PENTLAND HOMES & JARVIS HOMES
KINGSNORTH GREEN
ENVIRONMENTAL STATEMENT
June 2015 Wardell Armstrong Sir Henry Doulton House, Forge Lane, Etruria, Stoke-on-Trent, ST1 5BD, United Kingdom Telephone: +44 (0)845 111 7777 Facsimile: +44 (0)845 111 8888 www.wardell-armstrong.com
DATE ISSUED: June 2015 JOB NUMBER: ST13901 REPORT NUMBER : 001
PENTLAND HOMES & JARVIS HOMES
KINGSNORTH GREEN
ENVIRONMENTAL STATEMENT
June 2015
This report has been prepared by Wardell Armstrong LLP with all reasonable skill, care and diligence, within the terms of the Contract with the Client. The report is confidential to the Client and Wardell Armstrong LLP accepts no responsibility of whatever nature to third parties to whom this report may be made known.
No part of this document may be reproduced without the prior written approval of Wardell Armstrong LLP.
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PENTLAND HOMES & JARVIS HOMES Kingsnorth Green Environmental Statement
CONTENTS
VOLUME 1 – ENVIRONMENTAL STATEMENT, DRAWINGS AND APPENDICES 2.1 – 8.1
ENVIRONMENTAL STATEMENT 1 Introduction ...... 1 2 Approach and Scope of Environmental Assessment ...... 2 3 Description of the Site ...... 11 4 Description of the Development ...... 14 5 Alternatives ...... 17 6 Consultation ...... 21 7 Land Use and Soils ...... 25 8 Ground Conditions ...... 46 9 Water Resources ...... 73 10 Noise and Vibration ...... 92 11 Air Quality ...... 145 12 Ecology ...... 180 13 Landscape and Visual Impact ...... 225 14 Archaeology and Cultural Heritage ...... 259 15 Climate Change ...... 298 16 Residual and Cumulative Impacts ...... 310
DRAWINGS Drawing Name Drawing ST13901 -008 Site Location Plan Drawing 14007(sk)001 Rev N Illustrative Masterplan Drawing KNMP001 Original Masterplan Drawing 7.1 ALC Classification Drawing 9.1 Location of Discharge Consents Drawing 10.1 Noise Monitoring Locations Drawing 10.2 Noise Sensitive Receptor Locations Drawing 10.3 Noise Contour Plot – Baseline 2014 Drawing 10.4 Noise Contour Plo t – Without Development 2023 Drawing 10.5 Noise Contour Plo t – With Development 2023
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Drawing 10.6 Noise Contour Plo t – Difference between 2023 With Development and 2014 Baseline Drawing 10.7 Noise Contour Plot – Difference between 2023 With Development and 2023 Without Development
Drawing 10.8 Noise Contour Plo t – LAeq 16 hour Daytime Noise With Development 2023
Drawing 10.9 Noise Contour Plo t – LAeq 16 hour Night Time Noise With Development 2023 Drawing 11.1 Existing & Proposed Sensitive Receptor Locations (Air Quality) Drawing 13.1 Photoview Location Plan Drawing 14.1 Designated Heritage Assets Drawing 14.2 Non -Designated Heritage Assets Drawing 14.3 1839 Kingsnorth Tithe Map Drawing 14.4 Geophysical and Aerial Photography Anomalies
APPENDICES Appendix 2.1 Flood Risk Assessment Appendix 2.2 Glossary Appendix 3.1 Transport Assessment – Non-Technical Summary Appendix 3.2 Utilities Report Appendix 6.1 Stakeholder Workshop – Invitees and Attendees
VOLUME 2 – APPENDICES 9.1 – 14.4
APPENDICES Appendix 8.1 Envirocheck Report Appendix 9.1 Magnitude of Impacts and Sensitivity of Receptors (Water Resources) Appendix 10.1 Noise Monitoring Results Appendix 11.1 Traffic Flow Information Used in the Air Quality Assessment Appendix 11.2 2013 Wind Rose for Gatwick Airport Meteorological Recording Station Appendix 11.3 Model Verification Procedure Appendix 11.4 Air Quality Assessment Results Appendix 12.1 Ecological Appraisal completed by The Landscape Partnership (2013)
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Appendix 12.2 Arboricultural Report Appendix 12.3 Badger Survey Report Appendix 12.4 Bat Activity Survey Report Appendix 12.5 Breeding Bird Survey Report Appendix 12.6 Winter Bird Survey Report Appendix 12.7 Dormouse Surveys Appendix 12.8 Great Crested Newt Survey Report Appendix 12.9 Hedgerow Survey Appendix 12.10 Reptile Survey Report Appendix 12.11 Water Vole Survey Appendix 12.12 Policies Relevant to Ecology Appendix 12.13 Summary of Criteria for Nature Conservation Evaluation Appendix 12.14 Bat Roost Potential Report Appendix 13.1 Photoviews 1 – 26 Appendix 14.1 Heritage Assets Appendix 14.2 Impact Assessment Methodology Appendix 14.3 Geophysical Survey Appendix 14.4 Additional Geophysical Survey
VOLUME 3 – NON-TECHNICAL SUMMARY
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1 INTRODUCTION
1.1 Terms of Reference
1.1.1 This Environmental Statement (ES) has been prepared on behalf of Pentland Homes and Jarvis Homes in connection with an outline planning application for a residentially led mixed-use development on approximately 60.98 hectares (ha) of land south of Kingsnorth, Ashford. The development will be known as Kingsnorth Green.
1.1.2 The Kingsnorth Green application site is divided into four distinct parcels of land by Ashford Road, Bond Lane, and existing residential development: Area 1 to the north- west; Area 2 to the south-west; Area 3 in the centre; and Area 4 to the east.
1.1.3 The location of the site is shown on Drawing ST13901-008 and the indicative masterplan for the development is shown on Drawing 14007(sk)001 Rev N.
1.1.4 This ES reports the findings of an Environmental Impact Assessment (EIA) carried out in accordance with the criteria set out in the Town and Country Planning (Environmental Impact Assessment) Regulations 2011, in respect of the proposed residentially led mixed use development comprising up to 750 dwellings at Kingsnorth Green, Ashford.
1.1.5 The Planning Application for the proposed development is supported by this ES (and Non-Technical Summary) and by other documents, including the following:
• Design and Access Statement (Farrells)
• Planning Statement (Ian Bull Consultancy Ltd)
• Development Specification (Ian Bull Consultancy Ltd)
• Transport Assessment (Peter Brett Associates LLP)
• Statement of Community Involvement (Quantum PR)
• Five Year Housing Land Supply Study (Peter Brett Associates LLP)
• Illustrative Masterplan and Parameter Plans (Farrells)
• Sustainability Assessment (Wardell Armstrong LLP)
1.1.6 The outline planning application has been submitted to Ashford Borough Council (ABC) as the authority responsible for determining the application.
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2 APPROACH AND SCOPE OF ENVIRONMENTAL ASSESSMENT
2.1 Introduction
2.1.1 The statutory requirement for Environmental Impact Assessment (EIA) derives from “Directive 2011/92/EU of the European Parliament and the Council of 13 December 2011 on the assessment of the effects of certain public and private projects on the environment” (Directive 2011/92/EU). The Directive requires that EIA shall identify, describe and assess in accordance with Articles 4 to 12, the direct and indirect effects of a project on human beings, flora, fauna, soil, water, air, climate, the landscape, material assets, cultural heritage, and the interaction between these.
2.1.2 EIA is a decision making tool which identifies and assesses the significance of potential environmental impacts of proposed developments in an objective and systematic manner. This enables appropriate mitigation measures to be shaped and be incorporated within the design, in order to minimise impacts on the environment.
2.1.3 The Environmental Statement (ES) is the main communication tool for presenting the key findings of the EIA. It is intended to inform decision-making in the determination of the planning application.
2.1.4 This ES has been prepared in accordance with the requirements of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (‘2011 Regulations’) which translate the EIA Directive into UK planning legislation.
2.2 Planning Policy
2.2.1 In addition to the 2011 Regulations the main policy documents of relevance to this application include the National Planning Policy Framework (NPPF) at the national level; and those contained within Ashford’s Local Development Framework (LDF) at the local level.
2.2.2 The NPPF was published in March 2012, replacing all Planning Policy Statements (PPS) and Planning Policy Guidance (PPG). Local authorities are required to interpret and apply the NPPF policies locally. Consequently ABC are now preparing a new Local Plan which will guide development across the borough up to 2030, and replace the LDF. However as the new Local Plan has not yet been adopted, the documents within the LDF are still relevant to this application.
2.2.3 The key Development Plan Document (DPD) within the LDF is the Core Strategy, adopted in July 2008, which sets out the council’s vision and objectives for growth in
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the borough for the period between 2006 and 2021. The following policies within the Core Strategy are of relevance:
Policy CS1: Guiding Principles
This policy lists the key planning objectives which will be applied by the council when deciding planning applications. These objectives include minimising flood risk; protecting water supply and quality; protecting air quality standards; conserving and enhancing the historic environment and built heritage; protecting the countryside and landscape; enhancing biodiversity; and mitigating and adapting to climate change.
Policy CS5: Ashford Urban Extensions
This policy proposes major new development at Chilmington Green/Discovery Park and Cheesemans Green/Waterbrook, and states that a third area will be identified and formally adopted no later than 2014.
Policy CS10: Sustainable Design and Construction
All major developments must incorporate sustainable design features to help deliver the aim of zero carbon growth in Ashford.
Policy CS11: Biodiversity and Geological Conservation
Development proposals should avoid harm to biodiversity and geological conservation interests. Proposals should aim to “ maintain and, where practicable, enhance and expand biodiversity by restoring or creating suitable semi-natural habitats and ecological networks to sustain wildlife in accordance with the aims of the National and Kent Biodiversity Action Plans. If, exceptionally, there are circumstances in which other considerations justify permitting development that causes harm to such interests, appropriate mitigation or compensation measures will be required.”
Policy CS19: Development and Flood Risk
Development proposals within the 100 year undefended river floodplain (plus an appropriate allowance for climate change) will not be permitted unless it can be demonstrated that the development would not be at an unacceptable risk of flooding, and it would not result in increased flood risk elsewhere.
Policy CS20: Sustainable Drainage
All development should include appropriate sustainable drainage systems (SuDS) and aim to achieve a reduction in the pre-development runoff rate, or at least result in no
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net additional increase in runoff rates (dependent on the location of the proposals). SuDS should also be designed so as to enhance biodiversity and the landscape.
Policy CS21: Water Supply and Treatment
Development proposals must be able to demonstrate that there are, or will be, adequate water supply and wastewater treatment facilities in place. In addition, “Schemes that would be likely to result in a reduction in the quality or quantity of groundwater resources will not be permitted ” and “ The Council will support, in principle, infrastructure proposals designed to increase water supply and wastewater treatment capacity subject to there being no significant adverse environmental impacts and the minimisation of those that may remain .”
2.2.4 In addition to the Core Strategy, the LDF comprises a number of DPDs which are geographically specific. Relevant to this application is the Urban Sites and Infrastructure DPD, which contains the following relevant policy:
Policy U23: Landscape Character and Design
This policy states that development on the edge of the urban area shall be designed to complement and enhance the local landscape character, and existing important landscape features should be retained. It also lists factors which should be taken into consideration, including the composition and natural patterns of drainage; trees and woodlands; wildlife habitats; field boundaries; and historic landscape features.
2.2.5 The Ashford Borough Local Plan (2000) has now been largely superseded by the LDF. However there are a number of saved policies from the Local Plan (2000) which are relevant:
Policy GP12: Protecting the countryside and managing change
Development proposals should protect the countryside for its own sake, for its landscape and scenic value, and for the important wildlife habitats it contains.
Policy EN10: Development on the edge of existing settlements
New developments proposed on the settlement edge should respect the character of the settlement and provide an appropriate transition to the surrounding countryside.
Policy EN27: Landscape conservation
Important landscape and wildlife features should be protected or enhanced.
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Policy EN31: Important habitats
Development which is likely to have significant adverse impacts on important habitats will not be permitted unless mitigation measures are planned to reduce or remove these impacts.
Policy EN32: Important trees and woodland
Development will not permitted if it is likely to result in damage to or the loss of important trees or woodland.
2.3 Requirement for Environmental Impact Assessment
2.3.1 An EIA is statutorily required prior to ‘development consent’ being granted for any project which is likely to have significant effects on the environment. ‘Development consent’ is a term which includes the grant of planning permission.
2.3.2 Schedule 2 of the 2011 Regulations lists projects for which EIA is not mandatory, but may be appropriate, depending on the scale of the proposed project and the sensitivity of the site and its surroundings. Paragraph 10b ‘Urban development projects’ lists projects as Schedule 2 which have an overall development area of over 5ha; include more than 150 dwellings; or include more than 1ha of non-residential urban development. On this basis the applicant has considered it appropriate to carry out an EIA for the proposed development.
2.4 Specific Requirements of the EIA
2.4.1 The EIA Directive 2011/92/EU sets out specific requirements for the content of an ES, which have been translated under Schedule 4 of the 2011 Regulations for the UK.
2.4.2 The 2011 Regulations state the ES should provide a detailed description of the development during construction and operational phases. The ES must outline the main alternatives and indicate the main reasons for the choice of scheme, taking into account the environmental effects.
2.4.3 While every ES should provide a full factual description of a project’s effects, the emphasis of Schedule 4 is on the significant effects to which a project is likely to give rise. Other effects of little or no significance need only brief reference in the ES, to indicate that their relevance has been considered.
2.4.4 Schedule 4 of the ‘2011 Regulations’ provides a checklist, which should form the basis of an impact assessment, these include effects on:
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• Flora and fauna;
• Soil;
• Water;
• Air
• Climate;
• Material assets, including the architectural and archaeological heritage;
• The landscape; and
• The inter-relationship between the above.
2.4.5 The above checklist, the Stakeholder Workshop (see below), previous assessments undertaken at the site and the extensive experience Wardell Armstrong has in undertaking EIA for similar schemes has been used as a basis for identifying potential impacts of the assessment. Due to the size and scale of the proposals it was considered that all environmental issues would require consideration. As such, no topics were scoped out.
2.4.6 In the context of the development proposal and its potential environmental impacts, the following technical areas have been given consideration:
• Land Use and Soils;
• Ground Conditions;
• Water Resources (including Flood Risk and Drainage as Appendix 2.1);
• Noise;
• Air Quality;
• Ecology;
• Landscape and Visual Impact;
• Archaeology and Cultural Heritage; and
• Climate Change.
2.4.7 The option to request a scoping opinion from the planning authority is provided for under Part 4 of the 2011 Regulations. However, due to the size and scale of the proposals it was considered that all environmental issues would require consideration
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and as such, no topics were scoped out. Therefore, it was not considered necessary to request a scoping opinion from ABC.
2.4.8 Although a scoping opinion was not requested, many of the consultation bodies that would be contacted by ABC during the preparation of their scoping opinion were still contacted during the preparation of this ES. A Stakeholder Workshop was also held prior to the preparation of the ES, at which the key issues associated with the site were presented, and stakeholders were provided with the opportunity to request additional information be included in the scope of the ES. Both the Leader of Ashford Borough Council and Chief Planning Officer were invited to attend the workshop, but they both declined and advised that they considered the event to be premature and should not be held. However the applicant and the consultant team believed that the consultation process should begin as early as possible, to ensure key stakeholder responses could be taken into consideration during the EIA process and development design (see Chapter 6 for further details).
2.5 Structure of the Environmental Statement
2.5.1 The format of this ES conforms to the legislative requirement for EIA. This includes non-technical information such as a brief description of the local and surrounding area; a detailed discussion of the project development; the scheme alternatives; and details of consultation.
2.5.2 Technical information provides a detailed examination of the key environmental impacts associated with the development for each technical section of the ES. Where appropriate, consideration was given to positive and negative potential impacts; secondary and cumulative effects; and impacts in the short, medium and long term, including temporary and permanent effects. Mitigation measures have been formulated to address negative impacts and the residual impacts are assessed.
2.5.3 Each technical section of the ES has followed a generalised format, comprising:
• Introduction;
• Planning Policy Context;
• Methodology;
• Baseline Information;
• Impact Assessment;
• Mitigation Measures;
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• Residual Impacts; and,
• Conclusions.
2.5.4 The ES is accompanied by a Non-Technical Summary (NTS), a separate standalone document which provides a summary of the information contained in the ES. It details the significant effects of the proposed development, using non-technical language and appropriate illustrations.
2.5.5 A glossary of technical terms is included as an appendix to this ES (Appendix 2.2).
2.5.6 Baseline data was obtained from published information sources; non-confidential data supplied by the various organisations consulted; previous site work undertaken by others; and additional fieldwork specifically undertaken by Wardell Armstrong for this EIA.
2.5.7 Methodologies for predicting the nature, extent, magnitude and significance of environmental impacts vary according to the topic area being considered. The methodology for predicting impacts is set out at the beginning of each technical assessment chapter. Quantitative methods can make reference to thresholds and indicative criteria set out within government regulations and guidelines. Where quantitative criteria are not available, or not appropriate, qualitative methods have been adopted relying on previous experience and professional judgement.
2.5.8 The objective of prediction is to identify the magnitude and other dimensions of identified change in the environment with a project action in comparison without the same project or action. The assessment of significance gives context to the predicted impact and makes a judgement of the severity of the impact on a particular environmental receptor. Significance is generally a function of impact magnitude and the importance/sensitivity of the resources or receptors. Whilst the methods for determining impact significance can vary according to the topic area considered, the underlying principles remain consistent. The assessment of significance generally takes into consideration all or a combination of the following factors:
• Geographical extent;
• Rate of change;
• Reversibility of impact;
• Probability of impact;
• Duration of impact;
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• Size and magnitude of impact; and
• Sensitivity/importance/substitutability of receptor.
2.5.9 The criteria for the assessment of significance has been selected and applied in accordance with published guidance specific to the individual topic areas covered in the technical assessments. Such guidance represents the industry standard method for assessing potential impacts and is consistent with EIA best practice. The published guidance used in the undertaking of the assessments is referenced in each technical chapter. Where published guidance or criteria is not available the chosen method for assessing impacts and their significance is explained in detail to ensure transparency.
2.5.10 Where significant impacts have been identified, mitigation measures have been recommended to avoid, reduce or remedy such impacts. These have involved alterations to the basic design or operation of the development or the introduction of specific safeguards to ameliorate potential effects. The assessment methodology has therefore been used to refine the development proposals in an iterative process.
2.5.11 Assessment and mitigation of the key environmental issues have been used to reduce impacts to the lowest practicable level consistent with the overall objectives. Any residual effects, either during the construction or operational period or in the long- term, are also identified where appropriate and the significance of these residual impacts is assessed.
2.6 Cumulative Impact Assessment
2.6.1 Schedule 4 of the EIA Regulations states that an Environmental Statement must include a description of the likely significant effects of the development, including reference to possible cumulative effects.
Cumulative effects with other developments
2.6.2 The EIA has taken into account major development projects in the area of a similar size, scale and type which, in conjunction with the proposed Kingsnorth Green development, could collectively impose a significant impact on the environment.
2.6.3 Schemes to be taken into consideration in the assessment include those in the process of planning (either an application has been submitted and is awaiting a decision, or permission has been granted but construction is not complete). These were identified by consulting ABC’s online planning application search facility. Developments which
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are no longer in the process of planning (i.e. construction has been completed) are considered within the baseline.
2.6.4 The relevant schemes to be considered have been identified as:
• Chilmington Green;
• Park Farm; and
• Cheesemans Green.
2.6.5 The potential cumulative environmental effects of these developments with the proposed Kingsnorth Green development have been assessed in detail in this ES within the individual technical chapters, in accordance with best practice guidelines and procedures. A summary of the main conclusions is provided in Chapter 16.
Cumulative impacts on receptors
2.6.6 The cumulative impact assessment also has a second aspect. The EIA has taken into consideration where a significant residual impact is expected to occur on a particular receptor as a consequence of collective actions, aspects or effects of the proposed development. Chapter 16 summarises all residual impacts likely to be experienced for each type of receptor and assesses the significance of these cumulative effects. The receptors considered include: humans, flora/fauna, soils/land, air/climate, water, landscape, heritage assets, transport infrastructure, and socio-economic assets.
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3 DESCRIPTION OF THE SITE
3.1 Introduction
3.1.1 This Chapter of the ES provides an overview of the site location and a description of the site and the surrounding areas. It intends to give a general appreciation of the site setting. The technical assessments set out in Chapters 7 to 15, each contain a summary of the description of the site and a detailed description of the baseline environmental conditions of the site and its environs, relevant to the scope and nature of the topic area under consideration.
3.2 Site Location
3.2.1 The site is located south of Kingsnorth, on the southern edge of Ashford, Kent.
3.2.2 The development area is divided into four distinct parcels of land by Ashford Road, Bond Lane, and existing residential development: Area 1 to the north-west; Area 2 to the south-west; Area 3 in the centre; and Area 4 to the east.
3.2.3 Area 1 is bound by Pound Lane to the north and Ashford Road to the east; by the gardens of properties on Ashford Road to the south; and by agricultural land to the west. A gas pressure reducing station is located adjacent to the north-east corner of this area.
3.2.4 Area 2 is bound by Ashford Road to the east agricultural land to the south-east; Magpie Hall Road to the south; by agricultural land to the west; and the gardens of properties on Ashford Road to the north.
3.2.5 Area 3 is bound by Ashford Road to the west, agricultural land to the north and north- east; Bond Lane to the south-east; and properties on Steeds Close and Ashford Town Cricket Club to the south. A water tower is located adjacent to the eastern boundary.
3.2.6 Area 4 is bound by Steeds Lane to the south; Bond Lane and agricultural land to the east and north-east; Isaac Wood to the north-west; and agricultural land to the west.
3.2.7 The location of the site and its boundaries are shown on the Site Location Plan, Drawing ST13901-008.
3.3 Site Description
3.3.1 The site is approximately 60.98ha in size and divided into 4 sections as described above. The majority of the development area currently comprises arable land, which at the time of the surveys (Summer 2014) was predominantly oilseed rape.
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3.3.2 Area 1 comprised a single field of oilseed rape, with a small area of ruderal vegetation west of centre enclosed by the surrounding crop.
3.3.3 Area 2 comprised four fields. The northern field was oilseed rape. The southern three fields were semi-improved grassland with a small number of scattered individual trees, and three ponds close to the southern boundary.
3.3.4 Area 3 comprised six fields. The two small fields to the north and north-west comprised improved grassland. The adjacent field to the east and south of these two fields was oilseed rape, however in the south-eastern corner of this field there was an area of improved grassland and a pond; and a fenced area of improved grassland in the northern corner. The field to the east was wheat with small areas of improved and semi-improved grassland to the south-east. The remaining two fields to the south were oilseed rape, with a small section of semi-improved grassland in the south-west corner and two individual trees to the south-east.
3.3.5 Area 4 comprised six fields, the majority of which were oilseed rape. However there was a small paddock of improved grassland to the north-west. There were two ponds, one adjacent to the northern boundary and one to the south.
3.3.6 Field boundaries across the development area predominantly comprise semi- improved grassland, scrub, hedgerows and hedgerow trees with some fencing. The majority of the ponds are surrounded by semi-improved grassland and scrub.
3.3.7 The development area gently slopes up to a ridge which crosses the centre of the site in a west-east direction, with a high point within the north-east of Area 3.
Surrounding Land Use
3.3.8 The site is located south of Kingsnorth, which predominantly comprises low density linear development on Church Hill, Pound Lane and Ashford Road surrounded by agricultural land. Within Kingsnorth there are community facilities including a primary school, a pub and a village hall.
3.3.9 The site is located on the southern edge of Ashford and so to the north of the site development density increases. However it is still broken up by areas of agricultural land, particularly on the land surrounding the recent Park Farm development to the north-east of the site, and land adjacent to Romney Marsh Road. Park Farm is a residentially led development which includes a large supermarket and other community facilities such as a recreation centre.
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3.3.10 The density of development continues to increase towards the centre of Ashford, where the predominant land use changes from residential to commercial and industrial.
3.3.11 Ashford International is located approximately 3km north of the site in the centre of Ashford. The M20 is located approximately 4km north-east of the site on the opposite side of Ashford.
3.3.12 The remaining land outside of Ashford is predominantly agricultural, with large areas of woodland to the south of the site, and some low density linear development.
Vehicular and Pedestrian Access
3.3.13 At present there is no formal vehicular access through the site or from the site to surrounding properties. There are field gates into the site along the adjacent roads, which are used by farm vehicles to access the site.
3.3.14 The application area is traversed by a number of footpaths. The Greensand Way is a long distance footpath which crosses Areas 4 and 3 in a south-east to north direction. There is one further footpath in Area 4, and three further footpaths in the southern part of Area 3. There are no footpaths within Areas 1 or 2.
3.3.15 See Appendix 3.1 for a Non-Technical Summary of the full Transport Assessment carried out in support of this planning application.
Existing Public Utilities
3.3.16 Overhead power lines cross the south-west corner of Area 2 in a northerly direction.
3.3.17 A public sewer is located parallel to the western boundary of Area 3 for approximately 350m. A public sewer also crosses the eastern corner of Area 2 for approximately 30m.
3.3.18 See Appendix 3.2 for the full Utilities Report.
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4 DESCRIPTION OF THE DEVELOPMENT
4.1 Introduction
4.1.1 This section includes:
• A description of the proposed development;
• An indicative development timetable; and
• A summary of the design process.
4.2 The Development Proposals
4.2.1 The proposals are for a low density, residentially led mixed use development including green spaces and incorporating sustainable drainage systems (SuDS).
4.2.2 Outline application is being sought for a mixed use development comprising:
• Up to 750 dwellings in a mix of size, type and tenure.
• Up to 210 m sq. (gross internal floor space) of A1 – A5 uses, but with no individual units greater than 150 m sq.
• Up to 180 m sq. (gross internal floor space) of community/leisure uses of Classes D1 and D2.
• 1 form entry primary school.
• Provision of local recycling facilities.
• Provision of areas of formal and informal open space.
• Installation of utilities infrastructure to serve the development, including flood attenuation, surface water attenuation, water supply, waste water facilities, gas supply, electricity supply (including sub-station, telecommunications infrastructure and renewal energy).
• Transport infrastructure including a new access roundabout in the vicinity of the Ashford Road/Magpie Hall Road/Steeds Lane junction, new priority control junctions on Ashford Road, a new distributor road through the site to provide relief to the existing Ashford Road plus an internal network of roads and junctions, footpaths and cycle routes.
• New planting and landscaping both within the proposed development and on its boundaries as well as ecological enhancement/mitigation works.
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• Associated ground works.
4.3 Development Timetable
4.3.1 It is anticipated that subject to planning permission being granted by the end of 2015, construction of the development could commence towards the end of 2016 with the first dwellings completed in 2017.
4.3.2 It is estimated that the development of Kingsnorth Green could be completed within approximately 5 years, based on an average completion rate of between 150 and 200 dwellings per year. However this completion rate will be dependent on wider market factors and the number of house builders on site at one time.
4.4 Mitigation and Design
4.4.1 The EIA process and its accompanying consultation programme have served to shape and refine the Kingsnorth Green proposals by identifying any potential adverse effects, issues or constraints that could be effectively ‘designed out’ of the development proposals at an early stage. In this way the site design parameters have evolved in response to external and public feedback consultation and the results of technical assessments, and have undergone various iterations to incorporate measures to mitigate or simply avoid adverse environmental impacts, or enhance the environmental benefits of the scheme.
4.4.2 Consideration for the environment is an inherent aspect of any ‘sustainable’ development project. In this way the Kingsnorth Green proposals have been conceived and have evolved in a manner consistent with the principles of sustainable design. For full details please refer to the Sustainability Appraisal which accompanies this planning application.
4.4.3 Each technical chapter of this ES explains how identified adverse impacts will be avoided, reduced or compensated, with regards to ‘in-built’ measures pertaining to the site design; measures associated with operational methods and techniques; or specific strategies or action plans. These are also summarised in the final conclusions chapter of this ES.
4.4.4 Table 6.1 in Chapter 6 below sets out how the outcomes of public consultation and the extent to which these issues have been considered and have influenced the site design and development proposals.
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4.4.5 As far as possible, potential significant adverse environmental impacts have been ‘designed out’ of the scheme through the holistic, participatory and iterative EIA and site design processes, and through conformance with the over-arching principles of sustainable urban design. However measures have also been incorporated into the proposals to mitigate any impacts that cannot be adequately addressed through design. A crucial part of the EIA process is to assess the significance of the impacts following implementation of the proposed mitigation, otherwise known as ‘residual impacts’. Residual impacts are considered in the individual technical chapters and the summary and conclusions chapter of this ES.
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5 ALTERNATIVES
5.1 Introduction
5.1.1 The 2011 EIA Regulations advise that Environmental Statements should provide “ an outline of the main alternatives studied by the applicant or appellant and an indication of the main reasons for the choice made, taking into account the environmental effects”.
5.1.2 There are three key aspects which have informed the reasons for the choice of development proposed – planning policy; previous development proposals; and environmental considerations.
5.2 ‘Do Nothing’ Option
5.2.1 The first scenario to review in the consideration of alternatives is the ‘do nothing’ scenario. This scenario is to assume that the proposed development would not be built and allow the existing site to continue with its current use as agricultural land.
5.2.2 This option would eliminate the environmental impacts brought by the development but would not contribute to local policy within the LDF. Policy CS2 (The Borough Wide Strategy) within the Core Strategy sets out a housing target of 16,770 new units for the Ashford Growth Area, and 1,180 new units for the rest of the Borough. In addition, the Five Year Housing Land Supply Study carried out by Peter Brett Associates LLP for this application found that Ashford has a significant short fall in its five year housing land supply. Therefore developing this site would help to meet the five year housing land supply. Not developing it may result in increased pressure to develop less suitable, rural sites located outside of the Ashford Growth Area.
5.2.3 During the examination of the Core Strategy the Inspector stated state that a third urban extension should be identified and formally adopted no later than 2014. Notwithstanding the Inspectors conclusions and the requirement of adopted Policy CS5, the Local Authority have failed to carry out an early review of the Core Strategy and a third urban extension has not been identified or formally adopted by 2014, as required. Kingsnorth Green is ideally located in relation to the two existing urban extensions, and will allow improved transport links to be established. During the Examination the Inspector stated that Kingsnorth Green was “ the only area that I could recommend for inclusion whilst complying with the procedural tests of soundness ” (for full details please refer to the Planning Statement and Design and Access Statement which accompany this planning application).
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5.2.4 The proposed development also brings forward many positive social and economic contributions to Ashford, such as improved public transport and increased education provision. By not developing this site these valuable contributions to the sustainable development of the area will be lost.
5.2.5 The ‘do nothing’ alternative can therefore be discounted.
5.3 Alternative Site Locations
5.3.1 The identification, evaluation and testing of possible alternative options for housing growth and urban expansion is an essential part of spatial planning and is an integral part of the plan-making process at all levels of the planning hierarchy.
5.3.2 The land at Kingsnorth Green was identified as one of three urban extensions (alongside Chilmington Green and Cheesemans Green) within the Greater Ashford Development Framework, published in 2005. Ashford’s Local Development Framework Core Strategy did not propose an urban extension at Kingsnorth, although it did for Chilmington Green and Cheesemans Green. However following the Examination in Public in 2007 the Inspector concluded that there was “ no clear justification for the non-inclusion of a Kingsnorth expansion area ”, and, as stated above, Kingsnorth Green was “ the only area that I could recommend for inclusion whilst complying with the procedural tests of soundness ”.
5.3.3 The Kingsnorth Green site is well served by an existing high capacity highway network, and is ideally located to the south of the Park Farm development and to the east of Chilmington Green. This position enables a range of public transport improvements to be explored, which would not be possible if the proposed development was located to the north of Ashford.
5.3.4 The dual carriageway between Park Farm and the centre of Ashford provides access to key town centre services, including the Designer Outlet and the railway station, and it is currently underutilised. The development of Kingsnorth Green in combination with the existing Park Farm development would create sufficient capacity to support the introduction of a frequent bus service between the south of Ashford and the town centre. In addition, the location of the Kingsnorth Green site in relation to Chilmington Green creates the opportunity for a new public transport link to the south of Ashford to be established.
5.3.5 The scope for identifying alternative sites on the periphery of Ashford is limited, as much of the land is constrained by a range of environmental issues. As this ES will
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demonstrate, development of the proposed scheme at Kingsnorth Green would not result in any significant adverse impacts upon the environment. However, alternative land surrounding Ashford is affected by a number of issues including the following:
• Large areas of land to the north-west, north-east and south-west of Ashford are located within Flood Zones 2 and 3.
• The Kent Downs Area of Outstanding Natural Beauty (AONB) is located approximately 1km from the northern edge of Ashford, and there are long distance views from within the AONB across Ashford. Development around the north of Ashford could potentially adversely impact upon the AONB.
• Hatch Park, a Site of Special Scientific Interest (SSSI) and Grade II Registered Park and Garden, is located approximately 1.5km to the east of Ashford.
• Godinton Park, a Grade II* Registered Park and Garden, is located adjacent to the north-eastern edge of Ashford.
• Hoads Wood SSSI is located approximately 2km to the west of Ashford.
5.3.6 Therefore the most suitable location for development in terms of environmental impact is to the south of Ashford, where the two currently identified urban extensions are also located. This is also the most sustainable location in terms of improving the transport network.
5.3.7 Therefore the Kingsnorth Green site is considered to be the most suitable location for the proposals in terms of sustainability and environmental impact.
5.4 Alternative Site Design
5.4.1 The proposals for Kingsnorth Green have evolved as the result of an ongoing, iterative, design process, in which various design alternatives have emerged, been proposed and considered. The design specification has been influenced by factors such as planning policy requirements; environmental constraints identified through the EIA process; feedback from ABC interest groups, stakeholders and the general public as a result of an extensive programme of consultation and engagement.
5.4.2 See Drawing KNMP001 for the original illustrative masterplan. The proposal has subsequently been amended and improved through various iterations to reflect new information on site constraints and the design vision obtained from the constructive feedback received. The latest masterplan (Drawing 14007(sk)001 Rev N) provides a number of benefits over the original design, including the avoidance of significant
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impacts on ecology and areas of archaeological importance, and a reduction in flood risk. Therefore the current masterplan (Drawing 14007(sk)001 Rev N) is considered to be the alternative which would be most beneficial for the environment.
5.5 Conclusion
5.5.1 It is considered that the development proposals were conceived through a transparent and comprehensive assessment of the reasonable alternatives. There is a demonstrated need for additional housing to be developed in Ashford, and the Kingsnorth Green site is ideally located in terms of sustainability and limited environmental constraints. Options for the spatial distribution of housing growth to meet an identified need have been adequately assessed through the EIA process. Meanwhile the site design has evolved to take account of policy and environmental constraints and the views of stakeholders and the community.
5.5.2 It is concluded therefore that the proposed development constitutes the most sustainable alternative for growth to meet housing needs and objectives of the area, whilst minimising adverse impacts on the environment.
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6 CONSULTATION
6.1.1 The outline planning application submitted for Kingsnorth Green has been informed and guided by early discussions with the Council. Pre-application discussions have been held with Council officers and other stakeholders to review the draft planning application proposals.
6.1.2 To assist in the respective studies of baseline conditions, potential impacts and mitigation measures the following organisations/people were consulted:
• Wendy Rogers, County Archaeologist at Kent County Council, was consulted during the preparation of the ES.
• The Environmental Health Department at Ashford Borough Council were contacted regarding the noise assessment, however no response was received.
• The scope of the air quality assessment was decided in consultation with Richard Woodcock of the Environmental Health Department at Ashford Borough Council.
• The Environment Agency, the Lead Local Flood Authority (Kent County Council) and the River Stour Internal Drainage Board were contacted with regards to the Flood Risk Assessment.
• South East Water were consulted in the preparation of the Water Resources chapter and Utilities report.
• Southern Water were contacted to discuss network capacity in relation to foul water.
6.1.3 A Stakeholder Workshop was held at the Singleton Environment Centre on 17 th July 2014. The purpose of the workshop was to discuss the proposals for the site; inform key stakeholders of the potential planning, transport and environmental issues which had so far been identified; discuss the scope of the environmental assessment; and request feedback on any further issues they felt should be considered.
6.1.4 Invitations to attend were sent to 62 individuals and organisations by letters dated 17 th , 18 th and 21 st June. 39 responses were received, of which 28 provisionally accepted and 11 declined. 22 people attended the workshop (Please see Appendix 6.1 for full list of invitees and those that attended).
6.1.5 Both the Leader of Ashford Borough Council and Chief Planning Officer declined to attend and advised that they considered the event to be premature and should not be
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held. However the applicant and the consultant team believed that the consultation process should begin as early as possible, to ensure key stakeholder responses could be taken into consideration during the development design.
6.1.6 A Public Consultation Exhibition was held on the 12th March 2015 at Ashford Town Cricket Club, adjacent to the site.
6.1.7 The plans and the public exhibition were publicised through an advert in the local paper (the Kentish Express, circulation 12,764), a press release to local media, individual leaflets delivered to 251 residents neighbouring the site, a letter sent to 38 stakeholders, and through the website ( www.kingsnorthmasterplan.co.uk).
6.1.8 The exhibition was attended by 200 people and 56 feedback forms were completed. Feedback was received via questionnaire, telephone, post, email and discussion at the consultation.
6.1.9 The majority of concerns raised were in relation to traffic, which have been addressed within the Transport Assessment submitted as part of this planning application. However Table 6.1 below summarises the issues raised during the consultation process relevant to the environment, and how these have been considered within the EIA and have influenced the site design and development proposals.
Table 6.1 Response to issues raised during the consultation process Issues Raised Response The current risk of flooding to A Flood Risk Assessment and Drainage Strategy has been surrounding existing properties, prepared for the proposals (see Appendix 2.1). Measures potentially exacerbated by poor such as SuDS will be incorporated into the scheme, and any management of the existing retained drainage ditches within the control of the applicant drainage ditches within the site. will be appropriately managed. These measures will ensure that there is no increased risk of flooding to the site or the surrounding areas. Increased traffic resulting from The Air Quality and Noise assessments within this ES the proposed development. (Chapters 10 and 11) have assessed the indirect impacts of increased traffic on existing and future residents, and provided mitigation measures where appropriate. Retention and protection of The scheme has been designed ar ound the existing Public existing footpaths which cross Rights of Way to ensure their retention, and also includes the site. the creation of new footpaths and cycleways. Preservation of the archaeology A comprehensive assessment of the archaeological within the site. potential of the site has been carried out (see Chapter 14).
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This has included a review of aerial photographs and a geophysical survey, to identify the areas of the site most likely to contain archaeological remains of greater than low (local) importance. Following identification of these areas, the design of the scheme was revised to ensure minimal disturbance to them; these areas are now designated as green space. Impact on historical buildings. A comprehensive assessment of the impact of the proposals on the setting of heritage assets has been carried out, and mitigation measures are provide where necessary (see Chapter 14 for full details). Impact on existing habitats and An ecological survey has been undertaken of the site, and wildlife within the site. subsequently a large number of specialist species surveys were undertaken. The results of these surveys informed the design of the scheme, which was revised in order to leave the most ecologically important areas of the site undeveloped. Species specific mitigation measures have also been put forward, and new habitats will be created outside the site, on land within the applicant’s control. For full details please refer to Chapter 12. Impact on views and A Landscape and Visual Impact Assessment has been carried countryside. out to assess the impact of the proposals on views and the landscape. Mitigation measures including landscaping, green space and additional planting have been incorporated into the scheme and considered within the assessment. A buffer has been created between the proposed scheme and Kingsnorth. Drainage and sewage issues. A drainage strategy has been produced which details how foul and surface water will be managed (see Appendix 2.1 and Chapter 9 for full details). In addition to this, discussions were held with Southern Water on the possibility of submitting an early Section 98 application in order to ensure there is sufficient capacity at the wastewater treatment works. However Southern Water advised that a Section 98 application should not be submitted at such an early stage of planning (Section 98 applications are not usually submitted until after an outline planning application has been approved).
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Potential increased usage of a A new footpath was incorporated within the design of the footpath crossing the land of an scheme, which will provide access to the footpath network adjacent property. within the site and potentially discourage use of the footpath located within the neighbouring resident’s land.
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7 LAND USE AND SOILS
7.1 Introduction
7.1.1 This chapter of the ES assesses the likely significant effects of the development on the environment in terms of soil resources and agricultural land capability across the site, and incorporates soil survey information. In particular, the assessment considers the quality of agricultural land and the loss/damage to soil resources, and potential effects on local agricultural businesses within the site.
7.1.2 This chapter describes: the assessment methodology, the baseline conditions at the site and surroundings; the likely significant environmental effects; the mitigation measures required to prevent, reduce or offset any significant adverse effects; and the likely residual effects after these measures have been employed.
Definitions
7.1.3 The ‘Agricultural Land Classification of England and Wales: Revised guidelines and criteria for grading the quality of agricultural land’ (MAFF, 1988) (ALC) is a standardised method for classifying agricultural land according to its versatility, productivity and workability, based upon inter-related parameters including climate, relief, soil characteristics (texture, structure, depth etc.) and drainage. These factors form the basis for classifying agricultural land into one of five Grades (with Grade 3 land divided into Subgrades 3a and 3b) on the basis of its potential productivity and cropping flexibility.
7.1.4 The term ‘best and most versatile’ (BMV) agricultural land is used to define agricultural land of ALC Grades 1 (excellent quality), 2 (very good quality) and Subgrade 3a (good quality). BMV land is afforded a degree of protection against development within planning policy, for example within the National Planning Policy Framework (Department for Communities and Local Government, 2012). Moderate, poor and very poor quality land is designated Subgrade 3b or Grades 4 and 5 respectively, and is restricted to a narrower range of agricultural uses.
7.1.5 Gleying is the process of iron reduction (opposite to oxidation) in soils from ferric (reddish in colour) to ferrous compounds (grey or colourless), by microorganisms or by-products of decomposing organic matter. Gleying occurs in areas devoid of oxygen when the soil is waterlogged. The resulting mottling (spots or blotches of colour) can therefore be used to identify occurrence of temporary excessive soil wetness / waterloging.
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7.2 Assessment Approach
7.2.1 Baseline characteristics of the soil resource, agricultural productivity and land use at the site are assessed using published information sources and data collected during a soil survey. Aspects of agricultural and soil characteristics are considered including climate, topography, drainage, depth of soil resources and soil qualities, such as texture.
Methodology
Desk study
7.2.2 Information regarding the soils and ALC of the site was obtained from the following sources:
• Soils and their use in South East England (Soil Survey of England and Wales, 1984) and accompanying 1:250,000 South East England Sheet;
• Agricultural Land Classification of England and Wales: Revised guidelines and criteria for grading the quality of agricultural land (MAFF, 1988);
• Climatological Data for Agricultural Land Classification: Gridpoint datasets of climatic variables at 5km intervals for England and Wales (Met. Office, 1988); and
• 1:250,000 Provisional Agricultural Land Classification Sheet, South East England (MAFF 1984).
Site Survey
7.2.3 Soil profile characteristics were investigated across the site in August and November 2014 using a hand-held Edelman Auger capable of sampling to a depth of 120cm. Samples were taken at a density of 1 per hectare, which allows accurate assessment of the agricultural land classification of the site. Sample frequency was increased where geomorphological, biological, or land use features indicated a likely change in soil type.
7.2.4 Following this the soil profile characteristics were used to determine the Agricultural Land Classification (ALC) grade of the land across the site, to establish whether it is classified as best and most versatile agricultural land.
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Impact Assessment
7.2.5 Following the determination of the ALC grade(s) of the land within the surveyed areas, the effect of the development on the soil resource, drainage, and agricultural land is assessed and the significance established. This is determined using the following criteria:
Sensitivity of Receptors
7.2.6 The sensitivity of the baseline environment is set out in Table 7.1. The criteria relates to areas of agricultural land quality, and agricultural drainage.
Table 7.1 Sensitivity of Receptors Receptor Sensitivity Justification Soils and Agricultural land Best and most versatile soils and Land capable of producing a very wide range to a High agricultural land (ALC Grades 1, 2 and 3a) moderate range of crops. Moderate quality soils and agricultural Medium Land capable of producing a range of crops. land (ALC Grade 3b) Land capable of producing a narrow range of crops Lower quality soils and agricultural land Low or suited to use as improved grassland and rough (ALC Grade 4 and lower) grazing. Agricultural drainage Agricultural drainage (e.g. a field drain system) Agricultural drainage systems Medium controlling soil water level for crop production. Magnitude of change
7.2.7 For agricultural land, the guideline criteria for determining the magnitude of change from the baseline (pre-development) condition are based on a threshold of the loss of 20 ha of BMV agricultural land, which is taken from Natural England Technical Information Note TIN049 and referenced in the NPPF. In the absence of specific and documented guidance relating to the determination of the magnitude of change from baseline conditions in relation to the soil resource and drainage, other criteria are based on professional experience. The criteria have been adopted in other assessments that have previously been agreed and accepted as best practice, and are based upon permanent / irreversible changes and long term/ short term / temporary changes to the soil resource and drainage arising as a result of the proposed development.
7.2.8 The magnitude of change has been defined for agricultural land by reference to Table 7.2.
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Table 7.2 Magnitude of change of the development on Agricultural Land – based on Agricultural Land Classification
Magnitude Guideline criteria for potential impact on ALC High >20ha of BMV land (ALC Grade 1, 2 or 3a) permanently developed for non-agricultural use. Medium >20ha of BMV land (ALC Grade 1, 2 or 3a) temporarily in non-agricultural use. Low >20 ha of non-BMV land (ALC grade 3b, 4 or 5) developed for non-agricultural use Basis of assessment 1. A 20ha for loss of best and most versatile agricultural land threshold follows the approach of Statutory Instrument 2010 No. 2184, The Town and Country Planning (Development Management Procedure) Order 2010, Schedule 5. This stipulates that the Secretary of State for the Environment Food and Rural Affairs should be consulted before the grant of permission. 2. Natural England Technical Information Note TIN049; Second edition, 19 December 2012.
7.2.9 The magnitude of change has been defined for the soil resource by reference to Table 7.3.
Table 7.3 Magnitude of change to Soil Resources
Scale of Impact Damage to soil resource Loss of soil resource Very high Permanent irreversible damage to soil resource quality <25% of soil resources retained on through handling, stockpiling etc. site High Long term temporary / reversible damage to soil resource 25-50% of soil resources retained on quality through handling, stockpiling etc. site Medium Moderate term temporary / reversible damage to soil >50% of soil resources retained on resource quality through handling, stockpiling etc. site Low Short term, reversible damage or disruption to soil >50% of soil resources retained on resource quality through handling, stockpiling etc. site Negligible No damage or disruption to soil resource quality All soil resources retained on site Criteria based on professional experience
7.2.10 The assessment criteria selected to determine the magnitude of change of the development upon agricultural drainage (both on site and off site) are summarised in Table 7.4, based upon permanent/irreversible changes and long term/short term/temporary changes to agricultural drainage arising as a result of the proposal.
Table 7.4 Magnitude of change of the development on agricultural drainage
Magnitude Disruption to agricultural drainage High Permanent (irreversible) disruption to off-site drainage Medium Long term (reversible) disruption to off-site drainage Low Short term, reversible disruption to off-site drainage Negligible Little or no change or disruption to off-site drainage. Criteria based on professional experience
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Significance Criteria
7.2.11 The significance of effects is determined in relation to the sensitivity of the baseline resource and magnitude of change from the baseline condition, using the matrix shown in Table 7.5.
Table 7.5 Significance of effect
Sensitivity Magnitude High Medium Low None Very high / High Major Major Moderate Minor Medium Major Moderate Minor Minor Low Moderate Minor Minor Negligible / none Negligible Minor Minor Negligible / none Negligible / none
7.2.12 Within the matrix (Table 7.5) the impacts that are defined as major and moderate are considered result in a significant effect.
Mitigation
7.2.13 Upon determining the likely significance of the impacts associated with the proposed development, mitigation measures are proposed to minimise the effects and consequently the significance of these impacts. Residual impacts are identified and cumulative effects assessed.
7.3 Policy Framework
European level
Environmental Impact Assessment Directive
7.3.1 The EIA Directive identifies the types of project for which an EIA is required to be undertaken in order to identify, describe, and assess the direct and indirect effects of such a project on different receptors.
7.3.2 Article 3b identifies the soil as a receptor, whilst Article 3d states it is to be considered alongside its interactions with the other receptors identified in Article 3a-c. This ensures sustainable management of natural resources, including soil and agricultural land.
Seventh Environment Action Programme
7.3.3 The European Union’s Soils Thematic Strategy (COM (2006) 231) was adopted in 2006, with the objective of protecting soils across the European Union (EU). This was followed by the proposed Soils Framework Directive (COM (2006) 232) which set out the principles for soil protection through a comprehensive Thematic Strategy. The
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proposed Soils Framework Directive was never formally adopted and was withdrawn by the European Commission in May 2014.
7.3.4 However, the Seventh Environment Action Programme (EAP) 1 was adopted in November 2013. The 7th EAP sets out nine priority objectives and will guide European environment policy until 2020. Additionally, in order to give more long-term direction, the EAP also sets out a vision for 2050. The EAP recognises that soil degradation is a serious challenge and requires that all land within the Union is managed sustainably by 2020, that soils are adequately protected. The EAP commits the EU and its Member States to increasing efforts to reduce soil erosion, increase soil organic matter and to remediate contaminated sites.
National level
National Planning Policy Framework
7.3.5 Paragraphs 111 and 112 of The National Planning Policy Framework (NPPF), 2012 promote the sustainable management and protection of soils and agricultural land consistent with the economic, social and environmental needs of England. These paragraphs state:
“Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.
Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development on agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.”
7.3.6 Consequently, impacts to the soil resource and best and most versatile (BMV) agricultural land are to be considered and the resource protected against development, where their importance overrides the economic benefits of the development itself.
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Soil Strategy for England
7.3.7 The National Strategy for England; Safeguarding our Soils (DEFRA, 2009), provides a long-term guide to direct policy regarding the protection of soils in England. The strategy highlights the importance of the protection of soils, especially in agricultural landscapes and during development. Protecting soils ensures the protection of their related ecosystem services, the mitigation of climate change, and prevention of contamination.
7.3.8 In particular, Chapter 1 of this document ensures soils are sustainably managed and degradation threats are successfully dealt with, whilst Chapter 2 puts this into the context of agricultural landscapes. Chapter 6 ensures effective soil protection during development and construction, with a focus on the protection of soil-related ecosystem services. Furthermore, in response to this DEFRA has constructed a series of best practice guidelines for the handling and storage of soil resources during development, which are referred to later within this ES chapter.
Local level
Ashford Borough Local Plan
7.3.9 The Local Plan for Ashford Borough has largely been superseded by the Local Development Framework, however, selected polices have been saved until the framework can be fully adopted.
7.3.10 Ashford Borough Council adopted the Local Development Plan in 2000. Policy RE8; Protection of Agricultural Land, was not saved, however, it is still used informally to guide planning policy as it remains in line with the NPPF. This states that:
“Proposals which will result in the permanent loss of the best and most versatile agricultural land (Grades 1, 2 and 3a as defined in MAFF’s Agricultural Land Classification) will not be permitted other than those shown on the Proposals Map.”
7.3.11 This is particularly relevant in the Borough as the majority of land is identified as best and most versatile and is therefore essential to the nation’s future agricultural production.
Emerging policy
7.3.12 The emerging Local Development Framework Core Strategy (adopted in 2008) is being reviewed to become the new Ashford Local Plan, which will set out the objectives for
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Ashford Borough until 2030. The protection of agricultural land is not specifically mentioned, however Policy CS1; Guiding Principles, states that sustainable development is a key planning objective which will be implemented through:
“…C. Protection for the countryside, landscape and villages from adverse impacts of growth and the promotion of strong rural communities…
…F. The best use of previously developed land and buildings to help regenerate urban areas and the carefully phased release of green field land to make best use of a finite resource…”
7.3.13 These key planning objectives ensure that development within the Borough is sustainable and in line with national planning policy.
7.3.14 Furthermore, the Core Strategy Sustainability Report states in paragraph 5.4.12 that more consideration needs to be given to promote local agriculture, with particular reference to fringe farming around the borough’s urban centres, which is reiterated in Objective 9.1. Objectives 2.4 and 2.5 state the need to promote the protection of soil and agriculture within the borough, instead of its loss to development.
7.4 Baseline
Desk Study
Soils
7.4.1 The entire site is characterised by soils belonging to the 711e Wickham 1 soil association.
7.4.2 The underlying geology of this association is described as drift over Cretaceous clay or mudstone. Soils are fine silty, or fine loamy over clay. They are characteristically seasonally waterlogged, with extensive mottling and gleying. Underlying clay subsoils have a shrink-swell characteristic causing them to extensively crack when dry, and being significantly waterlogged when wet.
7.4.3 Figure 7.1 displays a typical profile of the Wickham 1 soil association.
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Figure 7.1 Typical profile of the Wickham 1 soil association
7.4.4 The soil’s weak structured topsoils can become heavily eroded on sloping land, both during the summer during heavy rainfall and when the soils are suffering from droughtiness, and in the winter when the soils are saturated causing rapid runoff.
7.4.5 Consequently, due to their seasonal waterlogging, and droughtiness nature, cultivation of the land can be quite difficult. Typical land uses include permanent grassland, ley and winter cereals, with the grassland often being used for grazing sheep and cattle. Extensive amounts of woodland are also found on this soil association, with a large portion of ancient woodland found in the south east.
Agricultural Land Classification
7.4.6 The Provisional 1:250,000 Agricultural Land Classification Sheet (MAFF 1984) indicates the land at the proposed site, is classed as ALC grade 3 (potentially best and most versatile, moderate to good quality agricultural land). The scale of this survey cannot be used to distinguish between subgrades and cannot be used to identify the ALC grade of the land at the field level. Between 1989 and 1999, some areas of England and Wales were surveyed at the field level by the Ministry of Agriculture Fisheries and Food (MAFF, now Defra), allowing a detailed assessment of the ALC for these areas to be undertaken. These are collectively known as post-1988 ALC surveys and are considered to be the most detailed and up to data dataset. However, post-1988 survey data are not available for the proposed site and consequently, a detailed soil survey was required to establish this information.
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Drainage
7.4.7 The site is characterised by gently undulating land, with the topographic high (approximately 49m AOD) in the south-east of the site, and the lowest topographies (approximately 38m AOD) in the north-west. Consequently, surface water naturally drains towards these topographic lows.
7.5 Site Survey
7.5.1 Site surveys were undertaken in August and November 2014 using a sample density of 1 soil profile inspection per hectare, using a standard Ordnance Survey 100m grid, although sample frequency was increased where geomorphological, biological, or land use features indicated a likely change in soil type.
7.5.2 The soil surveys confirmed the presence of the Wickham 1 soil association across the site, as discussed below.
Soils
7.5.3 The site survey generally confirmed the results of the desk study.
7.5.4 Topsoil was found to be clay loam or silty clay loam with a moderate to dense structure, and depths up to 30cm. Most topsoils were slightly mottled at 20cm depth and in some cases had a surface cover of green algae, indicating persistent waterlogging. Furthermore most topsoils had extensive mud cracking, indicating droughtiness to be an issue, owing to the soils high clay content. The clay fraction in the soil shrinks and swells with water availability, therefore if there is a particularly dry period extensive shrinking can occur leading to mud cracks.
7.5.5 Subsoil was found to be of a silty clay loam, clay loam, or clay texture. The clay fraction of the soil increased with depth. Upper subsoil was found to be of a moderate subangular blocky structure, with depths up to 25cm and extensive mottling. In most auger points, lower subsoil was found to have 2 distinct horizons. The first having a moderate to dense angular blocky structure with depths up to 25cm, and the second having a dense prismatic or massive structure with depths up to 50cm. Both horizons of the lower subsoil were extensively gleyed owing to waterlogging at depth. In Area 3, soil did not follow that of the desk study, with some augers showing weakly structured lower subsoil with large amounts of coal and stones. This horizon was sticky to touch, and in some cases the coal extended into the base of the upper subsoil. A horizon like this can usually be attributed to historic mining activity however a study of historic maps does not indicate a previous land use of the site other than
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agricultural. Consequently, this horizon could be attributed to the scattered superficial river terrace deposits on the site, in which rivers deposited gravels and detrital material with silt, clay and peat.
Drainage
7.5.6 Numerous ponds were dotted over the site, generally coinciding with river terrace deposits and topographic lows. The site was generally flat or gently sloping with surface water runoff towards the topographic lows in the centre of the site and in the north-west.
Agricultural Land Classification
7.5.7 The Provisional 1:250,000 Agricultural Land Classification Sheet (MAFF 1984) indicates the land at the site, is classed as ALC grade 3 (potentially best and most versatile, moderate to good quality agricultural land).
7.5.8 To distinguish between subgrades at the field-scale a soil survey was undertaken and the results used to calculate the ALC across the site.
Agroclimatic data
7.5.9 The agroclimatic data of a site influences the Agricultural Land Classification (ALC) in respect of growing conditions, and the soil reaction in terms of wetness and droughtiness. The Meteorological Office publishes agroclimatic data for England and Wales on a five kilometre grid basis, from which the definitive ALC grade can be calculated for each development after site surveying has been completed.
7.5.10 The interpolated agroclimatic data for the site is detailed in Table 7.6.
Table 7.6 Interpolated agroclimatic data for the proposed Kingsnorth Green site
TR 00044 38981 Average annual Rainfall (mm) 732 Accumulated Temperature ( oC) 1460 Field Capacity Duration (days) 152 Moisture Deficit Wheat (mm) 121 Moisture Deficit Potatoes (mm) 117
7.5.11 Table 7.6 highlights that the site has an average annual rainfall of 732mm, with an accumulated temperature of 1460°C. This equates to 152 days per annum in which the soil is at field capacity.
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ALC results
7.5.12 The soil survey and associated ALC calculations identified 20.3ha of Subgrade 3b (BMV) and 40.5ha of Subgrade 3b (non-BMV) agricultural land within the site (Drawing 7.1). Only the loss of BMV land is considered within planning policy. ALC grading across the site was limited by soil wetness. The remaining site area comprises non- agricultural land, urban land, woodland and waterbodies; as identified in Drawing 7.1.
Climate, site and soil limitations
7.5.13 The combination of average annual rainfall and accumulated temperature (722mm and 1460°C respectively, see Table 7.6) indicates that climate is not a limiting factor to ALC grade.
7.5.14 Gradient has a significant effect on mechanised farm operations since most conventional agricultural machinery performs best on level ground. The safe and efficient use of machinery on sloping land depends very much on the type and design of the machine and on the nature of the slope being farmed. The gradient over the site does not exhibit slopes likely to restrict agricultural machinery (more than 7°); therefore ALC grade is not limited by gradient.
7.5.15 Soil depth affects the range and type of crops able to be cultivated as it affects nutrient uptake, crop available water, root growth and anchorage. Soil depths consistently exceeded 60 cm across the site. Consequently soil depth is not considered to be a limiting factor anywhere on site.
7.5.16 Stones act as an impediment to cultivation, harvesting and crop growth through mechanical wear and tear of farm machinery. Furthermore they can cause a reduction in a soils available water capacity, depending upon the quantity, size, shape and hardness of the stones. All soils were found to be stoneless or slightly stony, however, this was not found to be a limiting factor to ALC grade.
Interactive limits
7.5.17 The physical limitations resulting from the interactions between climate, site and soil characteristics are soil wetness and droughtiness. Soil wetness limitations adversely affect plant growth or agricultural management (e.g. grazing, machine operation, poaching by livestock, smearing by machinery). For ALC purposes the soil wetness assessment takes account of:
• Climatic regime (duration of field capacity = 152 days);
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• Soil water regime based on soil profile characteristics (Wetness Class III and IV depending on soil texture and structure); and
• Texture of the top 25cm of the soil profile (clay loam or silty clay loam).
7.5.18 Based on the criteria identified above, the agricultural land within the site is identified as ALC grade 3a and 3b, limited by wetness.
7.5.19 Droughtiness is most likely to be a significant limitation to crop growth in areas with high evapotranspiration, or where the soil profile holds only small reserves of moisture. Droughtiness was only found to limit the ALC to grade 2 in the centre of the site. This was seen through extensive mud cracking and is due to the soils relatively high clay content. Elsewhere it was not found to limit the ALC grade.
Summary
7.5.20 Overall this indicates that the soils across the site are limited by wetness interactions, owing to the soils high clay content and slowly permeable subsoils.
7.6 Key Impacts and Likely Significant Effects
7.6.1 Agricultural land and the associated soil resource is considered in relation to the site masterplan (Drawing 14007(sk)001 Rev N), and therefore is subdivided into that which would be directly disturbed through construction of the built development (which would require soil stripping, storage, ground works, vehicle movements and infrastructure construction); and that which would not be subject to development and in which the soil profile would be left in situ for the land to be used for non-agricultural soft uses (such as green space, flood prevention zones, woodland landscape areas).
7.6.2 Table 7.7 highlights the likely impacts of the proposed development in the absence of mitigation measures, beyond those incorporated into the masterplan.
