farmland – renovation of farm buildings by urban-based owners and the associated introduction of non-characteristic materials, details, designs and exotic tree species – also other forms of diversification of marginal farmland to new uses such as fish farms, craft workshops, etc.
Decline in use of vernacular building materials in new developments and introduction of urban features such as lighting and alarms.
Decline in traditional management and neglect of small coppice woodlands, traditional orchards and hop gardens.
An increase in road traffic above levels acceptable for the rural nature of the generally small roads and winding lanes with subsequent increase in conflicts between motorised traffic, pedestrians, horse-riders and cyclists.
Pressures on the landscape from new main roads and improvements.
Incipient forces for change from new land uses such as pony paddocks and associated clutter, tennis courts, street lighting and from golf courses.
Loss of remoteness and erosion of local character by suburban type development and materials.
Replacement of characteristic hedges with conifers, concrete or close-boarded fences around urban edges.” (CA, 1999)
12.4.9 The landscape character of the High Weald AONB was assessed in the 1994 in a Landscape Character Assessment produced by the Countryside Commission (CC, 1994). The document identifies the LVIA study area as falling within the edge of the Brede character area. It characterises this area as being located on steeper slopes near Hastings and Battle with smaller fields and a predominance of pasture which give the landscape a less intensively farmed feel, interspersed by the subtle influence of the pony paddocks and barbed wire of the urban edge.
12.4.10 The document also identifies several pressures on this area, such as increasing traffic on country lanes, suburbanisation, agricultural diversification, lack of woodland and hedgerow management, loss of hedges and degradation of ponds.
Local Landscape Character
12.4.11 East Sussex Trees and Woodland Strategy (ESRF, 2001) is a county level landscape assessment document produced in 2001 by the East Sussex Rural Forum. This county
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character assessment study identified three landscape character areas falling within the LVIA study area, namely: Combe Haven Basin, Bexhill and Hastings.
12.4.12 East Sussex Landscape Assessment (ESCC 2010), a technical document produced in consultation with the district and borough councils, is the most recent update of the landscape character assessment at a county scale. It also identifies three character areas within the LVIA study area:
° The Combe Haven Valley (Area 10);
° Bexhill (Urban Area 30); and
° Hastings (Urban Area 31).
12.4.13 The Combe Haven Valley character area is a landscape characterised by small, winding High Wealden valleys converging to form a tract of levels which curve east and south to almost reach the sea at Glyne Gap, between Hastings and Bexhill. This pleasant rolling, well-wooded countryside affords excellent views of the sea and coastal towns, which have a strong influence on the area.
12.4.14 This area has the following key characteristics:
“Area is enclosed by the Battle ridge to the north-east.
Focal open, flat, winding valley floor with wetland.
Intricate terrain of small, winding valleys and ridges around levels, with abundant woods and ghylls. Extensive areas of ancient woodland.
Contrast between open valley floor and slopes.” (ESCC, 2010)
12.4.15 The study identifies several pressures, problems and detracting features in this area, including the expansion of urban edges of Bexhill and Hastings, industrial developments at Pebsham, large caravan parks on Filsham slopes, presence of electricity lines and pylons, impact of the BHLR, widespread horticulture and reduced viability of farming.
12.4.16 Several landscape priorities are proposed to mitigate these problems. In relation to the proposed development, the key priorities include:
° The establishment of strong development boundaries to Hastings and Bexhill strengthened by woodland;
° development of Pebsham/Combe Valley Countryside Park;
° Landscape management of urban fringe;
° Review conservation and enhancement of Combe Haven valley;
° Increase flooding areas and wetland; and
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° Reduce engineered features, and increase tree cover on slopes to help contain development and proposed link road.
12.4.17 The vision for this character area states: “A remote yet accessible valley contained by well wooded slopes. Its proximity to urban areas gives great potential for unique recreational opportunities. Well managed and enhanced wildlife habitats and increased biodiversity.” (ESCC, 2010)
12.4.18 The quality of the Combe Haven Valley within the LVIA study area has been assessed as good due to its recognisable structure, characteristic features including wetlands on the valley floor surrounded by wooded valley slopes, strong sense of place of this attractive countryside and a degree of tranquillity in its low elevated parts. The area has local value and contains areas designated for their nature importance, such as SSSI, LNR and SNCI. It does not contain any landscape designations and there are some distracting features in the landscape, such as electricity pylons and transmission lines. The overall sensitivity of this area is assessed as medium due to its good quality, local value and moderately distinctive character.
12.4.19 Bexhill Urban Area – Bexhill-on-Sea arose as a medieval trading port, built on gently sloping ground. It was transformed in the 19 th century by the seventh Earl De La Warr into an exclusive seaside resort. By the mid-20 th century, the resort began to lose its appeal, and became more residential in nature, while retaining much of its quiet Edwardian character. The town is now comprised of several merged villages. It is marginally separated from Hastings by Glyne Gap and Combe Haven valley, an important green gap between the built up areas. At the eastern end of the town the railway severs the town from the seafront.
12.4.20 The area has the following key characteristics:
“A quiet, residential seaside town with small-scale but ornate early Victorian and Edwardian seafront facades, facing spacious seafront lawns.
Strong 1930’s Modern influence, centred on the De La Warr pavilion on the seafront, constructed under the instruction of the ninth Earl De La Warr in 1935.” (ESCC, 2010)
12.4.21 The relevant landscape action priorities include producing a tree strategy for the whole town to strengthen its character and create local/neighbourhood distinctiveness, creation of a green network of open space and recreational corridors, traffic management; improving pedestrian and cycle access and tree planting and development of proposed Pebsham Countryside Park in conjunction with other regeneration initiatives.
12.4.22 The overall quality of the Bexhill Urban Area located within the LVIA study area has been assessed as good it contains areas of higher quality within the Old Town, however, the majority of this area falling within the LVIA Study Area is of ordinary quality with no distinctive features. There are no landscape designations within this area. The proposed development does not have a potential to affect the Old Town and the areas of high quality within this area. As a result, the sensitivity of Bexhill Urban Area to the proposed development is assessed as low due to low quality of the urban edge, local value and the ordinary character of the post-war expansion of Bexhill with no distinctive landscape features.
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12.4.23 Hastings Urban Area – Hastings grew from a small fishing port, in the medieval period. With the advent of the railway and the development of seaside tourism, elegant Georgian and Victorian terraces and crescents were built beside the well preserved Tudor old town. The town is situated to the west of a series of sandstone headlands. The seaside town’s ability to expand has been determined by surrounding environmental designations, the coastline and poor transport infrastructure.
12.4.24 The area has the following key characteristics:
“The town sits on sandstone, which is eroded into ridges and wooded ghylls, giving a series of parks, open spaces and sheltered woodland within the town.
The medieval Old Town is overlooked by the cliff-top castle ruins, and has narrow winding lanes, twittens, and timberframed Tudor cottages.
Hastings has the largest beach-launched fishing fleet in Europe, and the fishing boats, with the tall, ancient, black-weatherboard net huts give the Old Town its unique character.” (ESCC, 2010)
12.4.25 The relevant landscape action priorities include improving connections to seafront beach and town, continuing regeneration and improvement programme to the seafront; and improving the western approach through Glyne Gap and Bulverhythe.
12.4.26 The overall quality of the Hastings Urban Area located within the LVIA study area has been assessed as ordinary it contains areas limited contain limited distinctive features and several detracting features, such as A259, derelict railway development and neglected areas of townscape. There are no landscape designations within this area. The proposed development does not have a potential to affect this area. The sensitivity of Bexhill Urban Area to the proposed development is assessed as low due to ordinary quality and local value with no distinctive landscape features.
12.4.27 The North East Bexhill SPD (RDC, 2009) identifies two sub character areas of Combe Haven Valley within and in the vicinity of the site:
12.4.28 Area 1 – Glover’s Farm is described as north-facing sloping land, rising up from dismantled railway (on embankment) towards Glover’s Farmhouse and The Mount. This sub area of Combe Haven Valley is highly visible from parts of the Combe Haven and the facing slopes of the Battle-Hastings ridge to the north. Glover’s Farm sub area has an open character, although the woodland around The Mount provides a significant backdrop when viewed from the north. The Mount contains an underground reservoir as well as a prominent telecommunications mast. Glover’s Farmhouse is a historic building but it is not a Listed Building.
12.4.29 The quality of the Glover’s Farm sub area located entirely within the LVIA study area has been assessed as good due to its generally recognisable structure, characteristic local features such as small woodland areas, and open views to the north from higher elevations. The area has local value and contains features designated for their nature importance, such as a local SNCI along the dismantled railway. The northern and eastern part of this area is
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located within the proposed Combe Valley Countryside Park and offers stronger sense of tranquillity than its southern part around the Glover’s Farm. It does not contain any landscape designations. The overall sensitivity of this area to the proposed development is assessed as medium due to its good quality, local value and moderately distinctive character.
12.4.30 Area 2 – Upper Worsham Farm is a sub area of the Combe Haven Valley and extends from Wrestwood Road to the local ridgeline located to the south of the site. The landform within this area is undulating, affording distant views towards the High Weald AONB to the north. It is primarily an open arable farmed landscape defined by low hedges on field boundaries. The area is framed by pockets and areas of dense woodland, with Combe Wood to the north, Roundacre Wood and Pebsham Wood to the east and the woodland at The Mount to the west.
12.4.31 The area incorporates the group of buildings at Upper Worsham Farm, and smaller historic barns to the north east on the ridge. On Worsham Lane to the south is the Grade II Listed stone and flint Boulder Cottage. The area is well overlooked from existing housing, most notably on the Pebsham residential estate.
12.4.32 The quality of the Upper Worsham Farm sub area located entirely within the LVIA study area has been assessed as good to ordinary due to its generally recognisable structure, characteristic local features such as a small vegetated ridge running east-west, sense of place, and open views across the countryside towards the High Weald AONB in the north. The area has local value and does not contain areas designated for their nature importance, however, a small area of Ancient Woodland is located within this area. It does not contain any landscape designations and there are some distracting features in the landscape, such a prominent telecommunications mast and a rectangular reservoir at The Mount and unattractive farm buildings around the Upper Worsham Farm. The overall sensitivity of this area to the proposed development is assessed as medium due to its good to ordinary quality, local value and moderately distinctive character.
Visual Baseline
12.4.33 A location plan for representative viewpoints is shown in Figure 12.7 , Appendix G.1 of the ES. Photographs from representative viewpoints are shown in Figures 12.8.1 to 12.8.10 , Appendix G.1 of the ES.
12.4.34 Views from the south and are available predominantly for users of PRoW in the vicinity of the site. Residents of properties along Bexhill and Pebsham urban edge and users of Wrestwood Road have very limited views of the site due to existing buildings, vegetation and landform restricting the views.
12.4.35 There are a number of short and mid-distance views (up to 1.5km of the site) towards the site from Glover’s Farm, residential properties at St James’ Crescent and areas within the Proposed Countryside Park to the north of the site. Upper Worsham Farm has no direct views of the site due to existing vegetation obscuring the views.
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12.4.36 The site is partially visible from the north due to its location on a north-facing slope, adjacent to the Glover’s Farm. Lower elevations of the site are screened by an embankment of a dismantled railway covered by mature vegetation. This slope is a prominent feature in views from the most elevated PRoW within the Combe Valley Countryside Park. Views of the site from the High Weald AONB are very limited.
12.4.37 Night time views within the northern part of the LVIA study area are characterised by relatively dark skies, as this area contains limited development and local wooded ridges screen direct views of light sources within the surrounding urban areas. However, localised areas of urban sky glow are visible in the distance. Lighting proposed as part of the BHLR (under construction) and the consented NEBGR will be visible from the locations north of the site, including south-facing slopes of the Combe Haven Valley. This will change night-time baseline conditions during the operation of the Bexhill Enterprise Park.
12.4.38 In contrast to the relatively dark areas in the north, views from locations within the southern part of the LVIA study area, south of the site, are under strong influence of the existing lighting along Wrestwood Road and the surrounding urban areas.
Visual Receptors
12.4.39 The proposed development has potential to affect the following receptors:
° Local residents up to approximately 0.5km from the site, including residents of properties at St James’ Crescent and Glover’s Farm;
° Users of public footpaths, including Public Rights of Way, predominantly to the north of the application site;
° Road users, including motorists and cyclists; and
° Residents and workers in local farms.
12.4.40 These receptors are represented by 10 viewpoints within the LVIA study area. Viewpoint location plan is shown in Figure 12.7 , Appendix G.1 of the ES. Photographs from representative viewpoints are reproduced in Figures 12.8.1 to 12.8.10 , Appendix G.1 of the ES. The viewpoints are summarised below:
12.4.41 Viewpoint 1 is located on Wrestwood Road approximately 0.5km south of the application site (see Figure 12.8.1 , Appendix G.1 of the ES). This view (looking north) shows a gappy hedgerow running along Wrestwood Road and small trees, which partially obscure views of the wider countryside. The application site is screened by a vegetated ridge running from The Mount to the south of the Combe Wood. Once complete, the southern part of the consented NEBGR will be visible in mid-distance on undulating fields stretching from Wrestwood Road to a local ridge south of the site. The sensitivity assigned to this viewpoint has been assessed as low, as it represents views experienced by the users of Wrestwood Road.
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12.4.42 Viewpoint 2 is located near residential properties at the junction of Wrestwood Road and The Glades road (see Figure 12.8.2 , Appendix G.1 of the ES). A drop in topography and limited planting along the road create open view of the adjacent arable fields, which are located on a slope gently rising towards The Mount. Once complete, the southern part of the consented NEBGR will be visible on undulating fields near The Mount. A night-time view from this viewpoint is shown in Figure 12.8.2a , Appendix G.1 of the ES. The sensitivity assigned to this viewpoint has been assessed as high, as it represents views experienced by local residents.
12.4.43 Viewpoint 3 is located on a PRoW no. 67a located north of upper Worsham Farm. The view (looking west) is experienced by users of this local footpath (see Figure 12.8.3 , Appendix G.1 of the ES). This view is dominated by a hedge in the foreground. The viewpoint is located within the ZTV, however, existing hedgerow and woodland plantation obscure views of the application site. North-east Bexhill residential area is partially visible. Once complete, the southern part of the consented NEBGR will be visible on undulating fields near The Mount, along the existing woodland edge. The sensitivity assigned to this viewpoint has been assessed as medium, as it represents views experienced by the users of this locally important PRoW.
12.4.44 Viewpoint 4 is located on a PRoW no. 32a south of Glover’s Farm and represents views (looking north) experienced by walkers (see Figure 12.8.4 , Appendix G.1 of the ES). Due to its location on relatively high topography, it provides good, long distance views of the Combe Haven Valley. The vegetated ridges of the High Weald AONB are visible in the far distance. The application site is visible in mid distance on undulating fields next to Glover’s Farm and a dismantled railway. Once complete, the northern part of the consented NEBGR will be visible in mid-distance. The NEBGR will run in a shallow cutting, crossing the application site. The BHLR will be visible in mid to long-distance within the Combe Haven Valley. The sensitivity assigned to this viewpoint has been assessed as medium, as it represents views experienced by the users of this locally important PRoW.
12.4.45 Viewpoint 5 is located on a public footpath south of Acton’s Farm and represents views (looking south) experienced by PRoW users (see Figure 12.8.5 , Appendix G.1 of the ES). It provides views of a wide Combe Haven Valley within the area designated as a Proposed Countryside Park. Glover’s Farm is visible in the distance. Local areas of woodland on upper slopes screen views towards Bexhill. Views of the site are limited due to existing vegetation. Once complete, the northern part of the consented NEBGR will be predominantly screened by existing vegetation wrapping the site from the north and east. The BHLR will be visible in the foreground of the view. The sensitivity assigned to this viewpoint has been assessed as medium, as it represents views experienced by the users of this locally important PRoW.
12.4.46 Viewpoint 6 is located on a PRoW no. 33 running along the northern edge of the Combe Valley Countryside Park (looking south-east) and represents views experienced by PRoW users (see Figure 12.8.6 , Appendix G.1 of the ES). It provides views of a wide Combe Haven Valley with large areas of woodland and large grazing fields. The telecommunications mast located at The Mount is visible on top of the heavily vegetated ridge. Views of the site are limited due to existing woodland areas surrounding the site. Once complete, the
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northern part of the consented NEBGR will be partially screened by existing vegetation and the BHLR will be visible at the bottom of Combe Haven valley. A night-time view from this viewpoint is shown in Figure 12.8.11a , Appendix G.1 of the ES. The sensitivity assigned to this viewpoint has been assessed as medium, as it represents views experienced by users of this locally important PRoW.
12.4.47 Viewpoint 7 is located on a PRoW no. 34 located west of Acton’s Farm and on the centre line of the BHLR under construction. It currently represents views experienced by PRoW users, however, once the BHLR is operational, it will also provide views for road users approaching Bexhill from the north (see Figure 12.8.7 , Appendix G.1 of the ES). To a degree, it is also representative of views experienced by the residents of Acton’s Farm. It provides wide and open views of the Combe Haven Valley with grazing fields delineated by hedgerows in the foreground and vegetated ridges forming the backdrop. The telecommunications mast located at The Mount is surrounded by woodland and visible on top of a locally prominent ridge. Views of the site are limited due to existing woodland areas surrounding the site. Once complete, the northern part of the consented NEBGR will be partially screened by existing vegetation. The viewpoint will be located on the BHLR which will dominate the view. The sensitivity assigned to this viewpoint has been assessed as high, as it represents views experienced by the users of this locally important PRoW but also residents of the nearby Acton’s Farm.
12.4.48 Viewpoint 8 is located a PRoW no. 13b south of Hillcroft Farm represents views experienced by the users of this locally important footpath (see Figure 12.8.8 , Appendix G.1 of the ES). It provides open views of the Combe Haven Valley with vegetated ridges in the background. The telecommunications mast located at The Mount is surrounded by woodland and visible on top of a locally prominent ridge in the far distance. Views of the site are very limited due to the long distance from the viewpoint, topography and existing woodland areas surrounding the site. Once complete, the northern part of the consented NEBGR will be partially screened by existing vegetation and the BHLR will be visible at the bottom of Combe Haven valley. The sensitivity assigned to this viewpoint has been assessed as medium, as it represents views experienced by the users of this locally important PRoW.
12.4.49 Viewpoint 9 is located on a PRoW no. 16 south of Adam’s Farm, running through the wetlands of Combe Haven Valley. It represents views experienced by walkers ( see Figure 12.8.9 , Appendix G.1 of the ES). A flat area of wetland dominates the foreground of this view with local vegetated ridges in the backdrop. The telecommunications mast located at The Mount is surrounded by woodland and visible on top of a locally prominent ridge. Views of the application site are very limited due to low elevation of this viewpoint, and existing woodland areas surrounding the site. Once complete, the northern part of the consented NEBGR will be partially screened by existing vegetation and the BHLR will be visible at the bottom of Combe Haven valley. The sensitivity assigned to this viewpoint has been has been assessed as medium, as it represents views experienced by the users of this locally important PRoW.
12.4.50 Viewpoint 10 is located on a PRoW no. 11 on Hunters Hill, in the vicinity to a boundary of the High Weald AONB. It represents views experienced by PRoW users, residents of nearby properties and farms, and road users (see Figure 12.8.10 , Appendix G.1 of the ES). This
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long distance view shows the Combe Haven Valley with large fields bounded by low hedgerows and large areas of vegetation on valley slopes. The telecommunications mast located at The Mount is surrounded by woodland and visible on top of a locally prominent ridge. Views of the application site are very limited due to the long distance from the viewpoint, topography, and large areas of existing woodland surrounding the site. Once complete, the northern part of the consented NEBGR will be partially screened by existing vegetation and the BHLR will be visible at the bottom of Combe Haven valley. The sensitivity assigned to this viewpoint has been assessed as high, as it represents views experienced by the users of this locally important PRoW, road users but also local residents.
Summary of Landscape and Visual Baseline Receptors and Their Sensitivity
12.4.51 Tables 12.8 and 12.9 provide a summary of landscape and visual receptors and their sensitivity.
Table 12.8: Landscape Receptors and Sensitivity Character Area Sensitivity Combe Haven Valley Medium Bexhill Urban Area Low Hastings Urban Area Low Glover’s Farm Sub Area Medium Upper Worsham Farm Sub Area Medium
Table 12.9: Representative Viewpoints, Relevant Receptors and Sensitivity Viewpoint Receptors Sensitivity Viewpoint 1 – Wrestwood Road Looking North Road users Low Viewpoint 2 – Wrestwood Road / The Glades Local residents High Viewpoint 3 – PRoW no. 67a North of Upper PRoW users Medium Worsham Farm Viewpoint 4 – PRoW no. 32a South of Glover’s PRoW users Medium Farm Viewpoint 5 – PRoW no. 33 South of Acton’s PRoW users Medium Farm Viewpoint 6 – PRoW no. 34 Combe Valley PRoW users Medium Countryside Park Local residents, PRoW users, Viewpoint 7 – PRoW no. 34 West of Acton’s road users (when BHLR is High Farm, BHLR Alignment operational) Viewpoint 8 – PRoW no. 13b South of Hillcroft PRoW users Medium Farm Viewpoint 9 – PRoW no. 16 South of Adam’s PRoW users Medium Farm Viewpoint 10 – PRoW no. 11 on Hunters Hill Local residents, PRoW users High
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12.5 Assessment and Mitigation of Construction Effects
12.5.1 This section of the report assesses landscape and visual impacts associated with the construction of the proposed development and identifies the appropriate mitigation measures aimed at preventing, reducing or off-setting potential adverse impacts during the construction phase. Following the identification of mitigation measures, residual construction effects are assessed. The section also assesses cumulative construction effect with the construction of the NEBGR and BHLR.
12.5.2 Bexhill Enterprise Park construction activities which would potentially cause landscape and visual impacts include:
° Clearance of vegetation within the construction zone;
° Earthworks;
° Removal of existing buildings within the site;
° Construction of the proposed Bexhill Enterprise Park, including proposed buildings, areas of hardstanding, lighting columns, signage and fencing;
° Erection of temporary structures within the construction compounds;
° Movement of construction vehicles across the landscape (on-site and off-site);
° Diversion of Public Rights of Way crossing the site;
° Works associated with the implementation of the landscape scheme; and
° Removal of temporary construction facilities.
12.5.3 The construction of the proposed development would be carried out during normal working hours from Monday to Saturday. No construction works would be carried out during night- time, therefore lighting impacts during construction would be negligible.
Construction Effects
12.5.4 The proposed development has the potential to cause the following impacts on receptors identified in the baseline assessment:
° Adverse impacts on the southern edge of the High Weald AONB due to change in views towards the sea;
° Adverse impacts on local landscape character, including the following landscape and townscape character areas: Combe Haven Valley, Bexhill Urban Area, Upper Worsham Farm Sub Area and Glover’s Farm Sub Area, due to changes in natural, cultural and aesthetic / perceptual qualities of these character areas;
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° Adverse impacts on landscape elements and features within the Glover’s Farm Sub Area;
° Adverse impacts on visual receptors, such as local residential properties, users of Public Rights of Way, road users, including motorists and cyclists, and residents and workers in local farms; and
° Adverse impacts on PRoW users due to the closure of footpaths crossing the construction site.
12.5.5 It has been assessed that the proposed development would not cause any significant impacts on the Hastings Urban Area, due to its distance from the proposed development combined with effective visual screening provided by existing vegetation to the east and south of the site, and marginal impact of vehicle movement on the existing traffic within this area during construction. For this reason, the Hastings Urban Area will not be further considered in the assessment of landscape and visual effects.
Mitigation of Construction Effects
12.5.6 The proposed construction mitigation strategy focuses on minimising the effects of the construction activities by retaining as many landscape features as possible and their effective protection during construction, and by adjusting the construction programme and minimising the footprint of construction activities to reduce landscape and visual impacts as far as practicable.
