FRIDAYS LTD

ENVIRONMENTAL ASSESSMENT

NON TECHNICAL SUMMARY

PROPOSED POULTRY REDEVELOPMENT

AT

TOLEHURST FARM, CRANBROOK ROAD, KNOXBRIDGE, CRANBROOK, TN17 2BP

Prepared By:-

BRIAN BARROW BSc (Hons) MRICS Managing Director Acorus Rural Property Services Ltd Old Market Office 10 Risbygate Street Bury St Edmunds Suffolk, IP33 3AA

Tel: 01284 753271 Email: [email protected]

February 2019

Non Technical Summary 1. INTRODUCTION

This non technical summary document has been produced to summarise the issues, mitigation measures and effects relating to the proposed erection of 2 poultry buildings at Tolehurst Farm.

In terms of effects these have been graded as follows:-

None The development will not produce any effects beyond those which may be experienced within the current farming regime.

Low There will be an effect, this will be localised and will not impact on environmental and other features to their detriment when relating to existing uses (e.g. distance too far).

Medium There will be an effect which will impact on environmental features, but not significantly.

High A significant effect.

2. BACKGROUND

There are currently 2 poultry rearing sheds housing 13,500 birds each. In addition there are 96,000 laying birds housed in 2 buildings to the south of the site built 4 years ago.

In addition to the above production buildings there are two dwellings owned by the company and occupied by Fridays employees.

The site has an access from the East linking to the public highway.

3. THE PROPOSAL

Planning permission was obtained to construct two new poultry sheds to replace seven laying sheds. The sheds have since been constructed and are operational (Phase 1).

The proposal for Phase 2 is to demolish the existing rearing sheds to the north of the site which have a total floor area of 1,302 m² and erect 2 new rearing houses, each 120 m x 26.66 m which will have a total floor area of 6,398.4 m².

The new rearing buildings can be used to rear birds for three laying systems, Colony, Barn and RSPCA Assured Free Range. The number of birds to be housed in the sheds depends on the system used and will range from 138,864 to 322,560 birds.

Non Technical Summary

The scheme has been designed to take into account the potential environmental effects. The following elements form part of the Environmental Impact Assessment:-

Landscape Assessment Flood Risk Assessment Airborne Pollution, Including Odours and noise Ecological Impact Dirty and Clean Water Disposal Highways Archaeology

The impacts related to these issues are summarised in the following section.

Non Technical Summary 4. ENVIRONMENTAL IMPACT

The main impacts of the development is summarised as follows:-

4.1 CLEAN/DIRTY WATER AND FLOOD RISK

Issue Mitigation Measures Effect Assuming Mitigation

Pollution from dirty A total containment system is None – All dirty water and water run off proposed for collecting dirty water potentially contaminated rain from washing down. Disposal off water will be collected. site will be in accordance with Codes of Practice. Disposal of litter Used as organic fertiliser or sent None/Low –Poultry manure to anaerobic digester (AD) plant. reduces the need for non organic Sheeted lorries or trailers will be fertiliser and disposal is covered used. by Codes of Good Practice and Nitrate Regulations. Likely reduction of imported organic manures. AD plants are specifically designed to take manure. Clean water disposed System to be installed None/Low. Water will be incorporating water attenuation released at the current rate. Flood Risk Zone 1 Low – the land is in a low risk flood area

4.2 HIGHWAYS

Issue Mitigation Measures Effect Assuming Mitigation

Volume of traffic in The site already has agricultural Low – similar traffic. relation to dwellings traffic associated with its present use. Volume of traffic in The site is an existing poultry Low – The number of proposed relation to road unit. Traffic movement’s to the vehicles are low and of identical network proposed new rearing sheds will type to historical use. be low. Access point Site access already used for None/low– road network able to access by the business by take additional traffic. agricultural and other vehicles

Non Technical Summary 4.3 ODOURS, DUST AND NOISE

Issue Mitigation Measures Effect Assuming Mitigation

Odours Modern purpose designed Low, odour model plume shows buildings with high velocity fan that it is below the threshold outlets. Dirty water containment stipulated by the Environment system. Manure will be removed Agency. offsite. Distance from dwellings. Dust Existing landscaping Low – Distances significant, better location than the existing sheds. Noise New modern fans and insulation Low – Noise ratings of fans low replacing poor quality existing in relation to typical rural noises. buildings. Delivery and collection lorries have higher noise reading however this is short lived and distances are significant. Pests Full pest control programme to be None – Pests create problems to implemented. Careful use of operation, and it is in the chemicals to avoid damage to interest of operators to control wildlife. anyway.

4.4 LANDSCAPE

Issue Mitigation Measures Effect Assuming Mitigation

Visual impact of Limited visibility into site, sited Low. buildings within established poultry farm. Existing well established landscaping. Visual Impact from There are is a nearby footpath. Low. footpath However there is very limited The unit is in the vicinity of visibility into the site. existing agricultural and similar development

Non Technical Summary

4.5 ECOLOGY

Issue Mitigation Measures Effect Assuming Mitigation

Land use/ecology Agricultural land in arable use Low with low ecological value. Ammonia New housing with high speed, Low – no material changes high level ventilation. predicted from the current permitted levels.

4.6 ARCHAEOLOGY

Issue Mitigation Measures Effect Assuming Mitigation

Impact on Very little archaeological potential. None archaeological In vicinity of well preserved remains Roman road but this will not be directly impacted upon by proposed development.

5. ALTERNATIVES

The only alternatives are different layouts on the site or a different site on the farm, which were looked at. There are no alternative layouts or sites that would be better than the proposed given the well enclosed site.

6. CONSTRUCTION

There will be minimal disruption during construction of the unit.

This will take approximately 12 months and individual tasks will be over relatively short periods and will not have any significant environmental effects.

Non Technical Summary 7. CONCLUSION

The proposed development is to redevelop a poultry unit. The proposal will meet increasing welfare and environmental considerations including adhering to Best Available Techniques (BAT) as required by the Environment Agency. It is supported in policy terms.

The proposal makes best use of available sites. The design takes into account operational requirements and potential environmental effects.

From the information appraised through the Environmental Impact Assessment it is clear that the proposed development will have a low overall impact on the environment taking into account the mitigation measures proposed.

Non Technical Summary

C H A R T E R E D S U R V E Y O R S & P L A N N I N G C O N S U L T A N T S

THE OLD MARKET OFFICE – 10 RISBYGATE STREET – BURY ST EDMUNDS – SUFFOLK – IP33 3AA

Environmental Statement for:

PROPOSED POULTRY REDEVELOPMENT at TOLEHURST POULTRY FARM

Report prepared for:

FRIDAYS LTD

February 2019

NAME OF ORGANISATION

Acorus Rural Property Services Ltd – known as Acorus (Registered number 04514547)

OVERVIEW OF ORGANISATION

Acorus Rural Property Services Limited are a privately owned firm of Chartered Surveyors and Planning Consultants specialising in Rural Development.

Acorus has four offices nationwide of which the South and South East office operates from The Old Market Office, 10 Risbygate Street, Bury St Edmunds.

CONTACTS

Mr Brian R Barrow BSc (HONS) MRICS Managing Director Acorus Rural Property Services Limited The Old Market Office 10 Risbygate Street Bury St Edmunds IP33 3AA

Office: 01284 753271 Fax: 01284 748750 Mobile: 07774 972627

Email: [email protected]

Louise Gregory Rural Planning Consultant Acorus Rural Property Services Limited The Old Market Office 10 Risbygate Street Bury St Edmunds IP33 3AA

Office: 01284 753271 Fax: 01284 748750

Email: [email protected]

CONTENTS

SECTION TOPIC

TERMS OF REFERENCE

1 INTRODUCTION

1.1 Purpose of report 1.2 Scope of report 1.3 Initial consultation

2 SUMMARY OF PROPOSAL

3 BACKGROUND

3.1 Existing Site 3.2 Current Production 3.3 Current Condition 3.4 Supply Chain

PHYSICAL CHARACTERISTICS

3.5 Site Topography 3.6 Local Landscape 3.7 Land Grading 3.8 Present Cropping 3.9 Flood Risk

NEARBY BUILDINGS AND DWELLINGS

3.10 Surrounding properties and uses (1KM radius) 3.11 Surrounding towns and villages

ACCESS & ROAD NETWORK

3.12 Road network 3.13 Access 3.14 Footpaths

ECOLOGY

3.15 On site ecology (Phase 1 survey) 3.16 Local ecology (2KM radius) 3.17 Other designations (2KM radius)

PLANNING ADVISE & HISTORY

3.18 Planning history 3.19 Present applications in the locality 3.20 Planning policy

4 DETAILS OF PROPOSAL

4.1 Description of the proposed rearing enterprise 4.2 Layout of the site 4.3 Building construction 4.4 Husbandry and equipment 4.5 Labour 4.6 Litter

5 ITEMS TO BE ASSESSED

6 WATER DISPOSAL

6.1 Background 6.2 Clean Water 6.3 Dirty Water 6.4 Maintenance 6.5 Summary

7 FLOOD RISK

8 AIRBOURNE POLLUTION

8.1 Odours 8.2 Dust concentrations and emissions 8.3 Flies 8.4 Vermin 8.5 Noise

9 ECOLOGY

9.1 On and off site 9.2 Arboricultural Implications

10 HIGHWAYS AND TRAFFIC STATEMENT

10.1 Road network 10.2 Site access 10.3 Traffic movements 10.4 Mitigation 10.5 Impact 10.6 Impact on footpaths

11 LANDSCAPE IMPACT

12 PREVIOUS LAND USE/CONTAMINATION

13 ARCHAEOLOGY

14 ALTERNATIVES

15 CONSTRUCTION PHASE

16 CONCLUSIONS

APPENDICES

APPENDIX 1 SCOPING OPINION

APPENDIX 2 NATIONAL CHARACTER AREA

APPENDIX 3 PHASE 1 ECOLOGY SURVEY

APPENDIX 4 PROPOSED SITE LAYOUT

APPENDIX 5 FLOOD RISK ASSESSMENT

APPENDIX 6 ODOUR ASSESSMENT

APPENDIX 7 AMMONIA ASSESSMENT

APPENDIX 8 LANDSCAPE ASSESSMENT

APPENDIX 9 ARCHAEOLOGY REPORT

TERMS OF REFERENCE

Fridays Ltd has asked Acorus Rural Property Services to collate an Environmental Statement to be used in conjunction with his proposed planning application to erect new poultry buildings at Tolehurst Poultry Farm.

The report has been collated by B R Barrow BSc (Hons) MRICS and draws on technical information supplied by:

John Bailey - Acorus Rural Property Services Ltd James Hodson - Eco Check Consultancy Steve Smith and Phil Edgington – AS Modelling and Data Graham Hinton - Cedar Land Management Graham Fuller – Fridays Limited

1 INTRODUCTION

1.1 Purpose of the report

Acorus was requested by Fridays Ltd to undertake an Environmental Impact Assessment, which would identify the environmental effects of a proposed poultry unit upgrade involving the replacement of 2 poultry rearing sheds with 2 larger ones.

The report is intended to:-

1. Establish existing conditions on the site and surrounding area. 2. Identify and assess the environmental impact of the proposed rearing sheds. 3. Identify any measures necessary to mitigate adverse effects if appropriate.

1.2 Scope of the report

The report has been written as an Environmental Statement under the Town and Country Planning (Environmental Impact Assessment) Regulations 2017.

This development is a Schedule 1 development by virtue of being an installation for the rearing of poultry with more than 60,000 places for hens.

1.3 Initial consultation

A scoping opinion was sought by Mr Brian Barrow of Acorus Rural Property Services Ltd from Tunbridge Wells Borough Council, which is contained at Appendix 1. This was for a larger scheme for which phase 1 is now complete.

This statement has taken account of the initial scoping and the discussions during the phase 1 process.

2 SUMMARY OF PROPOSAL

Tolehurst Farm was built as a free range unit in the 1980’s. At that time free range units were small in scale in terms of shed size, although this farm contained a number of sheds.

Planning permission was granted on 20 September 2013 for the replacement of 7 existing poultry buildings with 2 new poultry buildings, together with associated landscaping and amendments to access (ref: 13/01965/FULMJ/TA1) – Phase 1.

This proposal is for the demolition of two additional rearing buildings to the north of the site which are small and in a poor state of repair and erect 2 larger modern sheds constructed to latest industry standards sited further away from residential properties – Phase 2.

3. BACKGROUND

3.1 Existing Site

There are currently 2 poultry rearing sheds housing 13,500 birds. In addition there are 96,000 laying birds housed in 2 buildings to the south of the site (Phase 1 now complete).

In addition to the above production buildings there are two dwellings owned by the company and occupied by Fridays employees.

The site has an access from the East linking to the public highway.

The existing sheds are as follows:-

Shed Bird No. System Type Dimensions No. (metres) H x L x W

1 6750 Rearing Roof inlet side 4.5 x 43 x 14 exhaust 2 6750 Rearing Side inlet roof exhaust 4.5 x 50 x 14

3 64,000 Free range High Speed Fans 6 x 260 x 20.5

4 32,000 Free range High Speed Fans 6 x 136 x 20.5

Photograph – Existing Rearing Sheds

3.2 Current Production

The current site at Tolehurst Farm forms one of several owned by Fridays Ltd. It involves both laying hens producing eggs and the rearing of hens to stock laying units.

The laying sheds were replaced approximately 4 years ago. The hens have access to grass at the rate of 1 hectare per 2,000 birds.

The rearing sheds are circa 40 years old and house birds inside only to produce point of lay pullets, which are moved to laying units either on site, or on other farms owned.

3.3 Current Condition

The site is only part operational, the standard of construction on the rearing sheds is no longer suitable for modern day requirements with one partly collapsed.

The small scale of the sheds makes repair and the installation of modern equipment uneconomic, and this means the birds per shed/flock are limited.

3.4 Supply Chain

The pullets reared on the farm will be utilised by Fridays across their farms in the South East of England.

The eggs produced on the farm from phase 1 are currently supplied to Fridays own packing station, which supplies major supermarkets.

Physical Characteristics

3.5 Site topography

The proposed site lies at co-ordinates 578499, 139963 or National Grid Reference TQ 785 399.

A site check of the holding against data provided by the Multi‐Agency Geographic Information for the Countryside (MAGIC) Interactive Map shows the soilscape of the site and land designations to be as follows:

Soilscape (England)

Main Surface Natural Natural Characteristic Semi- Reference Name Main Land Cover Texture Drainage Type Fertility natural Habitats Class ARABLE, LOAMY SOILS WITH WET ACID MEADOWS NATURALLY GRASSLAND 22 NATURALLY HIGH LOAMY LOW AND PASTURES AND WET AND GROUNDWATER WOODLAND WOODLAND WIDE RANGE OF PASTURE AND SLIGHTLY ACID LOAMY SLIGHTLY MODERATE GENERALLY ARABLE AND 8 AND CLAYEY SOILS WITH LOAMY IMPEDED TO HIGH BROADLEAVED AND GRASSLAND IMPEDED DRAINAGE DRAINAGE MIXED WOODLAND TYPES SLOWLY PERMEABLE GRASSLAND SEASONALLY WET LOWLAND SEASONALLY IMPEDED AND ARABLE 18 SLIGHTLY ACID BUT BASE- LOAMY MODERATE WET PASTURES AND DRAINAGE SOME RICH LOAMY AND CLAYEY WOODLANDS WOODLAND SOILS

3.6 Local landscape

A 2KM search was undertaken from the site for relevant local landscape designations as maintained from DEFRA databases.

DESIGNATION/ DISTANCE DESIGNATION DESIGNATION NOT SEARCHED PRESENT PRESENT Ancient woodland X AONB X Community Forests X National Parks X Nitrate Sensitive Areas X Nitrate Vulnerable Zones X Registered Common Land X Registered Parks & Gardens X National Character Areas X Green Belt X

Breakdown of features found: Ancient Woodland (England) Grid Reference Wood Name Theme ID Theme Name tq786394 BREWERS WOOD 1450958 ANCIENT & SEMI-NATURAL WOODLAND tq778387 HILLY AND FRIEZLEY WOOD 1451053 ANCIENT & SEMI-NATURAL WOODLAND tq800408 DUCK PIT WOOD 1450263 ANCIENT & SEMI-NATURAL WOODLAND tq795388 NUT WOOD 1450875 ANCIENT & SEMI-NATURAL WOODLAND tq770388 CATSTAIL WOOD 1450579 ANCIENT & SEMI-NATURAL WOODLAND tq802392 PARK WOOD 1450216 ANCIENT & SEMI-NATURAL WOODLAND tq796403 GRAND SHORE WOOD 1450456 ANCIENT & SEMI-NATURAL WOODLAND tq778391 NICHOLS WOOD 1450564 ANCIENT & SEMI-NATURAL WOODLAND tq803400 1450798 ANCIENT & SEMI-NATURAL WOODLAND

tq782379 1451060 ANCIENT & SEMI-NATURAL WOODLAND

tq780380 1450970 ANCIENT REPLANTED WOODLAND

tq801418 MAPLEHURST FARM WOOD 1122449 ANCIENT & SEMI-NATURAL WOODLAND tq800390 SISSINGHURST PARK WOOD 1450562 ANCIENT & SEMI-NATURAL WOODLAND tq786392 BREWERS WOOD 1450957 ANCIENT REPLANTED WOODLAND tq793398 1450235 ANCIENT & SEMI-NATURAL WOODLAND

tq769383 COUCHMANS WOOD 1451002 ANCIENT & SEMI-NATURAL WOODLAND tq779386 HILLY AND FRIEZLEY WOOD 1450960 ANCIENT REPLANTED WOODLAND tq778390 NICHOLS WOOD 1450563 ANCIENT & SEMI-NATURAL WOODLAND tq776381 HILLY AND FRIEZLEY WOOD 1451054 ANCIENT & SEMI-NATURAL WOODLAND tq793402 GRAND SHORE WOOD 1450252 ANCIENT & SEMI-NATURAL WOODLAND tq785379 1450872 ANCIENT & SEMI-NATURAL WOODLAND

tq797395 FOXEARTH WOOD 1450551 ANCIENT & SEMI-NATURAL WOODLAND tq798402 BIRCH WOOD 1450406 ANCIENT & SEMI-NATURAL WOODLAND tq781379 1450971 ANCIENT REPLANTED WOODLAND

tq774392 POND WOOD 1450959 ANCIENT REPLANTED WOODLAND tq798400 ELEVEN ACRE WOOD 1450444 ANCIENT & SEMI-NATURAL WOODLAND tq783395 BREWERS WOOD 1450223 ANCIENT & SEMI-NATURAL WOODLAND tq804403 1450797 ANCIENT & SEMI-NATURAL WOODLAND

tq803395 SEVEN PIT WOOD 1451000 ANCIENT & SEMI-NATURAL WOODLAND tq787396 SAUNDERS WOOD 1450552 ANCIENT & SEMI-NATURAL WOODLAND tq803399 VINCENT WOOD 1450538 ANCIENT & SEMI-NATURAL WOODLAND tq778379 BREACH WOOD 1450175 ANCIENT & SEMI-NATURAL WOODLAND tq766402 BOWLING ALLEY WOOD 1450452 ANCIENT & SEMI-NATURAL WOODLAND tq800404 1450796 ANCIENT & SEMI-NATURAL WOODLAND

tq768398 ROCK WOOD 1450423 ANCIENT & SEMI-NATURAL WOODLAND tq804394 SISSINGHURST PARK WOOD 1450800 ANCIENT & SEMI-NATURAL WOODLAND tq792397 REEVES WOOD 1450955 ANCIENT REPLANTED WOODLAND tq795386 NUT WOOD 1450876 ANCIENT & SEMI-NATURAL WOODLAND tq780386 HILLY AND FRIEZLEY WOOD 1451055 ANCIENT & SEMI-NATURAL WOODLAND tq772388 CATSTAIL WOOD 1450440 ANCIENT & SEMI-NATURAL WOODLAND tq784402 TOLLHURST WOOD 1450249 ANCIENT REPLANTED WOODLAND tq781393 BREWERS WOOD 1450956 ANCIENT & SEMI-NATURAL WOODLAND tq775390 POND WOOD 1451052 ANCIENT & SEMI-NATURAL WOODLAND tq800388 SISSINGHURST PARK WOOD 1450561 ANCIENT REPLANTED WOODLAND

tq803405 1451016 ANCIENT & SEMI-NATURAL WOODLAND tq779419 GOOSEBERRY WOOD 1120253 ANCIENT REPLANTED WOODLAND tq802387 SISSINGHURST PARK WOOD 1450437 ANCIENT & SEMI-NATURAL WOODLAND tq799394 1450799 ANCIENT & SEMI-NATURAL WOODLAND tq791396 REEVES WOOD 1450954 ANCIENT & SEMI-NATURAL WOODLAND

Nitrate Vulnerable Zones (England) NVZ TYPE NVZ AREA

Registered Parks and Gardens (England) Legacy UID Name Grade Reference Scale of capture Date of registration

2311 HARTRIDGE HOUSE II 1001289 1:10000 Tue, 14 Dec 1993 00:00:00 UTC

National Character Areas (England) Referenc Name Hotlink e LOW HTTP://WWW.NATURALENGLAND.ORG.UK/OURWORK/LANDSCAPE/ENGLANDS/CHARACTER/AREAS/LOW_ 121 WEAL .ASPX D HIGH HTTP://WWW.NATURALENGLAND.ORG.UK/OURWORK/LANDSCAPE/ENGLANDS/CHARACTER/AREAS/HIGH_ 122 WEAL WEALD.ASPX D

Further information regarding the National Character Areas can be found in Appendix 2.

3.7 Land grading

Land is graded as grade 3 land, and is thought likely to be of average agricultural quality.

3.8 Present cropping

The land is all under grass and grazed by the hens.

3.9 Flood Risk

The Environments Agency Flood Map shows the property to be outside of the flood risk zone.

3.10 Surrounding properties and uses

There are three farms in the vicinity of the site –

Paley Farm 808 m West Roack Farm 725 m East Saunders Farm 898 m SE

There are 3 dwellings less than 400 m away on the Northern side –

Tolehurst cottage Ian Cottage Gordon Cottages

There are various residential Dwellings more than 400 m but less than 1 km away –

Well House 141 m N Bumbles 492 m NE Various un-named dwellings 505 m NE Grandshore Place 776 m E Rose Cottage 669 m SE Thrift Cottages 595 m N Paley Mill 820 m W Hill view 938 m W Paley Farm 1 km W Amber Down Farm 992 m SW Rockmount 747 m SE Hockdene 914 m SE Foxgloves 972 m SE

The land surrounding the site seems to be mainly agricultural, with a large area of mixed woodland to the southern and eastern sides.

3.11 Surrounding towns and villages

The village of Knoxbridge is 0.7 km to the north, Cranbrook Common is 1.4 km to the south, and the village of Frittenden is 2.8 km to the north east.

Access and Road Network

3.12 Road network

The site has good access being adjacent to the main A229 road, which leads to and the .

3.13 Access

There is existing access onto the site via a tarmac track which is shared for the first part by a plant nursery, with tarmac tracks leading to all the poultry sheds. Visibility splays at the entrance are good onto an A class road.

Photograph – Existing Site Access

Typical internal road

3.14 Footpaths

There is one public footpath running along the western boundary, another approx. 0.2 km from the southern boundary, and another along the eastern boundary. There is also a footpath approx. 0.4 km to the north of the site.

Ecology and Protected Sites

3.15 On site ecology (Phase 1 survey)

A Phase 1 habitat survey has been undertaken by Eco Check Consultancy Ltd. The initial survey results obtained are found in the report at Appendix 3.

3.16 Local ecology (2KM radius)

A search of local ecological sites was undertaken and this identified the following:

SITE SEARCHED FOR SITES FOUND SITES NOT FOUND National Nature Reserves X Local Nature Reserves X

Sites of Special Scientific Interest X (5KM) Special Areas of Conservation X Special Protection Areas X AONB X Scheduled Monument X RAMSAR Sites (10 KM search) X

Sites of Special Scientific Interest (England) Reference Name Citation

1000110 RIVER BEULT 1005993

1000323 SISSINGHURST PARK WOOD 1001255

1000302 MARDEN MEADOWS 1000226

Scheduled Monuments (England) Legacy Scale of Reference Name Easting Northing Date UID Capture MEDIEVAL MOATED SITE, Fri, 13 Jul 1990 12720 1013122 1:10000 577832.534455 141352.188172 LOVEHURST MANOR 00:00:00 UTC MOOT MOUND 400M WEST OF Fri, 9 Oct 1981 12842 1013147 1:10000 578428.87454 140675.818509 KNOX BRIDGE 00:00:00 UTC

3.17 Other designations (2 KM radius)

No other designations were identified within a 2KM radius of the subject site.

Planning Advice and History

3.18 Planning history

A search of the Local Authority database of planning applications found no recent applications associated with the site.

3.19 Present applications in the locality

An online planning search has been undertaken and there are no current planning applications within the immediate locality which would impact on the proposed development were identified.

3.20 Planning policy and other legislation

National policy

National planning policy is contained within the NPPF as follows:-

“The purpose of the planning system is to contribute to the achievement of sustainable development.

Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives): a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure; b) a social objective – to support, strong vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well being; and c) an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

Paragraph 10 states that “So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development (paragraph 11).

Section 6 is entitled Building a Strong, Competitive Economy and Paragraph 83 – Supporting a Prosperous Rural Economy states:

“Planning policies and decisions should enable:-

a) the sustainable growth and expansion of all types of business in rural areas, both through conversion of existing buildings and well designed new buildings; b) the development and diversification of agricultural and other land based rural businesses…..”

In considering suitable locations for development the document indicates that local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of 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.

Environmental issues are of major concern with all forms of development. Agricultural development which is deemed significant, such as the additional poultry housing proposed, has the potential to have an impact on the environment.

Hence major development of this type were included within the Town and Country Planning (Assessment of Environmental Effects) Regulation 1988. Environmental issues tend to be site specific in relation to the importance of such issues as landscape impact, ecological issues, effect on water sources, highways and other important issues.

The Town and Country Planning (Environmental impact Assessment) Regulations 2017 details further issues to be considered. The above policy and regulations have been used as a basis for the preparation of this report with the major issues given the appropriate weight in initial consultations, and addresses accordingly.

Local policy

Tunbridge Wells Borough Council

POLICY EN1

All proposals for development within the Plan area will be required to satisfy all of the following criteria:

1 The nature and intensity of the proposed use would be compatible with neighbouring uses and would not cause significant harm to the amenities or character of the area in terms of noise, vibration, smell, safety or health impacts, or excessive traffic generation;

2 The proposal would not cause significant harm to the residential amenities of adjoining occupiers, and would provide adequate residential amenities for future occupiers of the development, when assessed in terms of daylight, sunlight and privacy;

3 The design of the proposal, encompassing scale, layout and orientation of buildings, site coverage by buildings, external appearance, roofscape, materials and landscaping, would respect the context of the site and take

account of the efficient use of energy;

4 The proposal would not result in the loss of significant buildings, related spaces, trees, shrubs, hedges, or other features important to the character of the built up area or landscape;

5 There would be no significant adverse effect on any features of nature conservation importance which could not be prevented by conditions or agreements;

6 The design, layout and landscaping of all development should take account of the security of people and property and incorporate measures to reduce or eliminate crime; and

7 The design of public spaces and pedestrian routes to all new development proposals should provide safe and easy access for people with disabilities and people with particular access requirements.

POLICY EN25

Outside of the Limits to Built Development, as defined on the Proposals Map, all proposals for development will be required to satisfy all of the following criteria:

1 The proposal would have a minimal impact on the landscape character of the locality;

2 The development proposal would have no detrimental impact on the landscape setting of settlements;

3 The development proposal would not result in unsympathetic change to the character of a rural lane which is of landscape, amenity, nature conservation, or historic or archaeological importance;

4 Where built development is proposed, there would be no existing building or structure suitable for conversion or re-use to provide the required facilities. Any new buildings should, where practicable, be located adjacent to existing buildings or be well screened by existing vegetation; and

5 Where an extension or alteration to an existing building is proposed, it would respect local building styles and materials, have no significant adverse impact on the form, appearance or setting of the building, and would respect the architectural and historic integrity of any adjoining building or group of buildings of which it forms part.

4. DETAILS OF PROPOSAL

4.1 Description of the proposed rearing and laying sheds

Planning permission was obtained to construct two new poultry sheds to replace seven laying sheds. The sheds have since been constructed and are operational (Phase 1).

The proposal for Phase 2 is to demolish the existing rearing sheds to the north of the site which have a total floor area of 1,302 m² and erect 2 new rearing houses, each 120 m x 26.66 m which will have a total floor area of 6,398.4 m².

The new rearing buildings can be used to rear birds for three laying systems, Colony, Barn and RSPCA Assured Free Range. The number of birds to be housed in the sheds depends on the system used and will range from 138,864 to 322,560 birds.

4.1.1 Proposed management Cycle

Birds will be placed in the sheds as day old chicks as at present. They will be grown on and removed from the site at 17 weeks (point of lay). The system is a multi tier system with belt cleaning equipment removing the manure twice weekly. When rearing in an aviary format, there will also be litter removed at the end of the rearing cycle.