Table 7.7 Summary of key impacts and likely significant effects associated with the proposed development – prior to mitigation
Impact identified Construction operations Sensitivity Magnitude Significance Construction phase Permanent loss of less Construction of buildings and HIGH LOW MINOR than 20ha BMV land to infrastructure ADVERSE (Not agricultural use through significant) built development. Loss or damage to soil • Soil stripping, handling and HIGH VERY HIGH MAJOR resources directly storage; ADVERSE impacted by development • Levelling ground; (Significant) • Vehicle movements on site; • Landscaping operations
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Table 7.7 Summary of key impacts and likely significant effects associated with the proposed development – prior to mitigation
Impact identified Construction operations Sensitivity Magnitude Significance Construction phase Disruption/severance to • Soil stripping, handling and MEDIUM MODERATE MODERATE agricultural drainage storage; ADVERSE • Vehicle movements on and off (Significant) site; • Landscaping operations. Operational phase None identified
Construction phase
7.6.3 The activities of the construction phase which may have an impact upon soils and agricultural land quality include:
• Pre-construction earthworks, which may have an impact upon soils and agricultural land, such as:
o Stripping and stockpiling of topsoil and subsoil.
o Ground excavation.
o Stockpiling materials.
o Levelling ground.
o Trenching.
o Road construction
o Vehicle movements on site.
• Construction which would involve the creation of individual buildings, access roads, and car parking areas.
Agricultural Land
7.6.4 The surveys identified 20.3ha of BMV (Subgrade 3a) within the proposed development. All of this land would be lost to agricultural use due to the proposed development, however the nature of this loss would be either permanent or temporary depending upon the final land use as identified in the site masterplan (Drawing 14007(sk)001 Rev N). Land subject to built development would be permanently lost to agriculture; however the areas identified as being for non- agricultural soft uses (green space, flood prevention zones etc .) would retain the potential to be returned to agricultural use in the future and hence the loss is
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considered temporary. Therefore less than 20ha of BMV of agricultural land (the threshold of loss identified in the NPPF) would be permanently lost due to development.
7.6.5 Using the criteria in Table 7.1, the presence of BMV land results in the sensitivity of the agricultural land within the proposed development being classed as high. However, as the area of permanent loss would be less than 20ha, the magnitude of change is considered to be low (Table 7.2). The scale of impact on agricultural land is therefore considered to be minor adverse leading to a non-significant effect (Table 7.5.
Soil resource
Direct disturbance
7.6.6 In areas of the masterplan identified as being subject to built development (buildings and infrastructure), the soil resource would be directly disturbed.
7.6.7 Using the criteria in Table 7.1, the presence of BMV land results in the sensitivity of the soil resource within the proposed development being classed as high. In the absence of appropriate mitigation measures, there is the potential for permanent irreversible damage to soil resource quality through handling, stockpiling etc., and the removal of the soil resource from site. This would constitute a very high magnitude of change to the baseline (Table 7.3). Therefore in the absence of appropriate mitigation the impact to the directly impacted soil resource would be considered major adverse leading to a significant effect.
Intact soils
7.6.8 Soil profiles which would be left intact for non-agricultural soft land uses would not be subject to the construction activities associated with built development, such as soil stripping, handling and stockpiling. However, they may still experience low intensity ground works such as landscaping, planting and trafficking by vehicles, to establish the conditions necessary for their change in land use. Any impacts on the soils resource due to these low intensity works are considered to be localised, very short-term and reversible; and therefore considered to be negligible leading to no significant effect.
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Agricultural drainage
7.6.9 The construction phase of the development may result in on-site and off-site impacts to agricultural drainage if existing drainage systems are not properly identified or rerouted. These systems are identified as being of medium sensitivity (Table 7.4), with the magnitude of change considered to be moderate as the impact would be of a temporary, medium duration and only relevant to eastern areas of the site where the proposed development lies adjacent to agricultural fields. Consequently, this results in a moderate adverse impact pre-mitigation, which is considered significant.
Operational phase
7.6.10 No impacts associated with the operational phase of the development are identified.
7.7 Mitigation and Residual Effects
Mitigation
7.7.1 Appropriate mitigation measures are recommended to reduce, prevent or control potential negative impacts of the proposed development upon soils and land use.
Construction phase
Agricultural land
7.7.2 The proposed development would result in the permanent removal of less than 20ha of Subgrade 3a (BMV) land from agricultural use. This loss cannot be fully mitigated. However, the site design is such that areas of BMV land (included within the green spaces identified within the masterplan) would retain the potential to be returned to productive agricultural use in the future.
Soil resource
7.7.3 There would be negligible impact to the soil resources within the areas identified within the site masterplan as green space, flood protection zones etc . Therefore only the soils within the development areas would be subject to disturbance and potential impact and require mitigation.
7.7.4 The majority of the disturbed soil resource would be retained on site for later use (such as in landscaping operations and the creation of soft-use recreation areas). Soil resources that cannot be reused on site would be put to beneficial use elsewhere in the locale. Therefore the loss of soil resource is considered temporary.
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7.7.5 The stripping, temporary stockpiling and reuse of topsoil resources has the potential to damage soil in terms of its structure, nutrient content and soil organism activity if not carried out in an appropriate manner. Disturbed soil resources would be protected against damage during these operations by adoption of appropriate up to date guidance measures. The current DEFRA guidelines for typical working methods and techniques used to protect topsoil resources include the following:
• The handling of soil resources only when sufficiently dry, generally limiting soil operations to the months April to September (although this period may be extended during dry periods). This is especially important given the waterlogged nature of the soils on site.
• The stripping, handling and storage of topsoil separately from subsoil movements.
• Subsoil only to be stored on areas striped of top soil. • Separate storage of soils of different types and/or quality. • Use of clearly defined haul roads and storage areas. • Appropriate seeding of soil storage mounds required on site for a period longer than six months, to prevent erosion and to maintain soil structure, nutrient content and biological activity.
• Minimising the number of machine movements across topsoil surfaces to minimise compaction and retain soil structure, again this is especially important given the waterlogged nature of the soils on Site. Achieved by the adoption of a bed/strip system.
7.7.6 However, some impacts to the soil resource, such as to its structural integrity, water holding capacity and nutrient holding capability, cannot be entirely mitigated, and therefore contribute to its loss and partial loss of function. Although this loss is reversible with appropriate management once the soils are replaced.
Drainage
7.7.7 During construction, measures to prevent excessive runoff to adjacent land, such as the creation of temporary grips and bunds or temporary holding lagoons would be in place. Additionally, impacts to existing on-site drainage would be mitigated through the implementation of sustainable drainage measures. A Sustainable urban Drainage System (SuDS) has been incorporated into the site masterplan to ensure that existing
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runoff rates are maintained. The detailed design and construction of the SuDS for the site would require approval by the Environment Agency.
Operational phase
7.7.8 As no significant effects were identified in association with the operational phase of the development, no mitigation measures are proposed.
Residual effects
7.7.9 Table 7.8 details the residual effects associated with the proposed development post- application of mitigation measures.
Table 7.8 Summary of the residual effects after the implementation of mitigation measures at the proposed development
Impact identified Significance Mitigation measures Significance of pre-mitigation residual effects Construction phase Permanent loss of MINOR Cannot be fully mitigated. MINOR ADVERSE less than 20ha BMV ADVERSE (Not Significant) land to agricultural (Not Significant) use through built development. Loss or damage to MAJOR Majority of disturbed soil resources reused on site. MINOR ADVERSE soil resources ADVERSE (Not Significant) The appropriate handling and storage of soils (DEFRA directly impacted by (Significant) guidelines) such as the handling of soil resources only when development. sufficiently dry, avoidance of machine movements across topsoils, separate handling and storage of topsoil and subsoils, and the seeding of soil stockpiles where necessary. Disruption/severance MODERATE Prevention of excessive runoff to adjacent land through the MINOR ADVERSE to to agricultural ADVERSE creation of temporary grips and bunds etc. NEGLIGIBLE drainage (Significant) (Not Significant) Rerouting of existing agricultural drainage systems. The implementation of SuDS (agreed by the Environment Agency) to combat the issues of a decrease in drainage efficiency. Operational phase None identified
Construction phase
Agricultural Land
7.7.10 The permanent loss of less than 20ha of BMV agricultural land to built development cannot be fully mitigated and therefore the residual impact of the proposed development remains minor adverse which would result in a non-significant effect.
Soil resource
7.7.11 Implementation of the mitigation measures outlined above would result in the correct handling and storage of the soil resource disturbed as a consequence of built
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development; and maximise the volume of soils retained and reused on site. The resulting damage or disruption to the disturbed soil resource would therefore be classed as short-term and reversible; and the magnitude of change from the baseline condition would be reduced to low (Table 7.3). The residual scale of impact to the disturbed soil resource would therefore be minor adverse, which would result in a non-significant effect (Table 7.5).
Agricultural Drainage
7.7.12 With mitigation measures outlined above in place, as a worst case, the proposed development would only result in short-term reversible disruption to both on-site and off-site drainage. Therefore the magnitude of change from the baseline condition is reduced to low (Table 7.4) and the overall impact is reduced to minor adverse to negligible, which would result in a non-significant effect (Table 7.5).
Operational phase
7.7.13 No residual effects are identified in association with the operational phase of the development.
7.8 Cumulative Effects
7.8.1 Assessment of the cumulative impacts associated with the proposed development within the locale has been undertaken in relation to the following schemes:
• Chilmington Green;
• Park Farm; and
• Cheesemans Green.
7.8.2 Table 7.9 identifies the details of each of the schemes.
Table 7.9 Schemes to be assessed through the cumulative impact assessment
Proposed Planning Details Area (ha) ALC Grades Scheme reference(s)
Chilmington 07/00012/AS Mixed use phased scheme – Development would see 415 ALC Grade 3, Green the creation of 5750 homes, and 1000 new jobs through potentially 10/00005/EIA/AS retail, commercial and industrial spaces. BMV land 11/00012/EIA/AS 12/00400/AS
Park Farm 10/01725/AS Mixed use phased scheme – Development started in the 23 ALC Grade 3, 1990s. Latest applications are for phases 3 and 3a (Park potentially 12/00005/EIA/AS (Park Farm Farm East). BMV land East) 13/00198/AS
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Cheesemans 02/00278/AS Mixed use phased scheme - Development would see 168 ALC Grade 3, Green the creation of 6500 homes, and 2000 new jobs through potentially 09/01566/AS retail, commercial and industrial spaces beyond 2021 at BMV land 10/01277/AS this site. Outline planning permission for part of the site was granted in 2006.
7.8.3 When these schemes are considered in relation to the proposed Kingsnorth Green development, this would result in a cumulative loss of 610.2ha of agricultural land from the locale of Grade 3 and above; BMV and potentially BMV.
7.8.4 Ashford Borough comprises 52,001 ha of land of ALC grades 1, 2 and 3, equating to 96% of the Borough’s agricultural land (54,226 ha), and 90% of its total land area (58,062ha). Consequently the cumulative loss of 610.2ha, equating to 1.2% of BMV and potentially BMV land, and 1.1% of the agricultural land of the locale, is not considered to be significant.
7.9 Conclusion
7.9.1 This chapter details the results of a soils and agricultural land use assessment completed for the development. The chapter assesses the results of a soil survey and agricultural land classification calculations carried out in accordance with current guidance, and outlines recommendations for mitigation as appropriate.
7.9.2 To establish the soil and agricultural land baseline across the site, a detailed soil survey was undertaken. This indicated that the site is characterised by mottled, clay loam soils of the Wickham 1 soil association.
7.9.3 The ALC calculations show the site comprises 20.3ha of BMV (Subgrade 3a, good quality) and 40.5ha of non-BMV (Subgrade 3b, moderate quality) agricultural land.
7.9.4 As identified in the site masterplan, some areas of the site would be utilised for green space, flood protection zones, etc. and consequently would not be subject to built development and disturbance. There would be negligible impact to soil resources in these areas as the soil profile will remain in situ; and, as the land would retain the potential to be returned to a productive agricultural use in the future, its loss is considered temporary.
7.9.5 In the areas identified for built development, the activities carried out during the earthworks and construction phase of the development would have the potential to result in the loss of, or damage to, soils; along with impacts to drainage. To reduce the potential impacts of earthworks and construction works, mitigation measures
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would be implemented. The retention and reuse of the disturbed soils elsewhere on site, in combination with the implementation of DEFRA best practice guidelines for the stripping, handling and storage of soil resources; and the implementation of SuDS and other water management techniques, would result in the earthworks and construction phase activities to having no significant effects on either soil resource or agricultural drainage.
7.9.6 The permanent loss of agricultural land to built development cannot be fully mitigated and therefore remains a minor adverse impact, leading to a non-significant effect.
7.9.7 The operational phase of the development is not considered to impact on agricultural land and soil resources or drainage, and therefore mitigation measures are not applicable.
7.9.8 There would be a cumulative loss of 610.2ha of BMV and potentially BMV land. This loss equates to 1.2% of BMV and potentially BMV land, and 1.1% of the agricultural land within Ashford Borough, and is therefore not considered to be significant.
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8 GROUND CONDITIONS
8.1 Introduction
8.1.1 This chapter outlines the assessment of ground conditions at the site. This has been undertaken by review of available desktop information regarding the conjectured geology beneath the site and current environmental risks associated with the site.
8.1.2 Making reference to the development proposal, a Phase 1 Geo-Environmental Desk Study of the site has been carried out in order to identify anticipated ground conditions and environmental risks. The desk study aims to identify any existing and potential receptors which may be present and the pathways by which the receptors may be exposed to any identified sources of contamination at the site.
8.2 Policy and Legislative Framework
8.2.1 The control of development and land use in the future is the responsibility of the planning system, which is the principal regulatory driver for this site. In March 2012, the Government released the National Planning Policy Framework (NPPF) which replaced all previous planning policy statements and guideline (PPS/PPG) documents including Planning Policy Statement (PPS) 23 Planning and Pollution Control. However, it should be noted that the NPPF does not change the statutory basis on which planning decisions are founded and emphasises the requirement for sustainable development.
8.2.2 A fundamental principle of sustainable development is that the condition of land, its use and its development should be protected from potential hazards. The NPPF states that:
“120. To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account.
Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner.
121. Planning policies and decisions should also ensure that:
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• the site is suitable for its new use taking account of ground conditions and land instability, including from natural hazards or former activities such as mining, pollution arising from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation;
• after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990; and
• adequate site investigation information, prepared by a competent person, is presented.”
8.2.3 Today almost all new development in England has the capacity to have significant effects on the environment, both positive and negative, therefore today's development industry is highly regulated by planning policy and law.
8.2.4 For England, the key national planning policies for development are set out in the NPPF. The focus of the NPPF is a presumption in favour of sustainable development. The NPPF recognises that development is essential to support sustainable economic growth and quality of life. As a result it is important that there is a sufficient supply of housing stock to provide the infrastructure, buildings, energy and goods that the country needs whilst ensuring that development does not have unacceptable adverse impacts on the natural and historic environment or human health.
8.3 Assessment Methodology
Scope
8.3.1 The desk study assesses the likely geological setting of the site based on published geological mapping. The results of the desk study have been used to determine the requirement for future site investigation works at the more detailed design stages and to produce this chapter of the Environmental Statement.
8.3.2 The objective of the desk study is to compile information from a range of sources to provide an assessment of the ground conditions at the site. At this time no intrusive investigations have been undertaken within the site boundary. Available published information has been used to assess the likely ground conditions which may be expected across the site. These data sources include the following:
• Envirocheck Environmental Data Reports;
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• Geological mapping and memoirs published by the British Geological Survey (BGS);
• Ordnance Survey Plans;
• Wardell Armstrong archives;
• BR211 – Radon, Guidance on Protective Measures for New Dwellings; and
• Environment Agency Groundwater Vulnerability Map.
Assessment Approach
8.3.3 Consideration is also given to the way in which the proposed development may affect the ground conditions at the site. The evaluation takes into account the effects of the change of land use together with the potential impact of the construction phase and the proposed end use of the land.
8.3.4 The assessment of contamination risk for the site reviews potential complete pollution linkages between a contaminant source and a sensitive receptor via an exposure pathway. The fundamental concept is that without each of the three elements (contaminant, pathway and receptor) being present on the site forming a complete pollution linkage there can be no contamination risk. The presence of contamination at a particular location does not necessarily represent an associated risk.
8.3.5 In order to assess the risk posed to a receptor by a contaminant, the sensitivity of the receptor exposure duration and site end-use scenario is taken into consideration. For example, the concentration of contaminants tolerable at a site to be developed for residential use, with gardens used to grow vegetables and accessible to young children, is lower than that tolerable on a commercial site, where soil is exposed only in minor areas of soft landscaping and where the only long-term users of the site are adults.
8.3.6 Criteria for assessing the significance of the potential effects are based on a qualitative assessment of the receptor sensitivity and the predicted magnitude of change from the baseline as a result of the proposed development.
8.3.7 The magnitude of change predicted and the sensitivity of identified receptors are used to qualitatively assess the impact significance of the proposed development. Impacts have the potential to be either adverse or beneficial. The details of impact assessment will be discussed in further detail later on in this ground condition assessment.
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Significance Criteria
8.3.8 In order to assess the risk posed to a receptor by a contaminant, the sensitivity of the receptor exposure duration and site end-use scenario is taken into consideration. For example, the concentration of contaminants tolerable at a site to be developed for residential use, with gardens used to grow vegetables and accessible to young children, is lower than that tolerable on a commercial site, where soil is exposed only in minor areas of soft landscaping and where the only long-term users of the site are adults.
8.3.9 Criteria for assessing the significance of the potential effects are based on a qualitative assessment of the receptor sensitivity and the predicted magnitude of change from the baseline as a result of the proposed development.
8.3.10 The magnitude of change predicted and the sensitivity of identified receptors are used to qualitatively assess the impact significance of the proposed development. Impacts have the potential to be either adverse or beneficial. The details of impact assessment will be discussed in further detail later on in this ground condition assessment.
Table 8.1 Magnitude Typical Description of the Change Predicted i.e. Large area of the site contains contamination levels that significantly Large exceed the intervention levels or Soil Guideline Values. Remediation to a state ‘suitable for use’ required prior to site development Moderate i.e. Proposals cause the release or mobilisation of contaminants through the creation of a pathway to expose receptors to high levels of contamination Small i.e. Contaminants identified on site are approaching the Soil Guideline Values, or are between the target and intervention levels. Remediation may be required prior to development Negligible i.e. Existing contaminants identified are found in relatively low concentrations that pose no significant risk to receptors, and therefore no remedial action is taken
8.3.11 The magnitude of an effect is to be considered by the nature of change, its severity, the duration of an effect and the likelihood of an effect occurring, therefore, the risk assessment has been based on a qualitative assessment and professional judgement. The magnitude of an impact has been described as either a ‘large’, ‘moderate’, ‘small’ or ‘negligible’. Potential effects in terms of ground conditions tend to be local,
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however, the effects have been considered in relation to different geographical contexts other than the study site.
Table 8.2 Sensitivity Receptor High Medium Low Negligible Typical i.e. Land to be used for i.e. Parks, i.e. i.e. industrial Description allotments or domestic playing fields commercial land uses or of Receptor gardens, to grow crops for and open land uses concrete human consumptions, or spaces covered upon which animals are area reared for human consumption
8.3.12 In this case the receptor may be an existing receptor affected by change in mobilisation of a pollutant, or a proposed land use that is potentially sensitive to the existing contamination.
8.3.13 In line with statutory guidance, the proposed land use is a key factor in determining an acceptable level of contamination. Therefore, if more than one land use is proposed for the site, the sensitivity of receptor may be determined according to the levels and locations of contamination identified in relation to the proposed master plan or site use, and the subsequent potential for contamination to affect receptors.
Table 8.3 Significance MAGNITUDE SENSITIVITY High Medium Low Negligible Large Major Major Moderate Minor Moderate Major Moderate Minor Negligible Small Moderate Minor Minor Negligible Negligible Minor Negligible Negligible Negligible
8.3.14 Major: Highly sensitive land uses, highly sensitive ecosystems and water receptors and also land uses resulting in human exposure to hazardous concentrations of contaminant (greater than their intervention level, or between intervention and target level). Pathway to release/mobilisation/exposure to contaminant is generated
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to humans and/or ecosystem. Potential for moderate and major changes to very sensitive ecosystems.
8.3.15 Moderate: Low sensitivity land uses, water receptors and ecosystems exposed to contaminant concentrations greater than their intervention level, or between intervention and target level. Also highly sensitive receptors exposed to contaminants approaching target level. Potential for minor changes to ecosystems.
8.3.16 Minor: Low sensitivity land uses, water receptors and ecosystems exposed to contaminant concentrations approaching target level. Potential for minor changes to ecosystem. High/moderately sensitive receptors are exposed to contaminants found in relatively low concentrations that pose no significant risk to humans, animals or plants.
8.3.17 Negligible: Non-sensitive land use, water course or ecosystem exposed to contaminants found in relatively low concentrations that pose no significant risk to humans, animals or plants.
8.3.18 With regards to significance, professional judgement can be used to vary the category where specific circumstances dictate, for example due to the vulnerability or condition of the receptor. For example, not all contaminants are harmful to all receptor types, such that a phototoxic contaminant may significantly impact a nature conservation receptor of importance for sensitive plants and not impact fauna. Factors such as chemical absorption and synergistic effects may also moderate the assessment. Impacts shall be reviewed on an overall basis of ‘adverse’ or ‘beneficial’, except where negligible magnitudes and sensitivities are noted.
8.3.19 The degree of ‘pollution’ will be fundamentally affected by, and can be moderated through reference to, the integrity of the pollutant linkage. The category will be dependent on the completeness and nature of the pathways between source and receptor. Other factors may also be deemed to amend the assessment, such as the local, regional or national shortage of a particular receptor resource.
8.3.20 The reason for and nature of any variation will be made clear in the assessment. If the degree of effect is moderate or above, then the effect is considered to be significant.
Uncertainties and Limitations
8.3.21 During the preparation of a ground conditions chapter, there are sometimes circumstances in which the information available to inform the assessment process is
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limited. For example, there is inevitably some uncertainty in predicting future impacts and effects, especially where a site walkover has not been able to be undertaken.
8.3.22 The work undertaken to provide the basis of this chapter comprised a study of available documented information from a variety of sources. The details given in this chapter have been dictated by the finite data on which it is based and are relevant only to the purpose for which the Environmental Statement has been commissioned. The information reviewed should not be considered exhaustive and has been accepted in good faith as providing true and representative data pertaining to site conditions. Should additional information become available which may affect the opinions expressed in this chapter, Wardell Armstrong LLP reserves the right to review such information and, if warranted, to modify the opinions accordingly.
8.3.23 It should be noted that any risks identified in this chapter are perceived risks based on the information reviewed; definitive risks can only be assessed following further ground investigation of the site.
8.4 Baseline Conditions
Site Description & Context
8.4.1 The full description of the site is given in Chapter 3. The application site, known as Kingsnorth Green, is located at NGR TR 00131 38738 and covers an area of 60.98ha. The site is situated in a predominately rural setting with the village of Kingsnorth approximately 0.4km to the north. The site boundary is illustrated in Figure 8.1 overleaf. For ease of reference regarding different geology across the site, the study area is divided into 6 different parcels of land (Site A to F).
8.4.2 Pentland Homes and Jarvis Homes control land delineated as the study site at Kingsnorth Green which is currently being promoted through the emerging Ashford Local Plan to 2030 for a varied land-use use scheme. The final masterplan (Drawing 14007(sk)001 Rev N) outlines this mixed use site, including 750 houses, green infrastructure, a community hall, a small retail/café outlet along with other features of the proposed development. The study area predominately comprises open fields and agricultural land. The Kingsnorth Green development is a combination of freehold (with uplift) and land under option.
8.4.3 Although the site is outlined as a single entity, the study area is a combination of various parcels of land, which combined comprise over 60ha of open fields/farmland.
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The majority of the site boundary is demarked by hedgerows containing mature and semi-mature trees.
8.4.4 Relevant Ordnance Survey plans and maps indicate, the site has a very varied topography. There is a general topographic slope from east to west, with levels falling from 49m AOD at the eastern area of site to 38m AOD at the western boundary. The northern part of the site is generally steeper than the southern part. A topographic survey has been undertaken with regards to the overall evaluation of site, which should be referenced with regard to the site topography.
Figure 8.1 Kingsnorth Green, Ashford (Reproduced from Google Maps)
Site Usage
8.4.5 Past editions of published Ordnance Survey plans and mapping dating between 1874 and 2014 have been reviewed in order to determine the development history of the site and the immediate surroundings. The historical plans for the site are included within the Envirocheck Report (see Appendix 8.1).
8.4.6 The earliest available mapping of the area dated 1874-1877 indicates the site to be an area of farm land and open fields, with minimal trees or vegetation being identified within the site area. The site itself has remained predominately undeveloped to date with no significant changes being indicated.
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8.4.7 In terms of land use, the site has always been associated with agricultural land. There are aerial photos indicating previous cultivation of the land (circa 1940). The aerial photos show that a combination of pastoral and arable farming has taken place across the study area.
8.4.8 The only significant building/structures identified within the study area are the Jarvis Homes residential properties (Myrtle Court) located immediately to the north of Site C (see Figure 8.1).
8.4.9 These residential properties first appear on the plans in 2006 (aerial photos indicate that some of the residential properties were still under construction at this time). There are various small farm buildings within the study area (southern areas of Sites A, E and F, northern area of Site F, etc.).
8.4.10 Aerial photos from 1940 indicate that the site area has not significantly changed in terms of land use and industrial/contaminative activities, from the earliest images to the current date.
Potential Ground Conditions as a Result of Land Use
8.4.11 Particular aspects of the site areas may have the potential to affect ground conditions within the site. These aspects are summarised below:
• Arable fields – it is considered likely that pesticides and fertilisers have been used across the site. There is a potential for traces of harmful pesticides and contaminants within the soils at the site, although the risk is considered to be low.
• Nitrate vulnerability – the entire site and surrounding area is indicated to be within a nitrate vulnerable zone. Soils do not absorb excess nitrate ions, which then move downward freely with drainage water, and are leached into groundwater, streams and oceans. Excessive nitrogen compounds cause eutrophication in water bodies. Water is considered eutrophic if it contains levels of nitrogen compounds that cause excessive plant growth resulting in an undesirable disturbance to the balance of organisms present in the water and to the quality of the water.
• Hedgerows and field ditches – standing water associated with the hedgerows and field ditches may cause localised softening of the ground. This could have implications for the design of foundations within these areas.
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• Ploughed horizons – the topsoil materials are likely to mark the approximate extent of ploughing depth across the site. Incorporation of fertilisers and other materials within this ploughed horizon could have introduced elevated levels of contaminants including heavy metals and metalloid compounds. Depth of topsoil also correlates to soil gas potential on the site.
• Areas within the vicinity of woodland – the presence of any established woodland may have resulted in the desiccation of near surface cohesive soils. Should future buildings be founded within these areas, this desiccation could affect the foundation depths appropriate for that section of the site.
• Disturbed Made Ground – due to the historical and present-day farm buildings within the study site boundary, there is likely to be disturbed Made Ground and/or structures associated with the foundations of the buildings. Previous ground investigation work should be reviewed to assess any Made Ground deposits (i.e. historic evidence of an area of material deposit in the centre of Site B) indicating any potential structural obstructions within the ground, i.e. concrete slabs, piles, foundation obstructions and/or other unidentified structural remnants.
• Ground Works – ground works for features adjacent to site (i.e. covered reservoir adjacent to western boundary) could have an impact on the ground conditions on site.
Geology
Made Ground
8.4.12 There are no records of Made Ground or landfill deposits within or adjacent to the application site. The potential for geological materials on site to be affected by landfill gas is therefore considered to be low.
Superficial Deposits
8.4.13 Published BGS data for the area (BGS Digital Geological map of Great Britain at 1:50,000 scale) indicates that there are minimal superficial deposits across the site area.
8.4.14 In central areas the site is underlain by small pockets of River Terrace Deposits (sand and gravel). This superficial deposit material is characterised by sand and gravel, locally with lenses of silt, clay or peat.
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8.4.15 Small pockets of Alluvium (clay, silt, sand and gravel) are detailed as being sparsely present within the northern areas of site. This stratum is characterised by normally soft to firm consolidated, compressible silty clay, but can contain layers of silt, sand, peat and basal gravel. A stronger, desiccated surface zone may be present.
Solid Geology
8.4.16 Published BGS data indicates that the majority of site is immediately underlain by bedrock geology of the Weald Clay Formation. This Formation is characterised by dark grey thinly-bedded mudstones (shales) and mudstones with subordinate siltstones, fine to medium-grained sandstones, including calcareous sandstone, shelly limestones and clay ironstones.
Structural Geology
8.4.17 There are no geological faults recorded on the application site.
Hydrogeology
8.4.18 The Environment Agency (EA) Website has been consulted in respect of the underlying aquifer designation. The EA indicate that the small pockets of superficial deposits underlying the site are classified as a Secondary A Aquifer.
8.4.19 Secondary A Aquifers are permeable layers 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. These are generally aquifers formerly classified as minor aquifers.
8.4.20 The underlying solid bedrock of the Weald Clay Formation is classified as being an unproductive strata. Although some sections of this formation contain limestone and sandstone, the overall classification is that of a non-water bearing formation with low permeability.
8.4.21 The EA have defined Source Protection Zones (SPZs) for 2000 groundwater sources such as wells, boreholes and springs used for public drinking water supply. These zones show the risk of contamination from any activities that might cause pollution in the area: the closer the activity, the greater the risk.
8.4.22 The site is not located within a Groundwater Source Protection Zone.
8.4.23 The EA also define how vulnerable the groundwater/aquifer is to contamination within the area (mainly due to geology transmissivity). In any given area, the groundwater within an aquifer, or the groundwater produced by a well, has some vulnerability to contamination from society's activities.
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8.4.24 Groundwater vulnerability is a function of the geologic setting of an area, as this largely controls the amount of time that has passed since the water fell as rain, infiltrated through the soil, reached the water table, and began flowing to its present location.
8.4.25 A small section of the northern area of Site B has been designated as ‘Minor Aquifer – High Vulnerability’. This is the only area on site which has been designated with vulnerability higher than ‘Minor Aquifer – Low’. This is likely to be due to the superficial deposits (Alluvium) identified within this northern area of Site B.
8.4.26 The Envirocheck report confirms that there are no surface water, groundwater or potable water abstractions recorded within 500m of site.
Hydrology
8.4.27 The site lies within the Stour catchment. The principle watercourse within the vicinity of the study area is the Whitewater Dyke which is located adjacent to the northern boundary of Site B. Whitewater Dyke is a tributary of the Great Stour River, joining with the East Stour and then the Great Stour at Pledge’s Mill at the bottom of East Hill in Ashford, Kent.
8.4.28 The Whitewater Dyke runs from its source near Shadoxhurst, 5.6 kilometres, to the East Stour in Willesborough. Whitewater Dyke will not be directly affected by the proposed development.
8.4.29 There are various tertiary rivers in the surrounding area of site. One of the tertiary rivers is located flowing from west to east through the southern area of Site A and along the southern boundary of Site D.
8.4.30 The majority of the study area is located within Flood Zone 1 (an area with little or no risk of flooding). However, a small northern section of Site B is located within Flood Zone 2 (an area of extreme flooding from rivers or seas without defences) and Flood Zone 3 (an area flooding from rivers or seas without defences).
Mineral/Aggregate Potential
8.4.31 The absence of deposits of sand or gravel on the site indicate that the potential for the site to contain economic deposits of aggregates is limited. Based on the assessment of the sub-surface material, the potential for minerals of economic value to be present on site is very limited.
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Site Sensitivity
8.4.32 Information published within the Envirocheck report indicates that the only aspect of concern regarding site sensitivity within the site boundary is nitrate vulnerability. The entire site and surrounding area is indicated to be within a nitrate vulnerable zone (NVZ). Farmers with land in NVZs must follow mandatory rules to tackle nitrate loss from agriculture.
8.4.33 The Nitrate Pollution Prevention Regulations bring into force the European Commission nitrates directive. The latest review came into force on 17 May 2013. The Regulations mean that land that drains into waters polluted by nitrates are designated as NVZs.
8.4.34 The Nitrates Directive is implemented by separate regulations in England and Wales. The Environment Agency is responsible for enforcing and assessing farmers' compliance with these regulations in England.
8.4.35 Until it is possible to confirm the extent of the agricultural processes which have taken place on site presently or historically (discussions with land owners, site operatives, occupants or local residents) then excess nitrogen should be considered a potential contaminant.
8.4.36 There are no designated Sites of Special Scientific Interest, Special Areas of Conservation, or Special Protection Areas on site or in the immediate surrounding area.
Ground Stability and Mining/Mineral Extraction
8.4.37 The environmental desk study data report has reviewed the following stability hazards on the site:
• The potential for compressible and collapsible ground at the site is generally very low. Deposits with potential to collapse when loaded and saturated are unlikely to be present. It is deemed that no special ground investigation would be required. Therefore it is unlikely to encounter increased construction costs or increased financial risk due to potential problems with collapsible deposits. However, there is a small northern section of Site B which is considered to have a moderate potential for compressible and collapsible ground which should be assessed during any site investigations and foundation assessments.
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• The potential for landslide ground stability hazards on the site are very low (slope instability problems are unlikely to be present).
• The potential for running sand ground stability hazards on the site ranges from no hazard to low (low potential for running sand problems if water table rises or if sandy strata are exposed to water).
• The potential for soluble rocks on the site is identified as being negligible.
• The potential for shrinking or swelling clay ground stability hazards across site are detailed as ranging between negligible to low.
• There are no records of coal mining affected areas or BGS recorded mineral sites on site or within the immediate surrounding area.
Radon Gas
8.4.38 The BRE ‘Guidance on Protective Measures for New Dwellings’ (BR 211) has been consulted. This document uses data obtained from the measurement of radon within existing houses, undertaken by the National Radiological Protection Board (NRPB), and an assessment of the geological radon potential of an area prepared by the British Geological Survey. The majority of the site is not in a Radon Affected Area, as less than 1% of properties are above the Action Level. The BRE guidance document classifies the site as not requiring radon protective measures.
8.4.39 However, the southern area of Site D is deemed to require basic radon protective measures in the construction of new dwellings or extensions. This area of site is in an intermediate probability radon area, as between 3 and 5% of homes are above the Action Level.
Landfill Sites and Waste Management Facilities
8.4.40 There are no historical, BGS recorded or registered landfill sites within 500m of the site.
Pollution Incident / Contaminated Land Register
8.4.41 There are no entries of local pollution incidences on site recorded on the Contaminated Land Register. However there are two incidences in relatively close proximity to the site.
8.4.42 One incident entry is recorded as taking place approximately 140m east of Site F on 24th March 1994: ‘a Category 3 minor incident involving unknown chemicals from a
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water company sewage discharge deposited in a land drain/stream running from Stumble Lane to railway.’ Although the chemicals deposited are unknown, the recorded notes detail mastic-like material deposited on a nearby river bank.
8.4.43 The other incident entry is recorded as taking place approximately 240m south of Site D on 9th May 1996: ‘a Category 2 significant incident involving fire water / foam after a fire at Cowell's Yard, Ashford Road.’
8.4.44 Neither incident are likely to have had a negative impact on the study area in any way.
Local Authority Pollution Prevention and Controls
8.4.45 There are two recorded Local Authority Pollution Prevention and controls within 500m of the site. The closest control is approximately 257m to the north of the site at Moatfield Meadow, Park Farm for a Tesco petrol filling station.
8.4.46 The other recorded control within 500m of site is located approximately 275m to the north of the site at Moatfield Meadow, Park Farm, for Prim Dry Cleaners.
Hazardous Substances
8.4.47 The desk study research indicates there have been no incidents or indication of hazardous substances on site or within the immediate surrounding area.
Potentially Contaminative Industrial Sites
8.4.48 Assessment of potentially contaminative industrial activity has been undertaken within a 500m radius of site to detail potential sources of contamination:
Active Industrial Sites
• Oak Tree Garage – Garage service located in-between Site E (southern boundary) and Site F (northern boundary)
• Bold Autobody – Car body repair service located in-between Site E (southern boundary) and Site F (northern boundary)
• M Pest Control – Pest & vermin control company located approximately 15m north of site B
• Powerflush Ltd – Power flushing company located approximately 75m to the north of Site B
• Freezecure – Refrigerator and freezer repair company located approximately 75m to the north of Site B
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• Woodgate – Garage service located approximately 160m to the north-east of Site C
• Cleaners Can Be – Commercial cleaning services located approximately 300m south-east of Site F
• J A Plant – Garage services located approximately 400m to the south-east of Site F
• D A Services – Domestic appliance servicing, repairs and parts service located approximately 410m to the north of Site B
• A1 Cleaning & Maintenance – Commercial cleaning services located approximately 410m to the north of Site B
• Van & Car Ltd – Car dealers located approximately 450m to the south-east of Site A
Historic Industrial Sites
• A I S Rail – Historic railway equipment manufacturers located approximately 15m north of Site B
• Forge Garage – Historic garage service located approximately 60m to the north-east of Site C
• F D M S Ltd – Historic MOT testing centre located approximately 70m north- east of Site C
• Kent Supplies – Historic medical equipment maintenance and repairs company located approximately 280m north-east of Site F
• Sendmeamirror.Com Ltd – Historic mirror and decorative glass manufacturers located approximately 300m south-east of Site F
• Friendly Autos – Historic car radiator servicing and repairs located approximately 450m to the south-east of Site A
• The Gun Shop – Historic gunsmiths located approximately 450m to the south- east of Site A
• Kingsnorth Ironworks – Historic wrought ironworks located approximately 450m south of Site A
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• Woodfolke – Historic cabinet makers located approximately 450m to the south-east of Site A
• Kent Shotblasting & Powder Coating – Historic powder coatings manufacturer located approximately 450m to the south-east of Site A
• Dragon Heat – Historic woodburning stoves retailer located approximately 450m to the south of Site A
• Gt Mini Skips – Historic waste disposal services located approximately 450m to the south of Site A
Potential for Ground Contamination
8.4.49 The historical mapping indicates that little change in land use has occurred over the application site and that land use on this site has been based around agricultural use since records began. This would suggest that ground contamination is likely to be limited, and associated to the site’s link to agriculture.
8.4.50 Although there are no identified sources of contamination on site, due to the large extent of the site area there are many potentially contaminative sources within the surrounding area (as detailed in Section 8.4.49).
8.4.51 The nearest sources of potential contamination (within 200m radius) are a garage and a car body repair shop located in-between Site E (southern boundary) and Site F (northern boundary), a pest control service located approximately 15m north of Site B, a power flushing company and a refrigerator/freezer repair company – both located approximately 75m to the north of Site B.
8.4.52 Historical records also show there was previously a railway equipment manufacturer located approximately 15m north of Site B, a garage located approximately 60m to the north-east of Site C and a MOT testing centre located approximately 70m north- east of Site C.
8.4.53 Although there are no fuel sites on site or within the immediate surrounding area, there are records of a historic filling station being present approximately 10m to the north of Site B.
Pathways
8.4.54 A number of possible pathways have been identified whereby potential receptors can be exposed to, or affected by, the identified contaminants:
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• Groundwater/perched groundwater;
• Surface water runoff – impermeable shallow mudstone and steep gradients;
• Dermal contact ingestion or inhalation of soil contaminants by site users;
• Ingestion of contaminated soil;
• Inhalation of contaminated dust;
• Uptake of contaminants from soil by flora; and
• Migration of soil borne contaminants via airborne dust.
The Projected Future Baseline
8.4.55 No significant changes to baseline conditions are likely to occur in the future if the proposed development does not proceed.
8.5 Key Impacts and Likely Significant Effects
Potential Impacts on the Proposed Development
8.5.1 The desk study research identified a number of elements which could have a potential effect on the proposed development. These factors are summarised below:
• Localised softening of shallow clay – due to the historical land use and the conjectured ground conditions across the site it is considered that there is a potential for areas of softened materials where surface water may have permeated shallow cohesive materials. Localised softening may require foundation depths to be increased to stiff clay horizons at greater depth;
• Desiccation of cohesive materials – where trees and large shrubs have been long established there is potential for localised desiccation of the shallow cohesive materials (northern boundary of Site F for example). Where any long established vegetation is removed there will be a requirement to extend foundations to a moisture stable horizon which may require deepened foundations;
• Shrinkability of cohesive materials – due to the nature of the cohesive materials at the site, the depth of foundations will also need to take account of any trees planted as part of landscaping works within the vicinity of buildings and other structures;
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• Contamination – it is considered that based on the desk study information and historical land use of the site, there is a low risk of significant contamination at the site. However, as part of the development of the site, geochemical laboratory testing should be undertaken to confirm the geochemical characteristics of the shallow soil materials. This work would be likely undertaken at an advanced stage of the development of the site. Review of the desk study researches indicates that there is a potential for pesticides and heavy metal contamination associated with pesticide spraying and fertiliser spreading across the site.
• Disturbed Made Ground – due to the presence of small farm buildings within the study site boundary, there is likely to be disturbed Made Ground and/or structures associated with the foundation of the buildings. There is also a potential for historic farm buildings across site which have not been identified on plans.
• Site levels – the site was noted to generally slope down from east to west, with levels falling from 49m AOD at the eastern area of site to 38m AOD at the western boundary. There are many variations in elevation across the site, although this is not a constraint to development of the site, it may be prudent to consider the various gradients across site to ensure that ground stability is not adversely affected by any development.
• The nearest sources of potential contamination (within 200m radius) are identified as:
- A garage and a car body repair shop located in-between Site E (southern boundary) and Site F (northern boundary);
- A pest control service located approximately 15m north of Site B; and
- A power flushing company and a refrigerator/freezer repair store both located approximately 75m to the north of Site B.
• Historical records show there was previously a railway equipment manufacturer located approximately 15m north of site B, a garage located approximately 60m to the north-east of Site C and a MOT testing centre located approximately 70m north-east of Site C. These sites are now listed as redundant and inactive.
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• Although there are no fuel sites present on site or within the immediate surrounding area, there are records of a historic filling station being located approximately 10m to the north of Site B.
Potential Impacts of the Proposed Development on Ground Conditions
8.5.2 Alongside the potential effects that the ground conditions may impose on the detailed design of the proposed development, consideration has also been given to the impact that the proposed development may have on the ground conditions at the site. The potential impact may be considered in three stages:
Construction Phase Impacts
8.5.3 There are a number of potential impacts which may result from the construction phase of the development. Removal of topsoil materials and tracking of plant across uncovered cohesive bedrock material may cause additional weathering and disturbance to the shallow ground conditions and could result in softening and rutting of the surface.
8.5.4 Removal of topsoil materials is likely to increase surface run-off.
8.5.5 It is possible that contamination of the ground may occur due to activities relating to the developments. This could include spillage of oils and fuel from plant working at the site, chemical spillages and other contaminants, and potential for construction waste such as broken brick, tiles, waste concrete, cement, etc. to become incorporated into the surface of the ground.
8.5.6 A working plan should be designed, which will allow excavations to be managed efficiently and mitigate any potential environmental impacts, especially with regards to encountering unidentified areas of buried waste/contamination.
Impacts Relating to Land Use
8.5.7 The layout of the proposed development may also have an impact on the ground conditions. Removal or incorporation of trees and shrubs into the development area could have an impact on the condition of the clay material identified as the Weald Clay Formation. This may result in swelling or shrinkage of the ground dependent upon the hydrological conditions at the site. In addition, large areas of hardstanding are likely to reduce the amount of water ingress into the soils and potentially affect the ground conditions.
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Post Development Impacts
8.5.8 Following development of the site the ground will be affected by activities undertaken within the individual housing plots. This could include spillages of oils, fuels or other chemicals associated with vehicle and household activities. Similarly the various roads serving the development provide further potential for contamination of the ground. The potential presence of contaminants within the ground also identifies a potential for pollution of the site due to nearby potentially contaminative industries.
Table 8.4 Significance of potential impact (without mitigation) Potential effect Significance (pre- mitigation) Construction stage Soil contamination associated with agricultural use Moderate - within the area of site. Leached agricultural inputs, Adverse i.e. fertiliser, pesticides, herbicides, etc.; The entire site and surrounding area indicated to be within a NVZ Fuel and oil based hydrocarbon contamination Moderate - associated with plant and machinery activity on site. Adverse Contamination of the ground due to activities Moderate - relating to the development. This could include Adverse spillage of oils and fuel from plant working at the site, chemical spillages and construction wastes, etc. The potential for localised contamination associated Moderate - with adjacent land uses. Adverse
Post-completion stage Excluding unforeseen activities/alterations undertaken within the individual housing plots, the effects of the post-completion ground conditions are deemed to be the same as those in the construction stage. The potential for localised contamination associated Moderate - with adjacent land uses. Adverse
8.6 Mitigation
Construction Stage
8.6.1 As part of the detailed design stages of the development, where relevant, it would be sensible to undertake further assessment to determine the contaminative status of the site.
8.6.2 This assessment would aim to characterise the general geochemical nature of the site as well as focusing on particular areas of the site where potential contaminative
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conditions have been identified as part of the desk study researches, i.e. the nearby garage, car body repair shop, pest control service, etc. Assessment of the results of this testing will inform whether mitigation measures would be required.
8.6.3 Assessment of the ground conditions at the site will inform the design of the foundations appropriate for the structures within the development. If required, particular measures should be used to prepare the ground for development.
8.6.4 An appropriate intrusive site investigation should be undertaken once a detailed development layout is finalised. This investigation will provide up-to-date information pertaining to the contaminative and geotechnical characteristics of the shallow ground and will aid in the design of mitigation measures should they be deemed appropriate.
8.6.5 In terms of minimising the impact of the proposed development on the ground conditions, there would be a requirement during the development phase to ensure that materials and chemicals used during the construction would not impact the ground adversely. This would involve the use of bunded tanks, regular vehicle maintenance and minimisation of construction related waste. Appropriate measures should be in place to deal with accidental spills and any wastes produced during construction. Construction activities would also require material management plans to be prepared and implemented to audit waste materials and minimise potential adverse impacts to the ground.
Post-completion Stage
8.6.6 If identified as appropriate during the construction phase, a regime of on-going monitoring and assessment should be undertaken to review the impact of construction activity. The duration of this post-works assessment should be based on the achievement of designated site criteria. Post-work surveys are carried out to confirm the long-term effectiveness of the mitigation procedures undertaken during the construction phase.
8.6.7 There are few measures that may be put in place to minimise the impact that individuals occupying the proposed development may have on the ground conditions, however the clayey nature of the mudstone would help to contain any spillage or contamination within any isolated location and impede transmission.
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Residual Effects
8.6.8 It is considered that the agricultural land use of the site provides minimal impact upon the proposed development of the site. Where limited potential impacts associated with particular features at the site and surrounding area have been identified, it is considered that with the implementation of appropriate mitigation measures, residual effects will not be significant at the site.
Table 8.5 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of mitigation) residual effect Construction stage Clay at shallow depths, which Minor - Adverse As part of the detailed design Negligible have the potential to heave / stages of the development, where shrink due to the influence of relevant, it would be beneficial to trees. undertake further assessment to determine the contaminative Localised softening and/or Minor - Adverse Negligible status of the site. Specific desiccation of clay. mitigation measures will be Soil contamination associated Moderate - required to reduce significant Minor with agricultural use within the Adverse adverse effects potentially caused area of site. Leached agricultural by the proposed development. inputs, i.e. fertiliser, pesticides,
herbicides, etc.; The entire site and surrounding area indicated In terms of minimising the impact to be within a NVZ of the proposed development on the ground conditions, there Localised ground gases Minor - Adverse would be a requirement during Negligible associated with topsoil materials the development/construction Removal or incorporation of trees Minor phase to ensure that materials Negligible and shrubs into the development and chemicals used during the could have an impact on ground construction would not impact conditions. the ground adversely. This would involve the use of bunded tanks, Fuel and oil based hydrocarbon Moderate - regular vehicle maintenance and Negligible contamination associated with Adverse minimisation of construction plant and machinery activity on related waste. Appropriate site. measures should be in place to Contamination of the ground due Moderate - deal with accidental spills and any Minor to activities relating to the Adverse wastes produced during development. This could include construction. Construction spillage of oils and fuel from plant activities would also require working at the site, chemical material management plans to be spillages and construction prepared and implemented to wastes, etc. audit waste materials and minimise potential adverse The potential for localised Moderate - impacts to the ground. Minor contamination associated with Adverse adjacent land uses.
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Removal of topsoil materials and Minor Negligible tracking of plant across uncovered cohesive bedrock material Removal of topsoil materials is Minor Negligible likely to increase surface run-off.
Post-completion stage Excluding unforeseen A regime of on-going activities/alterations undertaken geochemical/geotechnical within the individual housing assessment should be undertaken plots, the effects of the post- shortly after the development completion ground conditions are phase to review the impact of deemed to be the same as those construction activity. The in the construction stage. duration of this post-works assessment should be based on Activities undertaken within the Minor Negligible the achievement of designated individual housing plots. This site criteria. Post-work surveys could include spillages of oils, are carried out to confirm the fuels or other chemicals long-term effectiveness of the associated with vehicle and mitigation procedures undertaken household activities. during the construction phase. The potential for localised Moderate - Minor
contamination associated with Adverse adjacent land uses. There are few measures that may be put in place to minimise the The roads serving the Minor impact that individuals occupying Negligible development provide further the proposed development may potential for contamination of have on the ground conditions, the ground. The potential however the predominately presence of sewerage within the clayey nature of the mudstone ground also identifies a potential would help to contain any spillage for pollution of the site due to or contamination within any leakage or overflow from the isolated location and impede sewer network. transmission.
8.6.9 Should the site development progress, no further cumulative effects are predicted, and any residual impacts are likely to be the same as those discussed above.
8.7 Cumulative Impacts
8.7.1 As discussed previously there are no perceived significant residual impacts on the ground conditions of the site as a result of the proposed development. The proposed development of the application site, together with the development of any other sites within the surrounding area (Chilmington Green, Park Farm and Cheesemans Green) has the potential to give rise to cumulative effects, where the effects of different developments combine and result in greater or different effects from those which
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would arise from an individual development alone. Wardell Armstrong have reviewed records of similar assessments regarding proposed development of nearby sites.
8.7.2 The potential for cumulative effects in this environmental statement has been made on the basis of information held by Wardell Armstrong and as described in the historical environmental statements for potential developments in the immediate surrounding area.
8.7.3 The geology of the surrounding area and the application site are generally similar. The potential for the development of the surrounding area to give rise to significantly greater cumulative effects on local geology, ground conditions or mineral resources is considered to be very small. In addition, it is considered that the proposed site would not contribute to any additional cumulative effects on the ground conditions of the surrounding areas.
8.8 Conclusions
8.8.1 The potential environmental impacts with regard to ground conditions at the site have been assessed. The assessment has taken account of the potential for geotechnical and contaminative issues as a result of the existing ground conditions and the proposed development of the site.
8.8.2 The ground conditions for the site have been conjectured from desk study research which has included a review of geological information, historical mapping, and environmental information. The site is recorded to be agricultural land. The ground conditions are conjectured to predominately comprise strata of the Weald Clay Formation. This formation is characterised by dark grey thinly-bedded mudstones.
8.8.3 Consideration of the potential effects that the ground conditions may have on the development has identified the principal issues listed below:
• Localised softening of clay/cohesive materials;
• Desiccation of clay/cohesive materials;
• The possibility of clay/cohesive materials being at considerably shallow depths, which has the potential to heave/shrink due to the influence of trees;
• The potential for localised soil contamination associated with adjacent land uses, especially the potentially contaminative industries located within 200m of site (current and historical);
• The entire site and surrounding area indicated to be within a NVZ;
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• The presence of moderate slopes and variations in elevation across the site;
• The possible presence of localised ground gases associated with topsoil materials; and
• Presence of farm buildings across site (possibility of asbestos containing material used within construction of the building). Presence of historical and current farm buildings may also indicate disturbed Made Ground associated with the foundations of the buildings.
8.8.4 The impact that the proposed development may have on the ground conditions at the site has also been considered. There is a potential for disturbance and contamination of the ground during and after the construction of the development. The principle potential effect is during the construction phase of work with the risk of chemical spillages and disturbance of the ground by construction plant.
8.8.5 Appropriate method statements and risk assessments should be produced and adhered to by the contractor to ensure that the risk of contamination arising due to the contractor’s work is minimised.
8.8.6 As part of the detailed design works, following the formation of a detailed development layout, intrusive site investigation works should be undertaken to better characterise the site in terms of the above potential issues. This investigation would aid the design of foundations and confirm the contaminative status of the site.
8.8.7 The assessment undertaken as part of this environmental statement is adequate at this current stage of the works, and given the site’s past and present use, the assessment concludes residual effects will not be significant.
8.8.8 The desk study research did not identify any widespread potential contaminant sources on-site. No industrial processes or significant material storage has been identified at the site. However, sources of contamination may potentially exist within unforeseen ground conditions.
8.8.9 At the detailed design stage the topography of the site should be assessed with regards to a geotechnical review, indicating whether the site will require re-grading and possible retaining walls to accommodate any potential changes in site levels. Current access routes should be evaluated with regards to any future works, i.e. large plant access.
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8.8.10 The hydrogeological and hydrological assessment should also be reviewed together with this ground conditions assessment. This would allow for a full evaluation of potential sources of contamination from the wider area (in relation to groundwater and surface water pathways, i.e. groundwater flow and direction) to be undertaken.
8.8.11 It is considered likely that following any intrusive site investigation works at the more detailed stages, any issues relating to the shallow and deeper ground conditions could be addressed during the development of the site. Mitigation measures may include extending foundations to a deeper depth with more suitable allowable bearing capacity should the bedrock material be found to be either soft or excessively desiccated.
8.8.12 Should further assessment indicate contamination is present at the site, this could be addressed either using site-specific risk assessments or by undertaking remediation works designed to remove the linkage between source, pathway and receptor.
8.8.13 Suitable design of the development and management of the construction phases will minimise the impact on the ground, ensuring that no significant impacts are caused relating to the development of the site. This would include consideration of the hydrogeological regime at the site along with design to ensure that the development does not adversely affect the underlying strata. Management of the construction with appropriate material handling and waste minimisation would also reduce the potential for impacts on the ground.
8.8.14 It is considered that with appropriate precautions following development at the study area, there will not be any significant residual effects related to the ground conditions at the site.
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9 WATER RESOURCES
9.1 Introduction
9.1.1 This chapter presents an assessment of potential development impacts on surface water and groundwater resources. The assessment relates to the proposed development of up to 750 dwellings plus a local centre with community and retail use, associated open space (including allotments and areas of habitat enhancement), foul and surface water infrastructure, internal footpaths, cycle routes and estate.
9.1.2 It is proposed that new junctions are to be constructed along Ashford Road to provide major access points for the development. New internal roads will link into the existing road network at Bond Lane and Pound Lane.
9.1.3 The site is shown on Drawing ST13901-008.
9.1.4 The objective of this section of the ES is to establish baseline hydrological and hydrogeological conditions at the Kingsnorth Green site and in the surrounding area, including nationally and internationally designated sites which could be affected by the proposal and to assess the potential impact of the proposed development on the surface water and groundwater regime.
Review of Nationally and internationally designated sites
9.1.5 There is one of international importance within 10km of the site, Wye and Crundale Downs Special Area of Conservation (SAC). Wye and Crundale Downs (also designated as a SSSI) is designated for its chalk grassland and broad-leaved woodland.
9.1.6 Wye and Crundale Downs Special Area of Conservation is 9km to the north of the proposed development. Wye and Crundale Downs consists mostly of species-rich chalk grassland. The SAC is located within Lewes Nodular Chalk formation and New Pit Chalk formation, which are partially classed as Aquifer. However, the SAC is not located within the proposal’s catchment and there are no direct pathways from the proposal to the SAC. Therefore, it is not considered further in this assessment.
9.1.7 There are no nationally important sites located within 2km of the site. However, three nationally important sites are located between 3 and 5km from the site. These are:
• Alex Farm Pasture SSSI • Orlestone Forest SSSI • Ham Street Wood SSSI and National Natural Reserve
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9.1.8 The proposed development at Kingsnorth Green is located the Orlestone Forest and Alex Farm SSSI Impact Risk Zone. The Impact Risk Zones are a GIS tool used by Natural England to make a rapid initial assessment of the potential risks to Sites of Special Scientific Interest (SSSIs) posed by development proposals. They define zones around each SSSI which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts.
9.1.9 According to Natural England’s information, Orlestone Forest and Alex Farm SSSI could potentially be affected by all type of developments, including residential proposals. However, in terms of potential for the proposed development to affect the hydrology of Orlestone Forest and Alex Farm SSSI, it should be noted that the Kingsnorth Green site is downstream of the SSSI and there are no direct pathways from the proposal to the SSSI. Therefore this is not considered further in this assessment.
9.1.10 Additionally, there is a Local National Reserve, Ashford Green Corridor, approximately 3km to the north of the site.
9.1.11 A description of each site is given in Chapter 12, Ecology.
Legislation, Policy and Guidance
9.1.12 The following items of legislative framework, planning policy and guidance are considered to be relevant to the proposed development in the context of water resources:
• Legislative Framework: o Water Framework Directive 2000/60/EC; o Groundwater Directive 80/68/EEC; and o Water Act 2003. • Planning Policy: o National Planning Policy Planning Policy Statements; and o Local Planning Policy. • Guidance: o Control of Water Pollution from Construction Sites – Guide to Good Practice (CIRIA 2002); o Control of Pollution from Construction Sites C532 (CIRIA 2001); o Environmental Good Practice on Site C650 (CIRIA 2005); and o Control of Water Pollution from Linear Construction Projects C649 (CIRIA 2006).
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9.2 Assessment Methodology and Significance Criteria
Scope of the Assessment
9.2.1 The assessment of effects of the proposed development on hydrology and hydrogeology, including water levels and quality, incorporates the following:
• An assessment of the baseline conditions on the site, in the immediate surrounding areas and up to a 6km radius from the site; • An assessment of the potential impacts of the proposed development during construction and post-construction; • Mitigation measures to reduce impacts on hydrology and hydrogeology which may arise as a result of the proposed development; and • The residual impacts of the proposed development following the implementation of the proposed mitigation measures.
Assessment Methodology
9.2.2 This work has been carried out with reference to and in general accordance with relevant British Standards and the EA’s publication “A handbook for Scoping Projects 1”. In accordance with this guidance, mitigation measures are proposed to reduce significant potential negative impacts identified.
9.2.3 An additional document, produced by the Office of the Deputy Prime Minister (ODPM, 2000) entitled “Environmental Impact Assessment: A Guide to Procedures” includes a checklist (contained within Appendix 5 of the Guide) of matters to be considered in an ES, and recommends that all matters relating to water quality and quantity should ideally be dealt with in a single chapter. This approach is also in accordance with the principles of the Water Framework Directive (WFD), which is designed to improve and integrate the way water bodies are managed throughout Europe (i.e. promoting the conjunctive management of surface water and groundwater as a single resource). Flood risk has been treated in a separate report, but the relevant findings are integrated into this chapter.
9.2.4 For assessment of the water environment, the ODPM Guide to Procedures recommends, as a minimum, consideration of effects of any proposed development on the following:
• Surface water courses and drainage patterns; • Groundwater levels and flow directions;
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• Coastal or estuarine hydrology (where applicable); and • Ambient or baseline water quality.
9.2.5 The impact assessment process identifies and assesses the likely significant effects of the proposed development in relation to the construction and operation phases. Where effects (including cumulative and or compound effects) are deemed likely to be significant, monitoring and/or mitigation measures may be required and, in the case of the latter, re-assessment of residual effects will then also be necessary.
9.2.6 Environmental effects should be evaluated with reference to definitive standards and legislation where available. However, where it is not possible to quantify effects, qualitative assessments based on available knowledge and professional judgements are an acceptable alternative.
9.2.7 The criteria for determining the significance of impacts is based upon the following method:
probability of occurrence x magnitude of impact = risk of potential impacts; then risk of potential impacts x sensitivity of receptor = significance of potential effects.
9.2.8 Indicative criteria for the definition of magnitude of impacts and indicative classification of sensitivity of receptors are provided in Appendix 9.1.
9.2.9 This methodology considers the probability of an impact occurring and the magnitude of the impact, should it occur. Risk is considered to be Very High, High, Medium, Low or Very Low and is determined with reference to Table 9.1 below.
Table 9.1: Risk Classification of Potential Impacts Probability of Magnitude of Impact of Development Occurrence Major Moderate Minor Minimal High Very High Very High High Medium Medium Very High High Medium Low Low High Medium Low Very Low Negligible Medium Low Very Low Very Low
9.2.10 On the premise that impacts are consequences of the development, the criteria for determining the significance of those impacts is based upon the following method:
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Magnitude of impact x sensitivity of receptor = effect significance
9.2.11 Effect significance is considered to be Very High, High, Medium, Low, Very Low or Negligible as indicated in Table 9.2. If the significance of the potential effect is medium or higher, then it is considered significant in terms of the EIA and mitigation measures would be required.