12.5.7 The following mitigation measures are proposed during construction of the scheme:
° Recycling as much soil on site as possible to minimise the impact associated with construction vehicle traffic, including the movement of lorries in and out of the site;
° Retain and secure topsoil excavated during construction to re-use it during site restoration;
° Stockpiling of materials would be kept within the site boundary and in visually sensitive discreet location, such as areas of lower elevation or fields screened by the surrounding vegetation, where possible. The height of stockpiles would be kept up to 5 meters to minimise their visual impact;
° To safeguard the existing vegetation to be retained, tree protection zones would be created and fenced off to ensure that development would not encroach onto the root protection areas. Existing trees and hedges would be protected in accordance with BS 5837:2012 Trees in Relation to Design, Demolition and Construction;
° Construction compounds, including portacabins and construction machinery, would be located, where possible, in visually discrete locations to minimise impact on the surrounding rural landscape and visual amenity;
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° Construction and security lighting would be shielded, where possible, and directed downwards to minimise light pollution; and
° Providing diversions of PRoW crossing the site and affected by construction activities.
Residual Construction Effects
12.5.8 This section of the report assesses residual construction effects after implementation of the construction mitigation measures for the standalone Bexhill Enterprise Park. Cumulative construction effects with the construction of the BHLR and NEBGR (committed developments) are also assessed. All landscape and visual impacts during construction would be short-term and of temporary nature.
Landscape Character Areas
12.5.9 The construction impact of the Bexhill Enterprise Park on the Combe Haven Valley landscape character area would be predominantly on its south-western part, in the vicinity of Glover’s Farm. The direct impact would include limited loss of landscape elements and features, such as areas of arable land and grassland, small sections of hedgerows and some trees, and temporary diversion of the existing watercourse within the site. Changes to topography would be also limited, as the proposed development would generally follow the north-facing slope and there would be only small variations to topography within the site. The main impact would be from the presence of construction machinery on site, including cranes, and from construction of employment buildings. There would be some impact on the landscape area’s tranquillity and character, not limited to the site but extending farther to the north and north east, due to the visibility of some construction activities from the valley floor. Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to additional physical loss of landscape elements and features, in particular within the BHLR footprint, higher volume of construction traffic, and road construction activities.
12.5.10 The magnitude of residual construction impact is assessed as low, as it would be limited to a small, peripheral part of this character area and the loss of key landscape elements and features would be limited. The duration of construction effect would be short-term. The significance and nature of residual effect would be temporary and minor adverse.
12.5.11 The magnitude of cumulative construction impact with the construction of the NEBGR and BHLR is assessed as medium, as the loss of landscape elements and features would be higher and there would be a greater loss of tranquillity within the area, although this change would be temporary. The duration of cumulative construction effect would be short-term. The significance and nature of residual effect would be temporary and moderate adverse.
12.5.12 During construction, the proposed development would have no physical impact on the Urban Bexhill Area . Some views of construction activities within the site would be available only from residential properties of Bexhill urban edge to the south-west of Glover’s Farm. Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to additional physical loss of landscape elements and features, in particular along the BHLR alignment, higher volume of construction traffic, and road
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construction activities, which would also include NEBGR construction between the site and Wrestwood Road along Bexhill urban edge. Cumulative views of all construction activities would be available only from peripheral parts of this area.
12.5.13 The magnitude of residual impact is assessed as low and adverse and the overall significance of the temporary effect is assessed as not significant.
12.5.14 The magnitude of cumulative construction impact with the construction of the NEBGR and BHLR is assessed as low, as the physical impact on this area would remain relatively limited and although there would be a temporary change in views within the north-eastern part of this area, its character would prevail. The duration of cumulative construction effect would be short-term. The significance and nature of residual effect would be temporary and not significant.
12.5.15 The construction impact on the Glover’s Farm landscape character area would occur to the south of the dismantled railway embankment, where construction of the proposed development would take place on the north-facing slope. The construction activities would result in a loss of high percentage of the area’s landscape, changing it from rural to development. The construction activities would cause a direct, physical impact on the local landscape, including the loss of improved grassland within the scheme’s construction footprint, short sections of hedgerows, wet ditches, and small changes to landform. The area to the north of the dismantled railway embankment would remain physically untouched, however, it would receive views of construction, which would reduce the area’s tranquillity. The main impact would be from the presence of construction machinery on site, including cranes, and from construction of employment buildings. Besides physical impacts on the Glover’s Farm Area, there would be impacts on its tranquillity, local Public Rights of Way and views within and out of the area. Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to additional physical loss of landscape elements and features, in particular within the BHLR footprint, higher volume of construction traffic, and road construction activities. However, this increase would be limited, as the construction of the NEBGR within this character area would be absorbed within the construction site for Bexhill Employment Area and the BHLR would be constructed adjacent to the proposed development.
12.5.16 The magnitude of residual impact is assessed as high, as it would affect a significant part of this small character area. The duration of the construction effect would be short-term. The significance and nature of residual effect would be temporary and major adverse.
12.5.17 The magnitude of cumulative construction impact with the construction of the NEBGR and BHLR is also assessed as high and the significance and nature of residual effect would be temporary and major adverse.
12.5.18 The construction impact on the Upper Worsham Farm landscape character area would be limited to impact on its character and views from this area, and there would be no physical loss of landscape within this area. The majority of construction, including erection of buildings on higher topography and larger construction machinery, would be effectively
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screened by the existing ridge running south of the application site and existing vegetation which would be unaffected.
12.5.19 Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, predominantly within the western part of this landscape character area where the NEBGR would be constructed along hedgerows and woodland running to the east of the urban edge of Bexhill and adjacent to The Mount. The NEBGR construction activities within this area would stretch from Wrestwood Road to a local ridge south of Glover’s Farm. Consequently, there would be physical impact on this area, however, few valuable landscape features would be lost as a result of construction activities. The main landscape features to be lost would include mature trees along Wrestwood Road, small sections of species-poor hedgerows and arable land. Changes to topography would be very limited, as the NEBGR would follow the area’s undulating topography. There would be some impact on the area’s tranquillity and character, not limited to the site but extending farther to the east, due to the visibility of some construction activities around the northern part of the NEBGR from the valley floor. However, the visibility of NEBGR construction activities would be seen in the context of vehicle movement on Wrestwood Road and would be limited in some areas due to undulating topography and intervening vegetation. Views of the parallel construction of the BHLR and Bexhill Enterprise Park from this area would be very limited.
12.5.20 The magnitude of residual impact is assessed as negligible, as it would be no physical impact on this area and view of construction would be extremely limited. The duration of construction effect would be short-term. The significance and nature of residual effect would be temporary and not significant.
12.5.21 The magnitude of cumulative construction impact with the construction of the NEBGR and BHLR is assessed as low, as it would be limited to a small, peripheral part of this character area and the loss of valuable landscape elements and features would be very limited. The significance and nature of residual effect would be minor and adverse.
Visual Receptors
12.5.22 Visual impacts of the proposed development on visual receptors within the LVIA study area are represented by the selection of viewpoints covering all main angled and types of publicly accessible views from residential areas and Public Rights of Way, and have been assessed in the field.
12.5.23 Figure 12.7 , Appendix G.1 of the ES shows the locations of viewpoints and the Zone of Theoretical Visibility of the proposed development.
12.5.24 Receptors at Viewpoint 1 would experience very limited views of construction activities above the vegetated ridge to the east of The Mount. All construction activities on lower topography would be screened from this viewpoint. The hedgerow in the foreground screens similar views to the north. The duration of the residual construction effect would be short- term and the magnitude of impact is assessed as negligible. The significance and nature of residual construction effect would be temporary and not significant.
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12.5.25 Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to NEBGR construction activities along Wrestwood Road, including vegetation clearance, road construction activities, diversion of traffic, presence of construction machinery, earthworks and the construction compound. However, the change in view would be seen in the context of existing traffic on Wrestwood Road and the overall change would be smaller compared to more static, rural views. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as medium. The significance and nature of cumulative construction effect would be temporary and minor adverse.
12.5.26 Receptors at Viewpoint 2 would experience very limited views of construction activities above the vegetated ridge to the east of The Mount. All construction activities on lower topography would be screened from this viewpoint. The only partially visible elements would be the construction cranes and buildings under construction on the highest topography, however, their visibility would be limited due to distance and existing ridge obscuring the views. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as negligible. The significance and nature of residual construction effect would be temporary and not significant.
12.5.27 Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to NEBGR construction activities on the arable fields in the vicinity of The Mount. Due to the distance from the NEBGR construction site and intervening landform and vegetation, only a small proportion of its construction would be seen. The construction of the NEBGR would be seen in the context of the traffic on local roads occupying the foreground of the view and the overall change will be smaller compared to more static, rural views. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of cumulative construction effect would be temporary and moderate adverse. During construction, lighting impacts would be negligible and night-time impacts would not be significant.
12.5.28 Receptors at Viewpoint 3 may experience extremely limited views of construction machinery, such as construction cranes, above the vegetated ridge to the east of The Mount. All construction activities on lower topography would be screened from this viewpoint. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as negligible. The significance and nature of residual construction effect would be temporary and not significant.
12.5.29 Construction of the NEBGR and BHLR would increase the magnitude of construction impact in the short term, due to NEBGR construction activities on the arable fields in the vicinity of The Mount. The hedgerow running alongside the PRoW in the foreground and the gently undulating topography would partially screen views of the construction activities, which would be seen on the backdrop of the woodland at The Mount. Moving construction traffic would be visible from this viewpoint. The construction of the NEBGR would introduce dynamic elements to this otherwise predominantly static view. Large arable fields in the foreground and a hedgerow would continue to dominate this view. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed
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as medium. The significance and nature of cumulative construction effect would be temporary and moderate adverse.
12.5.30 Receptors at Viewpoint 4 would experience views of the majority of development’s construction, including vegetation clearance, erection of temporary structures, construction vehicles and machinery, partially completed buildings and works associated with the implementation of landscape works. There would be a change in the character of the view from rural to development and some of the long distance views would be lost due to erection of higher structures within the site. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as high. The significance and nature of residual construction effect would be temporary and major adverse.
12.5.31 Construction of the NEBGR and BHLR would slightly increase the construction impact in the short term, however, the change would not be very significant, as the majority of construction of both roads would be obscured by the Bexhill Enterprise Park construction. Some additional visual impact would occur due to vegetation clearance along the dismantled railway, earthworks and additional stockpiles associated with the NEBGR and BHLR construction phase. The BHLR construction would be partially seen in mid distance. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as high. The significance and nature of cumulative construction effect would be temporary and major adverse.
12.5.32 Receptors at Viewpoint 5 would experience views of only high level construction activities within the application site due to effective screening provided by existing vegetation along the dismantled railway and to the east of the proposed development, which would screen low level construction within the site. The larger machinery on site, including cranes would punctuate the skyline, however, in the wider context of the view, the visual change would be limited to a localised area and the overall character of the view would undergo only a small, temporary change. The loss of existing trees within the view would be barely perceptible, as construction would take place predominantly on the agricultural fields and the surrounding vegetation would be retained and protected during construction. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of residual construction effect would be temporary and minor adverse.
12.5.33 Construction of the NEBGR and BHLR would increase the magnitude of construction impact predominantly due to the BHLR construction, which would be standing out in the view, as it would stretch from the dismantled railway at Glover’s to Acton’s Farm, across the fields in the foreground construction activities related to the construction of the northern roundabout with the NEBGR. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as medium. The significance and nature of cumulative construction effect would be temporary and moderate adverse.
12.5.34 Receptors at Viewpoint 6 would experience limited views of the construction activities within the application site due to effective screening provided by existing vegetation along the dismantled railway, which would screen some low level construction within the site. Construction within the western part of the site would be predominantly screened. The
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larger machinery on site, including cranes would punctuate the skyline, however, in the wider context of the view, the visual change would be limited to a localised area and the overall character of the view would undergo only a small, temporary change. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of residual construction effect would be temporary and minor adverse. During construction, lighting impacts would be negligible and night-time impacts would not be significant.
12.5.35 Construction of the NEBGR and BHLR would increase the magnitude of construction impact predominantly due to the BHLR construction, which would be partially seen through a distinctive tree line on a field boundary in the mid distance. There would be very limited views of the NEBGR construction activities related to the construction of its northern section, as vegetation, landform and the construction of the Bexhill Enterprise Park would obscure views of the NEBGR construction activities, including stockpiling, earthworks and vehicle movement. In the wider context of the view, the construction of the proposed development, the NEBGR and BHLR would have low impact on the overall character of the view, in which the construction activity would occupy only a localised area. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as medium. The significance and nature of cumulative construction effect would be temporary and moderate adverse. During construction, cumulative lighting impact would be negligible and night-time impacts would not be significant.
12.5.36 Receptors at Viewpoint 7 would experience views of predominantly high level construction activities within the application site due to effective screening provided by existing vegetation along the dismantled railway and to the east of the proposed development, which would screen low level construction within the site. The larger machinery on site, including cranes would punctuate the skyline, however, in the wider context of the view, the visual change would be limited to a localised area and the overall character of the view would undergo only a small, temporary change. The loss of existing trees within the view would be barely perceptible, as construction would take place predominantly on the agricultural fields and the surrounding vegetation would be retained and protected during construction. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of residual construction effect would be temporary and moderate adverse.
12.5.37 Construction of the NEBGR and BHLR would increase the magnitude of construction impact predominantly due to the BHLR construction which would occupy a significant proportion of the view (the viewpoint is located on the centre line of the BHLR). The view would undergo a major change from rural view to a view from a large road under construction. The PRoW will be closed during construction of the BHLR. The duration of the construction effect would be short-term and the magnitude of impact is assessed as medium, due to a temporary nature of this change. The temporary cumulative construction effect would be major and adverse.
12.5.38 Receptors at Viewpoint 8 would experience views of predominantly high level construction activities within the application site due to effective screening provided by existing vegetation along the dismantled railway and to the east of the proposed development, which would
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screen low level construction within the site. The larger machinery on site, including cranes, would punctuate the skyline, however, in the wider context of the view and a relatively long distance from the application site the visual change would be limited to a localised area and the overall character of the view would undergo only a small, temporary change. The loss of existing vegetation within the view would be barely perceptible, as construction would take place predominantly on the agricultural fields and the surrounding vegetation would be retained and protected during construction. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of residual construction effect would be temporary and minor adverse.
12.5.39 Construction of the NEBGR and BHLR would cause only a small increase of the construction impact predominantly due to the BHLR construction, which would be visible on the Combe Haven Valley floor in the foreground. The NEBGR construction would be absorbed by the Bexhill Enterprise Park under development and would not add any significant visual change to the view. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of cumulative construction effect would be temporary and minor adverse.
12.5.40 Receptors at Viewpoint 9 would experience views of only high level construction activities within the application site due to low elevation of the viewpoint combined with effective screening by existing vegetation along the dismantled railway and the existing woodland area to the east of the site which would screen all low level construction within the site. The larger machinery on site, including cranes would occasionally punctuate the skyline, however, in the wider context of the view, the visual change would be limited to a localised area and the overall character of the view would undergo only a very small, temporary change. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as negligible. The significance and nature of residual construction effect would be not significant.
12.5.41 Construction of the NEBGR and BHLR would increase the magnitude of construction impact predominantly due to the BHLR construction, which would be partially visible in the distance, as it would stretch from the dismantled railway at Glover’s to Acton’s Farm. Visibility of the BHLR construction would be greatly reduced by the combination of low topography, distance and shrubs on the bottom of Come Haven Valley floor. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as low. The significance and nature of cumulative construction effect would be temporary and minor adverse.
12.5.42 Receptors at Viewpoint 10 would experience very limited views of construction activities, due to the far distance from the site and existing vegetation adjacent to the site obscuring the view. Construction activities within the higher parts of the north-facing slope in the vicinity of Glover’s Farm would be barely perceptible due to distance and the wider context of this view, which contains a number of distinctive features, such as woodland areas, small farms and ridges, which add to its complexity and would reduce the visual change. The duration of the residual construction effect would be short-term and the magnitude of impact is assessed as negligible. The significance and nature of residual construction effect would be not significant.
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12.5.43 Construction of the NEBGR and BHLR would result in a very small increase of the visual impact, predominantly due to the BHLR construction, which would be visible on the Combe Haven Valley floor, near the prominent woodland area in mid distance. The duration of the cumulative construction effect would be short-term and the magnitude of impact is assessed as negligible. The cumulative construction effect would be temporary and not significant.
12.6 Assessment and Mitigation of Operation Effects
12.6.1 The proposed development has the potential to cause the following impacts on receptors identified in the baseline assessment:
° Impacts on the southern edge of the High Weald AONB due to change in views towards the sea;
° Impacts on local landscape character, including the following landscape and townscape character areas: Combe Haven Valley, Bexhill Urban Area, Upper Worsham Farm Sub Area and Glover’s Farm Sub Area, due to changes in natural, cultural and aesthetic/perceptual qualities of these character areas;
° Impacts on existing landscape elements and features within the Glover’s Farm Sub Area;
° Visual impacts on local residents, users of Public Rights of Way, road users, including motorists and cyclists, and residents and workers in local farms;
° Lighting impacts on landscape and visual receptors due to lighting proposed as part of the operational scheme;
° Impact on landscape character due to introduction of new landscape features within the proposed development contributing to the Combe Haven Valley Countryside Park planting;
° Impacts on PRoW;
° Townscape impact due to creation of a new development on the edge of North East Bexhill; and
° Landscape and visual impacts due to screening of NEBGR and BHLR by the proposed development.
12.6.2 It has been assessed that the proposed development would not cause any significant impacts on the Hastings Urban Area, due to its distance from the proposed development combined with the marginal impact of vehicle movement on the existing traffic due to the development. For this reason, the Hastings Urban Area will not be further considered in the assessment of landscape and visual effects during the operational phase.
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Mitigation of Operational Effects
12.6.3 The proposed landscape strategy for the operational scheme focuses on minimising the landscape and visual effects of the development by an effective planting scheme, inherent to the development design, which would serve both landscape and ecological purposes. A landscape scheme for the operational development is shown in illustrative format only (see Illustrative Masterplan in Appendix A.3). No off-site mitigation is proposed as part of the Bexhill Enterprise Park development. A comprehensive off-site mitigation scheme has been proposed as part of the NEBGR, approved in 2013.
12.6.4 The Illustrative Masterplan for the site has been generated by an overall vision precedent set by Policy BX2. There is an expressed need to balance site function and habitat creation on this site that has led to a landscape centred vision of a ‘Countryside Park’. The ‘Countryside Park’ vision has informed the Illustrative Masterplan.
Landscape Vision
12.6.5 The landscape design will take inspiration from the wider landscape context of the High Weald. The east-west linear context of the site’s contours must greatly inform the landscape and planting design. Policy BX2 states that “development (should be) contained from the wider countryside by well-defined topographical and landscape features.” The intention of the Illustrative Masterplan is to pull woodland belts through the site on terraces upon which the barn style buildings would sit. The wooded terraces would contain informal parking courts set within ‘clearings’ and populated by native woodland trees. The landscape design would have a ‘feel’ of an informal countryside park landscape with formal landscape gestures at buildings.
Planting Structure
12.6.6 The planting structure for the site draws on the context of the 600 hectare ‘green gap’ Countryside Park identified between Bexhill and Hastings, existing planting surrounding the site and future aspirations for sites to create their own ‘sense of place’. A planting strategy would be created that is borne out of the existing situation with an appreciation of “the various landscape features of woodland, hedgerows, copses, ponds and ditches (that) form part of an important local habitat mosaic .” (See Policy BX2.)
12.6.7 A hierarchy of planting structure would be developed for the site as follows:
° Forest swathes – wet and dry high forest planting to link with the proposed planting of the BHLR and NEBGR.
° Woodland bands – dry and wet woodland planting to punctuate the site along contoured terraces, extending the typology of the surrounding woodland into the landscape of the site.
° Linear hedgerows – a strong linear network of new native hedgerows to help delineate spaces and provide habitat connectivity.
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° Specimen trees – specimen semi-mature native trees would be planted individually or in avenues.
° Grassland – respectful of the current importance of grassland habitats the green swathe of parkland alongside the gateway road would extend into the site. Important Weald Native species would be combined with existing grass mixes used on BHLR and NEBGR.
° Aquatic planting – wet woodland and wet scrubland clumps would be formed around an attenuation pond with marginal vegetation on a shelf profile. A wetland meadow mix would be planted around the pond area and within site wide swales.
12.6.8 Together this planting hierarchy will provide a platform from which a rich biodiversity may develop into the future.
Water Features
12.6.9 Running along the terraced contours swales could provide for form and function providing another level of landscape and ecological interest within the site.
Movement and Connectivity
12.6.10 Paragraph 5.27 of Policy BX2 says “Landscape and movement strategies should dovetail with that for energy conservation.” The collective movement and connectivity of pedestrians, cyclists and vehicles would link north-south and east-west into the site to improve the connectivity of existing public rights of way.
Car Parking Courts
12.6.11 Car parking courts would be set within woodland clearings to provide an informal parking layout whist respecting the needs of the site as an operational enterprise park.
Lighting Strategy
12.6.12 A sensitive lighting strategy would be proposed that considers safety requirements, light spill, sensitive ecology and the requirements for the road network within the site to be built to adoptable standards.
Future Landscape Character
12.6.13 The Bexhill Enterprise Park’s sense of place should be created through the careful use of site topography, woodland planting across terraces with the use of trees and hedgerows to frame and contain future development. A sustainable, ecologically rich environment would be generated through an appreciation of landscape character, the existing sense of place and the creation of a new landscape design respectful of the existing site and parameter conditions. The existing land use, pattern and scale of the wider landscape character, and the openness, enclosure and visual sensitivity of the site are all considered and taken into account on the Illustrative Masterplan.
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Residual Operational Effects
12.6.14 This section of the report assesses residual operation effects after implementation of the operational mitigation measures outlined above.
Landscape Character Areas
12.6.15 The operational impact of the Bexhill Enterprise Park on Combe Haven Valley landscape character area would be predominantly on its south-western part, in the vicinity of Glover’s Farm. The proposed scheme would have direct impact on the area’s character and would cause limited physical impact on its landscape. The proposed development would introduce a variety of planting and landscape features in line with the Countryside Park objectives, improving the transition zone between the rural and urban areas and setting the new built features in a generous landscape framework, sympathetic to the Countryside Park ‘feel’ of the area around Glover’s Farm.
12.6.16 Once the planting matures, the proposed development would help partially mitigate the impact of the NEBGR and BHLR by partially screening both roads and associated traffic from some areas. In the context of the operational NEBGR and BHLR, the proposed development would have a minimal impact on tranquillity of the Combe Haven Valley LCA.
12.6.17 The loss of existing landscape within the site would be compensated by a range of valuable elements and features outlined in the landscape strategy and including trees, shrubs and a variety of water features such as swales and ponds. The proposed development would follow north-facing slope within the site and changes to topography would be limited.
12.6.18 Lighting would cause some adverse impact on this character area, however, once the proposed planting matures, the night-time visibility of the proposed development would gradually decrease. The proposed development would absorb the lighting of the operational NEBGR and therefore the nigh-time visual change within this area would be low. Visibility of the development’s lighting in the northern and eastern parts of this area would be very limited.
12.6.19 The magnitude of operational impact on the overall character of Combe Haven Valley and its landscape features is assessed as low, as it would be limited to a small, peripheral part of this character area and the loss of landscape elements and features would be compensated for with features of higher landscape and ecological value. The operational effect would be permanent. The significance and nature of residual permanent operational effect would be minor and beneficial.
