HORIZON CREMATION
HORIZON CREMATION, OXTED ROAD, OXTED, SURREY
Ecological Assessment
March 2020 8731.EcoAs.vf
COPYRIGHT
The copyright of this document remains with Ecology Solutions. The contents of this document therefore must not be copied or reproduced in whole or in part for any purpose without the written consent of Ecology Solutions.
PROTECTED SPECIES
This report contains sensitive information relating to protected species. The information contained herein should not be disseminated without the prior consent of Ecology Solutions.
CONTENTS
1 INTRODUCTION 1
2 SURVEY METHODOLOGY 2
3 ECOLOGICAL FEATURES 5
4 WILDLIFE USE OF THE SITE 7
5 ECOLOGICAL EVALUATION 11
6 PLANNING POLICY CONTEXT 23
7 SUMMARY AND CONCLUSIONS 28
PLANS
PLAN ECO1 Site Location and Ecological Designations
PLAN ECO2 Ecological Features
PLAN ECO3 Pond Locations
PHOTOGRAPHS
PHOTOGRAPH 1 Heavily grazed semi-improved grassland
PHOTOGRAPH 2 Hedgerow H1 and recently managed Bracken
PHOTOGRAPH 3 Hedgerow H2
PHOTOGRAPH 4 Tree line T1
APPENDICES
APPENDIX 1 Information downloaded from the Multi-Agency Geographic Information for the Countryside (MAGIC) website
Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 1. INTRODUCTION
1.1. Background and Proposals
1.1.1. Ecology Solutions was commissioned in January 2020 by Horizon Cremation to undertake an ecological assessment of land off Oxted Road, Oxted, Surrey (see Plan ECO1).
1.1.2. The proposals are for the construction of a crematorium with associated access, landscaping and parking infrastructure.
1.2. Site Characteristics
1.2.1. The site is approximately 4.4ha in size and comprises heavily grazed species-poor semi-improved grassland, surrounded, in the main, by mostly wooden post and rail fencing with occasional wooden post and barbed-wire fencing. Heavily managed hedgerows line the southern and eastern boundaries whilst semi-mature trees line the western boundary.
1.2.2. The site is located between the village of Godstone and the town of Oxted in the Tandridge district of Surrey. It is bound along its southern boundary by Oxted Road (A25), whilst Tandridge Hill Lane borders the site to the west and Barrow Green Road borders the eastern boundary. A footpath and bridleway are located along the northern boundary, separating the site from the adjacent regenerating woodland and disused sand quarry (Oxted Sand Pit). School Plantation, an area of planted broadleaved woodland, is located less than 15m east of the site on the far side of Barrow Green Road. Godstone Golf Club is situated to the west of the site whilst Tandridge Golf Course lies to the southeast.
1.2.3. The wider landscape consists predominately of open countryside, comprising pasture and arable fields bound hedgerows. Pockets of woodland, some of which is classed as ancient and semi-natural woodland or ancient replanted woodland, are also located in the wider landscape. The M25 motorway is located approximately 0.8km north of the site boundary at its closest point.
1.3. Ecological Assessment
1.3.1. This document provides an assessment of the ecological interest of the site. The importance of the habitats within the site are evaluated with due consideration given to the guidance published by the Chartered Institute of Ecology and Environmental Management (CIEEM)1.
1.3.2. Where necessary, mitigation measures are recommended so as to safeguard any significant existing ecological interest within the site and, where appropriate, potential enhancement measures are put forward and reference made to both national and local biodiversity priorities.
1 CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater, Coastal and Marine. Version 1.1 – Updated September 2019. Chartered Institute of Ecology and Environmental Management, Winchester.
1 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 2. SURVEY METHODOLOGY
2.1. The methodology utilised for the survey work can be split into three areas, namely desk study, habitat survey and faunal survey. These are discussed in more detail below.
2.2. Desk Study
2.2.1. In order to compile background information on the site and the surrounding area, Ecology Solutions contacted Surrey Biodiversity Information Centre (SBIC) and East Surrey Badger Protection Society (ESBPS).
2.2.2. Further information on designated sites from a wider search area was obtained from the online Multi-Agency Geographic Information for the Countryside (MAGIC)2 database which uses information held by Natural England and other organisations.
2.2.3. This information is reproduced at Appendix 1 and, where appropriate, on Plan ECO1.
2.3. Habitat Survey
2.3.1. A habitat survey was carried out by Ecology Solutions in January 2020 in order to ascertain the general ecological value of the site and to identify the main habitats and associated plant species.
2.3.2. The site was surveyed based around extended Phase 1 survey methodology3, as recommended by Natural England, whereby the habitat types present are identified and mapped, together with an assessment of the species composition of each habitat. This technique provides an inventory of the basic habitat types present and allows identification of areas of greater potential which require further survey. Any such areas identified can then be examined in more detail.
2.3.3. Using the above method, the site was classified into areas of similar botanical community types, with a representative species list compiled for each habitat identified.
2.3.4. All the species that occur in each habitat would not necessarily be detectable during survey work carried out at any given time of the year, since different species are apparent in different seasons. While it is acknowledged that the extended Phase 1 survey was undertaken at a sub- optimal time of year, it is considered that an accurate and robust assessment has been made given the habitats present. Further observations will be undertaken during proposed survey work.
2.4. Faunal Survey
2.4.1. Obvious faunal activity recorded during the site survey, such as birds or mammals observed visually or by call, was recorded. Specific attention
2 http://www.magic.gov.uk 3 Joint Nature Conservation Committee (2010). Handbook for Phase 1 Habitat Survey – a Technique for Environmental Audit. England Field Unit, Nature Conservancy Council, reprinted JNCC, Peterborough.
2 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 was paid to any potential use of the site by protected species, priority species or other notable species.
2.4.2. In addition, specific faunal surveys were undertaken to ascertain the presence of protected species including bats and Badgers Meles meles.
Bats
2.4.3. All of the trees within the site were subject to a ground-based assessment in January 2020 to determine their potential to support roosting bats. Features typically favoured by bats were searched for, including:
• Obvious holes, e.g. rot holes and old Woodpecker holes; • Dark staining on the tree, below the hole; • Tiny scratch marks around a hole from bat claws; • Cavities, splits and or loose bark from broken or fallen branches, lightning strikes etc.; and • Very dense covering of mature Ivy Hedera helix over trunk.
2.4.4. All field surveys were undertaken with regard paid to best practice guidelines issued by Natural England (20044), the Joint Nature Conservation Committee (20045) and the Bat Conservation Trust (20166).
Badgers
2.4.5. The site and immediate vicinity were subject to specific surveys for Badgers in January 2020.
2.4.6. The surveys comprised two main elements: firstly, searching thoroughly for evidence of Badger setts. If any setts were encountered each sett entrance was noted and plotted, even if the entrance appeared disused. The following information was recorded:
i) The number and location of well used or very active entrances; these are clear of any debris or vegetation and are obviously in regular use and may, or may not, have been excavated recently.
ii) The number and location of inactive entrances; these are not in regular use and have debris such as leaves and twigs in the entrance or have plants growing in or around the edge of the entrance.
iii) The number of disused entrances; these have not been in use for some time, are partly or completely blocked and cannot be used without considerable clearance. If the entrance has been disused for some time all that may be visible is a depression in the ground where the hole used to be together with the remains of the spoil heap.
4 Mitchell-Jones, A J (2004). Bat Mitigation Guidelines. English Nature, Peterborough. 5 Mitchell-Jones, A J & McLeish, A P (Eds.) (2004). Bat Workers’ Manual. 3rd edition. Joint Nature Conservation Committee, Peterborough. 6 Collins, J (Ed.) (2016). Bat Surveys for Professional Ecologists: Good Practice Guidelines. 3rd Edition. Bat Conservation Trust, London.
3 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 2.4.7. Secondly, evidence of Badger activity such as well-worn paths, run- throughs, snagged hair, footprints, latrines and foraging signs was recorded, so as to build up a picture of the use of the site by Badgers.
4 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 3. ECOLOGICAL FEATURES
3.1. An extended Phase 1 habitat survey was carried out by Ecology Solutions in January 2020.
3.2. The following main habitat / vegetation types were identified within the site during the survey undertaken:
• Poor semi-improved grassland; • Hedgerows; • Trees; • Bracken; and • Scrub / tall ruderal vegetation.