After the removal of all the birds from the shed, the remaining litter will be loaded into trailers, covered and removed from the site. It will be disposed of by spreading on fields, thus utilising its fertilising and soil improvement characteristics or will be removed to an Anaerobic Digester Plant. No manure will be stored on site nor will it be disposed of on land grazed by hens.

The whole shed and equipment will be power washed, disinfected and then dried out before the cycle starts again.

4.2 Layout of the site

The site will be laid out as shown on the Site Plan at Appendix 4.

4.3 Building construction

The new buildings will be of typical, modern, steel clearspan construction comprising:-

4.3.1 Materials

Each building will comprise of pre-cast concrete panel walls supported on strip foundations with an internal concrete floor poured over a continuous Damp Proof Membrane. The insulated side walls will be clad in stained timber and the insulated roof will be green steel sheeting.

The pitch of the roof will be 15º. The height to the eaves will be 3.6 metres with a height to ridge circa 7.3 metres.

4.3.2 Insulation

The shed roofs will be insulated with 200 mm fibreglass and the walls with 100 mm to achieve a U-value not less than 0.4 W/m² ºC thus eliminating condensation on the inner linings and minimising solar heat gain.

4.3.3 Floor

The sheds will be erected with a smooth and easily washable concrete floor on a continuous damp proof membrane. The dwarf walls will be reinforced on a poured concrete foundation and contain all dirty water and prevent the ingress of ground water.

4.3.4 Ventilation

The ventilation for the proposed new rearing houses will be as follows:-

- The ventilation system will consist of a computer controlled mechanical ventilation system.

- There will be air inlets on the side.

- There will be a number of 920 mm diameter air extraction chimneys on the roofs of the new sheds.

In the event of a failure in the mains electricity supply or an equipment breakdown, an alarm system linked to a generator will operate, allowing ventilation to continue.

4.4 Husbandry & Equipment

4.4.1 Stocking Rates

The stocking rates in these sheds can range from between 20 kg/m² to 40 kg/m².

4.4.2 Drinkers

The drinkers will be nipple drinkers with drink cups with rows running parallel to the long axis of each house.

The reason for choosing nipple drinkers with drink cups is not only for ease of management, coupled with good bird performance and maximum hygiene, but also to keep the moisture content of the litter as low as is practicable. A dry litter is a less odorous one and it is necessary to ensure that the risks of odours are minimised.

4.4.3 Feed

The feed will be blown from bulk feed lorries into the bulk bins. A centreless auger will convey feed to chain feeders.

The feed will be supplied by Fridays Feed Mill. It will be composed of high-quality raw materials, and be nutritionally tailored to the requirements of the different birds. It will contain enzymes that enhance the digestion of the cereal components of the feed. As a result of the improved digestion, the amount of water drunk by the birds is reduced, and this in turn leads to a lower moisture content of the litter. Consequently the risks of odours are reduced by this drier litter.

4.4.4 Heating

The rearing buildings will require heating to ensure the day old chicks are kept warm until they are able to keep themselves warm at around 5 weeks of age.

4.4.5 Water

Water for the site will be obtained from the mains supply. A back up storage tank will be installed above ground to be used in case of a problem with the mains supply.

4.4.6 Mortalities

These are removed from the houses daily and incinerated on site within the existing licensed APHA incinerator.

4.4.7 Pest Control (Rodents and Flies)

Rats can be attracted to poultry units, but are rarely a problem on well managed modern rearing and free range units because:-

- Modern building construction does not allow rats to enter the building easily, where as older sheds are more difficult to control, particularly timber.

- Bait points are provided at regular intervals replaced monthly which will control any rats that do appear.

Flies are not a problem with belt cleaned sheds as this is removed regularly twice per week.

4.5 Labour

There will be a farm manager and two stockmen employed by the unit plus part time labour to cover for holidays and sickness. The current rearing facility has one worker.

4.6 Manure

4.6.1 Removal

The litter will be taken by tractor and trailer (sheeted) to be used as an agricultural fertiliser or delivered to an anaerobic digester plant.

4.6.2 Quantities

Each 1,000 pullets will produce approximately 5.3 tonnes of manure per 17 week cycle.

Depending on the system operated will depend on the amount of manure produced, 123,000 pullets will produce approximately 652 tonnes per cycle and 322,650 pullets will produce approximately 1,711 tonnes per cycle.

5. ITEMS TO BE ASSESSED

Reference to the initial scoping opinion received from Tunbridge Wells Borough Council, for the phase 1 application and the background data collected during the Environmental Impact Assessment process has identified the following issues.

Clean and dirty water disposal and how this is handled particularly at the end of the cycle

The risk of airborne pollution in relation to odours, dust and noise

The effect on the landscape of the relocated sheds

The impact on the highways network from the increased numbers

The impact on ecology

The impact on archaeology

These aspects are assessed in the following sections with the technical information at various appendices.

6. DIRTY WATER DISPOSAL

6.1 Background

Permission is being sought for the erection of two new poultry rearing sheds running approx. west to east with a service/working yard at the western end and a clean access yard at the eastern end. The houses will each measure 120 m long x 26.66 m wide with a 10 m grass strip between them. There is virtually no slope on the site from north to south and a slope of about 0.8 m from west to east indicating that a minimum of site levelling will be required. At the same time 2 rather smaller sheds will be removed on the farm. Such a planning application requires the submission of a surface drainage system to the latest SUDS standards. This ensures that heavy and extreme rainfall on “hard” concrete and roof areas is “contained” within the site and so cannot directly cause issues on lower land by adding to surface water flooding or causing ditches to overflow. Our understanding is that we need to demonstrate that the new drainage system will meet today’s SUDS standards, but not the present buildings and yards.

Each batch of poultry will be in the houses for about 17 weeks before both houses are cleared and cleaned out. About 50% of the litter is removed by conveyors weekly into sealed trailers just outside the sheds with no pollution issues. The remaining 50% will be removed by “Bobcats” loading trailers standing on the service yard just outside the doors at the western end when the immediate yard will be dirty for 2-3 days.

The new houses will have gutters and downpipes feeding into stone drains containing a perforated plastic drain running to an attenuation basin/pond at the eastern end with an outfall to the ditch on the southern side via a much smaller flow regulating pipe. These drains will also take rainwater from the yards including the service yard, other than at the cleaning out time, and the access yard all of the time.

The site at a level of about 30 m is within Flood Zone 1 therefore flood risk is not considered to be an issue.

Roof and Hard Areas

2 New houses each 120 m long x 26.66 m wide = 6,398 m2 Control/Link building = 45 m2 Amenity Building = 216 m2 Service yard at western end 63 m x 10 m wide = 630 m2 Access at eastern end approx. 63 m by mean 10 m wide = 630 m2 ______Total 7,919 m2

Two old houses being removed together covering about 1,302 m2.

Soil Type

There are two different soil types in this immediate area. The first is Shabbington series which is developed on river terrace material which is commonly adjacent to, or just above, river floodplains. This soil type occurs immediately north of the farmstead at this site. The top 25 cm is sandy loam which is usually slightly stony. Below 25 cm the soil is slightly stony sandy clay loam and this soil texture continues normally to at least 120 cm depth. However, due to its position low on the floodplain the soil is grey and mottled below only 25 cm, becoming even greyer with ochreous mottles below around 55 cm. Winter flooding is a problem in some locations. Clay is normally found below 4 to 8 metres depth but with a layer of gravel in between. Although this soil type is easily cultivated, the presence of a high water table limits cropping on most fields. Conversely, where highly efficient field drainage has been installed this land has occasionally been used to grow fruit trees and hops.

The other local soil type to the south of the farmstead on slightly higher ground is mapped as the Curtisden soil series. The much more silty parent material is derived from local Ashdown Beds. The upper 45 cm is slightly stony silt loam or silty clay loam which is slightly mottled below 20 cm. There is usually a band of heavier silty clay loam around 30 cm thick in the subsoil which then becomes lighter at silt loam to 100 cm. Below 75 cm the soil is light grey in colour and mottled. Although this soil type is on somewhat higher ground than the Shabbington soil type cropping range remains limited by wetness because of the band of silty clay loam within the subsoil. Cereals and grassland are the most common crops with autumn drilling of cereals dominant. Because the topsoil contains a large amount of silt and fine sand it is susceptible to capping and formation of plough pans, especially where topsoil organic matter content is low. A lot of woodland has traditionally been established on this soil type in this part of .

The site is described by www.landis.org.uk/soilscapes as Soilscape 22: Loamy soils with naturally high water table. Slightly acid loamy and clayey soils with impeded drainage.

Approx. Position of Tolehurst Farm

The site goes on to describe the “Soils are mostly drained. Shallow groundwater and marginal ditches to most fields”

Hence the land is only suitable, as now, for a surface ditch drainage system.

6.2 Clean Water

6.2.1 Site Drainage

Greenfield site drainage figures obtained from www.uksuds.com for these new buildings give runoff rates for the proposed site as follows:-

Estimated Site Discharge IH124 results Q bar 3.53 1 in 1 year 3.25 l/sec. 1 in 30 years 5.5 l/sec. 1 in 100 years 12.21 l/sec.

The subsoil is a clayey soil with impeded drainage relying upon the adjacent ditches backed up by the extended balancing or attenuation pond/basin. Considering a site figure (see below) of 2 litres per second per ha over the extra 7,919 m2 of hard area this gives an added site drainage figure of 1.6 litres/second i.e. less than all the figures above. (On previous, usually smaller jobs, I have been encouraged to limit the flow to 1 l/sec/ha. but this is difficult on farms without the risk of frequent pipe blockages. I have in general agreed with the EA on a design flow of 2 litres/ha/sec. This gives a slightly

larger and thereby more manageable discharge pipe diameter and is also suggested in the SUDS information).

6.2.2 Rainfall

Rainfall on a “hard” roof area flashes off the surface in to a ditch at an alarming rate compared to a land drainage system typically considered to deliver 2.0 litres/sec/ha. The aim is to buffer rainfall and only allow it to drain in to a ditch or stream at the same rate as an agricultural drainage system permits. The drainage design needs to allow for rainfall on the new house roofs and immediate service yard areas to match 1 in 100 year figures plus in this case 30% (Ref. Kent CC SUDS summary) for global warming over the lifespan of the houses believed to be less than 50 years. Having been a poultry farm for many years the other houses and access roads/pads are already in place. The likely volumes are:-

Storm * Depth of Total Volume **Volume Restricted Storage Duration Rainfall mm of Rainfall allowing an discharge Volume m3 extra 30% 2.0 l/sec required on area of for global m3 m3 7,919 m2 warming m3 5 mins 14.1 112 145 1 144 15 mins 25.5 202 263 2 261 30 mins 33.5 265 345 4 341 1 hour 41.9 332 431 7 424 3 hours 55.5 439 571 22 549 4 hours 59.0 467 607 29 578 6 hours 64.4 510 663 43 620 12 hours 74.5 590 767 86 681 24 hours 85.5 677 880 173 707 36 hours 92.6 733 953 259 694 48 hours 97.8 772 1,003 347 657 72 hours 105.5 835 1,086 518 568 96 hours 113.4 898 1,167 691 476 8 days 143.7 1,137 1,479 1,555 Nil 25 days 222.0 1,758 2,285 4,859 Nil *Met. Office Data. ** Kent CC SUDS.

Some drainage to the ditch at the low rate is occurring all of the time during times of rainfall. The most challenging period for storage is between 12-36 hours requiring about 707 m3 of buffer capacity in the attenuation pond sited at the eastern end. After just over 4 days the extra buffer storage capacity should be empty even after this intense rainfall.

Providing this capacity ideally needs to be between the levels of the basin inlet pipes and the outlet pipe to the ditch. However this leaves a maximum depth of about 1 m and it’s likely that the farm will need to accept some water backing up the inlet pipes under

these exceptional conditions. We must ensure this does not mean it will come out of manholes or drains on the site.

6.2.3 Sizing the Attenuation Basin

This can be any shape to suit the farm but as a long narrow rectangle spanning the building width this could measure:-

Size at surface 60 m x 14.0 =840 m2 1 m depth Side walls 1 in 1.0 slope Base area 58 m x 12m = 696 m2

Capacity 768 m3

This will also allow for rainfall on the attenuation pond itself. Being long and narrow, spanning the width of the buildings, this will allow the large diameter drainage pipes to readily run straight into the attenuation basin. It is not really a pond as for the majority of the time (95% plus) in the normal sense of the meaning. The basin will more resemble a grassed depression. It will be sited at the eastern end of the buildings (see map below).

The 2 litres/sec. flow into the ditch equates to a 75 mm pipe with a fall of 1 in 150. (See chart below). I have adjusted the slope to more accurately match the flow required. The pipe will be in use all of the time for the site drainage with staff working from the service area and so any blockage should be readily spotted.

The www.uksuds.com site for storage volume suggests a buffer storage figure of 624 m3 using similar but not identical assumptions. (See summary report within the appendices).

6.2.4 Eaves Filler Drains

There will be 4 drains altogether under the eaves. Pipes laid in a stone trench with a 1 in 200 fall will deliver up to:-

65 mm 1.3 litres/sec (4.7 cu. metres/hour) 75 mm 1.7 litres/sec (6.3 cu. metres/hour) 85 mm 2.25 litres/sec. (8.10 cu. metres/hour) 100 mm 3.2 litres/sec. (11.5 cu. metres/hour) 115 mm 4.5 litres/sec (16.2 cu. metres/hour) 135 mm 6.8 litres/sec (24.4 cu. metres/hour) 155 mm 9.5 litres/sec (34.2 cu. metres/hour) 180 mm 16 litres/sec (57.6 cu. metres/hour) 210 mm 22 litres/sec. (79.2 cu. metres/hour) 250 mm 31 litres/sec. (111.6 cu. metres/hour) 300 m 50 litres/sec. ( 180 cu. metres/hour)

350 mm 76 litres/sec ( 274 cu. metres/hour)

Ref. Polypipe flow chart Restricted and open inlet –corrugated plastic pipes

The design need is to cope with the 30 minute storm of rain 1 in 100 years.

The houses measure 120 m long x 26.66 m = 3,199 m2. Each drain will therefore need to serve ½ the roof area 1,600 m2 plus ¼ of the service yards at each end 2 x 630/4 = 315 m2 giving a total of 1,915 m2. The water flows and therefore the pipe sizes necessary are as follows:-

Storm Intensity Volume Volume Discharge Volume Discharge Volume Duration mm/hr of runoff allowing an through surplus if through surplus if (Depth of m3 extra 30% 250 mm any 300 mm any Water mm) on roof for global pipe over m3 pipe over m3 area warming this period this period 1,915 m2 m3 250 mm m3 300 mm 15 mins 102 48.8 63.5 27.9 35.6 45 18.5 (25.5mm) 30 mins 67 64.1 83.4 55.8 27.6 90 Nil (33.5mm) 1 hour 41.9 80.3 104.3 111.6 Nil 180 Nil (41.9mm)

A 300 mm pipe is required for each drain as shown above, a 250 mm pipe is well short of capacity. However the is ample scope to take in water from the amenity and control/link buildings. In addition there is some void capacity within the stone drains. These will measure 120 m long x 400 mm wide x 750 mm deep. With an estimated 30% void capacity this adds a further 11 cu. metres of temporary storage capacity per drain.

The pipe could be graduated i.e. the first 1/3rd 210 mm, the second 250 mm and the final 1/3rd 300 mm. These will then run directly in to the attenuation basin/pond and finally the water will the water will reach the ditch.

6.2.5 Hydrobrake

A purpose built and sized hydrobrake would further minimise the chance of a blockage (e.g. Ref Hydro International www.hydrointernational.biz.) The intake pipes would need to be sized and specified at the design and manufacturing stage together with the required outflow of 2.0 litres/sec. Basically a hydrobrake consists of an inlet, an outlet and a baffled “volute” through which water is introduced tangentially. The outlet opening is 3-6 times greater than for conventional flow thus reducing the chance of blockages. This is not considered necessary for a scheme of this size with staff working on the site each day.

6.3 Dirty Water

6.3.1 Cleaning Out and Washing Down Inside the Houses

Approx. 50% of the manure is removed weekly using conveyors in to sealed trailers standing just outside the shed. There are no pollution issues with these. The other 50% is removed at the end of each batch by Bobcats via the doors at the western end into trailers standing on the service yard immediately outside the houses. The yard is therefore partly fouled for 2-3 days every 16 weeks.

Much of the final cleaning down between batches is a “dry operation” using compressed air. The final clean down uses pressure washers with the water draining to specialist dirty water tanks. These will also take rainwater from the service yard at the western end when it is dirty and the vehicles are being loaded. With these measures in place all the foul water can be disposed of safely.

The dirty water tank(s) should each hold 20 m3, being the maximum daily volume of pressure washing water when washing down the houses. The water will run into a series of drains within the houses and a sealed collection pipe running between the houses to 2 tanks, one at each end. With a level site this gives a greater fall on the pipework and so less chance of blockages occurring with water inevitably containing some solids. The concrete service yard will be slightly dished to 2 drains and these will house diverter valves to direct the water when dirty into the tank and when clean into the clean water system. There are likely to be two pumps, each operating 2 pressure washing lances with individual lances delivering about 15 litres per minute. They may run for 70% of the full working day and so the total volume of water used in an 8 hour day will be approx. 20 cu. metres. The tanks therefore each need to hold a minimum of 20 m3. In practice because of the warm temperature of the concrete floor inside the houses some of this water evaporates. Considering 25 mm of heavy rainfall during the working day on the yard measuring 630 m2 this would add a further 15.75 m3. Being completely in charge of the operation i.e. using their own staff the farm can if necessary empty the tanks during the day should we get heavy rainfall without the capital cost of “oversizing” the tanks. The tank will be emptied at the end of each working day in case heavy rainfall occurs overnight.

6.3 Maintenance

The drainage system is solely on land owned by the farm; hence there will be no delays or permissions needed to attend to any issues.

There are no pumps to go wrong or fail. The dirty service yard drains and water separation valves are only used and reset at the end of the cleaning out period i.e. every 16 weeks. For 15 weeks or so over a batch the western service yard is clean and the yard rainwater runs in to the clean water system. This is standard practice on these types of poultry unit. The access yard at the eastern end will be clean the whole of the time.

The ventilation system has air inlets under the eaves and high speed exhaust fans in the ridge which also carry away any dust from within the building. In practice no dust settles on the roofs necessitating washing them down and the potential blockage of the stone eaves drains. There is really very little to go wrong.

The inlets within the attenuation basin will be checked by the farm manager to ensure grass has not grown over the opening when each batch of poultry is due to leave the farm i.e. 3-4 times a year. With the basin/pond in a prominent position any blockages, no matter how unlikely, would be quickly spotted. A small block of concrete around each pipe, say 1 m across, would help to stop grass growing over the openings and also prevent any erosion. The small diameter outlet pipe (75 mm) is far more likely to block. This needs to be surrounded by 500 mm of concrete to minimise the ingress of grass and be subject to regular checking but working on a daily basis from the service yard any difficulties should be quickly spotted.

Over a course of some years it is possible for grass to encroach into and over the stone drains under each building eaves. These will be inspected annually to see if there is an issue. Small tussocks of grass can be removed by hand but any larger scale ingress will be sprayed off with Glyphosate, a translocated contact herbicide, leaving no residue within the drains to pass finally into the attenuation basin and so the ditch. It is approved for aquatic use. This kills all the plant tissue including the roots.

The whole site between and around the buildings will be strimmed and mown chiefly to maintain the appearance but also to minimise the habitat for vermin.

6.4 Summary

The need to match the pipe sizes to the 30 minute storm 1 in 100 years plus a global warming figure means that much larger than normal pipes need to be used. The site currently drains to ditches. If the pipes are installed and the attenuation basin/pond installed the system complies with all the Codes of Practice and given good management the chances of any pollution occurring or flooding downstream as a result of the development are minimal.

7. FLOOD RISK ASSESSMENT

A Flood Risk Assessment has been prepared and is contained at Appendix 5.

8. AIRBOURNE POLLUTION

8.1 Odours

8.1.1 Litter Moisture/Odourants

Research evidence suggests that odour emissions increase at the time of the growing period when litter moisture is also rapidly increasing or at high levels. It is known that when litter moistures exceeds 40% there is a progressive decline in the friability of the litter as the moisture increases.

When the litter moisture reaches about 46% the litter becomes capped, i.e. a crust forms, often on top of more friable litter under it. Excreta and moisture accumulate on the capped litter with the result that the activity of the aerobic bacteria that break down the excreta and allow moisture to be absorbed is reduced. There is a shift to an aerobic breakdown with the consequence that the release of volatile odorants is increased. It is therefore desirable to put strenuous efforts into management practices and building design that lead to low litter moisture levels. It is often the older buildings with less efficient ventilation and insulation that lead to odour problems. Odour emissions will be less and performance, welfare and profitability enhanced.

These problems can be avoided and are certainly not anticipated at the application site with the new more efficient sheds. The former MAFF booklet POULTRY LITTER MANAGEMENT (Ref: PD 1739) outlined the factors involved and how to avoid problems with litter quality.

Most poultry odours are believed to travel either absorbed into dust particulars or in solution within small water droplets. Ammonia is very soluble and can be carried outside the house within water droplets. It is likely to be further diluted by water in the outside atmosphere and is soon dissipated.

Protection of Water, Soil and Air - A Code of Good Agricultural Practice for Farmers, Growers and Land Managers

The revised Code of Practice was issued by DEFRA in 2009. It describes the main causes of air pollution from different agricultural activities and provides a practical guide to help farmers and growers avoid causing air pollution from odours, ammonia, smoke and green house gases.

In the case of a poultry unit, the most important factors relating to potential air pollution are ammonia and odours and the terms of the code will be strictly adhered to in the management practices used on the proposed site. Paragraphs 322 outlines the importance of Best Available Techniques and paragraphs 325 - 328 Deep Litter Poultry Systems.

8.1.2 Odour Model

AS Modelling and Data were commissioned to undertake an odour model for the existing and the redeveloped unit (see Appendix 6). This report takes into account replacement of the rearing units as well as the already completed phase 1.

Section 5 deals with the results from both scenarios.

The model shown will be a minor increase in odour under the new proposals due to an increase in the number of birds on site. The increase is however not predicted to exceed the Environment Agency guidelines.

In terms of the current situation the operators are not aware of any previous problems with odours from the site.

8.2 Dust concentrations and emissions

Within a poultry building, the main sources of dust are the birds, their food and the floor litter. Measurements of dust concentrations have been found to be variable, depending on the number and age of the birds as well as the level of activity within the buildings. The particle size of dust is variable too. In general terms, particles smaller than 2 microns (2 um) account for around 70% of the number of particles, but only 5% of the mass. Similarly, particles greater than 5 microns (5 um) account for under 10% of the number, but between 40 and 90% of the dust mass.

The particles of dust inside the building are emitted to the atmosphere via the ventilation system. The amounts of dust emitted are influenced by the level at which the ventilation system is operating. In hot summer weather, for example, the ventilation system will be opening at high rate.

The larger dust particulars (5 microns/5 um and over) found within the building either tend to fail to migrate to the ventilation fans, or are expelled from the building and immediately deposited to the ground. The unit employs ridge ventilation so there will not be any large concentrations of deposited dust on the ground outside, therefore creating few deposits entering the water course via land or French drains. Regular ammonium testing of the swale pond is carried out and all data recorded.

Once released to the atmosphere the dusts will be carried on the wind, with deposition continuing under the natural turbulent flow of the air. With increasing distance from the source there will come a point where the concentration of dust particles which originate from poultry buildings fall into a level below air quality guide-line values as laid down by the EU and eventually be indistinguishable from normal background dust levels.

Evidence indicates that annual average concentrations of poultry dust are not expected at distances exceeding 100 m from the source. Thus, only properties situated very close to a poultry building are in danger of exceeding either the EU and UK regulations on dust concentrations in air, or the tolerance threshold values for dust deposition.

When examining the above factors it can be seen that dust should cause no problems to nearby protected dwellings, because receptor properties are located sufficient distances away from the proposed unit. The proposal also puts the rearing sheds further away from dwellings than at present.

8.3 Flies

The new sheds will work mainly on a belt clearing system which means most of the manure is removed on a regular basis i.e. twice weekly. They therefore have no time to become a breeding ground for flies. The manure on the floor would be limited to a 17 week cycle with full removal of manure which also limits breeding opportunities. This is also kept dry and is not a good breeding ground for flies.

8.4 Vermin

Routine baiting and a well constructed site will ensure that there will be no risk of the rearing site becoming a breeding ground for rats or mice. The existing unit already has in place a routine baiting arrangement and this will continue with the expanded unit.

8.5 Noise

There are a number of sources of noise in a poultry unit, including ventilation fans, lorries and other vehicles. The new sheds will have significantly improved ventilation fans, which are contained within cowls directed upwards. The location, age and condition will all be marked improvements on the existing.

In addition the noise of feed being blown into the bulk bins might occasionally be heard. The noise of lorries and other vehicles may be heard in the vicinity, however this will be no different to the current scenario which has not understood to have caused any problems and again new bins and augers will be less problematic than the aged existing ones.

These noises will not be unusual in an agricultural area where grain stores and the livestock units use similar equipment and will last approximately 1 hour.

9. ECOLOGY

9.1 On and off site

Poultry units can have an impact on ecology in three ways, namely:- a) The site of the new buildings removing habitat, especially any elements constructed on previously undeveloped land. b) The impact on species that might use the site temporarily or immediate surrounding area. c) The impact of emission on sites of ecological interest further afield, principally ammonia.

In terms of a) and b) a Phase 1 Habitat Survey and assessment has been undertaken and is contained at Appendix 3.

In terms of c) Fridays have provided a report which is at Appendix 7. This was prepared for the variation to the IPPC permit. It concludes there will not be a material change in conditions from the current permit for the site.

9.2 Arboricultural Implications

These are dealt with in the ecology report.

10. HIGHWAYS AND TRAFFIC STATEMENT

10.1 Road network

The site has good access being adjacent to the main A229 road, which leads to Maidstone and the M20 motorway.

10.2 Site access

There is existing access onto the site via a tarmac track which is shared for the first part by a plant nursery, with tarmac tracks leading to all the poultry sheds. Visibility splays at the entrance are good onto an A class road.

10.3 Traffic movements

Traffic movements for poultry are relatively easy to establish due to the regular cycles. The two sheds will operate with different ages with shed 2 approximately 8 weeks behind shed 1.

The table below summarises the approx. monthly vehicle numbers to and from the unit (all loads assumed to be full loads) if the unit was operating at maximum capacity from day old chicks to depopulation at point of lay (17 weeks). The actual monthly figures will vary depending on the system but also the age gap between sheds 1 and 2 but the total within the year would be the same.

Proposed Traffic Movements

MONTH 1 2 3 4 5 6 7 8 9 10 11 12 Chicks In 3 3 3 3 3 3 Feed delivery 1 7 9 6 4 1 7 9 6 4 1 7 Pullets Removed 16 16 16 16 16 * Manure removal 8 8 8 8 8 8 8 8 8 8 8 8 (belt clean) Manure removal (floor) 4 4 4 4 4 Dirty Water – cleaning 3 3 3 3 3

• * this shows the second year • Floor removal of litter only applicable if aviary system is adopted for the batch of hens produced

In addition there will be 3 stockpersons visiting the unit (current unit has one stockperson).

It can be seen from the table that generally the predicted amount of traffic movements is low.

The variety of vehicle types, loads and therefore starting points/destinations will mean that movements will be distributed fairly quickly on leaving the unit onto which the farm track accesses. Given this is an agricultural area, where peaks and troughs in farm vehicle and other movements are common, it is considered that the change in movements will have little environmental effect.

10.4 Mitigation

There is no requirement for any mitigation, noting the use of the existing site access and the vehicle types will be very similar to existing.

10.5 Impact

The impact on traffic use will be low given the low level of vehicles and the fact the farm already is in operation.

10.6 Impact on footpaths

Footpaths will not be affected traffic wise.

11. LANDSCAPE IMPACT

A Landscape Assessment has been undertaken which is included at Appendix 8.

12. PREVIOUS LAND USE/CONTAMINATION

The existing units were built and managed by Fridays as poultry units. The land was bare agricultural land before. There are no contamination issues envisaged.

13. ARCHAEOLOGY

An archaeology report was prepared for Phase 1 and is at Appendix 9. Nothing is believed to have changed in the interim period.

14. ALTERNATIVES

The main alternatives are different sites for the proposed buildings. It is not considered, given the scale of the proposed buildings, there are sites any better than those proposed.

It is also necessary to keep them separate and away from the laying sheds and associated grazing areas.

15. CONSTRUCTION PHASE

The construction of the unit will involve the following phases:- a) Preparation.

b) Existing concrete pads will be removed and concrete crushed for use as a base for new concrete. c) Levelling of new sites and adding base. d) Erection of frame and installation of services. The frame will be all pre designed and the erection process will take a matter of a few days. e) Concreting and building works.

f) Demolition of the existing sheds - these are of simple timber construction so demolition of the frame is straightforward and would not cause significant impact noise wise.