12.6.20 The proposed development would have no physical impact on the Urban Bexhill Area , however, it would create a new, green edge to Bexhill, which would have a beneficial impact on its setting once the landscape proposals mature and absorb the northern part of the operational NEBGR and partially reduce the visibility of the BHLR from the north-eastern part of this character area. The proposed development would not be seen from the majority of Bexhill Urban Area.
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12.6.21 Due to a very limited physical impact on this area, and limited impact on its visual setting and character, the magnitude of operational impact is assessed as negligible and the overall significance of the direct and permanent effect is assessed as not significant.
12.6.22 The proposed development would cause a significant change to the physical landscape and landscape character of the Glover’s Farm area, within which the NEBGR and BHLR would be operational. The majority of landscape elements and features within its southern part would be replaced with the proposed development set within a generous landscape framework, designed to create a sense of place of a Countryside Park, in line with the SPD objectives. The area would become more enclosed while maintaining the key views to the north from its upper topography.
12.6.23 In the context of the NEBGR and BHLR, the proposed development would have a beneficial impact on this area, as it would enclose much of the vehicular traffic and both carriageways, reducing the impact of traffic with more static development set in generous tree planting.
12.6.24 The proposed planting would create a visually attractive, green development with a range of ecological mitigation measures incorporated into the scheme. The presence of new water features, including swales, would attract wildlife and become a destination for the local residents and visitors to the area.
12.6.25 In the wider context, the area would remain enclosed from the east by dense, mature planting to be retained and, thanks to footprint of the development set within the natural, vegetated field boundaries and enclosed by a ridge from the south, the new landscape within this area would create a coherent entity, which would become an integral part of the Countryside Park. Some of the existing, unattractive barns and sheds at Glover’s Farm would be replaced by the development.
12.6.26 There would be adverse impact due to lighting associated with the proposed scheme, however, the overall impact would be low as the development would screen some of the NEBGR and BHLR lighting that would be operational at the time.
12.6.27 The magnitude of operational impact is assessed as high, as the development would result in a significant change of the landscape within the area, however, the nature of this impact is considered to be beneficial due to its ‘green vision’, in in with the Countryside Park SPD and integrating the proposed development into the surrounding landscape, in particular upon the maturation of landscape. The operational effect would be permanent. The significance and nature of this residual effect would be major and beneficial.
12.6.28 The operational impact on the Upper Worsham Farm landscape character area would be minimal, as there would be no physical impact on the area’s landscape and the visibility of the proposed development would be very low and limited to the glimpses of buildings above the vegetated ridge stretching from The Mount to the east. The development would cause negligible impact on the area’s tranquillity, in particular in the context of Wrestwood Road and the NEBGR, which would be operational at this stage. The visibility of development’s lighting would be barely perceptible due to landform and existing woodland.
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12.6.29 The magnitude of operational impact is assessed as negligible, as there would be no physical impact on the area and the development’s visibility would be very low from this area. The operational effect would be permanent. The significance and nature of this residual effect would be not significant.
Visual Receptors
12.6.30 The visual impacts of the proposed development on visual receptors within the LVIA study area have been assessed in the field and are represented by a selection of viewpoints covering all main angled and types of views from residential areas and Public Rights of Way.
12.6.31 Figure 12.7 , Appendix G.1 of the ES shows the locations of viewpoints and the Zone of Theoretical Visibility of the proposed development. Viewpoint panoramas illustrating key views considered in the assessment are reproduced in Figures 12.8.1 to 12.8.10 , Appendix G.1 of the ES.
12.6.32 Receptors at Viewpoint 1 would experience glimpsed views of some new buildings located on higher topography, behind the vegetated ridge stretching from The Mount to the east. The development would be seen in the context of the operational NEBGR, which would run from Wrestwood Road towards the Bexhill Enterprise Park and BHLR farther to the north. There would be no significant change of baseline lighting conditions, as Wrestwood Road generates a significant amount of lighting and the change as a result of the proposed development would be barely perceptible.
12.6.33 The operational effect would be permanent and the magnitude of impact is assessed as negligible. The significance of residual operational effect is assessed as not significant.
12.6.34 Receptors at Viewpoint 2 would experience glimpsed views of some new buildings located on higher topography, above the vegetated ridge to the east of The Mount. The development would be seen in the context of Wrestwood Road and the operational NEBGR, which would be visible in the distance, on the backdrop of the woodland area surrounding The Mount. There would be no significant change of baseline lighting conditions, as Wrestwood Road generates a significant amount of lighting and the change as a result of the proposed development would be barely perceptible.
12.6.35 The operational effect would be permanent and the magnitude of impact is assessed as negligible. The significance of residual operational effect is assessed as not significant.
12.6.36 Receptors at Viewpoint 3 would experience no views of the completed development, which would be located behind the vegetated ridge to the east of The Mount. The operational effect would be permanent and the magnitude of impact is assessed as negligible. The significance of residual operational effect is assessed as not significant.
12.6.37 Receptors at Viewpoint 4 would experience views of the majority of Bexhill Enterprise Park with focus on development in its western part. The buildings and planting would become new features within the landscape and, as a result, the view would become more enclosed. However, key views to the north would be retained. Glimpsed views of the operational NEBGR and BHLR would be available through gaps in the development.
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12.6.38 The generous landscape framework would integrate the built features into the Countryside Park, creating a green development with a rural sense of place. Once the planting matures, the nature of this visual change would be beneficial, in particular in the context of the operational NEBGR and BHLR. A variety of landscape features, including ponds, swales and watercourses, would create a habitat for wildlife and a landmark, green development which would become a destination rather than a negative feature in the landscape. Development’s lighting would have some negative impact in the short distance, however, it would be seen in the context of NEBGR and BHLR lighting in the foreground of the view.
12.6.39 The operational effect would be permanent and the magnitude of impact is assessed as high. The significance and nature of residual operational effect would be major and beneficial.
12.6.40 Receptors at Viewpoint 5 would experience a small visual change compared to the baseline with the completed NEBGR and BHLR, which would become dominant man-made features on the fields in the foreground. The proposed development, including internal vehicular traffic, would be predominantly screened by existing mature vegetation to the east of the site and along the dismantled railway. The BHLR planting would provide further screening, once mature. In the wider context of the view, the visual change would be limited to a small area occupying a small percentage of the wider view and the overall character of the view would prevail. The development would be set in a generous landscape framework, which, once mature, would integrate it into the vegetate ridge. Development’s lighting would be visible in the context of the NEBGR and BHLR lighting and the visual change would not be significant. Buildings located on higher elevation within the site development would, in places, punctuate the skyline, however, the wooded character of the ridge would remain one of the key features within this view.
12.6.41 The operational effect would be permanent and the magnitude of impact is assessed as low. The significance of residual operational effect would be minor and beneficial.
12.6.42 Receptors at Viewpoint 6 would experience a small visual change compared to the baseline with the completed NEBGR and BHLR, which would become new man-made features on the fields in the mid-ground. The proposed development, including internal vehicular traffic, would be predominantly screened by existing vegetation along the dismantled railway. The BHLR planting would provide further screening, once mature. In the wider context of the view, the visual change would be limited to a small area occupying a small proportion of the wider view and the overall character of the view would prevail. The development would absorb the impact of the northern section of the NEBGR and the junction with the BHLR. The generous landscape framework, once mature, would integrate Bexhill Enterprise Park into the vegetate ridge. Development’s lighting would be visible in the context of the NEBGR and BHLR lighting and the visual change would not be significant. Buildings located on higher elevation within the site development would, in places, punctuate the skyline, however, the wooded character of the ridge would remain one of the key features within this view.
12.6.43 The operational effect would be permanent and the magnitude of impact is assessed as low. The significance of residual operational effect would be minor and beneficial.
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12.6.44 Receptors at Viewpoint 7 would only experience views of the most elevated parts of the development due to effective screening provided by existing vegetation along the dismantled railway and to the east of the proposed development, which would obscure views towards the lower parts of the site. During the operational phase, this viewpoint would be located on the BHLR, which would completely dominate the foreground of the view. The BHLR would join with the NEBGR near the dismantled railway and then continue into Bexhill. When mature, new planting would integrate the development into a vegetated ridge and the BHLR screen planting would further reduce the visibility of the enterprise park. With the BHLR in the foreground, the visual change would be limited to a small area occupying a small proportion of the wider view and the overall character of the view would prevail. Development’s lighting would be visible in the context of the NEBGR and BHLR lighting and the visual change would not be significant. Buildings located on higher elevation within the site development would, in places, punctuate the skyline, however, the wooded character of the ridge would remain one of the key features within this view.
12.6.45 The operational effect would be permanent and the magnitude of impact is assessed as low. The significance of residual operational effect would be moderate and beneficial.
12.6.46 Receptors at Viewpoint 8 would experience views of the upper parts of the Bexhill Enterprise Park, however, these would be limited due to the far distance from the site and existing and proposed vegetation that would screen the development. The proposed development would be partially screened by the landscape framework within the site, which would integrate the development into the vegetated ridge. The development would be seen in the context of the NEBGR and BHLR which would be operational at this stage and are included in operational baseline conditions. The BHLR would be visible on the Combe Haven Valley floor in the foreground creating a distraction within the view. In the wider context of the view and a relatively long distance from the application site, the visual change would be limited to a localised area and the overall character of the view would undergo only a small change. Development’s lighting would be visible in the context of the NEBGR and BHLR lighting and the visual change would not be significant. .
12.6.47 The operational effect would be permanent and the magnitude of impact is assessed as low. The significance of residual operational effect would be minor and beneficial.
12.6.48 Receptors at Viewpoint 9 would experience a very small visual change compared to the baseline with the completed NEBGR and BHLR, which would become new man-made features within the Combe Haven Valley. The proposed development, including internal vehicular traffic, would be predominantly screened by existing mature vegetation to the east of the site and along the dismantled railway. The BHLR planting would provide further screening, once mature. In the wider context of the view, the visual change would be barely perceptible and the proposed development would occupy a very small percentage of the wider view. The development would be set in a generous landscape framework, which, once mature, would integrate it into the vegetate ridge. Development’s lighting would be barely visible in the context of the NEBGR and BHLR lighting and the overall visual change would not be significant. Buildings located on higher elevation within the site development would, in places, punctuate the skyline, however, the wooded character of the ridge would remain one of the key features within this view.
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12.6.49 The operational effect would be permanent and the magnitude of impact is assessed as negligible. The significance of residual operational effect would be not significant.
12.6.50 Receptors at Viewpoint 10 would experience very limited views of the upper parts of the Bexhill Enterprise Park due to the far distance from the site and existing and proposed vegetation that would partially screen the development. Built form would be partially screened by the landscape framework within the site, which would integrate the development into the vegetated ridges. The development would be seen in the context of the NEBGR and BHLR which would be operational at this stage and are included in operational baseline conditions. The BHLR would be visible on the Combe Haven Valley floor in the foreground creating a new distraction within the view. In the context of this wide, open view with a number of distinctive features in it, and a relatively long distance from the application site, the visual change would be limited to a localised area and the overall character of the view would prevail. Development’s lighting would be visible in the context of the NEBGR and BHLR lighting and the visual change would not be significant.
12.6.51 The operational effect would be permanent and the magnitude of impact is assessed as negligible. The significance of residual operational effect would be not significant. The lighting impact would be of negligible magnitude and not significant.
12.7 Assessment and Mitigation of Cumulative Effects
12.7.1 The proposed development would cause adverse construction effects in cumulation with the construction of the NEBGR and BHLR on local landscape character, elements and features and on views experienced by local residents, users of public footpaths, road users and workers and residents of local farms. All cumulative construction effects will be direct, short- term, temporary and of primary nature.
12.7.2 In addition to the construction impacts caused by the Bexhill Enterprise Park, the construction of the NEBGR and BHLR would increase to amount of earthworks in the area, vegetation clearance, construction vehicle movements and adversely affect the visual amenity. The construction effects would generally increase in cumulation with the two road schemes.
12.7.3 Table 12.12 provides a summary of cumulative construction effects on landscape character areas and visual receptors.
Table 12.12: Summary of Cumulative Construction Effects Receptor Nature of Effect Significance LCA - Combe Haven Valley Adverse Moderate LCA - Bexhill Urban Area - Not Significant LCA - Glover’s Farm Adverse Major LCA - Upper Worsham Farm Adverse Minor VP 1 - Road users Adverse Minor VP 2 - Local residents Adverse Moderate VP 3 - PRoW users Adverse Moderate VP 4 - PRoW users Adverse Major VP 5 - PRoW users Adverse Moderate VP 6 - PRoW users Adverse Moderate VP 7 - Local residents, PRoW users Adverse Major
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Receptor Nature of Effect Significance VP 8 - PRoW users Adverse Minor VP 9 - PRoW users Adverse Minor VP 10 - Local residents, PRoW users - Not Significant
12.7.4 No additional mitigation measures have been proposed as part of the proposed development to mitigate cumulative effects of the future development within the BX2 allocation, as it is assumed that such mitigation measures would be included in future planning applications in line with the North East Bexhill SPD.
12.7.5 Future development of the entire BX2 allocation would result in the complete change of landscape within the allocation land from agricultural to development. The future development will extend the Bexhill Urban Area onto the Upper Worsham Farm land and the proposals will be naturally bordered and screened from the north by the existing vegetated ridge running from The Mount to the east and separating the future development from the Bexhill Enterprise Park. Once the BX2 allocation is developed, the proposed Bexhill Enterprise Park would not be visible from the south and the impact on visual receptors along Wrestwood Road would be superseded by the impact of future developments.
12.7.6 Similarly, cumulative impacts on views from the north towards the proposed development would not be significant due to distance, existing and proposed screening, elevation and angle of view.
12.7.7 The proposed development has the potential to cause the following cumulative impacts with the development of the wider BX2 allocation:
° Impacts on local landscape character, including the following landscape and townscape character areas: Combe Haven Valley and Upper Worsham Farm Sub Area, due to changes in natural, cultural and aesthetic/perceptual qualities of these character areas;
° Impacts on landscape elements and features within the southern part of the Combe Haven Valley character area and Upper Worsham Farm Sub Area;
° Impacts on visual receptors, such as local residential properties, users of Public Rights of Way, and residents and workers in local farms due to changes in views caused by the proposed employment and the development of the wider BX2 allocation;
° Impacts on PRoW users due to the potential closure and redirection of local footpaths; and
° Lighting impacts on visual receptors and impact on the tranquillity of the wider landscape.
Mitigation of Cumulative Effects
12.7.8 No additional mitigation measures are proposed as part of the proposed development to mitigate cumulative effects of the future development within the BX2 allocation, as it is assumed that such mitigation measures would be included in future planning applications in
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line with the North East Bexhill SPD. At the time of this planning application, no detailed proposals for developments within the wider BX2 land allocation are available.
12.7.9 The proposed landscape and visual mitigation measures designed for the operational NEBGR would help mitigate also potential cumulative effects with the future developments within the BX2 allocation, once the planting has begun to mature.
12.8 Summary of Residual Effects
Construction Effects
12.8.1 The proposed development would cause adverse construction effects on local landscape character, elements and features and on views experienced by local residents, users of public footpaths, road users and workers and residents of local farms. All construction effects will be direct, short-term, temporary and of primary nature.
12.8.2 The impacts would be caused predominantly by earthworks and vegetation clearance within the site, construction of the Bexhill Enterprise Park and removal of peripheral buildings in Glover’s Farm, construction vehicle movement, construction fencing and diversion of PRoWs crossing the site. Lighting impacts during construction of the scheme would be negligible.
12.8.3 The construction impacts would be mitigated by retention of key landscape features within the site according to the BS5837:2012, minimising construction vehicles movement through recycling of soil on site, locating stockpiles and construction compounds in visually discreet locations, shielding of construction lighting and diversion of PRoWs. No advance planting is proposed as part of the scheme.
12.8.4 The main residual construction effects on landscape character would be on local landscape around Glover’s Farm (major adverse) due to physical impacts on the relatively small Glover’s Farm character area and adverse impact on its tranquillity, as well as views within and out of the area. The construction of the proposed development would temporarily cause a major change on the aesthetic and perceptual aspects as well as physical landscape of this character area due to construction activities. There would be minor adverse effects on the landscape of Combe Haven Valley, predominantly due to limited loss of landscape features of local value, relatively scale of the physical impact on this area and limited impact on views within and out of this area. Construction activities would not significantly change the overall perception of this landscape character area and affect its key characteristics. Residual construction effects on the Upper Worsham Farm LCA and Bexhill Urban Area LCA would be not significant due to existing landform and vegetation that would screen the majority of construction activities.
12.8.5 Residual construction effects on visual receptors would be highly localised. Only users of the PRoW in the immediate vicinity of the construction site would experience major, yet temporary, adverse visual impact. Residents of Glover’s Farm would experience similar temporary impacts. Due to increased distance to the site, residents of Acton Farm would experience temporary moderate adverse impacts. All remaining groups of visual receptors within the LVIA study area would experience either minor adverse visual impacts or the impacts would be not significant, as the visibility of construction would be limited from more
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distance areas to the north and very limited (or no visibility) from the areas to the south, east and west.
12.8.6 Table 12.10 provides a summary of construction residual effects on landscape character areas and visual receptors.
Table 12.10: Summary of Residual Construction Effects Receptor Nature of Effect Significance LCA - Combe Haven Valley Adverse Minor LCA - Bexhill Urban Area - Not Significant LCA - Glover’s Farm Adverse Major LCA - Upper Worsham Farm - Not Significant VP 1 - Road users - Not Significant VP 2 - Local residents - Not Significant VP 3 - PRoW users - Not Significant VP 4 - PRoW users Adverse Major VP 5 - PRoW users Adverse Minor VP 6 - PRoW users Adverse Minor VP 7 - Local residents, PRoW users Adverse Moderate VP 8 - PRoW users Adverse Minor VP 9 - PRoW users - Not Significant VP 10 - Local residents, PRoW users - Not Significant
Operation Effects
12.8.7 The proposed, completed development would cause beneficial operational effects on local landscape character, elements and features and on views experienced by local residents, users of public footpaths, road users and workers and residents of local farms. All operational effects would be direct, medium to long-term and permanent and of primary nature.
12.8.8 The proposed development would introduce a variety of planting and landscape features in line with the Countryside Park objectives, improving the transition zone between the rural and urban areas due to a provision of a generous landscape framework. The proposed development would include new man-made features sympathetic to the Countryside Park ‘feel’ of the area.
12.8.9 The landscape design will take inspiration from the wider landscape context of the High Weald. The east-west linear context of the site’s contours would inform the landscape and planting design. The intention of the Illustrative Masterplan is to pull woodland belts through the site on terraces upon which barn style buildings would sit. The wooded terraces would contain informal parking courts set within ‘clearings’ and populated by native woodland trees. The landscape design would have a ‘feel’ of an informal countryside park landscape with formal landscape gestures at buildings.
Residual Cumulative Effects
12.8.10 Future development of the wider BX2 allocation would result in the complete change of landscape within the allocation land from agricultural to development. The future development will extend the Bexhill Urban Area onto the Upper Worsham Farm land and the proposals would be naturally bordered and screened from the north by the existing
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vegetated ridge running from The Mount to east and separating the future development from the Bexhill Enterprise Park. Once the BX2 allocation is developed, the proposed Bexhill Enterprise Park would not be visible from the south and the impact on visual receptors along Wrestwood Road would be superseded by the impact of future developments.
12.8.11 Similarly, cumulative impacts on views from the north towards the proposed development would not be significant due to distance, existing and proposed screening, elevation and angle of view, depending on the representative viewpoint.
12.8.12 The main residual operational effects on landscape character would be on local landscape around Glover’s Farm (major beneficial), where a major change of landscape would occur, however, due to the generous landscape framework, the nature of this change will be beneficial. The development would create a Countryside Park sense of place in line with the SPD objectives. In the context of the NEBGR and BHLR, the proposed development would also have a beneficial impact on this area, as it would enclose much of the vehicular traffic and both carriageways, reducing the impact of traffic with more static development set in generous tree planting. The residual effect on the character and features of the wider Combe Haven Valley would be minor beneficial, as the development would occupy only its peripheral part and the overall change would be low considering the scale of this landscape. Residual operational effects on the Upper Worsham Farm LCA and Bexhill Urban Area LCA would be not significant due to existing landform and vegetation that would screen the majority of the proposed development.
12.8.13 When the landscape framework begins to mature, the main visual effect (major beneficial) would be on users of PRoW in the immediate vicinity of the site and residents of Glover’s Farm. Residents of Acton Farm located farther to the north would experience moderate and beneficial visual impacts. Users of PRoW to the north of the site would experience minor beneficial visual effects. All remaining residual operational visual effects would be not significant.
12.8.14 Table 12.11 provides a summary of operational residual effects on landscape character areas and visual receptors.
Table 12.11: Summary of Residual Operational Effects Significance (incl. Receptor Nature of Effect lighting) LCA - Combe Haven Valley Beneficial Minor LCA - Bexhill Urban Area - Not Significant LCA - Glover’s Farm Beneficial Major LCA - Upper Worsham Farm - Not Significant VP 1 - Road users - Not Significant VP 2 - Local residents - Not Significant VP 3 - PRoW users - Not Significant VP 4 - PRoW users Beneficial Major VP 5 - PRoW users Beneficial Minor VP 6 - PRoW users Beneficial Minor VP 7 - Local residents, PRoW users Beneficial Moderate VP 8 - PRoW users Beneficial Minor VP 9 - PRoW users - Not Significant VP 10 - Local residents, PRoW users - Not Significant
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12.9 Summary
12.9.1 A Landscape and Visual Impact Assessment (LVIA) of the proposed development of the Bexhill Enterprise Park has been completed using standard methodologies, including the 3rd Edition of the Guidelines for Landscape and Visual Impact Assessment. The scope of this LVIA has been determined through Environmental Impact Assessment (EIA) scoping undertaken with the statutory consultees, including Rother District Council (RDC).
12.9.2 The LVIA study area extends to roads A259 and B2182 in the south covering north-east fringes of the Bexhill urban area and in the west it is set along Watermill Lane. To the north, it contains the southernmost edge of the High Weald Area of Outstanding Natural Beauty (AONB) defined by Ballards Hill Road, south of the village of Crowhurst. In the east, the LVIA study area extends to A259 and a railway line running along the urban edge of Hastings. The LVIA study area was consulted and confirmed with the RDC.
12.9.3 There are no national or local landscape designations within the site. The nearest landscape designation, the High Weald Area of Outstanding Natural Beauty (AONB) is located approximately 2.4km to the north of the site. A Site of Special Scientific Interest is located approximately 0.6km to the north-east of the site. There are no other nationally designated landscape, nature or heritage designations within the LVIA study area.
12.9.4 The proposed development would include a generous landscape framework which would contain planting in line with the Countryside Park objectives. The proposed development would include new man-made features sympathetic to Combe Haven Valley Countryside Park landscape. The landscape design would take inspiration from the wider landscape context of the High Weald. The landscape design would aim to achieve a ‘feel’ of an informal countryside park.
12.9.5 The proposed development would have very localised impact on landscape and visual amenity. The adverse impacts of construction would change to beneficial on completion of the scheme, when the planting matures. The main impact would be on local residents and users of some Public Rights of Way in the immediate vicinity of the site and farther to the north (up to Acton’s Farm). There would be no significant impacts on the nationally designated landscape of the AONB and minimal impacts on the landscape and walkers within the proposed Combe Haven Valley Countryside Park. The visibility of the operational scheme in the local landscape would be localised thanks to existing undulating topography and the existing and additional planting.