Table 9.2: Effect Significance Sensitivity of Risk of Potential Impacts Receptor Very High High Medium Low Very Low Very High Very High Very High High Medium Low High Very High High Medium Medium Low Medium High Medium Medium Low Very Low Low Medium Medium Low Very Low Negligible Very Low Medium Low Very Low Negligible Negligible
9.3 Baseline Conditions
Published Sources of Information
9.3.1 The following sources of information have been reviewed to assess the baseline conditions:
• 1:625,000 Hydrogeology Map, England and Wales, 1977; • 1: 50,000 Geological Map Sheet 188, Cambridge, Solid and Drift edition; • Environment Agency Internet Database; • Environment Agency (2014). Information request response: o Discharge consented with conditions; o Source Protection Zones; o Water Abstractions; o Water available / not available map from CAMS; o Water Quality Samples; • Envirocheck Report, 56408042_1_1 May 2014; • Environment Agency, 2013, Stour Water Abstraction Licensing • Environment Agency, 2012, The State of Water in Kent • UK Technical Advisory Group on the Water Framework Directive, 2005, Classification Schemes in River Basin Planning: An Overview • WSP, 2010, Chilmington Green, Ashford Utilities Appraisal Summary
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Topography and Physical Features
9.3.2 The site comprises four parcels of land located to the south of the village of Kingsnorth in Kent. Kingsnorth itself is located approximately 3.5km to the south of the town centre of Ashford. An approximate grid reference at the centre of the site is TR 00078 38919 and the nearest postcode is TN23 3ES. A Site Location Plan is included as Drawing ST13901-008.
9.3.3 The site is located north of Magpie Hall Lane, south of Pound Lane, and either side of Ashford Road and Bond Lane in a rural location.
9.3.4 Residential properties are located along Ashford Road, Magpie Hall Lane, Pound Lane and Bond Lane in close proximity to the site, beyond which lies agricultural land.
9.3.5 The site comprises four parcels of land, as shown on Figure 9.1.
Figure 9.1 The Kingsnorth Green site (reproduced from Google Earth)
9.3.6 Ordnance Survey mapping shows the highest elevation to be approximately 50mAOD in the central parcel of the site. The land falls away from this high point in a north-
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westerly direction towards the north-western corner of the site at the boundary with Pound Lane. The elevation of the site in the north-western corner is approximately 37 - 40mAOD.
9.3.7 The land also falls away from the central high point in a south-westerly direction towards Magpie Hall Lane. The elevation of the site in the south-western corner, adjacent to Magpie Hall Lane, is approximately 43mAOD.
9.3.8 The south-eastern land parcel falls in a south-easterly direction towards the eastern site boundary. The elevation along the eastern site boundary of this land parcel is approximately 45mAOD.
9.3.9 The site is characterised by a number of fields, primarily used for agricultural purposes. A number of public footpaths and bridleways intersect the central and south-eastern land parcels, and an overhead power line crosses the south-western corner of the site.
Relevant Climate Information
9.3.10 The Met Office runs a weather station at Faversham, approximately 22km north of the site 2. The annual average rainfall for the period 1981 – 2010 for the nearest meteorological office weather station to the site is 645mm with the wettest months being June to August.
9.3.11 The UK Climate change projections 2009 for the South East Region predicted changes in precipitation under a medium emission scenario at 6% probability for the 2050s for summer and winter precipitation are detailed below 3:
• Summer Precipitation: o 2050s: -16% • Winter Precipitation: o 2050s:+6%
9.3.12 These climate change predictions indicate that summers will become drier and winters slightly wetter.
Hydrology Regional Hydrology
9.3.13 The site is located within the River Stour Catchment. The Stour Catchment Abstraction Management Strategy (CAMS) area covers 1,081km 2 and in addition to the River Stour
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and its tributaries, this strategy area includes the River Dour and the Dover Chalk block, the Isle of Thanet, and the Lydden Valley which receives water from the catchment of North and South Streams. The principal urban centres in the catchment are Ashford, Canterbury, Dover, Deal, Ramsgate and Margate.
9.3.14 The River Stour has two main tributaries. The Upper Great Stour originates at Lenham near Maidstone and the East Stour begins at Postling, near Folkestone. After the confluence of these two watercourses at Ashford, the river flows north-eastwards in a steep sided valley through the North Downs Area of Outstanding Natural Beauty to Canterbury. The Stour acts as a source of water for the lowland marshes either side through the operation of a number of pumping stations and gravitational feeds, controlled by sluices.
9.3.15 The majority of the area is dominated by Chalk. There are less permeable strata of Weald Clays underlying the southern parts of the catchment limits the contribution of baseflow to those upper reaches of the Great Stour. The geology determines the rivers’ flow regime, leading to low flows during summer and rapid runoff and flooding during the wetter months.
9.3.16 Approximately 65%, of water abstracted each year in the Stour catchment is drawn from groundwater sources. 51% of water abstracted from the environment is for public water supply 4.
9.3.17 The Environment Agency monitors the state of the catchment through Assessment Points (AP). The closer AP upstream of the site is located at South Willesborough. At this point the East Stour receives some spring flow from the Chalk and Lower Greensands, but much of its course and the courses of the Ruckinge Dyke and Whitewater Dyke pass over the less permeable Weald Clay. This gives rise to a more flashy flow regime, responding quickly and suffering from low flows between periods of significant rainfall.
9.3.18 The closer AP downstream of the site is by Wye, downstream of Ashford, where the flows of the Upper and East Stour Rivers combined. However, despite this increase in total flow, existing abstraction licences and new applications for consumptive abstraction are carefully assessed and controlled in order to protect other water users and the ecological status of the downstream reaches of the Stour.
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9.3.19 According to the Environment Agency’s report “The State of water in Kent” published in 2012, two-thirds of annual rainfall is lost to evapotranspiration and approximately 34% of rainfall reaches the water table recharging groundwater 5.
9.3.20 The National River Flow Archive monitors the Great Stour flow at Wye, approximately 9Km downstream of the site. Information for the Wye Gauging Station is detailed for the period 1962 – 2013. Relevant data is summarised in Table 9.3.
Table 9.3 Great Stour Flow Characteristics at Wye Item Unit Mean Flow (m3/sec) 2.2 Q95 (m3/sec) 0.5 Q70 (m3/sec) 0.9 Q50 (m3/sec) 1.42 Q10 (m3/sec) 4.7
Hydrology of the Site
9.3.21 The principle watercourse within the vicinity of the study area is the Whitewater Dyke which is located adjacent to the northern boundary of the site. Whitewater Dyke is a tributary of the Great Stour River, joining with the East Stour and then the Great Stour at Pledge’s Mill at the bottom of East Hill in Ashford, Kent.
9.3.22 The Whitewater Dyke runs from its source near Shadoxhurst, 5.6 kilometres, to the East Stour in Willesborough.
9.3.23 An unnamed watercourse flows in a north-westerly direction through the south- western parcel of the site, approximately 100m north of Magpie Hall Lane (See Area 2 and 3 at Figure 9.1). This watercourse connects into Whitewater Dyke to the west of the site.
9.3.24 Land drainage ditches are also present within the site, primarily along field boundaries. In particular, the available Ordnance Survey mapping shows a land drainage ditch flowing in a north-westerly direction along the southern boundary of the central land parcel, and two land drainage ditches flowing from Magpie Hall Lane in a northerly direction, within the south-western land parcel, and discharging to the unnamed watercourse.
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Surface Water Quality Regional Surface Water Quality
9.3.25 The Environment Agency Monitors the Great Stour water quality between Ashford and Wye, approximately 1km north (downstream) of the site. According to the Environment Agency data 6 the Great Stour between Ashford and Wye has the following characteristics.
Table 9.4 Great Stour water quality between Ashford and Wye Standards Characteristics Status Biological Quality According to the EA’s Moderate River Basin Management Plan 2009, the Great Stour is a River type 5 characterised by low altitude and predominantly calcareous geology (alkaline) Fish Moderate Macro invertebrates Good General Physico From Annex V of the Moderate Chemical Quality WFD Ammonia 0.3mg/l for lowland High with high alkalinity Dissolved Oxygen 54 for lowland with Moderate per cent saturation high alkalinity pH Between 9 and 6 High Phosphate 250 μg/l Moderate Note: Environment Agency data – UK Standard and conditions from UK Technical Advisory Group on the Water Framework Directive – UK Environmental Standards and Conditions 2008
9.3.26 The quality elements relevant in assessing ecological status and ecological potential for surface waters are:
• Biological quality elements (covering algae, plants, fish and invertebrates)2;
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• General physico-chemical quality elements 7.
9.3.27 The Great Stour therefore has a generally moderate biological and chemical status.
Surface Water Quality of the site
9.3.28 There is no information regarding the Whitewater Dyke. As discussed above, the Whitewater Dyke passes over the less permeable Weald Clay which suggests that the flow regime responds quickly to significant rainfall.
9.3.29 The entire area is classed as a nitrate vulnerable zone. Soils do not absorb excess nitrate ions, which then move downward freely with drainage water, and are leached into groundwater, streams and oceans. Excessive nitrogen compounds cause eutrophication in water bodies. Water is considered eutrophic if it contains levels of nitrogen compounds that cause excessive plant growth resulting in an undesirable disturbance to the balance of organisms present in the water and to the quality of the water.
Water Abstractions
9.3.30 EA records identify one surface water abstraction licence within 6km radius of the site. The locations of the water abstractions are shown on Drawing 9.1. The closest one is for agricultural purposes at Great Engeham Manor (approximately 5.8km to the south west).
9.3.31 The Envirocheck report confirms that there are no surface water, groundwater or potable water abstractions recorded within 500m of site.
Geology Made Ground
9.3.32 There are no records of Made Ground or landfill deposits within or adjacent to the application site. The potential for geological materials on site to be affected by landfill gas is therefore considered to be low.
7 UK Technical Advisory Group on the Water Framework Directive, 2005, Classification Schemes in River Basin Planning: An Overview
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Superficial Deposits
9.3.33 Published BGS data for the area (BGS Digital Geological map of Great Britain at 1:50,000 scale) indicates that there are minimal superficial deposits across the site area.
9.3.34 In central areas the site is underlain by small pockets of River Terrace Deposits (sand and gravel). This superficial deposit material is characterised by sand and gravel, locally with lenses of silt, clay or peat.
9.3.35 Small pockets of Alluvium (clay, silt, sand and gravel) are detailed as being sparsely present within the northern areas of site. This stratum is characterised by normally soft to firm consolidated, compressible silty clay, but can contain layers of silt, sand, peat and basal gravel. A stronger, desiccated surface zone may be present.
Solid Geology
9.3.36 Published BGS data indicates that the majority of site is immediately underlain by bedrock geology of the Weald Clay Formation. This Formation is characterised by dark grey thinly-bedded mudstones (shales) and mudstones with subordinate siltstones, fine to medium-grained sandstones, including calcareous sandstone, shelly limestones and clay ironstones.
Structural Geology
9.3.37 There are no geological faults recorded on the application site. More details are reported in Chapter 8.
Hydrogeology
9.3.38 The EA indicates that the small pockets of superficial deposits underlying the site are classified as a Secondary A Aquifer.
9.3.39 Secondary A Aquifers are permeable layers 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. These are generally aquifers formerly classified as minor aquifers.
9.3.40 The underlying solid bedrock of the Weald Clay Formation is classified as being an unproductive strata. Although some sections of this formation contain limestone and sandstone, the overall classification is that of a non-water bearing formation with low permeability.
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zones show the risk of contamination from any activities that might cause pollution in the area: the closer the activity, the greater the risk.
9.3.42 The site is not located within a Groundwater Source Protection Zone.
9.3.43 The EA also define how vulnerable the groundwater / aquifer is to contamination within the area (mainly due to geology transmissivity).
9.3.44 Groundwater vulnerability is a function of the geologic setting of an area, as this largely controls the amount of time that has passed since the water fell as rain, infiltrated through the soil, reached the water table, and began flowing to its present location.
9.3.45 The northern section of Area 1 has been designated as ‘Minor Aquifer – High Vulnerability’. This is the only area on site which has been designated with vulnerability higher than ‘Minor Aquifer – Low’. This is likely to be due to the superficial deposits (Alluvium) identified within the northern section of Area 1.
Conceptual Models
9.3.46 The proposed site is underlain by soils belonging to the Wickham 1 soil association which are characteristically seasonally waterlogged, with extensive mottling and gleying.
9.3.47 As discussed, the highest elevation is in the central parcel of the site. The land falls away from this high point in a north-westerly direction towards the north-western corner of the site at the boundary with Pound Lane.
9.3.48 The land also falls away from the central high point in a south-westerly direction towards Magpie Hall Lane.
9.3.49 The south-eastern land parcel falls in a south-easterly direction towards the eastern site boundary.
9.3.50 The majority of the site is immediately underlain by bedrock geology of the Weald Clay Formation. This formation is characterized by low permeability. Few pockets of superficial deposits are located within the site. According to the Environment Agency Stour Water Abstraction Licensing 8, the Whitewater Dyke is characterised by flashy flow regime suggesting that currently precipitation which occurs at the site is likely to
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flow toward the unnamed watercourse at the southern part of the site and toward the Whitewater Dyke or to be returned to the atmosphere by evapotranspiration.
9.4 Assessment of Impacts
9.4.1 Baseline hydrological and hydrogeological assessment has demonstrated that the proposed development site is located in the catchment of the Great Stour. It is therefore necessary to consider the potential for the proposed development to affect local surface water or groundwater resources.
9.4.2 The following paragraphs therefore consider:
• Identification and characterisation of potential hydrological and hydrogeological receptors; and • Assessment of effects during construction and post development phases.
Potential Receptors
9.4.3 Potential water receptors have been identified based on the hydrogeological and hydrological conceptual models constructed for the site:
• The Whitewater Dyke and Great Stour.
9.4.4 A horizontal pathway exists between the proposed site and surface water run-off, toward the Whitewater dyke from precipitation, before continuing to the Great Stour. The Great Stour supports water supply and sensitive habitats, therefore is considered to be of Medium sensitivity according to the criteria in Appendix 9.1.
Potential Impacts
9.4.5 The following paragraphs consider the identified receptors and the potential impacts of the proposed development. The potential impacts relate both to the construction phase and the post-development phase.
9.4.6 The impact assessment considers the following:
• Potential impacts on surface water flow and quality in the Great Stour tributary.
Effects on surface water flows Construction Phase
9.4.7 There are a number of potential impacts which may result from the construction phase of the development. Removal of topsoil materials and tracking of plant across uncovered cohesive bedrock material may cause additional weathering and
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disturbance to the shallow ground conditions and could result in softening and rutting of the surface.
9.4.8 Removal of topsoil materials is likely to increase surface run-off.
9.4.9 It is possible that contamination of the ground may occur due to activities relating to the development. This could include spillage of oils and fuel from plant working at the site, chemical spillages and other contaminants, reaching controlled water.
9.4.10 There is a direct pathway between the site and the Whitewater Dyke and, without mitigation measures, it is considered that the probability of the impact to occur would be high. The magnitude of the impact is considered moderate adverse leading to medium adverse significance.
9.4.11 Surface water drainage during the construction phase of the proposed development will be managed on-site through the adoption of standard pollution prevention measures and the use of soakaway systems for the final discharge of clarified surface water. There will be no planned off-site discharge of surface water. In the event of a failure of on-site drainage systems there could be the potential for discharge of excess surface water onto adjacent land.
Post-development
9.4.12 Surface water runoff is proposed to be managed in a sustainable manner through the use of Sustainable Drainage Systems (SuDS). SuDS provide a range of benefits, including flood risk management, in comparison to conventional piped drainage systems. In particular SuDS can reduce the rate and volume of surface water runoff, act as conveyance routes, provide water quality treatment, and enhance amenity and biodiversity when designed as part of a suitable SuDS management train.
9.4.13 An Indicative Surface Water Management Plan has been produced and is included in the separate Flood Risk assessment as Drawing ST13901-014. Options for SuDS within different areas of the proposed development are outlined in the separate FRA.
9.4.14 It is proposed that open SuDS features such as a ponds, wetlands or detention basins, or a combination of these are provided at the downstream end of the surface water drainage systems. This provides a site control feature for managing surface water runoff and a temporary storage area for flows that exceed the design capacity of the system.
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9.4.15 In addition, the open SuDS feature will also provide a final stage of treatment to ensure that water quality standards are met.
9.4.16 Due to the size and topography of the site, it is considered likely that the surface water drainage for the development will require multiple discharge points. There are a number of potential surface water outfall locations available for the development as shown on the Indicative Surface Water Management Plan (Drawing ST13901-014).
9.4.17 As the proposed development is to include a SuDS based surface water drainage system, the potential risk of adverse impact on surface water systems would therefore be minimal with high probability of occurrence and the significance of the potential effect will be medium. As the SuDS drainage system forms part of the proposed design of the site no additional mitigation is required.
9.4.18 There is the potential for the proposal to have an indirect impact on the Great Stour due to generation of foul water.
9.4.19 It is proposed that foul water will be discharged to the public foul sewerage network. Southern Water has stated that the public sewerage network cannot currently accommodate the anticipated foul flow rates from the development without the installation of further off-site sewers or significant upgrades to the current sewerage network. However, Southern Water has stated that there is sufficient capacity to accommodate the site at Ashford Waste water Treatment Works (see separate Utilities Report, Appendix 3.2). Subject to upgrade to the network, it is considered that Southern Water has the capacity to treat the additional foul water generated by the proposals at Ashford WwTW and therefore no indirect impact is likely to arise from the proposal. No additional mitigation measures are required.
9.5 Mitigation
9.5.1 SuDS drainage forms part of the proposed design of the site and no additional mitigation measures are required once the proposed development site has been completed. Significant impacts could potentially arise from the construction phase of the proposed development which will require mitigation measures to be implemented, as follows.
Surface water levels, flow and quality
9.5.2 Best practices will be adopted during construction to prevent adverse impacts to the nearby controlled water. A Construction Environmental Management Plan will be developed and implemented to ensure that risks of spills and leaks are minimised. All
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fuels, oils and other potentially polluting materials will be stored in appropriate containers and within a bunded compound in accordance with the EA’s Guidance Note on Pollution Prevention 6: Working at Construction and Demolition Sites. If contamination occurs to localised surface water at the construction site, then this will not be allowed to reach the ground. This water will be collected in temporary retention basins and then disposed of, under licence, via local foul sewer or by another appropriate method.
9.5.3 The FRA for the site confirms that SuDS elements will be incorporated as part of the proposed development to reduce potential drainage impacts.
9.5.4 Water derived from highways, car parks and driveways will flow through pre- treatment devices such as trapped gullies and oil/water interceptors to aid settlement of particulates and remove oils, before entering the SuDS.
9.6 Residual impacts
9.6.1 During construction activities there is the potential for materials such as fuel to be spilled or to leak from construction plant. These potential impacts will be mitigated by adopting best practices. Following the implementation of mitigation measures, the residual impact is considered to be minimal with a low probability of occurrence leading to low significance.
9.6.2 A reduction in the permeable surface area of a site would typically lead to a reduction in rainwater infiltration and groundwater recharge and a corresponding increase in surface water runoff. It is however proposed that the development will include SuDS. Following the implementation of mitigation measures, the residual impact is considered to be minimal with a low probability of occurrence leading to low significance.
9.6.3 The continued use of vehicles, with associated storage of fuels and oils, once the site is developed will represent a potential source of contamination to the nearby water and ground. Pre-treatment devices such as trapped gullies and oil/water interceptors to aid settlement of particulates and remove oils will be implemented as mitigation measures. Therefore following mitigation the impact is minimal with medium probability of occurring and the significance is low.
9.6.4 See Table 9.5 for a summary of residual impacts.
Table 9.5 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of mitigation) residual effect ST13901/001 Page 89 June 2015
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Construction stage Removal of topsoil materials and Medium - Adverse Adoption of Construction Low tracking of plant across Environmental Management Plan. uncovered cohesive bedrock All fuels, oils and other potentially material - increase surface run- polluting materials will be stored off. in appropriate containers and within a bunded compound in
accordance with the EA’s Contamination of the ground due Medium - Adverse Guidance Note on Pollution Low to activities relating to the Prevention 6: Working at development. This could include Construction and Demolition spillage of oils and fuel from plant Sites. If contamination occurs to working at the site, chemical localised surface water at the spillages and construction construction site, then this will wastes, etc. not be allowed to reach the ground. This water will be collected in temporary retention basins and then disposed of, under licence, via local foul sewer or by another appropriate method. Post-completion stage Reduction in the permeable Medium – Adverse Adoption of SuDS drainage Low surface area of a site would system as part of the proposed typically lead to a reduction in design of the site no additional rainwater infiltration and mitigation is required groundwater recharge and a corresponding increase in surface water runoff Continued use of vehicles, with Medium- Adverse Pre-treatment devices such as Low associated storage of fuels and trapped gullies and oil/water oils, once the site is developed interceptors to aid settlement of will represent a potential source particulates and remove oils will of contamination to the nearby be implemented water and ground. Indirect impact on the Great Medium – Adverse Foul water will be discharged to Negligible Stour due to generation of foul the public foul sewerage network. water Southern Water has stated that there is sufficient capacity to accommodate the site at Ashford Waste water Treatment Works subject to Upgrades to the network
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9.7 Cumulative impacts
9.7.1 The potential for cumulative effects in this environmental statement has been assessed on the basis of information held by Wardell Armstrong and provided in the planning applications submitted for proposed schemes in the surrounding area.
9.7.2 There are no perceived significant residual impacts as a result of the proposed development. The proposed development of the application site, together with the development of any other sites within the surrounding area (as discussed in Chapter 16 of the ES) has the potential to give rise to cumulative effects, where the effects of different developments combine and result in greater or different effects from those which would arise from an individual development alone. Records of similar assessments regarding the proposed development of nearby sites have been reviewed.
9.7.3 Chilmington Green is considered to be the only scheme in the surrounding area to have a potential combined effect with this proposal due to its size and proximity.
9.7.4 In terms of surface drainage, the Chilmington Green, Ashford Utilities Appraisal Summary produced by WSP on behalf of Ashford Borough Council in March 2012 states that the Chilmington Green site generally falls in elevation from north to south with the exception of the Brisley Farm area which falls east. The catchment descriptions confirms that the site straddles two main catchment areas: the River Stour to the east; and River Beult to the west.
9.7.5 The review of the Flood Risk Assessment prepared in connection with the application confirms that Brisley Farm in the north is the only area within the site to drain towards the Stour. The remainder of the development site drains towards the River Beult, with no combined effect with this proposal.
9.7.6 Regarding the northern part of Chilmington Green, it is proposed to use SuDS features to ensure greenfield run-off rates are achieved.
9.7.7 Therefore, it is not considered that development of the two schemes would result in a cumulative impact.
9.7.8 Regarding foul water, the review of the Chilmington Green, Ashford Utilities Appraisal Summary states that foul water from the site can be catered for by Bybrook Waste Water Treatment Works. Therefore, it will not have a cumulative impact with this proposal.
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10 NOISE AND VIBRATION
10.1 Introduction
10.1.1 This chapter assesses the noise and vibration impacts of the proposed development. In particular it considers:
• The potential effects of noise and vibration from the construction of the proposed development on existing sensitive receptors; and
• The potential impact of changes in noise at existing sensitive receptors during the operational phase of the proposed development; and • The potential impact of existing noise sources on the proposed noise sensitive areas of the proposed development. 10.1.2 The chapter describes the methods used to assess the noise and vibration impacts, the current baseline conditions at and in the vicinity of the proposed development, the potential direct and indirect impacts of the proposed development arising from noise and vibration and, the mitigation measures required to prevent, reduce, or offset the impacts and the residual impacts.
10.2 Planning Policy Context
National
10.2.1 An assessment is required to consider any potentially noise sensitive areas of the proposed development, i.e. the proposed residential area. The potential effects of the existing and future sources of noise on the proposed residential area of the proposed development have been assessed with reference to the following guidance:-
• National Planning Policy Framework, 2012;
• Noise Policy Statement for England 2010;
• World Health Organisation’s (WHO) Guidelines for Community Noise 1999;
• British Standard 8233: 2014 “Sound insulation and noise reduction for buildings – Code of practice” (BS8233);
• British Standard 4142:2014 (BS4142), “Methods for rating and assessing industrial and commercial sound”;
• BRE Controlling particles, vapour and noise pollution from construction sites, Parts 1 to 5, 2003;
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• British Standard 5228 -1:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 1: Noise” (BS5228-1);
• British Standard 5228-2:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 2: Vibration” (BS5228-2);
• Department of Transport’s memorandum, “Calculation of Road Traffic Noise” (CRTN), 1988; and
• Acoustic Design of Schools: Performance Standards Building Bulletin 93; 2014 (BB93:2014);
National Planning Policy Framework (March 2012)
10.2.2 In March 2012 the ‘National Planning Policy Framework’ (NPPF) was introduced as the current planning policy guidance within England. Paragraph 123 of the NPPF states:
10.2.3 “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 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.”
10.2.4 With regard to “ adverse impacts” the NPPF refers to the ‘Noise Policy Statement for England’ (NPSE), which defines three categories, as follows:
• NOEL – No Observed Effect Level
This is the level below which no effect can be detected. In simple terms, below this level, there is no detectable effect on health and quality of life due to the noise
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This is the level above which adverse effects on health and quality of life can be detected
• SOAEL – Significant Observed Adverse Effect Level
This is the level above which significant adverse effects on health and quality of life occur’
10.2.5 The first aim of the NPSE states that significant adverse effects on health and quality of life should be avoided. The second aim refers to the situation where the impact lies somewhere between LOAEL and SOAEL, and it requires that all reasonable steps are taken to mitigate and minimise the adverse effects of noise. However, this does not mean that such adverse effects cannot occur.
10.2.6 The Planning Practice Guidance (PPG) provides further detail about how the effect levels can be recognised. Above the NOEL noise becomes noticeable, however it has no adverse effect as it does not cause any change in behaviour or attitude. Once noise crosses the LOAEL threshold it begins to have an adverse effect and consideration needs to be given to mitigating and minimising those effects, taking account of the economic and social benefits being derived from the activity causing the noise. Increasing noise exposure further might cause the SOAEL threshold to be crossed. If the exposure is above this level the planning process should be used to avoid the effect occurring by use of appropriate mitigation such as by altering the design and layout. Such decisions must be made taking account of the economic and social benefit of the activity causing the noise, but it is undesirable for such exposure to be caused. At the highest extreme the situation should be prevented from occurring regardless of the benefits which might arise. Table 10.1 summarises the noise exposure hierarchy.
Table 10.1 Noise Exposure Hierarchy
Increasing Effect Perception Examples of Outcomes Action Level No specific Not noticeable No Effect No Observed Effect measures required Noise can be heard, but does not cause any change in behaviour or attitude. Can No specific Noticeable and No Observed adverse slightly affect the acoustic character of the measures not intrusive Effect area but not such that there is a perceived required change in the quality of life. Lowest Observed
Adverse Effect Level
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Noise can be heard and causes small changes in behaviour and/or attitude, e.g. turning up volume of television; speaking more loudly; closing windows for some of Mitigate and Noticeable and Observed Adverse the time because of the noise. Potential for reduce to a intrusive Effect non-awakening sleep disturbance. Affects minimum the acoustic character of the area such that there is a perceived change in the quality of life. Significant Observed
Adverse Effect Level The noise causes a material change in behaviour and/or attitude, e.g. having to keep windows closed most of the time, avoiding certain activities during periods of Noticeable and intrusion. Potential for sleep disturbance Significant Observed Avoid disruptive resulting in difficulty in getting to sleep, Adverse Effect premature awakening and difficulty in getting back to sleep. Quality of life diminished due to change in acoustic character of the area. Extensive and regular changes in behaviour and/or an inability to mitigate effect of noise leading to psychological stress or Noticeable and Unacceptable physiological effects, e.g. regular sleep Prevent very disruptive Adverse Effect deprivation/awakening; loss of appetite, significant, medically definable harm, e.g. auditory and non-auditory.
Noise from earthworks and Construction Phase Activities
10.2.7 The activities associated with the earthworks and construction phase of the proposed development will have the potential to generate noise and create an impact on the surrounding area.
10.2.8 Guidance on the prediction and assessment of noise from development sites is given in British Standard 5228 -1:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 1: Noise” (BS5228-1), and BRE Controlling particles, vapour and noise pollution from construction sites, Parts 1 to 5, 2003.
10.2.9 Construction noise can have disturbing effects on the surrounding neighbourhood. The effects are varied and are complicated further by the nature of the site works, which will be characterised by noise sources which will change location throughout the construction period. The duration of site operations is also an important
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consideration. Higher noise levels may be acceptable if it is known that the levels will occur for a limited period.
10.2.10 For the purposes of this assessment, the occupants of residential properties in the vicinity of the proposed development are considered to be the receptors most likely to be affected by the construction phases of the proposed development. Details of the receptors are set out in Table 10.2, and shown in Drawing 10.1.
Table 10.2 Existing Noise Sensitive Receptor Locations (Construction Noise)
Grid Ref Approximate Receptor Bearing Distance to Receptor Address Type from Site Site Easting Northing Boundary Nordale, Pound ESR 1 Residential 600061 139423 North (Area 1) Adjacent Lane
Jasmine, Mill Hill ESR 2 Residential 600036 139160 South (Area 1) Adjacent Ashford Road
St. Helens, Mill North East ESR 3 Residential 599894 138694 Adjacent Hill Ashford Road (Area 2) Goatley Farm ESR 4 House, Magpie Residential 599752 138488 South (Area 2) Adjacent Hall Road Mill End, Mill Hill ESR 5 Residential 600096 139072 North (Area 3) Adjacent Ashford Road
The Firs, Mill Hill South West ESR 6 Residential 599947 138675 Adjacent Ashford Road (Area 3)
Oakhurst, Bond ESR 7 Residential 600345 138689 East (Area 3) Adjacent Lane
Bond Cottage, ESR8 Residential 600528 138768 East (Area 3) Adjacent Bond Lane
The Farm House, ESR9 Residential 600346 138615 West (Area 4) Adjacent Bond Lane
South East ESR10 3 Bond Lane Residential 600166 138488 Adjacent (Area 3)
Kiln Farm, Bond North East ESR11 Residential 600693 138642 10m Lane (Area 4)
Herondell, East ESR 12 Residential 600804 138328 100m Stumble Lane (Area 4)
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10.2.11 The enabling and construction works will be restricted to daytime hours, specified by the local authority. Details of the noise survey carried out at the sensitive receptors are set out in this chapter.
10.2.12 In addition to the guidance from the local authority, the Control of Pollution Act 1974 (COPA 1974) gives the local authority power to serve a notice under Section 60 imposing requirements as to the way in which works are to be carried out. This could specify times of operation, maximum levels of noise which should be emitted and the type of plant which should or should not be used.
10.2.13 However it might be preferable for the chosen contractor to obtain prior consent under Section 61 of COPA 1974. Section 61, enables anyone who intends to carry out works to apply to the local authority for consent. Under Section 61 the local authorities and those responsible for construction work, have an opportunity to settle any problems, relating to the potential noise, before work starts.
10.2.14 In addition to COPA 1974, BS5228-1 provides guidance on significance criteria for assessing the potential noise impacts associated with the construction phase of large projects. For the purposes of this noise assessment, the noise likely to be generated by the earthworks and construction phase, have been assessed against significance criteria established, using the BS5228-1 ABC Method.
10.2.15 The ABC method for determining significance criteria requires the ambient noise levels at existing sensitive receptors to be determined. The ambient noise levels at each existing receptor location are then rounded to the nearest 5dB(A) to determine the appropriate threshold value in accordance with the category value A, B or C, as detailed in Table 10.3.
Table 10.3 Thresholds of Significant Impact from Construction Noise at Residential Receptors in accordance with the ABC Method of BS5228-1
Assessment Category and Threshold Value, in decibels (dB) Threshold Value Period (LAeq) Category A *1 Category B *2 Category C *3 Daytime (0700 to 1900 hours) and Saturdays (0700 to 1300 65 70 75 hours) *1 Category A: Threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are less than this value. *2 Category B: Threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are the same as Category A values. *3 Category C: Threshold values to use when ambient noise levels (when rounded to the nearest 5dB) are higher than Category A values.
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10.2.16 The noise level likely to be generated at the receptor during the construction phase, i.e. the ambient noise level plus construction noise, is then compared to the appropriate category value. If the noise level is greater than the appropriate category value, a significant noise impact may be registered.
10.2.17 For the purposes of this chapter it is possible to estimate the degree of impact from the site works (earthworks and construction), according to the suggested standards, by reference to the time periods during which noise levels may occur in excess of the quoted values. These levels can be seen in Table 10.4.
Table 10.4 Construction Noise Assessment Significance Criteria
Magnitude of Impact Criteria for assessing Construction Noise Impact Noise levels exceed the Assessment Category threshold level for the duration of Large the construction works. Noise levels exceed the Assessment Category threshold level for periods of more Medium than one month, but for significantly less than the whole duration of the construction works. Noise levels exceed the Assessment Category threshold level for periods of less Small than one month. Noise levels do not exceed the Assessment Category threshold level during any Negligible period.
10.2.18 The construction phase assessment will be carried out for, Existing Sensitive Receptors 1 to 11. Impacts will also be felt at receptors adjacent to and beyond those listed in Table 10.2. However impacts at these receptors will be less than at the listed receptors.
10.2.19 The daytime measured noise levels, from the baseline noise survey representative of the existing sensitive receptors have been provided below in Table 10.5.
Table 10.5 Construction Noise Assessment Criteria
Noise Level above which activities of Ambient Noise Level Appropriate Category Average Measured the Construction Rounded to the Value A, B or C in Receptor Noise Levels Phase may cause a nearest 5dB(A) accordance with (dB L Aeq ) significant impact at (dB L Aeq ) BS5228-1 the Receptor
(dB L Aeq )
ESR 1 (Monitoring 52 50 A 65 Location 1)
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ESR 2 (Monitoring 64 65 B 70 Location 2) ESR 3 (Monitoring 66 65 B 70 Location 4) ESR 4 (Monitoring 62 60 A 65 Location 5) ESR 5 (Monitoring 52 50 A 65 Location 6) ESR 6 (Monitoring 54 55 A 65 location 4) ESR 7 (Monitoring 47 45 A 65 Location 9) ESR8 (Monitoring 47 45 A 65 Location 9) ESR9 (Monitoring 47 45 A 65 Location 9) ESR10 (Monitoring 54 55 A 65 Location 3) ESR11 (Monitoring 47 45 A 65 Location 9) ESR12 (Monitoring 46 45 A 65 Location 10)
10.2.20 The noise assessment for the construction phase details baseline daytime noise levels measured at sensitive receptor locations and outlines the main construction activities that could give rise to noise impacts at receptors in the vicinity of the proposed development. It also sets out details of ‘best practice’ management and control measures to ensure that impacts are minimised as far as possible.
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Noise from Construction Vehicles
10.2.21 In addition to the earthworks and construction activities, vehicle movements to and from the proposed development have the potential to generate noise at existing sensitive receptors, in the immediate vicinity of the local road network
10.2.22 At this stage, detailed traffic data relating to the likely numbers of construction vehicles is not available. However, the number of construction vehicles is not considered to be significant, relative to the existing flows on the major road links surrounding the proposed development. It is therefore considered that the level of road traffic noise at sensitive receptor locations will not change significantly due to construction vehicles during the construction phases of the proposed development and this impact has not therefore been considered further.
Vibration from Construction Plant and Vehicles
10.2.23 Work involving heavy plant on an open site is likely to generate vibration, which may, in certain circumstances, propagate beyond the boundary of the proposed development. In situations where particularly heavy plant, vibrating compaction equipment or piling rigs are being used close to the proposed development boundary, nearby properties may experience ground-borne vibration.
10.2.24 The existing sensitive receptors most likely to be affected by vibration generated by the earthworks and construction phase works of proposed development are detailed in Table 10.2.
10.2.25 Guidance on the assessment of vibration from development sites is given in British Standard 5228 -2:2009 “Code of Practice for noise and vibration control on construction and open sites – Part 2: Vibration” (BS5228-2). BS5228-2 2009 indicates that vibration can have disturbing effects on the surrounding neighbourhood; especially where particularly sensitive operations may be taking place. The significance of vibration levels which may be experienced adjacent to a site is dependent upon the nature of the source.
10.2.26 It is not possible to mitigate vibration emissions from an open site. It is important therefore to examine the proposed working method to ascertain what, if any, operations would be likely to cause unacceptable levels of vibration at nearby sensitive locations. It is possible that these operations could be modified to reduce their vibration impacts.
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10.2.27 BS5228-2 indicates that the threshold of perception is generally accepted to be between a peak particle velocity (PPV) of 0.14 and 0.3mm/sec. In an urban situation it is unlikely that such vibration levels would be noticed. BS5228 also indicates that it is likely that vibration of 1.0 mm/s in residential environments will cause complaint, but can be tolerated if prior warning and explanation have been given to residents. The standard also indicates that 10 mm/s is likely to be intolerable for any more than a very brief exposure to this level.
10.2.28 The Highways Agency Research report No. 53 “Ground Vibration caused by Civil Engineering Works” 1986 suggests that, when vibration levels from an unusual source exceed the human threshold of perception, complaints may occur. The onset of complaints due to continuous vibration is probable when the PPV exceeds 3mm/sec.
10.2.29 British Standard BS6472: 2008 “Guide to Evaluation of human exposure to vibration in buildings. Part 1: Vibration sources other than blasting” (BS6472-1) suggests that adverse comments or complaints due to continuous vibration are rare in residential situations below a PPV of 0.8mm/sec. Continuous vibration is defined as “vibration which continues uninterrupted for either a daytime period of 16 hours or a night-time period of 8 hours”. The proposed earthworks and construction works at the site will not cause continuous vibration as defined in BS6472-1.
10.2.30 Human perception of vibration is extremely sensitive. People can detect and be annoyed by vibration before there is any risk of structural damage. Cases where damage to a building has been attributed to the effects of vibration alone are extremely rare; even when vibration has been considered to be intolerable by the occupants.
10.2.31 It is not possible to establish exact vibration damage thresholds that may be applied in all situations. The likelihood of vibration induced damage or nuisance will depend upon the nature of the source, the characteristics of the intervening solid and drift geology and the response pattern of the structures around the site. Most of these variables are too complex to quantify accurately and thresholds of damage, or nuisance, are therefore conservative estimates based on a knowledge of engineering.
10.2.32 Where ground vibration is of a relatively continuous nature, there is a greater likelihood of structural damage occurring, compared to transient vibration; for example that caused by transiting vehicles.
10.2.33 BS5228-2 2009 suggests that the onset of cosmetic damage is 15mm/sec (15 mm/s at
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4 Hz increasing to 20 mm/s at 15 Hz for residential or light commercial type buildings).
10.2.34 The adverse residual impacts are assessed against the categories set out in Table 10.6.
Table 10.6 Construction Vibration Assessment Significance Criteria
Magnitude of Impact Criteria for Assessing Construction Vibration impact
> 10mm per sec. Vibration likely to be intolerable for more than brief exposure. Large Approaching the level at which cosmetic damage may occur in light structures.
5mm - 10mm per second. Tolerance less likely even with prior warning and Medium explanation.
1mm – 5mm per second. Complaints are likely, but can be tolerated if prior warning Small and explanation given.
Negligible < 1mm per second. Below level at which complaints are likely.
Road Traffic Noise and Existing Sensitive Receptors
10.2.35 The operational phase of the proposed development will generate additional traffic movements on the existing road network and the site access roads which run through the site. Additional vehicle movements have the potential to increase road traffic noise levels at existing receptors located adjacent to the main routes to and from the proposed development.
10.2.36 The current and future road traffic noise levels at a number of sensitive receptors; both with and without the proposed development in place, have been predicted using the calculation procedures set out in CRTN. The memorandum was prepared to enable entitlement under the Noise Insulation Regulations 1975 to be determined; but it is stated in the document, that the guidance is equally appropriate for the calculation of traffic noise for land use planning purposes.
10.2.37 For the assessment of traffic noise, CRTN has been used to determine the noise levels at Operational Existing Sensitive Receptors (OESR) detailed in Table 10.7.
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Table 10.7 Operational Existing Noise Sensitive Receptor Locations (Road Traffic Noise)
Approximate Grid Ref Bearing Receptor Address Receptor Type Distance to Site from Site Easting Northing Boundary North OESR 1 37 Riverside Close Residential 600165 139511 130m (Area 1)
North OESR 2 21 Pound Lane Residential 600165 139465 20m (Area 1)
North OESR 3 Ashford Road Residential 600136 139386 60m (Area 1) North OESR 4 School House Residential 600182 139361 80m (Area 3)
East OESR 5 8 Myrtle Court Residential 600122 139280 20m (Area 1)
East OESR 6 Highview Residential 600053 139186 Adjacent (Area 1)
South West OESR 7 1 Council House Residential 599942 138681 Adjacent (Area 3)
West OESR 8 The Birches Residential 599392 138568 60m (Area 2)
Goatley Farm South OESR 9 Residential 599756 138479 Adjacent House (Area 2)
South OESR 10 First Stop Residential 599843 138440 10m (Area 2)
South OESR 11 1 Bond Lane Residential 600156 138453 30m (Area 3)
Kingsnorth CofE North OESR 12 School 600525 139306 220m Primary School (Area 3)
East OESR 13 Bond Cottage Residential 600531 138767 0m (Area 3)
Old Mumford Northeast OESR 14 Residential 600796 138944 100m Farm (Area 3)
North OESR15 Woodcock Green Residential 600943 138737 300m (Area 4)
East OESR 16 Warren Cottage Residential 600814 138265 140m (Area 4)
10.2.38 The traffic information for the proposed development has been provided by Peter Brett Associates LLP and includes HGV percentage and speed limits for each of the links. The traffic data has been provided in scenarios that include one future year with and without the proposed development. It is understood that there are no other
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committed developments in the area that need consideration within the traffic assessment undertaken by Peter Brett Associates LLP. Therefore there are no other committed developments in the area that need consideration within the noise assessment.
10.2.39 Impacts will also be felt at receptors adjacent to and beyond those listed in Table 10.7. However impacts at these receptors will be less than at the listed receptors.
10.2.40 The changes in road traffic noise levels have been assessed against a set of significance criteria. The criteria shown in Table 10.8 are based upon guidance contained within the Design Manual for Roads and Bridges, Volume 11, Section 3, Part 7, 2011 (DMRB) for the assessment of changes in road traffic noise. The criteria do not relate to the actual existing noise levels (i.e. traffic noise due to current residential development) but only the predicted changes.
Table 10.8 Road Traffic Noise Assessment Significance Criteria
Magnitude of Impact Criteria for Assessing Road Traffic Noise
> 10.0 dB increase or decrease in traffic noise (equating to a clearly perceptible Large / Large Beneficial increase in the loudness of noise). Medium / Medium 5.0 – 9.9 dB increase or decrease in traffic noise (equating to an increase in the Beneficial loudness of the noise which is at or about the threshold of perception)
Small / Small Beneficial 3.0 – 4.9 dB increase or decrease in traffic noise
Negligible 0.1 – 2.9 dB increase in traffic noise.
Road Traffic Noise and proposed Sensitive Receptors
10.2.41 In addition to existing sensitive receptors, a road traffic noise assessment has been carried out for identified sensitive receptors to assess the noise impact of the development led traffic on proposed receptors.
10.2.42 The future road traffic noise levels at a number of proposed sensitive receptors with the proposed development in place have also been predicted using the calculation procedures set out in CRTN.
10.2.43 Noise from development led traffic has been predicted using the methodology described for the proposed sensitive receptors described in Table 10.9 below, and shown on Drawing 10.1.
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Table 10.9 Proposed Sensitive Receptor Locations (Road Traffic Noise)
Grid Ref Receptor Receptor Type Location Easting Northing
Situated adjacent to the eastern PSR 1 Residential boundary of ‘Area 1’ adjacent to 600085 139267 Ashford Road. Situated in the north western part PSR 2 Commercial of ‘Area 3’ adjacent to Ashfield 600093 139201 Road. Situated in the south western part PSR 3 Residential of ‘Area 3’ adjacent to Ashfield 599940 138699 Road.
Situated in the eastern part of PSR 4 Residential 599850 138522 ‘Area 2’ adjacent to Ashfield Road.
Situated in the south eastern part PSR 5 Residential of ‘Area 2’ adjacent to Ashfield 599799 138483 Road and Magpie Hall Road.
Situated in the south eastern part PSR 6 Residential 600186 138494 of ‘Area 3’ adjacent to Bond Lane.
Situated in the central part of ‘Area 3’ adjacent to proposed PSR 7 Commercial 600234 138821 access roads off of Ashfield Road and Bond Lane. Situated in the southern part of ‘Area 4’ adjacent to Steeds Lane PSR 8 Residential 600438 138382 and the proposed access road off of Steeds lane. Situated in the south eastern PSR 9 Residential corner of ‘Area 4’ adjacent to 600646 138299 Steeds Lane. Situated in the eastern part of ‘Area 3’ adjacent to Bond Lane PSR 10 Residential 600422 138695 and the proposed access road off Bond Lane. Situated in the western part of ‘Area 4’ adjacent to Bond Lane PSR 11 Residential 600397 138644 and the proposed access road off Bond Lane. Situated in the central part of ‘Area 3’ adjacent to proposed PSR 12 Primary School 600208 138894 access roads off of Ashfield Road and Bond Lane.
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Industrial Noise and Existing Sensitive Receptors
10.2.44 British Standard 4142:2014 (BS4142), “Methods for rating and assessing industrial and commercial sound”, is used to rate and assess sound of an industrial and/or commercial nature including:
• sound from industrial and manufacturing processes;
• sound from fixed installations which comprise mechanical and electrical plant and equipment;
• sound from the loading and unloading of goods and materials at industrial and/or commercial premises; and;
• sound from mobile plant and vehicles that is an intrinsic part of the overall sound emanating from premises or processes, such as that from forklift trucks, or that from train or ship movements on or around an industrial and/or commercial site.
10.2.45 The standard is applicable to the determination of the following levels at outdoor locations:
• rating levels for sources of sound of an industrial and/or commercial nature; and
• ambient, background and residual sound levels, for the purposes of:
1) Investigating complaints;
2) Assessing sound from proposed, new, modified or additional source(s) of sound of an industrial and/or commercial nature; and
3) Assessing sound at proposed new dwellings or premises used for residential purposes.
10.2.46 The purpose of the BS4142 assessment procedure is to assess the significance of sound of an industrial and/or commercial nature.
10.2.47 BS4142 refers to noise from the industrial source as the ‘specific noise’ and this is the term used in this report to refer to noise which is predicted to occur due to activities associated with the proposed operations. The ‘specific noise’ levels, of the existing industrial premises that have been measured are detailed in Section 3 of this report.
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10.2.48 BS4142 assesses the significance of impacts by comparing the specific noise level to the background noise level (LA90). Section 3 provides details of the background noise survey undertaken.
10.2.49 Certain acoustic features can increase the significance of impacts over that expected from a simple comparison between the specific noise level and the background noise level. In particular BS4142 identifies that the absolute level of sound, the character, and the residual sound and the sensitivity of receptor should all be taken into consideration. BS4142 includes allowances for a rating penalty to be added if it is found that the specific noise source contains a tone, impulse and/or other characteristic, or is expected to be present. The specific noise level along with any applicable correction is referred to as the ‘rating level’.
10.2.50 The greater the increase between the rating level over the background noise level, the greater the magnitude of the impact. The assessment criteria given by BS4142 are as follows:
• A difference of around +10dB or more is likely to be an indication of a significant adverse impact, depending on the context.
• A difference of around +5dB is likely to be an indication of an adverse impact, depending on the context.
• The lower the rating level is relative to the measured background sound level, the less likely it is that the specific sound source will have an adverse impact or a significant adverse impact. Where the rating level does not exceed the background sound level, this is an indication of the specific sound source having a low impact, depending on the context.
10.2.51 During the daytime, BS4142 requires that noise levels are assessed over 1-hour periods. However, during the night-time, noise levels are required to be assessed over 15-minute periods.
10.2.52 Where the initial estimate of the impact needs to be modified due to context, BS4142 states that all pertinent factors should be taken into consideration, including:
• The absolute level of sound;
• The character and level of the residual sound compared to the character and level of the specific sound; and
• The sensitivity of the receptor and whether dwellings or other premises used
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for residential purposes will already incorporate design measures that secure good internal and/or outdoor acoustic conditions.
Guidance Noise Levels at Proposed Sensitive Receptors
10.2.53 The Noise Policy Statement for England refers to the World Health Organisation (WHO) when discussing noise impacts. The WHO Guidelines for Community Noise 1999 suggest guideline values for internal noise exposure which take into consideration the identified health effects and are set, based on the lowest effect levels for general populations. Guideline values for annoyance which relate to external noise exposure are set at 50, with an upper value of 55 dB(A), representing day time levels below which a majority of the adult population will be protected from becoming moderately or seriously annoyed respectively.
10.2.54 The following guideline values are suggested by WHO:
• 35 dB L Aeq(16 hour) during the day time in noise sensitive rooms
• 30 dB L Aeq(8 hour) during the night time in bedrooms
• 45 dB L Amax(fast) during the night time in bedrooms
• 50 dB L Aeq(16 hour ) to protect majority of population from becoming moderately annoyed
• 55 dB L Aeq(16 hour) to protect majority of population from becoming seriously annoyed
10.2.55 British Standard 8233 ‘Guidance on sound insulation and noise reduction for buildings‘, 2014 bases its advice on the WHO Guidelines. It suggests appropriate criteria and internal noise limits for resting and sleeping for different area types, for example in living room, dining room and bedroom areas.
10.2.56 The internal noise levels in habitable rooms are assessed against the following criteria suggested by BS8233:
• 35dB L Aeq during the daytime in living room and bedroom areas;
• 30dB L Aeq and 45 dB L Amax, f during the night-time in bedroom areas; and
• 55dB L Aeq (16 hour) during the daytime in outdoor living areas.
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10.2.57 In addition, for internal noise levels it states:
“Where development is considered necessary or desirable, despite external noise levels above WHO guidelines, the internal target levels may be relaxed by up to 5 dB and reasonable internal conditions still achieved.”
Furthermore, with regard to external noise, the Standard states;
“For traditional external areas that are used for amenity space such as gardens and patios, it is desirable that the external noise level does not exceed 50 dB
LAeq,T with an upper guidance value of 55 dB L Aeq,T which would be acceptable in noisier environments. However, it is also recognised that these guideline values are not achievable in all circumstances where development might be desirable. In higher noise areas, such as city centres or urban areas adjoining the strategic transport network, a compromise between elevated noise levels and other factors, such as the convenience of living in these locations or making efficient use of land resources to ensure development needs can be met, might be warranted. In such a situation, development should be designed to achieve the lowest practicable levels in these external amenity spaces, but should not be prohibited”.
10.2.58 The PPG summarises the approach to be taken when assessing noise. It accepts that noise can override other planning concerns, but states:
“Neither the Noise Policy Statement for England nor the National Planning Policy Framework (which reflects the Noise Policy Statement) expects noise to be considered in isolation, separate from the economic, social and other environmental dimensions of Proposed Development”.
10.2.59 Building Bulletin 93 ‘Acoustic design of schools: performance standards’, 2014 suggests guideline values designed to provide suitable internal ambient noise levels for:
• Clear communication of speech between teacher and student;
• Clear communication between students; and
• Learning and study activities.
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10.2.60 Internal ambient noise limits are expressed in terms of L Aeq , 30mins during normal teaching hours and assessed using the following criteria:
• An upper limit of 60 dB L Aeq (30 minutes) at the boundary of external premises used for teaching and recreation.
• Indoor ambient noise limits in schools of between 30 and 40 dB L Aeq (30 minutes) depending on the use of the room.
• 55 dB L Aeq (30 minutes) in unoccupied playgrounds, playing fields and other outdoor areas.
• 50 dB L Aeq (30 minutes) in at least one area of the unoccupied playgrounds, playing fields and other outdoor areas, to ensure suitable noise levels for outdoor teaching.
10.3 Methodology
Consultation
10.3.1 Prior to carrying out the noise assessment, Wardell Armstrong provided the proposed assessment methodology to the Environmental Health Department at Ashford Borough Council, no reply was received prior to the completion of this assessment.
10.3.2 The potential noise impacts set out below have been included within the noise assessment:-
• The potential impact of noise and vibration from construction phase activities on existing sensitive receptors located in the vicinity of the site. The potential impacts of the construction phase impacts have been assessed in accordance with British Standard 5228:2009 “Code of Practice for noise and vibration control on construction and open sites – Parts 1&2” (BS5228) and BRE Controlling particles, vapour and noise pollution from construction sites, Parts 1 to 5, 2003.
• The potential impact of existing sources of noise across the existing and proposed noise sensitive areas of the site. The potential impacts of the existing sources of noise, on proposed sensitive areas of the proposed development , have been assessed with reference to the ‘National Planning Policy Framework 2012’ (NPPF), Noise Policy Statement for England, Planning Practice Guidance – Noise, The World Health Organisation Guidelines for Community Noise 1999 (WHO), British Standard 8233 “Guidance on sound insulation and noise
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reduction for buildings” 2014 and British Standard 4142: 2014 “Methods for Rating and assessing industrial and commercial sound”.
• The potential impact of noise from development-generated vehicles on existing and proposed sensitive receptors on and in the vicinity of the site. The current and future traffic noise levels at a number of sensitive receptors; both with and without the proposed development in place, have been predicted using the calculation procedures set out in the Department of Transport’s memorandum, “Calculation of Road Traffic Noise” (CRTN), 1988.
Criteria for Significance of Impact
10.3.3 The potential noise effects associated with the proposed development have been assessed in accordance with the guidance detailed in Section 10.2 to determine whether statutory objectives are exceeded or whether undesirable/desirable consequences may occur on the receiving environment. Where potential adverse impacts are identified, appropriate mitigation measures are proposed to avoid, reduce or compensate for the adverse effects. The significance of an environmental impact will be determined not only by the magnitude of the impact but also by the sensitivity of the receptor, as shown in Tables 10.10 and 10.11 respectively
Table 10.10 Magnitude of Noise Impact
Sensitivity Description
Impact resulting in a considerable change in baseline environmental conditions predicted either to cause statutory objectives to be significantly exceeded or to Large result in severe undesirable/desirable consequences on the receiving environment. Impact resulting in a discernible change in baseline environmental conditions Medium predicted either to cause statutory objectives to be marginally exceeded or to result in undesirable/desirable consequences on the receiving environment.
Impact resulting in a discernible change in baseline environmental conditions with Small undesirable/desirable conditions that can be tolerated
No discernible change in the baseline environmental conditions, within margins of Negligible error of measurement
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Table 10.11 Sensitivity of Receptor
Sensitivity Receptor Type
Receptor/resource has little ability to absorb change without fundamentally altering its present character, or is of international or national importance. For example hospitals, High residential care homes, and internationally and nationally designated nature conservation sites which are also known to contain noise sensitive species (i.e. noise may change breeding habits or threaten species in some other way). Receptors/resource has moderate capacity to absorb change without significantly altering its present character. For example residential dwellings, offices, schools, and Medium play areas. Locally designated nature conservation sites which are also known to contain noise sensitive species (i.e. noise may change breeding habits or threaten species in some other way). Receptor/resource is tolerant of change without detriment to its character or is of low Low or local importance. For example industrial estates.
Negligible Receptor/ resource is not sensitive to noise.
10.3.4 The significance of an environmental impact for construction noise, road traffic noise and on site operational noise is determined by the interaction of magnitude and sensitivity. The Impact Significance Matrix used in this assessment is shown in Table 10.12.
Table 10.12 Impact Significance Matrix
Sensitivity Magnitude High Moderate Low Negligible
Large / Large Beneficial Very Substantial Substantial Moderate None
Medium / Medium Substantial Substantial Moderate None Beneficial
Small / Small Beneficial Moderate Moderate Slight None
Negligible None None None None
10.3.5 The threshold between insignificant and significant lies between “Moderate” and “Substantial” as identified within Table 10.12. Moderate impacts might be noticeable and intrusive but may cause a small change in behaviour. Substantial impacts might be noticeable and disruptive, and might cause a material change in behaviour or attitude.
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10.4 Baseline Conditions
Desk Study
10.4.1 The potential major sources of noise contributing to baseline conditions were identified through a desktop study of the proposed development and surrounding land uses using available maps and aerial photography. Roads surrounding the proposed development, including the Ashfield Road, Pound Lane, Church Hill, Magpie Hill Road and Steeds Lane were considered to be potential sources of noise currently affecting the site. The potential existing sensitive receptor locations and the proposed locations for on-site noise measurement were identified as those most likely to be affected by the proposed development.
Uncertainties
10.4.2 To reduce the level of uncertainty within the assessment the following steps have been taken:
• The noise measurement locations were selected to be representative of the noise level at the closest point of the receptors to the noise sources;
• In accordance with guidance, the sound level meter was mounted vertically on a tripod 1.5m above the ground. Monitoring locations were also more than 3.5m from any other reflecting surfaces;
• The distance between the source and nearest receptors has been measured from scale plans showing the locations of each building;
• The background noise measurements were undertaken during suitable weather conditions, during the proposed operational hours;
• The results of each measurement period were reported to the nearest 0.1dB; and
• Noise measurements were made using a Class 1, integrating sound level meter.
Noise Survey
10.4.3 On the 9 th and 10 th December 2014, Wardell Armstrong LLP carried out a noise survey to assess the noise levels across the proposed development site.
10.4.4 Noise measurements were taken at 11 monitoring locations considered to be representative of areas of the proposed residential development at the site, and
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existing residential dwellings, potentially affected by the construction works. The results can be found in Appendix 10.1 Noise Monitoring Results
10.4.5 The attended noise measurements were carried out over various time periods during the survey. The monitoring locations and periods of monitoring undertaken are listed below in Table 10.13. The monitoring locations are presented on Drawing 10.1.
Table 10.13 Noise Monitoring Location Details
Monitoring Location Period of Monitoring
1 – In the northern corner of ‘Area 1’ of the development site, adjacent to Pound Lane. The monitoring location was chosen to demonstrate the existing 0506-0526, 0620-0640, noise levels in the northern part of ‘Area 1’, in the vicinity of Pound Lane. 0725-0746, 0823-0843, (09/07/2014) This monitoring location is also considered to be representative of CESR 1 on Pound Lane.
2 – Adjacent to the eastern boundary of ‘Area 1’ of the site, adjacent to Ashford Road. The monitoring location was chosen to demonstrate the existing noise levels in the eastern part of ‘Area 1’, in the vicinity of Ashford 0547-0607, 0683-0714, Road. 0755-0815, 0850-0910, 1053-1653 (09/07/2014) This monitoring location is also considered to be representative of CESR 2 on and CESR 5 on Ashford Road.
3 – Adjacent to the southern boundary of ‘Area 4’ of the site, adjacent to Steeds Lane. The monitoring location was chosen to demonstrate the 0517-0533, 0739-0759, existing noise levels in the southern part of ‘Area 4’, in the vicinity of Steeds 1404-1704 (09/07/2014) Lane. 0644-0659, 0744-0804 This monitoring location is also considered to be representative of CESR 10 (10/07/2014) on Steeds Lane.
4- In the eastern part of ‘Area 2’ of the site, in the vicinity of Ashford Road. The monitoring location was chosen to demonstrate the existing noise levels 0603-0618, 0642-0658, in the eastern part of ‘Area 2’, in the vicinity of Ashford Road.. 0703-0723, 0834-0854, This monitoring location is also considered to be representative of CESR 3 1050-1350 (09/07/2014) and CESR 6 off Ashford Road.
5 – In the southern part of ‘Area 2’ of the site, adjacent to Magpie Hill Road. 0543-0558, 0623-0638, The monitoring location was chosen to demonstrate the existing noise levels 0806-0826, 1403-1703, in the southern part of the site in the vicinity of Magpie Hill Road. (09/07/2014) This monitoring location is also considered to be representative of CESR 4 on New House Lane. 0715-0735, (10/07/2014)
6 – In the northern part of ‘Area 3’ of the development site. This monitoring location is considered to be representative of the 1147-1247, (10/07/2014) background noise level in the vicinity of the northern part of ‘Area 3’.
7 – In the southern part of ‘Area 1’ of the development site. This monitoring location is considered to be representative of the 1025-1125, (10/07/2014) background noise level in the vicinity of the southern part of ‘Area 1’.
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8 - In the western part of ‘Area 3’ of the development site. This monitoring location is considered to be representative of the 1145-1245, (10/07/2014) background noise in the vicinity of the western part of ‘Area 3’.
9 - To the northwest of ‘Area 4’ of the development site. This monitoring location is considered to be representative of the 1308-1408, (10/07/2014) background noise in the vicinity of the north western part of ‘Area 4’.
10 – In the eastern part of ‘Area 4’ of the development site. This monitoring location is considered to be representative of the 1319-1419, (10/07/2014) background noise in the vicinity of the eastern part of ‘Area 4’.
11 – In the northern part of ‘Area 2’ of the development site. This monitoring location is considered to be representative of the 1028-1128, (10/07/2014) background noise in the vicinity of the northern part of ‘Area 2’.
10.4.6 It was not considered necessary to carry out continuous monitoring over a full 24 hour period. Noise monitoring ensured that adequate day and night time information was recorded; to include the peak traffic hours of 0700-0900 (day) and 0500-0700 (night), and what are considered the quieter periods of the daytime between the hours of 1000 – 1600 (day). This data along with existing and future year’s traffic data will be used to conduct the assessment of construction and operational noise impact.
10.4.7 The noise measurements were made using a Class 1, integrating sound level meter. The sound level meter was mounted vertically on a tripod 1.5m above the ground and more than 3.5 metres from any other reflecting surfaces.
10.4.8 All noise monitoring took place during dry and calm weather conditions. The sound level meter was calibrated to a reference level of 94dB at 1kHz both before, and on completion of, the noise survey. No drift in the calibration over 0.5dB was noted during the survey.