In total construction is expected to take approximately 12 months.

During construction there will be increased vehicle movements, but these will last for only a short period whilst materials are being delivered. Given the existing access and road network this will not cause any impact of concern other than earth moving equipment, but this is of a relatively short duration at the early stage of the construction process..

All framework and equipment will be delivered ready to fit so there will therefore be no concern noise wise at building works phase.

16. CONCLUSIONS

The background investigations and scoping opinion identified a number of aspects which may give rise to environmental effects of the development. The proposal consists of 2 poultry rearing sheds and the conclusions on the various aspects are as follows:-

Clean, Dirty Water and Flood Risk

Tanks will be installed to take dirty water from within the sheds during clean out and from the outside yard area when sheds are being emptied and vehicles loaded.

A clean water system involving a balancing pond is proposed to take roof water and yard water outside of the cleaning out period prior to draining to ditch. With these measures in place all water can be disposed of safely.

The site is within Flood Zone 1 therefore flood risk is not considered to be an issue.

Airborne Pollution

The issue of odours, dust and noise have been investigated including the involvement of Agromet specialists. These conclude that levels will be below Environment Agency guidelines.

Landscape Impact

The Landscape Assessment concludes that on completion of the development, the overall impact of the development is likely to be neutral due to the limited visibility of the site. No landscape mitigation is considered necessary.

Highways

The proposal makes use of an existing access and internal farm road network. Vehicle types will be as existing with some increase due to numbers.

Ecology

The impact on ecology is very low as concluded in the ecologist's report. In terms of deposition, the ammonia model does not predict any material changes from the current permitted levels.

Appendix 1

Scoping Opinion

Appendix 2

National Character Area

NCA 122: High Weald

Key Facts & Data

T his document provides a correspond to national data. If summary of environmental data you have any questions about collected for the NCA. It is the Key Facts and Data, please intended to help guide anyone contact: making decisions that may [email protected] affect the local environment. .uk. Your feedback will help The information contained here shape the content of the full is collated from the best NCA profiles, which will be available national datasets. It is published from September recognised local information 2012 onwards. may provide additional detail and that this will not always

www.naturalengland.org.uk Map of High Weald NCA Total Area: 174,885 ha

The above map is provided from the Countryside Character Area description pending completion of NCA maps. It is recognised that the content of this map may now be out of date in some cases and is included for general reference only. New maps will include updated content and be provided within the full NCA profiles, due to be completed by 2013 1. Landscape and Nature Conservation Designations The High Weald Area of Outstanding Natural Beauty covers an area of 135,863 ha (78% of the NCA).

Information on the High Weald AONB is available at:  http://www.highweald.org/

Source: Natural England (2011)

1.1 Designated nature conservation sites The NCA includes the following statutory nature conservation designations:

Tier Designation Designated Area in Proportion Site(s) NCA of NCA International Ramsar Pevensey 35 ha <1% Levels European Special Ashdown 3,198 2% Protection Area Forest SPA ha (SPA) Special Area of Ashdown 2,868 2% Conservation Forest SAC, ha (SAC) Hasting Cliffs SAC National National Nature n/a 0 ha 0% Reserve (NNR) National Site of Special A total of 59 5,416 3% Scientific sites wholly or ha Interest (SSSI) partly within the NCA Source: Natural England (2011)

Please Note: (i) Designated areas may overlap (ii) all figures are cut to Mean High Water Line, designations that span coastal areas/views below this line will not be included.

There are 268 Local sites in the High Weald NCA covering 11,260 ha which is 6.5 % of the NCA.

Source: Natural England (2011)

 Details of individual Sites of Special Scientific Interest can be searched at: http://www.sssi.naturalengland.org.uk/Special/sssi/search.cfm  Details of Local Nature Reserves (LNR) can be searched http://www.lnr.naturalengland.org.uk/Special/lnr/lnr_search.asp  Maps showing locations of Statutory sites can be found at http://magic.defra.gov.uk/website/magic/ -select ‘Rural Designations Statutory’

1.1.1 Condition of designated sites

SSSI Condition Category Area in NCA Percentage of NCA SSSI Resource Unfavourable declining 33 ha <1% Favourable 1,264 ha 23% Unfavourable no change 28 ha <1% Unfavourable recovering 4,092 ha 76%

Source: Natural England (March 2011)

 Details of SSSI condition can be searched at: http://www.sssi.naturalengland.org.uk/Special/sssi/reportIndex.cf m

2. Landform, Geology & Soils

2.1 Elevation The NCA reaches a maximum height of 241m at Crowborough Beacon in East Sussex. The lowest point is sea level.

Source:Natural England 2011

2.2 Landform & Process Although not exceeding 241m, the High Weald is a hilly country of ridges and valleys. Numerous major ridges run mainly east to west. These major ridges are deeply dissected by many tributaries of rivers which rise in the High Weald producing a network of small, steep sided ridges and valleys (gills).

Source: High Weald Countryside Character Area description

2.3 Bedrock Geology The Weald is a geologically complex anticline, a folded dome where the oldest rocks are exposed at the centre as the top has been worn down by erosion. These oldest rocks, the Upper Jurassic Purbeck Beds, are only exposed at the surface in the Crowhurst area. Overlying these are Lower Cretaceous sands, soft sandstones and clays out to the edge of the High Weald.

Source:High Weald Natural Area Profile, High Weald Countryside Character Area Description, British Geological Survey maps

2.4 Superficial Deposits Superficial deposits cover only a small percentage (7%) of the NCA. Of these, the majority are clays, silt and sands which follow river courses.

Source :High Weald Natural Area Profile, High Weald Countryside Character Area Description, British Geological Survey maps

2.5 Designated Geological Sites

Designation Number of Sites

Geological Site of Special Scientific Interest 17 (SSSI) Mixed Interest SSSIs 3

There are 38 Local Geological Sites within the NCA.

Source: Natural England (2011)

 Details of individual Sites of Special Scientific Interest can be searched at http://www.sssi.naturalengland.org.uk/Special/sssi/search.cfm

2.6 Soils and Agricultural Land Classification

The area is dominated by both sandy and heavy clay soils. Slightly acid loamy and clayey soils with impeded drainage cover the majority of the NCA.

Source:Countryside Character Area description, Natural England 2011

The main grades of agricultural land in the NCA are broken down as follows (as a proportion of total land area):

Agricultural Land Area in NCA Proportion of Classification NCA Grade 1 145 ha <1% Grade 2 1,293 ha <1% Grade 3 109,701 ha 63% Grade 4 38,047 ha 22% Grade 5 n/a 0% Non-agricultural 17,925 ha 10% Urban 7,771 ha 4%

Source: Natural England (2010) 3. Key Water Bodies & Catchments 3.1 Major Rivers/Canals The following major rivers/canals (by length) have been identified in this NCA.

River Name Length in NCA

Medway 30km Rother 28km Ouse 18km Tillingham 16km Dudwell 13km Brede 10km Cuckmere 7km Arun 6km Eden 5km

Source: Natural England (2010)

Please Note: other significant rivers (by volume) may also occur. These are not listed where the length within the NCA is short.

The High Weald is a source of a number of major rivers in the South East and has dendritic drainage pattern with numerous small streams forming the headwaters of the main rivers. The area also contains several reservoirs including Weir Wood, Ardingly, Bewl Water and Darwell.

Source: Natural England (2010)

3.2 Water Quality The total area of Nitrate Vulnerable Zone is 100,205 ha – 57% of the High Weald NCA.

Source: Natural England (2010)

3.3 Protected Areas  to be completed in consultation with the Environment Agency (full document only).

3.4 Water Framework Directive  to be completed in consultation with the Environment Agency (full document only).

4. Trees and Woodlands 4.1 Total Woodland Cover The NCA contains 41,442 ha of woodland (24% of the total area), of which 30,234 ha is ancient woodland.

Source: Natural England (2010)

4.2 Distribution and size of woodland and trees in the landscape The High Weald has the greatest amount of ancient woodland in any AONB, representing 7% of all ancient woodland in England. The character of the woodland within the High Weald is dominated by numerous small woods and sinuous gills, interconnected by narrow shaws.

Source:The cultural heritage of woodlands in the South East, 2007

4.3 Woodland Types A statistical breakdown of the area and type of woodland found across the NCA is detailed below.

Area and proportion of different woodland types in the NCA (over 2 ha)

Woodland Type Area in NCA Proportion of NCA Broadleaved 22,044 ha 13% Coniferous 5,374 ha 3%

Mixed 4,036 ha 2% Shrub / young trees 2,503 ha 1% Felled/land for prepared 3,260 ha 2% planting Source: Natural England (2010)

Area and proportion of Ancient Woodland and Planted Ancient Woodland within the NCA

Woodland Type Area in NCA Proportion of NCA Ancient semi-natural woodland 20,663 ha 12% Ancient re-planted woodland 8,719 ha 5% (PAWS) Source: Natural England (2004) 5. Boundary Features & Patterns 5.1 Boundary Features Fields are bounded by shaws (narrow bands of ancient woodland), woodlands and hedgerows.

Source: High Weald Countryside Character Area Description

5.2 Field Patterns Small, irregular, organic shaped fields. The landscape is essentially medieval with field patterns derived from post-Saxon/early medieval cultivation of small parcels of land from more extensive areas of woodland; commonly referred to as 'assarting'. The resultant character of the area is one of fields within woodland, with associated dispersed and isolated settlement.

Source: High Weald Countryside Character Area Description 6. Agriculture The following data has been taken from the Agricultural Census linked to this NCA.

6.1 Farm Type The pastoral character of the area is supported by the figure for grazing livestock farms (697, 2009) in comparison with cereals (210, 2009) and horticulture (201, 2009). Those classed as 'other' accounted for 763 holdings.

Source: Agricultural Census, DEFRA (2010)

6.2 Farm Size In 2009, farms between 5 and 20ha represented 36% of holdings, followed by 25% between 20 and 50ha, 14% between 50 and 100ha and 12% for less than 5ha. Those greater than 100ha also accounted for 12%.

Source: Agricultural Census, DEFRA (2010)

6.3 Farm Ownership 2009: Total farm area = 105,626 ha; owned land = 78,719 ha 2000: Total farm area = 97,466 ha; owned land = 75,676 ha

Source: Agricultural Census, DEFRA (2010)

6.4 Land Use In 2009, 62% of the total farmed area was grass and uncropped land (65,090ha). Cereals covered 12% of the farmed area (12,876ha) - the second most prevalent land use. Oil seeds accounted for 4% of farmed area. Other arable crops also accounted for 4%, with 2% represented by fruit.

Source: Agricultural Census, DEFRA (2010)

6.5 Livestock Numbers In 2009 there were 43,200 cattle (55,100 in 2000), 180,700 sheep (251,000 in 2000) and 8,800 pigs (12,900 in 2000).

Source: Agricultural Census, DEFRA (2010)

6.6 Farm Labour Principal farmers make up 56% of farm labour (2623, 2009). Numbers have remained relatively stable between 2000 and 2009 with the only significant change being a drop in the number of full-time workers (-9% to 630) and casual/gang workers (-21% to 601).

Source: Agricultural Census, DEFRA (2010)

Please Note: (i) Some of the Census data is estimated by Defra so will not be accurate for every holding (ii) Data refers to Commercial Holdings only (iii) Data includes land outside of the NCA belonging to holdings whose centre point is within the NCA listed.

7. Key Habitats and Species

7.1 Habitat distribution / coverage Woodlands including gill woodlands, shaws and hedgerows are found across the High Weald with ancient woodland a distinctive feature (see woodland section). Pockets of unimproved and semi-improved grassland (both acid and neutral) are notable. There are significant areas of heathland including Ashdown Forest, one of the most extensive areas of heathland in south-east England. Wetland habitats associated with the river valleys are also important. The High Weald has more than 10,000 ponds concentrated on the clay providing valuable habitats for a range of wildlife. Parklands contain relict ancient habitats such as veteran trees. The sand rock exposures are an important habitat for bryophyte assemblages.

Source: High Weald AONB Management Plan 2004, High Weald Natural Area Profile

7.2 Biodiversity Action Plan (BAP) Priority habitats The NCA contains the following areas of mapped priority habitats (as mapped by National Inventories). Footnotes denote local/expert interpretation. This will be used to inform future national inventory updates.

UK BAP Priority Habitat Area in NCA Proportion of NCA Broadleaved Broad habitat 26,538 ha 15% Lowland heathland 1,767 ha 1 1% Coastal & floodplain grazing 565 ha <1% marsh Lowland meadows 233 ha 2 <1% Maritime cliff & slope 167 ha <1% Lowland dry acid grassland 142 ha 2 <1% Fens 51 ha <1% Reedbeds 18 ha <1% Purple moor-grass & Rush 1 ha <1% Pasture Coastal vegetated shingle <1 ha <1%

Source: Natural England (2011)

Footnotes: (1) High Weald AONB Management Plan 2nd edition (2009) states 1,931 ha of heathland within the AONB boundary. (2) High Weald AONB Management Plan 2nd edition (2009) states 655 ha of species-rich unimproved lowland meadows and dry acidic grassland within the AONB boundary

Maps showing locations of UK BAP Priority Habitats are available at  http://magic.defra.gov.uk/website/magic/ select ‘Habitat Inventories’

7.3 Key species and assemblages of species  These are listed in Annex 1 (full document only)  Maps showing locations of S41 species are available at http://data.nbn.org.uk/ 8. Settlement and Development Patterns 8.1 Settlement pattern The area is characterised by dispersed historic settlements of farmsteads and hamlets. The relatively few nucleated villages and small towns are usually sited alongside the main routes through the Weald. Many of these settlements developed as trading centres and associated with non rural industries and in several examples it is clear that the market was the original feature, later accompanied by a church.

Source: High Weald Countryside Character Area description; Countryside Quality Counts (2003)

8.2 Main Settlements The main settlements within the High Weald are: , Tunbridge Wells, Crawley, Bexhill and Haywards Heath.

Source: High Weald Countryside Character Area description; Countryside Quality Counts (2003)

8.3 Local vernacular & building materials Distinctive red tile, brick, local sandstone and timber building materials, often including hung tiles and white weatherboarding, are characteristic of the historic settlements, farms and cottages. Oast houses and timber framed barns are a particularly notable and characteristic element of the High Weald landscape.

Source: High Weald Countryside Character Area description; Countryside Quality Counts (2003) 9. Key Historic Sites & Features 9.1 Origin of historic features The High Weald has been occupied since at least the Mesolithic period but few pre-Roman sites exist. Iron was the major industry, first developed in the Iron Age and Roman periods but predominantly in the 15th – 17th centuries when the Weald was the foundry of England and the influence dominates the present landscape in the form of hammer ponds, furnace sites and evidence of charcoal-burning. The wealth generated by this industry also led to the abundance of large estates, grand houses and parklands. The NCA includes the site of the Battle of Hastings and substantial evidence of the Norman development of the area in the form of castles, churches and Medieval Buildings. Agriculture has also been important, including hop-production with oast houses notable and a large number of pre-1750 farm buildings survive.

The High Weald is characterised by ancient routeways (now roads and Rights of Way) in the form of ridge - top roads and a dense system of radiating droveways. Along with the prehistoric ridge-top ways, the droves were one of the most distinctive characteristics of the High Weald in the 14th century and remain so. (Harris 03)

Source: Countryside Quality Counts (2003), Draft Historic Profile, Countryside Character Area description (2004), Making of the High Weald, Roland B Harris 2003 9.2 Designated Historic Assets

This NCA has the following historic designations:

 56 Registered Parks and Gardens covering 4,599 ha  1 Registered Battlefield/s covering 77 ha  91 Scheduled Monuments  7,370 Listed Buildings

Source: Natural England (2010)

 More information is available at the following address: http://www.english-heritage.org.uk/caring/heritage-at-risk/  http://www.english- heritage.org.uk/professional/protection/process/national-heritage- list-for-england/

10. Recreation and Access 10.1 Public Access 6% of the NCA 10,926 ha is classified as being publically accessible.

The table below shows the breakdown of land which is publically accessible in perpetuity:

Access Designation Area in NCA Proportion of NCA National Trust (Accessible all 154 ha <1% year) Common Land 2,790 ha 2% Country Parks 412 ha <1% CROW Section 4(OC and 1,938 ha 1% RCL) CROW Section 15 2,734 ha 2% CROW Section 16 (Dedicated) 2,435 ha 2% Village Greens 255 ha <1%

Doorstep Greens 1 ha <1%

Forestry Commission Walkers 3,599 ha 2% Welcome Grants Local Nature Reserves (LNR) 750 ha <1% Millennium Greens 9 ha <1% Accessible National Nature n/a 0% Reserves (NNR) Agri-environment Scheme 132 ha 1% Access Woods for People 7,043 ha 4%

Sources: Natural England (2011)

Please Note: Common Land refers to land included in the 1965 commons register; CROW = Countryside and Rights of Way Act 2000; OC and RCL = Open Country and Registered Common Land.

10.2 Rights of Way

There are 3,043 km of Public Rights of Way at a density of 1.7km per km2. There are 0 National Trails within the NCA.

Sources: Natural England (2010)

11. Experiential Qualities 11.1 Tranquillity Based on the CPRE map of Tranquillity (2006) the areas of greatest tranquillity are away from the main transport corridors and major settlements. The pastoral, heavily wooded and intimate character of the landscape has a strong sense of tranquillity.

A breakdown of tranquillity values for this NCA are detailed in the table below: Tranquillity Tranquillity Score

Highest Value within NCA 42 Lowest Value within NCA -108 Mean Value within NCA -8 Sources: CPRE (2006)

 More information is available at the following address: http://www.cpre.org.uk/what-we-do/countryside/tranquil- places/in-depth/item/1688-how-we-mapped-tranquillity

11.2 Intrusion

The 2007 Intrusion Map (CPRE) shows the extent to which rural landscapes are ‘intruded on’ from urban development, noise (primarily traffic noise), and other sources of visual and auditory intrusion. This shows that there are patches of undisturbed land throughout the NCA. Disturbance is localised and centred around main roads, notably the A21, A26 and M23, and urban centres, particularly Hastings in the East and the Crawley/Gatwick area in the West. A breakdown of intrusion values for this NCA are detailed in the table below.

Intrusion 1960s 1990s 2007 Percentage Category change (1960s- 2007) Disturbed 20% 42% 50% +30% Undisturbed 76% 54% 44% -32% Urban 4% 4% 6% +2%

Sources: CPRE (2007)

Notable trends from the 1960s to 2007 are that the amount of land being described as disturbed has more than doubled with less than a half of the NCA being undisturbed in 2007 compared to more than three quarters in 1960. The amount of urban land has increased but less so than in some other areas and remains a small proportion (just under 6%) of the NCA.

 More information is available at the following address: http://www.cpre.org.uk/resources/countryside/tranquil-places

12 Data Sources

 High Weald Natural Area Profile, Natural England (English Nature 1997)  High Weald Countryside Character Description, Natural England (Countryside Commission/Countryside Agency 1998/1999)  Countryside Quality Counts, Natural England (Countryside Agency 2003)  Agricultural Census June Survey 20002009, Defra (2010)  Intrusion Map, CPRE (2007)  Tranquillity Map, CPRE (2006)  Draft Historic Profiles, English Heritage (2004)*  High Weald AONB Management Plan 2004, 2nd Edition, adopted March 2009  Making of the High Weald, Roland B Harris 2003  The Cultural Heritage of Woodlands in the South East, 2007.  For further information on Natural England data sources please see the Key facts and data interpretation note

Please note all figures contained within the report have been rounded to the nearest unit. For this reason proportion figures will not (in all) cases add up to 100%. The convention <1 has been used to denote values less than a whole unit.

Photo Credits

Front Cover: Burwash (c) High Weald AONB

V1.0

Appendix 3

Phase 1 Ecology Survey

PRELIMINARY ECOLOGICAL APPRAISAL AND IMPACT ASSESSMENT FOR PROPOSED FREE RANGE REARING SHEDS AT TOLEHURST FARM, CRANBROOK ROAD, KNOXBRIDGE, FRITTENDEN, KENT, TN17 2BP

Report produced by Client details Eco-Check Consultancy Ltd, Acorus Rural Property Services White House Cottage The Old Market Office Knapton Green 10 Risbygate Street North Walsham Bury Saint Edmunds Norfolk Suffolk NR28 0RU IP33 3AA Tel/ 01263 722199 -07914 130493 Tel/01284 753271

[email protected] [email protected]

DECEMBER 2018

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CONTENTS Page. No

CONTENTS

1. NON‐TECHNICAL SUMMARY ...... 3

2. INTRODUCTION ...... 7

3. METHODOLOGY ...... 10 3.1 Desk Study and Data Consultation ...... 10 3.2 Surveyor and Weather Conditions ...... 10 3.3 Extended Phase 1 Habitat Survey ...... 10 3.4 Protected and Key Species Survey ...... 11 3.5 Impact Assessment………… ...... 14 3.6 Limitations…………. ………...... 17 3.7 Legislation…………… ………...... 17

4. SURVEY FINDINGS AND EVALUATION ...... 20 4.1 Desk Study ...... 20 4.2 Phase 1 Habitat Survey ...... 22 4.3 Protected Species and Other Species of Nature Conservation Importance 23

5. ECOLOGICAL EVALUATION, IMPACT ASSESSMENT AND RECOMMENDATIONS. 28 5.1 Birds ...... 28 5.2 Bats ...... ………………… 29 5.3 Amphibians ...... …. 30 5.4 Reptiles ...... 30 5.5 Hedgehog and Small Mammals...... 31 5.6 Designated Sites and Priority Habitats...... 31

6. AVOIDANCE, MITIGATION & COMPENSATION...... 33

7. BIODIVERSITY ENHANCEMENT...... 36

8. ECOLOGICAL CONDITIONS AND RECOMMENDATIONS FOR FURTHER SURVEYS 37

9. REFERENCES ...... …. 39

Appendix 1 ‐ Site Plans...... 41 Appendix 2 – Desk Study Data ...... 43 Appendix 3 – Photos ...... 78 Appendix 3 – Species List ...... 80

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1. Non‐Technical Summary

The following summary is an extract of the report. Please ensure the report is read in its entirety for detailed survey findings and recommendations:

Eco‐Check Ltd were commissioned by Acorus Rural Property Services, to undertake a Preliminary Ecological Appraisal (PEA) at Tolehurst Farm, Cranbrook Road, Frittenden, Kent, TN17 2BP (TQ784403), herein referred to as site. Tolehurst Farm is a free range egg farm and comprises two large recently constructed layer houses, two rearing houses, egg packing building, offices, feed silos, agricultural dwellings and other ancillary buildings. Improved and semi‐improved grassland (pasture) is the dominant habitat within and surrounding the site bounded by intact hedgerows and trees, scattered trees and woodland. Beyond the boundaries of the application site is arable fields and grazed pasture.

The application relates to proposals for the demolition of two old rearing sheds and construction of two larger rearing houses approximately 140m to the west across an area of pasture grassland. The footprint of the existing buildings to be demolished is approximately 1,302m² and the new buildings with a footprint of approximately 9,468m² with an increase by 5,353m².

This highlighted the requirement for a preliminary ecological appraisal, desk study and ecological impact assessment to inform the planning process, to identify any key ecological receptors and identify where relevant any further surveys and avoidance/mitigation required to safeguard the key ecological receptors.

The objectives of the appraisal were to; identify the habitats and species present or potentially present and evaluate their importance, assess the impact of the development proposal and describe any measures necessary to avoid impacts, reduce impacts or compensate for impacts so that there is no net harm to ecological features.

The survey involved classifying and recording habitat types and features of ecological interest and identified the potential for protected species to be present by assessing habitat suitability for those species. The survey was undertaken by appropriately qualified and experienced personnel.

The site comprised a mosaic of habitats including broadleaved woodland, bare ground, buildings, tall ruderal, improved and semi‐improved grassland and intact species poor hedging and trees. The ecological value of the footprint of the demolition and construction areas is low whilst the boundary habitats are of moderate to high ecological value.

Based on the habitat types present, it is considered that the site has potential to support the following protected species or groups of species: invertebrates (common and widespread species), breeding birds, terrestrial mammals, foraging/commuting bats, roosting bats and reptiles.

In the absence of mitigation, the proposed development would give rise to a minor adverse impact on breeding birds, terrestrial mammals, habitats, invertebrates and foraging/commuting bats and roosting bats. The impact of the development on water vole, otter and hazel dormouse is considered to be negligible. The impact of the development on nearby statutory designated sites is neutral as the nearest site Sissinghurst Park Wood (SSSI) is 2km to the south‐east of the site.

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Avoidance, Mitigation and Compensation on site has been proposed which would reduce the overall impact to minor adverse‐neutral, including:

 Avoidance: Phased clearance of rough grassland and tall ruderal vegetation, creation of artificial refugia/hibernaculum along the edge habitats of the site (woodland, ditch, hedges); retention of all mature trees; timing of vegetation clearance and ground works to avoid the bird nesting season 1st March to 15th September inclusive; ensure a minimum 5m buffer zone is maintained along the field hedgerows and woodland edge; trenches and excavations to be covered at night or a mammal ramp provided; no trees to be removed without a preliminary bat roost assessment (PRA) being undertaken; no groundworks or plant machinery within the RPA’s of trees; building materials to be stored off the ground on pallets; sensitive lighting design in accordance with Bat Conservation Guidelines; measures to be taken to avoid killing/injuring of terrestrial mammals.

 Mitigation: Landscape planting to include native fruit and berry bearing trees, hedging, shrubs and plants which provide a nectar source to improve foraging resources for a range of invertebrate and bird species.

 Enhancement: Erection of bird and bat boxes. Relaxing mowing regime along the hedge bases and woodland edge.

The expected residual impact with implementation of the above mitigation would be minor adverse upon breeding birds, common invertebrates and terrestrial mammals and minor adverse‐neutral upon local sites of importance, habitats, reptiles, badger and foraging/commuting bats.

The overall impact assessment does not take into consideration those species for which further information is required. To fully assess the site for, and the impact of the proposed development upon, protected species, detailed survey is recommended for the following species:

 Preliminary Tree Roost Assessment (PRA)‐ If semi‐mature or mature trees are likely to be impacted upon, i.e where trees will be removed, root protection zones cannot be adhered to, or management is recommended by the appointed arborist, a Preliminary Tree Roost Assessment of the trees must be undertaken.

This report aims to establish an ecological baseline, identifying protected habitats and species that may be affected as a result of the proposed works. It aims to establish if further surveys are required and where possible make recommendations for design options that avoid significant effects on important ecological features and resources. The survey and assessment was completed by independent, qualified and experienced ecologists at a sub‐optimal time of year.

Our assessment found the application site interior to be of low/moderate ecological value, providing nesting opportunities for protected birds, marginal habitat for badger, amphibians and reptiles and habitats of high suitability for foraging and commuting bats.

The proposed development is likely to centre across the short grazed grassland pasture and it is assumed for the purpose of this assessment that there will be no loss of valuable habitats, trees or hedges bordering the site which will be retained and protected during and after the proposed development. We suggest that any habitat loss associated with the proposal can be adequately mitigated through landscaping, planting and other biodiversity enhancement measures.

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Table 1.0 – Executive summary

Protected Species Findings Potential Effect Recommended / Habitat Mitigation, Enhancements & Further survey requirements. Statutory Sissinghurst Park No predicted None Protected Site Wood (SSSI). The impacts (SSSI, RAMSAR main interest of the etc…) site are the rides, the woodland itself being almost entirely sweet chestnut coppice with few standard trees. Protected Species Findings Potential Effect Recommended / Habitat Mitigation, Enhancements & Further survey requirements. Protected/ Field Hedgerows Loss/disturbance Retain. Relax mowing Priority Habitats regime along hedge bases. Amphibians There are two No loss of aquatic Phased cutting of (Including Great ponds situated habitats. Potential grassland. Maintain edge Crested Newt) within 250m of the for injury/ habitats. Raise building application site P1 disturbance during materials off ground or & P2 and no clearance and enclose within fenced records of GCN. P1 construction works. area. Demolition has average materials to be cleared potential whilst P2 form site. has poor potential. Badgers No evidence found Hedges, woodland Precautionary approach on site. and pasture to ground works. provide suitable Enclosed wire mesh habitat. fencing likely to exclude badgers from the site. Bats The south No predicted Prior to any arboricultural woodland trees are impacts subject to works a detailed tree ancient re‐planted retaining mature roost assessment to be and semi‐natural hedgerow and undertaken. over 80 years old woodland trees and contained with potential bat frequent bat roost features. roosting features. Potential lighting Similarly, mature disturbance on hedgerow trees roost entrances. supported roost features.

The hedgerows and woodland

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bordering the site Artificial lighting Artificial lighting should may be used by could preclude bats be kept to the minimum bats as a foraging from foraging along required for safety. Use and commuting the site boundaries of anti‐pollution LED corridor and so this hedgerows and bollard lighting and avoid habitat should be tree canopies. floodlights and security retained, protected lights where possible. Use and not illuminated of timers and PIR/motion during or after the activated lights were development. suitable.