12.10 References
Council of Europe (CoE), 2004, “ European Landscape Convention CETS No. 176” , (Online) Available from: http://conventions.coe.int/Treaty/en/Treaties/Html/176.htm (Accessed 9 March 2013)
Countryside Agency and Scottish Natural Heritage (CA and SNH), 2000, “ Landscape Character Assessment: Guidance for England and Scotland ”, Cheltenham: The Countryside Agency
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Countryside Agency (CA), 1999, “Countryside Character. Volume 7: South East and London”
Countryside Commission (CC), 1994, “ The High Weald: Exploring the Landscape of the Area of Outstanding Natural Beauty ”, Cheltenham: Countryside Commission
Department for Communities and Local Government (DCLG), 2012, “ National Planning Policy Framework ”
Department for Communities and Local Government (DCLG), 2009, “ The South East Plan. Regional Spatial Strategy for the South East ”, London: TSO.
Department for Communities and Local Government (DCLG), 1997, “Lighting in the Countryside: Towards Good Practice” .
East Sussex County Council (ESCC), 2010, “The East Sussex Landscape Assessment”
East Sussex Rural Forum (ESRF), 2001, “Trees and Woodland. A Strategy for East Sussex. 2001”
Landscape Institute (LI), 2011, “ Photography and photomontage in landscape and visual impact assessment. Advice Note 01/11 ”.
Landscape Institute and Institute of Environmental Management and Assessment (LI and IEMA), 2013, “ Guidelines for Landscape and Visual Impact Assessment. Third Edition ”, London: Routledge.
Landscape Institute and Institute of Environmental Management and Assessment (LI and IEMA), 2002, “ Guidelines for Landscape and Visual Impact Assessment. Second Edition ”, London: Spon Press.Natural England (NE), 2011, “NCA 122: High Weald Key Facts & Data”
Rother District Council (RDC), 2009, “ North East Bexhill Supplementary Planning Document ”. Bexhill-on-Sea: RDC
Rother District Council (RDC), 2006, “ Local Plan. Adopted July 2006 ”. Bexhill-on-Sea: RDC
The Highways Agency (HA), 2010, “ Interim Advice Note 135/10 – Landscape and Visual Effects Assessment ”
UK Parliament, 2000, “ Countryside and Rights of Way Act ”, London: HMSO.
UK Parliament, 1997, “ Hedgerow Regulations (SI 1997/1160) ”, London: HMSO.
UK Parliament, 1949, “ National Parks and Access to the Countryside Act 1949 ” as Amended by the Environment Act, London: HMSO
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13 Ground Conditions
13.1 Introduction
13.1.1 This chapter identifies the likely significant effects of the proposed development in relation to ground conditions with consideration given to potential ground stability and contamination related impacts. This chapter has been prepared by Peter Brett Associates LLP (PBA) and is supported by a Phase 1 Ground Condition Assessment report comprising a ground stability appraisal and a Tier 1 qualitative contamination risk assessment (herein referred to as PBA 2013) presented as Appendix H.1 .
13.1.2 Surface water drainage including water quality is addressed in Chapter 14 of this ES.
13.1.3 The chapter describes the baseline conditions existing at the site and surroundings, the potential direct and indirect effects of the ground conditions, the methods used to assess the impacts, the mitigation measures required to prevent, reduce or offset any significant adverse effects; and the likely residual effects after these measures have been employed.
Impacts Considered
13.1.4 This chapter considers the effects relating to both:
° Potential geological issues arising from land instability (categorised as cavities (natural and anthropogenic), unstable slopes and subsidence due to ground compression); and
° Potential contamination issues associated with land use such as chemical storage and waste disposal.
13.1.5 It is recognised that certain soils can be a cause of land instability, either as a result of natural processes or as a result of historical anthropogenic activities such as mining or excavation, resulting in landslides or slips, soil creep, and ground compression. Where there are reasons for suspecting instability, appropriate assessments are undertaken to determine whether a development will be threatened by unstable ground conditions.
13.1.6 In addition, the presence of contamination can impact human health and the environment, adversely affecting or restricting the beneficial use of land. Without appropriate mitigation, the presence of substances with potential to cause harm to human health, property and the wider environment may limit or altogether preclude development.
Study Area for Ground Conditions
13.1.7 The assessment presented in this chapter is focussed on a study area comprising the site. Searches were commissioned on point source (grid reference 574960, 109270) with radii of up to 1km from this point (the 1:2500 scale historical maps were based on a search radius of 250m). The point source is located approximately 350m south east from the centre of the proposed development, given that the data was originally sourced to provide information for the proposed North East Bexhill Gateway Road (NEBGR), which will pass through the centre
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of the proposed Bexhill Enterprise Park. Whilst the two developments are separate, they are inherently linked. The information provided includes a buffer zone to include sufficient environmental site sensitivity and historical mapping of the proposed development and its environs to enable an assessment of the environmental setting of the site to be determined. The date of source data was February 2013 and is considered to be submission suitable basis for this assessment.
13.2 Policy Context
Legislation
13.2.1 The protection and conservation of the soil and groundwater environment is covered within a variety of legislative and policy frameworks.
13.2.2 UK legislation on contaminated land is principally contained in Part 2A of the Environmental Protection Act (EPA), 1990, as amended by the Environment Act 1995. The Statutory Guidance that accompanies the Act has recently been revised and was issued by DEFRA in April 2012 (Department of Environment, Food and Rural Affairs Environmental Protection Act 1990: Part 2A Contaminated Land Statutory Guidance).
13.2.3 Contaminated Land for the purpose of Part 2A is defined as: “…any land which appears to the local authority in whose area it is situated to be in such condition, by reason of substances in, on or under land that: (i) Significant harm is being caused or there is significant possibility of such harm being caused; or (ii) Pollution of controlled waters is being, or is likely to be, caused.”
13.2.4 Part 2A defines ‘harm’ as “harm to the health of living organisms or other interference with the ecological systems of which they form part, and, in the case of man, includes harm to his property.” The notion of ‘significant harm’ and the ‘significant possibility’ of such harm being caused is also set out within Part 2A. The local authority is required to assess whether the harm, or the possibility of the harm being caused, is significant. The definition is modified where harm is attributable to radioactivity.
13.2.5 The principle of risk assessment underlies the determination of whether these definitions apply in the identification of contaminated land. Risk assessment is carried out via ‘source- pathway-receptor’ principles to evaluate the potential for pollutant linkages and to identify unacceptable risk. The application of risk assessment techniques to the management of contaminated land is set out in the technical framework presented in the Model Procedures for the Management of Contaminated Land (EA 2004).
13.2.6 DEFRA recently reviewed the contaminated land regime in England for the first time since its introduction in 2000. The purpose was to consider whether improvements could be made to the regime, taking into account the experience of nearly ten years of delivery and the latest scientific evidence. The review found the primary legislation (Part 2A of the Environmental Protection Act 1990) remained fit for purpose, and there was a strong need to keep it, however there were flaws in the accompanying Statutory Guidance which had undermined the effectiveness of the regime and created considerable regulatory uncertainty.
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13.2.7 Following the review of the contaminated land regime including public consultation, revised Statutory Guidance was issued and the Contaminated Land (England) (Amendment) Regulations 2012 (SI 2012/263) and the Contaminated Land Statutory Guidance for England 2012 came into force on 6th April 2012. This revised Statutory Guidance while still taking a precautionary approach allows regulators to make quicker decisions about whether or not land is contaminated under Part 2A preventing costly remediation operations being undertaken unnecessarily. It also offers better protection against potential health impacts by concentrating on the sites where action is actually needed.
13.2.8 The 1980 Groundwater Directive 80/68/EEC and the 2006 Groundwater Daughter Directive 2006/118/EC of the Water Framework Directive 2000/60/EC (WFD) are the main European legislation in place to protect groundwater. Under Article 22 of the WFD the 1980 Directive is due to be repealed in December 2013.
13.2.9 Controlled waters are also protected by Part 2A of the Environmental Protection Act 1990.
13.2.10 The Environment Agency has a remit to prevent or reduce the risk of water pollution, wherever possible, and to ensure that it gets cleaned up if pollution occurs that might lead to effects on ecosystems or people. A regulatory regime supporting this policy has been introduced by the Water Resources Act 1991 (as modified by the Environment Act 1995), the Environmental Permitting Regulations 2010.
National Planning Policy Framework
13.2.11 The publication of the National Planning Policy Framework (NPPF) in March 2012 and its immediate implementation has resulted in the withdrawal of the following national planning policies associated with ground conditions:
° Planning Policy Statement (PPS) 9: Biodiversity and geological conservation;
° Planning Policy Guidance (PPG) 14: Development on unstable land;
° Planning Policy Statement (PPS) 23: Planning and pollution control; and
° Letter to the Chief Planning Officers: Model planning conditions for development on land affected by contamination.
13.2.12 Associated with the release of the NPPF is the review of the technical guidance that accompanies Section 57 of the Environmental Protection Act (EPA). This guidance came into force in April 2012 and reviews the way contaminated land is assessed under the EPA.
13.2.13 Section 11, Paragraphs 120 and 121 of the National Planning Policy Framework (NPPF) (DCLG 2012) describe the policy considerations the Government expects Local Planning Authorities (LPA) to have in regard to land affected by contamination when preparing policies for development plans and in taking decisions on applications.
13.2.14 For planning purposes, the NPPF requires that the assessment of risks arising from contamination and remediation requirements should be considered on the basis of the
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current environmental setting, the current land use, and the circumstances of its proposed new use. The NPPF stipulates that planning policies and decisions should ensure that:
° “The site is suitable for its new use taking account of ground conditions and land instability, including from natural hazards or former activities from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation” ; and that
° “After remediation, as a minimum, land should not be capable of being determined as contaminated land under Part 2A of the Environmental Protection Act 1990; and adequate site investigation information, prepared by a competent person, is presented.”
Regional Spatial Strategy
13.2.15 The Regional Spatial Strategy for the South East was revoked on 25th March 2013, with the exception of two spatially specific policies. Neither of these retained policies relate to the proposed development, as they are spatially specific.
Local Planning Policy
13.2.16 The Rother Local Plan was adopted in June 2006. The Local Plan is the statutory local plan for Rother District. The Local Plan 2006 sets out a framework of policies to guide and encourage development in the District, whilst safeguarding and enhancing the environment. The following policies from the Local Plan are considered relevant in relation to ground conditions.
Policy DS1
13.2.17 In determining whether development is appropriate in a particular location, proposals should accord with the following principle:
(xiii) To “avoid development on unstable land except where the proposal demonstrates that actual or potential instability can reasonably be overcome.”
Policy DG1
13.2.18 All development should meet the following criteria:
“(x) It provides adequate and appropriate means for foul and surface water drainage, with suitable alleviation and mitigation measures where necessary and does not prejudice water quality”; and
“(xiii) Which states that the development should properly address any known or suspected contamination of the site, or threat from landfill gas, through site investigations and suitable remediation.”
13.2.19 Appendix 2 of the Local Plan refers to Key Structure Plan and Waste Local Plan policies as referenced in the Local Plan and includes:
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Twenty One Criteria for the 21st Century
“(g) Protecting and enhancing water quality and maintaining groundwater and river levels for human consumption, industrial and agricultural water supply and to support local biodiversity”;
“(h) Avoiding the development of land which is unstable, at risk to flooding or which would be likely to increase the risk of flooding elsewhere”; and
“(j) According with the objectives of and not causing damage to the Sussex Downs and High Weald Areas of Outstanding Natural Beauty (AONB), Ashdown Forest, downland, wetland, open heathland, ancient woodlands, undeveloped coast (including Heritage Coast), Sites of Special Scientific Interest (SSSI), Special Protection Areas (SPA), Special Areas of Conservation (SAC), Ramsar sites, nature reserves, ancient monuments, conservation areas, historic parks and gardens, battlefields and other areas of designated or recognised important landscape, archaeological, geological, ecological or historical character and their settings.”
Nature Conservation
13.2.20 EN17 states that “the existing natural resource of species, habitats and geological features, including statutory sites of national and international importance and their settings, ancient woodland, and other sites of demonstrable geological, landscape or wildlife importance (including the active residence of specially protected species) will be protected from damage. Particular regard will be paid to the protection of river corridors and the special habitats of downland, wetland, open heathland, ancient woodland, meadows, salt marsh and shingle. This policy includes sites notified under the Ramsar convention, Special Protection Areas (SPA) and Special Areas of Conservation (SAC); Sites of Special Scientific Interest (SSSI), National, Marine and Local Nature Reserves (NNR, MNR, LNR); and non-statutory sites such as Sites of Nature Conservation Importance (SNCI) and Regionally Important Geological Sites (RIGS).”
Guidance
13.2.21 There are numerous technical guidance documents on the assessment and management of contamination including Contaminated Land Report CLR 11 (EA 2004).
13.2.22 A summary of the guidance relating to the protection of groundwater resources is presented in the publication by the Environment Agency (EA) entitled ‘Groundwater Protection: Principles and Practice (GP3)’ (EA, 2012).
13.3 Methodology
13.3.1 A combined EIA Screening and Scoping Opinion was sought from RDC on the 14th March 2013. In relation to ground conditions the development was identified as being on agricultural land “unlikely to include significant contamination” . It was therefore proposed that the ground conditions chapter would be based on a Tier 1 Ground Conditions Assessment.
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13.3.2 A Scoping Opinion was issued by RDC on the 10th May 2013, reference PE/01358/2012, which supported the proposed approach. In relation to ground conditions RDC states that:
“The ES should explain the extent of the study area and justify the reasons for this. The Tier 1 Ground Conditions Assessment (desk study) should cover a sufficiently large area to address all potential risks. The Environment Agency welcomes the inclusion of assessment as part of the EIA and note that there are no known areas of contaminations. The commitment to consider the need or otherwise for a Phase 2 Preliminary Ground investigations is welcomed. The ES should justify the decision taken.”
13.3.3 Furthermore the Scoping Opinion Included correspondence from the Environment Agency dated 12th April 2013 reference KT/2013/116126/01-L01 which stated in relation to Land Contamination:
“We would have no outright concerns regarding the proposed development. We welcome the inclusion of Sustainable Drainage Systems within the development: these can be very effective at attenuating potential pollutions prior to discharge to controlled waters. The intended Tier 1 Ground Conditions Assessment is noted; although there are no known areas of contamination we welcome its inclusion.”
13.3.4 Model Procedures for the Management of Contaminated Land Report CLR 11 (EA 2004) promotes a tiered approach to the assessment of land and water quality as follows:
° Tier 1 – A qualitative assessment of historical and published information, together with a site reconnaissance, undertaken in order to develop a preliminary conceptual site model and inform a preliminary risk assessment;
° Tier 2 – An assessment of ground condition data using published generic assessment criteria to screen the site and establish whether there are actual, or potential, unacceptable risks; and
° Tier 3 – detailed – A quantitative assessment involving the generation of site specific assessment criteria (SSAC).
13.3.5 In order to evaluate whether the presence of a source of contamination could potentially lead to harmful consequences a source-pathway-receptor methodology is adopted, with the underlying principle the identification of pollutant linkages. A pollutant linkage consists of the following three elements:
° A source/hazard (a substance or situation that has the potential to cause harm or pollution);
° A pathway (a means by that the hazard moves along / generates exposure); and
° A receptor/target (an entity that is vulnerable to the potential adverse effects of the hazard).
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13.3.6 Without a pollutant linkage the contamination may be a hazard but does not constitute a risk unless all three elements are present. Therefore, in assessing the potential for contamination to cause a significant effect, the extent and nature of the potential source or sources of contamination must be assessed, pathways identified, and sensitive receptors or resources identified and appraised, to determine their value and sensitivity to contamination related impacts.
13.3.7 The methodology that has been used for the assessment of significant effects is presented below and includes assessment of (1) the effects of the ground conditions on the proposed development and (2) the effects of the proposed development on the ground conditions. Where relevant, reference is made to other specialist chapters within this Environmental Statement.
13.3.8 The assessment has been carried out with reference to the requirements of the Design Manual for Roads and Bridges (DMRB) Volume 4, Section 1 (Earthworks), Part 7 and DMRB Volume 11, Section 3 (EIA Techniques), Part 11 which requires:
° Identification of Baseline Conditions – In this instance these have been determined from a review of available published information as described in the Tier 1 report in Appendix H.1 ;
° Prediction of the changes to the baseline conditions as a result of the proposed development;
° Identification of the mitigation measures required;
° Assessment of the residual construction impacts in the context of the proposed mitigation;
° Assessment of the residual operational impacts in the context of the proposed mitigation; and
° Conclude the key findings.
13.3.9 The methodology adopted in this chapter is qualitative with a progression from factual information (stated with reasonable certainty) regarding the baseline conditions, to appraisal informed by professional judgement and expression of opinions on the relative significance.
13.3.10 Baseline conditions have been identified using a Phase 1 Ground Condition Assessment report (PBA 2013) which presents information on the geotechnical and geoenvironmental setting of the site, attached as Appendix H.1 . PBA 2013 describes the types and locations of:
1 Potential Sources of Contamination (PSCs), based on identification of current and historic landuse; and
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2 Potential Geological Hazards (PGHs), based on identification of geological hazards (such as slope stability, compressibility, high groundwater levels, shrinkage/swelling of clay stratum).
13.3.11 The report also identifies the type and sensitivity of potential receptors (including consideration of human health, buildings, groundwater, surface water and ecological systems) and identification of possible migration or transportation pathways.
13.3.12 Whilst there are some inherent limitations associated with Phase 1 studies, it is considered that any uncertainties with the land and water quality baseline dataset for the proposed development are small.
13.3.13 The Phase 1 Ground Condition Assessment report presents information from the following sources of information:
° Review of PBA North East Bexhill Gateway Road (NEBGR) Phase 1 Ground Condition Assessment reference 27511/003/R01/rev0 dated February 2013, which included Historical and current Ordnance Survey maps and environmental information in the public domain;
° Review of readily available published geological maps and memoirs;
° Review of British Geological Society (BGS) Borehole Records (if appropriate/available);
° Review of PBA’s national natural and mining cavities (non-coal) databases;
° Review of current guidance on the potential for radon to be present;
° Review of published maps on hydrogeology and groundwater vulnerability;
° An internet search (using Google or a similar search engine) ;
° Web based information on ecological sites with international and national designations using a search radius of 1, 2 or 5km depending on the site specific circumstances; and
° Inspection of the site and surrounding area for visual evidence of potentially contaminative features.
13.3.14 A potential risk exists when a pollutant linkage is identified when all the three elements are connected. The level of ‘Risk’ involves establishing what degree of harm might result to defined receptors (consequence) and how likely (the probability of the event occurring).
13.3.15 Significance of effect is a function of the magnitude of impact (deviation from the baseline condition), the sensitivity and value of the receptor/resource, the duration and reversibility.
13.3.16 A receptor is classified in terms of its value or sensitivity; the criteria used in this ground conditions chapter are described in Table 13.1 . The classifications have been generated using descriptions of environmental receptor importance and value given in various guidance
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documents including NHBC 2008 and DETR 2000. Human health and buildings classifications have been generated by PBA using the attribute description for each class.
Table 13.1: Criteria Used in Ground Conditions for Classifying Receptor Value or Sensitivity) Classification Definition Groundwater: Source Protection Zone High Surface water: High Ecological Status Receptor of Ecology: Special Areas of Conservation (SAC and candidates), Special Protection national or Areas (SPA and potentials) or wetlands of international importance (RAMSAR) international importance Buildings: World Heritage site or Conservation Area Human health: Residential and uses where children are present Groundwater: Principal aquifer & Secondary A aquifer Medium Surface water: Good or Moderate Ecological Status Receptor of Ecology: SSSI, National or Marine Nature Reserve (NNR or MNR) County wildlife county or sites regional importance Buildings: Area of Historic Character Human health: Employment Groundwater: Secondary B aquifer or Unproductive Low Surface water: Poor Ecological Status Receptor of Ecology: local habitat resources or no designation local importance Buildings: Local value Human health: Transient or Limited Access
13.3.17 For the purposes of this ground condition chapter the following criteria have been adopted to describe magnitude:
° Large – A discernible impact that causes a key attribute of the receptor to be lost/degraded;
° Moderate – A discernible impact that exceeds a standard (for example a soil guidance value (SGV) but that does not cause a key attribute of the receptor to be lost / degraded;
° Small – A discernible impact that is below a standard (for example a soil guidance value (SGV) and does not cause a key attribute of the receptor to be lost/degraded; and
° Negligible – No discernible impact.
13.3.18 The matrix for assigning the various significance criteria is presented as Table 13.2 .
Table 13.2: Significance Criteria for Ground Condition Effects
Sensitivity/ Magnitude of Effect Value of Receptor Large Moderate Small Negligible High Severe Major Moderate Minor Medium Major Moderate Minor Not Significant Low Moderate Minor Not Significant Not Significant
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13.3.19 The proposed mitigation measures used to manage any likely significant effects (including management of risk or elimination of pollutant linkage) are identified using professional judgement and experience, drawing upon relevant guidance.
13.3.20 Residual effects are then identified and further assessment of significance carried out. Significance considers the scale and duration of the effect creating the impact so that a localised (small scale), short term impacting event is assigned a lower significance than a regional (large scale) or long term event. Additionally, greater significance is assigned to pollution or damage that is non-reversible.
13.4 Baseline Conditions
13.4.1 This section describes the baseline conditions established from the studies identified above and current at the time of reporting.
Geological Setting
13.4.2 The published geological map (BGS, 1980) identifies within the site or in the immediate vicinity the following features:
° No superficial deposits.
° The site is underlain by the Ashdown Beds described as locally thinly laminated and closely fissured sandstone, siltstone and mudstones.
° Bands of the underlying ‘Clay in Ashdown Beds’ are shown at surface to the south of the site immediately adjacent to woodland (the Mount) and as a thin band to the east of the site.
° An outcrop of the overlying Wadhurst Clay is shown to the east of the site at the top of the northern slope, with a further outcrop to the north west (downslope).
° Two faults are shown at surface bounding the site. The first trending east west across the southern boundary and a second adjacent to the northern boundary also trending east west and at this point appearing along the dismantled railway. Both faults are shown as down thrown to the north.
° There are a number of published borehole records in the vicinity of the site. A well record 54.9m deep approximately 150m to the east of the eastern boundary site shows alternating beds of clay, sand and stone to the termination depth of the well. No geological units are given however the stratigraphy described is indicative of expected geology provided by the geological maps. A cluster of boreholes located approximately 100 to 150m to the north east of the north eastern corner of the site show clays from the Ashdown Beds underlying topsoil to a depth no greater than 0.4m. Underlying the clays at a depth between 7.5m to below present ground level (bgl) 16.0m bgl claystone is encountered. Water was noted to be seeping into the boreholes at depths between 3.8m bgl to 6.2m bgl.
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° PBA are aware of a number of intrusive investigations for the BHLR, however, at this time no records have been made available.
Hydrogeological Setting
13.4.3 The Ashdown Beds are designated a Secondary A (formerly Minor) Aquifer with the Clays in Ashdown Beds unclassified (formerly a Non Aquifer).
13.4.4 There are no reported licensed groundwater abstractions within 2km of the site centre.
13.4.5 The site is not located within any groundwater Source Protection Zone (SPZ).
13.4.6 Given that the site geology comprises Ashdown beds overlying Clay in Ashdown Beds the groundwater levels at the site are likely to be variable and in large areas of the site, depending on topography, close to surface.
13.4.7 Water strikes within these deposits may also be sub artesian in nature due to the presence of confining less permeable clay layers within the Ashdown Beds.
Hydrological Setting
13.4.8 The nearest main river is Coombe Haven Stream located some 500m to the north. Various unnamed surface water features have been identified on the site including drains and issues.
