DOCUMENT 8.4.4

Statements of Common Ground Wildlife Trust

National Grid (Richborough Connection Project) Order

Application Ref: EN020017 July 2016

Richborough Connection Project Statement of Common Ground between National Grid and Kent Wildlife Trust

National Grid National Grid House Warwick Technology Park Gallows Hill Warwick CV34 6DA

Signed

(July 2016)

Richborough Connection Project - Statement of Common Ground

Document Control

Document Properties

Organisation Amec Foster Wheeler

Author Caroline Gettinby

Approved by Emer McDonnell

Statement of Common Ground Between National Grid and Title Kent Wildlife Trust

Document Reference 8.4.4

Version History

Date Version Status Description/Changes

07.07.16 7 Signed Signed SoCG for Deadline 2

1 Richborough Connection Project - Statement of Common Ground

2 Richborough Connection Project - Statement of Common Ground

Table of Contents

1 INTRODUCTION ...... 5 1.1 Purpose of this Document ...... 5 1.2 Approach to the SoCG ...... 5 2 CONSULTATION ...... 6 2.1 Role of Kent Wildlife Trust in the DCO process ...... 6 2.2 Summary of consultation...... 6 3 MATTERS AGREED ...... 9 3.1 Summary of current position ...... 9 3.2 Kent Wildlife Trust principal matters agreed ...... 9 3.3 Kent Wildlife Trust specific matters agreed ...... 10 4 MATTERS CURRENTLY OUTSTANDING ...... 17 4.1 Summary of current position ...... 17 4.2 Kent Wildlife Trust specific matters currently outstanding ...... 17

3

Richborough Connection Project - Statement of Common Ground

1 INTRODUCTION 1.1 Purpose of this Document 1.1.1 This Statement of Common Ground (SoCG) is between National Grid Electricity Transmission Ltd (“National Grid”) and Kent Wildlife Trust relating to the Development Consent Order (“DCO”) application for the Richborough Connection Project. It has been prepared in accordance with the guidance1 published by the Department of Communities and Local Government. 1.1.2 This SoCG has been prepared to identify matters agreed and matters currently outstanding between National Grid and Kent Wildlife Trust. The SoCG will evolve as the DCO application progresses through examination.

1.2 Approach to the SoCG 1.2.1 This SoCG is structured as follows: • Section 1 provides an introduction to this SoCG and a description of its purpose. • Section 2 states the role of Kent Wildlife Trust in the DCO application process and details consultation undertaken between National Grid and Kent Wildlife Trust. • Section 3 sets out matters agreed between National Grid and Kent Wildlife Trust. • Section 4 sets out matters where agreement is currently outstanding between National Grid and Kent Wildlife Trust. • Appendix A includes the signing off sheet.

.

1 Planning Act 2008: Guidance for the examination of applications for development consent. Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/418015/examinations_guidance- __final_for_publication.pdf

5 Richborough Connection Project - Statement of Common Ground

2 CONSULTATION 2.1 Role of Kent Wildlife Trust in the DCO process 2.1.1 Founded in 1958, Kent Wildlife Trust is a registered charity2 and a leading conservation organisation covering the whole of Kent and , dedicated to protecting wildlife and wild habitats for everyone to enjoy. The Trust owns and manages areas of land for the benefit of wildlife and nature conservation. It is supported by membership of approximately 30000 individuals and corporate supporters. The Trust provides an educational resource for local people through its reserves, five visitor centres and education outreach team. It supports and administers Local Wildlife Sites (sites of county importance for nature conservation) and offers a professional consultancy service through its specialist advice team. The Trust also employs planning officers, who comment on development proposals and planning policy in respect of wildlife interest in Kent. 2.1.2 Kent Wildlife Trust engages proactively in the planning process across the county. In the context of the proposed development, Kent Wildlife Trust’s responsibilities relate primarily to its reserves that it either owns or manages and to sites that are designated as Local Wildlife Sites (LWS). However, Kent Wildlife Trust may also comment on the need to comply with Natural England’s standing advice on legally protected species. Kent Wildlife Trust mayrespond to planning proposals affecting nationally or internationally protected sites where: • this may serve to support and reinforce the national agency’s position; • there may be an impact on a Kent Wildlife Trust reserve; and • there may be a significant risk to nationally or internationally important biodiversity should they fail to submit an independent view. 2.1.3 Kent Wildlife Trust comments only on the potential impacts on wildlife in respect of development consultations.