3.3. The locations of these habitats are shown on Plan ECO2 and are set out in more detail below.
3.4. Poor Semi-improved Grassland
3.4.1. The majority of the site comprises an area of heavily grazed, species-poor, semi-improved grassland (see Photograph 1). The site is surrounded on all sides by fencing (mostly wooden post and rail, occasionally wooden post and barbed wire) with a wooden post and rail fence dissecting the site, running north to south.
3.4.2. Having been subject to intense grazing by both horse and Rabbit Oryctolagus cuniculus, the grassland sward height is very short and has a poor species diversity, comprising common grass species and herbaceous species. Species recorded include Perennial Rye Grass Lolium perenne, Cock’s-foot Dactylis glomerata, Yorkshire Fog Holcus lanatus, Annual Meadow-grass Poa annua and False Oat-grass Arrhenatherum elatius, alongside occasional Common Nettle Urtica dioica, Field Speedwell Veronica persica, Dove’s-foot Cranesbill Geranium molle, Spear Thistle Cirsium vulgare, Cleavers Galium aparine, White Dead-nettle Lamium album, Ribwort Plantain Plantago lanceolata, Yarrow Achillea millefolium, Daisy Bellis perennis, Ragwort Senecio jacobaea, Lesser Burdock Arctium minus, Campion Silene sp. and Cow Parsley Anthriscus sylvestris. A single Great Mullein Verbascum thapsus was noted along the northern boundary, adjacent to the bridleway.
3.5. Hedgerows
3.5.1. Hedgerows are present along the southern and eastern boundaries of the semi-improved grassland, whilst a semi-mature treeline forms the western boundary. Both hedgerows are heavily managed and described separately below.
3.5.2. Hedgerow H1 lies along the south of the site, adjacent to Oxted Road, and is approximately 295m in length, 1m in depth and varies between 2.2m and 1.3m in height (see Photograph 2). A large gap is present in the centre of the leggy hedgerow, which is dominated by Hawthorn Crataegus monogyna, with occasional Elder Sambucus nigra, Ivy and Bramble Rubus fruticosus. Ground flora was minimal at the time of the survey, with only Lords-and-ladies Arum maculatum and Common Nettle recorded.
5 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020
3.5.3. Hedgerow H2 is a continuation of Hedgerow H1 and runs north along the eastern boundary of the site, adjacent to Barrow Green Road (see Photograph 3). Like Hedgerow H1, Hedgerow H2 is leggy, and several gaps were also noted within the hedgerow, this time to the north beneath a mature Pedunculate Oak Quercus robur tree. The hedgerow is approximately 135m in length, 1m in width and 2.2m in height. It is dominated by Hawthorn, although Elm Ulmus sp., Blackthorn Prunus spinosa and Sycamore Acer pseudoplatanus were also noted, alongside Bramble. As with H1, the ground flora is low in diversity comprising Common Nettle, Ground Ivy Glechoma hederacea, Ribwort Plantain and Lords-and-ladies.
3.6. Trees
3.6.1. The majority of the trees present on site are associated with the tree line along the western boundary (see Photograph 4), although a semi-mature Oak was noted within Hedgerow H2 and three Ash Fraxinus excelsior trees are present in the southeast corner of the grassland field. Species within the tree line include Hawthorn, Ash, Sycamore and Oak.
3.7. Bracken
3.7.1. Bracken was noted encroaching into the west of the site with a narrow strip also present along the southern hedgerow of the site. The majority of the Bracken had been subject to recent management and had been cut down to ground level at the time of the survey (see Photograph 2).
3.8. Scrub / Tall Ruderal Vegetation
3.8.1. Two small areas of tall ruderal vegetation mixed with Bramble scrub are present within the site; one is located in the southwestern corner of the site, at the junction of Oxted Road and Tandridge Hill Lane and another in the northeast of the site, adjacent to Barrow Green Road. In both cases, the area comprises Common Nettle and Bramble.
3.9. Background Records
3.9.1. Given the habitats present, and their current intense usage as a horse paddock, the presence of any notable species is highly unlikely.
3.9.2. Six Bluebell Hyacinthoides non-scripta records dating from 2010 were returned by the data search; the closest of these was recorded approximately 1.1km to the northwest of the site.
3.9.3. Two records of the invasive Giant Hogweed Heracleum mantegazzianum were recorded within the vicinity of the site. The closer, and more recent, of the two was observed in 2004 approximately 1.5km southwest of the site boundary, separated by woodland and arable fields.
3.9.4. Four Japanese Knotweed Fallopia japonica records were returned; the closest was recorded at a location approximately 0.9km northeast of the site boundary in 1996 whilst the most recent was recorded approximately 1.2km northeast of the site in 2011.
6 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 4. WILDLIFE USE OF THE SITE
4.1. General observations were made during the surveys of any faunal use of the site, with specific attention paid to the potential presence of protected species.
4.2. Bats
4.2.1. There are no buildings on site that would offer any suitable roosting opportunities for bats.
4.2.2. Two Ash trees within the site were noted for their potential to support roosting bats. These are summarised below and their locations shown on Plan ECO2.
4.2.3. T1 is a semi-mature Ash tree located along the western boundary of the site. A number of tear outs on the stem of the tree are present which have resulted in the exposure of the heartwood and formation of a several cavities that are considered to have low bat roosting potential.
4.2.4. T2 is another semi-mature Ash tree which grows in the southeast of the site. As with Tree T1, tear outs on the stem of the tree have resulted in several cavities forming within the heartwood of the tree. This is considered to provide low bat roosting potential.
4.2.5. The site offers some suitable commuting and foraging opportunities in the form of the hedgerows, although it is considered that a large proportion of the site offers sub-optimal foraging opportunities being mainly open heavily grazed fields. The site is located within a landscape which contains a good amount of woodland (including ancient woodland) which may increase the likelihood of bats utilising the site.
4.2.6. Thirteen records for four bat species were returned by the data search. These include five records for unidentified bats Vespertilionidae sp., the most recent of which was recorded in 2010 approximately 1.1km northwest of the site, whilst the closest record was observed approximately 0.6km west of the site.
4.2.7. Four Common Pipistrelle Bat Pipistrellus pipistrellus records were returned by SBIC. All of the records dated from 2010, with the closest record observed approximately 1.1km to the northwest of the site.
4.2.8. Two records for Soprano Pipistrelle Pipistrellus pygmaeus were returned by the data search, both of which are dated from 2010, with the closest observed approximately 1.1km to the northwest of the site.
4.2.9. A single Noctule Bat Nyctalus noctula was recorded at a location approximately 1.3km north of the site boundary in 2010.
4.2.10. A single Brown Long-eared Plecotus auritus was recorded within a 100m grid square at a location approximately 1.9km southwest of the site boundary in 2011.
4.2.11. Natural England European Protected Species (EPS) licences were granted to allow the damage / destruction of a bat roosting place at two
7 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 locations approximately 1.5km and 1.6km east of the site boundary in 2016, both in respect of Common Pipistrelle.
4.3. Badgers
4.3.1. The semi-improved grassland and hedgerows offer some limited foraging and dispersal opportunities for this species.
4.3.2. Several mammal holes were identified within the hedgerows and tree line along the western, southern and eastern boundaries of the site, although these are considered to be attributed to Rabbits. No evidence of Badger was observed within the site, although a larger mammal hole, orientating to the north, is present approximately 15 to 20m to the north of the site along the adjacent embankment, and while there was no evidence of Badger recorded at the entrance, it does have the characteristics of a Badger sett entrance.
4.3.3. Surrey Biodiversity Information Centre did not return any records for Badgers within a 3km radius of the site. However, sett records returned by ESBPS revealed setts as close as 700m from the site boundary. Owing to the sensitive nature of the records, the types or age of these sett records was not detailed.
4.4. Dormice
4.4.1. The hedgerows on site are considered to be sub-optimal for Dormice Muscardinus avellanarius, being fairly leggy for the majority of their lengths, and typically comprising only one or two woody species.
4.4.2. The hedgerows are separated from nearby woodland by roads and paths, although it should be noted that Dormice have previously been recorded crossing duel carriageways, and thus single carriageways such as Barrow Green Road and Tandridge Hill Lane would not represent a barrier for dispersal.
4.4.3. A single record for Dormice was returned by the data search. This record dates from 2009 and was recorded approximately 1.2km northeast of the site boundary.