13.4.9 It is known that spring lines are commonly found in the local area at the boundary of relatively permeable deposits and less permeable horizons, in particular, at the boundary between the more permeable Ashdown Beds and the underlying Clay in Ashdown Beds. Three springs were observed in depressions spread towards the southern (higher elevation) boundary of the site. This suggests the majority of the site is overlain by a relatively impermeable layer however where the ground level drops a more permeable layer will be encountered.
13.4.10 Two of these springs were noted at being at the top of the two largest ‘ghylls’ on-site. ‘Boggy’ ground was noted down the majority of these two ghylls with water starting to flow towards the northern boundary. Flowing water is collected from these two springs at the northern boundary by pipes located at the base of the two separate ghylls. The water is then piped under the dismantled railway embankment towards the north eastern corner of the site and discharged into open ditches. Flow at this point was observed to be a steady flow approximately 100mm deep. The third spring day-lights in a drainage trench next to a farm track running parallel to the eastern edge of the western paddock. Boggy ground was noted for approximately 10.0m where water had pooled in a pond approximately 1.0m in diameter and no deeper than 200mm.
13.4.11 Historical mapping show ‘issues’ located immediately north of the north eastern corner of the site on the opposite side of the northern side of the dismantled railway and at the top of the eastern ghyll. ‘Sinks’ and springs are shown at the base of the western ghyll. Water collecting from these features is shown to be collected along the northern boundary of the
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site and discharged on the northern side of the north eastern boundary as described in the previous paragraph.
Land Use
13.4.12 The site is located on Glovers Farm and can generally be split into three areas:
° A cluster of buildings (barns, storage sheds, etc.) located in the western corner of the site;
° A smaller central paddock used for a grazing animals; and
° A larger eastern paddock also used for grazing animals.
13.4.13 Bounding the southern boundary is a farm track which starts at the Glovers Farm complex and continues past the eastern boundary and heads towards the neighbouring farm. Splitting off to the north of this farm track another track separates the central and eastern paddocks and continues on to the north under the existing dismantled railway embankment. Splitting off to the south of the southern boundary farm track is a gated access track which leads through to an area, approximately 300m to the south, through wood to a clearing containing a buried water reservoir and telecommunications mast (referred to as The Mount). Consent to discharge process effluent to freshwater stream / river is held by South East Water Ltd at this location.
13.4.14 The railway line and embankment at the northern site boundary (Bexhill Branch) was constructed prior to 1909 and the track removed prior to 1968 (dismantled). The railway is in cutting where it passes through the residential area to the west of the site, under Glovers Lane, adjacent to Glovers Farm moving to embankment as the ground elevation falls to the east.
13.4.15 A triangular shaped area immediately to the north of the railway line has been identified as an area of landfill known as ‘Glovers Farm’ at Glyndebourne. The landfill reference is given as WR2-156 and reported to have accepted inert waste between 1970 and 1974. However, correspondence from the Environment Agency (EA) in 2006 indicates that non-inert wastes were deposited.
Potential Receptors
13.4.16 Human Health – During the construction phase there will be worker occupation at the site. Off-site land users are predominantly transient being farmland, but the adjacent farms are assumed to be occupied and residential in nature. The development of the Bexhill Enterprise Park will introduce human occupants and the construction of the NEBGR and the BHLR will introduce transient human traffic. Construction workers, commercial end users and transient human traffic have been taken forward as potential receptors during the construction phase and operational phase respectively. Consideration has also been given to potential future occupiers of residential development allocated to the south east of the site. A worst case sensitivity value of High has been used for human health receptors.
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13.4.17 Controlled Waters – On-site surface water bodies and groundwater have been taken forward as potential receptors during both the construction phase and operational phase. A worst case sensitivity value of Medium has been used for controlled water receptors.
13.4.18 Ecological Systems – Coombe Haven Local Nature Reserve, located some 835m north east of the site, is designated a Site of Special Scientific Interest (SSSI). The DMRB identifies that statutory bodies will be given the opportunity to comment on developments within 100m of a statutory designated sites. Whilst the distance to the ecological systems would normally have been eliminated as potential receptors for the purposes of ground condition assessment, it should be noted that connectivity via surface water and groundwater migration will be considered under controlled water receptors (i.e. worst case sensitivity value of Medium).
13.4.19 Archaeology, Ancient Monuments and Industrial Heritage – Based on the land use information identified these have been eliminated as potential receptors for the purposes of the ground condition assessment.
13.4.20 Buildings and Property – Includes buildings / structures, services / pipes, crops, livestock, pets, woodland. The current onsite land use is farmland (crop and animal receptors) and woodland. The MAGIC web site shows the site to be located in an area where the Agricultural Land Classification is Grade 3 Good to Moderate. The Soilscapes Viewer on Landis.org.uk describes the soil as slightly acid loamy and clayey with slightly impeded drainage and moderate to high fertility. The employment space will introduce construction materials and services. Consideration is given to chemical attack (aggressive ground conditions) and physical failures due to instability hazards. A sensitivity value of Low has been used for these receptors.
13.4.21 Regionally Important Geological and Geomorphological sites (RIGS) – none have been identified within 100m of the site and therefore RIGS are eliminated as potential receptors.
Potential Geological Hazards (PGH)
13.4.22 NPPF paragraph 121 requires an assessment of potential constraints associated with ground instability. Three categories are considered (i) cavities (natural and anthropogenic), (ii) unstable slopes and (iii) subsidence due to ground compression.
13.4.23 PGH 1 Cavities – Based on the available data (no recorded presence) this PGH has been eliminated.
13.4.24 PGH 2 High Groundwater and Unstable Slopes – Whilst there is no evidence of instability present at the site, there are surface water features within the site and there is likely to be localised high groundwater and possibly sub-artesian conditions which have the potential for weaken founding strata. PGH2 has been assigned a hazard rating of 3 out of 5 typically with the potential to cause a Moderate magnitude of change, although for human health this could be Large.
13.4.25 PGH 3 Compression – The Ashdown Beds and Clay in Ashdown Beds may contain a significant proportion of clay sized particles. There may be potential for these deposits to
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shrink/swell upon changes in moisture content as these materials will be susceptible to seasonal changes in moisture content. Similarly in areas close to any pre-existing trees or hedgerows the moisture content of the soils may be slightly lower than the surrounding area, presenting the potential for swelling/ground heave to occur as the moisture content recovers following removal of vegetation during site clearance. There are also geological faults crossing the site and as a result of potentially differing strata to be present there is the potential for differential settlement to occur. PGH3 has been assigned a hazard rating of 3 out of 5 typically causing Moderate magnitude of change, or possibly Large.
Potential Contamination Hazards (PCH)
13.4.26 PCH 1 – Agricultural – On site. The site is part of a wider area of farmed land with the potential for residual chemicals associated with land and crop spraying. Furthermore given the presence of Glovers Farm, with agricultural plant and machinery being stored at the farm there is the potential for chemical, fuel and oil spillages. Potential contaminants include Herbicides, Biocides and Fertilisers and Hydrocarbons. PCH1 has been assigned a hazard rating of 1 out of 5 with the contamination typically only generating a Small magnitude of change.
13.4.27 PCH 2 – Agricultural – Off site. The site is part of a wider area of farmed land with the potential for residual chemicals associated with land and crop spraying. Furthermore given Glovers Farm also extends off-site, with agricultural plant and machinery being stored at the farm there is the potential for chemical, fuel and oil spillages. Potential contaminants include Herbicides, Biocides, Fertilisers and Hydrocarbons. PCH2 has been assigned a hazard rating of 1 out of 5 with the contamination typically only generating a Small magnitude of change.
13.4.28 PCH 3 – Historic Landfill – Off site. Anecdotal information on the presence of putrescible waste in a designated Inert Landfill. Potential contaminants include flammable and/or asphyxiant gases. PCH3 has been assigned a hazard rating of 3 out of 5 typically with the potential to cause a Moderate magnitude of change, although for human health this could be Large.
13.4.29 PCH 4 – Storage of fuels during construction phase with possible spillage. Potential contaminants include Hydrocarbons. PCH4 has been assigned a hazard rating of 3 out of 5 typically with the potential to cause a Moderate magnitude of change.
13.4.30 PCH 5 – Contaminated run-off from roads and car parking. Potential contaminants include hydrocarbons and metals as well as unknowns associated with spillage of chemicals during transportation. PCH5 has been assigned a hazard rating of 3 out of 5 typically with the potential to cause a Moderate magnitude of change but with a worst case of Large for chemical spillages during accidents.
13.4.31 PCH 6 – Storage / use of chemicals during operational phase. Potential contaminants may include hydrocarbons as well as unknowns. PCH6 has been assigned a hazard rating of 3 out of 5 typically with the potential to cause a Moderate magnitude of change.
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13.5 Assessment and Mitigation of Construction Effects
Assessment of Construction Effects
13.5.1 Construction phase activities could disturb, expose or mobilise existing contamination. The works will introduce new potential contamination sources through the temporary storage of chemicals (fuels) and potentially through the importation of soils for earthworks. Instability hazards (slope failure) could be activated by the works. Some form of moisture conditioning or treatment may be required to achieve suitable compaction densities.
13.5.2 It is reiterated that for the purposes of this chapter, potential effects have been initially assessed in the absence of mitigation that will be incorporated into the detailed design of the development in order to make the site suitable for use.
13.5.3 PGH2. The localised high groundwater hazard will require control mitigation measures to be incorporated during construction. Such risks will need to be considered and allowed for in design in order to facilitate construction such that the quality of ground and surface waters are not adversely affected. Dewatering of excavations could discharge contaminated water into surface water with a Moderate magnitude of change. Landslide instability could, in the event of an extreme event, cause loss of life to construction workers (a large magnitude of change on a receptor classed as High sensitivity), could alter surface water drainage (a Moderate magnitude of change on a receptor classed as Medium sensitivity) and will cause the loss of agricultural soil (a worst case magnitude of change of Large on a receptor classed as Low value / sensitivity).
13.5.4 PGH3 Compression Instability is not a construction phase hazard as it relates to differential settlement caused by the development on the ground.
13.5.5 PCH1 and 2 are hazards associated with agricultural land use. Construction workers could come into contact with residual chemicals and dust could be generated by the works and migrate to off-site receptors. The magnitude of change is likely to be Small.
13.5.6 PCH3 is an historic landfill located outside of the construction works with the potential for gas generation and migration. The magnitude of change is given a worst case of Large for loss of life in the case, of an extreme event, of explosive atmosphere. The construction works are not considered to cause the hazard to affect any other receptors.
13.5.7 PCH4 is the storage of chemicals during construction works. The magnitude of change caused by spillage is considered to be Small for Human Health receptors. The hazard could impact controlled waters but due to the relatively small volumes the magnitude of change is assessed as Moderate.
13.5.8 PCH5 and 6 are not hazards present during construction phase.
Mitigation of Construction Effects
13.5.9 Soil and / or groundwater remediation is considered unlikely to be required given the nature of the contaminant sources identified, however this will be confirmed through intrusive
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ground investigations. Mitigation measures will be adopted to reduce the potential impacts of contamination associated with (a) dust generation during earthworks, (b) run- off/dewatering discharges, (c) chemical storage/spillage and (d) Health and Safety of Workers (H&S) with respect to skin contact, inhalation and ingestion of contaminated material whilst on the site. Such measures will follow the pollution prevention guidelines issued by the Environment Agency and CIRIA (2001).
13.5.10 Potential ground instability hazards have been identified within the site. The potential impacts of hazards will be addressed through appropriate design of any earthworks slopes and drainage and incorporation of techniques such as retaining walls, reinforced earth, or soil nailing, french or counterfort drains drainage blankets or reinforced earth as necessary. The localised high groundwater hazard will require control mitigation measures to be incorporated during construction by way of groundwater control in excavations for example.
13.5.11 An intrusive investigation will be undertaken, the findings of which will inform the mitigation measures to be implemented. Whilst ground investigation works will be required in due course in order to confirm the nature of the ground conditions, it is considered at this stage that viable risk management options are available that can be managed through mitigation measures / adoption of good practise measures during construction.
13.5.12 It is recognised that should soil conditioning or treatment be required as part of the earthworks for the scheme construction then there may be the potential to cause dust. Earthworks guidance is presented in DMRB including management of dust generation (dust mitigation measures are identified in Chapter 10 : Air Quality). Should any form of chemical stabilisation be considered then the treated soil could have the potential to impact controlled water receptors. Field trials would ensure that behaviour is characterised and the mix is optimised. Construction of temporary or permanent earthworks drainage prior to earthworks operations would prevent uncontrolled run-off. Generation of contaminated run-off could be minimised through the control of earthworks and use of compaction of soils to prevent infiltration ingress.
13.5.13 In accordance with current health and safety legislation, the contractor will be required to adopt measures to mitigate the risk to site workers.
13.5.14 An earthworks strategy describing removal, handling, storage and placement of will be developed following award of the contract to construct the scheme and will form part of the Construction Environmental Management Plan (CEMP), to be secured through a suitable planning condition.
13.5.15 The development will seek to promote the re-use of excavated materials through optimisation of cut and fill operations in order to improve the sustainable and cost effective development of land. The use of the Definition of Waste: Development Industry Code of Practice (DoWCoP) provides a clear, consistent and streamlined process which enables the legitimate reuse of excavated materials on-site or their movement between sites with a significantly reduced regulatory burden. In many instances the DoWCoP can provide an alternative to Environmental Permits or Waste Exemptions when seeking to reuse excavated materials.
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13.5.16 The CEMP will document the environmental management procedures during construction include the measures to manage chemical storage. The mitigation measures for management of run-off/dewatering discharges are presented in Chapter 14 : Surface Water and Drainage. Such measures will follow the pollution prevention guidelines issued by the Environment Agency and CIRIA (2001).
13.5.17 The potential for the off-site landfill to generate gas is not known and a worst case scenario has been assumed. Unless proven otherwise temporary structures should be elevated above ground level to prevent gas ingress.
13.5.18 There will be a loss of agricultural soil which should be considered expected given that the local planning policy designates the site for development, rather than agriculture.
13.5.19 The employment area will be designed to avoid / minimise the potential for instability via the design of appropriate slope angles, incorporation of groundwater control measures or soil reinforcement as necessary.
13.5.20 Appropriate design requirements for construction materials will be specified to mitigate against risks from land and water quality and the associated hazards.
13.5.21 The measures to mitigate the risk to land, ground and surface waters described above will effectively mitigate the risk to ecology and wildlife. The identified sensitive receptors associated with the Coombe Valley SSSI is however recognised and as such emergency control measures should be put in place to deal with any localised spillages to protect the surface water and ground water.
13.6 Assessment and Mitigation of Operational Effects
Assessment of Operational Effects
13.6.1 The proposed development comprises an employment space (within use classes B1a, B1b and B1c) and associated uses including plant, pedestrian and vehicle circulation, car parking, cycle parking, landscaping, and utilities. The majority of the site will therefore be hard cover/paved however it is recognised that areas either side of the NEBGR will remain as soft landscaping, or utilised as a surface water drainage attenuation or SUDs uses. While the development will greatly reduce infiltration and mobilisation of contaminates the proposed development will introduce potential migration routes as a result of the presence of services and drainage. New contamination sources are also considered in the form of in road run-off and accident / spillage.
13.6.2 It is reiterated that for the purposes of this chapter, potential effects have been initially assessed in the absence of the mitigation that will be incorporated into the detailed design of the development in order to make the site suitable for use.
13.6.3 PGH2. The localised high groundwater hazard will be considered and allowed for in design such that the quality of ground and surface waters are not adversely affected and that the baseflow to any sensitive controlled waters is not adversely affected. In relation to land instability, in an extreme event, this could cause loss of life to users of the development,
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including road users, (a large magnitude of change on a receptor classed as High sensitivity), could alter surface water drainage (a Moderate magnitude of change on a receptor classed as Medium sensitivity) and could impact building and property receptors (an assumed worst case magnitude of change of Moderate on a receptor classed as Low value/sensitivity).
13.6.4 PGH3 is a ground instability hazard associated with compression. A magnitude of change of Moderate on a receptor classed as Low value/sensitivity.
13.6.5 PCH1 and 2 are hazards associated with agricultural land use. The development will create a cap over the majority of the soils potentially impacted and also prevent direct infiltration which will reduce the current contaminant. There will however be a large area either side of the NEBGR that will be left as landscaping. Therefore the magnitude of change is likely to be Small on a receptor classed as Medium (controlled water) and High (human health) respectively.
13.6.6 PCH3 is a historic landfill located outside of the site with the potential for gas generation and migration. The magnitude of change is given a worst case of Large for loss of life in the case of explosive atmosphere. There is not considered to be a hazard any other receptors.
13.6.7 PCH4 is not present during the operational phase.
13.6.8 PCH5 is associated with contaminated run-off from the commercial/light industrial development entering the drainage system. The hazard could impact controlled waters with the magnitude of change assessed as Moderate, worst case Large should an extreme event occur.
13.6.9 PCH6 is the storage of chemicals during operation of the development. The magnitude of change caused by spillage is considered to be Small for Human Health receptors. The hazard could impact controlled waters but due to the relatively small volumes the magnitude of change is assessed as Moderate.
Mitigation of Operational Effects
13.6.10 Further assessment of the groundwater regime and slope stability will be undertaken as part of further investigations and stability constraints developed to inform the earthworks design. Appropriate design of counterfort drains, toe and crest drainage will be incorporated to enable control of both groundwater and surface waters. If necessary, soil reinforcement and or retaining walls will be used to support exposed soils for steeper slopes or vertical cuts. Where existing waster courses or groundwater issues exist, suitable measures will be incorporated within the surface water drainage design so as not to impede or restrict flow.
13.6.11 Measures to mitigate the effects of compressible ground hazard will be refined as the design is progressed based on the findings of the site investigation. Measures could include specifying a maximum thickness and compaction requirements for the earthworks. The surface water drainage strategy will incorporate measures such as interceptors to protect the quality of controlled waters.
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13.6.12 The placement of buildings / hardcover, as well as replacement of the existing surface water drainage system will mitigate against the risk of infiltration and potential mobilisation / migration of contaminants. The removal of potential contamination sources, together with any localised remedial action necessary, will reduce the risk of migration of contaminants impacting ground and surface water.
13.6.13 To reduce the potential risk of ingestion and uptake of contaminants by future site users outside of the hard standing areas, a layer of clean soil cover will be provided in areas of soft landscaping and gardens. The depth and form of soil cover required will be agreed with RDC and will depend on the risk associated with any potential contaminants. It is expected that, where required, provision of a 600mm thick layer will be sufficient to limit any risk of bulk movement of contaminated material to the surface (BRE, 2004). A greater depth of soil cover will be required in landscaped areas where trees or deep rooting shrubs are proposed to be planted. Where hard standing area (buildings/roads) exists, the potential of infiltration and potential mobilisation / migration of contaminants will be mitigated. The removal of potential contamination sources, together with any localised remedial action necessary, will also reduce the risk of migration of contaminants impacting ground and surface water.
13.6.14 The principal risk to controlled waters following construction will result from the potential release of pollutants associated with uncontrolled / accidental spillage either through run-off or discharge via drainage collection systems. Measures to manage / collect run-off and prevent uncontrolled discharges will follow the guidance given in pollution prevention guideline (PPG1) issued by the Environment Agency.
13.7 Assessment and Mitigation of Cumulative Effects
13.7.1 There is the need to consider the cumulative effects of the development proposed in the local area, including the BHLR, the NEBGR and the residential development to be provided as part of the wider BX2 allocation.
13.7.2 PGH2 is a ground instability hazard associated with potential high groundwater and instability from landslides. The cumulative effect of potential future adjacent developments considered in relation to the potential high groundwater hazard will require appropriate measures to be incorporated in the drainage strategy for the site in terms of the protection of groundwater quality, level and flow. Consideration will be given to any specific groundwater control measures incorporated through adjacent developments and the impact that they may have on the groundwater and or surface water regime at the site.
13.7.3 Development of the NEBGR on the central strip of the site and the BHLR to the north could have a cumulative effect in relation to the ground stability hazard. Depending on the scale of any instability, in an extreme event, this could cause loss of life to users of the employment area (a Large magnitude of change on a receptor classed as High sensitivity), could alter surface water drainage (a Moderate magnitude of change on a receptor classed as Medium sensitivity) and could impact buildings and property receptors (an assumed worst case magnitude of change of Moderate on a receptor classed as Low value/sensitivity). The design of the employment land area will have due regard to any design measures
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incorporated to mitigate the risk and should therefore not destabilise or adversely affect the earthworks design or structures of the BHLR.
13.7.4 PGH3 is a ground instability hazard associated with compression. The impacts of this hazard are predominately on road development (point of compressed soils). Development of the Bexhill Enterprise Park is unlikely to have a cumulative effect in relation to this hazard as it is location specific. The design of structures for the employment land will consider this hazard.
13.7.5 PCH1 and 2 are hazards associated with agricultural land use and development of the NEBGR and the BHLR is unlikely to have a cumulative effect in relation to this hazard. The roads will be paved therefore providing a cap preventing direct infiltration.
13.7.6 PCH3 is an historic landfill located north of the dismantled railway with the potential for gas generation and migration. Currently any gas generated can vent to surface, however if the landfill were to be built on the likelihood for gas migration would be increased. Development is not proposed on the landfill and therefore there is not considered to be a cumulative effect associated with this hazard. If development was to occur adjacent to the landfill consideration will need to put into the provision of gas protection measures unless intrusive investigation data concludes that gas is not a hazard.
13.7.7 PCH5 – Contaminated run-off from all the proposed roads entering the drainage system and PCH6 chemical storage on the Bexhill Enterprise Park (the nature of the contaminants are unknown at this stage) could have a cumulative effect in relation to controlled waters which will require appropriate measures to be incorporated in the drainage strategy for the employment area. Measures to manage / collect run-off and prevent uncontrolled discharges will follow the guidance given in pollution prevention guideline (PPG1) issued by the Environment Agency.
13.7.8 There will be a cumulative effect associated with potential future adjacent developments in relation to the loss of agricultural soil.
13.7.9 It is considered that there should not be any significant cumulative effects as a result of the proposed NEBGR, BHLR and the Bexhill Enterprise Park within the BX2 allocation in relation to ground conditions as the majority of the Bexhill Enterprise Park allocation is located away from the NEBGR and BHLR. Dwellings to be provided in accordance with the wider BX2 allocation will need to be designed in response to prevailing ground conditions but should not be significantly affected by the ground condition effects associated with the NEBGR or the BHLR.
13.8 Summary of Residual Effects
13.8.1 The potential effects related to the construction and operation of the NEBGR, BHLR and proposed Bexhill Enterprise Park have been reassessed on the basis of the mitigation measures identified above. Residual effects are presented in Tables 13.3 , 13.4 and 13.5 .
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Table 13.3: Assessed Residual Effects Related to Ground Conditions (Construction)
Residual Effect Receptor Justification Significance Effects reduced by the use of appropriate protective clothing and Human Health equipment and methods of working. Temporary support and Not Significant – Site Workers incorporation of ground and surface water control measures as necessary. The CEMP will document the procedures to minimise and manage Controlled Not Significant spillages from chemical storage, dust generation, dewatering Waters discharges and run-off. The CEMP will document the procedures to minimise and manage Other Not Significant spillages from chemical storage, dust generation, dew atering (Property, discharges and run-off. Animals and Agricultural land will be lost as a result of the Bexhill Enterprise Moderate Crops) Park however the site is designated for development rather than Adverse agriculture.