2.2 Summary of consultation 2.2.1 Kent Wildlife Trust is not defined as a prescribed or non-prescribed consultee in the DCO process, although National Grid seek to consult with them the Trust as a matter of best practice. Consultation carried out by National Grid and the way in which it has informed the DCO application is set out in full in the Consultation Report (Volume 6, Document 6.1) submitted with the DCO application. Kent Wildlife Trust was included in the pre-application consultation carried out by National Grid. 2.2.2 KWT has indicated that no further meetings are required, but that it wishes to continue providing feedback on pertinent issues. National Grid and Kent Wildlife Trust continue to be in direct communication in respect of the DCO application and issues where relevant to Kent Wildlife Trust interests. 2.2.3 This SoCG between National Grid and Kent Wildlife Trust is based on an extensive programme of consultation and discussions as summarised in Table 2.1.

2 Registered charity number 239992

6 Richborough Connection Project - Statement of Common Ground

Table 2.1 Consultation between National Grid and Kent Wildlife Trust

Date Details

9 August 2013 Formal Kent Wildlife Trust response to Route Corridor Study (RCS).

30 April 2014 Meeting between National Grid and Kent Wildlife Trust to discuss progress on the project since the publication of the RCS and preliminary findings of the Connections Options Appraisal and Reporting (COR). To discuss and agree scope of designated site, habitat and species issues relevant to Kent Wildlife Trust interests.

9 July 2014 Formal Kent Wildlife Trust response to COR.

19 August 2014 Letter from National Grid to Kent Wildlife Trust relating to their COR response.

10 September 2014 Meeting between National Grid and Kent Wildlife Trust to discuss survey findings to date, surveys scoped in going forward, Kent Wildlife Trust‘s response to the COR report and to discuss EIA scoping.

20 October 2014 National Grid issue the link to the EIA Scoping report, incorporating PINs comments to Kent Wildlife Trust for information/comment.

20 March 2015 Meeting between National Grid and Kent Wildlife Trust to discuss Kent Wildlife Trust response to Preliminary Environmental Information Report (PEIR) and project progress, survey results to date and remaining survey scope for 2015.

9 April 2015 Formal Kent Wildlife Trust response to Section 42 consultation.

5 June 2015 - 2 Ongoing email communications from National Grid to Kent Wildlife Trust to September 2015 arrange meeting/conference call with reserves manager. Kent Wildlife Trust clairified that the Trust does not directly manage Local Wildlife Sites and therefore it is not necessary to discuss future management or mitigation measures on site with the Reserves Manager East.

2 September 2015 Kent Wildlife Trust issues e mail stating that further meetings are not necessary for this project at this stage, however will provide comment on draft mitigation plans when completed for Local Wildlife Sites affected.

3 and 22 National Grid e mailed Kent Wildlife clarifying whether a conference call September regarding the discucsion on birds is no longer required (the need for a site meeting having been ruled out already).

2 October 2015 National Grid issue of draft Method Statements A, C and E and Cover Noteto Kent Wildlife Trust for comment for Kemberland Wood LWS.

20 November 2015, Call, and follow up e mail between Ian Simms of AFW and Kent Wildlife Trust. It was agreed that a SoCG would be prepared between the parties. The call 24 November 2015 included KWT’s general agreement on the approach to mitigation in respect of the site specific plans relating to Kemberland Wood LWS. Kent Wildlife Trust commented that the Trust would comment on the draft site mitigation plans for other Local Wildlife Sites affected once they are issued.

7 Richborough Connection Project - Statement of Common Ground

Date Details

11 December 2015 Kent Wildlife Trust was contacted by an individual with ownership at Kemberland Wood LWS. They were concerned that their land had not been adequately surveyed for Great Crested Newt (GCN) as part of the Richborough Connection project. They stated that they had themselves recorded GCN on their land. Therefore, Kent Wildlife Trust asked AFW in an email of 11th December whether this site had been re-surveyed following this record being submitted by the landowner. In this email, Kent Wildlife Trust stated that the details of the draft Mitigation Statement for Kemberland Wood LWS was satisfactory, the above query notwithstanding.