4.5. Other Mammals
4.5.1. The site contains suitable habitat for Hedgehog Erinaceus europaeus foraging and dispersal, including the hedgerows, small elements of scrub and, to a lesser degree, the semi-improved grassland.
4.5.2. Two historical records were returned by SBIC for Hedgehog. The closest and more recent of the two records was recorded within a 100m grid square at a location approximately 0.4km northeast of the site in 1998.
4.5.3. Evidence of Fox Vulpes vulpes within the site was also noted and, as previously mentioned, the site supports a large population of Rabbits. Moles Talpa europaea were also evident across the site.
8 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 4.6. Birds
4.6.1. The site offers suitable foraging and nesting opportunities for birds in the form of the hedgerows, scrub and trees along the boundaries of the site.
4.6.2. A small assemblage of birds was observed while on site, with Blue Tit Cyanistes caeruleus, Carrion Crow Corvus corone, Robin Erithacus rubecula, Great Tit Parus major, Blackbird Turdus merula and Feral Pigeon Columba livia being recorded by sight or call.
4.6.3. Records of a number of protected species were returned by the data search. These are, however, all more than twenty years old.
4.6.4. Two Cuckoo Cuculus canorus records were returned by the data search; both recorded in 1997, the closer of the two was at a location approximately 0.9km southwest of the site.
4.6.5. A single Grey Wagtail Motacilla cinerea was also recorded in 1997 at a location approximately 1.5km southwest of the site boundary.
4.6.6. A House Martin Delichon urbicum, Mute Swan Cygnus olor and a Stock Dove Columba oenas were all observed within a 100m grid square approximately 0.9km east of the site boundary in 1996.
4.6.7. A Kestrel Falco tinnunculus was observed approximately 1km southeast of the site in 1996.
4.6.8. Two Kingfisher Alcedo atthis records were returned by the data search; the closer, and more recent of the two, was observed at a location approximately 0.9km east of the site in 1997.
4.6.9. A Mistle Thrush Turdus viscivorus was observed approximately 1.3km north of the site boundary in 1996.
4.6.10. A Song Thrush Turdus philomelos was recorded approximately 1.4km south of the site boundary in 1997.
4.6.11. A Tawny Owl Strix aluco was recorded approximately 1.7km southeast of the site boundary in 1997.
4.7. Reptiles
4.7.1. The site contains negligible opportunities for reptiles. The grassland present possesses a very short sward height and lacks any characteristics typically favoured by reptiles having been heavily grazed by horses.
4.7.2. Individual records for Adder Vipera berus, Common Lizard Zootoca vivipara and Slow Worm Anguis fragilis were recorded at a location approximately 1.2km north of the site boundary in 2010.
4.7.3. Two Grass Snake Natrix helvetica records were returned by the data search; the closer, and more recent, of the two was recorded within a 100m grid square at a location approximately 90m north of the site boundary within the adjacent Oxted Sandpit in 2012 and accounted for four individual Grass Snakes.
9 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020
4.8. Amphibians
4.8.1. There are no waterbodies present on site to provide any breeding opportunities for this species. The heavily grazed grassland, which makes up the majority of the site, is considered to be sub-optimal for this species, whilst dispersal onto to the site is considered unlikely, given the surrounding busy roads.
4.8.2. Three waterbodies were identified within 500m of the site, with an additional pond located just beyond 500m (see Plan ECO3). Ponds P1, P2 and P4 are located within Godstone Golf Club. The closest of these (Pond P2) is located approximately 0.4km west of the site boundary and is separated from the site by Tandridge Hill Lane.
4.8.3. Pond P3 lies approximately 0.5km northeast of the site, within the vicinity of Tandridge Priory, and is separated from the site by paddocks, an area of plantation woodland and the rather busy Barrow Green Road.
4.8.4. Owing to the distances between the ponds and the site, the sub-optimal habitat for Great Crested Newts within the site and the surrounding dispersal barriers, it is considered unlikely that this species would be utilising the site, or indeed disperse into it from more favourable habitat in the wider landscape.
4.8.5. A single Smooth Newt Lissotriton vulgaris was recorded within a 100m grid square at a location approximately 90m north of the site boundary, within the adjacent Oxted Sandpit in 2012.
4.8.6. A Common Frog Rana temporaria was recorded approximately 1.6km northeast of the site boundary in 2009.
4.9. Invertebrates
4.9.1. Given the habitats present, it is likely an assemblage of common invertebrate species utilises the site. There is no evidence to suggest that any rare or notable species would currently be present.
4.9.2. The desk study provided records of five species of invertebrate listed as Species of Principal Importance under the Natural Environment and Rural Communities (NERC) Act 2006 within the vicinity of the site boundary.
4.9.3. A single White Admiral Limenitis camilla was recorded in 1997 at a location approximately 1.3km northwest of the site boundary whilst a Small Blue Cupido minimus was recorded in 1994 approximately 1.2km northwest of the site boundary.
4.9.4. Three Dingy Skipper Erynnis tages and three Grizzled Skipper Pyrgus malvae records were observed in 1998 and 2001 approximately 1.3km and 1.4km north of the site boundary.
4.9.5. Two records for Small Heath Coenonympha pamphilus were returned by the data search; the closest, and more recent, record was observed approximately 0.7km to the east of the site in 2003.
10 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 5. ECOLOGICAL EVALUATION
5.1. The Principles of Ecological Evaluation
5.1.1. The guidelines for ecological evaluation produced by CIEEM propose an approach that involves professional judgement, but makes use of available guidance and information, such as the distribution and status of the species or features within the locality of the project.
5.1.2. The methods and standards for site evaluation within the British Isles have remained those defined by Ratcliffe7. These are broadly used across the United Kingdom to rank sites so priorities for nature conservation can be attained. For example, current Sites of Special Scientific Interest (SSSI) designation maintains a system of data analysis that is roughly tested against Ratcliffe’s criteria.
5.1.3. In general terms, these criteria are size, diversity, naturalness, rarity and fragility, while additional secondary criteria of typicalness, potential value, intrinsic appeal, recorded history and the position within the ecological / geographical units are also incorporated into the ranking procedure.
5.1.4. Any assessment should not judge sites in isolation from others, since several habitats may combine to make it worthy of importance to nature conservation.
5.1.5. Further, relying on the national criteria would undoubtedly distort the local variation in assessment and therefore additional factors need to be taken into account, e.g. a woodland type with a comparatively poor species diversity, common in the south of England, may be of importance at its northern limits, say in the border country.
5.1.6. In addition, habitats of local importance are often highlighted within a local Biodiversity Action Plan (BAP). The Surrey BAP has been considered as part of this assessment and is referenced where relevant.
5.1.7. Levels of importance can be determined within a defined geographical context from the immediate site or locality through to the international level.
5.1.8. The legislative and planning policy context are also important considerations and have been given due regard throughout this assessment.
5.2. Habitat Evaluation
Designated Sites
5.2.1. Statutory Sites. There are no statutory designations of nature conservation value within the site or immediately adjacent to the site. The closest statutory site is Woldingham & Oxted Downs Site of Special Scientific Interest (SSSI), which is located approximately 1.2km to the northwest of the site, at its closest point. The site includes rich chalk grassland, scrub, and mature and secondary woodland, which support
7 Ratcliffe, D A (1977). A Nature Conservation Review: The Selection of Biological Sites of National Importance to Nature Conservation in Britain. Two Volumes. Cambridge University Press, Cambridge.
11 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 many species of characteristic plants and animals, including the rare Roman Snail Helix pomatia, Rufous Grasshopper Gomphocerripus rufus and Stripe-winged Grasshopper Stenobothrus lineatus.
5.2.2. Slightly further afield, Godstone Ponds SSSI is located approximately 1.3km to the southwest of the site, at its closest point. This statutory site contains a large range of wetland habitats, including good examples of a nationally uncommon woodland type (base-rich springline Alder Alnus glutinosa wood) and three ponds. The site also supports a rich community of breeding birds, approximately 54 species in total, including Sedge Warbler Acrocephalus schoenobaenus, Kingfisher, Tufted Duck Aythya fuligula, Coot Fulica atra, Great Crested Grebe Podiceps cristatus, Water Rail Rallus aquaticus and Little Grebe Tachybaptus ruficollis, in addition to a rich invertebrate fauna.