10.4.9 For the purpose of this assessment, daytime hours are taken to be 0700 to 2300 hours and night-time hours to be 2300 to 0700 hours.
10.4.10 A-weighted L eqs have been measured to comply with the requirements of NPPF,
BS8233 and WHO, together with A-weighted L 90s . The maximum and minimum sound pressure levels were also measured to provide additional information. The noise monitoring results are set out in full in Appendix 10.1.
10.4.11 Attended noise monitoring allows observations and detailed notes to be made of the significant noise sources which contribute to each of the measured levels. The observations identified the significant noise sources at the site to be as follows:
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Road Traffic: Noise from road traffic on the local road network was audible at all monitoring locations. Noise from road traffic on Pound Lane, Ashford Road, Steeds Lane and Magpie Hall Road was dominant at monitoring locations 1 to 5.
Industrial Noise: No noise of an industrial nature was identified throughout the survey period at any monitoring location.
Aircraft: Noise from overflights was occasionally audible at all monitoring locations.
Birdsong: Birdsong was audible during the survey at all monitoring locations throughout the survey.
10.4.12 With the exception of monitoring locations 6 to 11 which cover the daytime period only, for the assessment of construction activity, the measured noise levels for each monitoring location have been divided into daytime (07:00-23:00 hours) and night- time (23:00-07:00 hours) categories. The individual levels have been arithmetically averaged to give a representative single daytime and night-time level for each location. The results for each of the monitoring locations are presented in Table 10.14.
Table 10.14 Average Daytime and Night-time Noise Levels
Average Measured Noise Level L eq Monitoring Location Time (dB(A))
0700-2300 52 1 2300-0700 42 0700-2300 63 2 2300-0700 63 0700-2300 54 3 2300-0700 48 0700-2300 66 4 2300-0700 63 0700-2300 62 5 2300-0700 53 0700-2300 6 52*
0700-2300 7 51*
0700-2300 8 53*
0700-2300 9 47*
0700-2300 10 46*
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0700-2300 11 48*
*Background noise measurements made only for the assessment of daytime construction noise at existing sensitive receptors. 10.4.13 The maximum noise levels measured during each night-time period of the survey, at each of the monitoring locations, are summarised in Table 10.15.
Table 10.15 Summary of the Maximum Night-time Noise Levels
Monitoring Location Maximum Measured Noise Level L max (dB(A))
1 65
2 79
3 70
4 77
5 77
10.5 Impact Assessment
Noise from Earthworks and Construction Phase Activities
10.5.1 The activities associated with the earthworks and construction phase of the proposed development will have the potential to generate noise and create an impact on the surrounding area.
10.5.2 Construction noise can have disturbing effects on the surrounding neighbourhood. The effects are varied and are complicated further by the nature of the site works, which will be characterised by noise sources which will change location throughout the construction period. The duration of site operations is also an important consideration. Higher noise levels may be acceptable if it is known that the levels will occur for a limited period.
10.5.3 For the purposes of this assessment, the occupants of residential properties in the vicinity of the site are considered to be the receptors most likely to be affected by the construction phases of the proposed development. Details of the receptors are set out in Table 10.2.
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Vibration from Earthworks and Construction Phase Activities
10.5.4 Work involving heavy plant on an open site is likely to generate vibration, which may, in certain circumstances, propagate beyond the boundary of the site. In situations where particularly heavy plant, vibrating compaction equipment or piling rigs are being used close to the site boundary, nearby properties may experience ground- borne vibration.
10.5.5 The sensitive receptors most likely to be affected by vibration generated by the earthworks and construction phase works of the proposed development are detailed in Table 10.2.
Road Traffic Noise at Existing Sensitive Receptors
10.5.6 The operational phase of the proposed development will generate additional traffic movements on the existing road network. These additional vehicle movements have the potential to increase road traffic noise levels at existing receptors located adjacent to the main routes to and from the proposed development.
Road Traffic Noise at Proposed Sensitive Receptors
10.5.7 Once the proposed development is complete the operational traffic, in addition to the existing road traffic, has the potential to have a significant impact on the proposed sensitive receptors.
10.6 Assessment of Effects
Construction Phase Assessment
Noise from Earthworks and Construction Phase Activities
10.6.1 During the earthworks and construction phase, any work carried out at the proposed development is likely to generate noise that may propagate beyond the site boundary.
10.6.2 At this stage, detailed information regarding the nature and timescales of activities likely to take place during the earthworks and construction phase are not known. Activities on the site, which could give rise to construction noise impacts include (but are not limited to):
• Site preparation i.e. ground excavation, levelling of ground, trenching, trench filling, unloading and levelling of hardcore and compacting filling; and
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• Construction of the proposed development including piling, construction of access roads, fabrication processes e.g. planing, sanding, routing, cutting, drilling and laying foundations.
10.6.3 The contractor undertaking the enabling and construction works has not yet been appointed. However, it is considered that the enabling and construction works are likely to be restricted to daytime hours, i.e. between 08:00 and 17:00 hours Monday to Friday and 09:00 to 12:00 hours on a Saturday, with no work on Sunday and Bank Holidays. Based on the ambient noise levels measured during the daytime period, the appropriate category value has been determined for each of the sensitive receptors, as detailed in Table 10.5.
10.6.4 The earthworks and construction phase activities have the potential to generate short- term increases in noise levels, above those recommended in BS5228-1. The levels of noise received at the receptors closest to the proposed development would depend on the sound power levels of the machines used, the distance to the properties, the presence of screening or reflecting surfaces and the ability of the intervening ground to absorb the propagating noise.
10.6.5 The nearest noise sensitive receptors to the proposed development, as detailed in Table 10.2, will vary depending on the phase of the proposed development under construction. Given the potentially small distances between the construction activities and residential dwellings, noise levels at the receptors may occur above those detailed in Table 10.5.
10.6.6 Proposed residential properties which become occupied before the completion of the construction phase of the proposed development would experience a similar noise impact. The noise generated by the earthworks and construction phases of the proposed development may therefore exceed the limits stated in BS5228 at the existing and proposed sensitive receptors located in the immediate vicinity of the construction phases of the proposed development.
10.6.7 The noise impact of the construction phase on existing and proposed residential properties is moderate to slight.
10.6.8 It is therefore recommended that mitigation measures be put in place that will reduce the scale of the potential effect. Details can be found in the Mitigation and Residual Impacts section of this chapter.
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Vibration from Earthworks and Construction
10.6.9 Wardell Armstrong’s archives contain field trial measurements of ground vibration associated with types of plant likely to be used at the proposed development. The representative, measured levels, made by Wardell Armstrong using a Vibrock B801 Digital Seismograph, are set out in Table 10.16.
Table 10.16 Measured Vibration Levels of Plant Under normal Operating Conditions
Distance from Source Plant Type 10m (mm/s) 20m (mm/s) 30m (mm/s) 25-30 tonne excavator 0.175 0.075 Background 25 tonne dumptruck (Volvo A25) Loaded 1.000 0.150 Background Empty 0.225 0.050 Background Dozer 1.050 0.400 Background Vibrating roller Drum Vibrator on 4.470 3.270 2.350 Vibrator off 0.500 0.150 0.050 Loading shovel 1.025 0.150 Background
10.6.10 The nearest sensitive properties to the proposed construction works, as detailed in Table 10.2 of this chapter, will vary depending on the phase of the proposed development under construction. The sensitive receptors could include proposed dwellings which become occupied before the completion of the construction phase of the proposed development. As a worst case scenario, earthworks and construction works may potentially take place at a distance less than 10 metres from existing residential properties.
10.6.11 At this distance, it is possible that vibration due to the operation of various construction plant, and in particular a vibratory roller, may be above the threshold of complaint. However, the vibration levels are highly unlikely to be above the threshold of structural damage. It is possible that residential properties would therefore potentially experience some adverse impact. However these would be transient only and for very limited periods during the works, i.e. when activities take place at the proposed development boundaries.
10.6.12 In addition to the earthworks and construction works described, it is possible that piling will be required. At this time, the type(s) of piling which would be used at various
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locations across the site is not known and it is likely that the contractor responsible for undertaking the works at the site would decide the method of piling.
10.6.13 BS5228-2 recognises that the most common form of vibration associated with piling is the intermittent type derived from conventional driven piling. The intensity of vibration disturbance, which may be registered at a receptor, will be a function of many factors. These are set out in BS5228-2 and include:
• Energy per blow or cycle;
• Distance between source and receptor;
• Soil structure interaction i.e. nature of connection between soil and structure being monitored; and
• Construction of structure and location of measuring points e.g. soil surface, building foundation and internal structural element.
10.6.14 As the responsible contractor has not yet been appointed, detailed information regarding the above is not known. It is not therefore possible to assess the potential impacts of vibration generated by piling.
10.6.15 The vibration impact of the construction works at existing and proposed residential receptors is moderate to slight .
10.6.16 The receptors likely to be affected by piling will vary depending of the phase of the proposed development under construction. Once the precise building locations, ground conditions for each location and type(s) of piling are confirmed, vibration levels could be estimated and recommendations for control made as appropriate. Mitigation measures are discussed within the Mitigation and Residual Impacts section of this chapter.
Operational Phase Assessment
Road Traffic Noise and Existing Sensitive Receptors
10.6.17 Noise modelling has been carried out in accordance with CRTN to assess any potential changes in road traffic noise across the proposed development for the future operational year of 2023, i.e. with the proposed development traffic in place. The
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results of the SoundPLAN daytime noise modelling are shown on Drawings 10.3 to 10.9.
10.6.18 The noise levels at each of the receptors considered have been assessed by comparing the noise levels predicted for the following scenarios;
• Scenario 1: 2014 Base year;
• Scenario 2: 2023 Opening/Future Year (Without Development); and,
• Scenario 3: 2023 Opening/Future Year (With Development).
10.6.19 The predicted noise levels are detailed in Table 10.17 below.
Table 10.17 Predictions for the 2014 Base year, 2023 “Without Development ” and 2023 “With Development ” Scenarios and Changes in Predicted Road Traffic Noise Levels
Predicted L 10 18hour dB(A) at the façade of the Receptor Change in Change in Scenario 2: Scenario 3: Existing Predicted Road Predicted Road 2023 Future year 2023 Future year Sensitive Floor Scenario 1: Traffic Noise Traffic Noise without the with the Receptor Level 2014 Baseline Levels between Levels between proposed proposed Number (Drawing 10.3) Scenario 1 and Scenario 2 and development development Scenario 3 Scenario 3 (Drawing 10.4) (Drawing 10.5) (Drawing 10.6) (Drawing 10.7) Ground 55.5 60.3 60.4 4.9 0.1 ESR 1 Floor 1ST Floor 55.8 60.5 60.7 4.9 0.2 Ground 66.1 66.5 67.3 1.2 0.8 ESR 2 Floor 1ST Floor 67 67.4 68.2 1.2 0.8 Ground 66.3 68.1 68.6 2.3 0.5 ESR 3 Floor 1ST Floor 66.8 68.2 68.7 1.9 0.5 Ground 65.4 66.5 66.7 1.3 0.2 ESR 4 Floor 1ST Floor 64.8 65.9 66.2 1.4 0.3 Ground 67.3 67.1 68.1 0.8 1.0 ESR 5 Floor 1ST Floor 67.4 67.6 68.5 1.1 0.9 Ground 63.3 63.8 64.2 0.9 0.4 ESR 6 Floor 1ST Floor 64.5 65 65.4 0.9 0.4 Ground 62 62.5 62.7 0.7 0.2 ESR 7 Floor 1ST Floor 63 63.5 63.6 0.6 0.1
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Ground 61.5 62.4 62.4 0.9 0.0 ESR 8 Floor 1ST Floor 62.4 63.3 63.3 0.9 0.0 Ground 65.6 66.4 66.3 0.7 -0.1 ESR 9 Floor 1ST Floor 65.8 66.7 66.6 0.8 -0.1 Ground 63.2 63.8 62.9 -0.3 -0.9 ESR 10 Floor 1ST Floor 64.2 64.8 63.8 -0.4 -1.0 Ground 57.3 58.1 58.3 1.0 0.2 ESR 11 Floor 1ST Floor 58.3 59.2 59.4 1.1 0.2 Ground 60.3 61.6 61.6 1.3 0.0 ESR 12 Floor 1ST Floor 60.6 61.9 61.9 1.3 0.0 Ground 52.4 53.8 54.1 1.7 0.3 ESR 13 Floor 1ST Floor 52.9 54.3 54.7 1.8 0.4 Ground 63.1 64.5 64.5 1.4 0.0 ESR 14 Floor 1ST Floor 62.4 63.7 63.7 1.3 0.0 Ground 55 56.3 56.3 1.3 0.0 ESR 15 Floor 1ST Floor 56.1 57.4 57.4 1.3 0.0 Ground 59.4 60.5 60.8 1.4 0.3 ESR 16 Floor 1ST Floor 60.2 61.2 61.5 1.3 0.3
10.6.20 The changes in noise levels have been assessed against the significance criteria contained in Table 10.8. The results show that the highest increase in noise level between 2014 and 2023 with the development will be approximately 4.9dB(A), however the highest increase in noise level between 2023 without and 2023 with the development will be approximately 1.0dB(A). In accordance with the significance criteria detailed within Table 10.8, this increase in road traffic noise with respect to the proposed development will be negligible at the existing receptors. The change in noise level at all existing sensitive receptors considered in this assessment will be no more than 1dB, when considering future traffic flows, and therefore the impact will be none at these sensitive receptors, when considered in accordance with the criteria in Table 10.12.
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Road Traffic Noise at Proposed Sensitive Receptors
10.6.21 Noise modelling has also been carried out to determine the future levels of road traffic noise at the proposed sensitive areas of the proposed development.
10.6.22 The noise level calculations using CRTN are presented as LA10,18hour. This has been
converted to an LAeq,16hour . The results of the SoundPLAN daytime noise modelling for future year 2023 is shown on Drawing 10.8. The night-time results shown on Drawing 10.9 have been derived by using the methodology in Transport Research Laboratory
Converting the UK traffic noise index L A10,18h to EU noise indices for noise mapping (TRL) guidance document.
10.6.23 The Illustrative Masterplan (Drawing 14007(sk)001 Rev N) shows the location of the sensitive areas across the proposed development. The proposed sensitive receptors are selected with respect to existing and proposed noise sources, in particular the surrounding and proposed road network. The locations of the site access roads are also shown on the Masterplan, the results of the prediction calculations for 2023 (with proposed development traffic in place) are shown in Table 10.18.
Table 10.18 Predictions for the 2023 “With Development” Scenario at Proposed Sensitive Receptors.
Proposed Sensitive Predicted Daytime L eq,16hour dB(A) at Predicted Night-time L eq, 8hour dB(A) at Receptor Number the façade of the Receptor the façade of the Receptor
PSR 1 63 54
PSR 2 67 58
PSR 3 63 54
PSR 4 64 56
PSR 5 61 53
PSR 6 54 46
PSR 7 53 45
PSR 8 57 49
PSR 9 57 49
PSR 10 57 48
PSR 11 54 46
PSR 12 54 46
10.6.24 The calculated noise levels for the proposed sensitive receptors (PSR) have been used to calculate the sound attenuation required to achieve internal and external guideline noise levels.
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External Daytime Noise Levels at Proposed Residential Properties
10.6.25 Noise levels in external living areas of the proposed dwellings have been assessed in accordance with the guideline noise levels for external living areas and:
• 55dB L Aeq ,T should be considered as the upper guideline value for external living areas as recommended by WHO 1999 and BS8233:2014.
10.6.26 Table 10.19 details the attenuation required in order to achieve 55dB(A) in outdoor living areas. Daytime noise levels are taken from Table 10.18, 2023 “With Development”.
Table 10.19 Calculated Daytime Noise Levels in Outdoor Areas of Proposed Sensitive Receptors.
Attenuation Required to Daytime Noise Level (Figures Proposed Sensitive Receptor Location Achieve 55dB(A) (Figures in in dB L Aeq 16hour ) dB(A))
PSR 1 63 8
PSR 2 67 12
PSR 3 63 8
PSR 4 64 9
PSR 5 61 6
PSR 6 54 0
PSR 7 Assessed Separately
PSR 8 57 2
PSR 9 57 2
PSR 10 57 2
PSR 11 54 0
PSR 12 Assessed Separately
10.6.27 The results presented within Table 10.19 indicate that mitigation measures are required to attenuate against existing noise sources in external living areas in the area of proposed sensitive receptors 1, 2, 3, 4, 5, 8, 9 and 10 which are closest areas to
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major road links; Ashford Road, Magpie Hall Road and Steeds Lane. It is considered that the noise levels at sensitive receptors further into the site will be protected by the development itself. Therefore no mitigation measures are required for these properties.
Internal Daytime Noise Levels at Proposed Residential Properties
10.6.28 The daytime noise levels in noise sensitive rooms of the proposed dwellings have been assessed in accordance with the guidance noise levels:
• 35dB L Aeq wherever possible
10.6.29 The predicted daytime noise levels have been used to determine the noise levels likely at the facades of the properties in the vicinity of the proposed noise sensitive parts of the proposed development, during the daytime period.
10.6.30 Before internal noise levels can be calculated 3dB(A) must be added to the free-field measured levels to allow for the reflection of noise from the proposed housing facades when the buildings are in place.
10.6.31 The calculated noise levels at the façades of the proposed dwellings, together with the
level of attenuation required to achieve 35dB L Aeq in the living room areas, are summarised in Table 10.20.
Table 10.20 Façade Noise Level at the proposed development area and Level of Attenuation Required to Achieve the Internal Daytime Noise Limit Level of Attenuation Needed To Noise Level at the Façade of the Proposed Sensitive Receptor Achieve Guideline Noise Levels Property L eq,16hour (dB(A)) (dB(A))
PSR 1 66 31
PSR 2 70 35
PSR 3 66 31
PSR 4 67 32
PSR 5 64 29
PSR 6 57 22
PSR 7 Assessed Separately
PSR 8 60 25
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Table 10.20 Façade Noise Level at the proposed development area and Level of Attenuation Required to Achieve the Internal Daytime Noise Limit Level of Attenuation Needed To Noise Level at the Façade of the Proposed Sensitive Receptor Achieve Guideline Noise Levels Property L eq,16hour (dB(A)) (dB(A))
PSR 9 60 25
PSR 10 60 25
PSR 11 57 22
PSR 12 Assessed Separately
10.6.32 The facades of dwellings facing into the site will be protected by the building itself and/or screened by other buildings and topography. It is considered that the noise levels at these facades and therefore the level of attenuation the facades would need
to attenuate to achieve 35dB L Aeq in the living rooms and bedrooms will be less than those detailed in Table 10.20.
10.6.33 Mitigation measures will be required in the final design, and are detailed within the Mitigation and Residual Effects section of this chapter.
Internal Night Time Noise Levels at Proposed Residential Properties
10.6.34 In accordance with guidance noise levels, the acceptable night-time noise levels within bedroom areas are:
• 30dB L Aeq wherever possible as recommended by BS8233:2014; and
• Individual noise events should not normally exceed 45dB L Afmax as
recommended by BS8233:2014 .
10.6.35 The predicted and measured night-time noise levels have been used to determine the noise levels likely, at the facades of the properties in the vicinity of the proposed receptors, during the night-time period.
10.6.36 Before internal noise levels can be calculated 3dB(A) must be added to the free-field measured levels to allow for the reflection of noise from the proposed housing facades when the buildings are in place.
10.6.37 The calculation methodology in TRL has been used to predict the night-time noise level at the location of proposed sensitive receptors.
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10.6.38 The calculated noise levels at the façades of the dwellings, together with the level of
attenuation required to achieve 30dB L Aeq and/or 45dB L Afmax in the bedrooms, are summarised in Table 10.21.
Table 10.21 Façade Noise Level at Properties in the Proposed Sensitive Receptor Locations and Level of Attenuation Required to Achieve the Internal Night-time Noise Limit
Proposed Measured Level of Attenuation Needed To Noise Level at the Façade Sensitive Maximum Value Achieve Guideline Noise Levels of the Property L eq,8hour Receptor (dB(A)) (dB(A))
PSR 1 57 82 2 27
PSR 2 61 82 2 31
PSR 3 57 80 4 35
PSR 4 59 80 4 35
PSR 5 56 80 5 35
PSR 6 49 N/A 19
PSR 7 Assessed Separately
PSR 8 52 73 3 28
PSR 9 52 73 3 28
PSR 10 51 N/A 21
PSR 11 49 N/A 19
PSR 12 Assessed Separately
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Table 10.21 Façade Noise Level at Properties in the Proposed Sensitive Receptor Locations and Level of Attenuation Required to Achieve the Internal Night-time Noise Limit
Proposed Measured Level of Attenuation Needed To Noise Level at the Façade Sensitive Maximum Value Achieve Guideline Noise Levels of the Property L eq,8hour Receptor (dB(A)) (dB(A))
1Measured maximum noise level captured at monitoring location 2 2Measured maximum noise level captured at monitoring location 3 3Measured maximum noise level captured at monitoring location 4 4Measured maximum noise level captured at monitoring location 5 10.6.39 The facades of dwellings facing into the site will be protected by the building itself and/or screened by other buildings and topography. It is considered that the noise levels at these facades and therefore the level of attenuation the facades would need
to attenuate to achieve the 30dB L Aeq and 45dB L Amax in the bedrooms will be less than those detailed in Table 10.21.
10.6.40 Mitigation measures will be required in the final design, and are detailed within the Mitigation and Residual Effects section of this chapter.
Road Traffic Noise at Proposed School
10.6.41 The Illustrative Masterplan (Drawing 14007(sk)001 Rev N) indicates that the proposed development will include a School, located in the central part of ‘Area 3’ adjacent to the proposed site access road off of Ashford Road.
10.6.42 In accordance with the requirements of BB93, the following daytime noise levels should be achieved:
• An upper limit of 60 dB L Aeq (30 minutes) at the boundary of external premises used for teaching and recreation.
• Indoor ambient noise limits in schools of between 30 and 40 dB L Aeq (30 minutes) depending on the use of the room.
• 55 dB L Aeq (30 minutes) in unoccupied playgrounds, playing fields and other outdoor areas.
• 50 dB L Aeq (30 minutes) in at least one area of the unoccupied playgrounds, playing fields and other outdoor areas, to ensure suitable noise levels for outdoor teaching.
10.6.43 The predicted external daytime level of road traffic noise at the proposed Primary
school is 54dB L Aeq 16-hour at the nearest point to the road. The results of the noise
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modelling indicates that mitigation measures would not be required to ensure the required external and internal noise levels are achieved during the daytime. However, once the proposed development is operational there is potential for additional noise impact from traffic on the proposed infrastructure.
10.6.44 Mitigation measures are discussed further in Mitigation and Residual Effects section of this chapter.
Road Traffic Noise at Proposed Community and Retail
10.6.45 The daytime noise levels in noise sensitive rooms of the proposed Community and Retail buildings have been assessed in accordance with the following guidance noise levels:
• Staff/meeting room, training room 35 - 45dB L Aeq .
• Executive Office 35 - 40dB L Aeq .
10.6.46 Although the specific uses of Community buildings are unknown at this stage these noise limits provide a robust assessment as it is likely that the proposed use of Community buildings is of a less noise sensitive nature than that considered.
10.6.47 The predicted daytime noise levels have been used to determine the noise levels likely at the facades of the business centre in the vicinity of the proposed noise sensitive parts of the proposed development, during the daytime period.
10.6.48 Before internal noise levels can be calculated 3dB(A) must be added to the free-field measured levels to allow for the reflection of noise from the proposed facades when the buildings are in place.
10.6.49 The calculated noise levels at the façades of the proposed dwellings, together with the
level of attenuation required to achieve 35 - 45dB L Aeq in sensitive rooms of the proposed Community and Retail buildings, are summarised in Table 10.22.
Table 10.22 Façade Noise Level at the Proposed Development area and Level of Attenuation Required to Achieve the Internal Daytime Noise Limit Level of Attenuation Needed To Noise Level at the Façade of the Proposed Sensitive Receptor Achieve Guideline Noise Levels Property L eq,16hour (dB(A)) (dB(A))
PSR 7 56 21 - 11
10.6.50 The facades facing into the site will be protected by the building itself and/or screened by other buildings and topography. It is considered that the noise levels at these
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facades and therefore the level of attenuation the facades would need to attenuate
to achieve 35 - 45dB L Aeq internal noise levels will be less than those detailed in Table 10.22.
10.6.51 Mitigation measures will be required in the final design, and are detailed within the Mitigation and Residual Effects section of this chapter.
Assessment of Proposed Industrial and Commercial Premises
10.6.52 The Illustrative Masterplan (Drawing 14007(sk)001 Rev N) indicates areas encompassing ‘Community Buildings’, ‘School’, ‘Pubs and Retail’, spread out across the northern part of Area 3.
10.6.53 These proposals are categorised as industrial/commercial premises which will involve activities and equipment that are expected to generate noise. Activities that are likely to generate noise include:
• Noise from vehicle movements entering and leaving the premises;
• Vehicle movements within the proposed car parks;
• Noise from patrons entering and leaving the market square and mixed use areas;
• Noise from students and employees at the school;
• Mobile plant such as pallet trucks operating within the service yard of the proposed premises; and
• Ancillary noise sources associated with the proposed premises including external plant; and
• Deliveries and/or collections of goods with the proposed premises, including HGVs.
10.6.54 At this stage, Wardell Armstrong does not have any specific information relating to future activities, ancillary noise sources, opening hours or delivery times associated with the proposed premises. It has not therefore been possible to estimate the level of noise likely to be generated by activities associated with the premises, at the existing and proposed sensitive receptors.
10.6.55 Mitigation measures will be incorporated into the site design at the detailed design stage, to ensure the noise impacts of the proposed premises are reduced to acceptable levels at the existing and proposed sensitive receptors. The detailed design
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of the areas described will include mitigation measures to reduce noise levels generated wherever practicable.
10.7 Mitigation and Residual Impacts
10.7.1 The proposed development design is set out in the Illustrative Masterplan (Drawing 14007(sk)001 Rev N) and described within Chapter 4 of this ES.
10.7.2 This section describes the measures which are required to mitigate any significant environmental impacts.
Construction Phase
Noise from Earthworks and Construction
10.7.3 To reduce the potential impact of noise levels generated by the construction phase of the proposed development at existing receptor locations in the immediate vicinity of the site, mitigation measures will be required.
10.7.4 Best working practice will be implemented during each phase of the earthworks and construction works at the site. The construction works will follow the guidelines in BS5228-1 and the guidance in BRE Controlling particles, vapour and noise pollution from construction sites, Parts 1 to 5, 2003.
10.7.5 The following measures will be put in place to minimise noise emissions:
• When works are taking place within close proximity to those sensitive receptors identified, screening of noise sources by temporary screen may be employed;
• All plant and machinery should be regularly maintained to control noise emissions, with particular emphasis on lubrication of bearings and the integrity of silencers;
• Site staff should be aware that they are working adjacent to a residential area and avoid all unnecessary noise due to misuse of tools and equipment, unnecessary shouting and radios;
• A further measure to reduce noise levels at the sensitive receptors would include, as far as possible, the avoidance of two noisy operations occurring simultaneously in close proximity to the same sensitive receptor;
• Adherence to any time limits imposed on noisy works by the local authority;
• Implement set working hours during the week and at weekends;
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• Ensure engines are turned off when possible; and
• Should earthworks/earthworks and construction activities need to be carried out during night-time hours, the local authority could include a planning condition which requests advance notice and details of any night working to be provided.
Noise from Construction Vehicles at Future Existing Sensitive Receptors
10.7.6 Mitigation measures will be required to reduce the noise and vibration impact of construction vehicles at future existing sensitive receptors, this will consist of management of construction vehicles to minimise the noise and vibration impact.
10.7.7 The management is likely to include;
• Times of vehicle movements;
• Frequency of movements, (i.e. maximum HGVs permitted per hour); and,
• Site speed limit.
10.7.8 Furthermore, the maintenance of the road surface, including road sweeping and repair of pot holes will also aid in reducing the likelihood of complaints at future existing sensitive receptors.
Vibration from Earthworks and Construction
10.7.9 BS5228-2 recognises that the most common form of vibration associated with piling is the intermittent type derived from conventional driven piling.
10.7.10 To minimise the potential for vibration to be generated by any necessary piling it is recommended that careful consideration is given to the type of piling to be used. For example auger bored piles would be preferable to driven piles with regards to a reduced potential for noise and vibration to be generated. However, it is recognised that the piling process will need to be selected on the basis of the strata to be encountered, the loads to be supported and the economics of the system.
10.7.11 The receptors likely to be affected by piling will vary depending of the phase of the proposed development under construction. Once the precise building locations, ground conditions for each location and type(s) of piling are confirmed, vibration levels could be estimated and recommendations for control made as appropriate.
10.7.12 To keep ground borne vibration to a minimum the following measures, as referred to in BS5228-2, should be put in place:
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• Substitution: Where reasonably practicable, plant and or methods of work likely to cause significant levels of vibration at the receptors identified, should be replaced by less intrusive plant/methods of working; and
• Vibration Isolation of plant at source: This may prove a viable option where the plant is stationary (e.g. a compressor, generator) and located close to a receptor.
10.7.13 There are a number of measures which can be implemented, depending upon the type of piling chosen. BS5228-2 indicates that mitigation might include: use of alternative methods, removal of obstructions, provision of cut-off trenches, reduction of energy input per blow, reduction of resistance to penetration. Continuous flight auguring would cause minimal vibration even when very close to the piling operation.
10.7.14 As the construction programme and methodologies become more defined it is suggested that earthworks and construction vibration be reconsidered and that a detailed strategy for control be implemented.
Operational Phase – Proposed Receptors
Glazing Requirements
Daytime Noise Sensitive Rooms
10.7.15 When assessing daytime noise levels in noise sensitive rooms, the noise attenuation provided by the overall building facade should be considered. To mitigate noise levels, the composition of the building facade can be designed to provide the level of attenuation required. Glazing is generally the building element which attenuates noise the least, so the proportion of glazing in a building facade is an important consideration when assessing overall noise attenuation.
10.7.16 In the absence of design details for the building facades, it has been assumed that the glazing to noise sensitive rooms would comprise about 25% of the facade area. To calculate the overall attenuation provided by this percentage of glazing in a brick or block facade, a non-uniform partition calculation can be used.
10.7.17 The calculation combines the different degrees of attenuation of the wall element and the window element. A facade element comprising a solid brick or blockwork, will attenuate by 45-50dB (British Standard 8233: “Sound insulation and noise reduction for buildings – Code of practice” 1999) whereas standard thermal double glazing will attenuate traffic noise by 26-29 dB(A) (BRE Digest 379 ”Double glazing for heat and
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sound insulation). The overall noise attenuation provided by this combination is, therefore, between 32dB(A) and 35dB(A).
10.7.18 The noise attenuation requirements for daytime noise sensitive rooms across the site are summarised in Table 10.20. Table 10.20 indicates that standard thermal double glazing would ensure that internal noise levels in living room and bedroom areas at the proposed dwellings across the site, during the daytime, will achieve guidance noise levels.
10.7.19 However with windows open the attenuation provided by the facades across the site will fall to approximately 15dB(A). This would allow the recommended internal noise limits to be exceeded in some living rooms and bedrooms.
10.7.20 Therefore some form of acoustic ventilation will be required to achieve the required internal daytime noise levels for proposed dwellings.
10.7.21 At this stage, a detailed site layout has not yet been confirmed. Detailed glazing requirements will need to be confirmed on a plot by plot basis once a detailed design layout is available.
10.7.22 The facades of the buildings further into the site, away from the major road links, will be protected by the buildings themselves and/or screened by other buildings and topography. It is considered that the noise levels at these facades, and therefore the level of attenuation the facades would need to attenuate, to achieve guidance noise levels, will be less than those detailed in Table 10.20.
Night Time Bedroom Areas
10.7.23 The noise attenuation requirements for bedrooms are summarised in Table 10.21. Table 10.21 indicates that standard thermal double glazing would ensure that internal noise levels in bedroom areas at the proposed dwellings meet guidance noise levels in proposed residential dwellings with windows closed, using the assumptions stated in paragraphs 10.7.16 to 10.7.17.
10.7.24 However with windows open the attenuation provided by the facade will fall to approximately 15dB(A). This would allow the recommended internal noise limits to be exceeded in some bedrooms.
10.7.25 Therefore some form of acoustic ventilation will be required to achieve the required internal night-time noise levels for proposed dwellings.
10.7.26 The facades of the dwellings facing into the site, away from major road links, will be
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protected by the building itself and/or screened by other buildings and topography, particularly at ground floor level. It is considered that the noise levels at these facades, and therefore the level of attenuation the facades would require to achieve guidance noise levels, will be less than those detailed in Table 10.21.
10.7.27 It should be noted that the noise attenuation requirements for bedrooms during the night-time is greater than is required during the daytime. Therefore the higher glazing and ventilation specification to attenuate noise at night should be used.
10.7.28 Glazing requirements can be confirmed on a plot by plot basis, once a detailed design layout is available.
Daytime Community and Retail Buildings
10.7.29 The noise attenuation requirements for sensitive rooms are summarised in Table 10.22. Table 10.22 indicates that standard thermal double glazing would ensure that internal noise levels in office areas at the proposed community and retail buildings meet guidance noise levels with windows closed, using the assumptions stated in paragraphs 10.7.16 to 10.7.17.
10.7.30 However with windows open the attenuation provided by the facade will fall to approximately 15dB(A). This would allow the recommended internal noise limits to be exceeded in some offices.
10.7.31 Therefore some form of acoustic ventilation will be required to achieve the required internal levels for proposed community and retail buildings.
10.7.32 The facades of the offices facing into the site, away from major road links, will be protected by the building itself and/or screened by other buildings and topography, particularly at ground floor level. It is considered that the noise levels at these facades, and therefore the level of attenuation the facades would require to achieve guidance noise levels, will be less than those detailed in Table 10.22.
10.7.33 Glazing requirements can be confirmed, once a detailed design layout is available.
Acoustic Ventilation Requirements
10.7.34 It is recommended that the acoustic ventilation proposed at the site should, as a minimum, comply with Building Regulations 2010 Approved Document F1 Means of Ventilation and British Standard BS5925 1991: “Code of Practice for Ventilation Principles and Designing for Natural Ventilation.
10.7.35 The implementation of the recommended glazing together with acoustic ventilation
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should ensure that the required internal night-time noise limits, with a direct line of sight of the main noise sources, are met.
10.7.36 The façades of some of the proposed buildings may be protected by the buildings themselves and/or screened by other buildings depending upon the final site layout.
10.7.37 The requirement for acoustic ventilation would need to be confirmed once a detailed design layout is available.
Road Traffic Noise at the Proposed School
External Daytime Noise Levels
10.7.38 At this stage a detailed layout showing the design of the proposed school is not available. However the site monitoring and modelling process has shown that the
noise level at the proposed site is 54dB L Aeq 16-hour . This level is below the required 55dB
LAeq 30 minutes for playing areas, and above the required 50dB L Aeq 30 minutes, for outdoor teaching areas presented within BB93 during the daytime. Therefore mitigation is required in outdoor teaching areas.
10.7.39 Mitigation measures should be incorporated to ensure that at least one outdoor area
is below 50dB L Aeq (30 minutes), for outdoor teaching purposes.
10.7.40 The mitigation measures required will depend on the location and the orientation of the proposed school. The location, shape and orientation of the school building, could be designed to specifically reduce road traffic noise, and to ensure that an outdoor area suitable for teaching is created within the site boundary.
10.7.41 Noise attenuation schemes detailing the proposed mitigation measures to be implemented, to ensure the external noise limits are achieved at the school, will be submitted to the Local Authority for review and approval at the reserved matters stage.
Internal Daytime Noise Levels
10.7.42 The level of noise attenuation that the facades of the school will need to provide, to
achieve the more stringent internal noise level of 30dB L Aeq 30 minutes, during the daytime period (as required by BB93), will be approximately 24dB(A).
10.7.43 At this stage a detailed layout showing the design of the proposed school sites is not available. The level of attenuation the building facades will need to attenuate will therefore be dependent on the proposed use of the classroom and location in relation to the proposed development infrastructure.
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10.7.44 Standard double glazing will be sufficient to achieve the limit of 30dB L Aeq 30 minutes, with windows closed. Therefore some form of acoustic ventilation will be required to achieve the required internal levels for proposed community and retail buildings.
10.7.45 Noise attenuation schemes detailing the proposed glazing and ventilation requirements for proposed school sites of the proposed development can be submitted to the Local Authority for review and approval at detailed design stage.
Assessment of Proposed Industrial and Commercial Premises
10.7.46 The Illustrative Masterplan (Drawing 14007(sk)001 Rev N) indicates areas of ‘Community Buildings’ and ‘Pubs and Retail’ in the northern part of ‘Area 3’ of the site.
10.7.47 Activities associated with these uses that are likely to generate noise include:
• Noise from vehicle movements entering and leaving the premises;
• Vehicle movements within the proposed car parks;
• Noise from patrons entering and leaving the community area;
• Mobile plant such as pallet trucks operating within the service yard of the proposed premises;
• Ancillary noise sources associated with the proposed premises including external plant; and
• Deliveries and/or collections of goods with the proposed premises, including HGVs.
10.7.48 At this stage, Wardell Armstrong does not have any specific information relating to future activities, ancillary noise sources, opening hours or delivery times associated with the proposed premises. It has not therefore been possible to estimate the level of noise likely to be generated by activities associated with the premises, at the existing and proposed sensitive receptors.
10.7.49 Mitigation measures will be incorporated into the site design at the detailed design stage, to ensure the noise impacts of the proposed premises are reduced to acceptable levels at the existing and proposed sensitive receptors. The detailed design of the areas described will include mitigation measures to reduce noise levels generated wherever practicable.
Construction Phase Residual Impact
10.7.50 The activities carried out during the earthworks and construction phase of the
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proposed development will have the potential to generate short term increases in noise levels above the recommended noise limits, set in accordance with current guidance, at existing and proposed sensitive receptors surrounding the site. The use of heavy plant associated with the earthworks and construction works also has the potential to give rise to ground borne vibration.
10.7.51 To minimise the potential impact of construction works, mitigation measures would be put in place. These will include restrictions on working hours, the implementation of temporary screening where possible, and best working practices.
10.7.52 In addition to earthworks and construction it is possible that piling will be required. At this stage detailed information regarding the type of piling has not been confirmed. To minimise the potential for vibration to be generated by piling it is recommended that careful consideration be given to the type of piling used.
10.7.53 With the implementation of best working practice and restriction on working hours, the noise and vibration impacts of earthworks and construction phases, will be generally negligible , with only brief periods of slight to moderate impacts likely in the short term at local level.
Operational Phase
Existing Sensitive Receptors
10.7.54 Changes in road traffic noise at existing sensitive receptors as a result of development led road traffic will be negligible in the long term.
Proposed Sensitive Receptors and Noise
10.7.55 The noise sensitive areas of the proposed development, i.e. the residential areas will be subjected to noise from existing and proposed sources. The dominant source of noise at the sensitive areas of the proposed development is road traffic on the major road links in the vicinity of the site. In addition to the existing sources of noise, development generated vehicle movements on the local road network have the potential to increase noise levels across the proposed development.
10.7.56 The results presented within Table 10.19 to Table 10.21 indicate that mitigation measures are required to attenuate against existing noise sources in external living areas, and in internal living rooms and bedrooms at proposed sensitive receptors nearest to the existing road network. Mitigation measures will be incorporated into the Development design at the detailed design stage, to ensure the noise impacts are
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reduced to acceptable levels at the proposed sensitive receptors.
10.7.57 With the implementation of mitigation, it is considered that the impact of the existing noise sources on the proposed noise sensitive areas of the proposed development will be negligible .
Proposed Industrial and Commercial Developments
10.7.58 Mitigation measures will be incorporated into the proposed development design at the detailed design stage, to ensure the noise impacts of the proposed premises are reduced to acceptable levels at the existing and proposed sensitive receptors. The detailed design of the areas described will include mitigation measures to reduce noise levels generated wherever practicable.
10.7.59 With mitigation measures in place it is considered that the impact of the proposed noise sources on the existing and proposed sensitive areas of the proposed development will be negligible .
10.7.60 Mitigation measures will be incorporated into the proposed development design at the detailed design stage, to ensure the industrial noise impacts of the proposed premises are reduced to acceptable levels at proposed sensitive receptors. Once these measures are implemented the impact at existing sensitive receptors from the proposed industrial and commercial areas would be negligible in the context of each receptor.
Summary of Residual Impacts
10.7.61 Please see Table 10.23 below for a summary of the residual impacts.
Table 10.23 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of residual mitigation) effect Construction stage Noise impact from site Moderate - Slight Best working practice will be Negligible , with only preparation and construction of implemented during each brief periods of the proposed development. phase of the earthworks and Slight/Moderate construction works at the site impacts likely in the short term at local level Vibration impact from site Moderate - Slight Best working practice will be Negligible , with only preparation and construction of implemented during each brief periods of the proposed development. phase of the earthworks and Slight/Moderate construction works at the site impacts likely in the short term at local level
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Post-completion stage Noise impact form development- Negligible None Negligible generated vehicles on existing sensitive receptors Noise impact form future noise Negligible - Mitigation measures will be Negligible sources, including development- Substantial incorporated into the generated vehicles on proposed development design at the receptors detailed design stage, to ensure the noise impacts are reduced to acceptable levels at the proposed sensitive receptors. Mitigation measures could include, noise barriers, acoustic ventilation and glazing. Noise impact form future noise Negligible Noise attenuation schemes Negligible sources, including development- detailing the proposed glazing generated vehicles on the and ventilation requirements proposed school for proposed school sites of the proposed development can be submitted for review and approval at detailed design stage Noise impact form future noise Negligible - Mitigation measures will be Negligible sources, including development- Substantial incorporated into the generated vehicles on the development design at the proposed community and retail detailed design stage, to buildings ensure the noise impacts are reduced to acceptable levels at the proposed sensitive receptors. Mitigation measures could include, noise barriers, acoustic ventilation and glazing. Negligible - Negligible Noise impact form the proposed At this stage, Wardell Substantial industrial and commercial Armstrong does not have any premises specific information relating to future activities, ancillary noise sources, opening hours or delivery times associated with the proposed premises. Mitigation measures will be incorporated into the site design at the detailed design stage, to ensure the noise impacts of the proposed premises are reduced to acceptable levels at the existing and proposed sensitive receptors.
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10.8 Statement of Effects
Construction Phase Assessment – Noise and Vibration
10.8.1 The significance of noise and vibration effects from earthworks and construction is considered to be negligible , with site specific mitigation measures in place. However, the construction operations may have a short term, slight to moderate impact at existing sensitive receptors located in the immediate vicinity of the construction phases over the proposed development.
Operational Phase Assessment
Existing Sensitive Receptors
10.8.2 The increase in road traffic noise due to the operations of the proposed development on completion in 2023, at the existing sensitive receptors adjacent the local road network in the immediate vicinity of the proposed development, will be negligible in the long term. Therefore this impact is not considered to be significant.
10.8.3 Mitigation measures will be incorporated into the proposed development design at the detailed design stage, to ensure the noise impacts from proposed industrial and commercial operations are reduced to acceptable levels at the existing sensitive receptors and therefore having a negligible noise impact.
Proposed Residential Receptors
10.8.4 The results of the baseline noise survey and noise prediction calculations indicate that the noise levels at the proposed development should not be a determining factor in granting planning permission in accordance with current guidance. Once the mitigation measures detailed in the Mitigation section of this chapter have been implemented, the residual impact of road traffic noise from vehicles travelling along major roads and the proposed development access roads will meet all the required internal and external noise standards and have a negligible impact on future residents.
10.8.5 Mitigation measures will be incorporated into the proposed development design at the detailed design stage, to ensure the noise impacts from proposed industrial and commercial operations are reduced to acceptable levels at the proposed sensitive receptors and therefore have a negligible noise impact.
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10.9 Conclusions
Construction Phase Assessment – Noise and Vibration
10.9.1 The construction phase assessment has been undertaken to determine the risk and significance of noise and vibration from earthworks and construction for the proposed development. The assessment has been undertaken in accordance with the guidance on assessing the impacts of construction phase noise and vibration.
10.9.2 To minimise the potential impact of construction works, mitigation measures would be put in place. These will include restrictions on working hours, the implementation of temporary screening where possible, and best working practices.
10.9.3 In addition to earthworks and construction it is possible that piling will be required. At this stage detailed information regarding the type of piling has not been confirmed. To minimise the potential for vibration to be generated by piling it is recommended that careful consideration be given to the type of piling used.
10.9.4 With the implementation of best working practice and restriction on working hours, the noise and vibration impacts of earthworks and construction phases, are considered to be not significant.
Operational Phase Assessment – Road Traffic Noise
Existing Sensitive Receptor Locations
10.9.5 The existing noise sensitive areas in the vicinity of the proposed development, i.e. existing residential areas will be subjected to noise from existing and proposed sources.
10.9.6 Changes in road traffic noise at existing sensitive receptors as a result of development led road traffic will be negligible in the long term.
10.9.7 To summarise, the noise assessment indicates that the proposed development generated traffic will have a negligible impact, on existing sensitive receptor locations. Therefore the future noise impact from road traffic at existing sensitive receptors is considered not to be significant.
Proposed Sensitive Receptor Locations
10.9.8 The noise assessment has considered proposed sensitive receptor locations within the proposed development.
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10.9.9 The results of the baseline noise survey and noise prediction calculations indicate that the noise levels at the proposed development should not be a determining factor in granting planning permission in accordance with current guidance.
10.9.10 Mitigation measures will be incorporated into the proposed development design at the detailed design stage, to ensure the noise impacts from traffic, industrial and commercial operations are reduced to acceptable levels at proposed sensitive receptors.
10.9.11 Therefore the future noise impact from all noise sources at the proposed sensitive receptors is considered not to be significant.
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11 AIR QUALITY
11.1 Introduction
11.1.1 This chapter of the ES assesses the potential air quality impacts associated with the additional road traffic generated by the proposed development at Kingsnorth Green, Ashford. This comprises the following:
• A qualitative assessment to assess the potential air quality impacts of dust arising from the construction phase of works; and • Air dispersion modelling, using ADMS-Roads, to assess the potential air quality impact of development generated traffic.
11.1.2 This Chapter should be read in conjunction with Chapters 3 and 4 of the ES, which give details of the site location and development works to be undertaken at the site.
11.2 Planning Policy
Air Quality Standards and Objectives
11.2.1 The UK National Air Quality Strategy (NAQS) was published in March 1997 fulfilling the requirement under the Environment Act 1995 for a national air quality strategy setting out policies for the management of ambient air quality. The Strategy sets objectives for eight pollutants, which may potentially occur in the UK at levels that give cause for concern. These pollutants are: nitrogen dioxide, sulphur dioxide, carbon monoxide,
lead, fine particulates (PM 10 ), benzene, 1,3–butadiene and ozone.
11.2.2 The Strategy was reviewed and a Review Report 9 and Consultation Document 10 were published by the Department of the Environment, Transport and the Regions in 1999. A revised version (The Air Quality Strategy (AQS) 2000), which supersedes the 1997 Strategy, was published in January 2000. The AQS 2000 strengthens the objectives for a number of pollutants with the exception of that for particulates, which was replaced with the less stringent EU limit value.
11.2.3 The objectives for the eight pollutants in the Strategy provide the basis of the implementation of Part IV of the Environment Act 1995. The Air Quality Strategy objectives for each pollutant, except ozone, were given statutory status in the Air
9 Department of the Environment, Transport and the Regions, January 1999. Report on the Review of the National Air Quality Strategy, Proposals to amend the Strategy. 10 Department of the Environment, Transport and the Regions 1999, The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. A consultation document. ST13901/001 Page 145 June 2015
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Quality (England) Regulations, 2000 11 and Air Quality (England) (Amendment) Regulations 2002 12 (‘the Regulations’).
11.2.4 In 2007 the Air Quality Strategy was revised. This latest strategy 13 does not remove any of the objectives set out in the previous strategy or its addendum, apart from
replacing the provisional 2010 objective for PM 10 in England, Wales and Northern
Ireland with the exposure reduction approach for PM2.5 . The UK Government and the Devolved Administrations have now therefore set new national air quality objectives
for particulate matter smaller than 2.5µm diameter (PM 2.5 ).
11.2.5 EU Directive 2008/50/EC 14 came into force in June 2008 and was transposed into legislation in England on 11 th June 2010 as ‘The Air Quality Standards Regulations 2010’ 15 . This EU Directive consolidates existing air quality legislation and provides a
new regulatory framework for PM 2.5 .
11.2.6 The current Air Quality Standards and Objectives, as set out in the Air Quality Standards Regulations 2010, are detailed in Table 11.1.
Table 11.1 Air Quality (England) Regulations 2010. Summary of Current Air Quality Standards and Objectives
Pollutant Averaging Period Limit Value
350µg/m 3 not to be exceeded more 1 hour than 24 times a calendar year Sulphur Dioxide 125µg/m 3 not to be exceeded more 1 day than 3 times a calendar year
200µg/m 3 not to be exceeded more 1 hour than 18 times a calendar year Nitrogen Dioxide Calendar year 40µg/m 3
Benzene Calendar year 5µg/m 3
Lead Calendar year 0.5µg/m 3
50µg/m 3 not to be exceeded more 1 day than 35 times a calendar year PM 10 Calendar year 40µg/m 3
11 The Air Quality (England) Regulations 2000. SI No 928. 12 The Air Quality (Amendment) Regulations 2002. 13 Department of Environment, Food and Rural Affairs, The Air Quality Strategy for England, Scotland, Wales and Northern Ireland. July 2007. 14 Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on Ambient Air Quality and Cleaner Air for Europe. 15 Statutory Instruments 2010 No. 1001 The Air Quality Standards Regulations 2010. ST13901/001 Page 146 June 2015
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Table 11.1 Air Quality (England) Regulations 2010. Summary of Current Air Quality Standards and Objectives
Pollutant Averaging Period Limit Value
25µg/m 3 to be met by 1 st January PM 2.5 Calendar year 2015
Carbon Monoxide Maximum 8 hour daily mean 10mg/m 3
Target Value for the total content in Date by which target value should Pollutant the PM 10 fraction averaged over a be met calendar year
Arsenic 6ng/m 3 31 st December 2012
Cadmium 5ng/m 3 31 st December 2012
Nickel 20ng/m 3 31 st December 2012
Benzo(a)pyrene 1ng/m 3 31 st December 2012
11.2.7 Examples of where the Air Quality Objectives should/should not apply are included in Table 11.2. This table is taken from Local Air Quality Management Technical Guidance document LAQM.TG (09) 16 .
Table 11.2 Examples of where the Air Quality Objectives Should/Should Not Apply Objectives Should Generally Not Averaging Period Objectives Should Apply At Apply At Annual Mean All background locations where Building facades of offices or other members of the public might be places of work where members of regularly exposed. the public do not have regular Building facades of residential access. properties, schools, hospitals, libraries, Hotels, unless people live there as etc. their permanent residence. Gardens of residential properties. Kerbside sites or any other location where public exposure is expected to be short term. 24 hour (daily) All locations where the annual mean Kerbside sites, or any other location mean objectives would apply together with where public exposure is expected Hotels. to be short term. 8 hour mean Gardens of residential properties 1 1 hour mean All locations where the annual mean Kerbside sites where public would and 24 and 8-hour objectives apply. not be expected to have regular Kerbside sites (e.g. pavements of busy access. shopping streets).
16 Part IV of the Environment Act 1995: Local Air Quality Management Technical Guidance 2009. ST13901/001 Page 147 June 2015
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Table 11.2 Examples of where the Air Quality Objectives Should/Should Not Apply Objectives Should Generally Not Averaging Period Objectives Should Apply At Apply At Those parts of car parks and railway stations etc. which are not fully enclosed where members of the public might reasonably be expected to spend one hour or more. Any outdoor locations to which the public might reasonably be expected to spend one hour or longer. 15 min mean All locations where members of the public might reasonably be exposed for a period of 15 minutes or longer. 1: Such locations should represent parts of the garden where relevant public exposure is likely, for example where there is seating or play areas. It is unlikely that relevant public exposure would occur at the extremities of the garden boundary, or in front gardens although local judgement should always be applied.
11.2.8 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, July 2007, establishes the framework for air quality improvements based on measures agreed at a national and international level. However, despite these measures, it is recognised that areas of poor air quality will remain and these should be dealt with through the Local Air Quality Management (LAQM) process using locally implemented measures.
11.2.9 LAQM legislation in the Environment Act 1995 requires local authorities to conduct periodic review and assessments of air quality. These aim to identify all those areas where the air quality objectives are being, or are likely to be, exceeded.
11.2.10 All Authorities were required to undertake the first stage of review and assessment which concluded in September 2001. In those areas identified as having the potential to experience elevated levels of pollutants the authority was required to undertake a more detailed second stage review comprising two steps; Updating and Screening Assessments and Detailed Assessments. Where it was predicted that one or more of the air quality objectives would be unlikely to be met by the end of 2005, local authorities were required to proceed to a third stage, and if necessary, declare Air Quality Management Areas and make action plans for improvements in air quality, in pursuit of the national air quality objectives.
11.2.11 In 2007 an Evaluation Report was commissioned by the UK Government and Devolved Administrations. Following this review revised LAQM Technical Guidance was published in February 2009 comprising LAQM.TG(09). This revised guidance draws together previous guidance and the recommendations of the 2007 Evaluation Report.
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LAQM.TG(09) maintains the phased approach to review and assessment established in previous technical guidance. The intention is that local authorities should only undertake a level of assessment that is commensurate with the risk of an air quality objective being exceeded.
11.2.12 Where a Detailed Assessment indicates that any of the air quality objectives are likely to be exceeded, an Air Quality Management Area (AQMA) must be designated, or the geographical boundaries of an existing AQMA must be confirmed. An AQMA should only be declared if a Detailed Assessment has been undertaken.
11.2.13 Once an AQMA has been declared the local authority is required to undertake a Further Assessment within 12 months of the declaration.
11.2.14 A rolling programme of Updating and Screening Assessment and Detailed Assessment based on a three-year cycle has been laid down by Defra in its LAQM.TG(09) policy guidance. This is supplemented by Progress Reports which are intended to maintain continuity in the LAQM process between the three-yearly cycle of Review and Assessment. Progress Reports are required in the years when the authority is not completing an Updating and Screening Assessment.
11.2.15 The National Planning Policy Framework, introduced in March 2012 requires that planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants, taking into account the presence of AQMAs and the cumulative impacts on air quality from individual sites in local areas. Planning decisions should ensure that any new development in AQMAs is consistent with the local air quality action plan.
11.2.16 The Planning Practice Guidance states that whether or not air quality is relevant to a planning decision will depend on the proposed development and its location. Concerns could arise if the development is likely to generate air quality impacts in an area where air quality is known to be poor. They could also arise where the development is likely to adversely impact upon the implementation of air quality strategies and action plans and/or, in particular, lead to a breach of EU legislation (including that applicable to wildlife).
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Ashford Borough Council Local Air Quality Management Review and Assessment
11.2.17 Ashford Borough Council have undertaken three Updating and Screening Assessments
and four Progress Reports, to identify potential exceedances of the annual mean NO 2
and/ or PM 10 objective.
11.2.18 From the most recent report available, the 2014 Progress Report, it is understood that Ashford Borough Council currently have no Air Quality Management Areas (AQMAs) declared within the borough. The site is therefore not located within an area of air quality concern.
11.2.19 Ashford Borough Council maintains a network of NO 2 diffusion tubes to monitor the air quality across the area. There are approximately 16 diffusion tubes spread across the district located in Ashford, South West Ashford, near Junction 10 at the M20 and Tenterdon; one of which (ABC ref: AS06), is located along Hythe Road and will be used to verify receptors within close proximity.
11.3 Methodology
Consultation and Scope of Assessment
11.3.1 Consultation was undertaken in a series of communications, on 20 th August 2014, with the Environmental Health Officer at ABC. The following points were discussed and agreed;
• A construction phase dust assessment will be undertaken in accordance with the Institute of Air Quality Management (IAQM) guidance document ‘Guidance on the Assessment of Dust from Demolition and Construction‘, (February 2014);
• A detailed air quality assessment will be undertaken using the air dispersion model ADMS-Roads. This will consider the potential air quality impact of additional traffic, generated by the proposed development, at existing
sensitive receptor locations. In addition, NO 2 and PM 10 concentrations will be predicted at sensitive areas of the proposed development;
• Meteorological data will be obtained from the London Gatwick Airport recording station, located approximately 73km from the proposed development. This recording station is considered to be the most representative of conditions at the site due to its location away from the coast and its similar altitude;
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• A roadside NO 2 diffusion tube is located at Hythe Road (ABC ref: AS06). Monitoring data from 2013 will be used to undertake verification of the air dispersion model for receptors within close proximity. It is not possible to
verify receptor locations closer to the proposed development or PM 10 concentrations as there are no monitoring locations in the vicinity of the proposed development; and
• There are no representative background monitoring locations in the vicinity of the proposed development. Background pollutant concentrations will therefore be obtained from the Defra default concentration maps.
Construction Phase Assessment – Dust Emissions
11.3.2 To assess the impacts associated with dust and PM 10 releases, during the construction phase of the development, an assessment has been undertaken in accordance with the Institute of Air Quality Management (IAQM) guidance document ‘Guidance on the Assessment of Dust from Demolition and Construction‘, (February 2014).
Step 1
11.3.3 Step 1 of the assessment is to screen the requirement for a more detailed assessment. The guidance states that an assessment will normally be required where there are existing human sensitive receptors within 350m of the site boundary and/or within 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).
11.3.4 With regards to ecological receptors, the guidance states that an assessment will normally be required where there are existing ecological receptors within 50m of the site boundary and/or within 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).
11.3.5 As there are existing sensitive receptors locations within 350m of the site boundary, it is necessary to proceed to Step 2 of the assessment.
Step 2
11.3.6 Step 2 of the assessment determines the potential risk of dust arising in sufficient quantities to cause annoyance and/or health and/or ecological impacts. The risk is related to:
• The activities being undertaken (demolition, number of vehicles and plant etc.);
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• The duration of these activities;
• The size of the site;
• The meteorological conditions (wind speed, direction and rainfall);
• The proximity of receptors to the activity;
• The adequacy of the mitigation measures applied to reduce or eliminate dust; and
• The sensitivity of receptors to dust.
11.3.7 The risk of dust effects is determined using four risk categories: negligible, low, medium and high risk. A site is allocated to a risk category based upon two factors:
• Step 2A – the scale and nature of the works which determines the potential dust emission magnitude as small, medium or large; and
• Step 2B – the sensitivity of the area to dust impacts which is defined as low, medium or high sensitivity.
11.3.8 The risk of dust effects is determined for four types of construction phase activities, with each activity being considered separately. If a construction phase activity is not taking place on the site, then it does not need to be assessed. The four types of activities to be considered are:
• Demolition;
• Earthworks;
• Construction; and
• Trackout.
Step 3
11.3.9 Step 3 of the assessment determines the site-specific mitigation required for each of the activities, based on the risk determined in Step 2. Mitigation measures are detailed in guidance published by the Greater London Authority 17 , recommended for use outside the capital by LAQM guidance and the IAQM guidance document itself. If the risk is classed as negligible, no mitigation measures beyond those required by legislation will be necessary.
17 Greater London Authority (2006) The Control of Dust and Emissions from Construction and Demolition: Best Practice Guidance ST13901/001 Page 152 June 2015
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Step 4
11.3.10 Step 4 assesses the residual effect, with mitigation measures in place, to determine whether or not these are significant.
Existing Dust Sensitive Receptors – Human Receptors
11.3.11 The closest existing sensitive receptors to the proposed development are residential in nature and are detailed in Table 11.3.
Table 11.3 Existing Sensitive Receptors: Construction Phase Dust Assessment Approximate Distance Receptor Direction from the Site from the Site Boundary Closest dwellings Residential properties on Pound Lane North approximately 18m away Residential properties on Myrtle Closest dwellings North and East Court approximately 14m away Residential Properties on Pound Closest dwellings North Court approximately 8m away Closest dwellings Residential Properties on Church Hill North approximately 5m away Properties in different Residential Properties on Ashford Closest dwellings directions depending on Road approximately 4m away development area Residential Properties on Magpie Hall Closest dwellings South Road approximately 6m away Closest dwellings Residential Properties on Steel Close South approximately 12m away East and South of Area 3 Closest dwellings Residential Properties on Bond Lane and West of Area 4 approximately 3.5m away Residential Properties on Stumble Closest dwellings East Lane approximately 3.5m away
Existing Dust Sensitive Receptors – Ecological Receptors
11.3.12 There are no statutory designated sensitive ecological sites located within 50m of the site boundary and/ or within 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s). Ecological receptors do not therefore need to be considered within the assessment.
Operational Phase Assessment – Road Traffic Emissions
11.3.13 The air dispersion model ADMS-Roads (CERC, Version 3.2) has been used to assess the potential impact of development generated traffic on local air quality at existing receptor locations. In addition, pollutant concentrations have also been predicted at the proposed sensitive areas of the development i.e. at locations representative of the proposed residential dwellings. The air dispersion model has been used to predict
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nitrogen dioxide (NO 2) and particulate matter (PM 10 ) concentrations, as these are the pollutants most likely to exceed the air quality objectives.