Table 13.4: Assessed Residual Effects Related to Ground Conditions (Completed Development)
Residual Effect Receptor Justification Significance Effects reduced by the use of protective clothing and equipment Not Significant Not Significant and adoption of safety procedures with respect to ground gases. Effects reduced by the provision of clean soil cover in landscaped Human Health areas and adoption of construction safety procedures with respect Not Significant – Site Users to ground gases/ vapours. Design measures will be incorporated to address any residual risk of high groundwater or instability. The development will incorporate environmental mitigation design Controlled Not Significant e.g . use of petrol interceptors the design of which should consider Water future developments. Built Effects reduced by the use of appropriate design and specification Not Significant Environment of the proposed development. Other (including Property, Not Significant Removal of localised sources of contamination if encountered. Animals and Crops)
Table 13.5: Assessed Residual Effects Related to Ground Conditions (Cumulative)
Residual Effect Receptor Justification Significance Mitigation measures incorporated in the detailed design in relation Built Not Significant to the potential for high groundwater, instability and compressible Environment ground hazards. The developments will incorporate environmental mitigation Controlled Not Significant design e.g . use of petrol interceptors the design of which should Water consider future developments. Human Health Not Significant The potential for significant contamination is considered very low. Other (including Agricultural land will be lost as a result of the Bexhill Enterprise Moderate Property, Park and wider development however the site is designated for Adverse Animals and development rather than agriculture. Crops)
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13.9 Summary
13.9.1 An assessment has been undertaken of the likely significant effects of the proposed development in relation to ground conditions with consideration given to potential ground stability and contamination related impacts.
13.9.2 Baseline conditions have been identified using published and non-invasive information on the geotechnical and geoenvironmental setting of the site. The baseline describes the types and locations of (i) Potential Sources of Contamination (PSCs), based on identification of current and historic land use and (ii) Potential Geological Hazards (PGHs), based on identification of geological hazards (such as slope stability, compressibility, high groundwater levels, shrinkage/swelling of clay layers). The assessment also identifies the type and sensitivity of potential receptors (including consideration of human health, buildings, groundwater, surface water and ecological systems) and identification of possible pathways by which contamination could affect receptors.
13.9.3 A qualitative approach has been adopted, with a progression from factual information (stated with reasonable certainty) regarding the baseline conditions, to appraisal informed by professional judgement, guidance, standards, etc. and expression of opinions on the relative significance.
13.9.4 Although potential sources of contamination have been identified on and off site based on their nature it is considered that remediation of soil and groundwater is unlikely. Mitigation measures typical of construction good practise and documented in the Construction Environmental Management Plan (CEMP) will reduce the potential effects associated with contamination during construction phase to not significant.
13.9.5 During operation, the Bexhill Enterprise Park could introduce contamination sources such as contaminated run-off and chemical spillages from accidents. The drainage design will incorporate measures to minimise the impacts such as provision of interceptors. Mitigation measures will reduce the likely effects associated with contamination during operational phase to not significant.
13.9.6 The Bexhill Enterprise Park will result in a loss of agricultural land the effect of which is assessed as Moderate adverse, however it should be recognised that the site is allocated for development in local planning policy.
13.9.7 The Bexhill Enterprise Park may include some form of ground improvement of some soils to enhance their geotechnical suitability. Mitigation measures typical for good construction practise will ensure that the effects to controlled waters and ecology will be not significant.
13.9.8 Instability hazards have been identified and further investigations and assessment will be undertaken to inform the detailed design stage. Provided the relevant mitigation measures are implemented it is considered unlikely that the construction and operation of the Bexhill Enterprise Park would not adversely affect the geology.
13.9.9 An intrusive investigation will be undertaken to inform the design of the mitigation measures to be adopted.
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13.9.10 Development of the proposed employment area and other development proposed at North East Bexhill could have cumulative effects in relation to ground instability (landslides) and potential to impact controlled waters through surface water discharges. Mitigation should ensure that such effects are not significant.
13.10 References
EA 2004 Model Procedures for the Management of Contaminated Land Report CLR11 Environment Agency (EA), 2004.
EA 2012 Groundwater Protection: Principles and Practice (GP3) Environment Agency (EA), 2012.
NHBC 2008 Guidance on the safe development of housing on land affected by contamination R&D publication 66 Vol 1 and 2 published by National House Builders Council (NHBC).
DETR 2000 Methodology for Multi Modal Studies. Volume 2 Section 4. The Environmental Objective. Department of Environment, Transport and the Regions (DETR).
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14 Water Quality and Drainage
14.1 Introduction
14.1.1 This chapter assesses the likely significant effects of the proposed development on water quality and drainage. In assessing the likely significant effects of water quality, the water environment is assessed. Flooding, surface water and foul water drainage are also considered as integral to this assessment. This chapter is supported by a Flood Risk Assessment (FRA) at Appendix I .
14.1.2 The chapter describes the assessment methodology, the baseline conditions existing at the site and surroundings, the likely significant environmental effects, the mitigation measures required to avoid, reduce or offset any significant adverse effects; and any likely residual effects.
14.1.3 This chapter has been prepared by Peter Brett Associates LLP (PBA).
14.2 Policy Context
14.2.1 There is a wide range of international and national legislation relevant to the assessment of impacts to water quality and drainage, and many guidance documents concerned with mitigating potential impacts. Relevant documents are listed in Table 14.1 .
Table 14.1: Relevant Key Legislation and Guidance Documents
Context Legislation, Policies and Guidance Documents Water Framework Directive 2000/60/EC The Groundwater Directive 80/68/EEC International EC Dangerous Substances Directive 76/464/EEC and daughter directives EC Freshwater Fish Directive 76/659/EEC and daughter directives Drinking Water Directive 80/778/EEC The Water Act 2003 The Water Environment (Water Framework Directive) (England and Wales) Regulations 2003 The Control of Pollution (Oil Storage) (England) Regulations (2001) The Groundwater Regulations 1998 The Surface Waters [Dangerous Substances (Classification)] Regulations 1998 Control of Substances Hazardous to Health (COSHH) Regulations (1998) The Environment Act 1995 (as amended) The Surface Water (River Ecosystem) (Classification) Regulations 1994 The Water Resources Act 1991 (as amended 2003) National The Land Drainage Act 1991 (as amended) Food and Environment Protection Act 1985 WEBTAG Unit 3.3.11 The Water Environment Sub-Objective CIRIA Report 648 (2006) Control of water pollution from linear construction sites CIRIA Report 609 (2004) Sustainable Drainage Systems – Hydraulic, structural and water quality advice CIRIA Report 532 (2001) Control of water pollution from construction sites CIRIA Report 522 (2000) Sustainable urban drainage systems – design manual for England and Wales CIRIA Report 156 (1996) Infiltration Drainage – manual of good practice
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Context Legislation, Policies and Guidance Documents CIRIA Report 142 (1994) Control of Pollution from Highway Drainage Discharges Code of Good Agricultural Practice for the Protection of Water (the “Water Code”) (DEFRA 1998 as amended 2002) Guidelines for the use of herbicides on weeds in or near watercourses and lakes (DEFRA 1995 PB2289) Environment Agency Pollution Prevention Guidelines (PPG), the most relevant being: - PPG1 – General guide to water pollution and prevention; - PPG 2 – Above ground oil storage tanks; - PPG 3 - Use and design of oil separators in surface water drainage systems; - PPG 5 – Works in, near or liable to affect watercourses; - PPG 6 – Working at construction and demolition sites; - PPG 8 – Safe storage and disposal of used oils; - PPG 9 – Prevention of Pollution by Pesticides; - PPG 21 – Pollution incidence response planning; - PPG 22 – Dealing with spillages on highways; and - PPG 23 – Maintenance of structures over water. Sewers for Adoption 7th Edition (2012)
Legislative Framework and Objectives
14.2.2 In terms of the water environment, the Water Framework Directive (WFD) is an overarching piece of European Union legislation which has significant influence upon improving the water environment. The WFD is transposed to English law through the Water Environment (Water Framework Directive) (England and Wales) Regulations 2003. The WFD aims to establish "good ecological and chemical status in all surface waters and ground waters." It also promotes the importance of sustainable water use.
14.2.3 At a national level, the Government strategy document ‘A Better Quality of Life – A Strategy for Sustainable Development for the United Kingdom’ recognises the fundamental importance of good water quality to health and the environment. It identifies the major challenges to water quality which it states are; i) growing demand for water supplies, ii) pollution pressures from new development, iii) diffuse pollution inputs, iv) changed weather patterns, and v) loss of habitats.
14.2.4 The Bexhill Enterprise Park does not directly drain into a Main River but does drain to an Ordinary Watercourse. Under the Land Drainage Act (1991) consent from the Lead Local Flood Authority (LLFA) is required for any proposed discharges to controlled waters, and any alteration to an Ordinary Watercourse.
14.2.5 The Water Resources Act 1991 sets out the regulatory controls and restrictions that provide protection to the water environment through controls on abstractions, impounding and discharges, as well as identifying, amongst other things conservation, water quality and drought provisions. The Act is supplemented by:
° The Environment Protection Act 1991 which established the Environment Agency (E.A.); and
° The Environment Act 1995 which provides for integrated pollution control.
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14.2.6 Consent for any works affecting ordinary watercourses (in this case the agricultural drainage ditches which are crossed or affected by the Bexhill Enterprise Park) would need to be obtained from the Lead Local Flood Authority (LLFA), and these bodies would be consulted as the design progresses to obtain the relevant consents.
14.2.7 The Highways Act (1980, Section 299) gives a highway authority the right to discharge water; consent is needed to "interfere” with watercourses, and the Act states that this consent should not be "unreasonably withheld" . There is also a duty on highway authorities not to pollute. The overarching principle is that discharges to watercourses will be acceptable, but that this needs to be agreed with the EA, and appropriate mitigation provided.
14.2.8 In order to manage the water environment more effectively, the Floods and Water Management Act 2010 (FWMA) introduced powers for local authorities to manage flood risk, and encourages the use of sustainable drainage systems (SUDS). Under the act local authorities are identified as LLFA. Secondary legislation under this act will provide new powers for LLFA to approve SUDS, with SUDS Approval Bodies (SABs) approving, adopting and maintaining SUDS in the future. National standards are currently being developed to take this forward, which are expected to be published in the near future. The FWMA also made changes to the Land Drainage Act (1991) requiring LLFA to consent to works to alter an Ordinary Watercourse.
14.2.9 Other important legislation this chapter refers to includes the Water Act 2003 and the Groundwater (England and Wales) Regulations 2009 .
14.2.10 The National Planning Policy Framework (NPPF) was published by the Government in 2012 and sets out a framework for the planning process in England. This document replaces, for the purposes of this chapter, PPG 23: Planning and Pollution Control and PPG 25: Development and Flood Risk. Contained within the NPPF are guidelines for planning authorities with regard to development in areas at risk of flooding and consideration of climate change.
14.2.11 In conjunction with the NPPF, the Government published the ‘Technical Guidance to the National Planning Policy Framework’ which provides additional guidance to local authorities to ensure the effective implementation of planning policy on development in areas at risk of flooding. This document elaborates on the requirements for the Sequential and Exception Tests with regard to new development.
14.2.12 Other national guidance which is relevant to the scheme includes:
14.2.13 Building Regulations 2010 Requirement H3 stipulates that rainwater from roofs and paved areas is carried away from the surface to discharge to one of the following, listed in order of priority:
° An adequate soakaway or some other adequate infiltration system, or where that is not reasonably practicable;
° A watercourse, or where that is not practicable;
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° A sewer.
14.2.14 Construction Industry Research and Information Association (CIRIA) C697, 2007 The SuDS Manual provides guidance to deal with surface water as close to the source as possible and reproduce natural drainage patterns to prevent an increase in the volume and peak discharge from development sites.
Local Policy Framework Objectives
14.2.15 A review of the Southern Water, Water Resource Management Plan (October, 2009) identified the following:
° The site is located within Sussex Hastings Water Resource Zone (WRZ).
° There are no further strategic water resources projects planned for the WRZ, and it is anticipated that the water demand from all future development within the WRZ will be met with existing resources and through a combination of universal metering, leakage reduction, water efficiency measures.
° In 2009, approximately 12% of all customers were metered.
14.2.16 The site is located within Sub-Area 7 (Bexhill/ Bulverhythe and St Leonards/ Hastings) of the Environment Agency, Sussex and Cuckmere Catchment Flood Management Plan (CFMP) (December, 2009)
14.2.17 The CFMP states that the principal flooding issues in this locality are concerned with poor surface water drainage systems that suffer from blockages, debris and siltation, and also high groundwater levels that originate from sandstone formations around Bexhill.
14.2.18 The EA has applied 'Policy Option 4' to the management of flood risk within this Sub-Area, which is defined as "…areas of low, moderate or high flood risk where we are already managing the flood risk effectively but where we may need to take further actions to keep pace with climate change."
14.2.19 The proposed management actions by the EA include:
° Complete System Asset Management Plans (SAMPs) to determine how existing flood defences will be managed (Status: No information).
° Work with Rother District Council and the water companies to develop a Surface Water Management Plan (SWMP) for Bexhill and Hastings (Status: Not yet completed).
° Work with Rother District Council, Hastings Borough Council and East Sussex County Council and the Highways Agency to identify local restrictions to flows and ensure adequate channel capacity (Status: Not yet completed).
° Work with Rother District Council and Hastings Borough Council to influence spatial planning, providing advice on methods to reduce run-off and implementation of
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Sustainable urban Drainage Systems (SuDS) in all new developments (Status: Rother District Council Strategic Flood Risk Assessment recommends SuDS for all new developments).
° Complete flood mapping study for high risk watercourses in Bexhill and Hastings (Status: Flood Mapping of breaching of the sea defences and the impacts on the watercourses of the Pevensey Levels has been completed as part of the SFRA).
° Appraise and review how climate change will alter the effectiveness of the sea outfall at Egerton Park.
° Look at the feasibility and seek implementation of local improvements or schemes to better manage flood risk north of the A259.
° Appraise and review the capacity of Combe Haven sea outfall to adapt to the effects of climate change.
14.2.20 The EA, South East River Basin Management Plan, 2009 focuses on achieving protection, improvement and sustainable use of water and is a requirement of the WFD. The plan identifies the management of future development as one of the key aspects which can influence achievement of the WFD requirements.
14.2.21 The Environment Agency, Water Body Summary Sheet for the Combe Haven summarises any current water quality issues and any mitigations that are required. Based on data from 2009, the Combe Haven had been classified at a 'moderate' status, with issues relating to dissolved oxygen and mitigation measures required due to its 'heavily modified' status.
However in 2011, following a national review, this water body was de-designated and is no longer considered heavily modified. The dissolved oxygen data suggested some element of seasonality, with lower readings occurring during the summer months. The classification year (2009) was also a drought year which represented a worst-case scenario. In addition the habitat in which this water body is located is canal-like, and as such the reason for the original failure was attributed to morphology.
As a result, the national review concluded that the water body would be reclassified as Good and was not in need of any further mitigation or investigation.
14.2.22 A collection and review of available flood risk information within the Rother District is presented within the Rother District Council Level 1 Strategic Flood Risk Assessment (Rother, 2008). This Level 1 assessment applies the Sequential Test at the strategic scale to potential, and probable, development areas across the Rother District. The strategic allocation of development north of Bexhill (BX2) is confirmed within Flood Zone 1 in Appendix 10 (Rother, 2008). Rother District Council's Level 2 Strategic Flood Risk Assessment dated (Rother, 2008a) provides supplementary information to the Level 1 SFRA, to inform on specific tidal flood risk issues and suitability for development of key development areas and known flooding hotspots identified by Rother District Council in preparation of their LDF. The assessment states that an Exception Test is 'not required' for the strategic allocation of development North of Bexhill within the LDF (BX2 and BX3).
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14.3 Methodology
Pollution Control and Water Quality
14.3.1 The assessment of water quality effects has been considered in light of the NPPF, which requires development to aim towards minimising pollution and other adverse effects on the local and natural environment.
14.3.2 Qualitative information from the EA's River Basin Management Plan for the Cuckmeare and Pevensey Levels catchment, EA online mapping and local policy documents concerning baseline water quality and existing sources of pollution / control measures has been assessed in the context of the proposed development to provide a qualitative indication of the potential risk of water pollution and to identify suitable mitigation measures where appropriate.
Flood Risk and Surface Water Flooding
14.3.3 Flood risk has been assessed in accordance with the approach outlined within the NPPF, which considers the risk and impact of flooding at the site, as well as the impact of flooding as a result of the development.
14.3.4 An FRA has been undertaken for the site in accordance with the Technical Guidance to the NPPF. The baseline flood risk has been established through consultation with the EA, and the Level 1 and 2 SFRA.
14.3.5 Initial information on potential sources of flooding, historical flooding and expected flood water levels within the area was collected from a variety of sources including:
° The EA - a meeting with them was held on 15 March 2013.
14.3.6 The EA encourages the use of SUDS to prevent the water environment being adversely affected by increased surface water runoff and the increased risk of pollution and in particular diffuse pollution.
Climate Change
14.3.7 The EA/DEFRA W5-074/A 'Preliminary Rainfall Runoff for Development' states that 'climate change will be taken into account in hydrological regions by increasing the rainfall depth for computing storage volumes. No allowance for climate change should be applied to calculated Greenfield peak rates of runoff from the site for any hydrological region'.
14.3.8 At the meeting with the EA on 15 March 2013, it was agreed that the same parameter of the additional climate change factor of 20% used on the BHLR should be adopted for this scheme.
Supporting Information and Consultation
14.3.9 The following sources were used to understand conditions:
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° Environment Agency (EA) website (SPZ, groundwater conditions, WFD status);
° British Geological Survey website (groundwater conditions);
° South East River Basin Management Plan, 2009;
° Rother District Council Level 1 Strategic Flood Risk Assessment;
° Rother District Council's Level 2 Strategic Flood Risk Assessment;
° Ordnance Survey (OS) mapping;
° Meeting with BHLR design team on 1 March 2013;
° Meeting with EA on 15 March 2013; and
° Email correspondence with EA between 10 and 18 June 2013.
14.3.10 In addition to the desk-based study, a site walkover was completed on 18 October 2012 and 12 June 2013.
Significance Criteria
14.3.11 The methodology for resource appraisal, quantification of impacts and evaluation of significance of resulting effects is explained below.
14.3.12 The criteria and guidance presented below in Table 14.2 has been used to value the importance of attributes (receptors) within the water environment.
Table 14.2: Receptor Importance within the Water Environment Importance Criteria Example Level EC designated Salmonid/ Cyprinid fishery. WFD Class “High ‟. Attribute has Site protected/designated under EC or UK habitat legislation. high quality and Principal aquifer providing regionally important resource. Very high rarity on a SPZ regional or Floodplain or defence protecting more than 100 residential national scale. properties from flooding. High likelihood of pollution to the water environment by any means Major Cyprinid fishery. WFD class “Good ‟. Attribute has Species protected under EC or UK habitat legislation. high quality and Principal aquifer providing locally important resource or High rarity on local supporting river ecosystem. scale. SPZ 2. Floodplain or defence protecting between 1 and 100 residential properties or industrial premises from flooding. WFD Class “Moderate ‟. Attribute has Aquifer providing water for agricultural or industrial use with medium quality Medium limited connection to surface water. and rarity on SPZ 3. local scale. Floodplain or defence protecting 10 or fewer industrial properties
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Importance Criteria Example Level from flooding. WFD Class “Poor”. Attribute has low Unproductive strata. Low quality and rarity Floodplain with limited constraints and a low probability of on a local scale. flooding residential and industrial properties.
14.3.13 The assessment of significance of impact (or degree of change) related to drainage and water quality associated with the scheme (taking into account the proposed mitigation measures), and potential pollution risk to surface and groundwater follows the criteria set out in Table 14.3 . In some instances the significance has been assessed upon judgement of a qualitative appraisal of the magnitude of the effect and the sensitivity of the affected receptor in relation to hydrology and hydrogeology.
Table 14.3: Magnitude Criteria
Significance Level Criteria Example Compliance failure with EQS values. Results in loss of attribute Loss or extensive change to designated Major and/or quality and integrity of the nature conservation site or fishery. attribute. Loss or extensive change to an aquifer. Compliance with EQS values. Results in effect on integrity, or Moderate Partial loss in productivity to a fishery. loss of part of attribute. Partial loss or change to an aquifer. Compliance with EQS values. Results in some measureable Potential low risk of pollution to Minor change in attribute quality or groundwater. vulnerability. Increase in peak flood level. Results in effect on attribute, but The proposed scheme is unlikely to affect Negligible of insufficient magnitude to the integrity of the water environment. affect the use or integrity. Negligible change to flood risk. Assessment of either soluble or pollutant- Results in some beneficial effect bound pollutants is lower than previously Minor (Beneficial) on attribute or a reduced risk of assessed. negative effect occurring. Reduction in peak flood level. Removal of existing polluting discharge, Results in major improvement in Major (Beneficial) or removing the likelihood of polluting attribute quality. discharge occurring to a watercourse.
14.3.14 The approach to assigning significance of effects relies on reasoned argument, professional judgement and available guidance. The magnitude of flood risk and severity of the impact to people and property for the baseline and with development scenarios has been considered within the FRA.
14.3.15 Table 14.4 describes the significance criteria adopted for this assessment.
Table 14.4: Significance of Adverse Effects Importance of Attribute
Very high High Medium Low Highly Low Major Very significant Significant significant significance
Moderate Highly significant Significant Low significance Insignificant Minor Significant Low significance Insignificance Insignificant Negligible Low significance Insignificant Insignificant Insignificant Magnitude of Effect
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Limitations, Constraints and Assumptions
14.3.16 This assessment is limited by the information that is currently available. The constraints and limitations imposed by the information gathered have been documented. Site investigation related directly to the water environment and ground conditions has not been undertaken at this time. Other information including a desk based study of ground conditions has been used and which may need to be confirmed by investigations.
14.4 Baseline Conditions
14.4.1 The following section describes the baseline conditions for the local water environment at and in the vicinity of the site. The extent of the assessment covers land within the site boundary and any surrounding land that could be impacted or be susceptible to impact by the proposed development and vice versa. Consideration of ground conditions that could affect hydrogeological conditions is also described.
Fluvial and Tidal Flooding
14.4.2 The EA Flood Map (EA, 2012) shows the site outside of the extent of the 0.1% annual probability (1 in 1,000 year) flood extent. For planning purposes this is within Flood Zone 1 Low Risk. As such the site is considered to be at a Low Probability of fluvial flooding. Further detail is provided in the FRA in Appendix I.
14.4.3 The Level 1 SRFA provides flood mapping on sheets referenced "Pebsham/Glyne Gap". This shows the study area is in Flood Zone 1. The NPPF Technical Guidance Section 5 Table 1 identifies Zone 1 as a low probability, assessed as having a less than 1 in 1000 annual probability of river flooding (<0.1%).
14.4.4 The direct value of flood influence is considered of Low Importance as the site is outside the extents of fluvial flood risk. However the indirect value of flood influence is considered of High Importance as there are properties downstream of this site which could be affected indirectly by increased development areas upstream. However, the potential of this has not been quantified, although it is clear that the 'attenuating' effects of the ditches, pipes and other structures between this site and downstream development will already mitigate much of the risk.
Ground Conditions
14.4.5 Details of the ground conditions desk study is presented at Appendix H .
14.4.6 An extract of the published geological map (BGS, 1980) is presented as Figure 14.1 below in and indicates the following geological sequence:
° Superficial deposits: There are no superficial deposits present within the site or in the vicinity
° Bedrock: The majority of the site is underlain by the Ashdown Beds described as locally thinly laminated and closely fissured sandstone, siltstone and mudstones. Bands of the
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underlying "Clay in Ashdown Beds" are shown at surface in the southern half of the site immediately adjacent to woodland and in a narrow band on the flank of the southern slope area. An outcrop of Wadhurst Clay is shown to the east of the site at the top of the northern slope, with further bands of Clay in Ashdown Beds outcropping downslope.