Habitats of “Medium/High” suitability for foraging and commuting bats within and adjacent to site. Birds Trees, hedgerows, Loss of breeding Additional native planting buildings provide and nesting to provide nesting habitat for nesting habitat. opportunities. Bird boxes. birds. Disturbance to birds during works. Works to avoid bird Loss of foraging nesting season 1st March habitat within site. to 15th September Dormice Habitats of No predicted None marginal suitability. impacts Otters, Water No suitable habitat No predicted None. vole and White‐ on site. impacts. clawed Crayfish. Reptiles There are no Habitat loss. Management of on‐site obvious reptile habitats and new habitat habitats present Risk of injuring / creation for reptile within the killing reptiles species. managed pasture during fields, although the development Phased cutting of boundary works. grassland and keeping hedgerows, the grass at a short woodland, ditch height to discourage provide some reptiles from using. suitable habitat for reptile species. The grassland fields are regularly grazed/mown therefore it is unlikely that reptiles would be present in the area or may utilize the development site.

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2. Introduction

2.1. Background

Eco‐Check Ltd was commissioned to carry out a preliminary ecological appraisal (PEA) in relation to a planning application for the demolition of two rearing houses and replacement with two new larger rearing houses to the west across what is currently grazed pasture.

The development areas comprises improved and species poor improved grassland, bare ground, fencing and buildings bordered by intact hedgerows and trees and ancient re‐planted broadleaved woodland. This report is provided to support a planning application to Tunbridge Wells Borough Council for the proposed works at Tolehurst Farm, Cranbrook Road, Frittenden, Kent, TN17 2BP (TQ784403), herein referred to as ‘the site'.

This survey aims to highlight any evidence of (or potential for) protected species or habitats that could result in a constraint to the proposed demolition, clearance and construction works. The assessment follows guidelines produced by the Chartered Institute of Ecology and Environmental Management (CIEEM 2017).

2.2. Site Location and Description Tolehurst Farm is located approximately 2km south of and 4km north of Cranbrook within the Kent High Weald AONB. The site is situated in an isolated rural location close to the A229, TQ 785 401. The farm site in production covers an area of approximately 49ha and is surrounded by arable land and lowland pasture. The area is a gently undulating, lowland clay vale landscape, visually contained and enclosed by the wooded ridge of the High Weald to the south and the Greensand ridge to the north. The landscape of permanent pasture, with some larger arable fields, is studded with numerous small field ponds and water‐filled ditches, set within a framework of mature remnant hedgerow trees and hedgerows. The site itself is bound by post and wire mesh fencing, intact hedgerows and trees, dry ditch and woodland.

Figure 1.0. Site Location ‐ StreeetMap 2015

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2.3. Proposed Works

The application relates to proposals for the demolition of two old rearing sheds and construction of two larger rearing houses approximately 140m to the west across an area of pasture grassland. The footprint of the existing buildings to be demolished is approximately 1,302m² and the new buildings with a footprint of approximately 9,468m² with an increase by 5,353m². The existing access road will be utilised and concrete aprons will border the rearing houses to the east and west, an amenity building is also proposed. The proposed development plans are included in Appendix 1.

2.4. Scope of Survey

The ecological investigations undertaken include:

1. A desk study to gather existing information on statutory and non‐statutory sites of conservation interest, and any protected or notable species.

2. A survey to describe the vegetation and habitats of ecological importance utilizing the Handbook for Phase 1 Habitat Survey, (JNCC, 2010) and the National Vegetation Classification methodology as set out in the NVC Handbook (source: “Handbook for using the National Vegetation Classification” J.S.Rodwell, 2006 Joint Nature Conservation Committee).

3. A reconnaissance survey for evidence of protected species and identification of habitats suitable for such species. In particular the survey adopted the national survey methodologies for badgers, birds, reptiles, amphibians, water voles and bats.

4. Analysis of the data gathered from desk and field surveys and identification of any likely significant effects on protected species, including proposals for avoidance, reduction, compensation and enhancement measures.

5. Assessing the magnitude and nature of any impact the existing and proposed land use would make on the site, evaluate any residual effects of the land use and recommendations for further investigations where necessary.

The assessment aims to:

• Describe the baseline condition of the ecological features within the site;

• Assess the potential construction and operational impacts resulting from biophysical changes incurred by the land use;

• Identify the mitigations necessary to reduce the potential impact of the land use on designated sites, habitats, protected and notable species (i.e. ecological features) which occur within the site);

• Summarise the residual impacts of the land use on the ecology and nature conservation in the zone of influence.

The impact assessment presented in this report was undertaken in compliance with the Chartered Institute of Ecology and Environmental Management Preliminary Ecological Appraisal (CIEEM, 2017). Comments on the ecological value of the site as a wildlife resource and the significance of the change of land use follow the guidelines provided by Regini (2000).

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2.5. Legal Framework

The principal European and UK legislation relating to biodiversity and nature conservation relevant to the proposed development are:

• Conservation of Species and Habitats Regulations (2017)

• The EC Directive on the Conservation of Wild Birds (791409/EEC).

• The Wildlife & Countryside Act (1981) and subsequent amendments.

• The CROW Act 2000, particularly Section 74 habitats and species.

• The Protection of Badgers Act (1992).

The UK government is committed to a significant reduction of the current rate of biodiversity loss by 2020. This commitment is recognised in:

• The England Biodiversity Strategy

• UK Biodiversity Action Plan (UK BAP)

• Biodiversity 2020: A Strategy for England’s Wildlife

• National Planning Policy Framework (Replacement of PPS9);

• BS 42020:2013‐ Code of Practice for Planning and Development

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3. Methodology

3.1 Desk Study and Data Consultation

A desk study was undertaken using the Magic website to identify both statutory and non‐statutory designated sites for conservation and to identify the presence of priority/protected habitats or species within 2km of the proposed works.

A desk study for statutory and non‐statutory wildlife sites and protected and priority species was undertaken using records supplied by Kent and Biological Record Centre (KMBRC), 1:25000 scale maps and local satellite imagery was also reviewed prior to the field survey to identify features of potential interest including ponds, woodland, meadows and adjacent high‐quality habitat.

The potential for protected rare and/or priority species to be on site has been assessed considering the nature of the site and the habitat requirement of the species in question. Absence of records does not constitute absence of a species. Habitats on‐site may be suitable to support other protected/priority species that have not previously been recorded within the search area.

KMBRC does not allow its species records to be made publicly available, such as direct inclusion within this report. Species recorded have been taken into consideration for our impact assessment, however any accurate locations are determined to be sensitive and cannot be revealed.

3.2 Surveyor and Weather Conditions

The survey was undertaken on 9th November 2018 by James Hodson of Eco‐Check Ltd, an experienced ecological consultant with a BSc (Hons) in Environmental Sciences and MSc in Environmental Impact Assessment and licensed to undertake bat surveys and to disturb bats under Natural England Level 2 Bat Survey License 2017‐30927‐CLS‐CLS and great crested newts 2018‐36283‐CLS‐CLS. The weather was calm (2‐3 on the Beaufort scale), Sunny (<5% cloud cover) and 15 degrees C.

3.3 Phase One Habitat Survey

The vegetation and habitat types within the site were noted during the survey in accordance with the categories specified for a Phase 1 Vegetation and Habitat Survey (JNCC, 2010). Dominant plant species were recorded for each habitat present.

The site was inspected for evidence of and its potential to support protected or notable species, especially those listed under the Conservation of Habitats and Species (Amendment) Regulations 2017, the Wildlife & Countryside Act 1981 (as amended), including those given extra protection under the Natural Environment and Rural Communities (NERC) Act 2006 and Countryside & Rights of Way (CRoW) Act 2000, and listed on the UK and local Biodiversity Action Plans. Such species include amphibians, reptiles, bats, badgers, birds, dormice and water voles. Evidence of badgers was searched for throughout the site, including setts, footprints, feeding signs, hairs and droppings.

The site was searched for evidence of invasive plant species, such as Japanese knotweed (Fallopia japonica), Himalayan balsam (Impatiens glandulifera), giant hogweed (Heracleum mantegazzianum), horizontal/wall cotoneaster (Cotoneaster horizontalis) and floating pennywort (Hydrocotyle ranunculoides).

As the attributes of the site and its potential for protected, notable and invasive species may change over time, this report is broadly considered valid for a duration of two years, after which time it is recommended that an update site assessment is undertaken. In some cases, protected or invasive

10 species’ use of a site may change over a shorter timescale, for instance the use of a badger sett by badgers, which may change month to month. In such cases, appropriate precautionary advice or recommendations for update surveys are given within this report. The survey was carried out during the winter season and so the majority of flowering plants (March‐August) will likely be unrecorded.

3.4 Protected and Key Species Survey

Amphibians (Including Great Crested Newts)

Any ponds, lakes, reservoirs or other water bodies on site, or within 250M (with good habitat connectivity) were assessed for their potential to support breeding populations of amphibians, specifically Great Crested Newts. Assessing potential suitability for Great Crested Newt is undertaken using the Habitat Suitability Index (HSI), a geometric mean of ten habitat suitability criteria (see table 1.0) (Oldham et al. 2000). The resulting HSI score should be interpreted as either; Excellent (>0.8), Good (0.7 – 0.79), Average (0.6 – 0.69), Below Average (0.5 – 0.59) potential for supporting Great Crested Newts (Oldham et al. 2000)

Table 2.0 – Habitat suitability criteria used to calculate (HSI), the suitability of a pond to support Great Crested Newts (based on Oldham et al. 2000)

Indices Name: Description:

SI1 Geographic Location Lowland England or upland England, Scotland and Wales

SI2 Pond area To the nearest 50m²

SI3 Permanence Number of years pond dry out of ten

SI4 Water quality Measured by invertebrate diversity

SI5 Shade Percentage shading of pond edge at least 1m from shore

SI6 Fowl Level of waterfowl use

SI7 Fish Level of fish population

SI8 Pond count Number of ponds within 1km divided by 3.14

SI9 Terrestrial habitat Quality of surrounding terrestrial habitat

SI10 Macrophytes Percentage extent of macrophyte cover

Badgers

A visual assessment for setts, latrines, prints and evidence of foraging activity was undertaken within the site boundaries.

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Bats

A Preliminary Roost Assessment (PRA) was undertaken in accordance with methods outlined in the Bat Conservation Trusts “Bat Surveys for Professional Ecologists” (Collins, 2016) Including both a desk‐based and field‐based assessment. Details of these guidelines can be found in table 3.0.

Table 3.0 ‐ Guidelines for assessing the potential suitability of proposed development sites for bats, based on the presence of habitat features within the landscape (Adapted from table 4.1 pp. 35 in Collins, 2016)

Suitability. Description of Roosting habitats. Description of Commuting and Foraging habitats. Negligible Negligible habitat features on‐site Negligible habitat features on‐site likely to be used by roosting bats. likely to be used by commuting or foraging bats.

Low A structure with one or more Habitat that could be used by small potential roost sites that could be numbers of commuting bats such as a used by individual bats gappy hedgerow or un‐vegetated opportunistically. However, these stream, but isolated, i.e. not very well potential roost sites do not provide connected to the surrounding enough space, shelter, protection, landscape by other habitat. appropriate conditions and/or suitable surrounding habitat to be Suitable, but isolated habitat that used on a regular basis or by larger could be used by small numbers of numbers of bats (i.e. unlikely to be foraging bats such as a lone tree (not suitable for maternity or in a parkland situation) or a patch of hibernation.) scrub.

A tree of sufficient size and age to contain PRFs but with none seen from the ground or features seen with only very limited roosting potential.

Medium A structure or tree with one or Continuous habitat connected to the more potential roost sites that wider landscape that could be used by could be used by bats due to their bats for commuting such as lines of size, shelter, protection, conditions trees and scrub or linked back and surrounding habitat but gardens. unlikely to support a roost of high conservation status Habitat that is connected to the wider (with respect to roost type only – landscape that could be used by bats the assessments in this table are for foraging such as trees, scrub, made irrespective of species grassland or water. conservation status, which is established after presence is confirmed).

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High A structure or tree with one or Continuous, high‐quality habitat that more potential roost sites that are is well connected to the wider obviously suitable for use by larger landscape that is likely to be used numbers of bats on a more regular regularly by commuting bats such as basis and potentially for longer river valleys, streams, hedgerows, periods of time due to their size, lines of trees and woodland edge. shelter, protection, conditions and . surrounding habitat. High‐quality habitat that is well connected to the wider landscape that is likely to be used regularly by foraging bats such as broadleaved woodland, tree‐ lined watercourses and grazed parkland. Site is close to and connected to known roosts.

The habitats on and around the site were assessed for their commuting and foraging potential for bats. An evaluation system was applied to the commuting and foraging potential using the following criteria.

• Negligible commuting and foraging potential for bats. Habitat features unlikely to be used by commuting or foraging bats.

• Low commuting and foraging potential for bats. Habitats that could be used by a small number of commuting or foraging bats such as, a gappy hedgerow, unvegetated stream or lone trees, but are isolated and not well connected to the surrounding landscape.

• Medium commuting and foraging potential for bats. Habitats that are continuous and connected to the wider landscape such as, lines of trees, scrub, linked back gardens, grasslands and water features.

• High commuting and foraging potential for bats. Habitats that are continuous and connected to the wider landscape such as, river valleys and tree lined watercourses, hedgerows, lines of trees, deciduous woodland, and grazed parkland. These habitats are likely to be used regularly by commuting or foraging bats and are likely to be close to, or connected to, known roosts.

Birds

On‐site habitats were assessed for their potential to support breeding (nesting) birds. All bird species observed during the two field surveys as well as the reptile survey visits were recorded. Birds observed were categorized based on both their RSPB and BAP status.

Dormice

An initial inspection for evidence of Dormice or habitats that could support Dormice was undertaken.

Invertebrates

Specific sampling for invertebrates falls outside of the remit of a Preliminary Ecological Assessment. However, any invertebrates observed incidentally during the survey were recorded.

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Otters, Water voles, and White‐Clawed Crayfish.

On‐site habitats were assessed for their suitability to support Otters, Water Voles and White‐Clawed Crayfish.

Reptiles

All on‐site habitats were assessed for their potential to support reptiles and all any pre‐existing refugia including discarded plastics, paving slabs, bricks and wood were carefully examined in search of live individuals.

Risk Definition Category

PRESENT Presence confirmed in the course of current survey or recent, confirmed records. HIGH On-site habitat of high quality for a given species/species group. Site within/peripheral to a national or regional population stronghold. Good quality surrounding habitat and good connectivity. MODERATE On-site habitat of moderate quality, providing most or all of the known key requirements of a given species/species group. Local returns from the data search, within national distribution, suitable surrounding habitat. Factors limiting the likelihood of occurrence may include small habitat area, habitat severance, disturbance etc. LOW On-site habitat of poor to moderate quality for a given species/species group. Few or no returns from data search but presence cannot be discounted on the basis of national distribution, nature of surrounding habitats, habitat fragmentation, recent on-site disturbance etc. NEGLIGIBLE While presence cannot be absolutely discounted, the site includes very limited or poor quality habitat for a particular species or species group. No local returns from a data search, outside or peripheral to known national range for a species, surrounding habitat considered unlikely to support wider populations of a species/species group. UNKNOWN Insufficient data to make a determination of the risk of a species presence or absence. Table.4.0 Criteria for assessing presence of protected species

3.5 Impact Assessment

The assessment was undertaken in accordance with CIEEM (2016) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd Edition. Chartered Institute of Ecology and Environmental Management, Winchester.

In summary the impact assessment process involves:

 Assessing the value of ecological receptors at the site and those nearby that could be affected (e.g. designated sites, habitats, species);  Identifying the unmitigated impacts of the development (magnitude, spatial extent, duration, timing/frequency, reversibility);  Providing measures to avoid and mitigate for impacts;  Assessing the significance of residual impacts after specified mitigation;  Identifying appropriate compensation measures to offset significant residual effects, and;  Identifying enhancement opportunities to provide a new benefit for biodiversity.

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Value/scale of ecological features:

The value of ecological features uses conservation status (i.e. extent, relative abundance and distribution) to assign geographic levels at which the feature is considered to hold importance.

Ecological features should be evaluated within a defined geographical context (CIEEM, 2016). These are based upon criteria identified in the CIEEM (2016) guidance, which categorise the geographic context of ecological importance as within one of the following:

 International and European;  National;  Regional;  County, or local authority; and,  Local Importance/Parish (High or Low Value).

Only features deemed “important ecological features” (the term used in CIEEM, 2016) are carried forward into the assessment of potential impacts. Important ecological features are:

 Considered to be sufficiently valuable to the decision‐making process; and specifically of ”Local Importance (Higher value)” or higher using the geographic frames of reference in Appendix B and,  Likely to be significantly affected by the project (CIEEM, 2016).

For habitats, this includes the structure and composition of plant communities, the species they may support, and over what distance the habitat may have influence over e.g. wetlands may attract wintering birds from hundreds of mile away, whereas a small block of scrub may only support fauna in the local area

For species, this includes the abundance and distribution within a given geographical area e.g. a small population of great crested newt may be assessed to be of ‘local’ importance in the south of England where populations are abundant but, but of ‘county’ importance in the north of England where the species is more scarce. In depth details of geographic values of importance are summarised in Appendix 2.

Ecological features valued at Local Importance (Lower Value) or of negligible value (as per the valuation criteria in Appendix B) are not considered significant features and are scoped out of impact assessment.

It is not necessary to carry out detailed assessment of features that are sufficiently widespread, unthreatened and resilient to project impacts and will remain viable and sustainable (CIEEM, 2016). In some cases the data collected as part of the scoping process will be sufficient to inform the assessment of effects on a given feature. In other cases additional surveys will need to be undertaken.

Ecological features which are within the zone of influence of a development, but not considered important ecological features, can be ‘scoped out’ (excluded), with justification.

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Scale of impact and confidence levels:

Impacts on ecological features can occur either directly (e.g. loss of habitats, habitat fragmentation, noise/light disturbance) or indirectly (e.g. water/air quality, noise and light pollution, recreational disturbance). The overall impact is subjectively assessed taking into consideration a range of factors, including conservation status of an ecological feature, magnitude, spatial extent, duration, timing/frequency and reversibility. Impacts can be both positive and negative. The guidance used to quantify the scale of impacts is provided below;

Table 5.0 – Definitions of impact magnitude

The assessment of these impacts are subjective and based on predictions based on the available evidence and therefore may be inaccurate if predicted activities change or scale/extent of the proposed development alters. Therefore, we provide an indication of confidence levels for our assessment using the following criteria:

 Certain probability estimated at above 95%  Likely probability estimated above 50% but below 95%  Possible probability estimated at above 5% but below 50%  Unlikely probability estimated at less than5%

Consideration is also given to the potential for the development proposal to give rise to significant negative impact in combination with other proposed development in the area, where relevant. An overall assessment of value and predicted impact is provided, and this is based upon the highest level of value of any of the features or species present or likely to be present on the site, and similarly the overall assessment would be the impact of greatest significance.

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3.6 Limitations

Desk Study

These results can only give an indication of species presence in this location. The absence of recent records for certain species in an area may be due to the lack of survey effort or the non‐submission of records, rather than the absence of those species. Many species records are also at low resolution and do not indicate their exact location.

Field Survey

The comprehensiveness of the ecological assessment was limited by the season in which the site visit was made. To confirm the presence or absence of all protected species usually requires multiple visits at suitable times of the year. Summer surveys between May and September are considered optimal. The site visit focussed on assessing the potential of the site to support species given protection under British or European law. In view of the above constraints this assessment cannot be considered to provide a comprehensive survey of the ecological interest of the site. It does however provide a “snapshot “of the ecological interest present on the day of the visit and highlights areas where further survey work may be required.

3.7 Legislation

Protected Species

Bats

All bat species are listed under Annex IV (and certain species also under Annex II) of the European Union’s Council Directive 92/43/EEC (The Habitats Directive), and are given UK protected status by Schedule 2 of the Conservation of Habitats and Species Regulations 2017. Bats and their roosts also receive protection from disturbance from by the Wildlife and Countryside Act 1981 (as amended by the Countryside and Rights of Way Act 2000). This protection extends to both the species and roost sites. It is an offence to kill, injure, capture, possess or otherwise disturb bats. Bat roosts are protected at all times of the year (making it an offence to damage, destroy or obstruct access to bat roosts), regardless of whether bats are present at the time.

Birds

All bird species are protected under the Wildlife and Countryside Act 1981 as amended. This prevents killing or injuring any bird or damaging or destroying nests and eggs. Certain species (including barn owl Tyto alba) are also listed under Schedule 1 of the Wildlife and Countryside Act 1981, which prevents disturbance of the species or its nest and/or eggs at any time with protection by special penalties.

Reptiles

All native reptiles are listed on Schedule 5 of the Wildlife and Countryside Act 1981, and are afforded protection under Sections 9(1) and 9(5). For the reptile species occurring in Norfolk, adder Vipera berus, grass snake Natrix natrix, slow‐worm Anguis fragilis and common lizard Zootoca vivipara, this protection prohibits deliberate or reckless killing and injury but does not include habitat protection.

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Great Crested Newts

The great crested newt Triturus cristatus is fully protected in accordance with both national and international legislation. The species is listed under Annexes IV and II of European Directive 92/43/EEC, and Schedule 2 of The Conservation of Habitats and Species Regulations 2017. The species is also protected by Sections 9(4) and 9(5) of the Wildlife and Countryside Act 1981 as amended. It is an offence to knowingly or recklessly kill, injure, disturb, handle or sell the animal, and this protection is afforded to all life stages. It is unlawful to deliberately or recklessly damage, destroy, or obstruct the access to any structure or place used for shelter or protection; this includes both the terrestrial and aquatic components of its habitat.

Badger

Badgers Meles meles are protected under the Protection of Badgers Act 1992 and the Wildlife and Countryside Act 1981 (as amended). Under Section 1 of the Protection of Badgers Act 1992, it is a criminal offence, subject to certain mitigating circumstances, to wilfully kill, injure or take a badger, and under Section 3 of this legislation it is a criminal offence, in most circumstances, to destroy, damage or obstruct access a badger sett or part of it. A badger sett is defined in the 1992 Act as any structure or place that displays signs indicating use by a badger. Although a sett may be empty at a particular time, it may be used as part of a regular cycle throughout the year, and can therefore be considered to be in use. Under certain conditions, activities that could otherwise give rise to an offence may be licensed by the Department for Environment, Food and Rural Affairs (Defra) (for agricultural or land drainage purposes) or Natural England (for development covered by planning permission). A sett which can be shown to have been unused for at least a full year is considered to fall outside of the provisions of the 1992 Act. The badger is listed under Schedule 6 of the Wildlife and Countryside Act 1981 (as amended), which identifies animals that may not be killed or taken by certain methods.

Statutory Designated Conservation Sites

National ecological designations, such as Sites of Special Scientific Interest (SSSI) and National Nature Reserves (NNR), are also afforded statutory protection. SSSIs are notified and protected under the jurisdiction of the Wildlife and Countryside Act 1981 as amended. SSSIs are notified based on specific criteria, including the general representativeness and rarity of the site and of the species or habitats supported by it.

Local Non‐statutory Designated Conservation Sites

Local sites of importance to biodiversity, but falling below the criteria for SSSI selection, are designated in Kent as Local Wildlife Sites (LWS). These sites have no statutory protection, but are normally given consideration within local plans.

Species and Habitats of Principal Importance

Other priority species and habitats which are a consideration under the National Planning Policy Framework (NPPF) 2012, placing responsibility on Local Planning Authorities to aim to conserve and enhance biodiversity and to encourage biodiversity in and around developments. There is a general biodiversity duty in the Natural Environment and Rural Communities (NERC) Act 2006 (Section 40)

18 which requires every public body in the exercising of its functions to ‘have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’. Biodiversity, as covered by the Section 40 duty, includes all biodiversity, not just the Habitats and Species of Principal Importance.

Section 41 of the NERC Act lists a number of species and habitats as being Species/Habitats of Principal Importance. These are species/habitats in England which had been identified as requiring action under the UK BAP, and which continue to be regarded as conservation priorities under the UK Post‐2010 Biodiversity Framework. The protection of either Species of Principal Importance or Habitats of Principal Importance is not statutory, but “specific consideration”1 should be afforded by Local Planning Authorities when dealing with them in relation to planning and development control. Also, there is an expectation that public bodies would refer to the Section 41 list when complying with the Section 40 duty.

Figure 2.0. Aerial view of Site, proposed demolition and construction working areas and habitat map (not to scale) ‐ Google Earth 2018

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4. Survey Results

4.1. Desk Study

4.1.1. Designated sites

Sissinghurst Park Wood (SSSI) is situated 2km to the south‐east. The main interest of the site are the rides, the woodland itself being almost entirely sweet chestnut coppice with few standard trees.

There is a single Local Wildlife Site (previously called Sites of Importance for Nature Conservation‐ SINCS) within the search area;

 Leggs Wood, Frittenden, 40ha ‐ 775m east of site

Figure 3.0. Map of Designated Wildlife Sites and Priority Habitats within 2km – Magic Map 2018

RSPB

There are no RSPB sites within 2km of the site.

Protected / Priority Habitats:

Deciduous Woodland

Within 2km there are a number of blocks of broadleaved deciduous woodland, ancient/re‐planted and semi‐natural woodland, listed as a UK Priority Habitat in the National Forest Inventory 2014 (Magic, 2018) See Figure.3.0.

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Other Non‐Priority Habitats

Other priority habitats including traditional orchard and good quality semi‐improved grassland.

4.1.2. Notable species

The desk study returned records of 282 animal species records within 2km of the site. None of the records were identified within the development site. The records included;

1. The data request to Kent Bat Group returned a large number of records within the 5km search radius, this included: common pipistrelle, soprano pipistrelle, daubenton’s, natterer’s, serotine, noctule and brown long‐eared bat). All bats and their roosts receive strict legal protection from harm and are Species of Principal Importance and UK/Kent BAP species. 2. 1 record of hedgehog (Erinaceus europaeus) 3. 130 bird species including a variety of birds of conservation concern (BoCC) and UK/BAP species including skylark (Aluada arvensis), house sparrow (Passer domesticus), cuckoo (Cuculus canorus), turtle dove (Streptopelia tutur), little owl (Athene noctua), buzzard (Buteo buteo), house martin (Delichon urbicum), yellowhammer (Emberiza citronella), reed bunting (Emberiza schoeniclus), spotted flycatcher (Muscicapa striata), barn owl (Tyto alba), marsh tit (Poecile palustris), tawny owl (Strix aluco), starling (Sturnus vulgaris), fieldfare (Turdus pilaris), song thrush (Turdus philomelos) and mistle thrush (Turdus viscivorous). 4. There is a single historical badger record from Knoxbridge (2005) approximately 1km north of the farm. 5. There are two historical records of Hazel dormouse (Muscardinus avellanarius) within Brewers Wood which is adjacent to the southern farm boundary. These records are over 30 years old and give little indication to the likely population status of this species in the area. There are 4 other records within 2km all dating from 2014. 6. There are no historical records of common frog, common toad, reptiles, water vole, otter or great crested newt within the search radius.

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4.2. Habitats Habitats within and bordering the proposed demolition and construction works includes bare ground, buildings, broadleaved woodland, hedging and trees, dry ditch and tall ruderal vegetation. All of these habitats are common and unexceptional as habitats in their own right, although are discussed in relation to their potential to support protected species below.

The botanical diversity across the construction area is very limited comprising short grazed/mown semi‐improved and improved pasture grassland and occasional tall ruderals. The wider site boundaries have a greater diversity and ecological value associated with the trees, ditches and hedging.

The following broad habitat types and species were recorded at the site:

 Bare ground – J4  Broadleaved woodland‐ A1.1.1  Buildings – J3  Dry Ditch‐ J2.6  Improved and Semi‐improved grassland – B4/B6  Species poor intact hedge and trees – J2.3.2  Tall Ruderal – C3.1

Bare Ground (J4) Bare ground comprises a tarmacadam driveway running along the north edge of the survey areas and north of the existing and proposed buildings. A concrete apron borders the existing buildings to the east side.

Broadleaved Woodland‐ (A1.1.1) The existing and proposed buildings are bordered along the south boundary by broadleaved deciduous woodland and appears on the National Forest Inventory as UK Priority Habitat. The east section adjoining the existing buildings is semi‐natural with some more recent poplar plantation trees along the woodland edge. The west section bordering the field for the proposed new buildings is classified as ancient re‐planted woodland. The woodland trees specimens include grey willow (Salix cinerea), silver birch (Betula pendula), cherry (Prunus spp.), ash (Fraxinus excelsior), sycamore (Acer pseudoplatanus), alder (Alnus glutinosa), field maple (Acer campestre), oak (Quercus robur), beech (Fagus sylvatica) and holly (Ilex aquafolium). Some younger screening tree belts are present along the north woodland edge comprising Lombardy poplar (Populus nigra).

Buildings (J3.6) The existing rearing sheds cover approximately 1,300m². The buildings are constructed from concrete block base, external timber cladding and corrugated asbestos sheet. A small timber log‐cabin building is located 40m to the west but does not form part of the application.