11.3.14 Air quality modelling has been carried out for two assessment years, as follows:
• Base and Verification Year (2013): This is the most recent year for which meteorological data, road traffic data and air quality monitoring data is available; and
• Opening/ Future Year (2023): This is considered both without the development and with the development in place.
Road Traffic Data
11.3.15 The ADMS-Roads model requires the input of detailed road traffic flow information for those routes which will be affected by the proposed development. The traffic flow information used in the assessment is included in Appendix 11.1.
11.3.16 Detailed traffic flow information, for use in the ADMS-Roads model, has been obtained from Peter Brett Associates, the appointed transport consultant for the project. The traffic flow information has been provided as 24 hour AADT flows and HGV percentages for the following roads:
• M20 motorway;
• A20 Fougeres Way/Hythe Road;
• A2042 Bad Munstereifel Road/Romney Marsh Road;
• A2070 Bad Munstereifel Road/Kennington Road;
• A251 Trinity Road;
• A292 Hythe Road;
• B2229 Norman Road;
• Ashford Road;
• The Boulevard;
• Church Hill;
• Forestall Meadow;
• Kimberley Way;
• Magpie Hall Road;
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• Malcolm Sargent Road;
• Pound Lane;
• Romney Marsh Road;
• Steeds Lane;
• Waterbrook Avenue; and
• The proposed site accesses.
11.3.17 Air quality modelling has been carried out to estimate pollutant concentrations, due to road traffic emissions, for a total of three scenarios:
• Scenario 1: 2013 Base and Verification Year;
• Scenario 2: 2023 Proposed Opening/ Future Year ‘Without Development’; and
• Scenario 3: 2023 Proposed Opening/ Future Year ‘With Development.
Meteorological Data
11.3.18 The meteorological data used in the air quality modelling has been provided by the Met Office. Meteorological data has been obtained for 2013 from the London Gatwick Airport recording station, which is located approximately 73km from the proposed development.
11.3.19 This recording station is considered to be the most representative of the conditions at the proposed development due to its location relative to the proposed development. The meteorological data provides hourly wind speed and direction information. The 2013 wind rose for London Gatwick Airport is included in Appendix 11.2.
Existing Sensitive Receptor Locations
11.3.20 Sixteen representative existing sensitive receptor locations (identified as ESR 1 to ESR 16) have been selected along those routes most likely to be affected by the proposed development.
11.3.21 Details of the existing sensitive receptors considered within the assessment are provided in Table 11.4 and their location are shown on Drawing 11.1.
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Table 11.4 Existing Sensitive Receptor Locations
Grid Reference Type of Receptor Address Easting Northing Receptor
ESR 1 First Stop, Magpie Hall Road 599838 138436 Residential
ESR 2 The Birches, Magpie Hall Road 599388 138576 Residential
ESR 3 Mayclair, Steeds Lane 600123 138458 Residential Wainstones, Mill Hill, Ashford ESR 4 599964 138935 Residential Road Pine Tree Cottage, Mill Hill, ESR 5 600118 139643 Residential Ashford Road ESR 6 15 Pound Lane 600053 139486 Residential
ESR 7 School House, Church Hill 600199 139359 Residential
ESR 8 Chewton Lodge, Ashford Road 600306 139686 Residential
ESR 9 18 Redberry Road 600650 140081 Residential
ESR 10 Premier Inn, Ashford Central 602992 140533 Hotel
ESR 11 8 Nightingale Close 603571 141136 Residential
ESR 12 17 Nelson Close 603608 141502 Residential
ESR 13 21 Lacton Way 603499 141768 Residential
ESR 14 65 The Street 603739 141842 Residential William Harvey Hospital ESR 15 604117 142052 Hospital (Ashford) ESR 16 406e Hythe Road 603151 141976 Residential
ESR 17 Bond Farm 600497 138729 Residential
ESR 18 Old Mumford Farm 600804 138949 Residential
ESR 19 Avalon, Stumble Lane 600836 138313 Residential
ESR 20 Woodcock Green, Church Hill 600940 138748 Residential
Proposed Sensitive Receptor Locations
11.3.22 Ten proposed sensitive receptor locations (identified as PR 1 to PR 10) have been selected within the site at locations closest to the proposed site access roads and Ashford Road.
11.3.23 Pollutant concentrations have been predicted for Scenario 3 (as detailed in paragraph 11.3.17). It is only necessary to consider the ‘with development’ scenarios for
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proposed receptor locations as they will not experience any ‘without development’ conditions. It is not therefore necessary to consider the changes in pollutant concentrations at the proposed receptor locations.
11.3.24 The proposed sensitive receptor locations, considered in this assessment, are detailed in Table 11.5 and shown on Drawing 11.1.
Table 11.5 Proposed Sensitive Receptor Locations
Receptor Grid Reference Location Location Easting Northing Proposed receptor location within Area 1 closest to PR 1 600092 139257 the proposed site access road and Ashford Road. Proposed receptor location within Area 3 closest to PR 2 600067 139159 the proposed site access road and Ashford Road. Proposed receptor location within Area 3 closest to PR 3 600031 138987 Ashford Road. Proposed receptor location within Area 3 closest to PR 4 599932 138698 the proposed site access road and Ashford Road. Proposed receptor location within Area 2 closest to PR 5 599904 138653 Ashford Road. Proposed receptor location within Area 2 closest to PR 6 599864 138495 the proposed site access road and Ashford Road. Proposed receptor location within Area 3 closest to PR 7 600095 138541 the proposed site access road and Steeds Lane. Proposed receptor location within Area 4 closest to PR 8 600323 138495 the proposed site access road and Steeds Lane. Proposed receptor location within Area 4 closest to PR 9 600522 138328 the proposed site access road and Steeds Lane. Proposed receptor location within Area 3 closest to PR 10 600521 138780 the proposed site access road and Bond Lane.
Model Validation, Verification and Adjustment
11.3.25 Defra Local Air Quality Management Technical Guidance, 2009, (LAQM.TG(09)) recognises that model validation generally refers to detailed studies that have been carried out by the model supplier or a regulatory agency. The ADMS-Roads model has been validated by the supplier CERC.
11.3.26 Model verification is required to check the performance of the model at a local level. The verification of the ADMS-Roads model has been achieved by modelling concentrations at an existing monitoring location and comparing the modelled concentration with the measured concentration. As there is no roadside continuous analyser located along the routes adjacent to the proposed development, bias- adjusted monitoring data from one diffusion tube location has been used.
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11.3.27 The diffusion tube monitoring data used in the model verification is summarised in Table 11.6.
Table 11.6 NO 2 Diffusion Tube Data
Grid Reference NO 2 Annual Average Site Name Mean (µg/m³) with Bias X Y Correction Applied* AS06 603153 141990 33.3
*Obtained from Ashford Borough Council 2014 Progress Report
11.3.28 Diffusion tube AS06 is located within close proximity to Hythe Road and the M20 motorway. As ESR 11 to 16 are also located within relative close proximity to the M20 motorway, it was decided that the adjustment factor derived from the verification process would be applied to ESR 11 to 16 only. This was done in order to ensure greater accuracy of the modelling results and to prevent potential over-prediction at the other receptor locations.
11.3.29 It has not been possible to carry out verification for PM 10 concentrations as monitoring data is not available in the vicinity of the proposed development.
11.3.30 By comparing the monitoring data with the predicted concentration, an evaluation of the ADMS-Roads model’s performance has been made. Further details of the model verification procedure are included in Appendix 11.3. Uncorrected and corrected pollutant concentrations are included in Appendix 11.4.
Information Sources
11.3.31 The following sources of information have been used in the preparation of this report:
• Part IV Environment Act, Chapter 25, Air Quality, 1995;
• DEFRA, The UK National Air Quality Strategy, March 1997;
• The Air Quality Standards Regulations 2010;
• Department for the Environment, Food and Rural Affairs, Local Air Quality Management Technical Guidance LAQM.TG(09), published February 2009;
• Environment Protection UK (EPUK) Development Control: Planning for Air Quality (2010 Update), 2010;
• Institute of Air Quality Management (IAQM), Guidance on the Assessment of Dust from Demolition and Construction, published February 2014;
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• Ashford Borough Council, 2014 Progress Reports;
• Meteorological data for 2013 from the Gatwick Airport recording station, obtained from ADM Limited; and
• Traffic flow information, provided by Peter Brett Associates (detailed in Appendix 11.1).
11.4 Assessment of Significance
Construction Phase Assessment – Dust Emissions
11.4.1 The Institute of Air Quality Management (IAQM) guidance document ‘ Guidance on the Assessment of Dust from Demolition and Construction’ (February 2014) details criteria
for assessing the sensitivity of an area to dust soiling effects and health effects of PM 10 , as summarised in Tables 11.7 to 11.9 below.
11.4.2 The guidance then goes on to provide significance criteria for the classification of dust effects from demolition, earthworks, construction activities and trackout, as summarised in Tables 11.10 to 11.12 below.
Sensitivity of the Area – Human Receptors
11.4.3 The sensitivity categories for different types of receptors, to both dust soiling effects
and the health effects of PM 10 , are described in Table 11.7.
Table 11.7 Sensitivity Categories for Human Receptors
Sensitivity Dust Soiling Effects Health effects of PM 10 Category
Users can reasonably expect to enjoy a Locations where members of the public high level of amenity; are exposed over a period of time Appearance, aesthetics or value of a relevant to the air quality objective for property would be diminished; PM 10 ; High Examples include dwellings, museums Examples include residential properties, and other culturally important hospitals, schools, and residential care collections, medium and long term car homes. parks and car show rooms.
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Table 11.7 Sensitivity Categories for Human Receptors
Sensitivity Dust Soiling Effects Health effects of PM 10 Category
Users would expect to enjoy a Locations where people are exposed as reasonable level of amenity, but would workers and exposure is over a period not reasonably expect to enjoy the of time relevant to the air quality same level of amenity as in their home; objective for PM 10 ; The appearance, aesthetics or value of Examples include office and shop their property could be diminished; workers but will generally not include Medium People or property wouldn’t workers occupationally exposed to reasonably be expected to be PM 10 . continuously present or regularly for extended periods of time; Examples include parks and places of work. Enjoyment of amenity would not Locations where human exposure is reasonably be expected; transient; Property would not be diminished in Examples include public footpaths, appearance, aesthetics or value; playing fields, parks and shopping People or property would expected to streets. Low be present only for limited periods of time; Examples include playing fields, farmland (unless commercially-sensitive horticultural), footpaths, short term car parks and roads.
11.4.4 Based upon the category of receptor sensitivity, the sensitivity of the area to dust soiling effects is determined using the criteria detailed in Table 11.8.
Table 11.8 Sensitivity of the Area to Dust Soiling Effects on People and Property
Receptor Number of Distance from Source (m) Sensitivity Receptors <20m <50m <100m <350m
>100 High High Medium Low
High 10-100 High Medium Low Low
1-10 Medium Low Low Low
Medium >1 Medium Low Low Low
Low >1 Low Low Low Low
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11.4.5 Based upon the category of receptor sensitivity, the sensitivity of the area to the
health effects of PM 10 is determined using the criteria detailed in Table 11.9.
Table 11.9 Sensitivity of the Area to Human Health Impacts Annual Mean Receptor Number of Distance from Source (m) PM 10 Sensitivity Receptors Concentration <20m <50m <100m <200m <350m >100 High High High Medium Low
>32µg/m 3 10-100 High High Medium Low Low
1-10 High Medium Low Low Low
>100 High High Medium Low Low
28-32µg/m 3 10-100 High Medium Low Low Low
1-10 High Medium Low Low Low High >100 High Medium Low Low Low
24-28µg/m 3 10-100 High Medium Low Low Low
1-10 Medium Low Low Low Low
>100 Medium Low Low Low Low
<24µg/m 3 10-100 Low Low Low Low Low
1-10 Low Low Low Low Low
- >10 High Medium Low Low Low Medium - 1-10 Medium Low Low Low Low
Low - >1 Low Low Low Low Low
11.4.6 The risk of dust being generated by demolition activities at the site is determined using the criteria in Table 11.10.
Table 11.10 Risk of Dust Impacts - Demolition
Dust Emission Magnitude Sensitivity of Area Large Medium Small
High High Risk Medium Risk Medium Risk
Medium High Risk Medium Risk Low Risk
Low Medium Risk Low Risk Negligible
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11.4.7 The risk of dust being generated by earthworks and construction activities at the site is determined using the criteria in Table 11.11.
Table 11.11 Risk of Dust Impacts – Earthworks and Construction
Dust Emission Magnitude Sensitivity of Area Large Medium Small
High High Risk Medium Risk Low Risk
Medium Medium Risk Medium Risk Low Risk
Low Low Risk Low Risk Negligible
11.4.8 The risk of dust being generated by trackout from the site is determined using the criteria in Table 11.12.
Table 11.12 Risk of Dust Impacts – Trackout
Dust Emission Magnitude Sensitivity of Area Large Medium Small
High High Risk Medium Risk Low Risk
Medium Medium Risk Low Risk Negligible
Low Medium Risk Low Risk Negligible
Operational Phase Assessment – Road Traffic Emissions
Air Quality Significance Criteria
11.4.9 In order to assess the significance of the impact of the operational phase of the proposed development on local air quality, significance criteria have been used for
NO 2 and PM 10 , as detailed in Tables 11.13 and 11.14. The criteria relate to NO 2 and
PM 10 only, as these are the pollutants most likely to exceed the air quality objectives. The criteria are taken from Environmental Protection UK (EPUK) document ‘Development Control: Planning for Air Quality (2010 Update)’.
11.4.10 The impact magnitude and impact descriptors in relation to specific objectives for
annual mean NO 2 and PM 10 concentrations are detailed in Table 11.13.
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Table 11.13 Definition of Impact Magnitude for Changes in Annual Mean NO 2 and PM 10 Concentration Magnitude of change Annual Mean
Large Increase/decrease >4µg/m 3
Medium Increase/decrease 2-4µg/m 3
Small Increase/decrease 0.4-2µg/m 3
Imperceptible Increase/decrease <0.4µg/m 3
11.4.11 The EPUK document indicates that when describing an air quality impact at a specific receptor, the actual concentration at the receptor should be taken into account, in combination with the magnitude of change, using the approach detailed in Table 11.14. This approach is appropriate for the assessment of annual mean concentrations 3 of NO 2 and PM 10 in England i.e. where the objective concentration is 40µg/m .
Table 11.14 Air Quality Impact Descriptors for Changes to Annual Mean NO 2 and PM 10 Concentrations at a Receptor
Absolute concentration in relation Change in concentration* to objective / limit value Small Medium Large
Increase with scheme Above objective/limit value with Substantial Slight Adverse Moderate Adverse scheme (>40µg/m 3) Adverse Just below objective/limit value Moderate Slight Adverse Moderate Adverse with scheme (36-40µg/m 3) Adverse Below objective/limit value with Negligible Slight Adverse Slight Adverse scheme (30-36µg/m 3) Well below objective/limit value Negligible Negligible Slight Adverse with scheme (<30µg/m 3) Decrease with scheme Above objective/limit value Moderate Substantial Slight Beneficial without scheme (>40µg/m 3) Beneficial Beneficial Just below objective/limit value Moderate Moderate Slight Beneficial without scheme (36-40µg/m 3) Beneficial Beneficial Below objective/limit value Negligible Slight Beneficial Slight Beneficial without scheme (30-36µg/m 3) Well below objective/limit value Negligible Negligible Slight Beneficial without scheme (<30µg/m 3) *An imperceptible change (see Table 11.13) would be described as negligible
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Impact Magnitude and Receptor Sensitivity
11.4.12 The significance of an environmental impact for vehicular emissions is determined by the interaction of magnitude and sensitivity. The methodology for determining the sensitivity of the receptor is shown in Table 11.15.
Table 11.15 Methodology for Determining Sensitivity
Sensitivity Methodology
The location has little ability to absorb change without fundamentally altering its High present character, or is of international or national importance. e.g. a hospital The location has moderate capacity to absorb change without significantly altering Moderate its present character, or is of high importance. e.g. a residential dwelling The location is tolerant of change without detriment to its character, is of low or Low local importance. e.g. an industrial development
11.4.13 The Impact Significance Matrix used in this assessment is shown in Table 11.16.
Table 11.16 Impact Significance Matrix
Sensitivity Magnitude of Impact High Moderate Low
Substantial Substantial – Moderate Substantial – Minor Substantial Adverse/Beneficial Adverse/Beneficial Adverse/Beneficial Substantial – Moderate Moderate – Slight Moderate Slight Adverse/Beneficial Adverse/Beneficial Adverse/Beneficial Moderate – Slight Slight Slight Adverse/Beneficial Slight – Negligible Adverse/Beneficial Negligible/Not Negligible/Not Negligible/Not Negligible Significant Significant Significant 11.5 Baseline Assessment
Operational Phase Assessment – Road Traffic Emissions
Background Air Pollutant Concentrations
11.5.1 The ADMS assessment needs to take into account background concentrations upon which the local, traffic derived pollution is superimposed. The data may be derived through long term ambient measurements at background sites, remote from immediate sources of air pollution or alternatively from the default concentration maps, which have been provided for use with the revised LAQM.TG(09) guidance.
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11.5.2 In the absence of data being available from a representative background continuous analyser, background pollutant concentrations have been obtained from default concentration maps provided by Defra on their Local Air Quality Management web pages (http://laqm.defra.gov.uk/review-and-assessment/tools/backgroundmaps. html).
11.5.3 Current evidence suggests that nitrogen dioxide (NO2) background concentrations are not decreasing in accordance with expected reductions. At present, there is
uncertainty about how background NO 2 concentrations will change in future years.
11.5.4 To provide a robust assessment, it has been assumed that there will be no decrease
in NO 2 concentrations and therefore 2013 background concentrations and emission factors have been used in the opening/ future year model scenario.
11.5.5 The background pollutant concentrations used in the assessment are detailed in Table 11.17.
Table 11.17 Background Air Pollutant Concentrations Obtained from Defra Default Concentration Maps. NO x, NO 2 and PM 10 Concentrations Obtained from the 2011-Based Defra Default Concentration Maps (Grid Square: 603500m, 141500m) Pollutant Concentrations (µg/m 3) 2013 Background Concentrations
Oxides of Nitrogen (NO x) 25.04
Nitrogen Dioxide (NO 2) 18.42
Particulates (PM 10 ) 18.59
Modelled Baseline Concentrations
11.5.6 The baseline assessment (i.e. Scenarios 1 and 2) has been carried out for the sixteen
existing sensitive receptors considered (ESR 1 to ESR 16). The uncorrected PM 10 and
corrected NO 2 concentrations are detailed in Table 11.18 and included in Appendix 11.4 and 11.5, respectively.
Table 11.18 Calculated Annual Mean Concentrations (µg/m 3)
Receptor NO 2 (Corrected) PM 10 (Uncorrected) Scenario 1: 2013 Scenario 2: 2023 Scenario 1: 2013 Scenario 2: 2023 ESR 1 20.43 20.73 18.87 18.91
ESR 2 19.92 20.22 18.84 18.90
ESR 3 19.18 19.8 18.70 18.71
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Table 11.18 Calculated Annual Mean Concentrations (µg/m 3)
Receptor NO 2 (Corrected) PM 10 (Uncorrected) Scenario 1: 2013 Scenario 2: 2023 Scenario 1: 2013 Scenario 2: 2023 ESR 4 20.40 20.67 18.95 19.00
ESR 5 21.89 22.34 19.10 19.18
ESR 6 19.44 20.00 18.76 18.86
ESR 7 21.29 22.01 19.02 19.14
ESR 8 21.39 21.65 19.09 19.14
ESR 9 22.04 22.78 19.16 19.29
ESR 10 21.65 21.96 19.02 19.07
ESR 11 24.09† 24.71† 19.42 19.53
ESR 12 27.62† 28.98† 19.62 19.79
ESR 13 31.85† 34.08† 20.13 20.39
ESR 14 29.43† 31.11† 19.98 0.21
ESR 15 23.56† 24.48† 19.16 19.26
ESR 16 26.02† 26.95† 19.56 19.68
ESR 17 19.37 19.52 18.71 18.73
ESR 18 19.76 20.18 18.82 18.90
ESR 19 18.98 19.05 18.65 18.66
ESR 20 19.10 19.29 18.70 18.73
* NO 2 concentrations obtained by inputting predicted NO x concentrations into the NO x to NO 2 calculator 18 in accordance with LAQM.TG(09) † Corrected using the adjustment factor derived from the verifica on process Scenario 1: 2013 Base and Verification Year
11.5.7 The 2013 baseline annual mean NO 2 concentrations (uncorrected) for receptors ESR 1 to ESR 10 and ESR 17 to ESR 20 are predicted to range from 18.98 to 22.04µg/m 3. 3 Exceedance of the annual mean objective concentration for NO 2 (40µg/m ) is not predicted to occur.
11.5.8 The 2013 baseline annual mean NO 2 concentrations (corrected) for receptors ESR 11 to ESR 16 (i.e. receptor locations located within relative close proximity to the M20)
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are predicted to range from 23.56 to 31.85µg/m 3. Exceedance of the annual mean 3 objective concentration for NO 2 (40µg/m ) is not predicted to occur.
11.5.9 The 2013 baseline annual mean PM 10 concentrations (uncorrected) are predicted to range from 18.65 to 20.13µg/m 3 for the twenty existing sensitive receptor locations
considered. Exceedance of the annual mean objective concentration for PM 10 (40µg/m 3) is not predicted to occur.
Scenario 2: 2023 Opening/ Future Year, Without Development
11.5.10 The 2023 ‘without development’ annual mean NO 2 concentrations (uncorrected) for receptors ESR 1 to ESR 10 and ESR 17 to ESR 20 are predicted to range from 19.05 to 3 22.78µg/m . Exceedance of the annual mean objective concentration for NO 2 (40µg/m 3) is not predicted to occur.
11.5.11 The 2023 ‘without development’ annual mean NO 2 concentrations (corrected) for receptors ESR 11 to ESR 16 are predicted to range from 24.48 to 34.08µg/m 3. 3 Exceedance of the annual mean objective concentration for NO 2 (40µg/m ) is not predicted to occur.
11.5.12 The 2023 ‘without development’ annual mean PM 10 concentrations (uncorrected) are predicted to range from 18.66 to 20.39µg/m 3 for the twenty existing sensitive receptor locations considered. Exceedance of the annual mean objective 3 concentration for PM 10 (40µg/m ) is not predicted to occur.
11.6 Impact Assessment
Construction Phase Assessment – Dust Emissions
11.6.1 The main potential dust impacts associated with the construction phase of works are as follows:
• Earthworks which may be required prior to the construction phase of works. Sources of dust can include: o Cleaning the site; o Stripping and stockpiling of topsoil and subsoil; o Ground excavation; o Bringing in, tipping and spreading materials on site; o Stockpiling materials; o Levelling ground; o Trenching;
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o Road construction; o Vehicle movements on site roads; and o Windblown materials from site. • Construction which will involve the construction of individual building access roads, the car parking areas and the buildings themselves; and • Trackout which is the transport of dust and dirt by vehicles travelling from a construction site on to the public road network. This may occur through the spillage of dusty materials onto road surfaces or through the transportation of dirt by vehicles that have travelled over muddy ground on the site. This dust and dirt can then be deposited and re-suspended by other vehicles.
11.6.2 At this stage, it has been assumed that there are no demolition activities associated with the proposed development. Demolition has therefore not been considered within this assessment.
Step 2A
11.6.3 Step 2A of the construction phase dust assessment has defined the potential dust emission magnitude from earthworks, construction activities and trackout in the absence of site specific mitigation. Examples of the criteria for the dust emission classes are detailed in the IAQM guidance.
Step 2B
11.6.4 Step 2B of the construction phase dust assessment has defined the sensitivity of the area, taking into account the significance criteria detailed in Tables B5.7 to B5.9, to earthworks, construction and trackout. The sensitivity of the area to each activity is assessed for potential dust soiling and human health effects.
Step 2B
11.6.5 For earthworks and construction, there are between 10 and 100 residential receptor locations within 20 m of where these activities may take place.
11.6.6 For trackout, there are between 10 and 100 residential receptor locations within 50m of where trackout may occur, for a distance of up to 500m from the proposed site accesses.
Step 2C
11.6.7 Step 2C of the construction phase dust assessment has defined the risk of impacts from each activity. The dust emission magnitude is combined with the sensitivity of
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the surrounding area. The risk of dust impacts from each activity, with no mitigation in place, has been assessed in accordance with the criteria detailed in Tables 11.10 to 11.12.
Summary
11.6.8 Table 11.19 details the results of Step 2 of the construction phase assessment for human receptors.
Table 11.19 Construction Phase Dust Assessment (Step 2) – Human Receptors
Activity
Demolition Earthworks Construction Trackout
Step 2A
Dust Emission Magnitude N/A Large a Large b Large c
Step 2B
Sensitivity of Closest Receptors N/A High High High Sensitivity of Area to Dust Soiling N/A High High High Effects Sensitivity of Area to Human N/A Low d Low d Low d Health Effects Step 2C
Dust Risk: Dust Soiling N/A High High High
Dust Risk: Human Health N/A Low Low Low
a. Total site area of more than 10,000m 2 b. Total building volume estimated to be more than 100,000m 3 c. Estimation of HGV movements per day (>50 HGVs per day and unpaved road length of <100m) 3 d. Background annual mean PM 10 concentration is considered to be less than 24µg/m (based on data obtained from the LAQM defra default concentration maps, for the appropriate grid squares)
Operational Phase Assessment – Road Traffic Emissions
Existing Sensitive Receptor Locations
11.6.9 The impact assessment has been carried out for the twenty representative existing sensitive receptor locations (ESR 1 to ESR 20). Table 11.20 shows the changes in pollutant concentrations between 2023 Opening/Future Year ‘without development’
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and ‘with development’ scenarios. The uncorrected NO 2 and PM 10 concentrations and
corrected NO 2 concentrations are detailed in Appendices 11.4.
Table 11.20 Predicted NO 2 and PM 10 Concentrations at Existing Sensitive Receptor Locations for 2023 ‘Without Development’ and ‘With Development’ Scenarios Calculated Annual Mean Concentrations (µg/m 3) Receptor Level of Development NO 2 PM 10
Without development 20.73 18.91
ESR 1 With development 20.78 18.92
With – without development + 0.05µg/m³ + 0.01µg/m³
Without development 20.22 18.90
ESR 2 With development 20.23 18.90
With – without development + 0.01µg/m³ +/- 0.00µg/m³
Without development 19.28 18.71
ESR 3 With development 19.32 18.72
With – without development + 0.04µg/m³ + 0.01µg/m³
Without development 20.67 19.00
ESR 4 With development 20.67 19.01
With – without development +/- 0.00µg/m³ + 0.01µg/m³
Without development 22.34 19.18
ESR 5 With development 22.56 19.22
With – without development + 0.22µg/m³ + 0.04µg/m³
Without development 20.00 18.86
ESR 6 With development 20.07 18.87
With – without development + 0.07µg/m³ + 0.01µg/m³
Without development 22.01 19.14
ESR 7 With development 22.14 19.16
With – without development + 0.13µg/m³ + 0.02µg/m³
Without development 21.65 19.14
ESR 8 With development 22.13 19.24
With – without development + 0.48µg/m³ + 0.10µg/m³
Without development 22.78 19.29 ESR 9 With development 23.19 19.36
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Table 11.20 Predicted NO 2 and PM 10 Concentrations at Existing Sensitive Receptor Locations for 2023 ‘Without Development’ and ‘With Development’ Scenarios Calculated Annual Mean Concentrations (µg/m 3) Receptor Level of Development NO 2 PM 10
With – without development + 0.41µg/m³ + 0.07µg/m³
Without development 21.96 19.07
ESR 10 With development 22.01 19.08
With – without development + 0.05µg/m³ + 0.01µg/m³
Without development 24.71† 19.53
ESR 11 With development 24.80† 19.55
With – without development + 0.09µg/m³ + 0.02µg/m³
Without development 28.98† 19.79
ESR 12 With development 29.02† 19.80
With – without development + 0.04µg/m³ + 0.01µg/m³
Without development 34.08† 20.39
ESR 13 With development 34.09† 20.40
With – without development + 0.01µg/m³ + 0.01µg/m³
Without development 31.09† 20.21
ESR 14 With development 31.11† 20.21
With – without development + 0.02µg/m³ +/- 0.00µg/m³
Without development 22.48† 19.26
ESR 15 With development 24.48† 19.26
With – without development +/- 0.00µg/m³ +/- 0.00µg/m³
Without development 26.95† 19.68
ESR 16 With development 26.97† 19.68
With – without development + 0.02µg/m³ +/- 0.00µg/m³
Without development 19.52 18.73
ESR 17 With development 19.60 18.74
With – without development + 0.08µg/m³ + 0.01µg/m³
Without development 20.18 18.90
ESR 18 With development 20.20 18.90
With – without development + 0.02µg/m³ +/- 0.00µg/m³
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Table 11.20 Predicted NO 2 and PM 10 Concentrations at Existing Sensitive Receptor Locations for 2023 ‘Without Development’ and ‘With Development’ Scenarios Calculated Annual Mean Concentrations (µg/m 3) Receptor Level of Development NO 2 PM 10
Without development 19.05 18.66
ESR 19 With development 19.06 18.67
With – without development + 0.01µg/m³ + 0.01µg/m³
Without development 19.29 18.73
ESR 20 With development 19.31 18.74
With – without development + 0.02µg/m³ +/- 0.00µg/m³
† Corrected using the adjustment factor derived from the verification process
Scenario 3: 2023 Opening/Future Year ‘With Development’
11.6.10 The 2023 ‘with development’ annual mean NO 2 concentrations (uncorrected) for receptors ESR 1 to ESR 10 and ESR 17 to ESR 20 are predicted to range from 19.06 to 3 23.19µg/m . Exceedance of the annual mean objective concentration for NO 2 (40µg/m 3) is not predicted to occur.
11.6.11 The 2023 ‘with development’ annual mean NO 2 concentrations (corrected) for receptors ESR 11 to ESR 16 (i.e. receptor locations located within relative close proximity to the M20) are predicted to range from 24.48 to 34.09µg/m 3. Exceedance 3 of the annual mean objective concentration for NO 2 (40µg/m ) is not predicted to occur.
11.6.12 The 2023 ‘with development’ annual mean PM 10 concentrations (uncorrected) are predicted to range from 18.67 to 20.40µg/m 3 for the twenty existing sensitive receptor locations considered. Exceedance of the annual mean objective 3 concentration for PM 10 (40µg/m ) is not predicted to occur.
Assessment of Significance
11.6.13 Using the air quality significance criteria, detailed in Section 11.4 of this chapter, the impacts on air quality due to changes in pollutant concentrations can be assessed at the existing sensitive receptor locations considered.
11.6.14 In 2023, for NO 2, sixteen of the twenty existing sensitive receptors considered are
predicted to experience an imperceptible increase in NO 2 concentrations as a result
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of the proposed development (i.e. an increase of less than 0.4µg/m 3, in accordance
with Table 11.13). ESR 8 and ESR 9 are predicted to experience a small increase in NO 2 concentrations as a result of the proposed development (i.e. an increase of between 0.4 and 2µg/m 3, in accordance with Table 11.13). The remaining two existing sensitive receptors are predicted to experience no change (i.e. 0.00µg/m 3). All twenty existing receptor locations are therefore predicted to experience a negligible impact, or no impact, as a result of the proposed development, in accordance with Table 11.14.
11.6.15 All predicted NO 2 concentrations are below the objective/ limit values and no 3 exceedances of the NO 2 annual mean air quality objective of 40µg/m are predicted to occur in 2023 for both the ‘without development’ and ‘with development’ scenarios.
11.6.16 In 2023, for PM 10 , ten of the twenty existing sensitive receptor locations considered
are predicted to experience an imperceptible increase in PM 10 concentrations as a result of the proposed development (i.e. an increase of less than 0.4µg/m 3, in accordance with Table 11.13). The remaining ten existing sensitive receptor locations
considered are predicted to experience no change in PM 10 concentrations as a result of the proposed development (i.e. 0.00µg/m 3, in accordance with Table 11.13).
11.6.17 All predicted PM 10 concentrations are well below the objective/ limit values and no 3 exceedances of the PM 10 annual mean air quality objective of 40µg/m are predicted to occur in 2023 for both the ‘without development’ and ‘with development’ scenarios.
11.6.18 Nineteen of the twenty existing receptor locations are considered moderately sensitive in accordance with the criteria detailed in Table 11.15. ESR 15 is considered to be highly sensitive as it is a hospital. All of the existing sensitive receptors are predicted to experience a ‘negligible/not significant’ impact, or no impact, as a result of the proposed development when the magnitude of impact is considered along with the sensitivity of the receptor, in accordance with Table 11.16.
11.6.19 All negligible changes in concentrations, between ‘without development’ and ‘with development’ scenarios, are explained by slight changes in traffic flows on those roads closest to the receptor locations, with the proposed development in place.
Proposed Sensitive Receptor Locations
11.6.20 Air pollutant concentrations have been modelled for four proposed receptor locations for the 2023 ‘with development’ scenario, as detailed in Table 11.21. The uncorrected
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NO 2 and PM 10 concentrations are included in Appendices 11.4.
Table 11.21 Predicted Pollutant Concentrations at Proposed Receptor Locations for the 2023 ‘With Development’ Scenario Calculated Annual Mean Concentrations (µg/m 3) Proposed Receptor Location NO 2 (Uncorrected) PM 10 (Uncorrected)
PR 1 22.65 19.36
PR 2 22.40 19.34
PR 3 20.08 18.89
PR 4 22.28 19.31
PR 5 22.19 19.30
PR 6 23.83 19.41
PR 7 18.98 18.67
PR 8 19.42 18.73
PR 9 19.38 18.73
PR 10 19.07 18.68
Scenario 3: 2023 Opening/ Future Year ‘With Development’
11.6.21 The 2023 ‘with development’ annual mean NO 2 concentrations (uncorrected) are predicted to range from 18.98 to 23.83µg/m 3 for the ten proposed sensitive receptor
locations considered. Exceedance of the annual mean objective concentration for NO 2 (40µg/m 3) is not predicted to occur.
11.6.22 The 2023 ‘with development’ annual mean PM 10 concentrations (uncorrected) are predicted to range from 18.67 to 19.36µg/m 3 for the ten proposed sensitive receptor locations considered. Exceedance of the annual mean objective concentration for 3 PM 10 (40µg/m ) is not predicted to occur.
11.7 Mitigation and Residual Impacts
Construction Phase Assessment – Dust Emissions
Step 3
11.7.1 During the construction phase the implementation of effective mitigation measures will substantially reduce the potential for nuisance dust and particulate matter to be
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generated.
11.7.2 Step 2C of the construction phase assessment identified that:
• The risk of dust soiling effects is classed as high for earthworks, construction and for trackout; and
• The risk of human health effects is classed as low for earthworks, construction and trackout.
11.7.3 This assessment assumes that no mitigation measures are applied, except those required by legislation.
11.7.4 Site specific mitigation measures do not need to be recommended if the risk category is negligible. However, as the risk categories for these activities are not negligible, site specific mitigation measures will need to be implemented to ensure that dust effects will not be significant.
11.7.5 A best practice dust mitigation plan will be written and implemented for the site. This will set out the practical measures that could be incorporated as part of a best working practice scheme. This will take into account the recommendations included within the Institute of Air Quality Management (IAQM).
11.7.6 All dust and air quality complaints will be recorded and appropriate measures will be taken to identify causes and reduce emissions in a timely manner. Exceptional incidents which cause dust and/or emissions and the action taken to resolve the situation will be recorded in a log book to be made available to the local authority on request.
11.7.7 During the earthworks and construction phases of work, additional measures will be implemented to limit the generation of dust, which may include:
• Minimisation of the duration of the material handling activity and the amount of handling. Material handling methods will also aim to minimise the generation of airborne dust;
• Protection of surfaces and exposed material from winds until disturbed areas are sealed and stable;
• Ensuring that all vehicles will be sheeted when loaded;
• Dampening down of exposed stored materials, which will be stored as far from sensitive receptors as possible; and
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• Avoidance of activities that generate large amounts of dust during windy conditions.
11.7.8 Mitigation measures will also be implemented to reduce the possibility of dust being generated through the trackout of mud and dirt onto the public highway. These may include:
• The control of dust from general traffic at the site during demolition, earthworks and construction works by the provision of a wheel wash at the site exit and a road sweeper for use on site and public highways;
• The provision of easily cleaned hard standing areas for vehicles arriving at and leaving the site and for parking;
• Confining vehicles to areas of the site where appropriate dust control measures can be in operation; and
• Minimisation of vehicle movements and limitation of vehicle speeds – the slower the vehicle speeds, the lower the dust generation.
11.7.9 It is recognised that the final design solutions will be developed with the input of the Contractor to maximise construction efficiencies, to use modern construction techniques and sustainable materials, and to incorporate the particular skills and experience offered by the successful contractor.
Step 4
11.7.10 Step 4 of the construction phase dust assessment has been undertaken to determine the significance of the dust effects arising from earthworks, construction and trackout associated with the proposed development.
11.7.11 The implementation of effective mitigation measures during the construction phase, such as those detailed in Step 3, will substantially reduce the potential for nuisance dust and particulate matter to be generated and any residual impact should not be significant.
Operational Phase Assessment – Road Traffic Emissions
Existing Sensitive Receptor Locations
11.7.12 A detailed air quality assessment has been undertaken to consider the potential impact of the proposed development on air quality at twenty representative existing
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sensitive receptor locations.
11.7.13 The air quality assessment has predicted that there will be a negligible impact, or no
impact, on concentrations of NO 2 and PM 10 , at all of the existing receptors considered,
in 2023 with the development in place. All predicted NO 2 and PM 10 concentrations are below the annual mean objective of 40µg/m 3.
11.7.14 Taking into account the predicted impact of the proposed development, it is not therefore considered necessary to recommend measures to mitigate road traffic emissions.
11.7.15 The air quality assessment indicates that all existing sensitive receptor locations are predicted to experience a negligible impact, or no impact, as a result of the proposed development. It has not been necessary to recommend any measures to mitigate pollutant concentrations generated as a result of the proposed development as all
predicted NO 2 and PM 10 concentrations are below the annual mean objective of 40µg/m 3. Therefore the residual impacts will remain negligible and unchanged.
Proposed Sensitive Receptor Locations
11.7.16 The air quality assessment has also predicted pollutant concentration at seven proposed receptor locations within the proposed development site.
11.7.17 Predicted NO 2 and PM 10 concentrations are below the annual mean air quality objectives of 40µg/m 3, for 2023, at all ten of the proposed sensitive receptor locations considered. It is not therefore considered necessary to recommend measures to mitigate road traffic emissions.
Summary of Residual Impacts
11.7.18 Please see Table 11.22 below for a summary of the residual impacts.
Table 11.22 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of mitigation) residual effect Construction stage Dust soiling as a result of dust High risk - Adverse Best practice dust mitigation plan Negligible / Not emissions significant Human health effects as a result Low risk - Adverse Best practice dust mitigation plan Negligible / Not of fine particulate emissions significant Post-completion stage Impact of development- Negligible / Not None Negligible / Not generated vehicles on significant significant concentrations of NO 2
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Impact of development- Negligible / Not None Negligible / Not generated vehicles on significant significant concentrations of PM 10
11.8 Cumulative Impacts
Operational Phase Assessment – Road Traffic Emissions
11.8.1 The traffic flow information, provided by the appointed transport consultant for use in the air quality assessment, includes the consideration of the committed developments within the vicinity of the proposed development.
11.8.2 The results of the air quality assessment show that there will be a ‘negligible / not
significant’ impact on NO 2 and PM 10 concentrations at all twenty existing receptor locations considered.
11.9 Conclusions
Construction Phase Assessment – Dust Emissions
11.9.1 The construction phase assessment has been undertaken to determine the risk and significance of dust effects from earthworks, construction and trackout from the proposed development. The assessment has been undertaken in accordance with the guidance on assessing the impacts of construction phase dust published by the Institute of Air Quality Management (IAQM).
11.9.2 The risk of dust soiling effects is considered to be high for earthworks, construction, and for trackout. The risk of human health effects is classed as low for earthworks, construction and trackout. Site specific mitigation measures will therefore be implemented at the site.
11.9.3 With site specific mitigation measures in place, as detailed in Section 7 of this report, the significance of dust effects for earthworks, construction and trackout are considered to be not significant.
Operational Phase Assessment – Road Traffic Emissions
Existing Sensitive Receptor Locations
11.9.4 Air quality at twenty representative existing sensitive receptor locations has been considered in the air quality assessment. Nineteen of the existing receptor locations are considered to be moderately sensitive. ESR 15 is considered to be highly sensitive.
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11.9.5 In 2023, for NO 2 and PM 10 , all existing receptors considered show a negligible impact, or no impact, as a result of the proposed development, in accordance with the significance criteria detailed in Section 11.4 of this report.
3 11.9.6 No exceedances of the NO 2 and PM 10 annual mean air quality objective of 40µg/m are predicted to occur in 2023 for both the ‘without development’ and ‘with development’ scenarios.
11.9.7 All existing receptor locations are considered to be moderately or highly sensitive and are therefore predicted to experience a ‘negligible/not significant’ impact, or no impact, as a result of the proposed development when the magnitude of impact is considered along with the sensitivity of the receptor.
11.9.8 To summarise, the air quality assessment indicates that the proposed development generated traffic will have a negligible impact, or no impact, on existing sensitive receptor locations in 2023. It is therefore not considered necessary to incorporate measures to mitigate road traffic emissions.
Proposed Sensitive Receptor Locations
11.9.9 The air quality assessment and sensitivity analysis also predict pollutant concentrations at ten proposed sensitive receptor locations within the proposed development.
11.9.10 NO 2 and PM 10 concentrations are predicted to be below the respective annual mean air quality objectives, for 2023, at the proposed sensitive receptor locations considered. It is therefore not considered necessary to incorporate measures to mitigate road traffic emissions.
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12 ECOLOGY
12.1 Introduction
12.1.1 The following chapter of the Environmental Statement (ES) provides an assessment of the potential ecological impacts and effects on an area of land at Kingsnorth Green, Ashford.
12.1.2 The aims of this chapter are to:
• Describe the ecological baseline conditions within the proposed site; • Identify and evaluate the nature conservation and/or biodiversity present; • Identify any potential impacts (during the construction and operational phases of the development); • Establish the magnitude and significance of those identified impacts; • Identify the mitigation measures to address impacts; and • Assess any residual impacts.
Background
12.1.3 Wardell Armstrong LLP was commissioned by Pentland Homes and Jarvis Homes to undertake an ecological assessment of land proposed for residential development (following on from the Ecological Appraisal completed by The Landscape Partnership (TLP), in May 2013); incorporating a range of protected species surveys to inform the Ecology Environmental Statement Chapter.
12.1.4 For information regarding the location and description of the site, as well as details on the development proposals refer to Chapters 3 and 4 of this ES.
Definition of Terms
12.1.5 For the purposes of this section, the term ’site’ is used to refer to the redline boundary shown on Drawing ST13901-008.
12.2 Planning Policy and Legislation
12.2.1 This section sets out policy and legislation of relevance to the scheme and nature conservation.
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Policy
12.2.2 This ES chapter takes into account the requirements of the following national and local policies that currently affect the proposed development site:
• National Planning Policy Framework (NPPF), which states that when determining planning applications, local planning authorities should aim to conserve and enhance biodiversity; • Kent Environmental Strategy 2011 (VE Priority 9); and • Local Development Framework – Core Strategy (2008).
12.2.3 For further details refer to Appendix 12.12.
Legislation
12.2.4 The main statutory protection afforded to both species and habitats are listed below. The degree of protection varies between species but in general, it is an offence to intentionally injure or kill individual animals, or disturb their roosts or hibernacula.
• Wildlife and Countryside Act 1981, as amended (WCA); • The Protection of Badgers Act 1992; • The Countryside and Rights of Way Act 2000 (CRoW); • EC Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Flora and Fauna (‘the Habitats Directive’), interpreted into UK law by the Conservation of Habitats and Species Regulations 2012; • UK Post-2010 Biodiversity Framework (Formally UK BAP); and • Kent Local Action Plan (LBAP).
12.2.5 For a summary of relevant legislation concerning protected species and habitats likely to be present within the site and local area refer to Appendices 12.1 to 12.10.
12.3 Methodology
Desk Study
12.3.1 A desk study of available data sources was undertaken to identify the presence of any statutory and non-statutory designated sites of importance for nature conservation within 2 kilometres of the site, together with records of any notable or protected species and habitats.
12.3.2 The following websites and organisations were consulted:
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• MAGIC (the Multi Agency Geographic Information for the Countryside);
• Review of Ordnance Survey (OS) and satellite mapping;
• UK Biodiversity Action Plan (UKBAP); and
• Kent Local Biodiversity Action Plan (LBAP).
12.3.3 A review of the TLP Ecological Appraisal (2013) was undertaken to highlight the habitats present within the site and to inform future survey requirements (phase 2 surveys). Data obtained from the Kent and Medway Biological Records Centre (KMBRC) during the Appraisal in 2013 by TLP was also reviewed and used to inform this chapter.
Field Survey Methodology
12.3.4 Baseline surveys follow nationally recognised guidelines. For further detail of individual methodologies refer to Appendices 12.2 to 12.11.
Assessment of Impacts Methodology
12.3.5 The Environmental Impact Assessment follows the guidelines as set out within the Chartered Institute of Ecology and Environmental Managements (CIEEM, 2006) ‘Guidelines for Ecological Impact Assessment in the United Kingdom’, hereafter referred to as the CIEEM guidelines.
12.3.6 CIEEM Guidelines (2006) paragraph 4.2 indicates that the assessment of impacts should take into account both the value and sensitivity of ecological receptors:-
“The starting point for any assessment is to determine which ecological features or resources within the zone of influence are both of sufficient value to be included in the assessment and vulnerability to significant impacts arising from the project.”
12.3.7 In addition it is important to assess the magnitude of impacts upon each receptor:-
“The next step is to describe the changes to the baseline conditions likely to arise from the project and the resulting ecological impacts.”
12.3.8 For the purpose of this chapter, it has been assumed that each ecological receptor likely to be encountered within the site and the wider landscape will have a high sensitivity to the development. The assessment of impacts within this chapter will therefore focus upon a receptor’s value and the magnitude of impact upon it.
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12.3.9 By analysing the value (or sensitivity) of an ecological receptor and the magnitude of the impact, the significance of an impact can be ascertained. The CIEEM guidelines define a significant impact as:
“an impact (adverse or positive) on the integrity of a defined site or ecosystem(s) and/or the conservation status of habitats or species within a given geographical area, including cumulative impacts .”
12.3.10 In order to determine the significance of an impact, the value (or sensitivity) of ecological features and the magnitude of impacts require assessment.
Determining Value of Ecological Features
12.3.11 The conservation status of a site is defined in the Habitats Directive as it relates to internationally designated sites. The CIEEM guidance modifies the definition in order for it to be applicable to sites, habitats or species within any defined geographical area.
12.3.12 The assessment of the nature conservation value of the habitats within the site has been based on the ecological features identified through consultation, survey and the widely applied criteria described in ‘A Nature Conservation Review’ (Ratcliffe, 1977). A summary of the criteria is set out in Appendix 12.13. The levels of conservation importance are detailed in Table 12.1 below.
Table 12.1 Categories of Values. Value Category Relevance to Examples Site International EU An internationally important site e.g. Special Protection Area (SPA), Special Area of Conservation (SAC), Ramsar (or a site proposed for, or considered worthy of such designation); A regularly occurring substantial population of an internationally important species (listed on Annex IV of the Habitats Directive). National England A nationally designated site e.g. Site of Special Scientific Interest (SSSI), or a site proposed for, or considered worthy of such designation; A viable area of a habitat type listed in Annex 1 of the Habitats Directive or of smaller areas of such habitat which are essential to maintain the viability of a larger whole; A regularly occurring substantial population of a nationally important species, e.g. listed on Schedules 5 & 8 of the Wildlife and Countryside Act 1981 (as amended); A feature identified as a priority species/habitat in the UK BAP. Regional South East Areas of internationally or nationally important habitats which are degraded but are considered readily restored;
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A regularly occurring, locally significant population of a species listed as being nationally scarce. County Kent Viable areas of priority habitat identified in the LBAP or smaller areas of such habitat which are essential to maintain the viability of a larger habitat as a whole; A site designated as a non-statutory designated site e.g. Site of Importance for Natural Science, Kent Wildlife Trust Reserve/Wildlife Site, or a site listed on the Ancient Woodland Inventory (AWI). A regularly occurring, substantial population of a nationally scarce species, including species listed on the UK and Local BAPs e.g. common toad (a UK BAP species). Local Kingsnorth Areas of internationally or nationally important habitats which are degraded and have little or no potential for restoration; A good example of a common or widespread habitat in the local area, e.g. those listed as broad habitats on the LBAP; Species of national or local importance, but which are only present very infrequently or in very low numbers within the subject area. Within the Zone Within 30 Areas of heavily modified or managed vegetation of low species diversity of Influence metres of the or low value as habitat to species of nature conservation interest; site boundary Common and widespread species.
12.3.13 Individual species may be protected under European or National legislation. Such protection is relevant to the assignment of value to such species, but additional factors, such as population size and the nature of the distribution of the species are also considered. These factors affect the value of species.
12.3.14 The assignment of undesignated features such as Biodiversity Action Plan habitats and species or areas of ancient woodland may not fall clearly into the designations as described above. Therefore a number of other criteria are used to assess the nature conservation value of a defined area of land.
12.3.15 Some features that are currently of no particular ecological interest in themselves may nevertheless perform an ecological function. For example they may act as a buffer against negative impacts. This affects their value.
Magnitude of Impact
12.3.16 The magnitude of impacts is dependent upon whether they are permanent or temporary; adverse or beneficial; direct or indirect, as well as cumulative. In addition it is important to assess the magnitude of the effect upon the ‘Integrity’ of a site or ecosystem and upon the ‘Conservation Status’ of a species or habitat.
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12.3.17 Integrity is defined by CIEEM (2006) as:
‘the coherence of a sites ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified.’
12.3.18 CIEEM (2006) further defines Conservation Status as a habitat or species ability to maintain its long term distribution, function and size within a given geographical area.
12.3.19 Assessment of impacts upon the receptor will consider whether an impact is positive or negative, the magnitude, its extent, duration, reversibility, and timing and frequency. An impact will then be assigned to one of the four levels of magnitude as defined in Table 12.2 below. Professional judgement is used for this assessment.
Table 12.2 Magnitude Levels Level Of Magnitude Definition High Size and scale of the effects is such that it could lead to permanent or long-term effect on the integrity of a site or conservation status of a habitat, species assemblage or population. If adverse, this is likely to threaten its sustainability. If beneficial, this is likely to enhance its conservation status. Medium Size and scale of the effects is such that it could lead to permanent or long-term effect on the integrity of a site or conservation status of a habitat, species assemblage or population. If adverse, this is unlikely to threaten its sustainability. If beneficial, this is likely to be sustainable but it unlikely to enhance its conservation status. Low Size and scale of the effects is such that it could lead to short-term but reversible effect on the integrity of a site or conservation status of a habitat, species assemblage or population that is within range of variation normally experienced between years. Negligible Size and scale of the effects is such that it could lead to short-term but reversible effect on the integrity of a site or conservation status of a habitat, species assemblage or population that is within the normal range of annual variation.
Evaluation of Significance
12.3.20 The significance of an impact is the product of the magnitude of the impacts and the value of the nature conservation resource affected. There is no agreed method for assessing the significance of impacts on nature conservation receptors. Nevertheless, Table 12.3 summarises the general approach adopted in formulating the significance of effects. Professional judgement is then applied when determining significance for this assessment.
12.3.21 For the purpose of this EIA, impacts of moderate or major significance are regarded as significant effects.
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Table 12.3 Significance Matrix Value of Ecological Feature Magnitude of Impact
High Medium Low Negligible International Major Major Moderate Negligible National Major Moderate Minor Negligible Regional Major Moderate Minor Negligible County Moderate Minor Minor Negligible Local Moderate Minor Negligible Negligible Zone of Influence (including Minor Minor Negligible Negligible site)
12.4 Baseline conditions and evaluation of features
Information
12.4.1 A summary of the baseline conditions identified within the Extended Phase 1 Habitat survey completed by TLP and resultant Phase 2 surveys are provided below.
12.4.2 Phase 2 surveys considered relevant following review of TLP’s Extended Phase 1 Habitats survey report included:
• badger Meles meles ;
• bats;
• trees and hedgerows;
• dormouse Muscardinus avellanarius;
• great crested newt Triturus cristatus ;
• reptiles;
• birds; and
• water vole Arvicola amphibius .
Desk Study
Statutory and Non-Statutory Designated Sites
12.4.3 No statutory designated sites were located within 2km of the site.
12.4.4 Three non-statutory designated sites were located within 2km of the site:
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• AS21 – Shadoxhurst Woods and Pasture Local Wildlife Site located over 1km south of the site;
• AS61 – Woods, Pasture and Ponds Local Wildlife Site located over 1km south of the site; and
• AS19 – South Willesborough Dykes Local Wildlife Site located approximately 1.5km north of the site.
UK and LBAPs
12.4.5 A review of the National Biodiversity Action Plan (UKBAP) and the Kent Local Biodiversity Action Plan (LBAP) highlighted the habitats and species that are within the site (Table 12.4 below). Individual UK and LBAP species and habitats found to be present within the site have been evaluated against field survey results. Table 12.4 UKBAP and LBAP Habitats Status
Local habitats UKBAP/LBAP Waterbodies and Watercourses UKBAP/LBAP Hedgerows UKBAP/ LBAP Woodland, including ancient UKBAP/ LBAP Lowland calcareous grassland UKBAP/LBAP Reed beds UKBAP/LBAP Species Bird species, tree pipit Anthus trivialis , Stone-curlew UKBAP/LBAP Burhinus oedicnemus , nightjar Caprimulgus europaeus, linnet Carduelis cannabina , lesser redpoll Carduelis cabaret , skylark Alauda arvensis , cuckoo Cuculus canorus , lesser spotted woodpecker Dendrocopos minor, reed bunting Emberiza schoeniclus , hawfinch Coccothraustes coccothraustes, yellowhammer Emberiza citrinella, corn bunting Emberiza calandra , grasshopper warbler Locustella naevia , yellow wagtail Motacilla flava, spotted flycatcher Muscicapa striata , willow tit Poecile montanus , dunnock Prunella modularis , bullfinch Pyrrhula pyrrhula , turtle dove Streptopelia turtur , starling Sturnus vulgaris , song thrush Turdus philomelos, lapwing Vanellus vanellus , tree sparrow Passer montanus. Bats UKBAP/LBAP Great crested newt UKBAP/LBAP Water vole UKBAP/LBAP Dormouse UKBAP/LBAP Common toad Bufo bufo UKBAP/LBAP Slow worm Anguis fragilis UKBAP/LBAP Grass snake Natrix natrix UKBAP/LBAP Common lizard Zootoca vivipara UKBAP
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Protected and Notable Species
12.4.6 Consultation with KMBRC highlighted several protected and notable species within 2km of the site that are considered relevant to the site. These include 48 species of bird, eight species of herptile, 12 species of terrestrial mammal. See Appendix 12.1 for a full list of these species.
Field Survey Results
12.4.7 The results of the Extended Phase 1 Habitat survey and subsequent specialist phase 2 ecological assessments are presented below. Ecological features considered as potential constraints to development are evaluated in terms of their value and in respect to the development proposals. See Table 12.5 below for full details.
Habitats
12.4.8 The habitats recorded within the site are summarised below (full details and the location of compartment numbers can be found in the Extended Phase 1 Habitat Report, Appendix 12.1). In addition, please refer to the Arboricultural Report (Appendix 12.2) and Hedgerow Report (Appendix 12.9).
Semi-Natural Broadleaved Woodland
12.4.9 Semi-natural broadleaved woodland is present mostly within compartment B6 (Area 4 of the proposed scheme). A narrow strip of this habitat also exists along the southern boundary of B6 (Area 4 of the proposed scheme). Both ground and canopy species suggest these woodlands are of ancient origin, including Isaac Wood, a designated Ancient Woodland. Species include wild cherry Prunus avium , Oak Quercus robur , field maple Acer campestre , dog’s mercury Mercurialis perennis , cuckoo-pint Arum maculatum and yellow archangel Lamiastrum galeobdolon .
Scattered Scrub
12.4.10 This is located across the site; predominately around pond edges, along former hedgerow field boundaries and with grassland habitats. Species present include willow Salix sp., hawthorn Crataegus monogyna and blackthorn Prunus spinosa .
Semi-Improved Neutral Grassland
12.4.11 Semi-improved neutral grassland has been divided into three categories, including areas associated with arable field margins, grazed pasture and road verges:
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• Arable field margins – typically 2-4m wide, dominated by coarse grassland including false oat-grass Arrhenatherum elatius , cocks-foot Dactylis glomerata and red fescue Festuca rubra .
• Grazed pasture – recorded primarily in compartment B3 (Area 2 of the proposed scheme), this sward is considered species poor and includes species such as Yorkshire fog Holcus lanatus, Perennial rye-grass Lolium perenne and creeping bent Agrostis stolonifera.
• Road verges – the main road verges occur to the north of compartment B1 (Area 1 of the proposed scheme) and to the south of compartment B6. Species recorded include meadowsweet Filipendula ulmaria, meadow vetchling Lathyrus pratensis, and creeping cinquefoil Potentilla reptans.
Improved Grassland
12.4.12 This is recorded in compartments B2, B4, B5 and B6 (Areas 3 and 4 of the proposed scheme). The sward was grazed at the time of the survey and appears to be harvested for hay or silage in some years. The sward is typically species poor in composition, and includes amongst other species Yorkshire fog, cocks-foot and creeping thistle Cirsium arvense .
Arable
12.4.13 This is the dominant habitat within the site boundary. The predominant crops were cereal and oil seed rape.
Native Species-Rich Hedgerow
12.4.14 This habitat is present in a number of compartments, but principally in B1 and B6 (Areas 1 and 4 of the proposed scheme). Varying in height from 1.5m to 6m, ‘woody’ species include hawthorn, hazel Corylus avellana , Rose Rosa sp., Elm Ulmus sp., oak and ash Fraxinus excelsior . The understory was dominated by rank grasses (see semi- natural neutral grassland for species assemblage) and ruderal species including cow parsley Anthriscus sylvestris , nettle Urtica dioica , primrose Primula vulgaris and bluebell Hyacinthoides non-scripta .
Native Species-Poor Hedgerow
12.4.15 This habitat is generally dominated by hawthorn or blackthorn, with occasional species including oak, bramble Rubus fruticosus and holly Ilex aquifolium .
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Defunct Hedge
12.4.16 Of similar species assemblage to species poor hedge this comprised hedgerows with large gaps.
Scattered/Standard Trees
12.4.17 Several semi-mature and mature trees are present within the hedge lines and as field standards. Species include oak, white poplar Populus alba , ash, weeping willow Salix x babylonica , apple Malus domestica , hybrid black poplar Populus nigra and Lombardy poplar Populus nigra “Italica”.
Waterbodies
12.4.18 Waterbodies occur at relatively high density in the local area, with a number of larger and smaller waterbodies present within and surrounding the site. Approximately half of the ponds were overgrown with woody vegetation, and held only small amounts of water after a wet spring. Others appear to be more regularly maintained, lacking marginal vegetation.
Wet Ditch and Dry Ditch
12.4.19 Several ditches are present within the site, with the majority located within compartments B3, B5 and B6 (Areas 2, 3 and 4 of the proposed scheme). Many of the ditches were dry at the time of survey having recently been cleaned / dredged. It is considered that most of the ditches will be dry during the summer months. Botanical interest was associated with ditches in B1, B3 and B6 (Areas 1,2 and 4 of the proposed scheme), which support species including lesser water parsnip Berula erecta , sweet cicely Myrrhis odorata , common sorrel Rumex acetosa , square-stemmed willowherb Epilobium tetragonum , meadowsweet Filipendula ulmaria , bittersweet Solanum dulcamara and water mint Mentha aquatica .
Ruderal Vegetation
12.4.20 Scattered throughout the site, species include nettle, broadleaved dock, cow parsley, false oat grass and cocks-foot.
Species
Badger
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12.4.22 The majority of the site is arable, considered to be of sub-optimal foraging for badger. Hedgerow, woodland and grassland habitats are present in lower densities and provide optimal foraging habitat, as well as potential areas for setts.
12.4.23 The survey identified four setts within the survey area, including two outlier setts (sett 1 and sett 3) and two main setts (sett 2 and sett 4), of which one is considered disused and the other active.
Amphibians
12.4.24 For full details refer to the great crested newt report in Appendix 12.8. A summary is provided below.
12.4.25 The site and surrounding landscape has a number of waterbodies with the potential to support breeding great crested newt. A network of hedgerow field boundaries, woodland and grassland provide suitable terrestrial foraging/dispersal habitats, as well as opportunities for hibernation.
12.4.26 Great crested newt were identified in fourteen of the waterbodies surveyed. Population assessment identified three distinct groups of waterbodies which were all calculated as supporting medium populations of great crested newt: Group A – maximum individual adult count of 33; Group B – maximum individual adult count of 28; and Group C – maximum individual adult count of 18.
Water vole
12.4.27 Full details can be found within the water vole survey report included as Appendix 12.11 to this chapter. A summary is provided below.