Figure 14.1: Geological Map Extract
(BGS, BGS Data reproduced/based from sheet 320/321 by permission of the Director of the British Geological Survey under licence number C08/098-CSL © NERC. All rights reserved. Topographical details based on the OS 1" map of 1969 with the permission of the Controller of Her Majesty’s Stationary Office. Crown copyright reserved (2013).
Topography
14.4.7 A topographical survey was carried out by Technic Group (2013) and is provided as part of the FRA.
14.4.8 There are two areas of the Bexhill Enterprise Park, intersected by the proposed NEBGR. The existing ground profile generally falls from south to north.
14.4.9 The northern extent of the site east of the NEBGR borders the abandoned railway at a level of approximately 16mAOD and extends around 250m south to a level of approximately 32mAOD. The site west of the NEBGR rises from approximately 28.5mAOD at the northern extent to a level of approximately 32mAOD at the southern extent.
14.4.10 The watershed is therefore towards the location of an underpass under the route of the abandoned railway.
Hydrogeology and Groundwater
14.4.11 Site geology comprises Ashdown beds overlying Clay in Ashdown Beds. Groundwater levels at the site are likely to be variable due the inter-bedded ground conditions, and as observed on site, close to surface. It is known that in the local area, spring lines are commonly found at the boundary of relatively permeable deposits and less permeable horizons, in particular,
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at the boundary between the more permeable Ashdown Beds and the underlying Clay in Ashdown Beds.
14.4.12 Water strikes within these deposits may also be sub artesian in nature due to the presence of confining less permeable clay layers within the Ashdown Beds. On the northern side of the railway embankment the ground was noted to be saturated with a slight seepage of groundwater within a shallow ditch at the toe at the embankment enabling discharge of water to the east.
14.4.13 Deeper borehole records included as part of the site investigation indicate that the groundwater table was not encountered and is therefore deeper than 15m below ground level.
14.4.14 The EA maps show that the site is not within any source protection zone, although it does fall within the zone of a Secondary A aquifer. This means that the permeable bedrock layers are capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base flow to rivers. The hydrology and ground water are therefore considered to be of Medium Importance as the site is outside any Source Protection Zone but potential above ground capable of being a future productive strata.
Surface Water Features
14.4.15 The EA has no record of flooding within the site. At a meeting with the EA on 14 March 2013, the EA provided a flood map for surface water covering the site and surrounding area.
14.4.16 The 'Flood Map for Surface Water' shows areas where surface water would be expected to flow or pond, as a result of two different chances of rainfall event. The areas at risk of flooding are displayed in two bands showing a) surface water flooding and b) areas of deeper surface water flooding. The maps consider two storm likelihoods, 1 in 30 and 1 in 200 chance of occurring in any year.
14.4.17 The site is classified as 'greenfield', which means that it drains naturally according to local topography. It generally comprises open grazing and arable land. From a hydrological perspective, the site is considered a single catchment. Drainage of the Bexhill Enterprise Park will fall to an existing land drain (Ordinary Watercourse) that then falls north and east to the Combe Haven. The Combe Haven falls within the wider Cuckmere and Pevensey Levels Catchment.
14.4.18 Between the two development portions is a spring fed ditch (Ordinary Watercourse) which enters a shallow surface water pipe at a level of circa 14.50mAOD passing below the underpass to the abandoned railway. After about 50m this pipe emerges into a ditch (Ordinary Watercourse) on the north side of the abandoned railway embankment, and ultimately discharges to the Combe Haven to the east.
14.4.19 In terms of the WFD, the Combe Haven is not classified as a Heavily Modified Water Body and has moderate ecological potential overall. The WFD assessment parameters driving the classification are dissolved oxygen (moderate), and mitigation measures assessment (moderate). The watercourse also fails on hydrology (moderate). The water body is predicted
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to remain at a moderate status in 2015 with a prediction of good potential by 2027 if the mitigation measures are put in place. The Combe Haven is of considered Medium Importance under these assessment criteria due to the WFD classification.
14.4.20 Greenfield runoff rates for the site were established within the supporting documentation to the North East Bexhill Supplementary Planning Document (SPD) which was adopted by Rother District Council in 2009. As part of the masterplan development for North East Bexhill, Faber Maunsell was commissioned in 2007 by Rother District Council to prepare a drainage study. This application falls within catchments B and D of this study. These rates were calculated using the Flood Estimation for Small Catchments, Institute of Hydrology, Report No. 124, June 1994 and form an integral part of the land use scenario adoption under this SPD.
Foul Sewerage
14.4.21 The site is not served by a public foul water drainage network. However, as part of the NEBGR development (from which the Enterprise Park is accessed), a new sewer (or rising main) will be installed which will connect into the existing public foul system at Wrestwood Road, Bexhill. This attribute is assed as having Very High Importance , as without a means of foul drainage, the development would have very real consequence to the water environment.
14.4.22 However, it is fully intended and proposed below that the Enterprise Park will outfall into the existing public sewer system. A pumping station will be required at the northern extent of the east portion of the site due to the level difference with the NEBGR.
14.5 Assessment and Mitigation of Construction Effects
Assessment
14.5.1 Effects during construction may include the risk of pollution resulting from accidental spillages, increased surface runoff and increased sediment runoff risk from construction works, increased traffic and reduction of water quality in watercourses.
14.5.2 There would be potential for pollutants to enter the watercourses during the construction phase. The potential for pollutants to enter these would be highest during the construction of the connections to the watercourse, the realignment of the watercourses, and forming/cutting of earthworks. There is as yet no detailed design for the structures, however general effects in terms of runoff to surface water can be assessed at this stage. Potential pollutants to surface water runoff include:
° Concrete, cement or admixtures spillage from construction of the new carriageways and culverts;
° Sediment run-off from earthworks required for construction of new carriageways, footways and culverts;
° Sediment runoff water or wind-blown dust from spoil heaps; and
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° Leakage or spillage of fuel, oil or chemicals.
14.5.3 Sedimentation can have an adverse impact upon water quality and in turn, affect the in- stream flora and fauna. Suspended solids can also significantly reduce dissolved oxygen levels within the water and this could have adverse effects on aquatic organisms.
14.5.4 Spillage and leakage of oils, fuels and chemicals during construction (commonly during delivery and/or refuelling) could potentially affect surface and ground waters. Spillages could seep into the ground and enter the groundwater or be washed into nearby ditches through site runoff. Small quantities of oil have the ability to form extensive thin films which cover a large surface area of receiving waters. During turbulent conditions, the oil film can form an emulsion with the water. Oil also has the ability to bind to the surface of sediments, strata, flora and fauna. Even at relatively low concentrations, oil can be toxic to aquatic species and make the water unsafe for human consumption.
14.5.5 Uncured concrete has been shown to increase the pH of a watercourse and this change could seriously affect aquatic life.
14.5.6 The effect on existing groundwater is uncertain until ground investigations are carried out. While deeper borehole records from the BHLR site investigation indicate that the groundwater table is deeper than 15m below ground level. The groundwater levels at the site are likely to be variable and as observed on site, close to surface.
14.5.7 Water strikes within these deposits may also be sub artesian in nature due to the presence of confining less permeable clay layers within the Ashdown Beds.
14.5.8 There would therefore be some risk of groundwater flooding and contamination where ground levels would be reduced, and where local shallow strikes of groundwater could potentially be encountered during construction. It is unlikely that any reduction in ground levels would require groundwater levels to be reduced to facilitate construction; however there remains some potential for groundwater flooding and pollution of groundwater left above the surface during construction causing a slight adverse effect on surface water quality.
14.5.9 There will be occasions when materials may be stored close to the watercourses during the construction of the scheme. In comparison to the overall area used for construction these areas are very small in comparison. Therefore considering the temporary nature of the construction works and the likelihood of flooding this is considered to be negligible risk.
Mitigation
14.5.10 During construction surface water would be managed by a temporary drainage strategy until the operational drainage system is constructed.
14.5.11 A Construction Environmental Management Plan (CEMP will be prepared. The CEMP is an active document to be updated and expanded prior to the start of construction by the contractor, and it lists best practice measures which the contractor will adhere to as a minimum, including:
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° Pollution Prevention Guidance (PPG) 1 – General guide to the prevention of pollution;
° PPG 5 – Works and maintenance in or near water;
° PPG 6 – Working at construction and demolition sites;
° PPG 18 – Managing fire water and major spillages;
° PPG 21 – Pollution incident response planning;
° PPG 22 – Dealing with spillages on highways; and
° CIRIA – Control of Water from Construction Sites.
14.5.12 In order to mitigate any potential adverse effects to surface waters and groundwater during the construction phase, the following measures will be implemented as appropriate:
° Management of construction works so as to comply with the necessary standards and consent conditions as identified by the EA and Rother District Council.
° All construction workers would be briefed on the importance of maintaining water quality, the location of surface water features and the location and use of accidental spill kits as part of the site induction.
° The construction drainage network would incorporate measures (e.g. potentially an interceptor) to prevent the discharge of hydrocarbons to surface or ground water systems.
° In areas where there is increased risk of hydrocarbon/chemical spillage and around hazardous substance stores, additional precautions would be taken. These would include bunding (in accordance with EA PPG 8: Safe storage and disposal of used oil), impermeable bases, suitable drainage systems and sited away from any open drainage channels.
° Any stockpiled materials would be stored within enclosed areas to enable the runoff to be stored and treated where required.
° Any concrete works would be carefully controlled, and where required any concrete tankers would be washed out in controlled areas.
° All plant and machinery would be maintained in a good condition and any maintenance required would be undertaken within safe areas.
° A Pollution Prevention and Spill Response Procedure would be developed by the contractor and a site kit and clean up equipment would be maintained on site.
° Wheel washers and dust suppression measures would be used as necessary to prevent the migration of pollutants.
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° Continual monitoring of the surface water courses before, during and after construction to ensure no adverse impacts on water quality.
14.5.13 As the watercourse though the development is not a main river, it is classed as an ordinary watercourse under the Flood and Water Management Act (2010). Consent from the LLFA Is required to alter the ordinary watercourse or to do anything that affects its flow, under the Land Drainage Act (1991).
14.5.14 Storage of fuel oils, chemicals etc. would be as far as reasonably practical within the temporary construction compound, which is proposed to be located outside proximity to the watercourses.
14.5.15 As the mitigation measures listed above and in the CEMP form part of the scheme proposals, the potential effects which could arise during construction would be avoided or mitigated and therefore and therefore the magnitude of any changes would be not significant It is anticipated that there would be negligible effects during construction
14.6 Assessment and Mitigation of Operational Effects
Assessment
14.6.1 The increase of impermeable surfaces caused by the Bexhill Enterprise Park could potentially increase the risk of mobilising contaminants within surface water run-off such as hydrocarbons from vehicles. This could lead to a minor impact on water quality and downstream watercourses if not mitigated for within the surface water drainage strategy.
14.6.2 As demonstrated in the FRA the Bexhill Enterprise Park is assessed as being within Flood Zone 1. This means there is a low probability of flooding, assessed as having a less than 1 in 1000 annual probability of river flooding (<0.1%).
14.6.3 The FRA has assessed the risk of flooding from all sources including pluvial, fluvial, groundwater, ponds, other water bodies and overland flows. The FRA concluded that:
° There is negligible flood risk from other sources.
° The rate of surface water runoff from the road would be increased due to the impermeable area proposed, but this would be mitigated by the provision of attenuation ponds / swales as demonstrated in the surface water drainage strategy.
° The flood risk to the wider catchment would not be increased due to implementation of surface water attenuation.
Mitigation
14.6.4 To mitigate the risk of deterioration in water quality within the ordinary watercourses and groundwater bodies, the drainage design includes measures to filter, store and treat surface water through use of the "SUDS Management Train? approach. This approach is detailed in CIRIA C697 "The SuDS Manual?, and outlines the most appropriate uses and combinations
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of SUDS measures to treat surface water runoff and improve water quality through each stage of the surface water management system.
14.6.5 The drainage system will serve to intercept surface water runoff from carriageways, car parks, buildings and hard paved public areas. It will remove pollutants as near to the source before disposal to the on-site conveyance network. This network is likely to be formed of the following components:
° Carrier, filter and fin drains;
° Gullies;
° Bio-retention / rain gardens;
° Kerb and drainage systems;
° Permeable paving;
° Catchpits and manholes;
° Online Attenuation;
° Pollution control valves;
° Forebays;
° Attenuation ponds;
° Swales; and
° Headwalls.
14.6.6 The drainage system proposed is described within the FRA, but in summary attenuation ponds, swales and online attenuation is proposed to control the outfall flow which would discharge into the watercourses, and forebays are to be provided adjacent to the attenuation ponds. Drainage from car parking areas that meet the EA threshold would be directed through oil interceptors as part of the drainage system prior to discharging to the watercourses, thereby maintaining the level of quality of water discharging to these existing networks. The impact upon water quality will therefore be not significant .
14.6.7 The following specific measures are proposed to assist with managing water quality further:
° There will be a series of catchpit chambers upstream of the outfall to the attenuation ponds to arrest suspended debris.
° The detailed drainage design, in accordance with CIRIA C697, will ensure that sediment and contaminants are captured and water is treated, before being discharged from the site (the FRA provides the Total Treatment Volume required).
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° The proposed surface water drainage system includes trapped gullies to reduce sediment and hydrocarbon content.
° Runoff would be discharged via an oil interceptor to remove hydrocarbons before being discharged to the attenuation ponds, where parking areas meeting the EA threshold.
° Specific pollution prevention devices incorporated in the drainage system would have appropriate signs in order for emergency or highway services to operate and maintain them easily, and would be designed for ease and simplicity of operation and maintenance.
14.6.8 To mitigate any residual risk as a result of climate change a 20% increase in rainfall intensity has been incorporated into the drainage strategy.
Significance of Residual Operational Effects
14.6.9 With the operation of a new commercial development with associated car parking and roads, there remains a risk of accidental spillage of fuel through vehicle accidents. This risk is considered to have the potential to result in a minor effect on the groundwater attribute of medium importance . This is an unavoidable consequence of building a new development (as without the development there would be no risk, but with it there would be some risk, however unlikely). The proposal to incorporate a significant length of swales to the scheme positioned downstream of parking areas means that any spillage has a reasonable likelihood of being contained. The risk is considered to be no greater than other local roads and residential areas so is therefore not significant .
14.6.10 The proposed drainage system, with the mitigation measures taken into account, would reduce any potential effects of routine runoff to groundwater and diffuse pollution to watercourses such that the effect is considered not significant .
14.6.11 The scheme has potential to make some local improvements in the biodiversity value of the ditch flowing to the Coomb Haven by providing a variety of habitats as part of the diversion. This would help towards meeting WFD objectives of improving ecological potential to good status by 2027. It would also be in line with the NPPF which requires that development should retain, protect and enhance ecological interests. This would be achieved by:
° Incorporation of the SUDS system and the introduction of the two attenuation ponds as part of the scheme which would introduce habitat that has the potential to encourage ecological enhancement and biodiversity.
° The use of appropriate native species planting and grass seeding along affected watercourses and within and around the new attenuation ponds.
14.6.12 In summary, the implementation of the scheme complete with the mitigation measures detailed above would ensure that the effects to surface water regime and quality are not significant .
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14.7 Assessment and Mitigation of Cumulative Effects
14.7.1 The Bexhill Enterprise Park has been assessed in this chapter against the baseline water environment within the site as it currently exists and assuming that the BHLR and NEBGR are already constructed. There have been found to be no significant effects.
14.7.2 The BHLR is known to include similar measures including filter drains, and lagoons to control and mange surface water drainage and quality. The BHLR ES states that “with the mitigation measures proposed the impact on flooding would be neutral” ; the impact on surface water quality “would be only minor adverse during the construction phase and neutral during operation.”
14.7.3 It is not anticipated that the foul sewer networks will have any detrimental effect on the ground water quality.
14.7.4 The cumulative effect of all schemes on water quality and drainage to existing watercourses and the water environment is considered not significant .
14.8 Summary of Residual Effects
14.8.1 Surface water runoff from the proposed development will be managed at all stages from construction to operation. Discharge from the proposed development will be reduced to appropriate rates. As a minimum, the outline strategy included within the FRA ensures that there is no change in the rate of surface water discharge leaving the site, such that the residual impact on flood risk downstream of the site is insignificant .
14.8.2 The principle mechanism with which deteriorations in water quality could occur is through surface water diffuse pollution from the site. The control measures put in place during construction and the outline surface water drainage strategy within the FRA will ensure that contaminants, hydrocarbons and particulate matter, which have the potential to enter and negatively impact watercourses and groundwater systems, will be controlled at source as well as ensuring that the chemical quality of the discharge leaving the site meets appropriate standards. Implementation of the above measures will ensure that there is no change in water quality both on site and in receiving groundwater at downstream watercourses.
14.9 Summary
14.9.1 The investigation and assessment of water quality and drainage has shown that the risks to this environmental element are not significant . The site is not affected by flooding, and surface water mitigation measures are proposed within the FRA.
14.9.2 The environmental significance of the effects during construction of the Bexhill Enterprise Park has potential to cause minor impacts on water quality. This chapter has outlined a suite of mitigation measures that could be implemented at construction phase and within the CEMP to mitigate these impacts. By implementing these measures the significance of any effect during construction is not significant .
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14.9.3 Best-practice drainage design standards have been implemented to include water treatment solutions with the proposed design of the surface water attenuation ponds - this is outlined within the FRA. This chapter therefore shows that the significance of the environmental effects upon construction and occupation (use) of the Bexhill Enterprise Park has been managed appropriately.
14.10 References
ESCC 2012, Bexhill to Hastings Link Road Surface Water Drainage Philosophy, Document Number: B1297001/0500.06a/0001, Revision: 0 dated 22 February 2013, Jacobs U.K Limited, Maidstone.
ESCC 2007, Bexhill to Hastings Link Road Environment Statement, Chapter 9 Quality and Drainage, East Sussex County Council, Lewes
Peter Brett Associates, 2013, Environmental Impact Assessment, Chapter 14 Water Quality and Drainage
Environment Agency, 2013. Water Body Summary Statement: Combe Haven between Powdermill Stream Confluence and Coast, dated 17 June 2013.
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15 Cultural Heritage
15.1 Introduction
15.1.1 This chapter evaluates the effects of the proposed Bexhill Enterprise Park on cultural heritage. It is based on the findings of a heritage desk based assessment which is included in Appendix J.1 , the results of a geophysical survey which is included in Appendix J.2 , an historic buildings assessment of Glovers Farm which is included in Appendix J.3 , the results of the on-going archaeological investigations of the Bexhill to Hastings Link Road (BHLR) and discussions with the East Sussex County Archaeologist.
15.1.2 The key objectives of the assessment are to:
° Assess the potential impact of construction of the proposed development on known and potential non-designated archaeological heritage assets (there are no designated heritage assets within the site) and to evaluate the significance of the impact;
° Assess the potential impact of construction and operation of the proposed development on the setting of designated heritage assets and to evaluate the significance of the impact; and
° Identify measures for avoiding or mitigating potential impacts and detail any residual impacts that cannot be mitigated.
15.1.3 This chapter has been prepared by CgMs.
15.2 Policy Context
15.2.1 In March 2012, the government published the National Planning Policy Framework (NPPF), which replaced previous national policy relating to heritage and archaeology (Planning Policy Statement 5: Planning for the Historic Environment).
15.2.2 Section 12 of the NPPF, entitled ‘ Conserving and enhancing the historic environment ’ provides guidance for planning authorities, property owners, developers and others on the conservation and investigation of heritage assets. Overall, the objectives of Section 12 of the NPPF can be summarised as seeking the:
° Delivery of sustainable development;
° Understanding the wider social, cultural, economic and environmental benefits brought by the conservation of the historic environment;
° Conservation of England's heritage assets in a manner appropriate to their significance; and
° Recognition of contribution that heritage assets make to our knowledge and understanding of the past.
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15.2.3 Section 12 of the NPPF recognises that intelligently managed change may sometimes be necessary if heritage assets are to be maintained for the long term.
15.2.4 Paragraph 128 states that planning decisions should be based on the significance of the heritage asset and that level of detail supplied by an applicant should be proportionate to the importance of the asset and should be no more than is sufficient to understand the potential impact of the proposal upon the significance of that asset.
15.2.5 Heritage Assets are defined in Annex 2 as: A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage assets include designated heritage assets and assets identified by the local planning authority (including local listing).
15.2.6 Archaeological Interest is defined as a heritage asset which holds or potentially could hold evidence of past human activity worthy of expert investigation at some point. Heritage assets with archaeological interest are the primary source of evidence about the substance and evolution of places, and of the people and cultures that made them.
15.2.7 Designated Heritage Assets comprise of World Heritage Sites, Scheduled Monuments, Listed Buildings, Protected Wreck Sites, Registered Park and Gardens, Registered Battlefields and Conservation Areas.
15.2.8 Significance is defined as: The value of a heritage asset to this and future generations because of its heritage interest. This interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting.
15.2.9 Setting is defined as: The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral.
15.2.10 In short, government policy provides a framework which:
° Protects nationally important designated Heritage Assets;
° Protects the settings of such designations;
° In appropriate circumstances seeks adequate information (from desk based assessment and field evaluation where necessary) to enable informed decisions; and
° Provides for the excavation and investigation of archaeological heritage assets that are to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence publicly accessible.
15.2.11 In considering any planning application for development, the planning authority will be mindful of the framework set by government policy, in this instance the NPPF, by current Development Plan policy and by other material considerations.
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15.2.12 The Development Plan is provided by the Rother Local Plan (adopted in 2006), while the site is also covered by the North East Bexhill Supplementary Planning Document (adopted in 2009). There are no saved policies relating to cultural heritage in either document.
15.3 Methodology
15.3.1 A 500m search radius out from the Bexhill Enterprise Park and the site boundary for non- designated and designated heritage assets was used. This is referred to as the study area.
15.3.2 A heritage desk-based assessment was produced in accordance with the Institute for Archaeologists Standards and Guidance for Archaeological Desk-based Assessments (2008) and is included in Appendix J.1 . The desk based assessment included the assessment of designated and non-designated heritage assets within the 500m study area and the archaeological potential of the site. Sources of data included: East Sussex Historic Environment Record; National Monuments Record; the National Heritage List for England; historic cartographic and documentary sources in the East Sussex Records Office and the British Library; and unpublished material from recent nearby archaeological investigations (Chris Blanford Associates 2004; East Sussex County Council, Undated. Bexhill to Hastings Link Road, Environmental Statement Chapter 14: Cultural Heritage; Oxford Archaeology 2006a; Oxford Archaeology 2006b; Oxford Archaeology 2007, Oxford Archaeology 2008 & Oxford Archaeology 2013).
15.3.3 A geophysical survey of the site has been undertaken, the results of which are included in Appendix J.2.
15.3.4 An appraisal of the significance of Glover’s Farm has been undertaken the results of which are included in Appendix J.2 .
Significance Criteria
15.3.5 Criteria for assessing the magnitude of predicted change are given in Table 15.1 .
Table 15.1: Criteria for Assessing Magnitude of Change on Heritage Receptors
Magnitude Impact Total or substantial loss of the significance of a heritage asset. Substantial harm to a heritage asset's setting such that the significance of the asset would be totally lost or substantially reduced (e.g. the significance of a designated Major heritage asset would be reduced to such a degree that its designation would be questionable; the significance of an undesignated heritage asset would be reduced to such a degree that its categorisation as a heritage asset would be questionable). Partial loss or alteration of the significance of a heritage asset. Considerable harm to a heritage asset’s setting, such that the asset's significance Moderate would be materially affected/considerably devalued, but not totally or substantially lost. Slight loss of the significance of a heritage asset. This can include the removal of fabric that forms part of the heritage asset, but that is not integral to its significance (e.g. the demolition of later extensions/additions of little intrinsic value). Minor Some harm to the heritage asset’s setting, but not to the degree that it would materially compromise the significance of the heritage asset. Level of harm perceivable, but insubstantial relative to the overall interest of the heritage asset. Negligible A very slight change to a heritage asset. This can include a change to a part of a
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heritage asset that does not materially contribute to its significance. Very minor change to a heritage asset’s setting such that there is a slight impact not materially affecting the heritage asset's significance. No impact No change to a heritage asset or its setting.