5.2.3. The proposed development is located within the Impact Risk Zone for the above statutory sites; therefore, consideration should be had to the potential adverse indirect impacts of the proposed development on these sites. Should any planning application within this zone include combustion, which owing to the nature of the proposals it would, Natural England consider this to have potential to impact the SSSI through air pollution and any assessment should have consideration to this potential impact.
5.2.4. Natural England was consulted through the Discretionary Advice Service (DAS) for a similar Horizon Cremation scheme in 2018, regarding the scope of potential impacts of the development on Chasewater SSSI, Cannock Extension Canal Special Area of Conservation (SAC) and Cannock Chase SAC. The proposed development in that instance was much closer to the development site than is the case here, being approximately 0.1km away from Chasewater SSSI.
5.2.5. Regarding the scope of the assessment, Natural England’s advice was as follows:
The designated sites needing consideration as part of the air quality assessment will be dictated by a number of criteria (see steps 1-5 below) but initial screening is based on distance. The variables for this screening step in the process comprise the energy requirements for the crematorium and the distance to the designated site(s). We would advise that the following criteria are applied:
• Up to 20MW energy requirement – Assess impacts on any designated sites within 500m • 20-50MW energy requirement – Assess impacts on designated site within 2km • In excess of 50MW energy requirement – Assess impacts on European sites within 10km
For those designated sites falling within the distances quoted above (according to your assessment of the crematorium’s energy requirements) the submitted air quality assessment should address (but not be limited to):
1. Are the designated site’s notified / designated feature sensitive to the hazard? 2. What are the appropriate critical levels and critical loads for the features? 3. Is the magnitude of the effect likely to be significant?
12 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020
4. Is the ‘process contribution’ greater than the relevant threshold alone? 5. Consider existing background levels - Is the ‘predicted environmental concentration’ above the relevant threshold?
5.2.6. An air quality assessment has been undertaken by Phlorum to inform the proposed scheme, taking into consideration the ecological receptors present in the wider landscape and the effects of traffic flows and other factors, as well as the output of the facility itself.
5.2.7. For this proposed development, the total electrical requirement of proposed cremator at full load is expected to be 57kVA and the total natural gas requirement will be 586kW (0.586MW). The combined power requirement is therefore much less than Natural England's minimum threshold for concern for air quality effects. The potential for significant impacts on air quality and nutrient nitrogen deposition within the SSSI were screened out using criteria within Defra’s air emissions risk assessment. Predicted short and long-term impacts were considered to be indistinguishable from natural variations.
5.2.8. Based on the findings of the air quality assessment, is it considered unlikely that the proposed development will give rise to significant changes in air quality that would result in increased adverse effects on the SSSI habitats. Further information is provided in the air quality assessment.
5.2.9. Non-statutory Sites. The site is not subject to any non-statutory designations and there are no non-statutory sites immediately adjacent. The closest such site is Robins Grove Wood & Rye Wood Site of Nature Conservation Importance (SNCI), which is located approximately 0.8km northwest of the site boundary. The site is designated for its ancient semi- natural woodland, containing thirty-six ancient woodland indicators, including Herb Paris Paris quadrifolia.
5.2.10. Glebe Water and Moore's Shaw SNCI lies approximately 1km southwest of the site boundary, separated from the site by open grassland fields and the A25 / Oxted Road. The site contains a mesotrophic lake and marginal fen in addition to Alder Carr woodland in a classic serial succession.
5.2.11. Coney Hill & The Abbeys Potential Site of Nature Conservation Importance (pSNCI) lies less than 0.1km northeast of the site and shares a boundary with Robins Grove Wood & Rye Wood SNCI. No reason for the site’s potential designation has been given.
5.2.12. For the same reasons stated above for the statutory sites, no direct impact is expected to occur on these designated sites as a result of the development, yet best practice guidelines would still be followed to ensure that any potential adverse impacts are minimised. The air quality assessment found that the proposed development would not be likely to have an adverse effect on potential and confirmed non-statutory sites or areas of ancient woodland.
Habitats
5.2.13. The species-poor semi-improved grassland, which occupies the majority of the site, Bracken and scrub / tall ruderal vegetation are of limited intrinsic nature conservation value. The habitats of value in the context of the site
13 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 are the hedgerows and semi-mature trees, especially where these offer suitable nesting opportunities for locally present bird species or potential roosting opportunities for bats.
5.2.14. The semi-mature trees and hedgerows along the boundary of the site are of interest in the context of the site. A loss (approximately 152m) of the hedgerow along the eastern boundary is expected to facilitate access for the development.
5.2.15. This loss will be mitigated for with new native hedgerow planting along the eastern boundary, in addition to native hedgerow planting along part of the northern boundary, offering net gains in hedgerow planting post- development. The existing hedgerow present along the southern boundary will also be bolstered with planting, improving its largely gappy characteristics.
5.2.16. Significant areas of new woodland and species-rich meadow grassland will be established as part of the development of the site. A large portion of the existing grassland will be subject to scarification and over seeding of a native wildflower seed mix and locally sourced wildflower seeds, significantly improving the botanical interest of the site. New native woodland planting will be primarily established within the eastern portion of the scheme and will consist of native tree species of known value to wildlife. It is considered that these habitats will improve the overall green infrastructure through the site, improve connectivity to neighbouring habitats and achieve significant biodiversity net gains post-development.
5.2.17. The inclusion of a new wetland area in the northeast of the site offers further diversity in habitats across the site and improves its overall ecological value. The wetland will be planted with marginal species that could provide potential egg-laying opportunities for amphibians.
5.2.18. A biodiverse green or sedum roof is also being considered as part of the scheme and such a feature would offer additional benefits for a variety of species.
Biodiversity Net Gain
5.2.19. Overall, given the existing ecological interest of the site and the significant potential for wildlife enhancement, it is considered that the development would achieve a 10% Biodiversity Net Gain as a minimum.
5.3. Faunal Evaluation
Bats
5.3.1. Legislation. All bats are protected under Schedule 5 of the Wildlife & Countryside Act 1981 (as amended) and included on Schedule 2 of the Conservation of Habitats and Species Regulations 2017 (“the Habitats Regulations”). These include provisions making it an offence to:
• Deliberately kill, injure or take (capture) bats; • Deliberately disturb bats in such a way as to: - (i) be likely to impair their ability to survive, to breed or rear or nurture their young; or to hibernate or migrate; or
14 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 (ii) affect significantly the local distribution or abundance of the species to which they belong; • Damage or destroy any breeding or resting place used by bats; • Intentionally or recklessly to obstruct access to any place used by bats for shelter or protection (even if bats are not in residence).
5.3.2. While the legislation is deemed to apply when bats are not in residence, Natural England guidance suggests that certain activities such as re- roofing can be completed outside sensitive periods when bats are not in residence provided these do not damage or destroy the roost.
5.3.3. The words deliberately and intentionally include actions where a court can infer that the defendant knew that the action taken would almost inevitably result in an offence, even if that was not the primary purpose of the act.
5.3.4. The offence of damaging (making worse for the bat) or destroying a breeding site or resting place is an absolute offence. Such actions do not have to be deliberate for an offence to be committed.
5.3.5. European Protected Species licences are available from Natural England in certain circumstances, and permit activities that would otherwise be considered an offence.
5.3.6. In accordance with the Habitats Regulations Natural England must apply the three derogation tests as part of the process of considering a licence application. These tests are that:
1. the activity to be licensed must be for imperative reasons of overriding public interest or for public health and safety; 2. there must be no satisfactory alternative; and 3. the favourable conservation status of the species concerned must be maintained.
5.3.7. Licences can usually only be granted if the development is in receipt of full planning permission.
5.3.8. Site Usage. The initial examination of the site did not identify any buildings within the site boundary which could offer opportunities for roosting bats.
5.3.9. All of the trees within the site and adjacent land under the control of the applicant were subject to a ground-based assessment in January 2020, with Trees T1 and T2 being identified as possessing potential to support roosting bats. It is not expected at this stage that these trees will require removal in order to facilitate the development.
5.3.10. The hedgerows and mature trees offer some foraging and dispersal opportunities for bats, with the small element of scrub / tall ruderal vegetation offering limited foraging opportunities.
5.3.11. Mitigation and Enhancements. Further survey work is recommended to evaluate the existing site use by bats and fully assess the potential impacts the proposals may cause.
5.3.12. The survey work would consist of three bat activity transect surveys undertaken across the survey season. The activity transect surveys would
15 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 be bolstered by two static detectors which would be deployed around the site for a period of five nights on three occasions across the survey period. The results of both the activity transects and static bat detector surveys would be set out in an addendum report to be provided to Tandridge District Council on completion of the work.