14 December 2015 National Grid (Caroline Gettinby of AFW) confirmed by email on 14th December that a further presence/absence survey had been carried out for the site in Kemberland Wood between mid-March and mid-May 2015. This survey found no GCN. She also stated that, “although the pond is unsuitable to support a viable GCN population and the survey found no presence, the final Mitigation Plan outlines that any works in potentially suitable habitat within the vicinity of the pond will be conducted under a precautionary method statement for GCN, the pond itself being retained and protected from disturbance and damage”.

15 December 2015 Kent Wildlife Trust e mailed Caroline Gettinby to acknowledge that she had provided clarification on the additional survey work undertaken for GCN.

22 March 2016 Kent Wildlife Trust relevant representation stated that they would like to (received by ExA) submit comments in relation to the environmental impact of the Richborough Connection, in particular in relation to its chosen route and the potential impact upon biodiversity features along it.

17 May 2016 Kent Wildlife Trust issue letter to the Planning Inspectorate confirming their attendance at the preliminary meeting (8 June 2016) and stating their continued concerns in relation to the project.

26 April – 8 July National Grid and Kent Wildlife Trust exchange drafts of the SoCG for review 2016 and agreement: final signed version issued by National Grid on 7 July 2016, returned by Kent Wildlife Trust on 8 July 2016.

8 Richborough Connection Project - Statement of Common Ground

3 MATTERS AGREED 3.1 Summary of current position 3.1.1 Kent Wildlife Trust agrees that the project description for the proposed development is accurately set out in the Environment Statement (Volume 5, Document 5.2, Chapter 3) and this is not discussed further. 3.1.2 National Grid and Kent Wildlife Trust have worked together to ensure inclusion in the DCO application of a number of provisions discussed with Kent Wildlife Trust through consultation on the iterative design process.

3.2 Kent Wildlife Trust principal matters agreed 3.2.1 Kent Wildlife Trust agrees with the following principal matters relating to the DCO application: • The Connections Options Report (COR) – that whilst recognising that some limited and localised effects will occur, in its consideration of the potential effects of the proposed development on biodiversity, the connections options reporting approach is appropriate overall. • The Pylon Design Options Report (PDOR) (Volume 7, Document 7.8) - the selection of pylon technology in each section of the route is appropriate in its consideration of the potential effects of the proposed development on biodiversity - that the use of T- pylons would not be employed. The Trust’s view at pre- submission stage, based upon information provided at the Connection Options Report, is that the lattice pylon would be preferable to the T-pylon. This is because it was indicated in the Connection Options Report that the use of the T-pylon design would lead to a higher number of pylons being required in total, larger vegetation clearance required at each installation, larger work area and more substantial construction roads and infrastructure, leading to more overall vegetation and soil disturbance. Therefore, we concluded that the lattice pylon would result in less overall associated damage and disturbance effects on on terrestrial biodiversity interests. • That the choice of overhead line route over cabling, and lattice pylon over the T pylon design reduces the associated damage and disturbance effects on biodiversity, and is thus appropriate. • EIA Approach and Method – that the methodology used in the ES chapter for the prediction and assessment of effects on biodiversity assets is generally appropriate and follows appropriate guidance (CIEEM, 2006). • That the scope of assessment presented within ES is appropriate. • That Kent Wildlife Trust is willing to defer to the advice provided by Natural England in respect of effects on protected species (in respect of derogations) except where it believes that nationally important biodiversity is at risk if the Trust does not submit an independent view. • Baseline descriptions within the ES and supporting technical reporting of relevance to Biodiversity (Volume 5, Document 5.2, Chapter 9) are generally appropriate. Kent Wildlife Trust would like to clarify that it has received and revewed all those LWS mitigation plans that were requested, as detailed in Table

9 Richborough Connection Project - Statement of Common Ground

9.5 Doc 5.2, but, with the exception of Kemberland Wood, only when they were submitted as part of the DCO application in January 2016, not prior. • That the Planning Policy context for the DCO application, namely EN-1 and EN- 5 is appropriate