15.3.6 The sensitivity of the heritage asset will depend on factors such as the condition of the asset and its perceived heritage value and significance. The sensitivity of the heritage asset receptor is defined by its significance in terms of national, regional or local statutory or non- statutory protection and grading of the asset. Table 15.2 sets out the criteria for assessing sensitivity.
Table 15.2: Criteria for Assessing Sensitivity of Receptors
Sensitivity Criteria Very High World Heritage Sites Scheduled Monuments & Areas of Archaeological Importance Archaeological sites of schedulable quality & significance High Registered Historic Parks and Gardens (all grades) Historic Battlefields Medium Undesignated sites of demonstrable regional importance Sites with significance to local interest groups. Low Sites of which the significance is limited by poor preservation and poor survival of contextual associations.
15.3.7 The sensitivity of the receiving environment, together with the magnitude of change, defines the significance of the impact as set out in Table 15.3 , drawing upon the defined terms for each of the significance criteria in Table 15.1 .
Table 15.3: Criteria for Assessing Significance of Impact MAGNITUDE OF CHANGE Major Moderate Minor Negligible
Very High Severe Major Moderate Minor High Severe Major Moderate Minor Minor / Not Medium Major Moderate Minor significant
SENSITIVITY Low Moderate Minor Minor Not significant
15.4 Baseline Conditions
15.4.1 The location of sites / structures / finds identified in the following text are shown in Figure 3 in Appendix J.1 .
Prehistoric
15.4.2 There are no Palaeolithic remains recorded within the study area.
15.4.3 There are no Mesolithic remains recorded on the East Sussex HER. A single flint arrowhead dated to the late Neolithic/early Bronze Age has been discovered immediately to the north of the site (MES 125).
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15.4.4 Recent and on-going archaeological investigations along the route of the BHLR have revealed a complex sequence of occupation and land use of the area in the late Mesolithic / early Neolithic and the late Neolithic – Bronze Age periods (Oxford Archaeology 2013).
15.4.5 Recent archaeological work in association with the BHLR has revealed a series of Late Mesolithic / early Neolithic activity areas in the lower slopes of the nearby rivers with some lesser scatters of artefacts of the same date on the higher slopes of the valleys. This is indicative of a relatively densely occupied/exploited landscape at this time.
15.4.6 The BHLR investigations have established a similar pattern of late Neolithic / Bronze Age activity / occupation along with indications of woodland clearance of the higher slopes at this time. As with the Mesolithic/early Neolithic period, although there are no indications of late Neolithic / Bronze Age remains within the site, it is considered possible that remains of this period could be present.
15.4.7 No Iron Age remains have been recorded in the study area. However, numerous contemporary iron working sites are recorded from the nearby Weald. Undated, but of possible Iron Age date iron working sites have been recorded within or within close proximity to the study area. One of these (MES 7313) is located at the roundabout of the NEBGR and BHLR. A second iron working is located close by immediately to the north of the site (HER MES 66). Further iron working sites are recorded c. 100m west of the site (MES 114) and c. 400m north of the site (HER MES 308).
15.4.8 Overall the archaeological potential of the study area for the earlier prehistoric periods is considered to be moderate. Based on the evidence of iron working activity occurring in the general area, the potential for Iron Age remains is considered to be moderate to high. However, all of these potential iron working sites are undated and could be evidence of a later period(s).
Roman
15.4.9 There are no remains of certain Roman date recorded within the study area. However, during this period, the Bexhill and Hastings area was heavily exploited for iron working with major iron working sites at Beauport Park, Bynes Farm and at Little Henniker Wood possibly forming part of an imperial or military estate. Locally it is likely that the late Iron Age settlement pattern continued into the early Roman period, perhaps being replaced with larger centralised farmsteads and hamlets. Based on the level of evidence from the study area the archaeological potential of the study area for the Roman period is considered to be low to moderate.
Saxon-Medieval
15.4.10 There are no Saxon sites or finds recorded in the study area. In the early Saxon period the study area lay within the lands of the ‘Haestingas’ a tribal group forming part of the Kingdom of Sussex. Several local place names are of early Saxon origin. The place names of lower (now little) and upper Worsham Farm respectively, both to the east of the study area, are first recorded as ‘Wyrtlesham’ in AD772 (MES 19670). The place name ‘Pebsham’ (1km to
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the east of the site) originated as ‘Pyppels Hamm’ (Pyppels Farm) in the Anglo Saxon period though it is first recorded in the twelfth century (MES 19473).
15.4.11 The pattern of dispersed farmsteads that characterised the study area until the twentieth century was in place by the late medieval period. The nearest nucleated settlement was the medieval hamlet of Sidley to the west (MES 19687). A number of farmsteads within the wider study area were probably in use during the late medieval period. The East Sussex HER evidence records that Wood Farm (MES 19685) to the west was a large medieval farmstead.
15.4.12 Earthworks relating to land terracing and boundaries have previously been identified at the western end of the site during a walkover survey in 2004 (MES 7310). A medieval token is recorded within the north of the employment site (MES 15881) and medieval pottery found from 400m to the north-west of the site at Sidley Wood (MES 126).
15.4.13 The site is likely to have comprised agricultural land or woodlands in the Saxon and medieval periods. Therefore, it is considered to have a low to moderate potential for agricultural remains for this period and low potential for settlement remains.
Post-Medieval and Modern
15.4.14 The results of a map regression exercise are presented in Appendix J.1 . In summary, the historic maps show that the site has been entirely open land since at least 1806 with only development occurring in the vicinity of Glover’s Farm. The first historic map on which Glovers Farm is depicted on is the 1806 OS map ( Appendix J.1, Fig. 3 ).
15.4.15 Glover’s Farm is not listed. It was constructed over a number of different building phases, using a variety of construction techniques and materials, with a high degree of modern alteration in the form of window replacement (with plastic frames) and internal works. The timber frame of the historic core appears to be mid-seventeenth century in date, of the box frame type with small square panels and without any ornamental bracing. This structure has been rendered across its main elevation and internal damage along this wall suggests that it has been re-fronted entirely, or in part, with brick. The timber frame remains visible underneath paint along the rear wall and varnished along the eastern wall. With reference to the Secretary of State’s Principle of Selection for Listing Buildings (March 2010) and English Heritage’s Listing Selection Guide for Vernacular Houses (April 2011), it is considered that within the context of East Sussex, where there are already a considerable number of listed timber framed farmhouses, that Glovers Farm does not represent a good example of vernacular farmhouse in this vicinity. Whilst the plan form of the original timber framed building remains discernible in places, and the building’s subsequent development phases are of some interest, the degree of modern alteration to the fabric is such that the building is unlikely to satisfy statutory criteria for ‘special architectural or historic interest’. None of the rooms retain particular features that distinguish former uses (either specialist uses or relating to industrial use) or social status, nor does the building display any evidence of innovation. The modern alterations that have taken place are also not considered to be sympathetic to
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the historic building and have served to erode and obscure its heritage significance, particularly relating to the main living room. No evidence has been found to suggest that Glovers Farm has any interest with regard to historic figures of note or historic events, either on a national or local level.
Undated
15.4.16 Some undated earthworks of former quarrying activity have been recorded to the east of Glovers Farm (MES7310).
15.4.17 The geophysical survey has identified a negative response indicative of a banked feature which appears to predate the 1885 field boundary and has been classified as of probable archaeological origin. In addition, a series of positive anomalies are identified which may indicate former cut features such as ditches and may be of archaeological interest. Responses associated with modern activity such as magnetic disturbance, debris and ‘spikes’ are seen across much of the area. Also noted are anomalies indicative of modern agricultural activity and a former field boundary, in use until approximately 1951.
Designated Heritage Assets
15.4.18 There is one grade II listed building just to the east of the study area. This is Boulder Cottage which is an early 19 th century front to a possibly older building. The setting of the cottage is limited to its garden and the fields and lane immediately adjacent to the cottage. The proposed development lies well beyond the setting of the cottage.
15.4.19 There are no scheduled monuments, registered parks and gardens, conservation areas or world heritage sites within or near the study area.
15.5 Assessment and Mitigation of Construction Effects
15.5.1 An undated, but assumed to be Iron Age, iron working site has been recorded within the area of the NEBGR/BHLR roundabout (MES7313 & 66). These remains are considered to be of local importance / significance and therefore of low sensitivity. The construction of the roundabout will result in the destruction of this. The possible field boundaries recorded in the geophysical survey are considered to be of low sensitivity. These will be impacted by the construction of the development. Therefore, there will be a moderate effect on these remains. MES66 will be impacted by the construction of the BHLR not NEBGR.
15.5.2 There are three find spots within the site: a medieval token (MES 15881), a post-medieval token (MES15878) and an undated lead weight (MES15877). These are not indicative of associated below ground remains. Therefore, there will be no impact on these remains. There are some undated quarrying earthworks recorded to the east of Glovers Farm which will be impacted by the proposed development. These are considered to be of local importance/significance and therefore would be of low sensitivity. Should such remains be present, the construction of the NEBGR would have a moderate impact upon them.
15.5.3 It is possible that there could be as yet unrecorded archaeological remains within the NEBGR corridor. Should such remains be present, it is anticipated that would be of local
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importance / significance and therefore would be of low sensitivity. Should such remains be present, the construction of the NEBGR would have a moderate impact upon them.
15.5.4 The archaeological potential of the site will be clarified and quantified by a programme of detailed archaeological evaluation comprising a programme of trenching and other archaeological investigative techniques that will be undertaken as a condition of planning permission. The detail of the programme will be discussed and agreed with East Sussex County Council and Rother District Council following the granting of planning permission.
15.5.5 Should the evaluation have positive results, areas of archaeological significance that will be impacted by construction activities will be excavated and recorded in advance of construction commencing with the results being published following completion of the post- excavation analysis.
15.5.6 It is considered that the farmhouse of Glovers Farm is not a good example of vernacular domestic building in a wider national context and would not warrant listing, since it does not satisfy statutory criteria for ‘special architectural or historic interest’. It is proposed to demolish the house however the farmhouse will be recorded prior to demolition.
15.6 Assessment and Mitigation of Operation Effects
15.6.1 There will be a negligible impact from the operational phase of the Bexhill Enterprise Park on designated and non-designated heritage assets, as any effects would be associated with the construction phase.
15.7 Summary of Residual Effects
15.7.1 Following the implementation of the proposed mitigation proposals above, there will be no significant residual effects on designated or non-designated heritage assets, as any affected remains will have been identified and preserved by record.
15.8 Summary
15.8.1 The effects of the proposed Bexhill Enterprise Park on the historic environment have been assessed. A heritage desk based assessment has been undertaken in accordance with Standards and Guidelines issued by the Institute for Archaeologists. This has established the historic environment baseline conditions (i.e. the presence / absence, location and nature of designated and non-designated heritage assets). The desk based assessment has been supplemented by a geophysical survey and a designation assessment of the farmhouse at Glovers Farm.
15.8.2 The assessment has established that two possibly associated undated, but assumed to be Iron Age iron working sites of low sensitivity are located in the area of the NEBGR/BHLR roundabout. There are no remains of archaeological significance within the site. There is potential for as yet unrecorded remains which, if present are considered likely to be of low to medium sensitivity. The proposed development will have a moderate adverse impact upon these remains.
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15.8.3 Glovers Farmhouse is non-designated heritage asset and which was judged not to is not to be of sufficiently high special historic or architectural interest to warrant designation. The farmhouse will be demolished following preservation by record.
15.8.4 There only one designated heritage asset within the wider study area which is a Grade II listed cottage. There will be no effect on the setting of this designated heritage asset.
15.8.5 A mitigation strategy comprising evaluation trenching is proposed, along with the recording of Glovers Farm. Should this have positive results, this will be followed by full excavation and recording of archaeological remains where necessary. This will secured by an appropriately worded condition.
15.9 References
Chris Blanford Associates 2004. Bexhill to Hastings Link Road, Archaeological Desk Based Assessment
Department of Communities and Local Government National Planning Policy Framework 2012
Department of Communities and Local Government/Department of Culture Media and Sport/English Heritage PPS5 Planning for the Historic Environment: Historic Environment Planning Practice Guide 2010
East Sussex County Council Undated. Bexhill to Hastings Link Road, Environmental Statement Chapter 14: Cultural Heritage
English Heritage Comparison of PPS5 Policies with Historic Environment-Related Policies in the NPPF – Part 1 5 April 2012 unpublished document
English Heritage Comparison of PPS5 Policies with Historic Environment-Related Policies in the NPPF – Part 2 5 April 2012 unpublished document
Gibbard The Pleistocene History of the Lower Thames Valley 1994
Institute for Archaeologists Standard & Guidance for archaeological desk based assessment updated November 2008
Oxford Archaeology 2006a. Bexhill to Hastings Link Road, Desk Based Assessment
Oxford Archaeology 2006b. Bexhill to Hastings Link Road, Walkover Survey
Oxford Archaeology undated. Bexhill to Hastings Link Road, Cultural Heritage Gazetteer
Oxford Archaeology 2007. Bexhill to Hastings Link Road, Field Collection Survey
Oxford Archaeology 2008. Bexhill to Hastings Link Road, Geo-archaeological Field Assessment
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Oxford Archaeology 2013. Bexhill to Hastings Link Road, Archaeological and Geoarchaeological Evaluation Report
Wymer The Lower Palaeolithic Occupation of Britain 2 volumes 1999
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16 Summary & Impact Interactions
16.1 Introduction
16.1.1 Environmental effects can result from incremental changes caused by the interactions between effects resulting from a project. For the purpose of this assessment, the interactions between effects associated with the proposed development are defined as ‘combined effects’.
16.1.2 The direct and indirect effects of the proposed development have been assessed within the relevant topic chapters of the ES prepared by suitable technical specialists. Environmental effects are assessed relative to the topic under consideration. This approach can lead to the interaction of effects being reported in separate chapters but the collective effect on the same environmental resource(s) not being considered.
16.1.3 In response this chapter, prepared by Peter Brett Associates LLP, summarises the principal findings of each topic chapter of the ES to enable assessment of the potential for impact interactions. This chapter also provides a summary of the environmental effects identified throughout the ES and allows a judgement to be made of the overall effect of the proposed development during construction and operation.
16.2 Methodology
16.2.1 The assessment methodology for combined effects involves the identification of impact interactions associated with both the construction and operational phases of the proposed development upon one or more environmental resources. This is undertaken using a qualitative appraisal process.
16.2.2 This approach has been used by PBA for numerous EIAs and draws upon the following guidance:
° Institute of Environmental Management & Assessment, (2004), Guidelines for Environmental Impact Assessment (IEMA);
° Hyder, (1999), Final Report on the Study on the Assessment of Indirect and Cumulative Impacts, as well as Impact Interactions within the Environmental Impact Assessment (EIA) Process NE80328/D3/2, European Commission Directorate General XI, Environment, Nuclear Safety and Civil Protection; and
° Mitigation measures are identified in each of the topic chapters, and have been used to inform the assessment presented in this chapter.
16.2.3 The assessment of the significance of effects has been based on the generic significance criteria provided in Table 5.1 .
16.2.4 Cumulatively, the construction of the NEBGR and the BHLR with the proposed development is identified, with impacts on construction effects relating to traffic, noise, air quality, etc.
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being either not significant, or where a significant effect is identified then it is controlled via appropriate mitigation and good practice procedures detailed within each Construction Environmental Management Plan.
16.3 Construction Effects
16.3.1 The majority of the environmental effects identified during construction are not significant (air quality, ground conditions, water quality) or of minor adverse significance, although these are predominantly temporary in nature.
16.3.2 There is expected to be a moderate adverse effect on residents living close to the site as a result of noise during construction (although this effect will be intermittent during the construction period). Local residents may also be affected by minor adverse effects in relation to temporary severance impacts to footpaths and on adjacent open spaces and pedestrian and cyclist amenity in relation to open space receptors associated with the BHLR due to the importance of the footpath.
16.3.3 The ecological effects of the development vary in relation to which ecological receptor is considered. The majority of effects will not be significant, with minor adverse effects identified in relation to badger and minor beneficial effects in relation bats.
16.3.4 The landscape and visual assessment has established that such effects will be localised and that such effects while typically not significant in certain locations will be minor to moderate adverse, affecting key landscape elements and features, and tranquillity. Major adverse impacts are identified in relation to the Glover’s Farm landscape character area. Most views of the site and construction works will be limited and temporary, however there are adverse impacts on some views up to major significance.
16.3.5 The archaeological potential of the site is to be quantified by a programme of archaeological evaluation. The loss of Glovers Farmhouse is assessed a major adverse, and a programme of detailed recording is to be undertaken to mitigate this loss.
16.3.6 The adverse effects of the construction period on the community will be partially offset by a minor beneficial effect in relation to construction employment opportunities.
16.3.7 The only other significant effect identified during construction relates to the loss of agricultural land, however such land is designated for development in local planning policy.
16.3.8 Overall therefore there is considered to be a minor adverse effect on local communities as a result of the construction of the proposed development.
16.4 Operation Effects
16.4.1 The most significant effects during the operation of the Bexhill Enterprise Park relate to the economic benefits of the proposed development. The Bexhill Enterprise Park will provide allocated employment space, which provides employment opportunities for local people and a significant boost to the local economy. These economic effects are considered to be major beneficial effects.
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16.4.2 The majority of the other effects of the proposed development upon local people are not significant (noise, air quality, driver delay, and effects on pedestrians and cyclists, ground conditions, drainage and water quality, heritage assets).
16.4.3 A minor adverse effect is anticipated in relation to severance as a result of the additional traffic on roads affecting the public rights of way and users of the open spaces adjacent to the BHLR and Wrestwood Road, although this will be mitigated by design features of the NEBGR. Minor adverse impacts are also predicted in relation to fear and intimidation on open space users and schools due to the level of change in traffic flows, but this is not significant for residential areas. Driver delay is also of minor adverse significance for schools, but no other receptors. New footways and cycle ways are to be constructed and this will improve accessibility for both pedestrians and cyclists to new local employment facilities.
16.4.4 Implementation of new landscaping and habitat creation should overall result in a minor beneficial residual impact for wildlife in the long term.
16.4.5 Landscape and visual effects will be beneficial in the long term, reflecting the introduction of a variety of planting and landscape features to improve the transition zone between the rural and urban areas and providing buildings of high architectural quality.
16.4.6 Whilst the loss of agricultural land is considered moderate adverse impact, it is an accepted principle that the site is allocated for development in local planning policy.
16.4.7 Overall, therefore the Bexhill Enterprise Park is considered to have a moderate beneficial effect during operation.
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17 Glossary
AADT Annual Average Daily Traffic
ADMS Comprehensive Software for Modelling Air Quality
AEL Applied Ecology
AOD Above Ordnance Datum
AONB Area of Outstanding Natural Beauty
AQAP Air Quality Action Plan
AQMA Air Quality Management Area
BaP Benzo(a)pyrene
BAP Biodiversity Action Plan
BEP Bexhill Enterprise Park
BFI Baseflow Index
BgL Below Ground Level
BGS British Geological Survey
BHLR Bexhill to Hastings Link Road
BHS British Hydrology Society
BIS Department of Business, Innovation and Skills
BREEAM Building Research Establishment Environmental Assessment Method
BS British Standards
BSI British Standards Institution
BX2 Policy BX2 of the Local Rother Plan
BX3 Policy BX3 of the Local Rother Plan
CA Countryside Agency
CC Countryside Commission
CDMR Construction (Design and Management) Regulations
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CEMP Construction Environmental Management Plan
CIHT Chartered Institute of Highways and Transport
CIRIA Construction Industry Research and Information Association
CLG Communities and Local Government
COSHH Control of Substances Hazardous to Health
CRTN Calculation of Road Traffic Noise
CS Core Strategy
DCLG Department for Communities and Local Government
DEFRA Department for Environment, Food and Rural Affairs
DfT Department for Transport
DMRB Design Manual for Roads and Bridges
DoWCoP Definition of Waste: Development Industry Code of Practice
DTM Digital Terrain Model
DWS Drinking Water Standards
EA Environment Agency
EC European Commission
EFT Emission Factor Toolkit
EHO Environmental Health Officer
EIA Environmental Impact Assessment
EPA Environmental Protection Act
EPUK Environmental Protection UK
EQS Environmental Quality Standards
ES Environmental Statement
ESCC East Sussex County Council
ESEID East Sussex Energy, Infrastructure and Development
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ESRF East Sussex Trees and Woodland Strategy
FRA Flood Risk Assessment
FTEs Full Time Equivalent Jobs
FWMA Flood and Water Management Act
FZ Flood Zone
GCN Great Crested Newt
GEA Gross External Area
GFA Gross Floor Area
GFE General Further Education
GIA Gross Internal Area
GLA The Greater London Authority
GLVIA Guidelines for Landscape and Visual Impact Assessment
GP3 Groundwater Protection
HBC Hastings Borough Council
HDV Heavy Duty Vehicle: a vehicle with a gross vehicles weight greater than 3.5 tonnes, or instance HGVs and buses.
HMRC Her Majesty’s Revenue and Customs
HV High Voltage
IAQM Institute of Air Quality Management
IEEM Institute of Ecology and Environmental Management
IEMA Institute of Environmental Management and Assessment
IPPC Integrated Pollution Prevention and Control
JCAs Joint Character Areas
LAQM Local Air Quality Management
LDF Local Development Framework
LDV Light Duty Vehicle
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LEP Local Enterprise Partnership
LI Landscape Institute
LPA Local Planning Authorities
LTP Local Transport Plan
LV Low Voltage
LVIA Landscape and Visual Impact Assessment
NAQOs National Air Quality Objectives
NCAs National Character Areas
NEBGR North East Bexhill Gateway Road
NEETs Not in Education, Employment or Training
NERC Natural Environment and Rural Communities
NGR National Grid Reference
NHBC National House Building Council
NO 2 Nitrogen Dioxide
NO x Nitrogen Oxides, generally considered to be Nitric Oxide and Nitrogen Dioxide
NPPF National Planning Policy Framework
NPSE Noise Policy Statement for England
OS Ordnance Survey
PGHs Potential Geological Hazards
PM 10 Small Airborne Particles less that 10µm in diameter
PM 2.5 Small Airborne Particles less than 2.5µm in diameter
PPE Personal Protective Equipment
PPG Planning Policy Guidance
PPG Pollution Prevention Guidance
PPS Planning Policy Statement
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PSCs Potential Sources of Contamination
RDC Rother District Council
RFC Ration Flow to Capacity (calculated as the traffic demand divided by the junction capacity, when the RFC is 100%, it means that the junction is fully used)
RIGS Regionally Important Geological and Geomorphological Sites
SAC Special Areas of Conservation
SELEP South East Local Enterprise Partnership
SFRA Strategic Flood Risk Assessment
SGV Soil Guidance Value
SI Statutory Instrument
SNCI Site of Nature Conservation Importance
SPA Special Protection Areas
SPD Supplementary Planning Document
SPZ Source Protection Zone
SSAC Site Specific Assessment Criteria
SSEW Soil Survey of England and Wales
SSSI Site of Special Scientific Interest
SuDS Sustainable Drainage System
SW Surface Water
TA Transport Assessment
TAR Transport Assessment Report
TPO Tree Preservation Order
TRL Transport Research Laboratory
WFD Water Framework Directive
WHO World Health Organisation
WPZ Water Protection Zone
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