Dry Ditch (J2.6) Along the north edge and north‐east corner of the ancient re‐planted woodland is a dry ditch (D1) approximately 2m wide. The ditch lacked any aquatic vegetation and only holds water at certain times of year when draining off the pasture fields. The banks of the ditch comprise rough grassland and tall ruderals with some stands of bramble (Rubus spp.)

Improved grassland (B.4) The area of land bordering the existing rearing houses comprises short mown improved grassland, the sward height was approximately 2‐5cm and consists of predominantly ryegrass (>50% Lolium perenne). The other dominant grassland species included common nettle (Urtica diocia), cleavers (Galium aparine), broad‐leaved dock (R. obtusifolius), creeping buttercup (Ranunculus repens), white clover (Trifolium repens), daisy (Bellis perennis), bristly ox‐tongue (Helminthotheca echioides), creeping thistle (Cirsium arvense), ribwort plantain (Plantago lanceolata) and dove’s foot cranesbill (Geranium mole).

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Species Poor Semi‐Improved Grassland (B6) The field containing the proposed new rearing sheds and to the west of the existing buildings comprises species poor semi‐improved grassland with a taller sward height of approximately 10‐15cm. The dominant grassland species included ryegrass ( Lolium perenne), false oat‐grass (Arrhenatherum elatius), cock’s foot (Dactylis glomerata), yorkshire fog (Holcus lanatus), common nettle (Urtica diocia), creeping bent (Agrostis stolonifera), cleavers (Galium aparine), broad‐leaved dock (R. obtusifolius), creeping buttercup (Ranunculus repens), white clover (Trifolium repens), daisy (Bellis perennis), bristly ox‐tongue (Helminthotheca echioides), creeping thistle (Cirsium arvense), ribwort plantain (Plantago lanceolata), vetch (Vicia sativa), yarrow (Achillea millefolium), Flowering plants included white dead nettle (Lamium album), white campion (Silene latifolia), creeping cinquefoil (Potentilla reptans), scentless mayweed (Tripleurospermum inodorum) and common mallow (Malva neglecta).

Species Poor Intact Hedgerow and Trees (J2.3.2) The pasture fields are bordered by post and wire mesh fencing with mature mostly intact hedging and trees. The existing and proposed buildings are bordered to the north by a managed hedgerow (H1) with mature tree standards. The hedgerow comprises mostly hawthorn (Crataegus monogyna), blackthorn (Prunus spinosa), field maple (Acer campestre) and some standard trees of oak (Quercus robur), ash (Fraxinus excelsior), beech (Fagus sylvatica), silver birch (Betula pendula) and sycamore (Acer pseudoplatanus).

Tall Ruderal (C3.1) Tall ruderal vegetation is frequent along the base of the hedgerows, adjacent to the scattered trees, dry ditch, building edges and along the fence lines. The species noted included nettle (Urtica dioica), yarrow (Achilliea millefolium), ragwort (Jacobaea vulgaris), scentless mayweed (Tripleurospermum inodorum), cow parsley (Anthriscus sylvestris), hogweed (Heracleum sphondylium), thistle (Cirsium spp.), mugwort (Artemisia vulgaris) and sheep’s sorrel (Rumex acetosella.

4.3. Fauna

4.3.1. Field Survey Records

Faunal species observed at the site or in close proximity to the site is presented in Table.6.0

Common Name Scientific Name Black bird Turdus merula Buzzard Buteo buteo Carrion crow Corvus corone Chaffinch Fringilla coelebs Dunnock Prunella modularis (Amber) Gold finch Carduelis carduelis Great tit Parus major Grey squirrel Sciurus carolinensis Jay Garrulus glandarius Kestrel Falco tinnunculus Pied wagtail Motacilla alba Pigeon Columba livia domestica Robin Erithacus rubecula Table.6.0 Faunal species recorded

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Table 7.0, below, details the suitability of habitats within the site for key protected species. Species not detailed below are considered unlikely to be significantly impacted by the proposed works.

Species General Habitat Suitable habitat within site Additional notes (e.g. evidence of Requirements species) Reptiles Long grass, scattered Rough grassland and No reptile records in local area. scrub, hedgerows hedgerows Grass routinely mown/grazed. Invertebrates Species‐dependent. High Semi/improved grassland, Given the low diversity of suitable invertebrate diversity is woodland and hedgerows habitats and species, it is unlikely favoured in sites with a that the site supports any rare or mosaic of habitats and notable invertebrate populations diverse plant assemblage. or a diverse invertebrate assemblage.

Nesting birds Trees, shrubs, scrub, Trees, woodland, hedgerows, Evidence of birds nesting in hedgerows, cavities within woodland trees and hedgerows. buildings, waterbodies, Dunnock an Amber listed bird of arable fields, bare/stony conservation concern was ground. recorded. Badger Woodland, dense scrub, Some permanent grassland, No evidence of badgers was found meadows, field edges. pasture field margins and during the survey, such as setts, woodland. footprints, latrines, feeding evidence or hairs. Site is bound by wire and mesh fencing which may exclude badgers from the site. Great Breed in ponds and other Hedgerows, rough grassland, There are 2 ponds within 250m as crested waterbodies. Terrestrial woodland, ponds detailed in Section 4.3.2 and 5 of newts habitat includes woodland this report. The suitable terrestrial and grassland. habitats are small and subject to regular disturbance making the site less likely to be used. No GCN records within 2km. Refer to Section 5 & 6 of this report. Bats Roost in buildings, tree Some mature oak, beech, ash Boundary habitats likely used by cavities and caves. and sycamore specimens with foraging and commuting bats. No roost features identified in trees being removed. Refer to hedgerow (H1) and adjacent Section 5 & 6 of this report woodland but are not subject to disturbance. Table 7.0 – Protected and Priority Species

4.3.2 Protected Species and Other Species of Nature Conservation Importance

Invertebrates

No records for protected or Red Data Book (RDB) listed invertebrates within 1 km of the application area were provided. Small heath and scarce chaser have been recorded locally.

Mature trees within and adjacent to the site may provide some. However, mature trees with standing deadwood are confined to the wider site boundaries and outside the site interior. The site lacks the required diversity of deadwood to support significant populations of saproxylic invertebrates and is therefore not considered to be of importance to saproxylic invertebrates outwith the zone of immediate influence.

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Other habitats within the application area are not considered botanically or structurally diverse enough to support protected or nationally/locally rare invertebrate species and as such are not considered to be of importance to nature conservation outwith the immediate zone of influence.

Amphibians ‐ Great Crested Newt (GCN)

The site habitats of short grazed/mown grassland, bare ground and tall ruderals are of limited value to GCN. The boundary hedgerows, woodland and rough grassland margins provide some suitable terrestrial habitat.

Great crested newt is listed on Annexes II and IV of the EC Habitats Directive. It is protected under the Wildlife and Countryside Act (1981) (as amended) and is identified as a European Protected Species on the Conservation of Species and Habitats Regulations (2017). It is a UK BAP Priority Species and is listed on the local BAP.

2 ponds were identified within a 250m radius of the site boundaries as shown in Figure 2.

 Pond P1‐ 100m east of proposed new rearing houses and 35m north of existing buildings.  Pond P2‐ A large waterbody 210m south of the existing and proposed buildings.

Ponds P1 and P2 were assessed for their suitability to support great crested newts. The south boundary ditch D1 was dry and appears to only contain water occasionally and so was not assessed. The two ponds P1 and P2 were assessed as detailed below in Table 8.0.

The managed grassland across the construction area and bordering the buildings to be demolishes is a low value terrestrial habitat for GCN however the presence of amphibians and reptiles using the rough boundary grassland, tall herb, dead wood habitats, tree roots, leaf piles, ditch, hedge etc. for refuge and hibernaculum cannot be excluded entirely and so the site should be cleared in a sensitive manner.

HSI P1 P2 S1‐ Geographic zone 1 1 S2‐ Pond area 0.79 0 S3‐ Pond drying 0.9 0.9 S4‐ Water quality 0.67 1 S5‐ Shade 0.6 0.6 S6‐ Fowl 0.67 0.01 S7‐ Fish 0.33 0.01 S8‐ Pond density 1 1 S9‐ Terrestrial habitat quality 0.67 1 S10‐ Macrophyte cover 0.36 0.41 HSI 0.66 (Average) 0.1 (Poor) Table 8.0 ‐ HSI Assessment

Further recommendations with regards to GCN are provided in Section 5 & 6 below.

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4.3.3. Bats

All species of bat are protected under the EC Habitats Directive (1992), as implemented by the Habitats and Species Regulations (2017). These regulations amend the Wildlife and Countryside Act (1981) (as amended) which provides protection to certain animals under Section 9 and listed in Schedule 5 of the Act. Under the Act (as amended) it is an offence intentionally or recklessly to kill, injure, capture or disturb bats or to damage, destroy or obstruct access to any place used by bats for shelter or protection.

Buildings

A search of the exterior of the rearing houses to be demolished found no bat droppings, feeding remains or any evidence of bat activity or roosting bats. Due to restrictions on entering the building, internal inspections were not carried out. All facets were secure giving no potential entrances for bats. Corrugated roof profiles were documented where spaces could allow access to the roof voids. Taking into the consideration above, the building was assessed as having Negligible probability of bat interest due to the lack of suitable roost features, lack of evidence of bat activity and fact that the building has constant disturbance from hens, working activities, regular decontamination procedures and artificial lighting.

Trees

All trees were assessed for features such as cracks or cavities which may be of potential interest to roosting bats. The poplar plantation trees bordering the south side of the existing buildings are only approximately 20 years old and were assessed as having negligible potential to support roosting bats as no roost features were present; such as rot holes, peeling bark and woodpecker holes.

Within the block of ancient re‐planted woodland south of the proposed new rearing sheds and within the north hedgerow (H1) are numerous mature oaks, beech, sycamore and ash specimens which have moderate/high bat roost potential with tears, fissures, rot holes, flaking bark etc. None of these trees are being disturbed by the proposed new buildings or demolition works.

The boundary trees should be protected in accordance with BS:5837: 2012‐ Trees in Relation to Design, Demolition and Construction. The large open pasture fields surrounding the farm site, and the intact hedgerows, woodland, buildings, open water etc. are of high value to foraging and commuting bats and the site has good connectivity and foraging and commuting routes. The construction works and subsequent site operations will have no direct effect upon individual bats or their roosts subject to a sensitive lighting scheme and avoiding illumination of the boundary habitats.

Habitats

The proposed layout (Appendix 1) is not considered to infer any adverse impacts upon the foraging and commuting resources of the local bat population subject to a sensitive lighting scheme to avoid illumination of the boundary hedges, trees and woodland and further surveys are not considered necessary. Details of this are provided in Section 6 below.

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Bird species

All wild birds in the UK are protected under Section 1 of the Wildlife and Countryside Act (1981) (as amended) which makes it an offence to intentionally kill, injure or take any wild bird or to take, damage or destroy the nest (whilst being built or in use) or its eggs. Bird species listed in Schedule 1 of the Wildlife and Countryside (1981) Act, receive further protection which makes it an offence to intentionally or recklessly disturb these species while building a nest or in, on or near a nest containing eggs or young; or to disturb dependent young of such a bird.

The woodland, hedgerows and trees provide habitat for nesting birds. In addition, the pasture fields provide habitat for farmland ground nesting birds such as skylark and lapwing depending on management and sward height. A small number of common birds were noted on or flying over the site as detailed in Table 6.0. Recommendations for nesting birds are provided in Section 5 & 6 below.

Reptiles

The managed pasture grassland is of low value to reptile species however the rough boundary vegetation, hedges, ditch, woodland and tall ruderal vegetation combined with some open basking areas potentially provides habitat for grass snake (Natrix natrix) with adder (Vipera berus), common lizard (Zootoca vivpara) and slow worm (Anguis fragilis) less likely to be encountered. There are no potential refugia and hibernaculum within the site. No reptile records were returned within 2km of the site. No further surveys with regards to reptiles are therefore required although some avoidance measures are recommended in Section 5 & 6.

Badger

No evidence of badgers was found during the survey, such as setts, footprints, latrines, feeding evidence or hairs. No badger records within 1km of site. The hedgerows, ditch, woodland and permanent pasture grassland provide habitat for foraging badgers. However, the grazing fields are secured by post and wire mesh fencing which restrict access for badgers and other large mammals. In the event that any badgers are found during the course of the proposed works, work should be halted immediately, Natural England should be informed and allowed time to advise.

Hedgehog and Brown Hare

There was a single record of Hedgehog Erinaceus europaeus returned from within 2km of the Site. In addition to a single records of Brown Hare Lepus europaeus, both Species of Principal Importance, were also identified in the data search. Hedgehogs are protected under Schedule 6 of the Wildlife and Countryside act (as amended) and is listed as a Priority Species under the UK Biodiversity Action Plan. It is probable that hedgehogs are present on this site, at least at times. There is suitable habitat within the pasture fields and hedgerows as well as the adjacent woodland, pasture and farmland. No hedgehogs or droppings were observed during the site survey.

Otter, Water Vole and White‐Clawed Crayfish

There is Negligible risk of Otter, Water Vole or White‐Clawed Crayfish on site.

Invasive Plant Species

No invasive plant or animal species listed on Schedule 9 of the Wildlife and Countryside Act (1981) (as amended) were recorded on the day of the survey.

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5. Evaluation, Recommendations and Impact Assessment

Please note that all evaluation and recommendations are based upon the findings of this preliminary ecological appraisal and on the proposal outlined in 2.3 above. If the site changes then the potential for protected species to use the site may change accordingly. If the proposals alter from those at present then it is possible that the likely impacts will also change.

5.1. Bird Species

5.1.1. Overview of legislation relating to bird species

Under the Wildlife and Countryside Act 1981 it is illegal to take, damage or destroy the nests of wild birds whilst being built or in use. It is not an offence to carry out work in areas that they use, outside of the nesting period.

5.1.2. Summary of findings and likely impacts in absence of mitigation

Improved grassland pasture, arable fields and set‐aside habitat are suitable to ground‐nesting species such as skylark Alauda arvensis –UK Biodiversity Action Plan (UKBAP) and Birds of Conservation Concern (BoCC) Red List species.

The boundary hedgerows and woodland contained evidence of nesting birds and should be retained and protected during the course of the development. Nesting birds would likely be disturbed by demolition works, tree felling and arboricultural works during the period 1st March to 15th September.

The value of the site, for breeding birds is assessed as likely being of Low value at the Parish/ Neighbourhood scale and the impact of the development on birds is judged to be Moderate Adverse during demolition, clearance and construction and Minor Adverse‐Neutral in the long term.

5.1.3. Recommendations

It is recommended that hedge cutting and tree works as well as demolition works commences during the period between 15th September and end of February to avoid the main bird nesting season and to avoid potential disturbance to birds nesting within the area. May is a peak time for nesting birds and the buildings, fields, grassland, scattered trees and hedging bordering the site offers suitable breeding bird habitat. As new nests can be built at any time, it is recommended that any arboriculture works be carried out under ecological supervision, or following a visual inspection.

If this is not possible, then a nesting bird survey should be carried out by an experienced ecologist 24‐48 hours prior to works. If during the survey an active nest is identified it must be left in‐situ until the young have fledged and the nest has been abandoned. Bird nesting boxes should be erected to provide additional nesting opportunities.

The hedgerows and trees should be retained and protected during the course of the development with suitable tree and root protection measures (in line with the British Standard for trees in relation to construction BS 5837:2012). A 5m stand‐off zone between the new barn and the hedgerows should also be implemented.

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5.2. Bat Species

5.2.1. Overview of legislation relating to bat species

British bat species are protected under the Wildlife and Countryside Act (1981) and Conservation of Habitats and Species Regulations (2017). This makes it an offence to kill or injure bats or damage or destroy a place of shelter or protection, amongst other actions (see Appendix 2 for more details).

5.2.2. Summary of findings and likely impacts in absence of mitigation

The hedgerow and woodland trees within the site were assessed as having Moderate/High bat roosting potential. The hedgerows and woodland are likely to be used by a variety of foraging and commuting bat species in the local area.

5.2.3. Recommendations

The hedgerows and trees should be retained and protected during the course of the development with suitable tree and root protection measures. There is scope within the proposed development to enhance the site for bats. This can be achieved through the inclusion of bat boxes within the area of woodland and mature hedgerow trees.

In order for the resources discussed to be viable bat sensitive lighting should be employed to avoid light pollution. In general, it is recommended that site lighting is kept to a minimum. Security lighting should be operated on short timers. The following mitigation strategies have been taken from Bat Conservation Trust Landscape and Urban Design for Bats and Biodiversity (Gunnell et al., 2012) and other referenced sources:

 Minimise light spill by eliminating any bare bulbs and upward pointing light fixtures. The spread of light should be kept near to or below the horizontal plane, by using as steep a downward angle as possible and/or shield hood. Flat, cut‐off lanterns are best;  Use light sources that emit minimal ultra‐violet light (van Langevelde and Feta, 2001) and avoid the white and blue wavelengths of the light spectrum, so as to avoid attracting insects and thus potentially reducing numbers in adjacent areas;  Limiting the height of lighting columns to eight metres and increase the spacing of lighting columns (Fure, 2006) can reduce the spill of light into unwanted areas;  Avoid using reflective surfaces under lights or light reflecting off windows (e.g. on to trees);  Only the minimum amount of light needed for safety and access should be used and or turned off when the site is not in use;  Artificial lighting proposals should not directly illuminate boundary habitats, which may be of value to foraging or commuting bats and birds (e.g. green corridors);  Lighting that is required for security reasons should use a lamp of no greater than 2000 lumes (150 Watts) and be PIR sensor activated, to ensure that the lights are not on only when required (Jones, 2000; Collins, 2016);

5.2.4. Assessment of impact and licensing

The value of the Site to bats is assessed as Moderate at the Parish/ Neighbourhood scale due to the probability of use and connectivity to the wider environment. The impact of the development upon bats is considered to be Minor Adverse without mitigation due to potential impacts form lighting. This could be reduced to Minor Adverse‐Neutral with the recommendations being implemented. Including the retention and protection of the trees and hedges. The proposed works have a low

29 likelihood of impacting on roosting bats so the requirement for a European Protected Species Mitigation License EPSM is very unlikely.

5.3. Great Crested Newt

5.3.1. Overview of legislation relating to Great Crested Newt

The Great crested newt is an internationally important species. It is listed in Annexes II and IV of the EC Habitats Directive and Appendix II of the Bern Convention. It is protected under Schedule 2 of the Conservation of Habitats and Species Regulations 2017, and Schedule 5 of the Wildlife and Countryside Act 1981. Under Section 9(4) of the Wildlife and Countryside Act, it is an offence to intentionally kill, injure, damage, destroy, take or obstruct access to any structure or place which these species use for shelter or protection. The Countryside and Rights of Way Act 2000 introduces ‘reckless' to offences, in addition to those that are carried out with intent.

5.3.2. Summary of findings and likely impacts in absence of mitigation

The rough boundary grassland, hedge, ditch, woodland and other habitats bordering the site offer some suitable foraging and cover opportunities to great crested newts. Great crested newts may typically disperse up to 500m from their breeding ponds, although research undertaken by Natural England (Cresswell & Whitworth 2004) suggests that newts will rarely move further than 200‐250m from breeding ponds, with much reduced distances recorded where adjacent habitats are of good quality.

There are no records of great crested newt within 2km of the site and pond P1 has average potential only for supporting great crested newts. Pond P2 has poor potential.

There is a Low risk of Great Crested Newt presence in the terrestrial habitats on site. The site is considered to be of value at a site only scale for great crested newt. The impact on terrestrial and aquatic habitats are assessed as being neutral as there will be no loss of valuable habitat to amphibian species or loss of any aquatic habitat.

5.3.3. Recommendations

It is recommended that any stored materials such as timber, bricks, and sheet materials should be raised off the ground to prevent them from being used as refugia. Any rubble, brash or wood piles should be cleared by hand before moving. Demolishes building materials should be removed from site. Phased cutting or any rough grassland areas within the proposed construction area.

5.4 Reptiles

5.4.1 Overview of legislation relating to Reptiles

Reptiles are protected against intentional killing and injuring, sale and transport for sale under the Wildlife and Countryside Act 1981 (as amended). Natural England states that activities such as site investigations, site clearance and movements of machinery may breach this legislation by causing death or injury to reptiles (English Nature, 2004).

5.4.2 Summary of findings and likely impacts in absence of mitigation

The field boundary hedgerows and woodland with rough grassland and tall ruderals provides suitable habitat for reptile species and will be retained and protected by the existing post and wire

30 mesh fencing. These habitats are of only limited value to reptiles and so there is a low potential for disturbance or injury to reptiles during any clearance.

Given the limited suboptimal habitats present on site, their poor connectivity to favourable reptile habitats, plus the maintained short sward height of the grassland pasture, it is considered unlikely that reptiles are present within the proposed working areas, and therefore no further survey is required.

The value of the boundary habitats to reptiles is assessed as Low at the Parish/Neighbourhood scale. The impact of the development upon reptiles is considered to be Minor Adverse‐Neutral.

5.4.3 Recommendations

Any rough grassland and tall ruderal vegetation across the working areas will be strimmed to no less than 150mm during the first cut to make the habitat less suitable for reptiles and amphibians and to disperse them from the working areas. After 48 hours the grass may be cut to ground level or cleared to bare soil starting from the centre of the grass area working towards the edges.

5.5 Hedgehog and Brown Hare

There is a Moderate risk of Hedgehog presence on site. The site is considered to be of parish value for terrestrial mammals with the unmitigated impact assessed as minor adverse, due to potential disturbance during demolition, clearance and construction. Impacts would be reduced to neutral with the implementation of mitigation measures as detailed in Section 5.0 and 6.0.

5.6 Designated Sites and Priority Habitats

There are no statutory sites within a 2km radius of the farm and so no direct or indirect impacts are considered likely. There is a single Local Wildlife Site, Leggs Wood, Frittenden, 775m east of site and is designated for its woodland habitat. This habitat type is unlikely to be impacted. The impact on sites of national and local importance was assessed as Neutral.

The site and wider fields are bordered by intact hedgerows which are a UK Priority Habitat, the proposed works do not require any hedge removal or disturbance to the boundary habitats.

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Ecological Feature Scale of Value Unmitigated Confidence Residual or Impact Level Long‐Term Impact Sites of International International Neutral Certain ‐ Importance Sites of National National Neutral Certain ‐ Importance Sites of Local District Neutral Likely ‐ Importance Habitats Parish Minor Adverse Likely Minor adverse‐ Neutral Green Infrastructure Parish Neutral Likely Neutral

Reptiles Parish Minor Adverse Likely Neutral Great Crested Newts Site Only Neutral Likely ‐

Rare/Scarce Plant Low Neutral Certain ‐ Species Veteran Trees Negligible Negligible Certain ‐

Invertebrates Parish/District Minor Adverse Likely Neutral

Amphibians Negligible Negligible Certain ‐ (excluding GCN)

Breeding Birds Parish Moderate Likely Minor Adverse Adverse‐ Wintering Birds Negligible Negligible Certain ‐

Aquatic Mammals Negligible Negligible Certain ‐

Terrestrial Mammals Parish Minor Adverse Likely Minor Adverse‐ Neutral Roosting Bats High Minor Adverse Likely Neutral

Foraging/Commuting Parish Minor Adverse Certain Minor adverse‐ Bats Neutral Table 8.0 – Summary of ecological features, unmitigated impact and residual impact with mitigation

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6. Avoidance, Mitigation, Compensation and Enhancement

Ground Clearance Works‐

• As per the recommendations above building demolition, vegetation clearance and excavation works across the site should ideally be performed outside of the active bird breeding season 1st March‐ 15th September inclusive. If this is not possible a bird surveyor should visit the site to check for evidence of nesting birds prior to any clearance works.

•Rough grassland and tall ruderal vegetation across or bordering the construction areas will be strimmed to make the habitat less suitable for reptiles and amphibians. In addition, any artificial and natural refugia within the working areas (brash, bricks, wood, sheet materials etc.) would be hand‐ searched for the presence of reptiles and amphibians prior to commencement of works.

• Care should be taken with regards to vegetation clearance and earthworks due to potential disturbance to nesting birds, herpetofauna and small mammals.

Construction and Working Practices‐

• The timing of construction works will be sensitive to nesting birds. If possible, it is proposed that operations within the working area would preferably be started outside of the bird breeding season to minimise the risk of disturbance to breeding birds that have already commenced nesting. Once works commence birds are unlikely to start nesting within the working area. However, in order to avoid accidental harm to nesting birds, a 15m buffer zone will be marked around any nest using high visibility fencing to ensure that the nest is not disturbed, damaged or destroyed whilst in use.

•If any ground nesting birds are found to be nesting within or close to the working areas during the pre‐inspection survey or clearance, a 25m standoff from the nest will be marked out and observed, within which no operational activity would be permitted until the breeding attempt had concluded.

• Bird and bat boxes will be erected on the boundary and woodland trees to provide additional nesting and roosting opportunities and to compensate for potential disturbance to nesting birds. There is sufficient off‐site habitat for ground nesting birds to utilise.

• In the event that protected species are discovered within the site, works would need to stop until the situation has been further assessed, and if necessary, a mitigation strategy developed and an application made for a site license.

• The site manager and other relevant staff will be briefed (by suitably qualified ecologist) on the possible presence of protected species in the area (Toolbox talk). Staff will be provided with information relating to the legislation which protects species and habitats and briefed on the procedures to prevent disturbance or destruction of individuals or their habitats. Staff will also be briefed on the emergency procedures to be implemented should protected species be found during clearance and construction works.

• Habitats removed, wherever possible will be replaced at the earliest opportunity with native or wildlife attracting species.

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• Trenches, pits or holes dug on site that are to be left over night will be covered over or have a ramp placed in them so that any wildlife that falls in can climb out safely;

• The proposed location of the site compounds and any material storage areas will not extend into more important habitats, notably the mature trees, hedges and woodland edges.

• Care should also be taken if lighting any bonfires as these may be potential hedgehog refugia/hibernation sites. Any brash and log piles on site will be searched by hand before removal/burning (see above) and if they are discovered they should be translocated to a suitable location.

Lighting‐

•Any new external lights will be set on a motion detector and positioned in such a way that they do not shine on the tree canopies, hedges or woodland. Low intensity lighting should be used where possible in place of high intensity discharge or sodium lamps, this will minimize disturbance to foraging and commuting bats.

In accordance with the Bat Conservation Trust’s publication Bats and lighting in the UK (BCT, 2008) light pollution by artificial lighting will be kept to a minimum and light spillage avoided. The following specific mitigation will be put in place to minimize disturbance to bats caused by the lighting of the site:

 Lights will be pointed away from likely bat flyways and foraging areas (hedges, woodland, trees);  Screen planting will be wide and tall to maintain natural light conditions away from the site;  Low or high pressure sodium lamps will be used instead of mercury or metal halide lamps;  The light will be directed only to where it is needed, for example, by the use of hoods;

Tree Works‐

• All middle aged and mature trees where possible to be retained and protected in line with British Standard: 5837:2012 “Trees in Relation to Design, Demolition and Construction”

• If tree removal is scheduled between the months of 1st March and 15th September then a breeding/nesting bird survey should be first undertaken by the SQE.

• A search of any tree holes, cavities, flaking bark and dense creeping ivy on any trees to be removed will be undertaken to confirm the absence of any roosting bats, this is particularly important during the summer months when such features are used more frequently.

• In the event that any active nests are identified, no operational activity will be permitted within the stand‐off zones until the breeding attempt had concluded.

Pollution Control‐

Standard pollution prevention measures will be put in place including measures such as preventing dust by damping down bare ground and ensuring fuel is stored in bunded tanks. The Environment Agency PPG1 and PPG6 guidance on General Guide to the Prevention of Pollution and Working at

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Construction and Demolition Sites will be adhered to throughout the construction of the Proposed Development.

Liquid‐

Many of the materials used in construction operations, such as oil, chemicals, cement, lime, cleaning materials and paint have the potential to cause serious pollution. All fuel, oil and chemical storage must be sited on an impervious base within a bund and secured. The base and bund walls must be impermeable to the material stored and of an adequate capacity.

Leaking or empty oil drums must be removed from the site immediately and disposed of via a licensed waste disposal contractor. The contents of any tank are to be clearly marked on the tank, and a notice displayed requiring that valves and trigger guns be locked when not in use. Concrete is highly alkaline and corrosive and can have a serious impact on groundwater, soil and watercourses. It is essential to take particular care with all works involving concrete and cement. Suitable provision is to be made for the washing out of concrete mixing plant or ready mix concrete lorries so that washings do not flow into any drains or watercourse or seep underground.

Air, Noise and Vibration‐

Contractors will be expected to take measures to minimize the presence of air borne dust during clearance and construction. If possible any activities producing in excess of 70db should be avoided during the bird nesting season.

There is potential for the two new larger rearing sheds to give rise to an increase in ammonia or nitrogen emissions and there are areas of ancient woodland and ancient re‐planted woodland close to the site.

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7. Biodiversity Enhancement

The Natural Environment and Rural Communities Act 2006 (NERC) came into force on 1st October 2006. Under section 40 of the Act all public bodies have a duty to conserve biodiversity:

 “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity.”