5.3.13. The trees with identified PRFs are expected to be retained, however, in the event that these trees are required to be felled to facilitate the development, these features would be subject to closer inspection using specialised equipment by a licensed ecologist. Should any evidence of an active bat roost be recorded, a Natural England EPS licence would be required to facilitate the felling of the tree.
5.3.14. While further survey work is recommended the potential adverse effects from the proposals are considered to be minimal. The majority of the development is proposed for the centre of the site, thereby limiting the overall impact on the existing interest for bats. The eastern hedgerow will be lost to facilitate the new access to the site, however replacement native hedgerows, with connectivity to new woodland planting, will be established ensuring that the impacts on connectivity for foraging and commuting bats will be mitigated for and opportunities enhanced.
5.3.15. The southern hedgerow will be retained and enhanced and will continue to offer commuting and foraging resources for locally present bat species. New areas of native woodland and the seeding of wildflower meadow grassland will significantly improve the site’s suitability for foraging and dispersing bats.
5.3.16. A selection of bat boxes, such as Schwegler 1FF Bat Box and Green&Blue Bat Block or similar, will be installed on retained trees and / or incorporated into new buildings to serve as a further enhancement and increase bat roosting opportunities within the site post-development. The provision of new features such as a biodiverse green or sedum roof could also establish a good invertebrate assemblage, and in turn increase the foraging resource for bats.
5.3.17. While the development will be focused primarily within the centre of the site, careful consideration has been given as to the need for lighting and its extent and design. Where strictly necessary, lighting will be provided in active working and security-sensitive areas only. Lighting will be directional and has been designed specifically to avoid upward spill. Mature trees and hedgerows surrounding the site will not be subject to light spillage to ensure that dark corridors for bat activity remain post- development. Overall, the lighting strategy will be in line with current BCT and ILP guidelines8.
Badgers
5.3.18. Legislation. The Protection of Badgers Act 1992 consolidates the previous Badgers Acts of 1973 and 1991. The legislation aims to protect
8 Bat Conservation Trust and Institute of Lighting Professionals (2018) Guidance Note 08/18: Bats and artificial lighting in the UK. ILP, Rugby.
16 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 the species from persecution, rather than being a response to an unfavourable conservation status.
5.3.19. As well as protecting the animal itself, the 1992 Act also makes the intentional or reckless destruction, damage or obstruction of a Badger sett an offence. A sett is defined as “any structure or place, which displays signs indicating current use, by a Badger”. ‘Current use’ is defined by Natural England as any use within the preceding 12 months.
5.3.20. In addition, the intentional elimination of sufficient foraging area to support a known social group of Badgers may, in certain circumstances, be construed as an offence by constituting ‘cruel ill treatment’ of a Badger.
5.3.21. Local Authorities are therefore obliged to consult Natural England over any application that is likely to adversely affect Badgers.
5.3.22. Any work that disturbs Badgers is illegal without a licence granted by Natural England. Unlike the general conservation legislation, the Badgers Act 1992 makes specific provision for the granting of licences for development purposes, including for the destruction of setts.
5.3.23. Guidance produced by Natural England in 2002 developed guidelines on the types of activity that it considers should be licensed within certain distances of sett entrances. For example, using heavy machinery within 30 metres of any entrance to an active sett, and lighter machinery within 20 metres, or light work such as hand digging within 10 metres, all may require a license.
5.3.24. ‘Interim guidance’ issued by Natural England in September 2007 specifically states, “it is not illegal, and therefore a licence is not required, to carry out disturbing activities in the vicinity of a sett if no badger is disturbed and the sett is not damaged or obstructed.”
5.3.25. The guidance goes on to state, “where interference with a sett showing signs of use cannot be avoided during the development, a licence should be sought from Natural England.”
5.3.26. However, this guidance no longer makes reference to any 30m / 20m / 10m radius as a threshold for whether a licence would be required. Nonetheless, it is stated that tunnels may extend for 20m so care needs to be taken when implementing excavating operations within the vicinity of a sett and to take appropriate precautions with vibrations and noise, etc. Fires / chemicals within 20m of a sett should specifically be avoided.
5.3.27. This interim guidance allows greater professional judgment as to whether an offence is likely to be committed by a particular development activity and therefore whether a licence is required or not. For example, if a sett clearly orientates southwards into an embankment it may be somewhat redundant to have a 30 metre-exclusion zone to the north.
5.3.28. It should be noted that a licence cannot be issued until the site is in receipt of a full and valid planning permission and that generally licences are not granted between December and June inclusive to avoid disruption to the Badger breeding cycle.
17 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 5.3.29. Site Usage. Several mammal holes were identified within the hedgerows and beneath the tree line along the western, southern and eastern boundaries of the site, although these are considered to be attributed to Rabbits. No evidence of Badger was observed within the site, although a larger mammal hole, orientating to the north, is present approximately 15m to 20m to the north of the site, along the adjacent embankment, and while there was no evidence of Badger recorded at the entrance, it did hold the characteristics of a Badger sett entrance.
5.3.30. Mitigation and Enhancements. Owing to the orientation and distance of the large mammal hole from the site and proposed development footprint, no specific mitigation is considered necessary. With that said, Badgers are dynamic in nature and it is recommended that a check survey is carried out prior to the commencement of any works as a precaution to ensure that no new setts have been excavated within or immediately adjacent to the site since the initial survey.
5.3.31. In the event that a sett is recorded the project ecologist would take a view as to whether a Natural England licence will be required to close it. This licence would be obtained from Natural England and appropriate mitigation measures implemented according to the particular requirements of the situation. There is no evidence to suggest that such a licence will be required at the time of writing.
5.3.32. The desk study returned records of a number of setts within the locale of the site so the potential exists for Badgers to roam into areas where construction is underway and become trapped in trenches, excavate new setts in piles of subsoil or disturb chemicals that may be being used for development.
5.3.33. All site personnel will be made aware of the potential presence of this species; this will form part of the site induction.
5.3.34. The following measures will be followed throughout the construction phase of development:
• All site personnel will be made aware of the presence of this species and the appropriate steps required to ensure the safety of the Badgers while on site;
• Inclines and mounds of loose soil present ideal habitats for Badgers seeking to establish new setts; therefore, during the construction process, all dug ground and loose soil will be levelled and compacted wherever possible. This will prevent Badgers from attempting to excavate setts prior to completion of the works and causing potential disruption;
• Any mounds of material will be regularly checked for signs of Badgers, especially before disturbance or movement;
• Planks will be left in any uncovered trenches to provide any Badger that may stray onto the site with an escape route;
18 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020
• Any open trenches will be checked at the beginning of each day, to ensure that Badgers are not present, and at the end of each day, to ensure that the means of escape remain in place;
• Tools and loose materials will be stored in an appropriate container in order to reduce the risk of Badgers coming onto site and injuring themselves;
• No fires or chemicals should be left unsupervised anywhere on the site;
• Any open pipework greater than 150mm outside diameter will be blanked off at the end of each working day to prevent Badgers from entering the pipework; and
• Driven piling work will be undertaken only following consultation with the project ecologist.
5.3.35. In the event that any suspected Badger activity is observed during construction, work in the area will cease and Ecology Solutions will be contacted for advice.
5.3.36. For the most part, hedgerows and treelines present within the site will be retained, ensuring both potential foraging and dispersal opportunities for Badgers remain post-development. The provision of new native hedgerow, woodland planting and species-rich grassland will increase the opportunities for this species post-development.
Dormice
5.3.37. Legislation. Dormice are subject to the same level of legislative protection as bats (see above).
5.3.38. Site Usage. The hedgerows within the site are considered to be sub- optimal for this species being leggy in nature and species-poor. However, given the proximity of the site to nearby woodland and a nearby record for Dormice, it is considered that Dormice could be utilising the site.
5.3.39. Mitigation and Enhancements. While suitability for this species within the site is currently considered to be low, the desk study suggests Dormice are present within close proximity to the site and therefore it is recommended that further survey work is undertaken to determine presence or absence of this species. These surveys will consist of the installation of Dormice footprint tunnels, nest tubes and boxes within the hedgerows of the site.
5.3.40. Current Natural England guidance recommends that presence / absence surveys be carried out between April and November utilising Dormice nest tubes and nest boxes installed within the hedgerows. Dormice will readily use them, and examination through regular visits over a number of months can establish presence / absence.