3.3 Kent Wildlife Trust specific matters agreed 3.3.1 Matters of agreement with Kent Wildlife Trust relate to the scope and methods of the detailed assessment, the overhead line and pylon technology employed, and resultant site specific effects on biodiversity receptors of the proposed development; particularly those within Kent Wildlife Trust’s remit to comment on development potentially affecting Local Wildlife Sites. The mechanism and detailed pylon mitigation plans have also been agreed, reviewed and approved. Effects on ancient woodland and the approach to management and monitoring are agreed. 3.3.2 Kent Wildlife Trust has also commented on potential effects on Natura 2000 sites, the need and scope for Habitats Regulation Assesment (HRA), and protected species (where licensed mitigation would be required), which are within the statutory remit of Natural England. The specific matters discussed below have been identified through formal consultation on the iterative design process, consultation meetings and communications as set out at Section 2.2. These are detailed in Table 3.1 below.

10 Richborough Connection Project - Statement of Common Ground

Table 3.1 Specific Matters Agreed between National Grid and Kent Wildlife Trust

SoCG ID Matter Agreed Position Date Agreed

3.1 Nemo Link

3.1.1 Nemo Link Interconnector scheme It was agreed to limit the scope of discussions to the 10 September 2014 Richborough Connection project, and to exclude discussion of the Nemo Link Interconnector scheme, consented by Thanet and Councils in December 2013. Kent Wildlife Trust’s opinion that the combined impacts of both projects are significant remains an outstanding concern. A cumulative assessment will be undertaken to include Nemo Link.

3.2 Route Corridor Study (RCS), Connection Options Report (COR), Preliminary Environmental Information report) (PEI) and Environmental Statement

3.2.1 Direct and indirect impacts of the route placement It is agreed that the proposed 400kV PC route cannot be 9 July 2014 and 9 being different to the existing 132kV PX route to constructed in the same position as the 132kV PX route April 2015 be dismantled as the proposed 132kV line to be removed needs to remain in place until the new line is operational to continue to supply power to Thanet and as development has built up surrounding the existing route which would be a factor in the route of the new conneciton

3.2.2 Aproach, method and scope of EcIA assessment It is agreed that the scope provided and methodology 30 April 2014, 10 (in particular in respect of KWT interests; Local used in the ES chapter for the prediction and assessment September 2014, 20 Wildlife Sites and dependant species; Chislet of effects on biodiversity assets is appropriate and follows October 2014, 20 Marshes, Sarre Penn and Preston Marshes LWS, appropriate guidance (CIEEM, 2006). The scope of March 2015, 20 Ash Levels and South Richborough Pasture assessment discussed in meetings and as presented November 2015, 11 LWS, Little Hall and Kemberland Woods and within the ES is appropriate. December 2015. Pasture, West Blean and Thornden Woods; Great Stour, Ashford to Fordwich).

3.2.3 The selection of overhead line over cabling, and It is agreed that the selection of overhead line rather than 9 July 2014 lattice pylon over the T pylon design. the use of cabling is appropriate in respect of minimising effects on terrestrial biodiversity interests. The use of lattice pylons rather than T pylons reduces the associated damage and disturbance effects on biodiversity receptors, and is thus appropriate

3.3 Natura 2000 Statutory Sites including HRA.

11 Richborough Connection Project - Statement of Common Ground

SoCG ID Matter Agreed Position Date Agreed

3.3.1 Indirect impacts on the Thanet Coast and It is recognised that National Grid is consulting the 30 April 2014, 20 Sandwich Bay SPA and Stodmarsh SPA, and appropriate statutory authority (Natural England, (NE)) on March 2015 and 20 direct and indirect impacts on SSSIs (West Blean, statutorily designated sites, and on issues relating to November 2015, 11 Stodmarsh and Sandwich Bay to Hacklinge Habitat Regulation Assessment. The Habitat Regulation December 2015. Marshes). Assessment: No significant effects report, NSER, Volume 5, Document 5.5 has been produced in consultation with Natural England. KWT agrees that SPA qualifying interests that are not screened out (golden plover, hen harrier and gadwall) should be specifically addressed in the HRA. . KWT continue to be consulted on effects relating to dependant species in LWSs and detailed mitigation plans for remaining LWSs affected by the Richborough Connection.