Section 40(3) of the Act explains that:

 “Conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat”.

The duty applies to all local authorities and extends beyond just conserving what is already there to carrying out, supporting and requiring actions that may also restore or enhance biodiversity. This section sets out some measures which the developer should incorporate within the proposals to help maintain and improve the ecological value of the site generally during and after the proposed development.

Habitat Supplementation‐

Birds – To increase nesting opportunities generally, nest boxes should be installed. Installation of the nest boxes will be supervised by ‘Eco‐ Check Ltd’ or an experienced ecologist to ensure the correct positioning for each species.

The types of nest boxes will cover a range of species and could include;

 Schwegler 2M bird boxes (32mm)  Schwegler 2GR nest boxes (27mm)  Schwegler 1ZA wren roundhouse boxes  Schwegler 1N deep nest boxes for robins  Schwegler 1B general nest boxes  Schwegler 2HW nest box  Schwegler 2H Open Fronted Box

Bats‐ The combination of trees, hedges and grassland are valuable to foraging and commuting bats. Mature hedgerow and woodland trees contained some potential roosting features.

Bat Boxes‐ As a biodiversity enhancement and to compensate for the potential disturbance, areas for bats to roost in should be created and could include;

 ‘Schwegler 1FD’ bat boxes favoured by Pipistrelle and Long‐Eared bats;  ‘Schwegler 1FF’ bat boxes favoured by Pipistrelle and Noctule  ‘Schwegler 3FN’ bat boxes, favoured by Noctule and Bechstein’s bats;  ‘Schwegler 2F’ bat boxes, attractive to the smaller British bats.  ‘Schwegler 1WQ’ summer and winter roost box

These boxes are to be installed on the boundary, scattered and woodland trees within the site, ideally one on each elevation to provide the best variation in temperature, shelter and flight lines. If

36 only one elevation is used this should be south‐east facing as this provides the most shelter and warmth.

Plant native broad‐leaved trees. Suggested species include; oak (Quercus robur), field maple (Acer campestre) and sycamore (Acer pseudoplatanus).

Creation of artificial refugia and hibernacula for reptiles and amphibians along the fenced boundaries or behind existing fencing in the form of log piles, grass cuttings, brash piles etc. See Appendix 4 for guidance. 8. Ecological Conditions and Recommendations for Further Surveys

The overall impact assessment does not take into consideration those species for which further information is required. To fully assess the site for, and the impact of the proposed development upon, protected species, detailed survey is recommended for the following species:

 Preliminary Tree Roost Assessment (PRA)‐ If any mature trees with bat roost features are likely to be impacted upon, i.e where trees will be removed, root protection zones cannot be adhered to, or management is recommended by the appointed arborist , a Preliminary Tree Roost Assessment of the trees must be undertaken.

As the boundary trees and hedging are the principle valuable habitats it is recommended that these are retained as far as possible through the site development. This includes the areas of semi‐natural and ancient re‐planted woodland.

An Ecological Constraints and Opportunities Plan (ECOP) would highlight the boundary habitats as a high (and ultimately irreplaceable) constraint on development. Currently no additional survey works are recommended although continued involvement of an ecologist is recommended for the production of the ECOP.

The suggested condition below is based on BS42020:2013 and in terms of biodiversity net gain, the enhancements proposed will contribute to this aim. Recommended condition:

PRIOR TO COMMENCEMENT: COMPLIANCE WITH ECOLOGICAL REPORT RECOMMENDATIONS

“All ecological mitigation and enhancement measures and/or works shall be carried out in accordance with the details contained within the report (Eco‐Check, December 2018), as submitted with the planning application and agreed with the local planning authority prior to determination.”

Reason: To conserve and enhance Protected and Priority species and allow the LPA to discharge its duties under the UK Habitats Regulations, the Wildlife & Countryside Act 1981 as amended and s40 of the NERC Act 2006 and s17 Crime & Disorder Act 1998.

It is advised that if a period of more than 18 months passes between the date of this survey and the commencement of clearance and construction works then a further site survey should be made in addition to the pre‐works checks outlined above. A check of the buildings to be demolished trees will

37 be made prior to works and any tree works or hedge cutting undertaken under the advice of the ecological clerk of works (ECoW).

SPECIES LICENSING

A European Protected Species Mitigation (EPSM) licence would be needed to implement any impacts upon bats such as damaging a place used for shelter or disturbing the species in its place of shelter.

A European Protected Species Mitigation (EPSM) licence would be needed to implement any impacts upon reptiles or great crested newts such as damaging a place used for shelter or disturbing the species in its place of shelter.

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9. References

British Standards Institution (2013). BS42020 – Biodiversity – Code of practice for planning and development.

CIEEM (2017). Guidelines for Preliminary Ecological Appraisal. Chartered Institute of Ecology and Environmental Management, Winchester.

CIEEM (2015) Guidelines on Ecological Report Writing. Chartered Institute of Ecology and Environmental Management, Winchester.

CIEEM (2016) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd Edition. Chartered Institute of Ecology and Environmental Management, Winchester.

Froglife (1999) Reptile Survey: an introduction to planning , conducting and interpreting surveys for snake and lizard conservbation. Froglife Advice Sheet 10, Froglife, Halesworth

Gent T & Gibson S (2003)‐ Herpetofauna Workers Manual. JNCC, Peterborough.

Hill, D, FashaM, Tucker G, Shewry M & Shaw P (2005) Handbook of Biodiversity Methods: Survey Evaluation and Monitoring, Cambridge Univerity Press, Cambridge

Collins, J (2016). Bat Surveys for Professional Ecologists: Good Practice Guidelines, 3rd edition, Bat Conservation Trust.

DEFRA (2005) Fifth Quinquennial Review of Schedules 5 and 8 of The Wildlife and Countryside Act 1981. Department for Environmental, Food and Rural Affairs, London.

JNCC, (1993). Handbook for Phase 1 Habitat Survey: A technique for environmental audit (2010 reprint). Joint Nature Conservation Committee, Peterborough.

JNCC, (2006). Handbook for using the National Vegetation Classification.

Impact of Development on County Wildlife Sites and other areas of semi‐natural habitat‐ Norfolk Wildlife Trust (NWT), John Hiskett, August 2007

J.S.Rodwell, 2006 Joint Nature Conservation Committee.

Joint Nature Conservation Committee, 2003. Herpetofauna Worker’s Manual. JNCC Publications, Peterborough.

Froglife (2001), Great Crested Newt Conservation Handbook, Froglife, Halesworth, Suffolk

Mitchell‐Jones, & McLeish, A.P. Ed.(2004),3rd Edition Bat Workers’ Manual

Biodiversity 2020: A strategy for England's wildlife and ecosystem services (2011).

Natural England, MAGIC MAP Search, November 2018, www.magic.gov.uk

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COPYRIGHT

The copyright of this document remains with Eco-Check Ltd. The contents of this document therefore must not be disseminated, copied or reproduced in whole or in part for any purpose without the written consent of Eco-Check Ltd.

PROTECTED SPECIES This report contains sensitive information relating to protected species. The information contained herein must not be disseminated without the prior written consent of Eco-Check Ltd.

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Appendix 1

Site Location Map – Streetmap 2011

Aerial View of Tolehurst Farm and Surrounding Landscape‐ Google Earth 2008

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Appendix 2

Magic Map Check‐ December 2018

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Location of Woodland‐ KML Map

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APPENDIX 3

Picture 1. Two buildings to be demolishes Picture 2. Plantation tree belt along south boundary with existing buildings

Picture 3. Improved grassland bordering sheds to Picture 4. Dry ditch (D1) along south boundary be demolished with woodland

Picture 5. View across grassland field from south Picture 6. North boundary hedgerow and trees to north H1

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Picture 7. Fenced free range field and plantation Picture 8. Mature hedgerow and trees along trees adjoining south‐west corner north boundary with access road

Picture 9. View across grassland field from west Picture 10. Ancient and replanted broadleaved to east woodland along south boundary

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APPENDIX 4

Species Notes and Habitat Map Common Name Scientific Name Alder Alnus glutinosa Annual meadow grass Poa annua Ash Fraxinus excelsior Barren brome Anisantha sterilis Beech Fagus sylvatica Bindweed Calystegia sepium Birch Betula sp. Bittersweet Solanum dulcamara Blackthorn Prunus spinosus Bluebell Hyacinthoides non‐scripta Bramble Rubus fruticosus Bread wheat Tritium aestivum Broadleaf dock Rumex obtusifolius Celandine Ranunculus ficaria Chestnut Aesculus hippocastanum Chickweed Stellaria media Cleavers Galium aparine Cocks foot Dactylis glomerata Common bent Agrostis capillaris Common centaury Centaurium erythraea Common mallow Malva neglecta Common mouse ear Cerastium fontanum Common nettle Urtica dioica Common ragwort Senecio jacobaea Cow parsley Anthriscus sylvestris Creeping bent Agrostis stolonifera Creeping buttercup Ranunculus repens Creeping cinquefoil Potentilla reptans Creeping soft‐grass Holcus mollis Creeping thistle Cirsium arvense Cupressus (Cypress) Cupressus.sp Curled dock Rumex crispus Daisy Bellis perennis Dandelion Taraxacum officinale agg. Dog Rose Rosa canina Dove’s foot‐cranesbill Geranium molle Elder Sambucus nigra False oat‐grass Arrhenatherum elatius Field maple Acer campestre Garlic mustard Alliaria petiolata Ground Ivy Glechoma hederacea Groundsel Senecio vulgaris Hawthorn Crataegus monogyma Hazel Corylus avellana

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Hogweed Heracleum sphondylium Holly Ilex aquifolium Horse chestnut Aesculus hippocastanum Ivy Hedera helix Lombardy Poplar Populus nigra Mugwort Artemisia vulgaris Nettle Urtica dioica Oak Quercus robur Perennial ryegrass Lolium perenne Poppy Papaver rhoeas Prickly lettuce Lactuca serriola Prickly sow thistle Sonchus Asper Purple loosestrife Lythrum salicaria Ribwort plantain Plantago lanceolata Rough hawkbit Leontodon hispidus Rough meadow grass Poa trivialis Scentless mayweed Tripleurospermum inodorum Scots pine Pinus sylvestris Sheeps fescue Festuca ovina Silver birch Betula pendula Silverweed Argentina anserina Smooth sow‐thistle Sonchus asper Soft rush Juncus effusus Sorrel Rumex acetosa Spear thistle Cirsium vulgare Sycamore Acer pseudoplatanus Sycamore Acer pseudoplatanus Tormentil Potentilla erecta Tufted vetch Vicia cracca Water mint Mentha aquatic Water plantain Alisma lanceolata Water purslane Lythrum portula White campion Silene latifolia White dead nettle Lamium album White Dutch clover Trifolium repens Willow Salix.sp Willow herb Epilobium hirsutum Woundwort Stachys sylvatica Yarrow Achillea millefolium Yorkshire fog Holcus lanatus

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Appendix 4

Proposed Site Layout

Appendix 5

Flood Risk Assessment

FLOOD RISK ASSESSMENT

PROPOSED UPGRADE OF AN EXISTING POULTRY REARING UNIT

AT TOLEHURST FARM, KNOXBRIDGE, FRITTENDEN, KENT

INTRODUCTION

A planning application is to be submitted on behalf of Friday Ltd for the upgrade of an existing free range poultry unit at Tolehurst Farm, Knoxbridge, Frittenden, Kent

The application is for the removal of 2 existing rearing sheds to be replaced by 2 new rearing sheds.

SEQUENTIAL TEST

The Sequential Test is met as the development is located in Flood Zone 1.

Tolehurst Farm

The farm are adapting to market trends and keeping up to date and ahead of modern poultry keeping practices. Hence replacement free range houses have been constructed and 2 new rearing houses for new stock are now proposed.

These houses all have gutters and downpipes leading to stone drains containing a perforated plastic drain running to an attenuation pond and a much smaller regulating drainage pipe in to a ditch.

The manure and house washing down are all enclosed and being under cover the volumes are contained and not exaggerated by rainfall occurring at the same time as cleaning out and washing down.

SOIL TYPE

There are two different soil types in this immediate area. The first is Shabbington series which is developed on river terrace material which is commonly adjacent to, or just above, river floodplains. This soil type occurs immediately north of the farmstead at this site. The top 25 cm is sandy loam which is usually slightly stony. Below 25 cm the soil is slightly stony sandy clay loam and this soil texture continues normally to at least 120 cm depth. However, due to its position low on the floodplain the soil is grey and mottled below only 25 cm, becoming even greyer with ochreous mottles below around 55 cm. Winter flooding is a problem in some locations. Clay is normally found below 4 to 8 metres depth but with a layer of gravel in between. Although this soil type is easily cultivated, the presence of a high water table limits cropping on most fields. Conversely, where highly efficient field drainage has been installed this land has occasionally been used to grow fruit trees and hops.

The other local soil type to the south of the farmstead on slightly higher ground is mapped as the Curtisden soil series. The much more silty parent material is derived from local Ashdown Beds. The upper 45 cm is slightly stony silt loam or silty clay loam which is slightly mottled below 20 cm. There is usually a band of heavier silty clay loam around 30 cm thick in the subsoil which then becomes lighter at silt loam to 100 cm. Below 75 cm the soil is light grey in colour and mottled. Although this soil type is on somewhat higher ground than the Shabbington soil type cropping range remains limited by wetness because of the band of silty clay loam within the subsoil. Cereals and grassland are the most common crops with autumn drilling of cereals dominant. Because the topsoil contains a large amount of silt and fine sand it is susceptible to capping and formation of plough pans, especially where topsoil organic matter content is low. A lot of woodland has traditionally been established on this soil type in this part of Kent.

The site is described by www.landis.org.uk/soilscapes as Soilscape 22: Loamy soils with naturally high water table. Slightly acid loamy and clayey soils with impeded drainage.

Approx. Position of Tolehurst Farm

The site goes on to describe the “Soils are mostly drained. Shallow groundwater and marginal ditches to most fields”

Hence the land is only suitable, as now, for a surface ditch drainage system.

CLEAN WATER

Site Drainage

Greenfield site drainage figures obtained from www.uksuds.com for these new buildings give runoff rates for the proposed site as follows:-

Estimated Site Discharge IH124 results Q bar 3.53 1 in 1 year 3.25 l/sec. 1 in 30 years 5.5 l/sec. 1 in 100 years 12.21 l/sec.

The subsoil is a clayey soil with impeded drainage relying upon the adjacent ditches backed up by the extended balancing or attenuation pond/basin. Considering a site figure (see below) of 2 litres per second per ha over the extra 7,919 m2 of hard area this gives an added site drainage figure of 1.6 litres/second i.e. less than all the figures above. (On previous, usually smaller jobs, I have been encouraged to limit the flow to 1 l/sec/ha. but this is difficult on farms without the risk of frequent pipe blockages. I have in general agreed with the EA on a design flow of 2 litres/ha/sec. This gives a slightly larger and thereby more manageable discharge pipe diameter and is also suggested in the SUDS information).

Rainfall

Rainfall on a “hard” roof area flashes off the surface in to a ditch at an alarming rate compared to a land drainage system typically considered to deliver 2.0 litres/sec/ha. The aim is to buffer rainfall and only allow it to drain in to a ditch or stream at the same rate as an agricultural drainage system permits. The drainage design needs to allow for rainfall on the new house roofs and immediate service yard areas to match 1 in 100 year figures plus in this case 30% (Ref. Kent CC SUDS summary) for global warming over the lifespan of the houses believed to be less than 50 years. Having been a poultry farm for many years the other houses and access roads/pads are already in place. The likely volumes are:-

Storm * Depth of Total Volume **Volume Restricted Storage Duration Rainfall mm of Rainfall allowing an discharge Volume m3 extra 30% 2.0 l/sec required on area of for global m3 m3 7,919 m2 warming m3 5 mins 14.1 112 145 1 144 15 mins 25.5 202 263 2 261 30 mins 33.5 265 345 4 341 1 hour 41.9 332 431 7 424 3 hours 55.5 439 571 22 549 4 hours 59.0 467 607 29 578 6 hours 64.4 510 663 43 620 12 hours 74.5 590 767 86 681 24 hours 85.5 677 880 173 707 36 hours 92.6 733 953 259 694 48 hours 97.8 772 1,003 347 657 72 hours 105.5 835 1,086 518 568 96 hours 113.4 898 1,167 691 476 8 days 143.7 1,137 1,479 1,555 Nil 25 days 222.0 1,758 2,285 4,859 Nil *Met. Office Data. ** Kent CC SUDS.

Some drainage to the ditch at the low rate is occurring all of the time during times of rainfall. The most challenging period for storage is between 12-36 hours requiring about 707 m3 of buffer capacity in the attenuation pond sited at the eastern end. After just over 4 days the extra buffer storage capacity should be empty even after this intense rainfall.

Providing this capacity ideally needs to be between the levels of the basin inlet pipes and the outlet pipe to the ditch. However this leaves a maximum depth of about 1 m and it’s likely that the farm will need to accept some water backing up the inlet pipes under these exceptional conditions. We must ensure this does not mean it will come out of manholes or drains on the site.

Sizing the Attenuation Basin

This can be any shape to suit the farm but as a long narrow rectangle spanning the building width this could measure:-

Size at surface 60 m x 14.0 =840 m2 1 m depth Side walls 1 in 1.0 slope Base area 58 m x 12m = 696 m2

Capacity 768 m3

This will also allow for rainfall on the attenuation pond itself. Being long and narrow, spanning the width of the buildings, this will allow the large diameter drainage pipes to readily run straight into the attenuation basin. It is not really a pond as for the majority of the time (95% plus) in the normal sense of the meaning. The basin will more resemble a grassed depression. It will be sited at the eastern end of the buildings (see map below).

The 2 litres/sec. flow into the ditch equates to a 75 mm pipe with a fall of 1 in 150. (See chart below). I have adjusted the slope to more accurately match the flow required. The pipe will be in use all of the time for the site drainage with staff working from the service area and so any blockage should be readily spotted.

The www.uksuds.com site for storage volume suggests a buffer storage figure of 624 m3 using similar but not identical assumptions. (See summary report within the appendices).

Eaves Filler Drains

There will be 4 drains altogether under the eaves. Pipes laid in a stone trench with a 1 in 200 fall will deliver up to:-

65 mm 1.3 litres/sec (4.7 cu. metres/hour) 75 mm 1.7 litres/sec (6.3 cu. metres/hour) 85 mm 2.25 litres/sec. (8.10 cu. metres/hour) 100 mm 3.2 litres/sec. (11.5 cu. metres/hour) 115 mm 4.5 litres/sec (16.2 cu. metres/hour) 135 mm 6.8 litres/sec (24.4 cu. metres/hour) 155 mm 9.5 litres/sec (34.2 cu. metres/hour) 180 mm 16 litres/sec (57.6 cu. metres/hour) 210 mm 22 litres/sec. (79.2 cu. metres/hour) 250 mm 31 litres/sec. (111.6 cu. metres/hour) 300 m 50 litres/sec. ( 180 cu. metres/hour) 350 mm 76 litres/sec ( 274 cu. metres/hour)

Ref. Polypipe flow chart Restricted and open inlet –corrugated plastic pipes

The design need is to cope with the 30 minute storm of rain 1 in 100 years.

The houses measure 120 m long x 26.66 m = 3,199 m2. Each drain will therefore need to serve ½ the roof area 1,600 m2 plus ¼ of the service yards at each end 2 x 630/4 = 315 m2 giving a total of 1,915 m2. The water flows and therefore the pipe sizes necessary are as follows:-

Storm Intensity Volume Volume Discharge Volume Discharge Volume Duration mm/hr of runoff allowing an through surplus if through surplus if (Depth of m3 extra 30% 250 mm any 300 mm any Water mm) on roof for global pipe over m3 pipe over m3 area warming this period this period 1,915 m2 m3 250 mm m3 300 mm 15 mins 102 48.8 63.5 27.9 35.6 45 18.5 (25.5mm) 30 mins 67 64.1 83.4 55.8 27.6 90 Nil (33.5mm) 1 hour 41.9 80.3 104.3 111.6 Nil 180 Nil (41.9mm)

A 300 mm pipe is required for each drain as shown above, a 250 mm pipe is well short of capacity. However the is ample scope to take in water from the amenity and control/link buildings. In addition there is some void capacity within the stone drains. These will measure 120 m long x 400 mm wide x 750 mm deep. With an estimated 30% void capacity this adds a further 11 cu. metres of temporary storage capacity per drain.

The pipe could be graduated i.e. the first 1/3rd 210 mm, the second 250 mm and the final 1/3rd 300 mm. These will then run directly in to the attenuation basin/pond and finally the water will the water will reach the ditch.

Hydrobrake

A purpose built and sized hydrobrake would further minimise the chance of a blockage (e.g. Ref Hydro International www.hydrointernational.biz.) The intake pipes would need to be sized and specified at the design and manufacturing stage together with the required outflow of 2.0 litres/sec. Basically a hydrobrake consists of an inlet, an outlet and a baffled “volute” through which water is introduced tangentially. The outlet opening is 3-6 times greater than for conventional flow thus reducing the chance of blockages. This is not considered necessary for a scheme of this size with staff working on the site each day.

DIRTY WATER

Cleaning Out and Washing Down Inside the Houses

Approx. 50% of the manure is removed weekly using conveyors in to sealed trailers standing just outside the shed. There are no pollution issues with these. The other 50% is removed at the end of each batch by Bobcats via the doors at the western end into trailers standing on the service yard immediately outside the houses. The yard is therefore partly fouled for 2-3 days every 16 weeks.

Much of the final cleaning down between batches is a “dry operation” using compressed air. The final clean down uses pressure washers with the water draining to specialist dirty water tanks. These will also take rainwater from the service yard at the western end when it is dirty and the vehicles are being loaded. With these measures in place all the foul water can be disposed of safely.

The dirty water tank(s) should each hold 20 m3, being the maximum daily volume of pressure washing water when washing down the houses. The water will run into a series of drains within the houses and a sealed collection pipe running between the houses to 2 tanks, one at each end. With a level site this gives a greater fall on the pipework and so less chance of blockages occurring with water inevitably containing some solids. The concrete service yard will be slightly dished to 2 drains and these will house diverter valves to direct the water when dirty into the tank and when clean into the clean water system. There are likely to be two pumps, each operating 2 pressure washing lances with individual lances delivering about 15 litres per minute. They may run for 70% of the full working day and so the total volume of water used in an 8 hour day will be approx. 20 cu. metres. The tanks therefore each need to hold a minimum of 20 m3. In practice because of the warm temperature of the concrete floor inside the houses some of this water evaporates. Considering 25 mm of heavy rainfall during the working day on the yard measuring 630 m2 this would add a further 15.75 m3. Being completely in charge of the operation i.e. using their own staff the farm can if necessary empty the tanks during the day should we get heavy rainfall without the capital cost of “oversizing” the tanks. The tank will be emptied at the end of each working day in case heavy rainfall occurs overnight.

MAINTENANCE

The drainage system is solely on land owned by the farm; hence there will be no delays or permissions needed to attend to any issues.

There are no pumps to go wrong or fail. The dirty service yard drains and water separation valves are only used and reset at the end of the cleaning out period i.e. every 16 weeks. For 15 weeks or so over a batch the western service yard is clean and the yard rainwater runs in to the clean water system. This is standard practice on these types of poultry unit. The access yard at the eastern end will be clean the whole of the time.

The ventilation system has air inlets under the eaves and high speed exhaust fans in the ridge which also carry away any dust from within the building. In practice no dust settles on the roofs necessitating washing them down and the potential blockage of the stone eaves drains. There is really very little to go wrong.

The inlets within the attenuation basin will be checked by the farm manager to ensure grass has not grown over the opening when each batch of poultry is due to leave the farm i.e. 3-4 times a year. With the basin/pond in a prominent position any blockages, no matter how unlikely, would be quickly spotted. A small block of concrete around each pipe, say 1 m across, would help to stop grass growing over the openings and also prevent any erosion. The small diameter outlet pipe (75 mm) is far more likely to block. This needs to be surrounded by 500 mm of concrete to minimise the ingress of grass and be subject to regular checking but working on a daily basis from the service yard any difficulties should be quickly spotted.

Over a course of some years it is possible for grass to encroach into and over the stone drains under each building eaves. These will be inspected annually to see if there is an issue. Small tussocks of grass can be removed by hand but any larger scale ingress will be sprayed off with Glyphosate, a translocated contact herbicide, leaving no residue within the drains to pass finally into the attenuation basin and so the ditch. It is approved for aquatic use. This kills all the plant tissue including the roots.

The whole site between and around the buildings will be strimmed and mown chiefly to maintain the appearance but also to minimise the habitat for vermin.

The need to match the pipe sizes to the 30 minute storm 1 in 100 years plus a global warming figure means that much larger than normal pipes need to be used. The site currently drains to ditches. If the pipes are installed and the attenuation basin/pond installed the system complies with all the Codes of Practice and given good management the chances of any pollution occurring or flooding downstream as a result of the development are minimal.

Appendix 5

Flood Risk Assessment

A Dispersion Modelling Study of the Impact of Odour from the Existing Free Range Egg-Laying Chicken Houses and the Existing and Proposed Pullet Rearing Houses at Tolehurst Farm, near to Cranbrook in Kent

Prepared by Phil Edgington

AS Modelling & Data Ltd.

Email: [email protected]

Telephone: 01952 462500

3rd December 2018

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1. Introduction

AS Modelling & Data Ltd. has been instructed by Brian Barrow of Acorus Rural Property Services Ltd., on behalf of Fridays Ltd., to use computer modelling to assess the impact of odour emissions from the existing free range egg-laying chicken houses and the existing and proposed pullet rearing houses at Tolehurst Farm, near to Cranbrook, in Kent. TN17 3PN.

Odour emission rates from the existing and proposed poultry houses have been assessed and quantified based upon an emissions model that considers the likely internal odour concentrations and ventilation rates of the poultry houses. The odour emission rates so obtained have then been used as inputs to an atmospheric dispersion model which calculates odour exposure levels in the surrounding area.

This report is arranged in the following manner:

• Section 2 provides relevant details of the site and potentially sensitive receptors in the area.

• Section 3 provides some general information on odour, details of the method used to estimate odour emissions from the poultry houses, relevant guidelines and legislation on exposure limits and where relevant, details of likely background levels of odour.

• Section 4 provides some information about ADMS, the dispersion model used for this study and details the modelling parameters and procedures.

• Section 5 contains the results of the modelling.

• Section 6 provides a discussion of the results and conclusions.

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2. Background Details

Tolehurst Farm is located in a rural setting, approximately 2.0 km to the north of the small village of Sissinghurst, near to Cranbrook in Kent. The farm is at an altitude of approximately 35 m in gently rolling terrain with the land rising to Camden Hill to the south, at a height of 109 m. The land in the vicinity of the farm is used for arable farming and pasture and there are some semi-natural woodlands nearby.

The poultry unit at Tolehurst Farm provides accommodation for 14,000 pullets and 96,000 free range egg-laying chickens in four poultry houses. The pullets are reared for approximately 16 weeks in two houses to the north of the farmstead. These houses are ventilated via high speed ridge or roof fans, each with a short chimney and within the houses there are belt collection systems that enable the birds’ droppings to be removed from the houses twice weekly and taken off site. The egg-laying chickens are accommodated in two poultry houses to the south of the farmstead. These houses are also ventilated by high speed ridge or roof fans, each with a short chimney and within the houses there are belt collection systems that enable the birds’ droppings to be removed from the houses twice weekly and taken off site. The egg-laying chickens have daytime access to outside ranging areas via a series of pop holes along the sides of the poultry houses.

It is proposed that the two current pullet rearing houses be taken out of use and two new pullet rearing houses be constructed on a green-field site to the north-west of the farmstead. Three options are being considered for the accommodation of these pullets: a colony rearing system, cage rearing, whereby 322,560 pullets in total are housed within the aviary system; the non-Freedom Foods multi- tier aviary system whereby 275,588 pullets are accommodated in the two houses; and the Freedom Foods multi-tier aviary system whereby 138,864 pullets are accommodated in total. In all three cases, the “cages”, “non-Freedom Foods” and “Freedom Foods” scenarios, the two houses would be ventilated via high speed ridge fans, each with a short chimney and there would be belt systems within the houses that enable the birds’ droppings to be removed regularly and taken off the site. Under the proposals, the free range egg-laying chicken houses would remain. A fourth modelling scenario, for the existing operation at the farm, has also been undertaken.

There are some residences and commercial properties in the area surrounding the poultry houses at Tolehurst Farm. The closest residence to the existing pullet rearing houses is Tolehurst Cottage, which is approximately 50 m to the east and there are further residences at Knox Bridge, the closest being the Thrift Cottages, which are approximately 350 m to the north-east of the existing pullet rearing houses. The Tolehurst Farm residences are approximately 175 m to the north and Rose Cottages are approximately 350 m to the east, of the closest egg-laying chicken house. To the west, the closest residence is Paley Mill, which is approximately 380 m from the nearest egg-laying chicken house.

A map of the surrounding area is provided in Figure 1; the positions of the existing and proposed poultry houses is outlined in blue.