5.3.41. The guidelines rely on a survey effort scoring system with different months given different weighting; an overall effort score of 20 is the threshold for
19 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 a robust assessment. May, August and September are the optimal months for survey (scoring 4, 5 and 7 points respectively) with other months less optimal (June, July, October and November scoring 2 points each and April scoring just 1 point). Monthly checks would be carried out using an appropriate number of tubes and boxes installed in hedgerows and woodland approximately every 20 metres.
5.3.42. The footprint tunnel method is expected to be included as standard practice in the next edition of the survey guidelines. The approach follows recommendations set out by parties such as Suffolk Wildlife Trust9 and has been shown to have a higher detection rate for areas of scrub and hedgerow than the standard nest tube methodology alone. The use of the footprint tunnels also increases the rate of early detection for this species.
5.3.43. The guidance for footprint tunnel surveys states that these should be completed for at least three months, typically between May and October, though the tunnels can be installed as early as late March. Upon completion of the surveys a report would be provided to Tandridge District Council setting out the findings of the survey and an appropriate mitigation strategy.
5.3.44. Replacement native hedgerows are proposed along the eastern and northern boundary to mitigate any loss of this habitat, whilst the remaining hedgerow will be bolstered with native planting. A significant level of native woodland planting will be provided as part of the scheme which, once established, will represent net gains in suitable Dormouse habitat. New native hedgerow planting and woodland planting will include species of known value for Dormice to ensure that opportunities for this species are enhanced post-development.
Hedgehogs
5.3.45. Legislation. Hedgehog is a species of principal importance for the conservation of biodiversity under Section 41 of the NERC Act 2006.
5.3.46. The NERC Act 2006 requires the Secretary of State to:
… take such steps as appear… to be reasonably practicable to further the conservation of the living organisms and types of habitat included in any list published under this section, or… promote the taking by others of such steps.
5.3.47. Site Usage. No evidence of Hedgehogs was recorded during the survey work undertaken, though the desk study provided two records of Hedgehog in the vicinity of the site. The site contains suitable habitat for foraging and dispersal in the form of hedgerows, species-poor semi- improved grassland, scrub and tall ruderal vegetation.
5.3.48. Mitigation and Enhancements. The retention, creation and enhancement of the hedgerows, as part of the proposals, will offer continued opportunities for commuting and foraging Hedgehogs. In addition, new areas of native woodland / tree planting and species-rich
9 Bullion, S., Looser, A. and Langton, S. (2018). An Evaluation of the Effectiveness of Footprint Tracking Tunnels for Detecting Hazel Dormice. In Practice, (101), pp. 36-41.
20 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 wildflower meadows will offer further habitat and foraging opportunities for Hedgehogs.
5.3.49. The provision of ‘Hedgehog Houses’ will be provided and placed in discreet areas to encourage Hedgehogs, along with other small mammals, to settle within the site and provide year-round shelter.
Birds
5.3.50. Legislation. Section 1 of the Wildlife & Countryside Act 1981 (as amended) is concerned with the protection of wild birds, whilst Schedule 1 lists species that are protected by special penalties. All species of birds receive general protection whilst nesting.
5.3.51. Site Usage. A common assemblage of birds was recorded within the site, which supports suitable nesting and foraging habitats for a number of bird species. The main nesting habitats are the semi-mature trees and hedgerows, with some limited opportunities within the small elements of scrub in the southwest and northeast.
5.3.52. Mitigation and Enhancements. The southern hedgerow and semi- mature trees on the boundaries of the site will be retained. The loss of the hedgerow along the eastern boundary will be replaced with new native hedgerow, and a new length of hedgerow will be established along part of the northern boundary, thereby increasing the potential foraging and nesting opportunities for birds.
5.3.53. The proposed landscaping scheme will also provide new areas of woodland planting, comprising fruit-bearing species, the eastern portion of the site that will offer new nesting and foraging opportunities for birds, whilst new areas of species-rich wildflower meadow will increase the invertebrate interest and promote foraging opportunities for birds.
5.3.54. During the site preparation phase, it is recommended that any suitable bird nesting habitat be cleared outside of the nesting season (typically March to July inclusive) to avoid a potential offence under the legislation. Where this cannot be achieved a check survey for nesting birds should be undertaken by an ecologist, with any confirmed nests left in situ until the young have fledged.
5.3.55. A selection of bird boxes, such as Schwegler 1SP Sparrow Terrace, 1B Bird Box, 2GR Nest Box, 3S Starling Nest Box, 17 Swift Box and N24 and N25 Nest Bricks and Green&Blue Swift Block will be installed on retained trees and / or incorporated into new buildings to serve as a further enhancement and offer new nesting opportunities for a variety of bird species. The provision of features such as green walls, biodiverse green and / or sedum roofs could also establish a good invertebrate assemblage, and in turn increase the foraging resource for birds.
Invertebrates
5.3.56. Site Usage. Given the habitats present, it is likely an assemblage of common invertebrate species utilises the site; there is no evidence to suggest that any rare or notable species are currently present. The
21 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 grassland field within the site is thoroughly grazed and hence not considered likely to support a high level of entomological interest.
5.3.57. Mitigation and Enhancements. It is recommended that any new planting consist of native species rather than non-native species, as native species are known to support a greater assemblage of invertebrates which should in turn benefit local bat and bird populations.
5.3.58. Insect boxes, such as Schwegler Clay and Reed Insect Nesting Aid, Schwegler Woodcrete Insect Nesting Aid, Insect Towers or Bee Blocks, will be placed in discreet locations across the scheme to offer new opportunities for invertebrates. Further enhancements will be provided through the establishment of log piles, sourced from future tree management and placed along the site boundaries, to offer new opportunities for saproxylic species.
5.3.59. Biodiverse green or sedum roofs would also improve the floristic diversity for invertebrates and would be considered to be an enhancement post- development if included in the scheme.
22 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 6. PLANNING POLICY CONTEXT
6.1. Planning policy for development in Oxted, Surrey is administrated at two principally levels; nationally through the National Planning Policy Framework (NPPF) and locally through Tandridge District Council Development Plan documents.
6.2. Any proposed development will be judged in relation to the policies contained within these documents.
6.3. National Policy
National Planning Policy Framework (February 2019)
6.3.1. Guidance on national policy for biodiversity and geological conservation is provided by the NPPF, published in March 2012, revised on 24 July 2018 and updated on 19 February 2019. It is noted that the NPPF continues to refer to further guidance in respect of statutory obligations for biodiversity and geological conservation and their impact within the planning system provided by Circular 06/05 (DEFRA / ODPM, 2005) accompanying the now-defunct Planning Policy Statement 9 (PPS9).
6.3.2. The key element of the NPPF is that there should be “a presumption in favour of sustainable development” (paragraphs 10 to 11). It is important to note that this presumption “does not apply where the plan or project is likely to have a significant effect on a habitats site (either alone or in combination with other plans or projects), unless an appropriate assessment has concluded that the plan or project will not adversely affect the integrity of the habitats site” (paragraph 177). ‘Habitats site’ has the same meaning as the term ‘European site’ as used in the Habitats Regulations 2017.
6.3.3. Hence the direction of Government policy is clear; that is, the presumption in favour of sustainable development is to apply in circumstances where there is potential for an effect on a European site, if it has been shown that there will be no adverse effect on that designated site as a result of the development in prospect.
6.3.4. A number of policies in the NPPF are comparable to those in PPS9, including reference to minimisation of impacts to biodiversity and provision of net gains to biodiversity where possible (paragraph 170).
6.3.5. The NPPF also considers the strategic approach that Local Authorities should adopt with regard to the protection, maintenance and enhancement of green infrastructure, priority habitats and ecological networks, and the recovery of priority species.
6.3.6. Paragraphs 174 to 176 of the NPPF comprise a number of principles that Local Authorities should apply, including encouraging opportunities to incorporate biodiversity in and around developments; provision for refusal of planning applications if significant harm cannot be avoided, mitigated or compensated for; applying the protection given to European sites to potential SPAs, possible SACs, listed or proposed Ramsar sites and sites identified (or required) as compensatory measures for adverse effects on European sites; and the provision for the refusal for developments
23 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 resulting in the loss or deterioration of ‘irreplaceable’ habitats – unless there are ‘wholly exceptional reasons’ (for instance, infrastructure projects where the public benefit would clearly outweigh the loss or deterioration of habitat) and a suitable compensation strategy exists.