12.4.28 A network of drainage ditches and waterbodies occur across the site and surrounding land within a predominately agricultural landscape, offering suitable breeding and foraging habitat.
12.4.29 During the survey, water vole were recorded within waterbodies 7, 7a, 8, 9 and ditches 5 and 6; all located within compartment B3 of the site (Area 2 of the proposed scheme). No other compartments were found to support water vole.
Bats
12.4.30 Detailed results of the bat surveys are presented within the bat report, included as Appendix 12.4, and the bat roost potential report, included as Appendix 12.14.
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12.4.31 The majority of the site provides limited suitable habitat for bats as large areas of arable and improved grassland offer little foraging habitat due to their low insect abundance and diversity.
12.4.32 Areas of semi-improved neutral grassland, woodland, scrub/ruderal, mature hedgerows and waterbodies/ditches offer more optimal foraging habitats within the site. Many of these habitat form linear features associated with agricultural field boundaries and provide means of dispersal and commuting throughout the site and wider landscape.
12.4.33 The remaining hedgerows are of limited species diversity and appear to be regularly cut/managed, offering limited foraging potential or protection for commuting bats.
12.4.34 A single building exists within the site (B1); a single story pill box located to the west of the Ashford Road and Magpie Hall Road junction. Of entirely concrete construction B1 has a flat roof, open windows and door and is regularly frequented by sheltering cattle. B1 was inspected and no signs of bat activity were recorded. B1 is therefore considered to be of negligible bat roost potential.
12.4.35 Inspections of all trees considered suitable to support roosting bat was undertaken as part of the site bat assessment. Of the one hundred and eighty three trees inspected, fifteen trees were classified as category 1*; having multiple, highly suitable roost features capable of supporting larger roosts (equivalent to high roost potential). A further one hundred trees were identified as category 1; having definite bat potential, supporting fewer suitable features than category 1* trees or with potential for use by single bats (equivalent to moderate roost potential).
12.4.36 Further detailed assessment of these trees, including climbing and search of crevices using an endoscope is required to confirm the presence of bat roost. However, as none of these trees will be affected by the proposed scheme, such surveys were not considered to be necessary.
12.4.37 Activity surveys identified three species of bat within the site, including common pipistrelle, soprano pipistrelle and noctule. Automotive detector surveys identified the same three species, but with the addition of Myotis sp. and Nyctalus sp.
12.4.38 Pipistrelle species accounted for 98 percent of the bats recorded within the site. Common pipistrelle were recorded both foraging and commuting within the site and based on the earliest recording, are considered to be roosting within the vicinity of the site. Soprano pipistrelle were recorded in much lower numbers than common
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pipistrelle and were not observed close to dusk or dawn suggesting roost locations are not within close proximity to the site.
12.4.39 Noctule were recorded commuting within the site only. No foraging activity was observed.
12.4.40 Due to the infrequent nature of the calls, it is assumed that Myotis sp. bats are commuting through the site infrequently, and that it is not a main foraging or commuting route for any Myotis species. Increased activity of Myotis sp . recorded at one of the automated survey locations may indicate that this species is returning to a winter roost in the vicinity of the site.
12.4.41 A low number of Nyctalus sp. passes were recorded during the survey. Due to the infrequent nature of the calls and only single passes recorded, it is assumed that Nyctalus sp. are commuting through the site and that it is not a main foraging or commuting route for any Nyctalus species.
Breeding Birds
12.4.42 For full details refer to the breeding bird survey report in Appendix 12.5. A summary is provided below.
12.4.43 Initial scoping/walkover survey of the site confirmed the presence of habitat with the potential to support a wide range of breeding bird species, including declining farmland and woodland birds. Habitats predominantly included arable farmland with associated hedgerows and areas of grassland and broad-leaved woodland.
12.4.44 Three breeding bird survey visits resulted in a total of 47 bird species recorded within the site. Of these species, two are Schedule 1 listed (Barn owl Tyto alba and Hobby Falco subbuteo ), eight are UK Biodiversity Action Plan (BAP) priority species and seventeen Birds of Conservation Concern (BoCC).
12.4.45 Six UK BAP priority species, thirteen BoCC species and hobby were observed displaying breeding behaviour within the site.
12.4.46 The site is considered to be of local significance, supporting a good range of breeding bird species associated with farmland habitats incorporating species typical of arable crops, hedgerows, small woods and shelterbelts.
12.4.47 In terms of important habitats within the surveyed area the most significant are the field boundary features which support a diverse range of notable breeding species.
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Wintering Birds
12.4.48 For full details refer to the wintering bird survey report in Appendix 12.6. A summary is provided below.
12.4.49 During the initial scoping survey the site was identified as having the potential to support a wide range of wintering bird species; particularly farmland/hedgerow species and flocks of wading species such as golden plover and lapwing. The site consists predominantly of agriculture and hedgerow with small blocks of woodland.
12.4.50 Four wintering bird survey visits resulted in a total of 38 bird species recorded within the site. Of these species, two are Schedule 1 listed, seven are UK Biodiversity Action Plan (BAP) priority species and fourteen Birds of Conservation Concern (BoCC).
12.4.51 The site is considered to be of local significance, supporting a good range of wintering bird species associated with farmland and woodland habitats and incorporating species typical of arable crops, hedgerows, small woods and shelterbelts.
12.4.52 In terms of important habitats within the surveyed area the most significant are the field boundary features which support a diverse range of wintering bird species.
Reptiles
12.4.53 A summary of the reptile survey is given below. For further details refer to the full reptile report included as Appendix 12.10 to this chapter.
12.4.54 The majority of the site comprises intensively cultivated arable and pasture land, with comparatively few areas of suitable grassland, woodland and scrub that may provide suitable refuge, basking sites and foraging habitats for reptiles.
12.4.55 Field margins, with associated rough grassland, scrub and hedgerows, as well as several waterbodies were included within the reptile survey.
12.4.56 Three species of reptile were recorded within these areas, including:
• A low population (in compartments B2-B6; Areas2-4 of the proposed scheme) and good population (in compartments B1; Area 1 of the proposed scheme) of common lizard;
• An exceptional population of slow worm within compartments B1 and B5 (Areas 1 and 3 of the proposed scheme); and
• A low population of grass snake within compartments B1, B2, B3 and B6 (all areas of the proposed scheme).
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Dormouse
12.4.57 For full details refer to the dormice survey report included as Appendix 12.7 to this chapter. A summary is provided below.
12.4.58 Hedgerow field boundaries and woodland blocks within the site and immediate adjacent areas were assessed as having the potential to support breeding and nesting dormice, as well as offering routes for dispersal.
12.4.59 The survey identified that dormouse are present within parcels B2, B3, B5 and B6 (Areas 2-4 of the proposed scheme). Two adult dormouse were seen exiting from tubes T55 and T53 on two occasions. A total of nine dormouse nests were found.
Summary Evaluation of Ecological Features
12.4.60 Table 12.5 evaluates the ecological feature present within the site based on the desktop review and field survey. Each ecological receptor is given a value used to assess the significance of the impact of the proposed development.
Table 12.5 Evaluation of Baseline Conditions Ecological Receptor Evaluation Rationale Value Designated Sites AS21 – Shadoxhurst Woods Local Wildlife Site located over 1km from the site County and Pasture boundary. AS61 – Woods, Pasture and Local Wildlife Site located over 1km from the site County Ponds boundary. AS19 – South Willesborough Local Wildlife Site located over 1.5km from the site County Dykes boundary. Habitats Broad-leaved semi natural This is a UK and LBAP habitat and Isaac Wood, located County woodland. adjacent to compartment B6 is designated as an ancient woodland and is covered by a blanket Tree Preservation Order. This habitat is sparse within the site and immediate surrounding habitat, although prevalent in the wider landscape, particularly to the south of the site. As a result, this habitat is likely to be of county nature conservation value. Scattered scrub This habitat is common and widespread within the UK. Zone of influence It occurs sporadically along several field boundaries and (including site)
within the marginal vegetation of a number of waterbodies. This habitat is considered to be present within the wider landscape surrounding the site, particularly where agriculture is less intense. Although not a BAP habitat, scrub can provide a valuable resource for birds, reptiles, amphibians, bats and badger (all known to occur within the site). As a result
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of the above, this habitat is likely to be of zone of influence (including the site) nature conservation value. Semi-improved neutral Comprised of 3 categories, including grassland around Zone of influence grassland arable field margins, grazed pasture and road verges. A (including site)
common and widespread habitat within the UK this habitat provides suitable foraging and nesting opportunities for a number of bird and invertebrate species, as well as foraging badger and bats. As a result, this habitat is likely to be of zone of influence (including the site) nature conservation value. Improved grassland Recorded in many of the compartments, only B4 Zone of influence exhibited an unmanaged sward. Of low species (including site)
diversity this habitat is considered to be of low ecological value. Common and widespread within the surrounding landscape and UK, this habitat is offers limited foraging and nesting potential. As a result, improved grassland is likely to be of zone of influence (including the site) nature conservation value. Arable This habitat is common and widespread within the UK Zone of influence and is not a protected habitat type. No protected (including site)
species that are likely to occur on site are dependent on this habitat type; however, several wintering and breeding bird species, as well as badger will utilise this habitat for foraging. As a result, arable is likely to be of zone of influence (including the site) nature conservation value. Native species rich Located throughout but predominantly in County hedgerow compartments B1 and B6, this habitat comprises a wide variety of woody species. Both a UK and LBAP priority habitat, native species rich habitats are infrequent across the site. It is estimated that ancient and species rich hedges make up 25-35% of the hedges in Kent. This habitat offers suitable habitat for nesting and foraging dormouse, foraging bats, commuting and foraging amphibians and invertebrates, as well as foraging badger. As a result of its high diversity and ecology value and declining status, native species rich hedge is likely to be of county nature conservation value. Native species poor The predominant form of hedgerow within the site and Zone of influence hedgerow located within each compartment, the dominant (including site)
species included either hawthorn or blackthorn. Common and widespread in the local area and the UK, species poor hedge offers suitable foraging, commuting and nesting habitat for a number of protected species, including great crested newt, bats, badger, passerine species of bird and to a lesser extent dormouse. As a
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result, this habitat is likely to be of zone of influence (including the site) nature conservation value. Defunct hedge This habitat is of similar species composition to that of Zone of influence species poor hedge. Large gaps separate intact sections (including site)
of hedge and reduce its connectivity and foraging value. As a result this habitat is considered to be of low ecological value and therefore is likely to be of zone of influence (including the site) nature conservation value. Scattered/Standard trees A number of mature and semi-mature standard trees Local are present within the site, predominantly associated with field boundaries. Of affiliation to both UK and LBAP habitat (lowland mixed deciduous woodland and native woodland respectively), this habitat provides both suitable foraging habitat for a number of species including bats, birds and invertebrates, as well as suitable habitat for nesting birds and roosting bats. This habitat also provides favourable commuting routes for a number of protected species. Given that this habitat is often associated with species poor hedge across the site and its moderate ecological value, scattered/standard trees are likely to be of local nature conservation value. Waterbodies Standing water is a UKBAP and LBAP habitat due to the Local recent decline in its numbers throughout the UK. This habitat has the potential to support both breeding and foraging protected and notable species. Present both within the survey area itself and the wider landscape surrounding the site, ponds are likely to be of local nature conservation value. Wet and dry ditch Ditches with areas of open water for the majority of the Zone of influence year are listed under the LBAP. Ditches within the site (including site)
are considered likely to dry during the summer months, suggesting they are no classified under UK or LBAP priority habitat listings. Nevertheless, the ditches within the site have the potential to support protected species, including water vole, great crested newt and several bird species. Ditches are common within a typical agricultural landscape and are often associated with field boundaries. As a result, this habitat is likely to be of zone of influence (including the site) nature conservation value. Ruderal vegetation This habitat is common and widespread within the UK Zone of influence and is not a protected habitat type. No protected (including site)
species that are likely to occur on site are dependent on this habitat type. As a result, ruderal is likely to be of zone of influence (including the site) nature conservation value.
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Species Badger Badgers area a common and widespread species in the Zone of influence UK (estimated to be 288,000 individuals), but are (including site)
protected by the Protection of Badger Act 1992 due to frequent persecution. Generally activity levels were low with only 4 setts recorded. This may be a result of the limited sett building locations available, as well as large areas of arable land (a sub-optimal foraging habitat for badger). Based on the common status of badger, the low level of activity recorded across a large site and the presence of more suitable foraging and sett building habitat within the wider landscape, badgers are likely to be of zone of influence (including the site) nature conservation value. Great crested newt Local records confirmed the presence of great crested Local newt (GCN) within 2km of the site (89 individual adult records). Surveys confirmed the presence of GCN in 9 of the waterbodies surveyed, including 5 which were located within the site. GCN are Protected under the Wildlife and Countryside Act 1981 (WCA) and the Habitat Regulations 2012 and are listed under the UK and LBAP. GCN are common throughout much of England, including the south east and it is estimated the 400,000 individual GCN are present within the UK in over 18,000 breeding sites. The site provides suitable breeding, foraging, commuting and hibernating habitats for GCN. Based on the common status of GCN and the similar suitable breeding and foraging habitat within the wider landscape, GCN are likely to be local nature conservation value. Water vole Desk study records and survey results confirm the Local presence of water vole within the site and the surrounding landscape. Water vole are listed under the UK and Kent LBAP and are afforded protection under the WCA, 1981. Kent population is within the highest 3rd in mainland Britain. Habitats within the site suitable for water vole include ponds and the network of ditches, as well as the riparian vegetation. The presence of water vole within the site and the importance of the Kent population in regards to mainland Britain, water vole are likely to be of local nature conservation value.
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Bats The majority of the site is arable land, offering limited Local foraging/commuting potential. Linear features associated within field margins, such as hedgerows, ditches, woodland and semi-improved grassland provide foraging and commuting potential. Several bat species were recorded during the surveys, including common pipistrelle, soprano pipistrelle, noctule, Nyctalus sp., and Myotis sp.. Pipistrelle species were the most frequently recorded foraging and commuting a cross the site, whereas noctule, Myotis sp. and Nyctalus sp. were recorded in low numbers (commuting only) and it is anticipated the site does not form part of their main foraging habitat. The current UK population of the bat species recorded are; 2,430,000 of common pipistrelle, 1,300,000 of soprano pipistrelle and 50,000 of noctule of which 45,000 are within England. No roosts were confirmed within the site, however 115 trees were assessed as having the potential to support roosting bats. Therefore, based on the availability of suitable habitat present within the wider landscape, the current UK population estimates and the limited foraging potential within the site (except for pipistrelle sp.), it is anticipated that bats are of local nature conservation value. As no trees with bat roosting potential are scheduled for removal under the site proposals, no detailed tree assessment has been undertaken. Breeding birds The site supports several notable and protected species Local of breeding bird. Estimated UK populations are as
follows; bullfinch 220,000 pairs, cuckoo 16,000 pairs, dunnock 2,500,000 territories, green woodpecker 52,000 pairs, herring gull 140,000 pairs, house sparrow
5,300,000 pairs, kestrel 46,000 pairs, linnet 430,000
territories, mallard 61,000-146,000 pairs, meadow pipit 2,000,000 territories, reed bunting 250,000 territories, skylark 1,500,000 territories, song thrush 1,144,000 territories, starling 804,000 territories, swallow 860,000 territories, whitethroat 1,100,000 territories and yellowhammer 710,000 territories. Two Schedule 1 species (hobby and barn owl) were recorded foraging within the site. Breeding birds on site are associated with the arable, woodland and hedgerow habitats.
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The site was found to be supporting six of the twelve declining farmland bird species from the BTO and RSPB Farmland Bird Index. Based on the number of birds recorded compared to their UK estimates and the availability of similar available habitat surrounding the site, breeding birds are considered to be of local nature conservation value. Wintering Birds The site supports several notable species of bird none Local of which were found in significant numbers.. Two Schedule 1 species (redwing and fieldfare) were also recorded within the site neither of which will use the site for breeding. Wintering birds on site are associated with the arable, woodland and hedgerow habitats. The site was found to be supporting two of the twelve declining farmland bird species from the BTO and RSPB Farmland Bird Index. Based on the number of birds recorded compared to their UK estimates and the availability of similar available habitat surrounding the site, wintering birds are considered to be of local nature conservation value. Reptiles Hedgerow, grassland, scrub and waterbodies within the Local site provide suitable habitat for a number of reptile species, including common lizard, grass snake and slow worm. All of the recorded species are common and widespread across the south east of England. Although protected, these species are amongst the commonest of reptile species and are found within limited suitable habitat across a largely arable site. Based on this and the availability of more suitable habitat within the wider landscape, reptile populations are considered to be of local nature conservation value. Dormouse Several habitats within the site, namely species rich and County species poor hedges and ancient woodland blocks are suitable to support dormouse. Although these habitats are limited to field margins and the periphery of the site, evidence of dormouse was recorded in compartments B2, B3, B5 and B6, including 9 dormouse nests. Dormouse numbers have halved in England in the last 100 years but Kent remains one of the best counties for Dormouse in England. As a result of this and the known presence of dormouse within the site and surrounding landscape, dormouse are of county nature conservation value.
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Baseline conditions without development (the ‘Do Nothing’ scenario)
12.4.61 Existing habitats within the site are intensively managed for agricultural purposes, mainly for arable with some limited grazing and management of hedgerow boundaries. All other habitats relate to the boundaries of these agricultural uses across the site. It is considered therefore that there will be no change to the overall ecological nature conservation of the site should development not take place.
12.4.62 Should the site continue to be used for agriculture and current national trends remain, a further decline of species diversity associated with farmland habitats is expected within the site. Examples of this include succession of waterbodies, eutrophication of waterbodies resulting from runoff and intensive management of hedgerow field boundaries.
12.5 Potential impacts
Construction Phases
Statutory and Non-Statutory Designated Sites
12.5.1 No statutory designated sites are present within 2km of the site.
12.5.2 Three non-statutory designated sites are located 1km or more from the site. There is limited habitat connectivity between the site and these three sites as the terrestrial habitat in the area is predominantly agricultural. There is limited aquatic habitat connectivity in the form of drainage ditches; however, these are segmented and like those within the site are likely to be dry during the summer period. Consequently, no direct or indirect adverse impacts upon any of the designated sites are likely during the construction phase.
Habitats
12.5.3 Approximately 60% of the site will experience permanent habitat loss as a result of the development proposals. The built development will be predominantly located within areas of arable field, thus minimising impacts upon the more ecologically valuable habitats within the site. The remainder of the site area will be utilised for habitat enhancement and public open space.
Arable
12.5.4 It is anticipated that the arable land will be permanently lost as a result of the proposed development, primarily designated for housing. This habitat is of zone of
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influence (including site) nature conservation value based on its low diversity and ecological value, although it does offer some foraging potential. Impacts upon this habitat will be permanent and irreversible during construction of the site; however, when considering the common status of this habitat and the abundance of arable land in the local area, it is considered that there will not be an impact upon the conservation status of arable land. Impacts upon arable land therefore are considered to be of low to medium magnitude and as a result, the significance of the impact upon these habitats without mitigation is considered negligible to minor for the purpose of this EIA.
Hedgerows
12.5.5 There will be loss of small sections of hedgerow field boundaries (including defunct, species-rich and species-poor) and associated trees. Permanent loss of these habitats would be localised to allow access routes to intersect the site. Of the hedgerows within the site, sections of species-rich, species-poor and defunct hedgerows are to be lost. Sections of hedges H4, 6, 7, 11, 14, 15, 20, 22, 28, 46, 51 and 52 will be lost. Of these hedges, H7 and H20 are species rich and H22 and H28 are species rich and important ecologically. The impacts upon hedgerow will be permanent and irreversible. A very small number of standard trees would be lost as a result of the development including T101, a category A pedunculate oak tree. Species-rich hedgerows are of district nature conservation value and species-poor and defunct hedgerows are of zone of influence (including site) nature conservation value. The Masterplan design has sought to avoid impacts on the majority of species rich and ecologically important hedgerows as well as the majority of high-value trees. Based upon construction activities and the type of development, the magnitude of impact is considered to be low and the significance of impact without mitigation is considered to be negligible to minor for the purpose of this EIA.
Semi-improved neutral grassland
12.5.6 Semi-improved neutral grassland has been categorised into grazed pasture, road verges and areas around field margins. The development proposals necessitate the permanent loss of most of the semi-improved grassland within the site, however some areas will be retained and others created in recreational space. This habitat is of zone of influence (including site) nature conservation value based upon the common status of this habitat and presence within the wider landscape. The impacts upon this habitat will be both permanent and irreversible. It is considered that the impacts on semi-
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improved neutral grassland will be of low to medium magnitude and therefore of negligible to minor significance without mitigation, for the purpose of this EIA.
Improved Grassland
12.5.7 There would be loss of improved grassland as a result of the development proposals, however the development proposals will include new areas of improved grassland. This habitat would be lost to roads and residential dwellings. Improved grassland is no more than zone of influence (including site) nature conservation value based upon its low diversity and ecological value and common status. Impacts resulting from the construction of the site will be permanent. Thus, these impacts are considered to be of low to medium magnitude and as a result negligible to minor significance (without mitigation) for the purpose of this EIA.
Ditches
12.5.8 Construction activities will require the development of primary road access across Ditch 5 within compartment B3 (Area 2 of the proposed scheme). This will result in the loss of riparian vegetation where the crossing is located and likely disturbance to the aquatic habitat. Based upon their common presence across agricultural habitats and widespread status within the UK, ditches are no more than zone of influence (including site) nature conservation value. Construction impacts upon ditch 5 will be localised to the crossing point only, will be both direct and indirect, permanent and irreversible (loss of vegetation and bank side habitats), and temporary and reversible (disturbance to watercourse). Consequently, impacts upon this habitat is considered to be of negligible magnitude and as a result negligible significance (without mitigation) for the purpose of this EIA.
Other Habitats
12.5.9 There will be no loss to the remaining habitats identified within the site during the construction phase, including ancient woodland, which has been protected in the Masterplan through the inclusion of a minimum 15m buffer as per Natural England Standing Advice.
Species
Badger
12.5.10 Four badger setts were recorded within the site. This includes 2 outlier setts and 2 main setts (one disused), of which three are located along the periphery of the site.
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The Masterplan has allowed for adequate standoffs (minimum 30m) from all active setts and as such construction activities will not directly impact upon any of the known badger setts. Badgers are of zone of influence (including site) nature conservation value. There could be both direct and indirect impacts upon individual badgers as a result of the construction activities. These impacts include the potential for injury or death during construction, possible entrapment, indirect disturbance whilst occupying their sett, disruption and permanent loss of commuting routes, and the permanent loss of small areas of optimal (grassland, scattered scrub and hedgerow) and larger areas of sub-optimal foraging habitat (arable). The loss of these foraging habitats and disturbance during construction will not affect the conservation status of badger within the site and their wider population. As a result, the magnitude of impact upon badger is considered to be low and the significance of impacts without mitigation during construction on badger is likely to be of negligible significance for the purpose of this EIA. Nevertheless, mitigation measures will need to be incorporated into the development to ensure potential impacts are minimised.
Great Crested Newt
12.5.11 Great crested newt (GCN) were found in several waterbodies within and surrounding the site. The Masterplan has allowed for the retention of immediate terrestrial habitat (50m surrounding the waterbody) through the construction phase. There could be direct and indirect adverse impacts as a result of construction activities on intermediate foraging habitats. These include the potential for injury or death of individual GCN, possible entrapment, loss of foraging and commuting habitat, and potential disturbance during hibernating months. It is considered that the majority of terrestrial habitats within the construction areas are of low ecological value for great crested newt compared to the value of surrounding habitat to be retained. Great crested newts are of local nature conservation value based upon their relatively common status. Great crested newt could be present within the construction areas, although the likelihood of their presence is considered to be low within the less suitable habitat. Therefore, it is considered unlikely that impacts resulting from the construction stage would impact upon the conservation status of great crested newts. As a result, the magnitude of impact is considered to be low and the significance of impact without mitigation is considered to be negligible for the purpose of this EIA. Nevertheless, mitigation measures will need to be incorporated into the development to comply with the legal protection afforded to individual GCN and to ensure potential impacts are minimised.
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Water Vole
12.5.12 Water vole occur within several ditches and waterbodies across compartment B3 (Area 2 of the proposed scheme). Construction activities may result in both direct and indirect impacts upon water vole. These include injury or death, possible entrapment, loss of breeding and foraging habitat and loss of dispersal routes. Furthermore, creation of a primary road across Ditch 5 has the potential to segregate and cause the isolation of a known population. Water vole are of local nature conservation value based upon their nationally declining numbers, but high density within the county of Kent. The impacts upon water vole may be both permanent and irreversible (i.e. loss of small sections of terrestrial habitat) and temporary and reversible (i.e. disturbance to commuting routes, accidental pollution of watercourse). However, impacts during construction are unlikely to adversely affect the conservation status of water vole due to the relatively small areas of known habitat to be affected and the retention of the majority of all known water vole habitat within the site. Therefore the impacts are considered to be of medium magnitude. Consequently, the significance of construction activities without mitigation is minor for the purpose of this EIA. Nevertheless, mitigation measures will need to be incorporated into the development to ensure potential impacts are minimised.
Bats
12.5.13 Bats were recorded foraging and commuting across the site, including high numbers of common pipistrelle and low numbers of soprano pipistrelle, noctule, Nyctalus sp. and Myotis sp. Foraging was concentrated to linear features, including woodland edges, hedgerows and grassland habitats. Bats are considered to be of local nature conservation status. Construction activities will retain the majority of optimal foraging and commuting features, with the vast majority of habitats lost comprising less optimal foraging habitats (arable and improved grassland). No trees with suitable bat roosting potential will be lost as a result of the development as all suitable trees are either around the periphery of the site or within retained green space. Impacts resulting from construction activities (i.e. habitat loss and disturbance during foraging/commuting) would be indirect only, but would be both temporary and reversible (disturbance) and/or permanent and irreversible (foraging habitat loss). It is however, considered that impacts during construction will not impact upon the conservation status of bats. As a consequence, construction impacts will be of low magnitude and therefore of negligible significance (without mitigation) for the
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purpose of this EIA. Nevertheless, mitigation measures will need to be incorporated into the development to ensure potential impacts are minimised.
Birds
12.5.14 Impacts upon the avian assemblage during construction would comprise a direct impact through the permanent loss of arable land, field margins, semi-improved grassland and hedgerow sections and indirect disturbance comprising noise during construction works. This disturbance during construction will be temporary but the habitat loss and operational phase will be permanent. Breeding and wintering birds utilise areas of hedgerow, arable land, field margin and semi-improved grassland. Impacts upon the notable breeding bird assemblage (also inclusive of all other nesting birds) could be limited through appropriate timing of any vegetation clearance (i.e. avoidance of the nesting bird season which runs from March to August inclusive). In addition, the retention and/or reinstatement of appropriate habitats for species of conservation concern identified within the breeding and wintering bird surveys would also limit further impacts.
12.5.15 The magnitude of impacts during construction is anticipated to be low on the conservation status of avifauna based on the habitat evaluation provided in the PEA and the site’s breeding and wintering bird diversity highlighted in the Breeding Bird Survey and Wintering Bird Survey. The main impact during construction is anticipated to be from loss of declining farmland bird habitat such as arable land and field margins which currently support breeding skylark. Two displaying skylark were recorded during the surveys which signifies a relatively low population density compared to the number of breeding pairs nationally (1,500,000 territories nationally RSPB 2014) and the size of the arable habitats present on site. The hedgerows on site were found to be supporting a variety of both breeding and wintering birds including bullfinch, dunnock Prunella modularis , house sparrow Passer domesticus , linnet Carduelis cannabina , reed bunting, song thrush, whitethroat Sylvia communis and yellowhammer. All these species are classed as birds of conservation concern and are largely associated with the hedgerows in farmland landscapes. There will be a buffer stand-off distance to all the hedgerows to be retained on the site, and the majority of hedgerows will be retained, therefore the magnitude of impacts without mitigation during the construction phase is anticipated to be low on avifauna with the significance being negligible for the purpose of this EIA.
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Reptiles
12.5.16 Reptiles were recorded across the site, including grass snake, common lizard and slow worm. Suitable habitats include hedges, scrub, grassland and waterbodies. Much suitable habitat has been retained under the proposals, including all habitat within 50m of waterbodies and the majority of hedgerows. However, during construction of the site there could be both direct and indirect impacts upon reptiles. These include the potential for injury or death, possible entrapment, loss of suitable foraging habitat and the loss of dispersal routes. The majority of construction work will result in the loss of arable land, considered to be of low ecological value to reptiles. Loss of more suitable habitat, including hedge, waterbodies and scrub will be limited to access of primary roads across all compartments; as well as small blocks of improved grassland within compartments B3 and B4 and B6 (Area 2, 3 and 4 of the proposed scheme). These impacts will be permanent and irreversible but are not anticipated to adversely impact upon the conservation status of reptiles. Reptiles are considered to be of local nature conservation value. The impacts upon reptiles are considered to be of low magnitude. Consequently, the significance of construction impacts without mitigation upon reptiles are of negligible significance for the purpose of this EIA. Nevertheless, mitigation measures will need to be incorporated into the development to ensure that potential impacts are minimised and that legislation pertaining to reptiles is adhered to.
Dormouse
12.5.17 The site supports a number of habitats (hedgerows and woodland) that are suitable for dormouse and evidence of dormice has been found in four compartments. Construction activities will be concentrated on the large areas of arable land, not considered suitable habitat for dormouse. Where proposed new roads dissect the site, areas of hedgerow will be removed, potentially fragmenting known dormouse habitat. During construction activities impacts could be direct and indirect and may include injury or death, possible entrapment, loss of suitable foraging habitat and the loss/isolation of dispersal routes. These impacts will be permanent and irreversible without mitigation. Dormice are of county nature conservation value based on their national decline and Kent is one of the best counties for dormouse in the country. Construction impacts upon dormice are considered to be medium in magnitude. Consequently, the significance of impacts upon dormouse without mitigation is considered to be minor significance for the purpose of this EIA. Nevertheless,
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mitigation measures will need to be incorporated into the development to comply with the legal protection afforded to this species, as well as ensuring potential impacts in terms of injury/death and habitat fragmentation are minimised.
Operational phase
12.5.18 The operational phase of the development includes the creation of a number of habitats within the site, which will be implemented during the construction phase of the scheme. Consequently, these habitats are considered within the assessment below.
12.5.19 As the scheme comprises residential development, the proposed development is considered to be permanent.
Non-statutory and Statutory Designated Sites
12.5.20 No statutory designated sites are present within 2km of the site. Three non-statutory designated sites are located 1km or more from the site.
12.5.21 There is limited habitat connectivity between the site and these three designated sites, as the majority of the terrestrial land is predominantly agricultural. There is limited aquatic habitat connectivity in the form of drainage ditches; however, these are segmented and like those within the site are likely to be dry for at least part of the year. Consequently, no direct or indirect adverse impacts are likely to occur upon any of the designated sites as a result of the operational phase.
Habitats
12.5.22 Habitat loss is likely to be restricted to the construction phase of the site. In addition, existing habitats of value will be retained and protected and new habitats will be constructed within the construction phase, which will establish during the operational phase. All habitats could be impacted upon during the operation of the site and are assessed below.
12.5.23 Site layout and design has resulted in the retention of the majority of hedgerows (both species-rich and poor), semi-natural broadleaved woodland (including a 15m buffer around the Isaac Wood ancient woodland), waterbodies and watercourses, scrub, and standard trees. Furthermore, site proposals have included the creation of several large areas of open green space which will encompass several existing ecological receptors, including badger setts, great crested newt breeding ponds and water vole habitats, all of which have the potential to be enhanced. Creation and enhancement
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of the open green spaces is likely to increase the ecological value and diversity of the habitats within the site; compared to that which currently exists (i.e. predominantly arable). Residential gardens within the operation areas where arable land currently exists are furthermore likely to create habitats suitable for a number of protected and notable species, although are unlikely to be suitable for species which require open habitats such as skylark.
12.5.24 In addition, existing footpaths are to be bordered by open green space providing further foraging, nesting and commuting habitat for a number of protected and notable species within the site.
12.5.25 The habitats within the site range from zone of influence (including site) nature conservation value to county nature conservation value. All habitats have the potential to be directly and indirectly impacted upon during the operational phase of the development. These include deterioration of habitats, small scale loss of habitat and disturbance to habitats and species that rely upon them. Potential effects may include pollution incidents, litter, increased runoff, and direct impacts resulting from human activity (I.e. increased foot fall and vandalism). Operational impacts upon retained habitats will be permanent and irreversible. As a consequence, the magnitude of potential impacts upon the retained habitats is considered to be medium. The significance of these impacts without mitigation will therefore be minor for the purpose of this EIA.
Species
Badger
12.5.26 Impacts resulting from the operational phase upon badger will be both direct and indirect. These impacts include injury or death, indirect disturbance whilst occupying their sett, dividing or isolation of territories and the disruption of commuting routes retained during the construction phase. Operational impacts could be permanent and irreversible. Planting of green open spaces surrounding badger setts will include scrubby species including hawthorn, blackthorn and bramble in order to provide an additional food source, as well as discouraging human and pet access during the operational phase. Badger are of zone of influence (including site) nature conservation value and the magnitude of the impacts is considered to be medium, based upon the potential increase of collision with vehicles, permanent segregation of territories and disturbance to commuting routes. Impacts are not however
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considered to adversely impact upon the conservation status of badgers. As a consequence, the significance of impact upon badgers without mitigation is likely to be minor for the purpose of this EIA. Nevertheless, mitigation measures will be incorporated into the development to ensure potential impacts are minimised.
Great Crested Newt
12.5.27 Great crested newt were recorded in the site. Their breeding habitat, dispersal routes and immediate terrestrial habitat will not be lost during construction, and the operational phase is unlikely to result in further loss of these habitats. Furthermore, site design and layout will secure these habitats and creation of open green spaces will enhance their suitability for this species. The proposed SuDS areas within the site will establish naturally; thereby creating further habitat suitable to support breeding great crested newt. There would however, be both direct and indirect impacts resulting from the operation of the site. These could include death or injury, indirect and direct disturbance/degradation of breeding, foraging and commuting habitats and possible disturbance during hibernation. Operational impacts could be permanent and irreversible and would result from collision with vehicles, trapping within drainage infrastructure of roads, predation from pets, pollution of breeding sites, introduction of coarse fish to waterbodies and disturbance to retained terrestrial habitat. Great crested newts are of local nature conservation value. Residential gardens and the creation of new habitats are likely to enhance the area for great crested newts in localised areas corresponding with the existing populations. Overall it is anticipated therefore that their conservation status has the potential to be impacted long term, but development is unlikely to threaten the long term sustainability of the population, resulting in a medium magnitude. The significance of the impacts without mitigation is likely to be minor for the purpose of this EIA. Mitigation measures will be incorporated into the development to ensure potential impacts are minimised.
Water Vole
12.5.28 Habitats within the site are known to support breeding and foraging water vole, within compartment B3 (Area 2 of the proposed scheme), with the possibility of excursions during wet periods into connected ditches. The waterbodies within the site will be enhanced with appropriate planting where necessary to provide suitable marginal and riparian habitat for water vole. Impacts resulting from the operation of the site could be permanent and irreversible and both indirect and direct; including injury, death or disturbance, segregation/isolation of populations and disturbance of dispersal routes.
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Impacts could result from collision with vehicles, and predation from pets such as cats. The impacts upon water vole within this compartment are therefore considered to be of medium magnitude, as their conservation status may be negatively impacted, but it is unlikely that the population’s long term sustainability will be threatened. Water vole are of local nature conservation and with a medium magnitude of impact, the significance of impacts without mitigation is anticipated to be minor for the purpose of this EIA. Mitigation measures will be incorporated into the development to ensure potential impacts are minimised.
Bats
12.5.29 Five species of bat were recorded foraging and commuting across the site (predominantly common and soprano pipistrelle – nationally common species). Three other species, including noctule, Myotis sp. and Nyctalu s sp. were present in low numbers. Bats are considered to be of local nature conservation status. The primary habitats associated within foraging and commuting bats (hedges woodland and tree lines) are largely to be retained during both the construction and operational phases of the site. In addition, further habitats will be created which will establish during the operational phase (SuDS) and planting of green open spaces and enhancement of existing hedgerows will further increase available foraging and commuting habitats across the site. Impacts associated with the operational phase are likely to be both indirect and direct, and potentially permanent. These include disturbance to foraging and dispersal from increased lighting and potential for low level predation from pets. Impacts resulting from operation of the site could be permanent but are not considered to impact upon the conservation status of foraging and commuting bats. Thus, the magnitude of impact on foraging and commuting bats are considered to be medium. The level of significance without mitigation therefore is considered to be minor for the purpose of this EIA. Mitigation measures will be incorporated into the development to ensure potential impacts are minimised.
12.5.30 Further investigation of trees identified as having potential to support roosting bats may be required at the detailed planning application stage. This will allow further evaluation of impacts upon bats.
Birds
12.5.31 Impacts upon the avian assemblage during the operational phase will comprise the disturbance that residential development can bring comprising recreational/footfall pressure, lighting, noise and domestic pets. However, several of the species will
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readily make use of residential areas i.e. house sparrow, song thrush, starling and dunnock and are therefore likely to benefit from the provision of domestic gardens. Areas of green open space have been incorporated into the masterplan and these will be tailored towards providing high quality habitat for declining farmland birds which will not occupy domestic gardens and will be most impacted upon through the loss of open farmland landscapes such as skylark, barn owl, cuckoo and yellowhammer. The magnitude of impacts without mitigation during the operational phase is anticipated to be low on avifauna with the significance being negligible for the purpose of this EIA.
Reptiles
12.5.32 Reptiles including grass snake, common lizard and slow worm were recorded across the site. Impacts during the operational phase of the site are likely to be both indirect and direct and could include collision with vehicles, predation from pets and disturbance to hibernating and dispersal routes. Impacts upon reptiles could be permanent. Considered to be of local nature conservation value, the magnitude of impacts upon reptile within the operational phase is unlikely to significantly impact upon their conservation status resulting in a medium magnitude of effect. This is based upon their relatively common status throughout Kent and the UK. Consequently, the significance of impacts without mitigation are considered to be minor for the purpose of this EIA. Mitigations measures will be incorporated into the development to ensure potential impacts are minimised.
Dormouse
12.5.33 Dormice were recorded within a number of hedgerows across the site. Habitats within the site suitable to support dormouse are mostly to be retained and will be enhanced with appropriate planting where necessary to provide suitable habitat for dormouse. Planting of green open spaces within the site will provide further nesting and hibernating habitats for dormouse and will increase routes of dispersal within the site and surrounding landscape. There could however, be further direct and indirect impacts upon dormouse during the operational phase of the site. These could include predation from pets, potential fragmentation/isolation of the population, disturbance to nest and hibernation sites, degrading of suitable foraging habitat (species rich hedges) and increased risk of collision with vehicles. Impacts upon dormouse could be permanent and irreversible and may impact upon their conservation status. Dormouse are of county nature conservation value (Kent being one of the better
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counties for dormouse) and indirect and direct impacts within the operation areas have the potential to adversely affect the conservation status of dormouse within Kent. As a result the magnitude of impact will be high, thus the significance of impact without mitigation will be moderate for the purpose of this EIA. Mitigation measures will be incorporated into the development to ensure compliance with relevant legislation and ensure potential impacts are minimised.
12.6 Mitigation and Enhancement
12.6.1 Assessment of the potential impacts has established that significant effects (for the purpose of this EIA) will occur with regards to dormouse during the operational phase of the scheme. In order to address all significant effects resultant from the construction and operational phases, the mitigation measures will be included within a Construction Environmental Management Plan (CEMP) and Site Environmental Management Plan (SEMP).
12.6.2 Effects upon the remaining ecological receptors are assessed as not significant (for the purpose of this EIA) during the construction and operational phases of the scheme. However it is acknowledged that in order to comply with relevant legislation and best practice, the mitigation measures below will be included within the CEMP and SEMP.
Non-Statutory and Statutory Designated Sites
12.6.3 The assessment established that impacts upon designated sites resulting from both construction and operation of the site will not be significant for the purpose of this EIA. As a consequence, no mitigation measures are considered necessary.
Habitats
12.6.4 A Site Environment Management Plan will be developed prior to the onset of any development to allow for the management and creation of existing and new habitats with a specific focus towards mitigating impacts upon the species currently utilising the site and enhancing the overall value of the site for biodiversity.
12.6.5 There are no impacts which will have significant effects upon the habitats within the site. The majority of habitats impacted are common and widespread within the local area and the UK and are therefore predominantly of zone of influence (including site) nature conservation value. Only semi-natural broadleaved woodland and species rich hedgerow are of county nature conservation value.
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12.6.6 Buffer zones are to be incorporated around all retained habitat during the construction of the site which includes Isaac Wood which is designated as ancient woodland and which will have a minimum 15m buffer to any development as per Natural England Standing Advice.
12.6.7 The Masterplan includes significant areas of new habitat within the site and with this in mind and the mitigation in place, it is considered that there will be short term negligible adverse impacts upon habitats resulting from loss during construction; but minor beneficial impacts in the long term following creation and establishment of green spaces.
Species
Badger
12.6.8 Assessment established that impacts would not have significant effects on badgers. In compliance with current legislation, mitigation measures would be required to safeguard badgers during both the construction and operational phases of development.
12.6.9 Mitigation will include retaining a minimum 30m buffer around each sett, excluding all works during the construction phase. All setts will retain direct connectivity to off- site habitat and areas in the vicinity of the setts will be enhanced to provide better foraging and commuting habitat, such as sympathetic hedgerow management.
12.6.10 Signs will be installed at points where historic badger commuting routes cross primary and secondary roads to raise awareness and reduce the risk of collision with vehicles.
12.6.11 The above mitigation measures and site design and layout will ensure compliance with the relevant wildlife legislation and protection of badgers throughout construction and operation of the site.
12.6.12 It is therefore considered that there will be negligible adverse impacts upon badgers resulting from the construction and operation of the site; but possible minor beneficial impacts in the long term following establishment of enhanced foraging habitats within open green spaces and signage warning people of the presence of badgers in and around the area.
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Great Crested Newt
12.6.13 The assessment established that for the purpose of this EIA, impacts during the operation of the site will result in effects upon three separate medium populations of great crested newts. Mitigation measures will be required to ensure compliance with relevant legislation. These measures will include the following.
12.6.14 All construction areas within each compartment located within 500m from a known breeding pond will be trapped under Licence from Natural England. All great crested newts captured will be translocated to a previously designated/created receptor site/s.
12.6.15 Upon receipt of a Natural England licence for Great Crested Newts, temporary amphibian fencing will be erected around the construction area within each compartment, along with pitfall traps spaced every 10m, in accordance with the requirements (length of fence and number of pitfall traps) set out in the Great Crested Newt Mitigation Guidelines (2001).
12.6.16 Translocation of great crested newts from the development areas to a designated ‘receptor site’ will be for a minimum capture period of 60 days (as a result of the ‘medium’ population present) plus an additional 5 days clear during suitable weather conditions. If great crested newts are discovered, trapping would continue until there are 5 clear days of no great crested newts found.
12.6.17 Once the development site is determined to be clear of newts following capture and translocation, a destructive search of suitable terrestrial habitats to support newts, will occur across the construction areas under the supervision of an ecologist.
12.6.18 Once each area for development is free from vegetation, construction will commence (dependent on other ecological receptor requirements).
12.6.19 Fence checks will be undertaken twice weekly by the site contractor and once a month throughout the construction period by an ecologist to ensure the integrity of the fence is maintained in order to ensure great crested newts do not re-enter the site.
12.6.20 Once construction activities are completed, the temporary amphibian fence will be removed under the supervision of an ecologist. Any newts discovered within the temporary amphibian fencing will be translocated to the receptor area.
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12.6.21 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of great crested newts throughout construction and operation of the site.
12.6.22 With this mitigation in place, it is considered that there will be negligible adverse impacts upon great crested newt during construction and operation; but minor beneficial impacts in the long term following establishment of suitable habitat in open green spaces including the construction and establishment of receptor areas and ponds.
Water vole
12.6.23 The assessment established that operation of the site could cause effects on the water vole population within compartment B3 (Area 2 of the proposed scheme).
12.6.24 In order to comply with relevant legislation pertaining to water vole, the following mitigation measures will be implemented.
12.6.25 A minimum 10m buffer will be maintained around all waterbodies and watercourses within the site. Around GCN ponds this distance is significantly greater and as such there will also be benefits afforded to water voles.
12.6.26 The construction and establishment of SuDS ponds will provide several new areas of habitat within the vicinity of existing water vole populations, and this increase in habitat availability is likely to lead to a corresponding increase in water vole numbers as new territories become available.
12.6.27 At the detailed design stage, road crossing points will be located at the least active section of a water vole territory and will avoid damaging burrows. A search of the area by a suitable qualified ecologist prior to development can advise on the most appropriate crossing point.
12.6.28 Road crossing points should be designed using box culverts and will include ledges and will be of sufficient diameter and of a length to be unlikely to deter the movement of water vole.
12.6.29 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of water vole throughout construction and operation of the site.
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12.6.30 With this mitigation in place, it is considered that there will be negligible adverse impacts upon water vole during construction and operation; but minor beneficial impacts in the long term following establishment of open green spaces.
Bats
12.6.31 The assessment established that impacts resulting from the construction and operation of the site will not result in significant effects on the foraging and commuting bat population across the site.
12.6.32 However, in order to mitigate against the presence of foraging and commuting bats within the site, the likely presence of roosting bats within the site, and to comply with the relevant legislation afforded to bats, the following mitigation measures will be implemented.
12.6.33 Further survey work will be undertaken should further tree removal be required of trees considered suitable for roosting. If bats are roosting within the trees a licence will be required from Natural England to disturb or destroy the roost. Once the number and species of bats is known, appropriate mitigation can be provided.
12.6.34 In order to ensure no direct or indirect impacts to foraging or commuting bats, an appropriately designed lighting strategy will be implemented to prevent adverse impacts to the local bat population, for example by preventing light spill onto retained hedges and tree lines. Newly created and enhanced retained green space will provide additional foraging habitat for bats once vegetation is established.
12.6.35 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of bats throughout construction and operation of the site.
12.6.36 With this mitigation in place, it is considered that there will be negligible adverse impacts upon bats during construction and operation but minor beneficial impacts in the long term following establishment of open green spaces.
Birds
12.6.37 The assessment established that impacts resulting from the construction and operation of the site will not result in significant effects on the avian population present within the site.
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12.6.39 Detailed descriptions relating to mitigation will be provided by way of a mitigation strategy and Site Environmental Management Plan that covers the site as a whole, which will be developed prior to the onset of any development to allow for the management and creation of existing and new habitats with a specific focus towards declining farmland birds. Examples of mitigation will comprise reinstatement of semi- improved grassland for foraging barn owl and breeding skylark, associated areas of scrub habitat for meadow pipits and warbler species which can be parasitised by cuckoo and the incorporation of waterbodies which can support dragonflies and foraging hirundines which could then support foraging hobby. Maintenance of hedgerows will promote structural diversity and enhance the existing foraging and sheltering opportunities for both breeding and wintering birds. Details of sympathetic hedgerow management are detailed within the dormouse mitigation section below.
12.6.40 A range of bird species will make use of the vegetated areas on and around the site for breeding. All vegetation removal should ideally take place outside the breeding bird season (March to August inclusive). Should removal be required between March and August, a suitably qualified ecologist will assess the vegetation immediately prior to removal to determine the presence of breeding birds. If an active nest is identified prior to vegetation clearance, removal will not take place until all the young have fledged and the nest has been confirmed to be inactive.
12.6.41 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of birds throughout construction and operation of the site.
12.6.42 With this mitigation in place, it is considered that there will be negligible adverse impacts upon birds during construction and operation; but minor beneficial impacts in the long term following establishment of open green spaces.
Reptile
12.6.43 The assessment established that impacts resulting from the construction and operation of the site will not result in significant effects on the reptile population that is present within the site.
12.6.44 However, in order to mitigate against the presence of reptiles within the site, and in order to comply with the relevant legislation afforded to them, the following mitigation measures will be implemented.
12.6.45 Reptiles will be captured and translocated during the same process detailed within the great crested newt mitigation above.
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12.6.46 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of reptiles throughout construction and operation of the site.
12.6.47 Newly created habitat and enhanced retained habitat will provide further opportunities for reptiles, such as around SuDS ponds.
12.6.48 With this mitigation in place, it is considered that there will be negligible adverse impacts upon reptiles during construction and operation; but minor beneficial impacts in the long term following establishment of open green spaces.
Dormouse
12.6.49 The assessment established that impacts resulting from the operation of the site may result in significant effects upon the dormouse population present within the site.
12.6.50 Therefore, in order to mitigate against these effects and to comply with relevant legislation pertaining to dormouse, the following mitigation measures will be implemented.
12.6.51 The majority of hedgerows will be retained within the site, however, some gaps will be created within hedgerows to allow for road access. Sections of hedgerow to be removed will be checked for signs of nesting dormouse immediately prior to removal by a suitably qualified ecologist. Removal of vegetation should be completed by hand using hand held tools and if possible should be undertaken between May and October (inclusive) to avoid the hibernation period for dormouse.
12.6.52 The potential isolation of dormice on the site, through the construction of roads, will be mitigated for by the provision of artificial connectivity measures across key road crossings.
12.6.53 In addition, new hedgerow planting will be provided, where required, to enhance habitat connectivity for dormouse. A new section of hedgerow around the pond and to the south of Area 4 towards the southern boundary will be provided and gaps in the southern boundary will be filled to provide a more structured habitat for dormice to use.
12.6.54 Disturbance to dormice through the introduction of pets and people will be mitigated for by the implementation of a sympathetic hedgerow management regime across the site to enhance the habitat for dormice. Hedgerows will be cut on 3 year intervals, with some areas such as within retained and new recreational space, being left to
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grow for at least 7 years. Not all hedgerows on site will be cut in the same year, so that fruiting hedgerows area always present on site
12.6.55 A 2m buffer will be maintained around all retained hedgerows within the site to enable sympathetic habitat management to be carried out. Details of hedgerow management will be included within the SEMP.
12.6.56 The above mitigation measures will ensure compliance with the relevant wildlife legislation and protection of dormouse throughout construction and operation of the site.
12.6.57 With this mitigation in place, it is considered that there will be negligible adverse impacts upon dormouse during construction and operation; but minor beneficial impacts in the long term following establishment of open green spaces and sympathetic hedgerow management across the site.
Additional Mitigation Measures
12.6.58 Construction and operational activities have the potential to harm/kill animals within the site. Any excavations could pose a threat of entrapment and machinery on site could result in collisions. All excavations will be suitably fenced and a means of escape provided for the duration of the construction phase.
12.7 Assessment of residual impacts
12.7.1 Without mitigation, the development will result in both significant adverse impacts and non-significant adverse impacts (for the purpose of this EIA) upon the ecological receptors within the site. In order to mitigate against these impacts and to maintain best working practice and accord with relevant legislation, mitigation measures will be secured as detailed within the mitigation section above.
12.7.2 It is anticipated that with these mitigation measures in place, the development will not have significant impacts upon the ecological receptors within the site. On the contrary, it is likely that with these mitigation measures in place, the development will have some beneficial impacts upon a number of the habitats and species present across the site.
12.8 Cumulative impacts
12.8.1 Potential impacts of the proposed development on the existing ecological condition are not expected to extend beyond the site as any required ecological mitigation will be delivered on-site. The development will have no effects on surrounding ecologically
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designated sites and as such it is anticipated that there will not be any significant cumulative impacts on ecology arising from the development of Kingsnorth Green in combination with other developments in the surrounding area.
12.9 Summary and conclusions
12.9.1 This ecological assessment has identified and evaluated the elements that make-up the local ecosystems and has considered how the impacts of the development may affect each of these in accordance with NPPF and the CIEEM Guidelines for Ecological Impact Assessment (2006). A summary of the impacts in the absence of mitigation is provided in Table 12.6 below along with a summary of the residual impacts following mitigation.
12.9.2 Survey and consultation on ecology and nature conservation has been undertaken from the early stages of the proposed development. This work has allowed the compilation of a baseline that comprehensively characterises the ecological conditions within the site and adjacent areas.
12.9.3 Assessment has established that the proposed development does not affect the nature conservation of the three non-statutory designated sites within 2 kilometres of the site.
12.9.4 In terms of habitats, the proposals will result in the loss of habitats deemed not significant for the purpose of this EIA. In terms of the protected and notable species present, operation of the site could significantly impact upon great crested newt, water vole and dormouse.
12.9.5 Mitigation measures have been included in order to maintain best practice and to adhere to relevant legislation for ecological receptors for which non-significant and significant effects have been identified. With these mitigation measures in place, the proposals are considered unlikely to adversely impact upon the ecological receptors present within the site or their conservation status.
12.9.6 Residual impacts as a result of the mitigation and enhancement measures are likely to be beneficial to habitats and species within the site.
12.9.7 As no significant adverse impacts will result from the proposed development and that mitigation and enhancement measures will be undertaken there is likely to be an overall slight increase in the ecological value and diversity of habitats within the site. As a consequence, this assessment has established the development of the site will comply with the NPPF, as well as relevant species and habitat legislation.
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12.9.8 Further survey work will be required at the detailed application stage in order to provide detailed mitigation measures to address the impacts that may occur upon roosting bats, wintering birds and barn owl. Additional mitigation measures will be provided following completion of these surveys
Table 12.6 – Summary of Impacts and Mitigation
Ecological Significance of impact Mitigation Measures Impact Residual Impact without mitigation following Receptor during construction inclusion of and operation mitigation
Designated Considered to not to be None required N/A N/A Sites significant during construction or operation of the site.
Habitats Considered to not to be Retention of ecological Negligible Likely minor significant during valuable habitats during site beneficial impact construction or design and creation of open following operation of the site. green spaces and associated mitigation. planting.
Badger Considered to not to be Buffer zones around known Negligible Likely minor significant during badger setts, planting of beneficial impact construction or open green spaces and signs following operation of the site. along roadways. Mitigation mitigation. to adhere to relevant
legislation.
Great Considered no to be Capture and exclusion of Negligible Likely minor Crested significant during great crested newt from the beneficial impact Newt construction; but site. Creation of a receptor following significant during the site. Enhancement of open mitigation. operation of the site. green spaces for foraging and hibernating newts. SUDDS to establish naturally to become suitable for newts. Retention of all known breeding ponds.
Water Vole Considered no to be Buffer zones surrounding Negligible Likely minor significant during known water vole habitats beneficial impact construction; but to be retained. Planting and following enhancement of existing mitigation.
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significant during the habitats. Box culverts where operation of the site. road crossing dissect known territories.
Bats Considered to not to be Retention of foraging and Negligible Likely minor significant during commuting routes. Sensitive beneficial impact construction or lighting scheme. Planting of following operation of the site. open green spaces to mitigation. enhance foraging and
commuting within the site.
Birds Considered to not to be Retention of nesting and Negligible Likely minor significant during foraging habitats. Planting beneficial impact construction or of open green spaces to following operation of the site. encourage farmland bird mitigation. species.
Reptiles Considered to not to be Reptiles will be trapped and Negligible Likely minor significant during relocated during mitigation beneficial impact construction or for great crested newts. following operation of the site. Retention of commuting and mitigation. foraging habitats within the
site. Planting of open green space to encourage dispersal and provide additional habitat for reptiles.
Dormouse Considered no to be Buffer zones surrounding Negligible Likely minor significant during hedgerow habitats. beneficial impact construction; but Sensitive management of following significant during the hedgerows. Planting of new mitigation. operation of the site. hedgerows and gapping up of existing hedgerows. Provision of artificial connectively measures across key roads.
12.10 References
Bat Surveys: Good Practice Guidelines, Bat Conservation Trust. Hundt, L., 2012
The Bat Workers’ Manual, JNCC, 2004
Biodiversity: The UK Action Plan, DOE, 1994
Great Crested Newt Mitigation Guidelines, English Nature, 2001
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Guidelines for Ecological Impact Assessment, Institute for Ecology and Environmental Management, 2006
The Handbook for Phase 1 Habitat Survey – a Technique for Environmental Audit, JNCC, 2010
Herpetofauna Workers’ Manual, Gent & Gibson, 2003
A Nature Conservation Review, Ratcliffe, 1977
New Flora of the British Isles, 2nd Edition, Stace, C., 1997
Water vole Conservation Handbook 3 rd ed. WildCRU, 2011
The Dormouse Conservation Handbook 2 nd ed . Natural England, 2006
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13 LANDSCAPE AND VISUAL IMPACT
13.1 Introduction
13.1.1 This chapter of the Environmental Statement (ES) analyses the landscape and visual impacts which would be generated by a residentially led mixed-use development on land at Kingsnorth Green, Ashford.
13.2 Site Description
13.2.1 The site is approximately 60.98ha in size and is located off Ashford Road, Kingsnorth south of Ashford, Kent. The location of the site is shown on Drawing ST13901-008.
13.2.2 The site predominantly comprises irregular arable fields, with some smaller fields and paddocks of improved and semi-improved grassland. It consists of four distinct sections; Area 1 to the north-west, Area 2 to the south-west, Area 3 in the centre and Area 4 to the east.
13.2.3 Area 1 comprises a single arable field and is bound by:
• Pound Lane and residential properties to the north;
• Ashford Road and residential properties to the east; and
• Agricultural land to the south and west.
13.2.4 Area 2 comprises one arable field and two fields of semi-improved grassland. It is bound by:
• Agricultural land and residential properties to the west and north;
• Ashford Road and agricultural land to the east; and
• Magpie Hall Road and residential properties to the south.
13.2.5 Area 3 is the largest section and comprises four arable fields and two small fields of improved grassland. It is bound by:
• Ashford Road and residential properties to the west;
• Agricultural land to the north-east;
• Bond Lane to the south-east; and
• Cricket Ground and residential properties to the south-west.
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13.2.6 Area 4 comprises four arable fields and one small paddock of improved grassland. It is bound by:
• Bond Lane and residential properties to the west;
• Agricultural land, woodland and residential properties to the north and east; and
• Steeds Lane to the south.
13.2.7 The topography of the site is generally flat, gently sloping down in all directions from the high point at approximately 50mAOD in the north-east of Area 3. The land slopes more steeply to the north and south, creating a gentle ridge.
13.2.8 The topography of the surrounding area is generally flat and at a similar elevation to the site.
13.2.9 Impacts on landscape character are assessed by reference to National Character Area (NCA) Profile: 121 Low Weald as provided on Natural England’s website (www.naturalengland.org.uk); The Landscape Assessment of Kent (Kent County Council, 2004); and the Ashford Local Development Framework Landscape Character Study (Studio Engleback for Ashford Borough Council, 2005).
13.3 Planning Context and Policy Review related to Landscape
National Planning Policy
13.3.1 In March 2012 the government published the National Planning Policy Framework (NPPF), with the intention of consolidating and streamlining the guidance provided in Planning Policy Statements and Planning Policy Guidance. Central to the NPPF is a presumption in favour of sustainable development.
13.3.2 Twelve core principles are identified in the NPPF, which should underpin both plan- making and decision-taking. Of these twelve core principles, the following are most relevant to landscape and visual matters:
• “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings;
• take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
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• contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework;
• promote mixed use developments, and encourage multiple benefits from the use of land in urban and rural areas, recognising that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production). ”
13.3.3 Section 7 of the NPPF, ‘Requiring Good Design’, states:
“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 area development schemes .”
13.3.4 Section 11 of the NPPF relates to ‘Conserving and enhancing the natural environment’. It states at paragraph 109:
“The planning system should contribute to and enhance the natural and local environment by:
• protecting and enhancing valued landscapes, geological conservation interests and soils;
• recognising the wider benefits of ecosystem services;
• minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressure .”
Local Planning Policy
13.3.5 Ashford Borough Council’s Landscape Character Supplementary Planning Document (SPD) (April 2011) states that the following policies are relevant to landscape:
13.3.6 Policy CS9 – Design Quality, within Ashford Borough Council’s Core Strategy, (July 2008):
“Development proposals must be of high quality design and demonstrate a positive response to each of the following design criteria: a) Character, Distinctiveness and Sense of Place
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b) Permeability and Ease of Movement c) Legibility d) Mixed use and Diversity e) Continuity and Enclosure f) Quality of Public Spaces g) Flexibility, Adaptability and Liveability h) Richness in Detail i) Efficient use of Natural Resources”
13.3.7 Policy U23 – Landscape Character and Design, within the Urban Sites and Infrastructure Development Plan Document (DPD) (October 2012):
“Development which is on, or visible from, the edge on the urban area shall be designed in a way which complements and enhances the particular landscape character area within which it is located, and, where relevant, any adjacent landscape character area. Proposals shall have particular regard to the following: a) Landform, topography and natural patterns of drainage; b) The pattern and composition of trees and woodlands; c) The type and composition of wildlife habitats; d) The pattern and composition of field boundaries; e) The pattern and distribution of settlements, roads and footpaths; f) The presence and pattern of historic landscape features; g) The setting, scale, layout, design and detailing of vernacular buildings and other traditional man made features; h) Any relevant guidance given in the Landscape Character SPD. Existing features that are important to the local landscape character shall be retained and incorporated into the proposed development.”
13.3.8 In addition, Policy CS1 – Guiding Principles within the Core Strategy is also of relevance:
“Sustainable development and high quality design are at the centre of the Council’s approach to plan making and deciding planning applications.