3.3.2 Avoidance and Mitigation Plans (LWS sites) This Kent Wildlife Trust received an enquiry from a member of 20 November 2015, applies in particular to the affected Local Wildlife the public about Kemberland Woods and therefore this 24 November 2015, Sites; Chislet Marshes, Sarre Penn and Preston was discussed specifically.A detailed mitigation plan for 11 December 2015 Marshes LWS, Ash Levels and South Kemberland Wood Ancient Woodland was developed as Richborough Pasture LWS, Little Hall and per discussion with Kent Wildlife Trust, and a draft was Kemberland Woods and Pasture, West Blean provided by National Grid to Kent Wildlife Trust for and Thornden Woods; Great Stour, Ashford to comment (2.10.15). KWT responded on 11.12.15 that the Fordwich. overview approach to this mitigation for this site was appropriate and that the submitted mitigation plan information was adequate. Plans for all pylon locations where negative effects are assessed, are detailed within the Biodiversity Mitigation Strategy, Appendix 3E, Volume 5, Document 5.4).

3.3.3 Avoidance and Mitigation Plans (LWS sites) As the agreed mechanism, mitigation plans have been 15 January 2016 Chislet Marshes, Sarre Penn and Preston prepared for all proposed new pylons, and those to be 2 July 2016 Marshes LWS, Ash Levels and South dismantled, where there was potential for significant or Richborough Pasture LWS, Great Stour, Ashford legal effects. Where appropriate, these include reference to Fordwich. West Blean and Thornden Woods to specific, phased timings of works (paralleling the ancient woodland is also included. construction programme), to minimise negative effects on all receptors. All have been submitted with the DCO and would be secured through it. The mitigation plans illustrate sufficient mitigation to reduce the level of change and resultant effects to a non significant level.

12 Richborough Connection Project - Statement of Common Ground

SoCG ID Matter Agreed Position Date Agreed

3.3.4 Ancient Woodland: pylons and working in National Grid considered this when proposals for siting 5 July 2016 woodlands. pylons were being determined and specific efforts were made to ensure impacts on ancient woodland were minimised. Consequently, no pylons are proposed in ancient woodland habitat. Mitigation plans for those effects resulting from associated works that are proposed in ancient woodlands are detailed within the Biodiversity Mitigation Strategy, Appendix 3E, Volume 5, Document 5.4). The plan for Kemberland Wood (see SoCG ID matter no. 3.3.2) is agreed; plans which affect any other anceient woodland habitats were issued with the DCO application to Kent Wildlfie Trust in January 2016, and would be secured through its requirements. These have been reviewed by Kent Wildlfie Trust and agreed as being appropriate. NE has reviewed a similar Method Statement for Lynne Wood ancient woodland (given its status as an SSSI for the most part). This was also supplied to Kent Wildlife Trust with the DCO submission in January 2016. Biodiversity gain will be achieved in West Blean and Thornden Woods (Lynne Wood) SSSI in the short, through to long term, by improving structure and through further planting. All impacts on component EPS species in ancient woodlands are being licensed through Natural England’s derogation process.

13 Richborough Connection Project - Statement of Common Ground

SoCG ID Matter Agreed Position Date Agreed

3.3.5 Biodiversity gain where the existing 132kV PX Kent Wildlife Trust would like to see biodiversity gain in 5 July 2016 route is to be dismantled sections of the route where the existing line is removed and land beneath it restored. The dismantling of the 132kV PX route, alongside positive conservation management of the land under the proposed 400kV to improve (currently poor) structure, would result in biodiversity gain through regeneration / planting of habitats within the vacated zone in the medium to long term, There would be an adverse change of low magnitude in the short term, changing to a low beneficial change in medium to long term, and that no significant effect would result. Further information on the methods and impacts of the dismantling of the existing 132kV PX route is contained in the ES and supporting documents (Volume 5).