6.3.7. National policy therefore implicitly recognises the importance of biodiversity and that with sensitive planning and design, development and conservation of the natural heritage can co-exist and benefits can, in certain circumstances, be obtained.
6.4. Local Policy
Tandridge District Core Strategy (Adopted 2008)
6.4.1. The Tandridge District Core Strategy (TDCS) is the overarching document within the Local Plan which sets out the long-term strategic vision for the District. The TDCS also contains a set of key policies within which other more detailed policies can be prepared and set out in future Local Development Documents (LDDs). The Core Strategy was adopted on 15 October 2008 and will be replaced by the emerging Tandridge Local Plan 2033 once this document is adopted.
6.4.2. A single policy is relevant to nature conservation, as detailed below:
6.4.3. Policy CSP 17: Biodiversity. This policy states that developments should protect biodiversity and aim to restore or create suitable semi-natural habitats and ecological networks to sustain wildlife in accordance with the Surrey BAP aims. Downlands Countryside Management Project, Local Nature Reserves and Community Wildlife Areas will also be supported.
Tandridge Local Plan Part 2: Detailed Policies 2014 – 2029 (Adopted 2014)
6.4.4. The Tandridge Local Plan Part 2: Detailed Policies supports the adopted Core Strategy (Part 1 of the Tandridge Local Plan), containing a set of detailed planning policies to be applied locally in the assessment and determination of planning applications over the plan period (2014-2029). The policies replace the remaining ‘saved’ policies from the 2001 Tandridge District Local Plan. The suite of development management policies set out in the Tandridge Local Plan Part 2 will also be partially replaced, where it is necessary, by the Tandridge Local Plan 2033.
6.4.5. Several policies relevant in whole, or part to nature conservation within the Local Plan are detailed below.
6.4.6. Policy DP7: General Policy for New Development. This policy states that landscaping is an integral part of all proposed developments, with provisions for suitable new planting, trees and boundary treatments to enhance the site from the outset. Existing features such as trees and hedgerows should be retained wherever possible and where a new road is required, a suitably hard and/or soft landscaped gap will be required.
6.4.7. The policy also states that landscaping schemes, which makes provision for the retention of existing trees, should be submitted alongside the planning application when important trees are present. If trees are felled,
24 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 then the Council may require replacement planting, as part of any permission granted.
6.4.8. Policy DP10: Green Belt. This policy states that planning permission for any development harmful to the Green Belt, will normally be refused, and that proposals will only be permitted where exceptional circumstances exist.
6.4.9. Policy DP13: Buildings in the Green Belt. This policy states that Tandridge Council will regard the construction of new buildings within the Green Belt as inappropriate, unless very special circumstances can be demonstrated.
6.4.10. Policy DP19: Biodiversity, Geological Conservation and Green Infrastructure. This policy states that development proposals which seek to promote nature conservation and management, restore or create Priority Habitats or protect, enhance or increase the provision of multi- functional Green Infrastructure (GI) will be favoured by the Council.
6.4.11. In addition, proposals which would result in harm to local, national or statutory sites of biological importance or the broader GI network will be refused planning permission unless alternative locations with less harmful impacts are demonstrated to be unsuitable. Otherwise measures to avoid the harmful impacts arising, sufficiently mitigate or compensate for their effects must be incorporated by the proposals.
6.4.12. The granting of planning permission will be wholly exceptional where a proposal is likely to directly or indirectly harm an irreplaceable environmental asset of the highest designation, (i.e. a Site of Special Scientific Interest (SSSI), ancient woodland or veteran trees). Exceptions will only be made where benefits of development at the site clearly outweigh both the impacts on the features of the site and on any broader networks of SSSIs or outweigh the loss of any ancient woodland or veteran trees.
6.4.13. Proposals affecting (directly or indirectly) protected or Priority Species will only be permitted where it can be demonstrated that appropriate mitigation measures will be implemented to prevent possible harm.
6.4.14. Policy DP22: Minimising Contamination, Hazards and Pollution states that applications close to open countryside or intrinsically dark landscapes or areas important for nature conservation must prove that the lighting scheme is the minimum necessary for security, safety or working and that it minimises the potential pollution from glare or spillage.
Emerging Tandridge District Council’s Our Local Plan: 2033
6.4.15. Upon adoption, the new Local Plan will fully replace the existing Core Strategy and partially replace the Detailed Policies. The document was submitted for review in January 2019, but at this stage it is unclear as to when it will be adopted.
6.4.16. Policies relevant in whole or part to nature conservation within the future Local Plan are detailed below.
25 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 6.4.17. Policy TLP03: Green Belt states that planning permission for any inappropriate development harmful to the Green Belt, will be refused and would only be permitted where very special circumstances exist, to the extent that other considerations visibly outweigh any potential harm.
6.4.18. Policy TLP30: Green and Blue Infrastructure is concerned with protecting, enhancing and managing the existing green and blue infrastructure within the District. Developments should seek to provide a net gain, including suitable biodiversity, habitats and wildlife corridors whilst buffering those already in place.
6.4.19. Policy TLP35: Biodiversity, Ecology and Habitats states that development proposals should protect biodiversity and natural habitats and contribute to the wider Green and Blue Infrastructure (see above). Proposals should demonstrate a net gain in biodiversity, with schemes aiming to restore or create appropriate wildlife habitats and ecological networks; in addition, opportunities for Priority Habitat creation and restoration will be sought.
6.4.20. Proposals likely to adversely affect a SSSI, LNR, SNCI or pSNCI will not be permitted unless the benefits of the development outweigh the adverse impacts on the designated site and any adverse impacts on the wider biodiversity network. Where adverse impacts are unavoidable, the impacts must be adequately and proportionately mitigated; compensation will be required as a last resort.
6.4.21. Policy TLP37: Trees and Soft Landscaping states that the loss of trees, woodlands, hedgerows and vegetation of significant amenity or ecological value should be opposed, whilst existing trees, hedgerows and vegetation should be positively integrated into the site layout and protected in accordance with BS5837:2012.
6.4.22. Replacement planting is to be provided where trees have been removed prior to planning permission being granted. Where there is evidence of deliberate neglect / damage to trees or woodland assets, then the deteriorated state of the asset will not be taken into account in any decision.
6.4.23. New developments are expected to positively integrate space for additional trees, hedgerows and vegetation within layout design in addition to improving links between green spaces.
6.4.24. Developments which result in the loss / deterioration of ancient woodland and the loss of aged or veteran trees found outside ancient woodland (including from indirect impacts such as increased visitor pressure), will result in the refusal of planning permission, unless the need for the development in that location outweigh the loss and a suitable compensation strategy exists.
6.5. Discussion
6.5.1. The proposals for the site would be judged against the policies summarised above. Overall, it is considered that the development site is of low ecological interest with the exception of the hedgerows and trees. Further survey work has been recommended to determine the presence
26 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 of protected species within the site. The development of the site has the scope to offer significant enhancements to the existing habitats and increase opportunities for the local wildlife, achieving net gains in biodiversity and meeting the relevant policy requirements.
27 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 7. SUMMARY AND CONCLUSIONS
7.1. Ecology Solutions was commissioned in January 2020 by Horizon Cremation to undertake an ecological assessment of land off Oxted Road, Oxted, Surrey.
7.2. The site is to be subject to planning application for a crematorium with associated access, landscaping and parking infrastructure. The site was subject to an extended Phase 1 habitat survey in January 2020; a desk-based study was also undertaken to inform this assessment.
7.3. Statutory Sites. There are no statutory designations of nature conservation value within the site or immediately adjacent to it. The closest statutory site is Woldingham & Oxted Downs SSSI, which is located approximately 1.2km to the northwest of the site, at its closest point. Further afield, Godstone Ponds SSSI is located approximately 1.3km to the south of the site, at its closest point.
7.4. The proposed development falls within the Impact Risk Zones associated with the aforementioned SSSIs with air quality raised as a potential impact. An air quality assessment has been undertaken by Phlorum to inform the scheme which has concluded that predicted short and long-term impacts are considered to be indistinguishable from natural variations.
7.5. Based on this, is it considered unlikely that the proposed development will give rise to significant changes in air quality that would result in increased adverse effects on the SSSI habitats. Further information is provided in the air quality assessment.