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Figure 1. The area surrounding Tolehurst Farm

© Crown copyright and database rights 2018.

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3. Odour, Emission Rates, Exposure Limits & Background Levels

3.1 Odour concentration, averaging times, percentiles and FIDOR 3 Odour concentration is expressed in terms of European Odour Units per metre cubed of air (ouE/m ). The following definitions and descriptions of how an odour might be perceived by a human with an average sense of smell may be useful, however, it should be noted that within a human population there is considerable variation in acuity of sense of smell.

3 • 1.0 ouE/m is defined as the limit of detection in laboratory conditions.

3 • At 2.0 – 3.0 ouE/m , a particular odour might be detected against background odours in an open environment.

3 • When the concentration reaches around 5.0 ouE/m , a particular odour will usually be recognisable, if known, but would usually be described as faint.

3 • At 10.0 ouE/m , most would describe the intensity of the odour as moderate or strong and if persistent, it is likely that the odour would become intrusive.

The character, or hedonic tone, of an odour is also important; typically, odours are grouped into three categories.

Most offensive: • Processes involving decaying animal or fish remains. • Processes involving septic effluent or sludge. • Biological landfill odours.

Moderately offensive: • Intensive livestock rearing. • Fat frying (food processing). • Sugar beet processing. • Well aerated green waste composting.

Less offensive: • Brewery. • Confectionery. • Coffee roasting. • Bakery.

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Dispersion models usually calculate hourly mean odour concentrations and Environment Agency guidelines and findings from UK Water Industry Research (UKWIR) are also framed in terms of hourly mean odour concentration.

The Environment Agency guidelines and findings from UKWIR use the 98th percentile hourly mean; this is the hourly mean odour concentration that is equalled or exceeded for 2% of the time period considered, which is typically one year. The use of the 98th percentile statistic allows for some consideration of both frequency and intensity of the odours.

At some distance from a source, it would be unusual if odour concentration remained constant for an hour and in reality, due to air turbulence and changes in wind direction, short term fluctuations in concentration are observed. Therefore, although average exposure levels may be below the detection threshold, or a particular guideline, a population may be exposed to short term concentrations which are higher than the hourly average. It should be noted that a fluctuating odour is often more noticeable than a steady background odour at a low concentration. It is implicit that within the model’s hourly averaging time and the Environment Agency guidelines and findings from UKWIR that there would be variation in the odour concentration around this mean, i.e. there would be short periods when odour concentration would be higher than the mean and lower than the mean.

The FIDOR acronym is a useful reminder of the factors that will determine the degree of odour pollution: • Frequency of detection. • Intensity as perceived. • Duration of exposure. • Offensiveness. • Receptor sensitivity.

3.2 Environment Agency guidelines In April 2011, the Environment Agency published H4 Odour Management guidance (H4). In Appendix 3 – Modelling Odour Exposure, benchmark exposure levels are provided. The benchmarks are based on the 98th percentile of hourly mean concentrations of odour modelled over a year at the site/installation boundary. The benchmarks are:

3 • 1.5 ouE/m for most offensive odours. 3 • 3.0 ouE/m for moderately offensive odours. 3 • 6.0 ouE/m for less offensive odours.

Any modelled results that project exposures above these benchmark levels, after taking uncertainty into account, indicates the likelihood of unacceptable odour pollution.

6

3.3 UK Water Industry Research findings The main source of research into odour impacts in the UK has been the wastewater industry. An in- depth study of the correlation between modelled odour impacts and human response was published by UKWIR in 2001. This was based on a review of the correlation between reported odour complaints and modelled odour impacts in relation to nine wastewater treatment works in the UK with on-going odour complaints. The findings of this research and subsequent UKWIR research indicated the following, based on the modelled 98th percentile of hourly mean concentrations of odour:

3 • At below 5.0 ouE/m , complaints are relatively rare at only 3% of the total registered.

3 3 • At between 5.0 ouE/m and 10.0 ouE/m , a significant proportion of total registered complaints occur, 38% of the total.

• The majority of complaints occur in areas of modelled exposures of greater than 10.0 3 ouE/m , 59% of the total.

3.4 Choice of odour benchmarks for this study Odours from poultry houses are usually placed in the moderately offensive category. Therefore, for this study, the Environment Agency’s benchmark for moderately offensive odours, a 98th percentile 3 hourly mean of 3.0 ouE/m over a one year period, is used to assess the impact of odour emissions from the existing and proposed poultry houses at potentially sensitive receptors in the surrounding area.

3.5 Quantification of odour emissions Odour emission rates from poultry houses depend on many factors and may be rather variable. When only minimum ventilation is required, the odour emission rate may be relatively small, but in hot weather, ventilation requirements and odour emission rates are greater. The main source of odour from the existing and proposed poultry houses would be from the chimneys of the ridge or roof mounted fans. Some fugitive emissions from open pop holes along the sides of the free range egg- laying chicken houses would be possible, but because the houses would normally be under negative pressure, these emissions would be minimal. In order to prevent odours building up within the houses and provide negative pressure to prevent fugitive emissions, the modelling assumes that a minimum ventilation rate is maintained. The egg-laying chickens would have access to daytime ranging areas outside of the houses and some odour would arise from the manure deposited on the ranging areas. The modelling assumes that good practices for farm cleanliness are followed and that other sources of odour may be considered negligible.

Peak odour emission rates from the free range egg-laying chicken houses and from the pullet rearing houses are likely to occur when the housing is cleared of spent litter at the end of each production or rearing cycle. There is little available information on the magnitude of this peak emission, but it is likely to be greater than any emission that might occur whilst the birds are in the housing. The clearing of spent litter and manure usually takes one working day and it is normal to maintain ventilation during this time. There are measures that can be taken to minimise odour production whilst the housing is being cleared of spent litter and there is usually some discretion as to when the operation is carried

7 out; therefore, to avoid high odour levels at nearby sensitive receptors, it may be possible to time the operation to coincide with winds blowing in a favourable direction. As the poultry houses operate, or would operate, a belt system that enables litter to be removed from the houses frequently, it is assumed that these emissions would be significantly less than a more traditional house where the bird droppings accumulate in the house throughout the crop.

For the calculation of the emission rates from the free range egg-laying houses, the internal odour 3 concentration is assumed to be a constant 750 ouE/m . This figure is based upon a review of available literature and measured concentrations from similar poultry houses that are available to AS Modelling & Data Ltd.

For the calculation for the pullet rearing houses, the internal concentration is assumed to be a function of the age of the crop and the stocking density. The internal concentrations used in the calculations 3 3 increase exponentially from 300 ouE/m at day 1 of the crop, to approximately 1,850 ouE/m at day 112 of the crop.

The ventilation rates used in the calculations are based on industry standard practices. Minimum ventilation rates are as those of an operational poultry house and maximum ventilation rates are based on Defra guidelines. For the calculations in the free range egg-laying houses, the minimum ventilation rate is set at 1.0 m3-air/bird/h and the maximum ventilation rate is 7.5 m3-air/bird/h. If the external temperature is 13 Celsius, or lower, minimum ventilation only is assumed for the calculation. If the external temperature is 23 Celsius, or more, then the maximum ventilation rate is assumed. A transitional ventilation rate is calculated between these extremes.

For the pullet rearing houses, target internal temperature is 32 Celsius at the beginning of the production period and is decreased to 21 Celsius by day 91 of the cycle. If the external temperature is 7 Celsius, or more, lower than the target temperature, minimum ventilation only is assumed for the calculation. Above this, ventilation rates are increased in proportion to the difference between ambient temperature and target internal temperature. A maximum transitional ventilation rate (35% of the maximum possible ventilation rate) is reached when the temperature is equal to the target temperature. A high ventilation rate (70% maximum possible ventilation rate) is reached when the temperature is 4 degrees above target and if external temperature is above 33 Celsius the maximum ventilation rate is assumed.

Based upon these principles, an emission rate for each hour of the period modelled is calculated by multiplying the concentration by the ventilation rate. A summary of the emission rates used in this study for the egg-laying chicken houses are provided in Table 1a. As additional information, the 98th percentile emission rate is approximately 1.45 ouE/bird/s. As an example, a graph of the specific emission rate over the first year of the meteorological record is shown in Figure 2a for the egg-laying chicken houses.

For the pullet rearing houses, it is assumed for the calculations that the crop length is 112 days and that there is an empty period of 42 days after each crop. To provide robust statistics, three sets of calculations were performed; the first with the first day of the meteorological record coinciding with day 1 of the crop cycle, the second coinciding with day 50 of the crop and the third coinciding with

8 day 100 of the crop. A summary of the emission rates used in this study is provided in Table 1b for the pullet rearing houses for the cages scenario, as an example. It should be noted that the figures in this Table refer to the whole of the crop length whilst most figures quoted in literature are figures obtained from the latter stages of the crop cycle and therefore should not be compared directly to the AS Modelling & Data Ltd. figures in the table. The specific odour emission rate used for the clearing th process is approximately 1.05 ouE/bird/s and the 98 percentile emission rate is approximately

0.5 ouE/bird/s. As an example, a graph of the specific emission rate over the first year of the meteorological record for each of the three crop cycles is shown in Figure 2b for the pullet rearing houses for the cages scenario, as an example.

The chickens housed in the egg-laying houses would have access to outdoor ranging areas. As a precautionary measure, it is assumed that 20%1 of the droppings would be deposited on these ranging areas and an emission rate of 0.25 ouE/bird/s is used to calculate the emission rate. These emissions are assumed to be continuous with no diurnal, seasonal, or temperature dependent variations. N.B. These emissions are additional to emissions from the housing, are probably quite precautionary and are also intended to account for any fugitive emissions from the pop holes, which might occur when ventilation rates are low.

Soiled hard-standings and farm equipment at the site are a source of odour, these sources are usually minor in comparison to other emissions from the housing; nevertheless, a strict cleansing regime and the avoidance of even temporary storage of manures in trailers or spreading equipment at the site will help to ameliorate potential odour issues.

1. It should be noted that this figure is probably based primarily upon the widely accepted figure of 80% of dropping occurring at night when birds are housed and a single report; however, because, even under optimal conditions, not all of the birds go outside (50% is considered a high percentage), this does not imply that 20% of droppings occur outside the house.

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Table 1a. Summary of odour emission rates – egg-laying houses

Emission rate (ouE/s per bird as stocked during crop) Season Average Night-time Average Day-time Average Maximum Winter 0.210 0.209 0.214 0.861 Spring 0.388 0.257 0.520 1.562 Summer 0.701 0.420 0.870 1.562 Autumn 0.277 0.239 0.315 1.251

Figure 2a. Specific emission rate over the first year of the meteorological record – egg-laying houses

Specific odour emission rate over the first year of the meteorological record

1.8 1.6 1.4 1.2 Odour emission 1 rate (ou /bird/s) E 0.8 0.6 0.4 0.2

0

1

167 333 499 665 831 997

1993 2159 3653 3819 3985 5313 5479 5645 7139 7305 1163 1329 1495 1661 1827 2325 2491 2657 2823 2989 3155 3321 3487 4151 4317 4483 4649 4815 4981 5147 5811 5977 6143 6309 6475 6641 6807 6973 7471 7637 7803 7969 8135 8301 8467 8633 Time (hours)

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Table 1b. Summary of odour emission rates – pullet rearing houses, cages

Emission rate (ouE/s per bird as stocked during crop) Season Average Night-time Average Day-time Average Maximum Winter 0.153 0.138 0.183 0.587 Spring 0.160 0.133 0.187 0.745 Summer 0.187 0.142 0.214 0.784 Autumn 0.156 0.133 0.180 0.624

Figure 2b. Specific emission rate over the first year of the meteorological record – pullet rearing houses, cages

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4. The Atmospheric Dispersion Modelling System (ADMS) and Model Parameters

The Atmospheric Dispersion Modelling System (ADMS) ADMS 5 is a new generation Gaussian plume air dispersion model, which means that the atmospheric boundary layer properties are characterised by two parameters; the boundary layer depth and the Monin-Obukhov length rather than in terms of the single parameter Pasquill-Gifford class.

Dispersion under convective meteorological conditions uses a skewed Gaussian concentration distribution (shown by validation studies to be a better representation than a symmetrical Gaussian expression).

ADMS has a number of model options including: dry and wet deposition; NOx chemistry; impacts of hills, variable roughness, buildings and coastlines; puffs; fluctuations; odours; radioactivity decay (and γ-ray dose); condensed plume visibility; time varying sources and inclusion of background concentrations.

ADMS has an in-built meteorological pre-processor that allows flexible input of meteorological data both standard and more specialist. Hourly sequential and statistical data can be processed and all input and output meteorological variables are written to a file after processing.

The user defines the pollutant, the averaging time (which may be an annual average or a shorter period), which percentiles and exceedance values to calculate, whether a rolling average is required or not and the output units. The output options are designed to be flexible to cater for the variety of air quality limits, which can vary from country to country and are subject to revision.

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4.1 Meteorological data Computer modelling of dispersion requires hourly sequential meteorological data and to provide robust statistics, the record should be of a suitable length; preferably four years or longer.

The meteorological data used in this study is obtained from assimilation and short term forecast fields of the Numerical Weather Prediction (NWP) system known as the Global Forecast System (GFS).

The GFS is a spectral model: the physics/dynamics model has an equivalent resolution of approximately 13 km; terrain is understood to be resolved at a resolution of approximately 2 km (with sub 13 km terrain effects parameterised) and data are archived at a resolution of 0.25 degrees (site specific data may be extrapolated from nearby archive grid points or a most representative grid point chosen). The GFS resolution adequately captures major topographical features and the broad-scale characteristics of the weather over the UK. Smaller scale topological features may be included in the dispersion modelling by using the flow field module of ADMS (FLOWSTAR). The use of NWP data has advantages over traditional meteorological records because:

• Calm periods in traditional observational records may be over represented, this is because the instrumentation used may not record wind speeds below approximately 0.5 m/s and start up wind speeds may be greater than 1.0 m/s. In NWP data, the wind speed is continuous down to 0.0 m/s, allowing the calms module of ADMS to function correctly.

• Traditional records may include very local deviations from the broad-scale wind flow that would not necessarily be representative of the site being modelled; these deviations are difficult to identify and remove from a meteorological record. Conversely, local effects at the site being modelled are relatively easy to impose on the broad-scale flow and provided horizontal resolution is not too great, the meteorological records from NWP data may be expected to represent well the broad-scale flow.

• Information on the state of the atmosphere above ground level which would otherwise be estimated by the meteorological pre-processor may be included explicitly.

The wind rose for the raw GFS data at the site of the poultry unit is shown in Figure 3a.

Wind speeds are modified by the treatment of roughness lengths (see Section 4.7) and because terrain data is included in the modelling, the raw GFS wind speeds and directions will be modified. The terrain and roughness length modified wind rose for Tolehurst Farm is shown in Figure 3b; it should be noted that although, as might be expected, there is very little modification in this case; elsewhere in the modelling domain the modified wind roses may differ more markedly, reflecting the local flow in that part of the domain. The resolution of the wind field in terrain runs is approximately 100 m. Please also note that FLOWSTAR is used to obtain a local flow field, not to explicitly model dispersion in complex terrain as defined in the ADMS User Guide; therefore, the ADMS default value for minimum turbulence length has been amended.

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Figure 3a. The wind rose. Raw GFS derived data for 51.135 N, 0.549 E, 2014 – 2017

350° 0° 10° 340° 20° 2500 330° 30° 320° 40° 2000 310° 50° 1500 300° 60°

290° 1000 70°

280° 500 80°

270° 90°

260° 100°

250° 110°

240° 120°

230° 130°

220° 140° 210° 150° 200° 160° 190° 180° 170° 0 3 6 10 16 (knots) Wind speed 0 1.5 3.1 5.1 8.2 (m/s)

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Figure 3b. The wind rose. FLOWSTAR modified GFS derived data for NGR 578450, 140350

350° 0° 10° 340° 20° 2500 330° 30° 320° 40° 2000 310° 50° 1500 300° 60°

290° 1000 70°

280° 500 80°

270° 90°

260° 100°

250° 110°

240° 120°

230° 130°

220° 140° 210° 150° 200° 160° 190° 180° 170° 0 3 6 10 16 (knots) Wind speed 0 1.5 3.1 5.1 8.2 (m/s)

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4.2 Emission sources Emissions from the uncapped high speed ridge fans that are used to ventilate the existing free range egg-laying and pullet rearing houses and would be used to ventilate the proposed pullet rearing houses are represented by three point sources per house (EX1-4, PR1 and PR2, cages, non-Freedom Foods and Freedom Foods; a, b & c) within ADMS. Details of the point source parameters are shown in Table 2a. The positions of the point sources are shown in Figure 4, where they are marked by red star symbols.

Table 2a. Point source parameters Efflux Emission Emission rate per Height Diameter Source ID velocity temperature source (m) (m) (m/s) (˚C) (ouE/s) EX1 & EX2; a, b & c 2 6.0 0.8 11.0 Variable 1 Variable 1 EX3 & EX4; a, b & c 3 6.0 0.8 11.0 Variable 1 Variable 1 PR1 & PR2 (scenario); a, b & c 4 6.0 0.8 11.0 Variable 1 & 4 Variable 1 & 4 1. Dependent on crop stage and ambient temperature. 2. Included in existing scenario only. 3. Included in all scenarios. 4. Varied also for the cages, non-Freedom Foods and Freedom Foods scenarios.

The existing layer chicken houses have ranging areas, which are represented by area sources within ADMS (EX3_ranN, EX3_ranS, EX4_ranN and EX4_ranS). Note that the area sources cover the parts of the ranges most likely to be used frequently and not the whole ranging areas. Details of the area source parameters are provided in Table 2b. The positions of the area sources are shown in Figure 4, where they are marked by red polygons. Note, these sources are included in all four scenarios.

Table 2b. Area source parameters Emission Area Base height Emission rate Source ID temperature (m2) (m) (ou /s) (°C) E EX3_ranN 10,074 0.0 Ambient 1,600.0 EX3_ranS 10,359 0.0 Ambient 1,600.0 EX4_ranN 2,914 0.0 Ambient 800.0 EX4_ranS 2,856 0.0 Ambient 800.0

4.3 Modelled buildings The structure of the poultry houses and other nearby buildings may affect the odour plumes from the point sources. Therefore, these buildings are modelled within ADMS. The positions of the modelled buildings may be seen in Figure 4, where they are marked by grey rectangles.

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Figure 4. The positions of the modelled buildings and sources

© Crown copyright and database rights 2018.

4.4 Discrete receptors Fifty-five discrete receptors have been defined at a selection of nearby residences and commercial properties. The receptors are defined at 1.5 m above ground level within ADMS and their positions may be seen in Figure 5, where they are marked by enumerated pink rectangles.

4.5 Nested Cartesian grid To produce the contour plots presented in Section 5 of this report, a nested Cartesian grid has been defined within ADMS. The grid receptors are defined at 1.5 m above ground level within ADMS. The positions of the grid receptors may be seen in Figure 5, where they are marked by green crosses.

4.6 Terrain data Terrain has been considered in the modelling. The terrain data are based upon the Ordnance Survey 50 m Digital Elevation Model. A 6.4 km x 6.4 km domain has been resampled at 50 m horizontal resolution for use within ADMS. N.B. The resolution of FLOWSTAR is 64 x 64 grid points; therefore, the effective resolution of the wind field is 100 m.

4.7 Other model parameters A fixed surface roughness length of 0.4 m has been applied over the entire modelling domain. As a precautionary measure, the GFS meteorological data is assumed to have a roughness length of 0.375 m. The effect of the difference in roughness length is precautionary as it increases the frequency of low wind speeds and the stability and therefore increases predicted ground level concentrations.

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Figure 5. The discrete receptors and nested Cartesian grid receptors

© Crown copyright and database rights 2018.

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5. Details of the Model Runs and Results

For this study, the model was run with the calms and terrain modules in ADMS sixteen times; once for each year of the four year meteorological record and for each of the four scenarios.

Statistics for the annual 98th percentile hourly mean odour concentration at each receptor were compiled for each of the modelling runs.

A summary of the results of these modelling runs at the discrete receptors is provided in Table 3, where the maximum annual 98th percentile hourly mean odour concentrations are shown. Contour plots of the maximum annual 98th percentile hourly mean odour concentrations are shown in Figure 6a, for the existing scenario, Figure 6b, for the cages scenario, Figure 6c, for the non-Freedom Foods scenario and Figure 6d, for the Freedom Foods scenario.

3 In Table 3, predicted odour exposures in excess of the Environment Agency’s benchmark of 3.0 ouE/m as an annual 98th percentile hourly mean are coloured blue; those in the range that UKWIR research 3 3 suggests gives rise to a significant proportion of complaints, 5.0 ouE/m to 10.0 ouE/m as an annual 98th percentile hourly mean, are coloured orange and predicted exposures likely to cause annoyance and complaint are coloured red.

Table 3. Predicted maximum annual 98th percentile hourly mean odour concentrations at the discrete receptors

th 3 Maximum annual 98 percentile hourly mean odour concentration (ouE/m )

Non Freedom Freedom Food Receptor Existing Cage rearing X(m) Y(m) Food aviary aviary number GFS GFS GFS GFS Calms Calms Calms Calms Terrain Terrain Terrain Terrain

1 578619 140104 1.17 1.98 1.86 1.49 2 578678 140103 1.34 1.99 1.93 1.57 3 578716 140101 1.46 2.09 2.01 1.61 4 578744 140068 1.79 2.12 2.07 1.84 5 578718 140029 2.14 2.27 2.24 2.16 6 578710 140331 0.95 2.73 2.54 1.57 7 578745 140331 0.77 2.40 2.21 1.39 8 578769 140327 0.72 2.18 2.01 1.29 9 578831 140363 0.58 1.88 1.74 1.11 10 578969 140327 0.65 1.24 1.16 0.82 11 579058 140292 0.64 1.09 1.04 0.78 12 579071 140260 0.67 1.07 1.04 0.80 13 579126 140282 0.60 0.96 0.90 0.73 14 579151 140245 0.68 0.99 0.93 0.77 15 579420 140208 0.50 0.72 0.70 0.58 16 579258 139865 0.83 1.06 1.03 0.90 17 579334 139798 0.60 0.76 0.75 0.65 18 579347 139460 0.30 0.48 0.46 0.37

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th 3 Maximum annual 98 percentile hourly mean odour concentration (ouE/m )

Non Freedom Freedom Food Receptor Existing Cage rearing X(m) Y(m) Food aviary aviary number GFS GFS GFS GFS Calms Calms Calms Calms Terrain Terrain Terrain Terrain 19 579330 139362 0.24 0.41 0.39 0.33 20 579341 139277 0.21 0.35 0.34 0.29 21 579785 139446 0.17 0.30 0.29 0.24 22 579666 139219 0.16 0.28 0.27 0.23 23 579728 139216 0.16 0.28 0.27 0.22 24 578970 139219 0.29 0.42 0.40 0.36 25 579164 139203 0.23 0.38 0.36 0.31 26 579176 139147 0.20 0.34 0.33 0.28 27 579109 139114 0.20 0.33 0.32 0.25 28 579179 139059 0.17 0.29 0.29 0.23 29 579038 138893 0.13 0.22 0.21 0.17 30 579312 138955 0.14 0.24 0.23 0.20 31 578583 138905 0.14 0.22 0.21 0.19 32 578516 138933 0.15 0.24 0.23 0.20 33 577966 139235 0.21 0.28 0.27 0.25 34 577922 139308 0.23 0.32 0.32 0.29 35 577856 139130 0.15 0.22 0.21 0.19 36 577474 139030 0.17 0.27 0.25 0.22 37 577433 139608 0.27 0.52 0.49 0.40 38 577467 139752 0.27 0.57 0.54 0.42 39 577480 139832 0.27 0.59 0.56 0.44 40 577437 139922 0.23 0.54 0.50 0.38 41 577573 140099 0.29 0.60 0.58 0.45 42 577683 140115 0.37 0.77 0.74 0.54 43 577792 140040 0.56 0.98 0.93 0.74 44 578904 140575 0.36 1.34 1.24 0.83 45 578871 140640 0.32 1.19 1.10 0.76 46 578873 140697 0.30 1.13 1.03 0.70 47 578838 140711 0.28 1.22 1.13 0.76 48 579107 140737 0.26 0.68 0.64 0.47 49 578944 140788 0.26 0.87 0.81 0.56 50 578787 140799 0.24 1.11 1.03 0.68 51 578740 141001 0.18 0.70 0.65 0.47 52 579717 140709 0.20 0.40 0.39 0.30 53 579772 140948 0.16 0.33 0.32 0.24 54 578707 140749 0.27 1.37 1.27 0.82 55 578634 141066 0.18 0.68 0.63 0.43

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Figure 6a. Predicted maximum annual 98th percentile hourly mean odour concentration – existing scenario

© Crown copyright and database rights 2018.

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Figure 6b. Predicted maximum annual 98th percentile hourly mean odour concentration – cages scenario

© Crown copyright and database rights 2018.

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Figure 6c. Predicted maximum annual 98th percentile hourly mean odour concentration – non-Freedom Foods scenario

© Crown copyright and database rights 2018.

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Figure 6d. Predicted maximum annual 98th percentile hourly mean odour concentration – Freedom Foods scenario

© Crown copyright and database rights 2018.

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6. Summary and Conclusions

AS Modelling & Data Ltd. has been instructed by Brian Barrow of Acorus Rural Property Services Ltd., on behalf of Fridays Ltd., to use computer modelling to assess the impact of odour emissions from the existing free range egg-laying chicken houses and the existing and proposed pullet rearing houses at Tolehurst Farm, near to Cranbrook, in Kent. TN17 3PN.

Odour emission rates from the existing and proposed poultry houses have been assessed and quantified based upon an emissions model that considers the likely internal odour concentrations and ventilation rates of the poultry houses. The odour emission rates so obtained have then been used as inputs to an atmospheric dispersion model which calculates odour exposure levels in the surrounding area.

The modelling predicts that, for all three proposed options for the redevelopment of the pullet rearing houses at Tolehurst Farm, at all of the discrete receptors considered, the odour exposure would remain below the Environment Agency’s benchmark for moderately offensive odours, which is a th 3 maximum annual 98 percentile hourly mean concentration of 3.0 ouE/m .

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7. References

Chartered Institution of Water and Environmental Management website. Control of Odour. http://www.ciwem.org/policy-and-international/policy-position-statements/control-of-odour.aspx

Environment Agency, April 2007. H4 Odour Management, How to comply with your environmental permit. http://a0768b4a8a31e106d8b0-50dc802554eb38a24458b98ff72d550b.r19.cf3.rackcdn.com/geho0411btqm-e-e.pdf

S. Fournela, F. Pelletierb, S. Godboutb. Odour emissions, hedonic tones and ammonia emissions from three cage layer housing systems.

Nimmermark S. & Gustafsson G. Influence of Temperature, Humidity and Ventilation Rate on the Release of Odour and Ammonia in a Floor Housing System for Laying Hens.

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Appendix 6

Odour Assessment

Modelling ammonia emissions at Tolehurst poultry farm

(Permit Number KP3333US)

Report prepared for:

Fridays Limited Chequer Tree Farm Cranbrook Kent TN17 3PN

Report prepared by:

M J Sharp Senior Environmental Consultant November 2018

SAC Environment & Design 2 Technopole Centre Bush Estate Penicuik Midlothian EH26 0PJ

Tel: 0131 603 7511

Email: [email protected]

Modelling ammonia emissions at Tolehurst Poultry Farm Prepared for: Fridays Limited ______

CONTENTS

1. INTRODUCTION...... 3 1.1 Background ...... 3 2. MODELLING AT TOLEHURST FARM ...... 3 2.1 Emission factors ...... 3 2.2 Modelling methodology ...... 3 2.3 Sensitive receptors ...... 5 3. DISPERSION MODELLING RESULTS ...... 5 3.1 General ...... 5 3.2 Process contributions – concentrations and deposition ...... 5 4. CONCLUSIONS ...... 8 5. APPENDIX 1 ...... 9 6. FIGURE 1. Wind rose from Met data used in modelling (2010)...... 12 7. FIGURE 2 (below) Tolehurst 2018 Isopleths show predicted average ground level concentrations of ammonia in µg m-3 (2010 weather data)...... 12

______

SAC Consulting, November 2018 2 © SAC Consulting 2018. All rights reserved. Modelling ammonia emissions at Tolehurst Poultry Farm Prepared for: Fridays Limited ______

1. INTRODUCTION 1.1 Background Tolehurst poultry farm is located near Staplehurst in Kent. Tolehurst farm lies to the south of Knox Bridge village and contains free range and rearing housing. The site is currently permitted (KP3333US) for 96,000 places for layers and 84,000 places for pullets - a total of 180,000 birds. Fridays Limited are proposing to increase the capacity for pullet rearing on the site raising this to a total of 322,560 pullets that will be reared in two sheds each containing 161,280 birds. The number of free range laying hens will remain the same at 96,000.