14 Richborough Connection Project - Statement of Common Ground

Management and monitoring both during and after 3.3.6 Management and Monitoring: Commitment to 5 July 2016 construction would occur in respect of specified management, enhancement and monitoring. receptors, and as supported by NE and , that such works should be proportionate to effects. An ECoW or project ecologist would monitor sensitive receptors during delivery. Receptor specific management during, and monitoring after construction is described in Chapter 9 of the ES (Volume 5, Document 5.2) and the Biodiversity Mitigation Strategy (Document 5.4.3E).This requires pre-verification surveys before works in all areas where potential for protected species could result in a legal breach, monitoring of works in particular locations where determined by the location- specific pylon Method Statement, and management of specified habitats and receptors during and following construction. As well as the protection of retained hedge and woodland habitats, a scheme for the planting of trees, groups of trees, woodlands and hedgerows to replace those to be removed that accords with the Arboricultural Impact Assessment report (Document 5.4.3I) and the Biodiversity Mitigation Strategy (Document 5.4.3E) relevant to that stage of the project willsubmitted to and approved by the relevant planning authority as per Requirement 8 of the Draft DCO. Maintenance and decommissioning of the proposed 400kV route would also be subject to the same principles of pre-works ecological assessment and application of best practice and the prevailaing legislation as appropriate. These committments would be secured via relevant draft DCO requirements (notably 5(2)(b), 8, 9 and 10).

EPS licensing also applies in specified areas in agreement with NE, which through derogation licensing will secure enhancement, management and monitoring activities. In summary:

1. Bat boxes and translocated sections of tree (roosts) installed in Lynne and Kemberland Woodlands, as well as others identified through Sections A and B (on pylonmitigation figures) where a potential roost feature (PRF) would be lost. To be monitored once annually (during May to September) for 5 years from

15 Richborough Connection Project - Statement of Common Ground

SoCG ID Matter Agreed Position Date Agreed the time of installation. Management would include maintenance, cleaning or repair of the boxes as required ensuring they are useable. 2. Dormice: Temporary connectivity installed (dead- hedging) would be monitored through construction to ensure no loss of linkage. Post-construction population monitoring of nest boxes and nest tube transects would be conducted (50 boxes/tubes), over a period of three years (2019 through 2021, during April to November). A five year Habitat Maintenance and Management Plan would be implemented following (construction) works, 2019-2023 inclusive. (Management would include maintenance a minimum of once annually, cleaning or repair of the boxes as required ensuring they are useable for breeding; checking and repairing dead-hedging; checking log piles and supplementing with additional material as necessary). 3. Great crested newt exclusion fencing would be checked and repaired as required throughout the construction period. A five year Habitat Maintenance and Management Plan would be implemented immediately following (construction) works, 2018- 2022 inclusive. (Management would include: monitoring the condition of hibernacula and refugia piles and supplementing with additional materials as necessary, a minimum of once annually.)

16 Richborough Connection Project - Statement of Common Ground

4 MATTERS CURRENTLY OUTSTANDING 4.1 Summary of current position 4.1.1 Kent Wildlife Trust maintains an objection to the principle of the Richborough Connection Project, in relation to the choice of route corridor and its potential effects on bird disturbance and bird strike and other direct and indirect potential environmental impacts.

4.2 Kent Wildlife Trust specific matters currently outstanding 4.2.1 Kent Wildlife Trust’s matters currently outstanding are understood to relate to: • Route Corridor Study: Alternatives and position of route corridor in respect of effects on designated site ornithological interests. • Net gain for wildlife through additional enhancement along the route corridor, in accordance with the NPPF. 4.2.2 The matters currently outstanding are captured in Table 4.1 with the position of Kent Wildlife Trust and National Grid provided.