7.6. Non-statutory Sites. The site is not subject to any non-statutory designations and there are no non-statutory sites immediately adjacent. The closest such site is Robins Grove Wood & Rye Wood SINC which is located approximately 0.8km northwest of the site boundary. Glebe Water and Moore's Shaw SNCI lies approximately 1km southwest of the site boundary, separated from the site by open grassland fields and the A25 / Oxted Road.
7.7. It is not considered that any adverse impact will occur on the non-statutory sites in close proximity to the site, however it is recommended that best practice measures be followed throughout the construction phase of the development to minimise the risk of any pollution occurring. The air quality assessment found that the proposed development would not be likely to have an adverse effect on potential and confirmed non-statutory sites or areas of ancient woodland.
7.8. Habitats. The horse-grazed, species-poor, semi-improved grassland and scrub / tall ruderal vegetation are of limited intrinsic nature conservation value. The habitats of value in the context of the site are the hedgerows and more mature trees.
7.9. The hedgerow along the eastern boundary will be lost in order to facilitate access for the development, however the remaining hedgerow will be protected, bolstered and retained. New hedgerow planting will provide replacement habitats for any loss that occurs and should comprise native species of local provenance of known benefit to wildlife.
7.10. Additional new landscape planting, such as areas of native woodland, tree-lined walkways, species-rich wildflower meadow grassland, wetland and formal amenity planting will provide new opportunities for a range of species. A
28 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 biodiverse green or sedum roofs on proposed buildings could also provide enhancements.
7.11. Overall, given the existing ecological interest of the site and the significant potential for wildlife enhancement, it is considered that the development would achieve a 10% Biodiversity Net Gain as a minimum.
7.12. Bats. Two trees within the site were identified as possessing potential to support roosting bats. These trees are expected to be retained, however, in the event that the trees are required to be felled, they should be subject to a further assessment by experienced bat worker. Should any evidence of an active bat roost be recorded, a Natural England EPS licence would need to be obtained to facilitate the felling of the tree.
7.13. The hedgerows and trees on the boundaries of the site offer good foraging and dispersing opportunities for bats. While the loss of a hedgerow along the eastern boundary of the site is expected, this will be replaced with a new native hedgerow which will extend along the northern boundary. Given the location of the proposed development within the site, and minimal loss of existing features of interest, it is considered that the impacts on bats would be limited.
7.14. Further bat activity transect surveys are recommended. These would be undertaken three times across the survey period, adhering with current guidelines for a site with low suitability for bats. The surveys will be bolstered by the deployment of two static bat detectors placed around the site for a period of five nights. A report of the findings would be provided.
7.15. Habitat enhancements, such as native woodland planting, and the provision of bat boxes will offer new opportunities post-development. The lighting scheme for future developments within the site has also been designed with current guidance and has due regard for bats ensuring dark corridors are retained.
7.16. Badgers. Surveys for Badger were undertaken in January 2020. No evidence of Badgers was noted, although a large mammal hole was observed off-site to the north. A Badger survey should be undertaken prior to any construction work to ensure no new setts have been excavated since the initial surveys. Safeguards should also be employed throughout the construction phase of the development to ensure that no harm or entrapment to this species occurs.
7.17. The proposals for the site would retain any potential existing interest for this species whilst new native landscaping, including native, thorny, fruit-bearing species, will offer new foraging opportunities post-development.
7.18. Dormice. Sub-optimal opportunities are present for Dormouse within the hedgerows. Owing to the loss of a hedgerow, it is recommended that further survey work be undertaken, employing the use of footprint tunnels alongside the standard nest tubes and nest boxes. Deployment of the tunnels, nest tubes and boxes would be undertaken with surveys undertaken in accordance with survey guidance. Upon completion of the surveys a report would be provided to Tandridge District Council setting out the findings of the surveys and an appropriate mitigation strategy.
7.19. Hedgehogs. No evidence of Hedgehogs was recorded during the survey work undertaken. The retention and enhancement of the hedgerows will provide continued opportunities for commuting and foraging Hedgehogs, whilst the
29 Horizon Cremation, Oxted Road, Oxted, Surrey Ecology Solutions Ecological Assessment 8731.EcoAs.vf March 2020 establishment of new native landscaping, such as wildflower meadow grassland and woodland planting, will improve the site’s suitability for this species. The provision of ‘Hedgehog Houses’ will encourage Hedgehogs to settle within the site and provide year-round shelter.
7.20. Birds. A small assemblage of common bird species was identified during survey work. The trees, small area of scrub / tall ruderal vegetation and hedgerows offer nesting and foraging opportunities for birds.
7.21. During the site preparation phase, it is recommended that any suitable bird nesting habitat be cleared outside of the nesting season (typically March to July inclusive) to avoid a potential offence under the legislation. Where this cannot be achieved a check survey for nesting birds should be undertaken by an ecologist, with any confirmed nests left in situ until the young have fledged.
7.22. The proposed landscape planting, such as woodland and new hedgerow planting, will be based around native fruit bearing plant species and species of known wildlife value, to offer new foraging and nesting opportunities post- development. More substantial features such as biodiverse green or sedum roofs would offer additional foraging and nesting opportunities. Additional enhancements will include the installation of bird boxes on retained trees and / or new buildings.
7.23. Reptiles. The habitats within the site are not considered to be suitable for reptiles, comprising heavily grazed grassland which lacks any characteristics typically favoured by this group. While no mitigation is required, the proposals will likely improve the suitability for reptiles post-development through the establishment and relaxed management of new habitats.
7.24. Amphibians. No amphibians were recorded during the survey undertaken. Limited terrestrial opportunities are present, which are largely confined to the hedgerows. Three ponds are located within 500m of the site, but with limited connectivity to these ponds and limited opportunities for Great Crested Newts within the site, it is considered unlikely that this species would be present and no mitigation or further survey work is considered necessary. A new wetland area is proposed in the northeast of the site which, through the provision of new native aquatic and emergent planting, could offer new opportunities for amphibians post-development.
7.25. Invertebrates. Given the habitats present, it is likely a varied assemblage of common invertebrate species utilises the site. There is no evidence to suggest that any rare or notable species would currently be present. Landscape planting will improve the floristic diversity for invertebrates, increasing nectar resources post-development. The provision of log piles and insect hotels will also offer further enhancements for this group.
7.26. In conclusion, the survey work undertaken to date has identified the site as being of limited ecological value. The proposed loss of a hedgerow to facilitate the proposals will be offset through the provision of new replacement habitats and bolstering of retained features which aim to significantly improve the site’s ecological interest. Further survey work is recommended in respect of certain species and groups in order to devise mitigation strategies as appropriate, but overall effects are expected to be minimal given the nature of the proposed development. The development has scope to offer significant biodiversity net gains and meet with all relevant planning policy.
30 PLANS PLAN ECO1 Site Location and Ecological Designations
PLAN ECO2 Ecological Features
PLAN ECO3 Pond Locations
PHOTOGRAPHS PHOTOGRAPH 1: Heavily grazed semi-improved grassland
PHOTOGRAPH 2: Hedgerow H1 and recently managed Bracken PHOTOGRAPH 3: Hedgerow H2
PHOTOGRAPH 4: Tree line T1 APPENDICES APPENDIX 1 Information downloaded from the Multi-Agency Geographic Information for the Countryside (MAGIC) website 8731: HORIZON CREMATION, OXTED ROAD, OXTED, SURREY
Legend Sites of Special Scientific Interest (England) SSSI Impact Risk Zones - to assess planning applications for likely impacts on SSSIs/SACs/SPAs & Ramsar sites (England) Special Areas of Conservation (England) Special Protection Areas (England)
0 0.5 1
km
Projection = OSGB36
xmin = 527000 0 0.7 5 1.5 ymin = 147400
xmax = 547300 km ymax = 156800 Map produced by MAGIC on 24 February, 2020. Copyright resides with the data suppliers and the map must not be reproduced without their permission. Some information in MAGIC is a snapshot of the information (c) Crown Copyright and database rights 2020. Ordnance Survey 100022861. that is being maintained or continually updated by the originating organisation. Please refer to the metadata for details as information may be illustrative or representative rather than definitive at this stage. Part of the ES Group
Ecology Solutions Limited Cokenach Estate Barkway Royston Hertfordshire SG8 8DL
01763 848084 [email protected] www.ecologysolutions.co.uk
ecology solutions for planners and developers