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Accordingly, the Council will apply the following key planning objectives: A. Development that respects the environmental limits that protect the high quality built and natural environment of the Borough, minimises flood risk, provides for adequate water supply, and protects water and air quality standards; B. The conservation and enhancement of the historic environment and built heritage of the Borough; C. Protection for the countryside, landscape and villages from adverse impacts of growth and the promotion of strong rural communities; D. New places - buildings and the spaces around them - that are of high quality design, contain a mixture of uses and adaptable building types, respect the site context and create a positive and distinctive character and a strong sense of place and security…”
13.4 Methodology
13.4.1 This landscape and visual assessment (LVIA) has been undertaken based on methodology set out in the Landscape Institute and The Institute of Environmental Management & Assessment Guidelines for Landscape and Visual Impact Assessment Third edition published by Routledge (GLVIA3, 2013). In addition the following sources have been utilised in the preparation of this report:
• Landscape Character Assessment – Guidance for England and Scotland (The Countryside Agency and Scottish Natural Heritage, 2002);
• An Approach to Landscape Character Assessment (Natural England, 2014); • Photography and Photomontage in Landscape and Visual Impact Assessment (Landscape Institute Advice Note 01/11);
• NCA profile 121 Low Weald as provided by Natural England (www.gov.uk/natural-england);
• The Landscape Assessment of Kent (Kent County Council, 2004); and
• Ashford Local Development Framework Landscape Character Study (Studio Engleback for Ashford Borough Council, 2005).
13.4.2 Guidance is provided by GLVIA3 on the area of landscape that needs to be covered in assessing landscape effects i.e. the “Study Area”.
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“Scoping should also identify the area of landscape that needs to be covered in assessing landscape effects. This should be agreed with the competent authority, but it should be recognised that it may change as the work progresses, for example as a result of field work, or changes to the proposal. The study area should include the site itself and the full extent of the wider landscape around which the proposed development may influence in a significant manner. This will usually be based on the extent of Landscape Character Areas likely to be significantly affected either directly or indirectly.” (GLVIA3 para. 5.2 page 70)
13.4.3 Accordingly the LVIA process has utilised a detailed desk survey analysis to identify the potential areas from which the proposed scheme would be visible. This involved an analysis of the ordnance survey map (1:25,000) of the area. This was used to identify potential areas of visibility from roads, properties, public rights of way and open access land (as defined within the Countryside and Rights of Way Act 2000) and also helped to define the area of landscape (referred in this assessment as the Study Area) which may be influenced by the proposed development. In addition the desk study analysed the landscape character area descriptions of relevance to the Study Area of the scheme.
13.4.4 This analysis formed the basis for site visits, which were carried out on the 16 th July 2014 and the 6 th March 2015. A representative series of photographs (generally from public viewpoints) illustrating these views (taken with the equivalent of a 50mm lens), are included as Photoviews 1 – 26 (Appendix 13.1).
13.4.5 Each photoview has been produced to show the context of representative views of the development and have been used as the basis for both the landscape and visual assessments. Each photoview is accompanied by a table and a location plan. The table describes the location of each vantage point; the components of the existing view; the components of the view following construction of the development; and the components of the view ten years following the construction of the development. This has been assessed using the methodology and guidance documents set out below.
13.5 Guidance
Guidelines for Landscape and Visual Assessment (2013) – GLVIA 3
13.5.1 GLVIA 3 states that when undertaking an LVIA, this should consider:
• Landscape effects i.e. the effects on the landscape as a resource; and
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• Visual effects i.e. effects on views and visual amenity.
13.5.2 It also states that; “LVIA must deal with both and should be clear about the difference between them”.
(GLVIA 3 para 2.22 page 21)
13.5.3 The guidelines explain that both landscape and visual effects are dependent upon the sensitivity of the landscape resource or visual receptors and the magnitude of impact.
Landscape Effects Landscape Sensitivity
13.5.4 The sensitivity of the landscape resource is defined by the 2013 guidelines as follows:
“Landscape receptors need to be assessed firstly in terms of their sensitivity, combining judgements of their susceptibility to the type of change or development proposed and the value attached to the landscape...” (GLVIA 3 para 5.39, page 88)
13.5.5 Commenting on Susceptibility to Change GLVIA3 states:
“This means the ability of the landscape receptor (whether it be the overall character or quality/condition of a particular landscape type or area, or an individual element and/or feature, or a particular aesthetic or perceptual aspect) to accommodate the proposed development without undue consequences for the maintenance of the baseline situation and/or the achievement of landscape planning policies and strategies. …Since landscape effects in LVIA are particular to both the specific landscape in question and the specific nature of the proposed development, the assessment of susceptibility must be tailored to the project. It should not be recorded as part of the landscape baseline but should be considered as part of the assessment of effects.” (GLVIA 3 para 5.40 and 5.42, page 88 & 89)
13.5.6 GLVIA 3 comments on the value of the landscape receptor as follows:
• “The value of the Landscape Character Types or Areas that may be affected based on the review of any designations… where there are no designations judgements based on criteria that can be used to establish landscape value;
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• The value of individual contributors to landscape character, especially the key characteristics…” (GLVIA 3 para 5.44, page 89) Magnitude of Landscape Effects
13.5.7 The methodology used for the quantification of the magnitude of landscape effects is based on the:
• Size or scale of the change to the landscape resource,
• The geographical extent of the area influenced (The Study Area); and,
• Its duration and reversibility. Size and Scale
13.5.8 Impacts on existing landscape elements contributing to landscape character are relatively easy to assess, e.g. number of mature trees and length of hedgerow lost as a result of development as compared with extent of replacement planting. However, aesthetic or perceptual aspects of the landscape can be altered by the removal/addition of these landscape elements such that this can affect the key characteristic of landscape character e.g. removal of hedgerows changing a small scale landscape into in open landscape dominated by a large field system.
Geographical Extent (Study Area)
13.5.9 The geographical extent of landscape effects will vary depending on the nature of the proposal. The desk study established that for this scheme the area over which landscape impact could occur relates to the visibility of the scheme which is largely determined by the extent of vegetation surrounding the site, topography and adjacent development.
Duration and Reversibility
13.5.10 Duration is judged in terms of short, medium or long term. For the purposes of this assessment the effects during construction are considered to be short term and effects following construction are considered to be long term.
13.5.11 The following provides examples of the approach taken in this assessment when determining the magnitude of landscape change within the defined study area. These effects may be permanent or reversible (short, medium or long term):
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• High – major alteration to key elements/characteristics of the baseline and/or introduction of uncharacteristic elements to the landscape.
• Medium – alterations to key elements/characteristics of the baseline and/or introduction of elements that may be prominent but not significantly uncharacteristic of the landscape.
• Low – minor alteration to key elements/characteristics of the baseline and/or introduction of elements that may not be uncharacteristic of the landscape.
• Negligible – very minor alteration to key elements/characteristics of the baseline and/or minimal change resulting from introduction of elements that is not uncharacteristic of the landscape. Significance of Landscape Effects
13.5.12 A consideration of the sensitivity of the landscape receptors to the development and the magnitude of the change resulting from the development, determines the significance of effect of the predicted impact.
13.5.13 Within this assessment thresholds of landscape effects are determined from different combinations of sensitivity and magnitude to which different emphasis may apply. However, the following provides examples of the approach taken in this assessment:
• Very substantial effect, where effects are of both high sensitivity and high magnitude;
• Substantial effect, which can be a product of high sensitivity or high magnitude;
• Moderate effect, where effects can result from medium sensitivity and magnitude, or low sensitivity with high magnitude;
• Slight effect, where effects can be product of low sensitivity or low magnitude coupled with low or medium sensitivity/magnitude;
• Negligible effect, where the impact of the development is minimal; and,
• Nil/no effect.
13.5.14 For this assessment impacts that are ‘moderate to substantial’ or greater are considered to be significant.
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Visual Effects
Visual Sensitivity
13.5.15 Visual sensitivity relates to the susceptibility of visual receptors to change and the value attached to views. For the purposes of this assessment the value of views assessed are classified as being of medium value (i.e. they may be of value locally but not of value at national level). As a consequence the main determinant of sensitivity of visual receptors is the susceptibility of these receptors to change. Visual sensitivity is set out below.
13.5.16 For visual impacts the sensitivity of visual receptors are classified as follows:
• High Sensitivity e.g. users of outdoor recreational facilities or attractions including public rights of way, open access land or heritage assets (whose interest or attention is focused on the landscape); communities where the development would result in changes in landscape setting or; occupiers of residential properties (ground floor views).
• Medium Sensitivity e.g. people travelling through or past the affected landscape by car, train or other means of transport; upper storey views from residential properties.
• Low Sensitivity e.g. users of sporting and other recreational facilities (whose interest or attention is not focused on the landscape); people at their places of work. Magnitude of Visual Effect
13.5.17 The quantification of magnitude for visual impacts is classified as being of high, medium or low magnitude according to the following criteria:
• size or scale of the visual change;
• the geographical extent of a visual effect from a viewpoint; and
• its duration and reversibility.
Size and Scale
13.5.18 Size and scale of the visual change relates to:
• The scale of change in the view with respect to the loss of addition of features in the view and changes in its composition including the proportion of the view occupied by the proposed development; and
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• The degree of contrast or integration of any new features or changes in the landscape with the existing or remaining landscape elements and characteristics.
Geographical Extent (Study Area)
13.5.19 Geographical extent will be dependent on:
• The angle of view in relation to the main activity of the receptor;
• The distance of the viewpoint from the proposed development; and,
• The extent of the area over which the changes would be visible.
Duration and Reversibility
13.5.20 Duration is judged in terms of short, medium or long term. For the purposes of this assessment the effects during the construction are considered to be short term and effects following construction are considered to be long term. The development will be permanent.
13.5.21 As an example of how the above contributes to magnitude of visual effect, a low magnitude of visual change may arise from a new feature which is not discordant with the surrounding view and is visible over a small area. By contrast a high magnitude of visual impact may be generated by a contrasting new feature visible over a larger area.
Significance of Visual Effects
13.5.22 The sensitivity of visual receptors to the development and the magnitude of the change resulting from the development, determines the significance of the visual effect of the development.
13.5.23 Within this assessment thresholds of levels of visual effect are determined from different combinations of sensitivity and magnitude to which different emphasis may apply. However, the following provides examples of the approach taken in this assessment:
• Very substantial effect, where impacts are of both high sensitivity and high magnitude;
• Substantial level of effect which can be a product of high sensitivity or high magnitude;
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• Moderate effect where impacts can result from medium sensitivity and magnitude, or low sensitivity with high magnitude;
• Slight effect where impacts can be a product of low sensitivity or low magnitude coupled with low or medium sensitivity/magnitude;
• Negligible effect where the impact of the development is minimal; and,
• Nil/no effect.
13.5.24 For this assessment impacts that are ‘moderate to substantial’ or greater are considered to be significant.
Cumulative Effects
13.5.25 The guidance within chapter 7 of GLVIA 3 has been utilised in this assessment. This chapter paraphrases Scottish guidance, which defines cumulative effects as being:
“The additional changes caused by a proposed development in conjunction with other similar developments or as the combined effect of a set of developments, taken together (SNH, 2012)”
(GLVIA 3 para. 7.3, page 120)
13.5.26 GLVIA 3 comments that the baseline for assessing cumulative landscape and visual effects should include:
“…those schemes considered in the LVIA and in addition potential schemes that are not yet present within the landscape but are at various stages in the development and consenting process:
• schemes with planning consent;
• schemes that are the subject of a valid planning application that has not yet been determined.”
(GLVIA 3 para. 7.13, page 123)
13.5.27 Accordingly such proposed schemes are included in the assessment of cumulative effects. These include the following:
• Chilmington Green;
• Park Farm; and
• Cheesemans Green.
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13.6 Presentation of Results
13.6.1 The results of the landscape assessment are discussed below in Section 13.8 onwards.
13.6.2 The results of the visual assessment analyse the effects on views from public viewpoints in terms of the degree of visual change that would be generated. A series of photographs have been taken from public viewpoints with potential views of the development. These have been used to form the baseline position.
13.6.3 Photoviews 1 – 26 (Appendix 13.1) determine the visual impact of the proposals taking into account factors such as local topography, vegetation and existing development. The location of these Photoviews is illustrated on Drawing 13.1.
13.6.4 A table and a location plan accompany each Photoview. The table describes the location of each vantage point; the components of the existing view; the components of the view following construction of the development; and the components of the view ten years following the construction of the development.
13.7 Baseline Information
Surrounding Landscape Character
13.7.1 The site falls within NCA 121: Low Weald, described on Natural England’s website as follows:
“Key characteristics: • Broad, low lying, gently undulating clay vales with outcrops of limestone or sandstone providing local variation. • A generally pastoral landscape with arable farming associated with lighter soils on higher ground and areas of fruit cultivation in Kent. Land use is predominantly agricultural but with urban influences, particularly around Gatwick, Horley and Crawley. • Field boundaries of hedgerows and shaws (remnant strips of cleared woodland) enclosing small, irregular fields and linking into small and scattered linear settlements along roadsides or centred on greens or commons. Rural lanes and tracks with wide grass verges and ditches. • Small towns and villages are scattered among areas of woodland, permanent grassland and hedgerows on the heavy clay soils where larger 20th-century villages have grown around major transport routes.”
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13.7.2 Within The Landscape Assessment of Kent (2004) and the Ashford Local Development Framework Landscape Character Study (2005) the site falls within the character area Bethersden Farmlands, described as follows:
“Ancient settlement in this landscape is evidenced by the line of the Roman road to Tenterden that crosses near Shirkoak and the vernacular village centres of Bethersden and Kingsnorth. There is also dull 20th century development, however, in association with these villages, for example.
Although around Bethersden and Woodchurch, the typical Wealden pattern of small fields and bushy hedgerows remains, where the land is flatter, from Great Chart, around Stubb’s Cross and across to Kingsnorth, this has broken down with fields enlarged and hedgerows removed to allow mechanisation for arable farming. Where this has occurred a smooth, simple landscape has resulted, often with the garish hues and pungent odour of oilseed rape dominating in summer.
Population pressure is focused on the flatter lands to the north where both agricultural intensification and expansion of Ashford, notably through proposals for Chilmington Green and Park Farm are changing the established rural landscape patterns to one that is both less varied and less tranquil.”
13.7.3 Within the Ashford Local Development Framework Landscape Character Study (2005) the site straddles the boundary between two District Landscape Types (DLT). Land to the west of Ashford Road (Areas 1 and 2) are located within the DLT Kingsnorth Arable; and land to the east of Ashford Road (Areas 3 and 4) are located within DLT Kingsnorth Wooded Pasture.
13.7.4 DLT Kingsnorth Arable is described as follows:
“Characteristic Features
• Open gently undulating mixed farmland of medium sized fields with sheep grazing and arable land
• Remnant hedges and intermittent hedgerow trees
• Open views to the north and west; to the south and east are linear settlements along Magpie Hall Lane and Ashford Road
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• The vegetated lane of Long Length lies to the north-west
Condition
A coherent pattern of medium sized fields primarily used for grazing with some arable with remaining hedgerow trees giving a layered effect and depth to the landscape, however there is some poaching and loss of hedgerows and replacement with stock fencing. The powerlines are a localised detractor.
Sensitivity
The grazed fields accentuate the subtle undulating topography and together with the hedgerow trees, which give a layered effect, the area has an apparent sense of place. There is a 10m level change rising to the area around Ashford Road which is locally prominent.”
13.7.5 DLT Kingsnorth Wooded Pasture is described as follows:
“Characteristic Features
• Open undulating mixed farmland with arable and sheep grazing with a mix of gappy and strong hedgerows with intermittent trees. • Woodlands of neglected hornbeam coppice with oak standards which include Isaac Wood, Park Wood, Stumble Wood, Sticket Wood and Park Lane Wood. • The area between Park Farm and Kingsnorth is designated as a country park with new planting and pond, and is well used by dog walkers. • The oast at Finn farm is locally prominent. • The A2070 bounds the eastern edge and the urban fringe of Ashford is visible to the north.
Condition
The pattern of elements is somewhat variable with a mix of large arable fields to small paddocks, with some loss of hedgerows. The mosaic of coppice woodlands, scrub vegetation and new planting provide a network of semi- natural habitats which would be improved through management. The A2070 bounds the eastern edge.
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Sensitivity
The mix of gently undulating topography, farmed landscape and woodlands gives the area some sense of continuity over time, especially to the east which is smaller in scale, although the sense of place is somewhat eroded by the loss of field boundaries and larger arable fields, and especially to the north around Park Farm. Visibility is intermittent.”
13.7.6 These descriptions provide a clear picture of the landscape character within which the site is located. The landscape is gently undulating and predominantly comprises medium to large arable fields, with some smaller paddocks. Hedgerows have been removed to enlarge fields in order to allow arable farming, which has resulted in a simpler landscape and this has somewhat eroded the sense of place. There is smaller scale landscape to the east at Isaac Wood where there is a mixture of strong and gappy hedgerows. Agricultural intensification and the expansion of Ashford are changing the established rural character and reducing tranquillity. The overhead lines also detract from the rural character of the landscape. There are long distance views to the north, however visibility is intermittent and views are constrained by the surrounding settlements, scattered hedgerow trees, woodland and the undulating topography.
Relevant Designations
13.7.7 The site is located on arable land to the south of Ashford. Isaac Wood, to the north- east of Area 4, is ancient woodland. There are also a number of Listed Buildings located on the roads adjacent to the site, and a Conservation Area in Kingsnorth to the north of the site. There are no further designated areas within the study area.
13.7.8 Ashford Borough Council’s Planning Information Map Viewer 19 was consulted on 15/07/2014 in order to identify the presence of current Tree Preservation Orders (TPOs) within or in close proximity to the site. Two TPOs were identified within close proximity to the site:
• TPO No 16 1984 (Ref. T151/37/01), a region at Isaac Wood, adjacent to the north-eastern boundary of Area 4; and
• TPO No. 4 1991 (Ref. T151/37/04), two points at Mill House on Ashford Road, adjacent to the western boundary of Area 3.
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13.7.9 It is not anticipated that the proposals will have any impact on these TPOs.
Visual Receptors
13.7.10 The distribution of visual receptors influences the extent of the study area for both the landscape and visual effects.
13.7.11 A combination of topography, vegetation and existing development means that views of the site are generally restricted to locations within or adjacent to the site. The Study Area is therefore confined to the site area and the immediate vicinity.
13.7.12 The following receptors which could potentially experience visual impacts were identified within the study area:
• Motorists and road users on Ashford Road, Pound Lane, Magpie Hall Road, Steeds Lane, Bond Lane, Stumble Lane and Church Hill;
• Users of the Public Rights of Way network within the site and in the surrounding area;
• Residents of properties located in Kingsnorth and on the roads listed above; and
• Ashford Town Cricket Club.
13.7.13 No further sensitive receptors have been identified within the study.
13.8 Potential Impacts upon Landscape Character
13.8.1 The main impacts that would affect the landscape character of the site and the surrounding area as a result of the proposals are identified as:
• Change of land use from arable farming and semi-improved grassland to residential development and landscaped green space; and
• Limited local removal of hedgerows.
13.8.2 The nature of landscape effects have been determined by assessing the magnitude of the effect (both physical and perceptual) and the sensitivity of the landscape resource.
13.8.3 The sensitivity of the landscape resource has been determined by analysing the landscape baseline to determine:
• Susceptibility to Change; and, ST13901/001 Page 241 June 2015
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• Landscape Value.
Landscape Character Sensitivity
Landscape Susceptibility to Change
13.8.4 Table 13.1 below provides a summary of those factors affecting susceptibility to change of the Landscape Character Areas within and immediately surrounding the site with visual connectivity to the scheme i.e. the Study Area.
Table 13.1 Landscape Character Susceptibility to Change within Study Area Factors affecting Susceptibility Comment Level of (Landscape Receptors) Susceptibility Topography - Topography (immediate Predominantly flat topography- other Low-Medium area) screening elements provide strong influence on perception. Ridge in centre of site prevents views across entire site.
- Topography Predominantly flat topography- other Low-Medium (surrounding area) screening elements largely restrict long distance views.
Vegetation - Screening vegetation Hedgerows and trees will provide partial Medium screening of the development.
Existing Development - Residential Provides screening of the development Low and has urbanising effect on landscape character.
- Agricultural buildings Provides screening of the development. Low
- Major roads Urbanising influence on character. Low
Overall Landscape Character Susceptibility to Change within the Study Area Low-Medium
Landscape Value
13.8.5 Components which contribute to landscape value within the Study Area are outlined below in Table 13.2.
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Table 13.2 Components contributing to Landscape Value Components Comment Value contributing to Landscape Value (Landscape Receptors) Landscape The site comprises hedgerows and hedgerow Medium Beneficial Quality/Condition trees enclosing arable farmland.
Land to the north of the site is densely Medium Adverse developed.
Remaining land surrounding the site comprises Medium Beneficial hedgerows and hedgerow trees enclosing arable farmland.
Scenic Quality Landscape of the site partially contributes to Medium Beneficial the scenic quality of the wider Study Area.
Urbanised landscape to the north of the site Medium Adverse detracts from the scenic quality of the wider study area. Medium Beneficial Remaining landscape surrounding the site partially contributes to the scenic quality of the wider study area.
Rarity N/A N/A
Representativeness The site and its surroundings are a typical Medium-High example of the landscape character area. Beneficial
Conservation Interests Ancient Woodland partially within the site. No Medium Beneficial further designations within the site.
A number of listed buildings are located on the Medium Beneficial roads adjacent to the site.
A Conservation Area is located to the north of Medium Beneficial the site.
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Table 13.2 Components contributing to Landscape Value Components Comment Value contributing to Landscape Value (Landscape Receptors) Recreation Value A number of public rights of way are located High Beneficial within the site and the study area, including the Greensand Way.
Perceptional Aspects Tranquillity of site affected by urbanisation to Low Adverse the north and transmission towers to the west.
Associations None identified. N/A Overall Landscape Value Low-Medium Beneficial
Sensitivity of the Landscape Resource
13.8.6 From the above analysis it can be seen that the sensitivity of the landscape resource within the defined study area is influenced by the presence of landscape receptors which affect susceptibility to change and landscape value. This assessment concludes that the overall sensitivity of the landscape resource to this type of development is low-medium within the study area.
Magnitude of Landscape Change
13.8.7 The magnitude of landscape change has been determined by analysing:
• The size and scale of the landscape effects;
• Geographical extent of landscape impacts (study area); and,
• Duration and reversibility of effect.
13.8.8 The magnitude of landscape effects within the study area are outlined in Table 13.3 below.
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Table 13.3 Magnitude of Landscape Effects Landscape Size and Scale Geographical Duration Magnitude of Components Extent of and Effect within Landscape Reversibility Study Area Impact Addition of Change of land use Perceived Permanent High Adverse residential from arable farmland within site and development to residential immediate development. setting only. Loss of arable Change of land use Perceived Permanent High Adverse farmland from arable farmland within site and to residential immediate development. setting only. Creation of Change of land use Perceived Permanent Slight Beneficial landscaped green from arable farmland within site and space to landscaped green immediate space. setting only. Loss of hedgerows Limited local removal Perceived Permanent Slight Adverse and trees of hedgerows for within site and roads. immediate setting only. Addition of Additional planting of Perceived Permanent Slight Beneficial hedgerows and trees and hedgerows within site and trees within site. immediate setting only. Medium-High Overall Magnitude of Landscape Effect within Study Area Adverse
Significance of the Landscape Impact of the Scheme
13.8.9 The significance of the landscape impacts of the proposals are set out in Table 13.4 below.
Table 13.4 Significance of Landscape Effects Sensitivity of Landscape Magnitude of Landscape Significance of Landscape Resource within Study Area Change within Study Area Impact within Study Area Low-Medium Medium-High Adverse Moderate-Substantial Adverse
13.8.10 Consequently landscape impacts for these proposals would be moderate-substantial adverse for the study area, which is limited to the site and immediate surrounding area.
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13.9 Potential Visual Impacts
13.9.1 A visual appraisal of the scheme was undertaken on the 16 th July 2014. This identified public highways, footpaths, residential properties and other public amenity areas from which the development would be visible. A second visual appraisal was undertaken on the 6 th March 2015. A series of representative photographs were taken (see Photoviews 1 – 26 in Appendix 13.1), these have been used as the basis of the visual impact assessment.
13.9.2 It should be noted that visual impacts would be very restricted, to the site and immediate surrounding area, due to topography and the vegetation and development surrounding the site.
Visual Impact upon Public Highways
13.9.3 In terms of visual impact, public highways have been assessed as outlined below. It should be noted that all views from public highways will be transient and will be of medium sensitivity.
13.9.4 The scheme will generate visual impacts for sections of:
• Ashford Road;
• Magpie Hall Road;
• Steeds Lane;
• Bond Lane;
• Pound Lane; and
• Church Hill
13.9.5 Ashford Road is located within the area of development, adjacent to Areas 1 and 2 to the east and Area 3 to the west. Visual impacts on the southern section of the road where it is immediately adjacent to the site boundary would be substantial adverse during and following construction as open views of the development would be available (see Photoviews 2 and 3). However these impacts would reduce to moderate adverse ten years after construction, as mitigation planting would have matured sufficiently to partially screen the development. Visual impacts on the northern section of the road where it is immediately adjacent to the site boundary would be
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moderate to substantial adverse during and following construction as although some open views of the development would be available, others would be partially screened by intervening vegetation and changes in topography (see Photoviews 16, 17 and 19). Visual impacts on the northern section of the road would reduce to slight to slight- moderate adverse ten years after construction. Views from the remainder of the road are generally screened by intervening vegetation and development.
13.9.6 Magpie Hall Road is located adjacent to the southern boundary of Area 2. The view from the western section of the road will predominantly be of the area being retained for ecological mitigation. Therefore visual impacts on this section of the road would be slight adverse during and following construction as any views of the development would be in the far distance and partially screened by intervening vegetation (see Photoview 1). These impacts would reduce to negligible adverse ten years after construction, as mitigation planting would have matured sufficiently to screen the majority of views of the development. However from the eastern section of the road, close proximity and open views of the development would be available. Visual impacts on this section of the road would therefore be substantial adverse during and following construction, reducing to moderate adverse once mitigation planting has matured sufficiently to partially screen the development.
13.9.7 Steeds Lane is located adjacent to the southern boundary of Area 4. Visual impacts on the section of the road immediately adjacent to the site would be substantial adverse during and following construction due to open views of the development being available, partially screened by existing and proposed vegetation on the site boundary (see Photoview 6). However these impacts would reduce to slight-moderate adverse ten years after construction, as mitigation planting would have matured sufficiently to partially screen the development. Visual impacts on the remainder of the road to the east, south of Area 3, would be nil due to views being screened by intervening built development, vegetation and the cricket club, however more open views would be available at the junction with Bond Lane. Visual impacts on the junction would be slight adverse during and following construction as there would be oblique views of the development, partially screened by intervening vegetation and built development. Ten years after construction impacts on the junction would decrease to negligible- slight adverse , due to increased screening by mitigation planting.
13.9.8 Bond Lane is located partially within the area of development, adjacent to Area 3 to the north-west and Area 4 to the south-east. Visual impacts on sections of the road
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which are immediately adjacent to the site boundary would be substantial adverse during and following construction as open views of the development would be available (see Photoview 4). However these impacts would reduce to moderate adverse ten years after construction, as mitigation planting would have matured sufficiently to partially screen the development. Visual impacts on the remainder of the road where views of the site are available would be negligible to moderate adverse during and following construction due to screening by intervening vegetation and built development, and negligible to slight adverse ten years after construction (see Photoviews 5 and 10). These impacts would decrease to nil to the north of the road as the distance from the site increases.
13.9.9 Pound Lane extends west from Kingsnorth and is located adjacent to the northern boundary of Area 1. The majority of views of the site from this road are screened by existing built development, strong hedgerows on the site boundary and hedgerow trees to the west. The most open views would be available from the existing field entrance (see Photoview 20). During and following construction visual impacts on the section of this road adjacent to the site would be moderate adverse , increasing to substantial adverse at the existing field entrance. These impacts would reduce to slight adverse ten years after construction, as mitigation planting would have matured sufficiently to partially screen the development, and to nil to the west of the road as the distance from the site increases.
13.9.10 Church Hill is located within Kingsnorth, approximately 100m north of the site at the closest point. The majority of views from this road are screened by intervening vegetation and built development. The only section of the road which will experience views of the site is at the junction with Ashford Road (similar to Photoview 19). Visual impacts on this short section of the road would be moderate adverse during construction and slight-moderate adverse following construction due to views being oblique and partially screened. Ten years after construction these impacts would reduce to slight adverse , due to increased screening by mitigation planting.
13.9.11 Views from remaining roads in the area would generally be screened by existing development, topography and vegetation and impacts would not exceed nil- negligible adverse (see Photoviews 23 and 24).
13.9.12 All impacts identified above would continue to reduce over time as the mitigation planting matures, thereby increasing screening of the development.
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Visual Impact upon Public Rights of Way
13.9.13 There are a number of designated public rights of way within the vicinity of the site. Receptors using public rights of way would be of high sensitivity.
13.9.14 The scheme will generate visual impacts for sections of:
• Footpath AW319;
• Footpath AW320;
• Footpath AW318;
• Footpath AW315;
• Footpath AW317; and
• The Greensand Way (Footpaths AW315; AW316; AW319; and AW298). 13.9.15 AW319 is located within the site, extending from the south-west corner of Area 3 on Ashford Road, up to the northern boundary of Area 3 and continuing northwards as the Greensand Way (assessed below). Visual impacts on this footpath would be very substantial adverse during construction due to open views of the development being available (see Photoviews 13 and 14). Visual impacts would remain substantial to very substantial adverse following construction for the majority of the footpath, reducing to substantial adverse ten years after construction due to increased screening by mitigation planting. However, following construction there will be moderate beneficial impacts on the northern end of the footpath where views will be of green space. Ten years after construction these impacts will increase to moderate to substantial beneficial as the planting within the green space matures over time.
13.9.16 AW320 and AW318 are both located within Area 3. AW320 extends from Ashford Road in a south-eastern direction towards Bond Lane. AW318 is located in an approximately north-south orientation between AW319 and AW320. Visual impacts on these footpaths would be very substantial adverse during construction due to open views of the development being available, and substantial to very substantial adverse following construction due to open views of both housing and green space being available (see Photoviews 4 and 15). Ten years after construction these impacts would reduce to moderate to substantial adverse , due to increased screening by mitigation planting.
13.9.17 AW315 is located within Area 4, extending from the field to the south of Steeds Lane northwards through the site to Bond Lane. It then continues within Area 3 as the ST13901/001 Page 249 June 2015
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Greensand Way (assessed below). Visual impacts on the section of this footpath within the site would be very substantial adverse during construction due to open views of the development being available (see Photoview 9). Following construction impacts would be substantial to very substantial adverse where open views of housing are available. Ten years after construction these impacts would reduce to moderate to substantial-very substantial adverse , due to increased screening by mitigation planting. However where open views of green space are available following construction, there would be a moderate beneficial impact, increasing to substantial beneficial ten years after construction as the planting matures. Visual impacts on the section of the footpath to the south of Steeds Lane would be moderate-substantial adverse during and following construction, due to views being partially screened by vegetation on Steeds Lane. Impacts on this section of the footpath would decrease to moderate adverse ten years after construction due to the development generally being screened by mitigation planting (see Photoview 22).
13.9.18 AW317 extends southwards from Bond Lane, parallel to the site boundary through Isaac Wood, and adjoins the Greensand Way on the north-eastern boundary of Area 4. Visual impacts on the majority of this footpath would be slight to moderate adverse during construction due to screening by intervening vegetation and changes in topography (see Photoview 10). These impacts would decrease to negligible adverse following construction as the majority of views would either be screened by mitigation planting, or be of green space. Ten years after construction impacts on sections of the footpath from which views of green space are available would be slight beneficial . The most open views would be available from the where the footpath adjoins the Greensand Way on the site boundary (see Photoview 7). Visual impacts on this short section of the footpath would be very substantial adverse , decreasing to substantial adverse ten years after construction due to the development being partially screened by mitigation planting.
13.9.19 The Greensand Way is a long distance footpath located within Areas 4 and 3, and adjacent to the northern boundary of Area 1. It extends from the eastern boundary of Area 4 towards Bond Lane as footpath AW316, and then continues north through Area 3 as footpath AW15. Visual impacts on these sections of the footpath would be very substantial adverse during construction as there would be open views of the development (see Photoviews 7, 8, 9, 11, 12 and 13). Following construction these impacts would decrease to substantial to very substantial adverse for sections of the footpath with open views of housing. Some sections of the footpath within the site
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will experience slight to moderate beneficial impacts following construction, where views are wholly of green space. The footpath then continues north of Area 3 towards Church Hill as footpath AW319. Visual Impacts on this section would be substantial adverse during construction as views would be partially screened by intervening vegetation, decreasing to negligible to slight beneficial following construction as the majority of the view would be of green space (see Photoview 18). The footpath then continues westwards on Church Hill. There would be no impacts on this section as views would be screened by intervening built development and topography. Views of the site would become available again where Church Hill adjoins Ashford Road (similar to Photoview 19). Visual impacts on this short section of the footpath would be substantial adverse during and following construction as oblique, partially screened views of the development would be available. It then continues on Pound Lane, where visual impacts would be substantial to very substantial adverse during and following construction due to open views being available at the field entrance, with the remainder of views from this road partially screened by the hedgerow on the site boundary (see Photoview 20). The footpath then continues eastwards away from Pound Lane across agricultural land. Glimpses of the development would be available from this section of the footpath (see Photoview 21). Visual impacts would be negligible adverse during and following construction due to views being distant and generally screened by intervening vegetation. All impacts identified above would reduce over time as the mitigation planting matures, thereby increasing screening of the development.
13.9.20 Overall visual impacts on Greensand Way would be moderate-substantial to very substantial adverse during and following construction for sections of the footpath within the site. However following construction some sections have views which would be predominantly or wholly of green space. Visual impacts on these sections would be negligible to moderate beneficial . All impacts identified above would continue to reduce over time as the mitigation planting matures, thereby increasing screening of the development. Ten years after construction impacts on the majority of the Greensand Way would reduce to moderate to substantial adverse , and impacts on sections of the footpath with views of green space would reduce to negligible to moderate beneficial .
13.9.21 Views from remaining public rights of way in the area would generally be screened by existing development, topography and vegetation. There is a network of footpaths within Kent Downs Area of Outstanding Natural Beauty (AONB), approximately 9.5km
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north-east of the site, from which distant views of Ashford and the surrounding area are available. Impacts on these footpaths would not exceed nil-negligible adverse as views would be distant and the development would be screened by intervening vegetation and built development (see Photoviews 25 and 26).
13.9.22 Impacts identified above would continue to reduce over time as the mitigation planting matures, thereby increasing screening of the development.
Visual Impact upon Residential Properties
13.9.23 Views of the development would be available from the following properties:
• Properties on Ashford Road and Myrtle Court;
• Properties on Magpie Hall Road;
• Properties on Steeds Close;
• Properties on Bond Lane;
• Properties on Stumble Lane;
• Mumford House;
• Properties in the south of Kingsnorth; and
• Properties on Pound Lane.
13.9.24 There are a number of properties located along the length of Ashford Road, and on Myrtle Court. Impacts would be highest on the individual properties adjacent to the site boundary, such as 1 & 2 Ashford Road; Jasmine; Indrashiri; High View and properties on the southern side of Myrtle Court (see Photoviews 3, 16 and 19). Visual impacts on these properties would be very substantial adverse as views would be available from both ground and upper floor windows. Visual impacts on remaining properties which overlook the site and also have views from both ground and upper floor windows would be very substantial adverse . However ten years after construction impacts on these properties would reduce to substantial adverse , as mitigation planting would screen views from ground floor windows. The row of houses to the east of Ashford Road, although adjacent to the site boundary, would have the majority of views screened by intervening vegetation (as illustrated in the far distance
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of Photoview 4). Visual impacts on remaining properties on Ashford Road would be slight adverse due to views being oblique and partially screened by vegetation and changes in topography, and generally limited to upper floor windows.
13.9.25 Properties on Magpie Hall Road are adjacent to the site boundary and overlook the development. Visual impacts on these properties would be very substantial adverse as views would be available from both ground and upper floor windows. However ten years after construction impacts on these properties would reduce to substantial adverse , as mitigation planting would screen views from ground floor windows.
13.9.26 Properties to the north of Steeds Close, adjacent to the site boundary, would experience partial views of the development. Visual impacts on these properties would be slight adverse as views would only be available from upper floor windows and would be partially screened by intervening vegetation.
13.9.27 Properties on Bond Lane would experience views of the site, particularly Taylor Farm (Grade II listed building) and Bond Farm, as illustrated by Photoviews 8 and 12. Visual impacts on these properties would be very substantial adverse as views would be available from both ground and upper floor windows. However ten years after construction impacts on these properties would reduce to substantial adverse , as mitigation planting would screen views from ground floor windows.
13.9.28 Properties to the west of Stumble Lane may experience glimpses of the development through boundary vegetation. Visual impacts on these properties would be slight adverse as views would generally be screened by intervening vegetation.
13.9.29 Mumford House is a Grade II Listed Building located on Church Hill to the north of the site (visible in the far distance of Photoview 11). Views of the development would be available from ground and upper floor windows, partially screened by intervening vegetation. Visual impacts would therefore be substantial adverse during construction. However these would decrease to negligible-slight adverse following construction as the majority of the view would be of green space. Ten years after construction impacts would reduce to negligible adverse , as the majority of the view would be of green space and views of the development would be partially screened by mitigation planting.
13.9.30 Properties located south of Church Hill in Kingsnorth may experience views of the development from upper floor windows. However the majority of views would be
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screened by the dense boundary vegetation on the northern site boundary. Visual impacts on these properties would therefore be negligible-slight adverse .
13.9.31 The majority of properties on Pound Lane, adjacent to the site boundary, would experience views from both ground floor and upper floor windows, partially screened by vegetation on the site boundary. Visual impacts on these properties would be therefore be substantial to very substantial adverse. However ten years after construction impacts on these properties would reduce to moderate to substantial adverse , as mitigation planting would screen views from ground floor windows.
13.9.32 All impacts identified above would continue to reduce over time as the mitigation planting matures, thereby increasing screening of the development. Views from remaining properties in the area would be screened by existing development, topography and vegetation.
Visual Impact upon Recreational Facilities
13.9.33 The Queens Head is a Grade II Listed Building and pub located approximately 50m north of the site at the closest point. The majority of views would be screened by intervening built development, vegetation and changes in topography. However there may be some oblique views of the development from the rear of the pub, where the car park and beer garden is located, partially screened by intervening built development and vegetation. Visual impacts on this area of the pub would be moderate adverse , decreasing to slight adverse once mitigation planting has matured.
13.9.34 Ashford Town Cricket Club is located adjacent to the southern boundary of Area 3. Views of the development would generally be screened by vegetation on the site boundary and visual impacts would be slight adverse , decreasing to negligible-slight adverse ten years after construction as mitigation planting will screen the majority of views.
13.10 Cumulative Impacts
13.10.1 The following schemes were considered within the assessment of cumulative impacts:
• Chilmington Green;
• Park Farm; and
• Cheesemans Green.
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13.10.2 There is no inter-visibility between the site and Park Farm or Cheesemans Green. Therefore there is not expected to be any cumulative landscape or visual impacts in combination with these schemes.
13.10.3 There are open views eastwards from the Chilmington Green site, however the Kingsnorth Green site is screened by intervening topography and vegetation, and impacts would not exceed nil-negligible adverse (see Photoviews 23 and 24). Therefore there is not expected to be any cumulative landscape or visual impacts resulting from the development of Kingsnorth Green in combination with Chilmington Green.
13.11 Mitigation and Residual Impacts
13.11.1 As this EIA has been undertaken as an iterative process, the scheme has already been designed to ensure mitigation is implemented in the form of landscaped green space and additional planting within and on the edge of the development. These measures have been taken into consideration in the above assessment.
13.11.2 Advance planting will be undertaken, allowing the vegetation in later phases to mature sufficiently to reduce visual impacts during and following construction. However as it is not possible at this stage of planning to identify which receptors will be located within the later stages, within this assessment it is assumed that the planting will not have matured sufficiently to screen development during or immediately following the construction phase. Therefore the assessment has considered visual impacts during construction, following construction and ten years after construction. However it should be noted that for receptors in later phases impacts will be lower than those identified above due to advance planting.
13.11.3 Therefore the level of impacts identified for the development once planting has matured are the residual impacts. However all impacts would continue to reduce over time as mitigation planting would continue to mature, thereby increasing screening.
13.12 Conclusions
Landscape Character
13.12.1 The main impacts that would affect the landscape character of the site and the immediate surrounding area as a result of the proposals are identified as:
• Change of land use from arable farming and semi-improved grassland to residential development and landscaped green space; and
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• Limited local removal of hedgerows.
13.12.2 The landscape was assessed as being of low-medium sensitivity, based on a low- medium susceptibility to change and a low-medium beneficial value. The magnitude of change to the landscape resulting from the proposals was assessed as being medium-high adverse.
13.12.3 Landscape impacts on the site and immediate surrounding area would therefore be of moderate-substantial adverse significance.
Visual Impacts
13.12.4 During and following construction the majority of visual impacts on users of roads adjacent to the site boundary would be moderate to substantial adverse , and negligible to moderate adverse for users of roads in close proximity to the site. These would reduce to slight to moderate adverse and negligible to slight adverse respectively ten years after construction due to increased screening by mitigation planting. Where the road overlooks areas of ecological mitigation, visual impacts would reduce to slight adverse following construction and negligible adverse ten years after construction.
13.12.5 Visual impacts on footpath users would be moderate-substantial to very substantial adverse during and following construction for footpaths within and adjacent to the site; negligible to moderate-substantial adverse for footpaths in close proximity to the site; and nil-negligible adverse for footpaths with distant views of the site. Ten years after construction visual impacts would reduce to moderate to substantial-very substantial adverse for footpaths within and adjacent to the site; negligible to moderate adverse for footpaths in close proximity to the site; and nil-negligible adverse for footpaths with distant views of the site due to increased screening by mitigation planting. Following construction some sections of footpaths have views which are predominantly or wholly of green space. Visual impacts on these sections would be negligible to substantial beneficial .
13.12.6 Visual impacts on properties which overlook the site and have views from both ground and upper floor windows would be substantial to very substantial adverse during construction. These impacts would remain the same following construction for the majority of properties, however for properties which overlook green space impacts would reduce to negligible-slight adverse . Ten years after construction impacts on the properties which overlook the development would reduce to moderate to substantial
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adverse , due to mitigation planting screening views from ground floor windows. Impacts on remaining properties with views of the site would be negligible to slight adverse during and following construction.
13.12.7 Visual impacts on visitors to the beer garden of the Queens Head pub in Kingsnorth would be moderate adverse , and visual impacts on users of Ashford Town Cricket Club would be slight adverse . Ten years after construction these impacts would reduce to slight adverse and negligible-slight adverse respectively, due to increased screening provided by mitigation planting.
Residual Impacts
13.12.8 See Table 13.5 below for a summary of the residual impacts.
Table 13.5 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of mitigation) residual effect (10 years following completion) During and following construction Potential impacts on landscape Moderate- Landscaped green space and Moderate- character of the site and substantial additional planting within and on substantial immediate surrounding area. adverse . the edge of the development adverse . would be provide an increased Potential visual impacts on users Moderate to Slight to moderate level of screening and improve substantial adverse where of roads adjacent to the site views and landscape character. boundary. adverse where roads overlook roads overlook development. development. Negligible adverse Slight adverse where roads where roads overlook areas of overlook areas of ecological ecological mitigation. mitigation. Potential visual impacts on users Negligible to Negligible to slight of roads in close proximity to the moderate adverse. adverse. site.
Potential visual impacts on users Moderate- Moderate to of public footpaths within and substantial to very substantial-very adjacent to the site. substantial substantial adverse where adverse where footpaths overlook footpaths overlook development. development. Negligible to Negligible to moderate substantial beneficial where beneficial where footpaths overlook footpaths overlook green space. green space.
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Potential visual impacts on users Negligible to Negligible to of public footpaths in close moderate- moderate adverse. proximity to the site. substantial adverse. Potential visual impacts on users Nil-negligible Nil-negligible of public footpaths with distant adverse. adverse. views of the site.
Potential visual impacts on Substantial to very Moderate to residents of properties. substantial substantial adverse for adverse for properties properties overlooking overlooking development. development. Negligible-slight Negligible-slight to adverse for slight adverse for properties properties overlooking green overlooking green space. space. Potential visual impacts on users Slight to moderate Negligible-slight to of recreational facilities. adverse. slight adverse .
Summary
13.12.9 Due to the size of the site, there are a large number of receptors within it, or adjacent to it, which will experience adverse impacts as result of the development. However, all significant adverse impacts are limited to receptors within or adjacent to the site. In addition, mitigation in the form of landscaped green space and additional planting will create beneficial impacts. This assessment has used a worst case scenario of mitigation planting not maturing sufficiently to screen development during or immediately following construction. However it should be noted that impacts will be lower than those identified above for receptors located within later phases of the development, as advance planting would be undertaken.
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14 ARCHAEOLOGY AND CULTURAL HERITAGE
14.1 Introduction
14.1.1 This section of the Environmental Statement (ES) sets out the archaeological and historic background of the area and provides an evaluation of the significance of the heritage assets within the site boundary. Potential impacts through development to identified heritage assets are established, their significance assessed and appropriate mitigation measures for reducing these potential impacts are proposed where relevant. Setting impacts to heritage designations within the vicinity of the site are also assessed.
14.1.2 In order to inform this assessment baseline data was obtained from the following:
• Kent Historic Environment Record (HER) consulted April 2014; • Kent History and Library Centre; • In house datasets of designations (English Heritage/Historic England 2015): • Scheduled Monuments • Listed Buildings • Registered Parks and Gardens • Registered Battlefields • The National Heritage List for England (English Heritage website).
14.1.3 In addition, a walkover survey of the site was undertaken in July 2014.
Definitions of Terms
14.1.4 For the purposes of this section, the term ‘site’ is used to refer to the application area. The term ‘search area’ relates to the wider area defined for the purposes of baseline information collection. This has been set at 1-1.5km from the boundary of the site.
National and local planning policy and guidance
14.1.5 Statutory designations comprise scheduled monuments, protected wrecks, listed buildings and conservation areas. In addition to the national and local planning policy, presented below, the Ancient Monuments and Archaeological Areas Act (1979) provides protection for scheduled monuments. Likewise, applications affecting listed buildings and conservation areas are considered in respect to the Town and Country Planning (Listed Building and Conservation Areas) Act (1990).
14.1.6 Non-statutory designations, comprising registered parks and gardens and registered battlefields, are assessed under national and local planning policy only. This is also the
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case for the remainder of the archaeological resource. These are non- statutory designations and comprise entries onto a Historic Environment or Sites and Monument Record as well as previously unknown features which may be recorded as part of a desk based assessment or environmental impact assessment.
National Policy
14.1.7 The National Planning Policy Framework (NPPF) defines the role of the planning system as to promote and achieve sustainable development and involves ‘seeking positive improvements in the quality of the built, natural and historic environment’ (Department for Communities and Local Government 2012 paragraph 9).
14.1.8 Under the NPPF Plan making and decision taking is informed by 12 core planning principles including the requirement for the planning system to conserve heritage assets in a manner appropriate to their significance, so they can be enjoyed for their contribution to the quality of life for this and future generations (Department for Communities and Local Government 2012 paragraph 17).
14.1.9 Where heritage assets are to be affected by development, local authorities should require the applicant to describe the significance of the assets affected (including the contribution made to the significance of the asset by its setting); the level of detail being proportionate to the asset’s importance and which may include a field evaluation.
14.1.10 In determining applications, the NPPF stipulates that ‘great weight’ should be given to the asset’s conservation and that substantial harm to or loss of a Grade II listed Building should be exceptional, whilst substantial harm to or loss of assets of highest significance most notably Scheduled Monuments; protected wrecks; battlefields and Grade I and II* Parks and Gardens should be wholly exceptional, (Department for Communities and Local Government 2012 paragraph 132).
14.1.11 Developments where substantial harm to or total loss of significance of a heritage asset is likely should be assessed against specific tests and should deliver substantial public benefits which outweigh any loss or harm, (Department for Communities and Local Government 2012 paragraph 133). Less than substantial harm to a designated asset require public benefits including the securement of an optimum viable use, (Department for Communities and Local Government 2012 paragraph 134). Impacts to the significance of non-designated assets will require a balanced judgement based on the level of significance and the scale of harm (Department for Communities and
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Local Government 2012 paragraph 135), although non-designated assets which are of equivalent significance to designated assets will be considered as such, (Department for Communities and Local Government 2012 paragraph 139).
14.1.12 The NPPF also requires developers to ‘record and advance understanding of the significance of any heritage assets to be lost’ through archaeological excavations and reporting (Department for Communities and Local Government 2012 paragraph 141).
Local Policy
14.1.13 Relevant saved policy from the Ashford Borough Local Plan comprises the following policy which is quoted in full:
“Policy EN23: Sites of Archaeological Importance
In exceptional circumstances, permission may be given for development affecting important archaeological sites of regional or local importance, if the applicant has demonstrated that the site will be satisfactorily preserved either in situ or by record. Any archaeological recording should be by an approved archaeological body and take place in advance of development in accordance with a specification and programme of work to be submitted to and approved by the Borough Council.”
14.2 Baseline information
Geology and Topography of site
14.2.1 Solid geology within the 60.98ha site comprises Weald Clay formation. No superficial geology is recorded across the vast majority of the site; the exception is the north- western most 1.4ha of the site where superficial geology comprises sand and gravel (British Geological Survey 2014). This part of the site is located in immediate proximity to the Whitewater Dyke (a tributary of the East Stour located 2km to the north). A tributary stream of the Whitewater Dyke crosses the south-western part of the site.
14.2.2 A low ridge, roughly following the 50m AOD contour, crosses the site on a north-west to south-east alignment. The highest point within the site, 53.6m AOD, is located on this ridge. The southern two thirds of the site are located on gradual south facing slopes down to a height of 40-43m AOD. The northern third of the site is located on gradual north-facing slopes down to a height of 40-44m AOD.
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Archaeological Background
14.2.3 The Kent Historic Environment Record was consulted for entries within the search area (taken as an area of approximately 1km radius from the site boundary). Besides identifying heritage assets that may be directly or indirectly affected by the proposed development this search boundary was expected to provide sufficient data to represent the archaeological character of the area. Information on designated heritage assets was downloaded from Historic England (Historic England 2015).
14.2.4 From these consultations it was established that there are 164 heritage assets recorded within the search area, as detailed in Appendix 14.1.
Previous Archaeological Work Westhawk Farm
14.2.5 Westhawk Farm is located 160m north-east of the site on an area of alluvial deposits including sand and gravel on the 40m AOD contour. It is located immediately adjacent to the Roman road between Benendon and Canterbury which extends 300m west of the site. The area was subject to geophysical survey and trial trenching in 1997. This demonstrated a high density of archaeological remains dated to the Roman period (Kent Archaeological Unit 1997) and part of the area was subsequently scheduled (reference 1017645).
Missenden
14.2.6 Located 700m north of the site on Weald Clay (in close vicinity to alluvial deposits of sand and gravel), Missenden was located to the immediate north of Westhawk Farm. Consequently, Missenden was subject to geophysical survey and trial trenching at the pre-determination stage and excavation as a condition to planning consent. Whilst the geophysical survey was inconclusive (due to interference from modern features), the trial trenching and excavation recorded evidence for the remains of a Bronze Age field system and settlement activity dating to the early Roman period (Pre Construct Archaeology 2006 and Archaeo2009). Specifically, the trial trenching recorded evidence for waste pits on low lying land liable to flooding. After the apparent dumping of made ground to increase ground levels to 38.8-38.9m AOD, the trial trenching recorded evidence for settlement which comprised a flint raft and a number of postholes. The later excavation, whilst finding no structures, recorded ill-defined wattle imprints and a probable hearth which attested to first century settlement activity (Archaeology South East 2009).
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Chartfields (Brisley Farm)
14.2.7 Archaeological fieldwork of the Brisley Farm Area, 770m-1.3km north-west of the site, was undertaken from 1999 onwards by Archaeology South East as a condition to planning consent. This comprised trial trenching at the 2% level and five subsequent excavations. Whilst flint indicating activity from the Late Neolithic to Bronze Age periods was recovered, no associated features were recorded within 1km of the site; just beyond the 1km search area a possible Late Bronze Age field system was recorded. This was overlain by early and middle Iron Age field systems and evidence for Middle to Late Iron Age settlement on the 40m contour. Late Iron Age/early Romano British funerary activity was also recorded including two rare warrior burials. This was all set within a wider agricultural landscape including enclosures and droveways.
14.2.8 In closer vicinity to the site, 930m north-west, the fieldwork recorded evidence for a separate Romano-British agricultural settlement dated to AD120-200. This most likely represented settlement associated with a pastoral regime as a consequence of the poor drainage qualities of the Weald Clay and may have acted as a transitional site between the earlier Iron Age site (located further to the west - now abandoned) and the Roman settlement located at Westhawk Farm.
14.2.9 The fieldwork also recorded a late Iron Age/early Romano British cremation cemetery 900m north-west of the site. Evidence for a medieval farmstead was also recorded 800m-1km north-west of the site (Archaeology South East 1999a, 1999b, 2003 and 2004).
Millbank Reception Centre
14.2.10 The excavation of seven trial trenches was undertaken at the predetermination stage 780m north of the site. At a height of 42-44m AOD, geology comprised Weald Clay in the immediate vicinity of alluvial deposits of sand and gravel. The trenching recorded a ditch, gully and pit in one trench. These were all dated to the Late Iron Age/Early Roman period and potentially represent settlement activity due to the presence of daub. A second trench recorded six undated possible graves which may represent an outlying Roman cemetery to the east of Westhawk Farm (Canterbury Archaeological Trust 2003).
Ashford Southern Ring Main Water Pipeline
14.2.11 The 2km long water pipeline which is aligned through an extensive area of Weald Clay, is, at its closest point, located 100m south of the site boundary. A geophysical survey
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recorded evidence for buried remains of a known Roman road 890m west of the site (HER reference MKE44618). In closer vicinity to the site the survey recorded possible field boundaries of an ‘ancient field system’ and zig-zag elements of a possible Second World War defence trench. These were recorded in fields located c.100m south of the site.
14.2.12 Where the route crossed the course of a roman road archaeological excavation of its line established a Mid to Late Iron Age date for the road, recorded as a holloway (HER reference TQ 93 NE 76) most likely providing access to the nearby Iron Age settlement at Brisley Farm.
14.2.13 The remainder of the route was subject to a strip, map and sample exercise. Results indicate that clearance (deforestation) may have started earlier than the Bronze Age; Lower Palaeolithic flints were recorded 770m west of the site (HER reference TQ 93 NE 75) and in closer vicinity, c.100m south, a small well preserved assemblage of scrapers and blades dated to the Late Mesolithic/Early Neolithic and the Mid/Late Neolithic and early Bronze Age were recorded (no HER reference).
14.2.14 The earliest occupation evidence comprised Bronze Age pottery within two ditches 300m south-west of the site (HER reference TQ 93 NE 80). Mid to Late Iron Age potsherds within four ditches were recorded 810m west of the site (HER reference TQ 93 NE 84). Five fire pits were also recorded, one of which, located 315m south-west, contained twenty potsherds from a single vessel dated c.50BC -70AD (HER reference TQ 93 NE 81).
14.2.15 In general the fieldwork indicated an area which was liable to flooding but divided into plots and used probably for animal husbandry from the Bronze Age through to the Iron Age. In reflection of this, settlement activity appears to have been transient and short term and more often than not associated with agricultural activity.
Park Farm East
14.2.16 Located 930m-c.1.3km east of the site, Park Farm East was initially subject to trial trenching at c.2% (Pre-Construct Archaeology 2003). In general the trial trenching recorded the presence of a field system potentially dating to the Bronze Age to early Iron Age periods, although little dating evidence for the field system was available.
14.2.17 In respect of probable settlement activity, the earliest evidence comprised two areas of dated Late Bronze Age - Early Iron Age activity. These comprised an isolated pit located at 41.3m AOD c.1km east of the site and another isolated pit at 37.7m AOD
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c.1.2km east of the site. Both pits contained Late Bronze Age/Early Iron Age pottery. A posthole of Mid to Late Iron Age date was found within the same trench as the latter pit and activity into the Late Iron Age was evident on a slightly raised area within the valley floor, above 37m AOD (Pre Construct Archaeology 2003). Geology in this area is alluvium (sand, gravel and silt) over Weald Clay. This was targeted by later excavation which recorded eight Iron Age round houses (Area 3) (Wessex Archaeology 2004).
14.2.18 The trial trenching also recorded further Late Iron Age activity within an area of Weald Clay in close vicinity to sand and gravel deposits on the side and crest of a hill at 42.1m AOD c.1-1.1km east of the site. This area was also targeted by excavation (Area 1 and 2) (Wessex Archaeology 2004). The excavation recorded Iron Age round houses most likely of Late Iron Age date. Some late Bronze Age re-deposited pottery was recorded within one of the round house gullies. The round houses were incorporated into rectilinear enclosure systems predominantly of Late Iron Age date. An iron smelting furnace was also recorded. The alignment of later enclosure ditches perpendicular to the nearby Roman Road between Lympne and Maidstone (400-500m north-east) and the presence of Romanised pottery fragments within the earlier enclosure ditch fills suggests a settlement which spanned the Late Iron Age/early Roman date periods (Wessex Archaeology 2004).
Chilmington Green
14.2.19 Archaeological fieldwork of the 420ha Chilmington Green Area, located 930m-3.1km west of the site, has comprised geophysical survey, fieldwalking and limited trial trenching. The geological conditions at Chilmington Green, are similar to those at Kingsnorth i.e. Weald Clay.
14.2.20 Trial trenching was undertaken in 2004 in the section of Chilmington Green which borders Brisley Farm (discussed above). This recorded a southerly extension of the previously recorded Iron Age settlement into the Chilmington Green Site, c.1.1km north-west of the site. This extension included a number of roundhouses (Archaeology South East 2004).
14.2.21 The fieldwalking which was undertaken in 2010 across 374ha did not retrieve a large amount of material and was notably lacking in the area where the 2004 trial trenching took place. However, the features recorded during the trial trenching were recorded as being sealed beneath a subsoil present below the plough soil. These would not therefore, have been disturbed by the plough (Archaeology South East 2004). Apart from a concentration 2.5km north-west of the site, little was found in the way of
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Roman pottery, despite the presence of a Roman Road. This may indicate a lack of significant roadside activity away from the known settlement at Westhawk Farm. Concentrations of medieval pottery and CBM were noted within fields in the vicinity of Chilmington Green village, a known medieval focus located c.2.1km north-west of the site (Wessex Archaeology 2010).
14.2.22 The geophysical survey initially comprised gradiometer scanning which was undertaken across the whole Chilmington Green area in 2010 (Wessex Archaeology 2010). This appeared to be successful in recording anomalies of possible archaeological origin and was followed by detailed gradiometer of selected areas in 2011 (Wessex Archaeology 2011). Trial trenching of geophysical anomalies was not undertaken prior to the submission of the application which was registered and validated on the above information.
14.2.23 In order to provide further information, post submission (prior to determination), further detailed survey over additional parcels of land not previously subject to a detailed survey was undertaken in 2012 (Archaeology South East 2012). In addition, targeted trial trenching of some geophysical anomalies previously identified by Archaeology South East and Wessex Archaeology was undertaken (Archaeology South East 2013). This comprised 18 trial trenches. These were located in two parcels of land located 1.3km west and 1.7km north-west of the site. Of the 19 geophysical anomalies targeted only five were confirmed through trial trenching and of these only one was recorded as archaeological in origin.
14.2.24 Analysis of the geophysical survey aside, this trenching did record other features indicative of the area being within a Late Bronze Age to Iron Age/Roman field system away from the densely settled areas present further to the north on slightly higher ground at Brisley Farm.
Cheesemans Green
14.2.25 Located c.1.5km east of the site, trial trenching was undertaken at the 5% level as a condition to planning consent. This followed fieldwalking and geophysical survey which had both proved inconclusive. The geological conditions comprise Weald Clay. The evaluation recorded evidence for Iron Age/Roman activity.
Historic Landscape Characterisation
14.2.26 The site is located within the Central Valley Area which is thought to have been subject to intensive agricultural activity for at least the last 200 years. The majority of the site
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is within land classified as ‘small wavy bounded fields with ponds’. The exception is the south-western parcel of land within the site which is classified as ‘medium regular fields with straight boundaries’. The ‘small way bounded fields with ponds’ are most likely post medieval in origin whilst the ‘medium regular fields with straight boundaries’ typically represent nineteenth and twentieth century enclosure of former downland during the nineteenth and twentieth centuries (OAU 2001).
Statutory Designated Heritage Assets Scheduled Monuments
14.2.27 There are no Scheduled Monuments within the boundary of the site. There is one Scheduled Monument within the search area. This comprises Westhawk Farm, a Romano-British roadside settlement which is located 360m north of the site on an area of sand and gravel (reference 1017645), see Drawing 14.1.