17 Richborough Connection Project - Statement of Common Ground

Table 4.1: Matters Currently Outstanding between National Grid and Kent Wildlife Trust

SoCG ID Matter Kent Wildlife Trust position National Grid Position

4.1 RCS

4.1.1 NGET’s selection of the Preferred the southern corridor option due to National Grid’s Consultation Feedback report considered all Northern Corridor and effects on concerns regarding the direct and indirect responses received to the RCS and as a result, the Northern SPA bird interest. negative impacts on biodiversity receptors in Corridor was selected on balance. It was assessed that respect of SPA designate species within overall it would result in the least likely environmental effects. Northern Corridor (Thanet Coast and Sandwich This selection was supported by RSPB and Natural England Bay SPA, Stodmarsh SPA, Ash Level and (NE). Throughout the consultation process, and following South Richborough Pasture LWS, Chislet consideration of Collision Risk modelling, NE maintain the Marshes, Sarre Penn and Preston Marshes view that the north corridor would result in lower effects than LWS). The northern corridor is closer to the the southern option. The Habitat Regulation Assessment: No Thanet Coast and Sandwich Bay SPA and significant effects report, NSER, has also concluded that no within the wetland habitats of Ash Levels and Likely Significant Effects would result on any International South Richborough Pasture LWS (DO21) and sites Volume 5, Document 5.5.) The NSER considered the Chislet Marshes, Sarre Penn and Preston SPA qualifying species and all supporting sites with Marshes LWS (CA56). These are supporting connectivity to the SPA (including the cited LWSs). NE’s sites for birds associated with the Thanet Coast position is that the detail of survey methods, results and and Sandwich Bay SPA. For this reason, a associated analysis is sufficient to satisfy the needs of the greater number of bird species and numbers of HRA and that all SPA qualifying interests are screened out individuals would be expected to be present in with the exception of three species, golden plover (qualifying these areas and therefore greater expected interest for Thanet Coast and Sandwich Bay SPA), hen potential negative impacts. harrier and gadwall (both qualifying species for Stodmarsh SPA). The assessment indicates that there would be low Kent Wildlife Trust remains concerned about (Golden plover) to very low (remaining bird receptors) the potential risk of collision for golden plovers impacts, and that no significant effect would result. NE has and does not agree that there would be no agreed with the assessment, and that no Likely Significant impact on golden plover populations. The Effects would result on any international sites. The definition results indicate that there will be a likely small of “Significant” in relation to collision has been as specifically impact upon this species. However, for a agreed with NE, Table 9.4 of Doc 5.2 “A 1% threshold of qualifying SPA species at a key supporting site significance has been adopted with respect to potential bird this is still a concern to Kent Wildlife Trust. As deaths against background mortality from the relevant this area is also designated as a Local Widllife population” and further clarified in Appendix B Doc 5.5 Site, this adds to our concern because the Trust NSER as “a 1% increase in baseline mortality.” Section 9.8 has a responsibility to highlight the need to (paragraphs 9.8.9-9.8.13) sets out the definitions of protect these sites of county importance and significance for the wider ecological assessment. their associated habitats and species.

4.2 Enhancement

18 Richborough Connection Project - Statement of Common Ground

SoCG ID Matter Kent Wildlife Trust position National Grid Position

4.2.1 LHES (Document 5.8) Kent Wildlfie Trust would like to see further In the BMS, Doc 5.4.3E, paragraph 1.1.3: The Landscape enhancements secured. and Habitat Enhancement Scheme (LHES) Volume 5, Document 5.8 sets out potential additional measures National Grid has identified to enhance biodiversity. National Grid cannot guarantee these measures because their implementation relies on landowners’ agreements. The measures outlined in the LHES are in addition to the embedded environmental measures (mitigation) that have been proposed in order to minimise significant environmental effects identified as a result of the Environmental Impact Assessment. These embedded measures are reported in the ES Doc 5.2 and Embedded Measures Schedule Doc 5.4.2B, and secured through a series of draft DCO Requirements within Schedule 3, Doc 2.1(A), including the BMS, Doc 5.4.3E, through draft DCO Requirement 5.

19 Richborough Connection Project - Statement of Common Ground

APPENDIX A – SIGNING SHEET

APPROVALS

Signed

On Behalf of National Grid Electricity Transmission Ltd

Name EMER MCDONNELL

Position SENIOR CONSENTS OFFICER

Date 07.07.2016

APPROVALS

Signed VANESSA EVANS BY EMAIL ON 08.07.16

On Behalf of Kent Wildlife Trust

Name VANESSA EVANS

Position PLANNING AND POLICY OFFICER

Date 08.07.16

20