Listed Buildings
14.2.28 There are no Listed Buildings within the boundary of the site. There are 30 Listed Buildings within the search area. These comprise one building listed at Grade I and 29 buildings listed at Grade II, see Drawing 14.1.
Conservation Areas
14.2.29 The site is not located within a Conservation Area. The Kingsnorth Conservation Area is located adjacent to the site boundary, see Drawing 14.1.
Registered Parks and Gardens
14.2.30 The site is not located within a Registered Park and Garden. There are no Registered Parks and Gardens within the search area.
Non Statutory Designated Heritage Assets Registered Battlefields
14.2.31 The site is not located within a Registered Battlefield. There are no Registered Battlefields within the search area.
Known Non Designated Heritage Assets Non-Designated HER Entries
14.2.32 The HER records four non-designated heritage assets within the site boundary. These comprise a pill box (HER reference TQ 93 NE 74), a copper alloy coin (HER reference MKE79111), the site of a corn mill (HER reference TR 03 NW 11) and a faint rectangular cropmark (HER reference TR 03 NW 116), see Drawing 14.2. ST13901/001 Page 267 June 2015
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General Historical Background Prehistoric
14.2.33 The HER does not record any evidence for prehistoric activity within the boundary of the site. However, it is thought that River systems of the East Stour may have been a foci for small bands of hunters during the early prehistoric period (Wessex Archaeology 2011). Indeed a palaeolithic hand axe and flints have been recorded 540m north of the site and 770m west of the site respectively (HER references TR 03 NW 117 and TQ 93 NE 75) and as discussed above, fieldwork undertaken in respect of the Ashford Southern Ring Main indicated that clearance of the area may have commenced during the early prehistoric period.
14.2.34 Much of the fieldwork in the surrounding area (Ashford Southern Ring Main, Missenden, Brisley and Chilmington) has also recorded evidence for an extensive Bronze Age field system (Archaeology South-East 2004). However, little settlement evidence has been recorded and it is probable that settlement was transient and short term (Kent Archaeological Projects 2011). Bronze Age funerary activity is well attested to by barrows on the North Downs to the north of the search area.
Iron Age/Romano British (AD43 to 410AD)
14.2.35 The HER does not record any dated evidence for Iron Age/Roman activity within the boundary of the site. However this is the period most well attested to within the wider area and a faint rectangular cropmark located at the highest point within the site boundary (53.6m AOD) may be indicative of activity of this date (HER reference TQ 03 NW 116).
14.2.36 Whilst this is uncertain, within the wider area localised areas of high ground within the poorly drained Weald Clay have proven to be a focus for settlement activity dating to the Iron Age/Roman periods. The main Iron Age settlements in the immediate vicinity of the search area have been recorded 1.1km north-west of the site (Brisley Farm) and 1-1.2km east of the site (Park Farm).
14.2.37 At Brisley Farm this was located on Weald Clay on the 40m contour and comprised settlement dating to the Middle to Late Iron Age periods which included within it funerary activity relating to two warrior burials. The burials became a focus for activity during the second half of the first century but subsequent to this the settlement, first established in the Middle Iron Age, was abandoned.
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14.2.38 At Park Farm, a Middle to Late Iron Age nucleated valley floor settlement was recorded within a slightly raised area of sand and gravel 1.2km east of the site (Powell 2013). This was modest in its nature and was probably focused on animal husbandry with elements of agriculture. Additional round houses in slightly closer vicinity to the site, c.1.1km, themselves in close vicinity to sands and gravels, were recorded along with a furnace which appears to have been constructed for iron working and the melting of copper alloy. Numerous phases of re-organisation were evident and by the start of the Roman period the settlement, like the Brisley Farm settlement, appears to have been curtailed/abandoned perhaps in favour of the settlement at Westhawk Farm (Powell 2013).
14.2.39 The main Roman settlement has been recorded at Westhawk, 160m-930m north-east of the site. The settlement was established on well drained geology (sand and gravel) in the immediate vicinity of the Roman road between Benendon and Canterbury (HER reference TQ 93 NE 66). The settlement extended northwards and towards the end of the period required the creation of made ground to support settlement in areas previously liable to flooding (Missendon).
Early Medieval (c.410 to 1066AD)
14.2.40 The HER does not record any evidence for Anglo Saxon activity within the boundary of the site. Within the search area, it is thought that the Church of St Michaels at Kingsnorth may have had an Anglo Saxon precursor, 215m north of the site. In addition, possible Saxon remains have been recorded at Brisley 950m north-west of the site (HER reference TQ 94 SE 169).
Medieval (c.1066 to 1540AD)
14.2.41 The establishment of settlement at Kingsnorth by the end of the eleventh century is verified by its inclusion in the Domesday Book (1086). A number of moated houses are known to have existed at Kingsnorth (Hasted 1797-1801). This attests to drainage requirements as well as defensive ones. The nearest moated house to the site is recorded at Old Mumford Farmhouse, 100m east (HER reference TR 03 NW 5). It is likely that during this period the site was located within the open field system.
Post medieval and Modern (c.1540 onwards)
14.2.42 The earliest cartographic evidence studied as part of this assessment comprised the 1839 Kingsnorth Tithe Map, see Drawing 14.3. This showed the land within the site as being managed by five farms. These comprised Pound Farm (Grade II listed building
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reference 1320407), Kiln Farm (now known as Bond Farm Grade II listed building reference 1115501), Taylor Farm (Grade II listed building reference 1362666), Goatley Farm (HER reference MKE83105), Smithfield House/Farm (HER reference MKE83105) and Mill House (Grade II listed building reference 1071462). Land use was a mixture of pasture and arable. In addition, an area of woodland was recorded as extending within the eastern boundary of the site. No buildings were depicted within the boundary of the site; notably, a windmill recorded on the HER as being located within the boundary of the site was depicted outside of the site boundary (HER reference TR 03 NW 11).
14.2.43 By the time of the production of the 1874-1877 Ordnance Survey Map, some of the field boundaries within the north-western and central parts of the site had been removed. Between 1961/2 and 1974/5 field boundaries were removed from within the south-western part of the site.
14.2.44 The map regression has shown that since at least 1839 there have been no buildings located within the boundary of the site, including the site of Shipley Hatch windmill (HER reference TR 03 NW 11) which the Tithe Map depicts outside of the site boundary. The exception is a Second World War pill box (HER reference TQ 93 NE 74) which is shown on current mapping within the south-western-most land parcel within the boundary of the site. This was part of defensive network across this part of Kent. Associated with this system were WWII trenches which have been recorded c.100m south of the site.
Aerial Photographic Evidence
14.2.45 Aerial photographs were viewed at the Kent Historic Environment Record. These included aerial photographs dating from the 1940s onwards. No cropmarks were visible in the area of the HER record TR 03 NW 116. However, to the east of this (within the site boundary) cropmarks were visible on a black and white 1940 aerial photograph and a colour 2012 aerial photograph, WA1 on Drawing 14.4. These include enclosures which may indicate settlement activity.
Site Visit
14.2.46 A walkover survey of the site was undertaken in July 2014.
14.2.47 The site was inspected to:
• establish the presence of above ground archaeology, whether or not previously recorded;
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• assess and validate data collected as part of the desk-based assessment; • assess the topography of the site and • to assess inter-visibility with heritage designations.
14.2.48 The site was observed as being predominantly arable in nature, under a crop of rape or wheat. The only exceptions to this were two fields in the south-west of the site fronting Magpie Hall Road, a small field in the north of the site between White ‘Chimmneys’ and ‘Myrtle Court’ and a small field in the east of the site fronting onto Bond Lane. There was also a small part of the eastern part of the site which was located within an area of woodland.
14.2.49 Isolated oaks were present within a number of the fields and oaks were also prevalent within hedgerows where present. Ditches were present alongside some hedgerows, the most substantial of which was noted along the eastern boundary plot 183 on Drawing 14.3. This was approximately 1m deep, see Plate 1.
14.2.50 A small storage barn was present in the field to the west of Bond Farm, see Plate 2. The remains of a similar structure were evident in the south-eastern most field of the site, see Plate 3. A pill box was present in the south of the site, see Plate 17. No other structures were observed within the site.
14.2.51 The site of the crop mark recorded by the HER was under wheat, see Plate 4. No differential crop growth was noted in this location or further to the north-east in the same field where baseline collection indicated possible further cropmarks.
14.2.52 Views towards Listed Buildings adjacent to or in the immediate vicinity of the site were noted. In respect of views from the Listed Buildings, Mumford House (reference 132415) was noted to be most open to the site, see Plate 5. Bond Farmhouse (reference 115501), Taylor Farmhouse (reference 1362666), Mill House (reference 1071462) and Whitegates (reference 1362668) were also noted to have views of the site, see Plates 6, 7, 8, 9 and 10. In respect of Mumford House (reference 132415), Bond Farmhouse (reference 115501), Mill House (reference 1071462) and Whitegates (reference 1362668) these views were possible from the rear elevations. In respect of Taylor Farmhouse, open views were possible from the front elevation. However, it should be noted that in respect of views of these buildings, as they are appreciated from the public highway, the site would not be particularly visible. This would be either due to the presence of intervening vegetation or to the intervening presence of the buildings themselves.
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14.2.53 Conversely whilst not particularly visible from the buildings themselves, the site would be visible to varying degrees in views from the public highway of Shipley Hatch (reference 1320382), The Queens Head Public House (reference 1071466) and Pound Farmhouse (reference 1320407) see Plates 11, 12 and 13.
14.2.54 In respect of the other Listed Buildings in closest vicinity to the site, Old Mumford Farmhouse and barn (references 1362669 and 1115433), a barn to the northwest of Smithfield House (reference 1320438) and Houghton House (reference 1071469) were noted to be screened from the site by intervening vegetation, see Plates 14,15 and 16.
14.2.55 Plates 5, 10 and 14 also show the view towards the Kingsnorth Conservation Area.
Plate 1: Substantial ditch located to the east of the field located between ‘Chimmneys’ and ‘Myrtle Court’
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Plate 2: Small storage barn of wood and metal construction to west of Bond Farm (metre scale bar)
Plate 3: Remains of structure on south-eastern most field of site
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Plate 4: Site of HER reference to a small cropmark enclosure (reference TR 03 NW 116)
Plate 5: View from within the site towards Grade II listed Mumford House (reference 1320415)
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Plate 6: View from the boundary of the site towards Grade II Mumford House (reference 1320415)
Plate 7: View from the site boundary towards Grade II Bond Farmhouse (reference 1115501)
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Plate 8: View from front of Grade II Taylor Farmhouse towards the site (reference 1362666)
Plate 9: View from within the site towards Grade II Mill House (reference 1071462)
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Plate 10: View from the site boundary towards Grade II Whitegates (reference 1362668)
Plate 11: View of Grade II Shipley Hatch (reference 1320382). Site to RHS of frame
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Plate 12: View of site (beyond Triumph garage) and Queen’s Head public house (reference 1071466). Taken from front of Grade II Pound Green (reference 1320408)
Plate 13: View of site and Grade II Pound Farmhouse (reference 1320407)
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Plate 14: View from within the nearest field within the site towards Old Mumford Farmhouse and barn (references 1362669 and 1115433)
Plate 15: View from within the nearest field within the site towards the barn to the north-west of Smithfield Farmhouse (references 1320438)
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Plate 16: View from within the nearest field within the site towards Houghton House (references 1071439)
Plate 17: WWII Pill box located within the southern part of the site
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Geophysical Survey
14.2.56 A geophysical survey of the site has been undertaken at the predetermination stage. This is appended in full to this report, see Appendices 14.3 and 14.4. For ease of reference the possible archaeological anomalies identified by the survey are depicted on Drawing 14.4. In summary, the geophysical survey recorded:
• A possible ring ditch located on Weald Clay on a north facing slope at a height of 46.7m AOD (WA2 on Drawing 14.4). • A number of possible soil filled features some of which may relate to former agricultural division of the landscape. On the basis of previous fieldwork in the wider area these could relate to the Late Bronze Age/Iron Age division of the landscape for agricultural/pastoral purposes (WA3 on Drawing 14.4). • Four possible kilns on Weald Clay in the centre of the site on a slight south facing slope at 43.5-42.2m AOD (WA4 on Drawing 14.4). • Some possible pits (which may be geological in origin) located on Weald Clay on a slight south-western facing slope at 47.5-46.4m AOD (WA5 on Drawing 14.4). • Other bands of anomalies, two of which are more than likely geological in origin (WA6 on Drawing 14.4). However one band coincides with the HER reference of a rectangular cropmark and appears more anthropogenic - therefore this may be archaeological in origin (WA7 on Drawing 14.4) (HER reference TR 03 NW 116). The latter band (WA7) is located on Weald Clay at the high point of the site and on a north/east facing slope (53.6-51.5m AOD). • Anomalies corresponding with field boundaries as shown on the Tithe Map (WA8 on Drawing 14.4). • An isolated soil filled feature located on Weald Clay at a height of 39.8m AOD (WA9 on Drawing 14.4).
14.2.57 The survey did not verify the presence of anomalies according with the cropmarks recorded during baseline collection (WA1 on Drawing 14.4).
14.2.58 Fieldwalking was also undertaken of all ploughed fields (the majority of the site). No finds concentrations were recorded and the majority of the assemblage was post medieval in date, see Appendix 14.3.
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Summary of Baseline
14.2.59 Consultation undertaken with the Kent Historic Environment Record and the review of information from Historic England data sets has established that there are no designated heritage assets within the boundary of the site. However 32 heritage designations are present within the search area. The setting of a designated heritage asset may be a material consideration if any impact to it would cause impact to its overall significance.
14.2.60 With regards to potential buried remains, the land within the boundary of the site was probably part an extensive Bronze Age/Iron Age agricultural landscape. The first non- transitory, permanent settlements within this landscape have been dated to the Middle to Late Iron Age and have been recorded on areas of localised high ground to the east and the west of the site. These have been recorded on areas of sand and gravel or on areas of Weald Clay in close vicinity to areas of sand and gravel. Whilst the majority of the site is located on the poorly draining Weald Clay, the elevated nature of the land within parts the site may have made it an attractive place for permanent settlement during the Iron Age in-particular. Indeed, the geophysical survey and aerial photograph analysis of the site has indicated that the highest point within the site and the land to its east may have been utilised for settlement activity (WA1 and WA7 on Drawing 14.4). Other isolated anomalies of interest include a possible ring ditch (WA2 on Drawing 14.4) and possible kilns (WA4 on Drawing 14.4). Other soil filled features including possible drainage ditches relating to the probable division of the landscape from the Bronze Age onwards are shown as WA3 on Drawing 14.4.
14.3 Identification and assessment of impacts
14.3.1 Using the criteria set out in Appendix 14.2 the following impacts, their magnitude and their significance are predicted. These are split into direct (construction) and in-direct impacts.
Direct Impacts
14.3.2 Ground disturbance will have the potential to disturb buried archaeological remains. The significance of this impact is presented below.
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Table 14.1 Potential Construction Impacts Physical impact to heritage assets Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact Possible ring Archaeological: low to Proposals in this area comprise housing. Most likely ditch (WA2 on medium (likely to be Magnitude of impact = major moderate Drawing 14.4) truncated by the adverse plough) i.e. there is no evidence for the presence of remains of high importance Possible soil Archaeological: low to Whilst some of these anomalies are located in areas Most likely up field ditches medium i.e. there is no of proposed green space the proposals affecting to moderate dispersed site evidence for the some of these anomalies include housing. adverse wide (WA3 on presence of remains of Magnitude of impact = up to major Drawing 14.4) high importance Cluster of four Archaeological: low to Proposals in this area comprise housing and a road, Most likely possible kilns medium i.e. there is no Magnitude of impact = major moderate (WA4 on evidence for the adverse Drawing 14.4) presence of remains of high importance Possible pits Archaeological: low to Proposals in this area comprise housing. Most likely (WA5 on medium i.e. there is no Magnitude of impact = major moderate Drawing 14.4) evidence for the adverse presence of remains of high importance Band of Archaeological: most Proposals in this area comprise ‘green space’. No greater anomalies likely medium i.e. there Conditional to the green space comprising non- than slight possibly is no evidence for the intrusive or very limited groundworks the impact adverse indicative of presence of remains of would be minimal activity, high importance Magnitude of impact = negligible to minor potentially related to HER reference TR 03 NW 116 (WA7 on Drawing 14.4) Cropmarks Archaeological: most Proposals in this area comprise ‘green space’. No greater observed on likely medium i.e. there Conditional to the green space comprising non- than slight 1940 and 2012 is no evidence for the intrusive or very limited groundworks the impact adverse aerial presence of remains of would be minimal photographs high importance Magnitude of impact = negligible to minor
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Table 14.1 Potential Construction Impacts Physical impact to heritage assets Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact (WA1 on Drawing 14.4) Pill box within Historic/architectural: Proposals in this area comprise housing and a road. Moderate the site low to medium Magnitude of impact = major adverse boundary (HER reference TQ 93 NE 74) Unknown Archaeological: most Magnitude of impact = up to major Most likely buried remains likely low to medium i.e. moderate there is no evidence for adverse the presence of remains of high importance
Indirect Impacts
14.3.3 There is a potential that the setting of designated heritage assets within the vicinity will be impacted upon.
Table 14.2 Potential Operational Impacts Impact to Grade I Listed Buildings Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact Church of St Michael Architectural/historic: The value of the building, located 210m north of Neutral (reference 1362667) high the site lies predominantly within its fabric. This would not be impacted upon by the proposals. The principal setting elements that contribute towards the significance of the building are its churchyard and its physical position in Kingsnorth. These would not be impacted upon by the proposals which would not be visible from the building or from its immediate surrounds due to the presence of mature vegetation. There would be no impact to setting elements that contribute towards the overall significance of the building. Magnitude of impact = no change Impact to Scheduled Monuments
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Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact Romano British Archaeological/historic: The importance of the monument, located 360m Neutral roadside settlement high north of the site, lies predominantly within its and pillbox fabric and buried remains. These would not be (reference 1017645) impacted upon by the proposals. In respect of setting, intervening areas of residential development are present between the monument and the site. Magnitude of impact = no change Impact to Grade II Listed Buildings Receptor Receptor Receptor Receptor Wix’s Farmhouse Architectural/historic: The value of the farmhouses, located 500m south, Neutral (reference 1071461), medium 570m south-east, 740m east, 830m north-west Sticketts Farmhouse and 900m north-west of the site respectively, lies (reference 1320439), predominantly within their built fabric. This Finn Farmhouse would not be impacted upon by the proposals. (reference 1071467), Setting elements that contribute towards the Willowbed significance of a farmhouse principally comprise Farmhouse its rural backdrop but specifically its own (reference 1320433) landholding (the land over which its holds rights and of design and function). The proposals would not Brisley Farmhouse impact upon the landholdings of Wix’s (reference 1071463) Farmhouse, Sticketts Farmhouse, Finn Farmhouse, Willowbed Farmhouse or Brisley Farmhouse. Furthermore, intervening vegetation would provide screening. There would be no impact to setting elements that contribute towards the overall significance of the buildings. Magnitude of impact = no change Bond Farmhouse Architectural/historic: The importance of the building located 50m from No greater (reference 1115501) medium the boundary of the site lies predominantly within than its built fabric. This would not be impacted upon moderate by the proposals. In respect of setting, the adverse proposals would impact upon a proportion of the farm’s historic and current landholding. However, proposals in the immediate vicinity of the farmhouse (which would be visible from the rear of the farmhouse) comprise green spaces in the foreground and the landholding to the north-east of the farmhouse, which is visible on approach to
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the farmhouse (and most likely from the main elevation), would be unaffected by the proposals. Magnitude of impact = moderate Pound Farmhouse Architectural/historic: The importance of the building located 50m from No greater (reference 1320407) medium the site boundary lies predominantly within its than slight fabric. This would not be impacted upon by the adverse proposals. In respect of setting, the proposals would impact upon a proportion of the farms historic landholding. However the farmhouse is no longer associated with the land which is now under the management of another farm. In addition, the farmhouse has been surrounded by modern residential development, further isolating it from its past context, see Plate 13. Magnitude of impact = negligible Taylor Farmhouse Architectural/historic: The importance of the building lies predominantly No greater (reference 1362666) medium within its built fabric. This would not be impacted than upon by the proposals. In respect of setting, the moderate proposals would impact upon a proportion of the adverse farms historic landholding. However, the farmhouse is no longer associated with the land within the boundary of the site which is now under the management of another farm. Therefore, whilst the building is still set within a rural backdrop, the importance of the backdrop in respect of the farmhouse as it currently stands has been diminished. Furthermore, the farmhouse would not be surrounded by the proposed development and its former land holding to the immediate north-west and south- west (to the south of Steeds Lane) would not be impacted upon. Views of the farmhouse from Bond Lane would not be significantly impacted upon and views from the front elevation of the farmhouse towards the site, see Plate 8, would retain an element of green space. Magnitude of impact = minor to moderate Old Mumford Architectural/historic: The importance of the building lies predominantly No greater Farmhouse medium within its fabric. This would not be impacted upon than slight (reference 1362669) by the proposals. In respect of setting, the adverse proposals would impact upon a proportion of the farms historic landholding. However the land is no
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longer managed by Old Mumford and the proposals within that part of the historic land holding would be screened from view by intervening vegetation, see Plate 14. Furthermore, the vast majority of the farmhouse’s historic landholding, along with the immediate and current rural backdrop would be unaffected. Magnitude of impact = negligible Mill House Architectural/historic: The importance of the building lies predominantly No greater (reference 1071462) medium within its built fabric. This would not be impacted than upon by the proposals. In respect of setting, the moderate proposals would impact upon a proportion of the adverse buildings historic landholding (the south-western part of the site). However, the building is no longer associated with the land within the boundary of the site which is now under the management of a distant farm. Due to the general perception of the building as a rural/semi-rural dwelling, setting elements that may contribute towards its significance can include its rural setting. However, the fact that the building is no longer associated with the land within the site reduces its influence and perceived association with the land on the south-west of the site. In respect of the surrounding countryside in the immediate vicinity of the building, it should be noted that modern twentieth century development is already present in the vicinity of the building which is no longer an isolated rural dwelling on Ashford Road. Nevertheless the proposed development would be visible from the rear of the property, see Plate 9. Magnitude of impact = minor to moderate Shipley Hatch Architectural/historic: The value of the building, located adjacent to the No greater (reference 1320382) medium boundary of the site, lies predominantly within its than fabric. This would not be impacted upon by the moderate proposals. Due to the general perception of a adverse cottage as a rural/semi-rural dwelling, setting elements that may contribute towards its significance can include its rural setting. However, the nature of the building as a cottage, rather
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than a farmhouse, reduces its influence and perceived association with the surrounding countryside and it should be noted that modern twentieth century development is already present in the vicinity of the cottage which is no longer an isolated rural dwelling on Ashford Road. Nevertheless the proposed development would be visible from the rear of the property and within views of the property, see Plate 11. Magnitude of impact = minor to moderate Glebe Cottage Architectural/historic: The importance of the buildings lies Neutral (reference 1071464), medium predominantly within their fabric. This would not Mumford Cottage be impacted upon by the proposals. Setting (reference 1071465), elements that contribute to their significance are Piran Cottage their village centre location within the Kingsnorth (reference 1115476), Conservation area. This would not be impacted Mouse Hall upon by the proposals. Views of the site would be (reference 115481) screened by intervening vegetation. There would be no impact to setting elements that contribute towards the overall significance of the buildings. Magnitude of impact = no change Queens Head Public Architectural/historic: The importance of the building lies predominantly Neutral House (reference medium within its fabric. This would not be impacted upon 1071466) by the proposals. Setting elements that contribute towards an appreciation of the public house are its crossroads location. This would not be impacted upon by the proposals. Whilst the proposed residential development would be visible from the rear of the building and in views of the building, intervening areas of residential development are already visible, see Plate 12. There would be no impact to setting elements that contribute towards the overall significance of the public house. Magnitude of impact = no change Barn to north of Finn Architectural/historic: The value of the buildings lies predominantly Neutral Farmhouse medium within their fabric. This would not be impacted (reference 1071468) upon by the proposals. Setting elements that barn to south of Old contribute towards their significance are Mumford Farmhouse primarily limited to their association with Finn (reference 1115433) Farmhouse or Mumford Farmhouse. There would and oasthouses at be no impact to these associations or the
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Finn Farmhouse immediate rural backdrop to the buildings. (references 1115435 Furthermore, the proposals would be screened and 1362631) from view by intervening vegetation. Magnitude of impact = no change Houghton House Architectural/historic: The value of the former farmhouse located 15m Neutral (reference 1071469) medium from the site lies predominantly within its fabric. This would not be impacted upon by the proposals. In respect to setting, the historic/current landholding of the farmhouse would not be impacted upon, perimeter vegetation would provide screening and the proposals in the immediate vicinity of the building comprise green space. In addition the previous rural isolation of the farmhouse has been infringed upon already by twentieth century development (encroaching from the west). There would be no impact to setting elements that contribute towards the overall significance of the building. Magnitude of impact = no change Ponderville Architectural/historic: The importance of the building, located 670m Neutral (reference 1071470) medium south-east of the site, lies predominantly within its fabric. This would not be impacted upon by the proposals. In respect of setting, the immediate rural backdrop to the building would not be impacted upon. There would be no impact to setting elements that contribute towards the overall significance of the building. Magnitude of change = no change Glenmore Lodge Architectural/historic: The importance of the building, located in Neutral (reference 1320389) medium Stanhope, lies predominantly with their fabric. and Cloverley This would not be impacted upon by the Cottage (reference proposals. In respect of setting the buildings are 1362632) located within high density residential areas. There would be no impact to setting elements that contribute towards the overall significance of either building. Magnitude of impact = no change Pound Green Architectural/historic: The importance of the building lies predominantly Neutral (reference 1320408) medium within its fabric. This would not be impacted upon by the proposals. Whilst the proposed residential development would be visible from the front of
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the, intervening areas of residential development are already visible, see Plate 13. There would be no impact to setting elements that contribute towards the overall significance of the building Magnitude of impact = no change Mumford House Architectural/historic: The importance of the building, located 110m Slight adverse (reference 1320415) medium from the site, lies predominantly within its built fabric. This would not be impacted upon by the proposals. The setting of the building on approach through the village of Kingsnorth would not be impacted upon; the site would not be visible on approach to or entry to the property. Whilst the site would be visible from the rear of the building, see Plate 5, the proposals entail the retention of green space within 200m of the property. Magnitude of impact = minor Pickendon Architectural/historic: The importance of the building lies predominantly Neutral (reference 1320421) medium within its fabric. This would not be impacted upon by the proposals. In respect of setting, an area of intervening woodland would prevent inter- visibility and the immediate rural backdrop to the building would not be impacted upon. There would be no impact to setting elements that contribute towards the overall significance of the building Magnitude of impact = no change Barn to north-west Architectural/historic: The importance of the building located 25m from Neutral of Smithfield medium the site lies predominantly within its fabric. This Farmhouse would not be impacted upon by the proposals. In (reference 1320438) terms of setting and the contribution it makes to the significance of the building it should be stated that in this instance the functional and utilitarian nature of the building does not afford a contextual appreciation of its setting beyond that of its relationship with the immediate surrounds, i.e. the setting elements of the building which contribute to its significance and understanding do not necessarily include rural aesthetics or long views. Furthermore substantial mature vegetation would screen the site, see Plate 15. There would be no impact to setting elements
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that contribute towards the overall significance of the building. Magnitude of impact = no change Whitegates Architectural/historic: The importance of the building, located 130 from Slight adverse (reference 1362668) medium the site, lies predominantly within its built fabric. This would not be impacted upon by the proposals. The setting of the building on approach through the village of Kingsnorth would not be impacted upon; the site would not be visible on approach to or entry to the property. Neither would the site infringe on the relationship of the rectory with the Church of St Michael, its principal contextual building within the village. Whilst the site would be visible from the upper storeys of the rear of the building, see Plate 10, the proposals entail the retention of green space within 250m of the property. Magnitude of impact = negligible to minor Conservation Areas Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact Kingsnorth Historic/architectural: The importance of the Conservation Area lies No greater medium predominantly within its built heritage. This than slight would not be impacted upon by the proposals. In adverse respect of the setting of the Conservation Area, the proposals would not be visible from the majority of the Conservation Area, certainly the parts of the Conservation Area accessible by the general public. Furthermore, the proposals maintain green spaces within the parts of the site which are located in closest proximity to the Conservation Area; the closest built development would be located 100m from the Conservation Area boundary. Magnitude of impact = minor Non-Designated Assets Receptor Interest and Magnitude of Impact Significance of Significance of Interest Impact Smithfield/House Historic/architectural: The importance of the building located adjacent No greater Farmhouse (HER low to the site boundary lies predominantly within its than slight reference fabric. This would not be impacted upon by the adverse MKE83106) proposals. In respect of setting, the proposals
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would impact upon the former farmhouse’s historic landholding. However the farmhouse is no longer associated with the land which is now under the management of another farm. Therefore, whilst the building is still set within a rural backdrop, the importance of the backdrop in respect of the former farmhouse as it currently stands has been diminished. Whilst the proposed development would be visible from rear of the property and within views of the property mature vegetation present to the boundary of the property and the proposed green space in closest vicinity to the property will reduce the visual impact. Magnitude of impact = minor Goatley Farm (HER Historic/architectural: The importance of the building located adjacent No greater reference low to the site boundary lies predominantly within its than slight MKE83105) fabric. This would not be impacted upon by the adverse proposals. In respect of setting, the proposals would impact upon the former farmhouse’s historic landholding. However the farmhouse is no longer associated with the land which is now under the management of another farm. Therefore, whilst the building is still set within a rural backdrop, the importance of the backdrop in respect of the former farmhouse as it currently stands has been diminished. Nevertheless the proposed development would be visible from rear of the property and within views of the property. Magnitude of impact = moderate
Summary of Impacts
14.3.4 The proposed development has the potential to physically impact upon buried archaeological remains. The impact, if realised, is most likely to be of no greater than moderate adverse significance.
14.3.5 In respect of setting impacts to heritage assets the proposed development has the potential to impact upon the setting of eight Grade II Listed Buildings, a Conservation Area and three non-designated buildings.
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14.3.6 In respect of section 66 of the Listed Building and Conservation Areas Act (1990) and the special regard which should be applied when considering the desirability of preserving a building’s setting, the weight attributed to the setting impacts discussed above is a matter of planning judgement. Whilst this is the exclusive province of the Local Planning Authority it is stressed here that no setting impacts would be of greater than moderate adverse significance. Therefore no setting impacts would cause substantial harm to the overall significance of a heritage designation.
14.4 Mitigation and residual impacts
14.4.1 The site has been subject to a programme of fieldwork at the predetermination stage. This has comprised fieldwalking and geophysical survey. The results of the predetermination fieldwork, in combination with the other baseline studies undertaken as part of this assessment, has guided the masterplan of the site such that the most extensive and important archaeological remains are located within areas of green space. Subject to appropriate design, the potential impact to these buried remains has therefore been removed/minimised. In respect of other remains within areas of proposed built development there is no evidence to indicate the presence of extensive remains or remains of high importance. As such it is anticipated that no further work at the predetermination stage would be required.
Residual Impacts
14.4.2 The loss of buried archaeological remains due to development would be fully mitigated through the implementation of a programme of archaeological fieldwork. As a consequence of this there would be negligible adverse residual impacts on archaeological remains.
14.4.3 Please see Table 14.2 below for a summary of the residual impacts.
Table 14.2 Significance of residual impact (with mitigation) Potential effect Significance (pre- Mitigation measure Significance of mitigation) residual effect Construction stage Potential archaeological remains: Most likely Archaeological evaluation and Neutral moderate adverse excavation of necessary Possible ring ditch (WA4) Possible soil filled features (WA3) Four possible kilns (WA4) Possible pits (WA5)
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Possible archaeological remains No greater than Archaeological evaluation and Neutral related to HER reference TR 03 slight adverse excavation of necessary NW 116 Cropmarks observed on 1940 and No greater than Archaeological evaluation and Neutral 2012 aerial photographs slight adverse excavation of necessary Pill box Moderate adverse Building recording prior to Neutral demolition Unknown buried remains Most likely Archaeological evaluation and Neutral moderate adverse excavation of necessary Post-completion stage Bond Farmhouse (reference No greater than None proposed No greater than 1115501 moderate adverse moderate adverse Pound Farmhouse (reference No greater than None proposed No greater than 1320407) slight adverse slight adverse Taylor Farmhouse (reference No greater than None proposed No greater than 1362666) moderate adverse moderate adverse Old Mumford Farmhouse No greater than None proposed No greater than (reference 1362669) slight adverse slight adverse Mill House (reference 1071462) No greater than None proposed No greater than moderate adverse moderate adverse Shipley Hatch (reference No greater than None proposed No greater than 1320382) moderate adverse moderate adverse Mumford House (reference Slight adverse None proposed Slight adverse 1320415) Whitegates (reference 1362668) Slight adverse None proposed Slight adverse Kingsnorth Conservation Area No greater than None proposed No greater than slight adverse slight adverse Smithfield/House Farmhouse No greater than None proposed No greater than (HER reference MKE83106) slight adverse slight adverse Goatley Farm (HER reference No greater than None proposed No greater than MKE83105) slight adverse slight adverse
14.5 Cumulative impacts
14.5.1 In terms of archaeological sites, cumulative impacts will principally arise where each development removes individual areas of preserved archaeological remains resulting in a gradual erosion and fragmentation of the total archaeological resource of the region. The Kingsnorth Green development would contribute to the cumulative physical loss of archaeological remains from development in general within the region. However in all cases of development, including that at Kingsnorth Green, this would
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be offset by the contribution made to archaeological understanding of the area through excavation and recording.
14.6 Conclusions
14.6.1 Baseline information was gathered from the Historic Environment Record held by Kent County Council, the Kent History and Library Centre and Historic England data sets.
14.6.2 It has been established that no statutory designations would be physically impacted upon by the proposals. However nine designated heritage assets and three non- designated heritage assets may experience setting impacts. No setting impacts would be of greater than moderate adverse significance. Therefore all setting impacts would constitute impacts of less than substantial harm.
14.6.3 A non-designated pill box would be removed by the proposals. The significance of this impact would be of moderate adverse significance.
14.6.4 In respect of buried archaeological remains it has been established that the site has a potential for the presence of remains dating to the Iron Age/Roman periods. Baseline studies have identified two main areas within the site where such remains are most likely to be present and the masterplan of the site has been developed so as to minimise/remove any potential adverse impacts in these areas. Other identified and potential remains within the site are isolated and their likely importance does not necessarily warrant further work at the predetermination stage. It is therefore anticipated that further archaeological fieldwork could be undertaken as a condition to planning consent.
14.7 Bibliography
14.7.1 Cartographic Sources
Kingsnorth Tithe Map 1839 Ordnance Survey 1874-current
14.7.2 Bibliographic Sources
• Archaeology South East. (1999a) An archaeological field evaluation of land at Brisley Farm, Chilmington Green, Ashford, Kent • Archaeology South East. (1999b) Brisley Farm, Chilmington Green, Ashford, Kent phases I and II interim summary statement
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• Archaeology South East. (2001) An archaeological desk based assessment and walkover survey of land at Kingsnorth, Ashford, Kent • Archaeology South East. (2004) An archaeological evaluation of phase 9 at Brisley Farm (Chartfields), Chilmington Green, Ashford, Kent • Archaeology South East. (2003) Brisley Farm Ashford Kent a post excavation assessment report on the archaeological excavations 1998-2002 with proposals for publication • Archaeology South East. (2009) Archaeological investigations of land at Missenden, Kingsnorth Road, Ashford post excavation assessment and project design for publication • Archaeology South East. (2012) Detailed magnetometer survey land at ChilmingtonGreen Ashford Kent • Archaeology South East. (2013) Archaeological evaluation land south of Colman’s Kitchen Wood Brisley Farm Chilmington Green • Ashford Borough Council. (2000) Ashford Borough local plan • British Geological Service. (2014) Geology of Britain viewer: Available http://mapapps.bgs.ac.uk/geologyofbritain/home.html • Canterbury Archaeological Trust. (2003) Archaeological evaluation of land at Millbank Reception Centre Millbank Place, Ashford, Kent • Canterbury Archaeological Trust. (2012) An archaeological evaluation at the John Wallis Academy • Pre-Construct Archaeology. (2003) An archaeological evaluation Park Farm East, Ashford, Kent • Pre-Construct Geophysics. (2005) Fluxgate gradiometer and resistivity surveys: Missenden, Kingsnorth, Ashford, Kent • English Heritage. (2008) Conservation principles polices and guidance for the sustainable management of the historic environment • English Heritage. (2011) The setting of heritage assets • English Heritage. (2011) Seeing the history in the view a method for assessing heritage significance within views • English Heritage. (2014) National Heritage List for England downloadable GIS data • GSB Prospection. (unknown date) Report on geophysical survey Westhawk Farm III Ashford • Hasted, E. (1797-1801) The history and topographical survey of the county of Kent volume VII
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• Highways Agency. (2007) Design Manual for Roads and Bridges, Volume 11, Section 3, Part 2 • Kent Archaeological Projects and Abingdon Archaeological Geophysics. (2007) The results of a geophysical survey using magnetometry on the proposed route of the Ashford southern ring main pipeline, near Ashford, Kent • Kent Archaeological Projects. (2011) A post excavation assessment report for an archaeological investigation in advance of and during the excavation of the Ashford Southern ring main water pipeline at Stubbs Cross in Kent • Kent Archaeological Rescue Unit. (1997) Report on a programme of archaeological work at Westhawk Farm, Kingsnorth, Ashford • Oxford Archaeological Unit. (2001) Kent historic landscape characterisation final report • Pre-Construct Archaeology. (2006) Land at Missenden, Kingsnorth Road, Ashford, Kent evaluaiton • Powel, A. (2013) ‘Settlement and landscape reorganisation from the Middle Iron Age to the early Roman period: excavations south-east of Park Farm’, Arch Cant , 2013, pp295-307 • Wessex Archaeology. (2004) Park Farm East Ashford, Kent post excavation assessment report and updated project design • Wessex Archaeology. (2010) Chilmington Green, Ashford, Kent a programme of archaeological evaluation comprising a fieldwalking and gradiometer survey • Wessex Archaeology. (2011) Land at Chilmington Green Ashford, Kent geophysical survey report
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15 CLIMATE CHANGE
15.1 Introduction
15.1.1 This chapter provides an assessment of the effects of the project on the environment (climate) and the effects of climate change on the project. Including climate change in ES assessments is increasingly requested by Local Planning Authorities and the Institute of Environmental Management and Assessment (IEMA).
15.1.2 Climate change impacts on the project are the climate hazards, associated with weather variables which make projects vulnerable to the effects of climate change. Changes to our climate as a result of climate change are now unavoidable. It is widely recognised we must adapt to the effects of climate change as a result of Green House Gases (GHG) in the atmosphere. The UK is likely to see a future increase in temperature and a greater frequency of extreme weather events as a result of climate change.
15.1.3 Infrastructure and residential developments must be more resilient and adapt to climate change. Consideration needs to be given to the implications of increased temperatures experienced in the long term and the shading opportunities vegetation planting provides. The use of SuDS can adapt to increased rainfall and run off from hard surfaces on residential developments.
15.1.4 The impacts of the project on the environment (climate) are the GHG generated by the scheme at Kingsnorth Green, through construction, manufacture of materials for construction, transporting materials, the vehicular movements associated with transport movements and the GHG generated by the residents of the dwellings following completion of the development. Historically the construction of homes has been unsustainable; however, there is an increasing demand for builders to demonstrate compliance with the sustainability of their homes.
15.1.5 Residential developments have the potential to contribute to significant levels of
Carbon dioxide (CO 2); however, sustainable methods of construction, adaptive measures and mitigation reduce those impacts generated by the scheme. Kingsnorth Green has the potential to create long term benefits to offset the climate change impacts generated by the project.
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15.2 Policy
National Context
15.2.1 Chapter 10 of the National Planning Policy Framework (NPPF) 2012 ‘Meeting the challenge of climate change, flooding and coastal change’ , states planning plays a fundamental role in reducing greenhouse gas emissions, minimising vulnerability and providing resilience to climate change impacts.
15.2.2 Paragraph 94 indicates “local planning authorities should adopt proactive strategies to mitigate and adapt to climate change” .
15.2.3 Paragraph 95 states “to support the move to a low carbon future, local planning authorities should:-
• plan for new development in locations and ways which reduce greenhouse gas emission.”
15.2.4 Paragraph 99 states that the new developments should be planned to avoid increased vulnerability to impacts associated with climate change. Particular care should be taken in planning new development being brought forward in vulnerable areas such as areas at risk of flooding.
15.2.5 Core planning principles within paragraph 17 of the NPPF include:
-“Proactively drive and support sustainable economic development to deliver the homes, businesses and industrial units, infrastructure and thriving local places that the country needs”.
“support the transition to a low carbon future in changing climate, taking full account of flood risk and coastal change...”.
Local Context
Ashford Borough Council Core Strategy (adopted July 2008)
15.2.6 Policy CS1 ‘Guiding Principles’ states that “ Sustainable development and high quality design are at the centre of the Council’s approach to plan making and deciding planning applications. ” Therefore the Council applies a number of planning objectives, including that new development should aim to be zero carbon, and be designed to mitigate and adapt to the effects of climate change. Sustainable transport options should also be provided for large developments.
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15.2.7 Policy CS9 ‘Design Quality’ advises that “ development proposals should be of high quality design and demonstrate a positive response to ” a number of design criteria, including ease of movement, adaptability and efficient use of natural resources.
15.2.8 Policy CS10 ‘Sustainable Design and Construction’ states that “ All major developments… must incorporate sustainable design features to reduce the consumption of natural resources and to help deliver the aim of zero carbon growth in Ashford .” Developments, dependent on scale and type, are required to meet BREEAM standards and a minimum carbon dioxide reduction. Through meeting these requirements developments should also be carbon neutral, “ with any shortfall being met by financial contributions to enable residual carbon emissions to be offset elsewhere in the Borough .”
15.2.9 Policy CS15 ‘Transport’ seeks to promote sustainable modes of travel. This includes a requirement that “ development proposals must show how all highway, public transport, walking and cycling needs arising from the development will be satisfied and provide for the timely implementation of all necessary infrastructure ”. In addition, “Developments that would generate significant traffic movements must be well related to the primary and secondary road network, and this should have adequate capacity to accommodate the development .” Development proposals should also be designed to accommodate the provision of identified key transport infrastructure routes or facilities, where these are located within the site.
15.2.10 Policy CS20 ‘Sustainable Drainage’ requires that all development should include “appropriate sustainable urban drainage systems (SuDS) for the disposal of surface water, in order to avoid any increase in flood risk or adverse impact on water quality. ”
Ashford Borough Council Urban Sites and Infrastructure Development Plan Document (DPD) (adopted October 2012)
15.2.11 Policy U0 ‘Presumption in Favour of Sustainable Development’ states that the Council “will always work proactively with applicants jointly to find solutions which mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area .”
15.3 Baseline
Future Baseline - UK Climate Projections
15.3.1 The UK Climate Projections (UKCP09) provides climate information to help plan how to adapt to a changing climate. The data is focussed on the UK. The projections are
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based on Met Office Methodology and UKCP09 reflects scientists’ best understanding of future climate change. They address how uncertainty in future climate projections is included. UKCP09 recognises that no climate model can give a definite answer of what our future climate will be like 20 .
15.3.2 For the Kingsnorth Green scheme this assessment has looked at ‘future climate change’ for the variables ‘change in mean temperature’ and ‘change in mean precipitation’. The time period ‘2010 to 2039’ has been considered for the project for the construction phase and the time period ‘2070 to 2099’ has been considered to obtain information on changes in annual temperature and annual rainfall, to assess the long term impacts on the site. (Time period ‘2070 to 2099’ is the longest climate projection available from UKCP09).
15.3.3 Tables 15.1 and 15.2 provide annual temperature data under a range of different ‘Emission Scenarios’ and ‘Probability Levels’ for the time periods ‘2010 to 2039’ and ‘2070 to 2099’. This data has been used in the assessment of impacts of climate change on the project.
Table 15.1 UKCP09 Annual Temperature for Time Period 2010 to 2039 for the Kingsnorth Green area
Emission Scenario Probability Level (%) Temperature Increase (°C)
Low 10% 0 to 1°C
50% 1 to 2°C
90% 2 to 3°C
Medium 10% 0 to 1°C
50% 1 to 2°C
90% 2 to 3°C
High 10% 0 to 1°C
50% 1 to 2°C
90% 2 to 3°C
Data obtained from UKCP09
20 UKCP09 (2012) UK Climate Projections {Website} - http://ukclimateprojections.defra.gov.uk/21678 ST13901/001 Page 301 June 2015
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Table 15.2 UKCP09 Annual Temperature for Time Period 2070 to 2099 for the Kingsnorth Green area
Emission Scenario Probability Level (%) Temperature Increase (°C)
Low 10% 1 to 2°C
50% 2 to 3°C
90% 4 to 5°C
Medium 10% 2 to 3°C
50% 3 to 4°C
90% 5 to 6°C
High 10% 2 to 3°C
50% 4 to 5°C
90% 6 to 7°C
Data obtained from UKCP09
15.3.4 Tables 15.3 and 15.4 provide annual temperature data under a range of different ‘Emission Scenarios’ and ‘Probability Levels’ for the time periods ‘2010 to 2039’ and ‘2070 to 2099’. This data has been used in the assessment of impacts of climate change on the project.
Table 15.3 UKCP09 Annual Precipitation for Time Period 2010 to 2039 for the Kingsnorth Green area
Emission Scenario Probability Level (%) % Increase /Decrease of Annual Precipitation
Low 10% 0 to 10% Decrease
50% 0 to 10% Increase
90% 0 to 10% Increase
Medium 10% 0 to 10% Decrease
50% 0 to 10% Decrease
90% 0 to 10% Increase
High 10% 0 to 10% Decrease
50% 0 to 10% Decrease
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90% 0 to 10% Increase
Data obtained from UKCP09
Table 15.4 UKCP09 Annual Precipitation for Time Period 2070 to 2099 for the Kingsnorth Green area
Emission Scenario Probability Level (%) % Increase / Decrease of Annual Precipitation
Low 10% 0 to 10% Decrease
50% 0 to 10% Decrease
90% 0 to 10% Increase
Medium 10% 0 to 10% Decrease
50% 0 to 10% Decrease
90% 0 to 10% Increase
High 10% 0 to 10% Decrease
50% 0 to 10% Decrease
90% 0 to 10% Decrease
Data obtained from UKCP09
15.4 Methodology
Guidance
15.4.1 Currently there is no official guidance on how climate change adaptation and mitigation are considered in EIA practice, however, the 2011 Regulations do require forecasting methods associated with assessments to be described.
15.4.2 The IEMA Principle Series Climate Change Adaptation and Climate Change Mitigation EIA papers published in 2010 21/22 have been consulted.
21 IEMA (2010) The Institute of Environmental Management and Assessment {Website} www. iema .net/.../ climate 20 change 20 adaptation 20and20eia_0.pdf 22 IEMA (2010) The Institute of Environmental Management and Assessment {Website} www. iema .net/system/.../ climate 20 change 20 mitigation 20and20eia.pdf ST13901/001 Page 303 June 2015
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Methodology for impacts of climate change on the project
15.4.3 In addition, no official guidance or methodology currently exists for assessing the impacts of climate change on a project, however, consideration has been given to the following:
• project type, its location and its vulnerability to climate change;
• projects life span for construction, operation and decommissioning; and
• the climate hazards which are most significant to the project and require consideration in the EIA.
15.4.4 This information will be used in the identification of potential impacts of climate change on the project. Adaptation strategies are outlined where appropriate.
15.4.5 For the Flood Risk Assessment (FRA), NPPF methodology procedures have been followed which consider climate change impacts and design drainage in accordance with the effects of climate change. The FRA considers the effects of increased rainfall under NPPF.
Methodology for impacts of the project on the climate
15.4.6 For the impacts of the project on climate, this specifically relates to GHGs generated by the project. This considers carbon management and measures implemented to reduce greenhouse gas emissions.
15.4.7 The methodology has been based on IEMA Principle Series Climate Change Mitigation and EIA guidelines and the EIA hierarchy for managing project related GHG emissions 23 . This follows the ‘Avoid’; ‘Reduce’; ‘Substitute’; ‘Compensate’ hierarchy.
15.5 Assessment
Assessment of climate change impacts on the project
15.5.1 This ES has considered UKCP09 climate projections for precipitation and temperature during the construction phase. Climate change impacts are more acute for projects with a lifetime of over 30 years. Meteorologists suggest that for projects of less than this time period, it is considered that changes would result in normal weather patterns; however, the uncertainty inherent within climate change cannot discount the likelihood of extreme weather. Kingsnorth Green will have a construction phase
23 IEMA (2010) The Institute of Environmental Management and Assessment {Website} www. iema .net/system/.../ climate 20 change 20 mitigation 20and20eia.pdf ST13901/001 Page 304 June 2015
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of approximately 10 years and a lifetime in excess of 100 years, therefore future climate change needs to be considered.
15.5.2 The proposal involves the construction of approximately 750 residential dwellings; therefore adaptation in terms of resilience to structural building design features from the impacts of climate change are essential as these buildings are likely to see more extreme weather at the end of this century.
Precipitation
15.5.3 Based on the Low Emission scenario and a 50% and 90% probability level; and the Medium and High Emission scenarios and a 90% probability level, the Kingsnorth Green area is likely to have a 10% increase in annual precipitation during the construction phase (UKCP09 period 2010 to 2039). The impacts of increased precipitation on urban developments are an increase in peak discharge to local watercourses and frequency of floods. However for all remaining scenarios for this phase, the area is likely to have a 10% decrease in annual precipitation. For the 2070 to 2099 period the area is only likely to have a 10% increase in annual precipitation under the Low and Medium Emission scenarios and a 90% probability level. For all remaining scenarios for this phase, the area is likely to have a 10% decrease in annual precipitation.
15.5.4 Therefore it is unlikely that the area will experience a significant increase in precipitation which would increase the risk of flooding to the Kingsnorth Green scheme.
15.5.5 To further demonstrate that the proposed development is at no or little risk of flooding from adjacent watercourses and to address surface water drainage issues an FRA and Drainage Strategy has been prepared as part of this ES (Appendix 2.1).
15.5.6 The majority of the site is located within Flood Zone 1, with a minor area of the site in the north-western corner located within Flood Zone 2. The proposed development is classified as ‘more vulnerable’ within the NPPF, which is considered to be an appropriate development type within Flood Zones 1 and 2.
15.5.7 The FRA concluded that the risk of flooding to development would be extremely small and the site has been identified as being at low risk of flooding from all sources.
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Temperature
15.5.8 The construction phase has a life span of 10 years. The Low, Medium and High Emission Scenarios have been considered over the probability levels 10%, 50% and 90% for the UKCP09 time period 2010 to 2039. For this period the projections do not vary between Emission Scenarios, however they do vary between probability levels. Based on a 10% probability level the annual temperate is only likely to increase by 0°C to 1°C, based on a 50% probability level it is only likely to increase by 1°C to 2°C, and based on a 90% probability level it is only likely to increase by 2°C to 3°C. Bearing in mind that the construction phase is anticipated to last a considerably shorter time than the UKCP09 time period 2010 to 2039, temperature increase is not considered significant during the construction phase.
15.5.9 The future temperature is of greater concern for the Kingsnorth Green scheme, with temperatures likely to rise by 3°C to 4°C under the Medium Emission scenario in the ‘2070 to 2099’ period. However the adverse impact of potential rises in temperature can be reduced through strategic vegetation planting and building orientation (see below).
Resilience / Adaptation to climate change impacts
15.5.10 Resilience is fundamental to addressing climate change in EIA and makes projects less vulnerable to changing climatic conditions. Extreme weather associated with climate change can be uncertain in terms of its magnitude, frequency and spatial occurrence. Resilience is closely linked to adaptation.
15.5.11 Adaptation reduces the vulnerability of projects to climate change. Adaptive measures, including design features and construction materials can provide resilience to extreme weather. It is therefore important that resilience is designed into the EIA for all projects but particularly those longer term projects. Housing developments which will be subject to changing climatic conditions over the lifetime of the site must consider climate proofing developments.
15.5.12 There are a number of significant opportunities to reduce the impacts of climate change and provide resilience to climate change within the design of the Kingsnorth Green scheme:
• The construction of all dwellings will be compliant with the Code for Sustainable Homes. The Code makes provisions to ensure future housing stock will be better adapted to cope with the inevitable impacts of climate change;
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e.g. suitably insulating homes, homes will have to be designed to use no more than approximately 105 litres of water per person per day; providing adequate storage spaces (i.e. for cycles and drying space for clothes).
• Trees and vegetation lower surface and air temperatures through evapotranspiration, which can help reduce peak summer temperatures by 1- 5°C. In addition, if planted in strategic locations around buildings, vegetation can also provide shade, reducing the need and/or frequency to use air conditioning (thereby reducing GHG emissions). The Kingsnorth Green proposal will have planted areas as part of the development including street planting and therefore will contain a considerable number of shaded areas.
• SuDS features such as swales, detention basins and balancing ponds will be incorporated within the development design. SuDS are a form of adaptation and reduce the impacts of flooding by retaining water and reducing the volume of water discharging from the site, particularly during extreme weather when large volumes of rainfall can fall in a short timeframe.
• Building orientation determines potential for passive solar heating and reducing effects of extreme weather;
• The design of building layout can make significant reductions in heat requirements possible.
Assessment of impacts of the project on climate
15.5.13 Kingsnorth Green will comprise approximately 750 new dwellings, a primary school and community facilities. This development will generate GHG through construction and following completion of the dwellings. GHGs are well documented as contributing to global warming. The GHGs generated by the project are considered to be the main impact of the project on climate.
15.5.14 The Climate Change Act 2008 set in place legally binding targets for the UK Government to achieve a 34% reduction in greenhouses gas by 2020, increasing to an 80% reduction by 2050, compared with a 1990 baseline. The UK has also signed up to the EU Renewable Energy Directive which sets a target of 15% of energy from renewable sources by 2020.
15.5.15 For this project, GHGs are unavoidable and remain significant, as CO 2 is inevitably generated by the construction works, the manufacture of materials and the transport
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of materials to site. Because GHG emissions cannot be avoided, the aim is to reduce the significance of the project’s emissions, through mitigation.
15.5.16 Climate change mitigation is dealing with the causes of climate change (the GHGs emitted). Given the national commitments outlined above, there is an increasing demand for commercial operators to demonstrate the measures they are implementing to reduce GHG emissions. In addition the scheme will encourage sustainable forms of transport, including walking and cycling, and contribute to the
improvement of public transport links within Ashford. This will help to reduce the CO 2 emissions that are contributing to climate change.
15.5.17 There are a number of significant opportunities to reduce the impacts of the project on climate within the design of the development:
• Higher density development around the settlement centre and close to public routes;
• Connected street networks to provide clear and direct routes, particularly for pedestrians and cyclists;
• Range of community facilities at the ‘Local Centre’ that are easily accessible by the local community by foot and cycle to reduce the need to drive to other community
facilities which would increase CO 2 levels generated and contribute to climate change.
• Passive design features, including building air tightness and thermal efficiency, building orientation and use of appropriate material choices.
• Water efficient devices, water metering and rainwater harvesting to reduce water consumption within the site.
• Priority will be given to the selection of construction material with low environmental impact.
15.5.18 The design has taken into account the existing features of ecological value and retained them, where possible. The network of retained hedgerows will link with new structured landscape planting to maintain wildlife movement corridors around and beyond the application site.
15.5.19 An Ecological and Landscape Management Plan will be prepared for the site. The development will create amenity and community value in the landscape. The strategic
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planting of trees can also provide benefits in terms of adaptation of the site to climate change by assisting in lowering the temperatures in urban settings.
15.5.20 SuDS will be incorporated for the external works where practicable. There will be improved quality of collected water run-off prior to discharge of water courses where practicable.
15.5.21 To demonstrate that the proposed development will not increase the risk of flooding and to address surface water drainage issues an FRA and Drainage Strategy has been undertaken (Appendix 2.1). The risk of flooding posed by the development (from increased surface water runoff) is considered to be low following the implementation of appropriate mitigation measures (including SuDS).
15.6 Summary and Conclusions
15.6.1 The proposed development will provide residential and community facilities for the region, and improve public transport links within south Ashford, and between south Ashford and the town centre.
15.6.2 The Kingsnorth Green development will incorporate good design principles. A Sustainability Appraisal has been prepared as part of the planning application to address the sustainable construction of the development.
15.6.3 An Ecological and Landscape Management Plan will be prepared for the site and will include measures to compensate for habitats lost and provide biodiversity enhancement measures to benefit local wildlife. The development will create amenity and community value in the landscape and new strategic planting will assist in reducing the potential effects of climate change.
15.6.4 It is considered that overall, the scheme will meet the Government’s objectives on sustainable development and meets national and local economic, environmental and social policies and considers adaptation and mitigation measures to minimise adverse impacts relating to climate change.
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16 RESIDUAL AND CUMULATIVE IMPACTS
16.1 Residual Impacts
16.1.1 A crucial part of the EIA process is to assess the significance of the impacts following implementation of the proposed mitigation, otherwise known as ‘residual impacts’. Residual impacts are considered in each of the above individual technical chapters where relevant.
16.1.2 The mitigation of the key environmental issues have been used to reduce impacts to the lowest practicable level consistent with the overall objectives of the scheme. Any residual effects, either during the construction or operational period or in the long- term, are also identified where appropriate and the significance of these residual impacts are assessed within each technical chapter.
16.1.3 Following the implementation of the mitigation measures outlined within each technical chapter, the majority of residual impacts have been assessed as being insignificant.
16.1.4 The only significant residual impacts identified within this assessment are potential visual impacts on receptors within and adjacent to the site, and the impact on the landscape character of the site. However the impacts identified in this assessment are not unusual or excessive for a scheme of this size. Furthermore mitigation in the form of advanced planting and landscaped green space will help over time to successfully assimilate the proposed development into the local landscape.
16.2 Cumulative Impacts
16.2.1 Schedule 4 of the EIA Regulations states that an Environmental Statement must include a description of the likely significant effects of the development, including reference to possible cumulative effects.
Cumulative impacts with other developments
16.2.2 The EIA has considered major committed development projects in the area which, in conjunction with the proposed development, could collectively impose a significant impact on the environment. These include schemes with planning consent, or schemes that are the subject of a valid planning application that has not yet been determined.
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16.2.3 Schemes to be taken into consideration in the assessment of cumulative effects were identified by consulting ABC’s online planning application search facility. The relevant schemes to be considered were identified as:
• Chilmington Green;
• Park Farm; and
• Cheesemans Green.
16.2.4 The potential cumulative environmental effects of these developments with the proposed Kingsnorth Green development have been assessed in detail in this ES within the individual technical chapters, in accordance with best practice guidelines and procedures. A summary is provided below for each environmental issue.
Land Use and Soils
16.2.5 Development of the above schemes in combination with the proposed Kingsnorth Green development would result in a cumulative loss of 610.2ha of agricultural land from the locale, of Grade 3 and above (BMV and potentially BMV). Ashford Borough comprises 52,001ha of land of ALC grades 1, 2 and 3, equating to 96% of the Borough’s agricultural land (54,226 ha), and 90% of its total land area (58,062ha). Consequently the cumulative loss of 610.2ha, equating to 1.2% of BMV and potentially BMV land, and 1.1% of the agricultural land of the locale, is not considered to be significant.
Ground Conditions
16.2.6 There are no perceived significant residual impacts on the ground conditions of the site as a result of the proposed development. The geology of the surrounding area and the Kingsnorth Green site are generally similar. The potential for the development of the surrounding area to give rise to significant cumulative effects on local geology, ground conditions or mineral resources is considered to be very small. In addition, it is considered that the proposed Kingsnorth Green site would not contribute to any additional cumulative effects on the ground conditions of the surrounding areas.
Water Resources
16.2.7 There are no perceived significant residual impacts as a result of the proposed development. Chilmington Green is considered to be the only scheme in the surrounding area to potentially have a combined effect with Kingsnorth Green due to its size and proximity. However, following a review of the information regarding water
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resources submitted in support of Chilmington Green, it is not considered that development of the two schemes would result in a cumulative impact.
Ecology
16.2.8 Potential impacts of the proposed development on the existing ecological condition are not expected to extend beyond the site as any required ecological mitigation will be delivered on-site. The development will have no effects on surrounding ecologically designated sites and as such it is anticipated that there will not be any significant cumulative impacts on ecology arising from the development of Kingsnorth Green in combination with other developments in the surrounding area.
Landscape and Visual Impact
16.2.9 There is no inter-visibility between the site and the other developments. Therefore there is not expected to be any cumulative landscape or visual impacts.
Archaeology and Cultural Heritage
16.2.10 The Kingsnorth Green development would contribute to the cumulative physical loss of archaeological remains from development in general within the region. However in all cases of development, including that at Kingsnorth Green, this would be offset by the contribution made to archaeological understanding of the area through excavation and recording.
Cumulative impacts on receptors
16.2.11 The cumulative impact assessment also has a second aspect. The EIA has taken into consideration where a significant residual impact is expected to occur on a particular receptor as a consequence of collective actions, aspects or effects of the proposed development.
16.2.12 However, there are no significant residual impacts arising from these proposals. Therefore it is unlikely that any receptor would experience significant cumulative impacts from the combined effect of two or more sources; or from the impacts continuing over an extended period of time.
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