The variation to the permit will therefore be for an additional 238,560 pullet rearing places. It is important to note that although the increase in bird numbers appears large the increase in ammonia emissions is not proportional as a different husbandry system is to be used. The pullets will be reared in belt clean caged systems. Ammonia emissions will increase by 28%. To mitigate this increase advanced ventilation techniques will be employed to aid with dilution and dispersion of emissions.

To quantify the environmental impacts of the proposed changes the company has requested SAC Consulting to undertake modelling of ammonia emissions.

2. MODELLING AT TOLEHURST FARM 2.1 Emission factors Fridays Limited has in the past been in discussion with the Environment Agency regarding emission factors for the belt clean aviary system used in the two free range sheds at Tolehurst, as they felt that a factor of 0.08 kg NH3 per bird per year was too high for modern systems of the type proposed.

The EA subsequently approved a change to allow the use of an emissions factor of 0.06 kg NH3 per bird place per year, and this emission factor was used in the ammonia modelling report for the existing permit in 2013. Consequently, this factor has also been used for the proposed variation at Tolehurst Farm.

For pullet rearing an emission factor of 0.025 kg NH3 per bird place per year has been used. This was also the factor used in 2012 modelling for pullet rearing in belt cleaned cage systems at the company. The factor takes into consideration the much smaller birds (day old to 17 weeks with an end weight of approximately 1.3 kg at 17 weeks) and is an appropriate yet precautionary factor for pullet rearing in caged systems where birds are much smaller, manure is removed twice weekly, and annual occupancy is generally lower.

2.2 Modelling methodology Modelling has been undertaken using Cambridge Environmental Research Consultants’ latest version of their model ADMS V5.2. ADMS V5.2 is widely used in the UK as one of the current industry standard advanced models for dispersion from point, line, area and volume sources. Depending on the type of modelling to be undertaken, the model takes as a starting point information on emissions from each source, in this case each poultry shed, that includes: • release rate of the substances being considered; • release temperature; • release velocity or volumetric flow; ______

SAC Consulting, February 2018 3 © SAC Consulting 2018 All rights reserved Modelling ammonia emissions at Tolehurst Poultry Farm Prepared for: Fridays Limited ______

• release point location; • release point height; • release point diameter, line length, volume or area; • location and dimensions of any buildings nearby; • local terrain between source and receptor; and • location of sensitive receptors nearby.

Modelling emissions from agricultural buildings can present challenges due to the diversity of ventilation systems in use. In general terms buildings with open roof- mounted fans can be modelled as a number of point sources and the task is relatively straight forward. The poultry houses at Tolehurst incorporate high efflux velocity roof mounted ventilation systems and these are summarised in Table 1 below along with a brief description of the methods used for this modelling assessment.

Table 1 Ventilation systems in use at Tolehurst Farms

House Bird Nos System Manure Ventilation Modelling Fan Building dimensions removal method efflux L x W x H velocity, m s-1 Tol 1 161,280 Cage Twice per Side Point 13.3* 120 x 26.7 x 9.5 rearing, week inlet/roof sources belt clean ridge exhaust Tol 2 161,280 Cage Twice per Side Point 13.3* 120 x 26.7 x 9.5 rearing, week inlet/roof sources belt clean ridge exhaust Tol 3 32,000 Free range Twice per Side Point 11.5 136.2 x 20.5 x 7.5 aviary, belt week inlet/roof sources clean ridge exhaust Tol 4 64,000 Free range Twice per Side Point 11.5 136.2 x 20.5 x 7.5 aviary, belt week inlet/roof sources clean ridge exhaust *Fan speed of 13.3. m s-1 achieved by fitment of guide vanes1.

Terrain data The complex terrain module was used to take account of complex terrain as there are slopes in excess of 1:10 to the south of Tolehurst Farm.

Buildings effects Because there were ancient woodland sites close to the poultry houses the buildings module was applied to the dispersion model to take account of building downwash effects from those sources at roof height.

All inputs used in the modelling runs described in this report are collated in reports generated by the ADMS software. For transparency the report for the worst year (2010) is appended to this report. The weather station used for the installation was Herstmonceau using data from 2007 - 2011.

The background concentration for the area, obtained from the APIS database2, was -3 1.4 µg NH3 m .

1 Ziehl-Abegg SE Guide vane for agricultural applications. DLG Plume Rise test report 5642F www.dlg-test.de ______

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2.3 Sensitive receptors Sites of concern were identified in the Environment Agency’s screening exercise (undertaken in 2012). They consisted of one SSSI site, Sissinghurst Park Wood, and over 50 ancient woodland sites within 2 km of the farm. The closest of these are marked on Figure 1. Tolehurst Wood is located close to the rearing houses and Reeves Wood is approximately 80 metres to the east of the large free range house (Tol 4). Saunders and Brewers woods are also relatively close to the free range sheds being approximately 100 and 200 metres distant.

Because there are a large number of receptors within two kilometres of the poultry farm calculating specific values at all sites whilst applying other modelling features such as complex terrain and buildings effects would result in long model run-times. To reduce run-times specific values for only those sites likely to be affected by the farm as demonstrated during test model runs have been calculated. At distances greater than this it is considered that receptors are far enough away to be relatively unaffected.

Marden meadows SSSI and the River Beult SSSI were not included in the EA screening exercise. The closest edge of Marden Meadows is 5 km from the approximate centre point of the site and the closest point of the River Beult is approximately 4.63 km away. As these sites are unlikely to be affected and have screened out, they have not been included in this assessment.

Specific values for a number of ancient woodland locations and Sissinghurst Park Wood SSSI are listed below. Values are shown for both the higher and lower critical levels although the Environment Agency has confirmed that the ancient woodland -3 sites have been assigned a critical level of 3 µg m . A critical load (CLo) range of 10 - 20 kg N ha-1 y-1 has been applied to all sites listed in this assessment.

3. DISPERSION MODELLING RESULTS 3.1 General Results from the dispersion model for year 2010, which on balance is the worst year for the closest woodland sites, have been plotted as a contour plot on to Ordnance Survey maps shown in Figure 2 and are tabulated in Table 3.1 below. The isopleths on the map show the annual average ground level concentrations of ammonia in µg m-3 for 2010 weather data. The local wildlife sites are marked with the letters AW for ancient woodland or the name of the local site. Details of the modelling inputs are provided in Appendix 1, and a wind rose is shown in Figure 1.

3.2 Process contributions – concentrations and deposition Ammonia concentrations and the process contribution as a percentage of critical -3 levels of 1 and 3 µg NH3 m are provided in Table 3.1. In addition to concentrations an assessment of critical loads is also provided. Ammonia dry deposition has been calculated by the ADMS model after by applying a deposition velocity of 0.02 m s-1 across the modelled domain. This is an appropriate value for short semi-natural vegetation which is predominant around the poultry houses although there are woodlands to the south of the area. For specific locations, values for nitrogen deposition in kg N ha-1 y-1 have been provided. Some caution is advised when

2 UK Air Pollution Information System. www.apis.ac.uk ______

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interpreting deposition data due to the inherent uncertainties in assumptions used in calculating deposition. The process contribution of nutrient nitrogen as a percentage of the critical load in Table 3.1 below is based on the lower value of a critical load -1 -1 -3 range of 10 - 20 kg NH3 ha y . However, when applying a critical level of 3 µg m it is reasonable to assume the higher of the critical load range for nutrient nitrogen, in this case 20 kg N ha-1 y-1, otherwise nutrient nitrogen would be the limiting factor thus negating the effects of applying the higher critical level.

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Table 3.1. Modelling results

Site – closest Year PC, PC as % of PC as % of PC, N PC as % of point affected NH3, µg CLe of 1 µg CLe of 3 µg deposition, CLo of 10 -1 -1 -1 -1 m-3 m-3 m-3 kg N ha y kg N ha y Sissinghurst 2011 0.092 9 3 0.5 5 Park Wood SSSI 2010 0.148 15 5 0.8 8 2009 0.110 11 4 1.0 10 GR 2008 0.115 12 4 0.6 6 580064,139281 2007 0.117 12 4 0.6 6 Tolehurst Wood 2011 1.582 158 53 8.2 82 AW 2010 2.371 237 79 12.3 123 2009 1.614 161 54 8.0 80 GR 2008 1.830 183 61 9.5 95 578545,140309 2007 2.142 214 71 11.1 111 Grandshore 2011 0.269 27 9 1.4 14 Wood AW 2010 0.216 22 7 1.1 11 2009 0.275 28 9 1.0 10 GR 2008 0.287 29 10 1.5 15 579762,140597 2007 0.251 25 8 1.3 13 Duck Pit Wood 2011 0.198 20 7 1.0 10 AW 2010 0.149 15 5 0.8 8 2009 0.191 19 6 1.0 10 GR 2008 0.194 19 6 1.0 10 580021,140886 2007 0.164 16 5 0.8 8 Grand Shore 2011 0.472 47 16 2.4 24 Wood 2 AW 2010 0.433 43 14 2.2 22 2009 0.505 51 17 3.0 30 GR 2008 0.493 49 16 2.5 25 579271,140302 2007 0.487 49 15 2.5 25 Mapelhurst Farm 2011 0.105 11 4 0.5 5 Wood AW 2010 0.084 8 3 0.4 4 2009 0.100 10 3 1.0 10 GR 2008 0.088 9 3 0.5 5 579316,141621 2007 0.072 7 2 0.4 4 Reeves Wood 2011 1.980 198 66 10.2 102 AW 2010 1.443 144 48 7.5 75 2009 1.838 183 61 10 10 GR 2008 2.063 206 69 10.7 107 578928,139906 2007 1.912 191 64 9.9 99 Saunders Wood 2011 1.063 106 34 5.5 55 AW 2010 1.188 119 40 6.1 61 2009 1.058 106 35 5.0 50 GR 2008 1.098 110 37 5.7 57 578624,139728 2007 1.167 117 39 6.0 60 Brewers Wood 2011 0.744 74 25 3.8 38 AW 2010 0.837 84 28 4.3 43 2009 0.741 74 25 4.0 40 GR 2008 0.769 77 26 4.0 40 578038,139786 2007 0.888 89 30 4.6 46

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4. CONCLUSIONS 4.1 The worst years in terms of the highest ammonia concentrations at Sissinghurst Wood SSSI was 2010. There was some variation as to which was the ‘worst year at the Ancient Woodland sites but at three of the closest (Tolehurst, Saunders and Brewers Woods it was also 2010. -3 4.2 The process contribution of NH3 did not exceed 100% of a critical level of 3 µg m at any of the ancient woodland receptors, and did not exceed 50% of a critical load of either 1 or 3 µg m-3 at Sissinghurst Park Wood SSSI. 4.3 The process contribution of nutrient nitrogen exceeded 100% of the lower range of a critical load of 10 – 20 kg N ha-1 y-1 at two of the ancient woodland sites – Tolehurst Wood and Reeves Wood. 4.4 The process contributions of nutrient nitrogen were all within a critical load range of 10 – 20 kg N ha-1 y-1. When applying a critical level of 3 µg m-3 it is reasonable to apply the higher of the critical load range for nutrient nitrogen, in this case 20 kg N ha-1 y-1, otherwise nutrient nitrogen would be the limiting factor thus negating the effects of applying the higher critical level. 4.5 There are greater uncertainties in the calculation of nitrogen deposition and concentrations are likely to be more reliable for assessment purposes. 4.6 Due to the change in husbandry system and ventilation systems used for pullet rearing, the conclusions of this assessment are not materially different to the current permitted situation.

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5. APPENDIX 1

______ADMS 5.2 (5.2) ______Atmospheric Dispersion Modelling System ______Copyright (C) 2017 Cambridge Environmental Research Consultants Ltd. ______This run was made at 14:19 on the 14/11/2018 ______Report File ______

1. SETUP INFORMATION:

Site name : Tolehurst Project name: Tolehurst R1 2018 10 met dep

Input file pathname : C:\MJS project folders\ADMS 5\Runs\Fridays Tolehurst 2018\Tolehurst R1 2018 10 met dep.APL Command-line options : /E1 /ADMS

Model information: - Pathname C:\Program Files (x86)\CERC\ADMS 5\ADMSModel.exe - Version 5.2.2.0 - Build number 3080 - Release date February 2017

2. MODEL OPTIONS:

Dry deposition Buildings - 3 buildings defined: > 'Tol 1&2', centre (578434.0, 140383.0), height 9.0m, length 120.0m, width 26.0m, angle 93.0 degrees > 'Tol 3', centre (578203.0, 139947.0), height 6.2m, length 136.0m, width 21.0m, angle 93.0 degrees > 'Tol 4', centre (578800.0, 139855.0), height 6.2m, length 240.0m, width 21.0m, angle 70.0 degrees - 'Tol 1&2' is the 'Main building' for this run Complex terrain - Modelling hills - Pathname of hills data C:\MJS project folders\ADMS 5\Terrain data\Fridays\Knoxbridge.ter - Calculation grid resolution = 32x32

3. SOURCE OPTIONS:

Your run includes the following sources:

15 point sources - 'Tol1 P1' - 'Tol1 P2' - 'Tol1 P3' - 'Tol2 P1' - 'Tol2 P2' - 'Tol2 P3' - 'Tol3 P1' - 'Tol3 P2' - 'Tol3 P3' - 'Tol3 P4' - 'Tol4 P1' - 'Tol4 P2' - 'Tol4 P3' - 'Tol4 P4' - 'Tol4 P5'

POINT SOURCE GEOMETRY:

Source name, Height(m), Location, Diameter(m), Main building, Tol1 P1, 9.50, (578395.0, 140403.0), 0.66, (Main), Tol1 P2, 9.50, (578435.0, 140398.0), 0.66, (Main), ______

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Tol1 P3, 9.50, (578470.0, 140394.0), 0.66, (Main), Tol2 P1, 9.50, (578393.0, 140368.0), 0.66, (Main), Tol2 P2, 9.50, (578427.0, 140364.0), 0.66, (Main), Tol2 P3, 9.50, (578469.0, 140358.0), 0.66, (Main), Tol3 P1, 7.50, (578144.0, 139895.0), 0.66, (Main), Tol3 P2, 7.50, (578176.0, 139888.0), 0.66, (Main), Tol3 P3, 7.50, (578221.0, 139879.0), 0.66, (Main), Tol3 P4, 7.50, (578256.0, 139870.0), 0.66, (Main), Tol4 P1, 7.50, (578710.0, 139820.0), 0.66, (Main), Tol4 P2, 7.50, (578745.0, 139835.0), 0.66, (Main), Tol4 P3, 7.50, (578795.0, 139855.0), 0.66, (Main), Tol4 P4, 7.50, (578835.0, 139870.0), 0.66, (Main), Tol4 P5, 7.50, (578879.0, 139888.0), 0.66, (Main),

SOURCE CHARACTERISTICS:

Source name, Exit velocity(m/s), Temp(degC), Actual/NTP, Mol. mass(g), Cp(J/degC/Kg), Tol1 P1, 13.300, 20.000, Actual, 28.966, 1012.00, Tol1 P2, 13.300, 20.000, Actual, 28.966, 1012.00, Tol1 P3, 13.300, 20.000, Actual, 28.966, 1012.00, Tol2 P1, 13.300, 20.000, Actual, 28.966, 1012.00, Tol2 P2, 13.300, 20.000, Actual, 28.966, 1012.00, Tol2 P3, 13.300, 20.000, Actual, 28.966, 1012.00, Tol3 P1, 11.500, 20.000, Actual, 28.966, 1012.00, Tol3 P2, 11.500, 20.000, Actual, 28.966, 1012.00, Tol3 P3, 11.500, 20.000, Actual, 28.966, 1012.00, Tol3 P4, 11.500, 20.000, Actual, 28.966, 1012.00, Tol4 P1, 11.500, 20.000, Actual, 28.966, 1012.00, Tol4 P2, 11.500, 20.000, Actual, 28.966, 1012.00, Tol4 P3, 11.500, 20.000, Actual, 28.966, 1012.00, Tol4 P4, 11.500, 20.000, Actual, 28.966, 1012.00, Tol4 P5, 11.500, 20.000, Actual, 28.966, 1012.00,

EMISSION DATA:

Source name, Units, NH3, Tol1 P1, g/s, 0.043, Tol1 P2, g/s, 0.043, Tol1 P3, g/s, 0.043, Tol2 P1, g/s, 0.043, Tol2 P2, g/s, 0.043, Tol2 P3, g/s, 0.043, Tol3 P1, g/s, 0.015, Tol3 P2, g/s, 0.015, Tol3 P3, g/s, 0.015, Tol3 P4, g/s, 0.015, Tol4 P1, g/s, 0.024, Tol4 P2, g/s, 0.024, Tol4 P3, g/s, 0.024, Tol4 P4, g/s, 0.024, Tol4 P5, g/s, 0.024,

SUMMARY OF OUTPUT GROUP CONTENTS:

Group name, Source name, , Tol1 P1, , Tol1 P2, , Tol1 P3, , Tol2 P1, , Tol2 P2, , Tol2 P3, , Tol3 P1, , Tol3 P2, , Tol3 P3, , Tol3 P4, , Tol4 P1, , Tol4 P2, , Tol4 P3, , Tol4 P4, , Tol4 P5,

4. METEOROLOGY:

Site data: ______

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- Latitude (degrees) = 51.00 - Dispersion site: > Surface roughness (m) = .300 ~ Using model default Minimum Monin-Obukhov length (m) ~ Surface albedo = .230 (Model default) ~ Priestley-Taylor parameter = 1.000 (Model default) ~ Precipitation at dispersion site same as at met site - Meteorological measurement site: > Surface roughness same as dispersion site ~ Minimum Monin-Obukhov length same as at dispersion site ~ Surface albedo same as at dispersion site ~ Priestley-Taylor parameter same as at dispersion site

Meteorological data: - From file C:\MJS project folders\ADMS 5\Met data\Herstmonceux\herstadms10.met - Sequential met data - Height of recorded wind (m) = 10.0 - Met lines with wind speed at 10m less than .75m/s are not modelled - Met data in sectors, size (degrees) = 10.0

5. BACKGROUND DATA:

6. GRID OPTIONS:

Cartesian co-ordinate system Gridded output - Regular spacing - 31x31 - South-West corner at (576000.0, 138000.0) - North-East corner at (581000.0, 143000.0) - Number of heights = 1 - Minimum height(m) = .0 - Maximum height(m) = .0 Specified points output - 'Sissinghurst Wood' at (580073.0, 139282.0, .0) - 'Tolehurst Wood' at (578462.0, 140333.0, .0) - 'Grandshore Wood' at (579776.0, 140600.0, .0) - 'Duck Pit Wood' at (580024.0, 140882.0, .0) - 'Grand Shore Wood 2' at (579271.0, 140300.0, .0) - 'Maplehurst Farm Wood' at (579314.0, 141619.0, .0) - 'Reeves Wood' at (578985.0, 139911.0, .0) - 'Saunders Wood' at (578622.0, 139730.0, .0) - 'Brewers Wood' at (578038.0, 139787.0, .0)

7. OUTPUT OPTIONS:

Groups modelled - ''

POLLUTANT OUTPUT DATA:

Pollutant, Statistic, Condition, Percentiles, Exceedences, NH3, Long-term 1-hourly non-rolling (ug/m3), None, None, None,

______End of Report File ______

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6. FIGURE 1. WIND ROSE FROM MET DATA USED IN MODELLING (2010).

I:\MSOffice\ADMS\Met data\Herstmonceux\herstadms10.met

350° 0° 10° 340° 500 20° 330° 30° 320° 40° 400 310° 50° 300 300° 60°

290° 200 70°

280° 100 80°

270° 90°

260° 100°

250° 110°

240° 120°

230° 130°

220° 140° 210° 150° 200° 160° 190° 180° 170° 0 3 6 10 16 (knot s) Wind speed 0 1.5 3.1 5.1 8.2 (m/ s)

7. FIGURE 2 (below) Tolehurst 2018 Isopleths show predicted average ground level concentrations of ammonia in µg m-3 (2010 weather data).

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This product includes mapping data licensed from Ordnance Survey Crown Copyright and or database right 2018. License number 100027745

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Appendix 7

Ammonia Assessment

Cedar Land Management

Tolehurst Farm Cranbrook Road Frittenden Cranbrook Kent Landscape Visual Impact Assessment

Client: Acorus Rural Property Services The Old Market Office 10 Risbygate Street Bury St Edmunds Suffolk IP33 3AA

Location for replacement poultry buildings

Cedar Land Management 21 Mashbury Road Great Waltham Chelmsford CM3 1EN

Tel +44 (0)1245 362406 Mob +44 (0) 7876 141410

Job number ACOR18-637

Tolehurst Farm

Contents

1.0 Introduction

2.0 Visual Impact Assessment Methodology

3.0 Desk Study

4.0 Landscape Analysis

5.0 Field Study

6.0 Identification and Assessment of Landscape Impact

7.0 Significance of Effects

Appendices Appendix A: Site Plan and Block Plan Appendix B: Location Plan Appendix C: Extent of Visibility Appendix D: Representative Viewpoints Appendix E: Photographs from Representative Viewpoints

Tolehurst Farm

1 Introduction

1.1 Background

This report was commissioned by Acorus Rural Property Services and is a Landscape Visual Impact Assessment which forms part of the planning application for the demolition of two of the existing poultry buildings and their replacement with two new poultry buildings at Tolehurst Farm, Cranbrook Road, Frittenden, Cranbrook Kent, TN17 2BP.

The report has been prepared in accordance with the ‘Guidelines for Landscape and Visual Impact Assessment (third edition)’ produced by The Landscape Institute with The Institute of Environmental Management and Assessment.

1.2 Description of the Proposed Development

Tolehurst Farm extends to 49.18 ha (121.4 acres) and is a free-range poultry farm with extensive areas of grassland and new farm woodland. There are currently 2 poultry rearing sheds at the north of the farm, and 7 other sheds for housing free range poultry distributed roughly in a broad arc across the southern part of the farm.

The 2 rearing sheds extend to 1302m2 will be replaced by 2 larger buildings, each 120m x 26m in size which will be located in the grassland field to the west of the sheds to be demolished. The 2 new rearing sheds will each provide 3200m2 of accommodation, and the total area occupied by the 2 buildings will be 7600m2

The development proposals are shown on the Site Plan and Block Plan attached at Appendix A.

Tolehurst Farm

1.3 Location of the Development Tolehurst Farm is accessed off Cranbrook Road (A229), at Knox Bridge, via a long farm track and is located within an area of heavily wooded farmland where visibility is limited by landform and by the woodlands and wooded field boundaries.

The location for the 2 new rearing houses is at the northern end of the farm within a grassland field bounded to the south by woodland and to the north by a thick hedge.

Tolehurst farm is within the Tunbridge Wells Borough High Weald Special Landscape Area but falls outside of the High Weald Area of Outstanding Natural Beauty.

The location of the proposed farm is shown on the Location Plan attached at Appendix B.

Tolehurst Farm

2.0 Visual Impact Assessment Methodology

2.1 Methodology

The methodology includes a Desk Study, a Field Survey, and an analysis of the Landscape.

The report has been prepared following the guidance within the ‘Guidelines for Landscape and Visual Impact Assessment (third edition)’ produced by The Landscape Institute with The Institute of Environmental Management and Assessment.

The degree of detail concerning the development and its visual impact is considered appropriate for the nature, location, and scale of the development.

The objective of the visual impact assessment is to

• Describe and evaluate the existing landscape character and landscape components likely to be affected by the development.

• Identify the visual receptors with views of the development,

• Identify and describe the potential effects of the development on landscape character, landscape components, and on the visual receptors.

• Assess the significance of the effects, and the requirement for any mitigation measures to avoid, reduce or offset the effects.

Tolehurst Farm

3.0 Desk Study

3.1 Published References

The following documents have been consulted as part of the desk study

• Aerial photographs.

• MAGIC website for landscape designations – statutory and non-statutory MAGIC is a partnership between DEFRA, English Heritage, Natural England, Environment Agency, Forestry Commission, Communities and Local Government and Marine Management Organisation

• The Landscape Assessment of Kent October 2004 prepared by Jacobs Babtie for Kent County Council

• Borough Landscape Character Area Assessment 2002 Second Edition adopted by Tunbridge Wells Borough Council October 2011.

• High Weald National Character Area 122 Natural England

• NCA 122: High Weald Key Facts and Data Natural England

3.2 Statutory and Non-Statutory Designations Tolehurst farm is within the Tunbridge Wells Borough High Weald Special Landscape Area but falls outside of the High Weald Area of Outstanding Natural Beauty.

There are no other known statutory designations relating to the landscape applying to the site or its immediate surroundings. The farm is within a Nitrate Vulnerable Zone 2017 Surface Water area, but this has no landscape implications.

Tolehurst Farm

4.0 Landscape Analysis

4.1 Key Characteristics

The landscape character of the local area is accurately described within the Borough Landscape Character Area Assessment 2002 (Second Edition adopted by Tunbridge Wells Borough Council October 2011), where the landscape has been categorised within broad landscape character types and nineteen character areas based on their natural characteristics and historical influences. Tolehurst Farm is within Local Character Area 7: Sissinghurst Wooded Farmland.

The key characteristic features of the Sissinghurst Wooded Farmland landscape as described within the Borough Landscape Character Area Assessment and considered as relevant to the application site are as follows: -

• Localised gentle undulations in the landscape, brought about by presence of streams, introducing pockets of enclosure and shelter. • High proportion of woodland cover creating a framework of large coniferous plantations, mixed natural/plantation woodland blocks, small farm woods and linear ghyll woodlands in narrow valleys. • Medium pasture and medium/large arable fields introducing variety but occasionally comprising the intimate scale of the landscape. • No significant centres of settlement creating an introverted character, except where main roads cut through or around the area.

4.2 Landscape Character The High Weald National Character Area 122 is a large scale distinct National Character Area as categorised by Natural England.

‘An introverted rustic landscape of pasture farmland, mixed woodland, orchards and hop fields enclosed within undulating hills and occasional extensive views of the Low Weald’.

Tolehurst Farm

4.3 Quality of the Existing Landscape The landscape is well wooded with an intimate, enclosed character, and has an obvious strong rural character. The local landscape includes many of the area’s characteristic features and is generally in good condition with a distinct character.

4.4 Sensitivity of the Landscape The ability of the landscape to accommodate change without a detrimental effect on its character depends upon its sensitivity.

The landscape is sensitive to change, but the chosen location for the proposed replacement poultry buildings is on an existing poultry farm, with limited visibility in the wider landscape.

The key inherent landscape sensitivities relevant to this application are: -

• High proportion of woodland cover creating a framework of woodland blocks, including small farm woods. • Localised gentle undulations introducing pockets of enclosure and shelter • Medium pasture and medium/large scale field pattern. • Strong hedgerows and woody field boundaries providing sense of enclosure and intimacy.

Tolehurst Farm

5.0 Field Survey

5.1 Extent of Visibility The field survey was conducted from off the public roads in the area, and from the neighbouring properties to establish the extent of visibility of the proposed development and to assess the character and quality of the local landscape.

Tolehurst farm is situated within an area of heavily wooded farmland where visibility is limited by landform and by the woodlands and wooded field boundaries.

There are no views from Knox Bridge or from off Cranbrook Road (A229), or any other public path or road, apart from limited views into the site from off the public footpath which runs along the northern and western boundaries of the farm.

The current rearing sheds are visible from off the access track by Tolehurst Cottage, the closest residence, which forms part of a small compact group of residences with Ian Cottages and Gordon Cottages (Appendix D Photo 1).

The proposed new rearing sheds will be located further west into the adjacent grassland field (Appendix D Photo 2).

The buildings will be occasionally visible from off the public footpath north of the site but are not visible from the residence in the centre of Tolehurst farm, due to the hedges and surrounding woodland. The view from off the public footpath at the eastern end of the site is through gaps in the hedge and woody margin (Appendix D Photo 3).

The thick boundary hedge comprises native woody shrub species which is a good visual barrier, obscuring direct views into the site for most of its length (Appendix D Photo 4).

The site is occasionally visible through gaps in the hedge (Appendix D Photo 5 and Photo 6).

Tolehurst Farm

The extent of visibility off the public footpath is reached at the western end of the site (Appendix D Photo 7).

Views off the path further south west are completely obscured by the thickly wooded hedgerow. The site is only partially visible from off the farm track further west (Appendix D Photo 8) and not visible past this point.

The extent of visibility is shown on the plan, Extent of Visibility attached at Appendix C.

Tolehurst Farm

5.2 Landscape Visual Receptors A visual receptor is someone for whom the site forms a discernible part of their view. The proposed buildings are located on a farm where the grassland used by the free- range birds is almost completely enclosed within densely wooded field margins and by mature woodland. The proposed new rearing sheds will have limited visibility and few visual receptors, apart from people working on the farm or connected with the farm. The users of the public footpath north of the site will have occasional views of the new buildings but are unlikely to be sensitive visual receptors due to the existing buildings on the farm and the passing nature of their view.

The path does not appear to be frequently used by recreational users and does not form part of a longer walking route.

Visual receptors have been divided into receptor groups according to their location.

Receptors Receptor Closest Nature of Susceptibility Value Sensitivity Numbers distance the View to the Site

Local 100’s 10 m Part of the Low Low Low Residents internal and visitors farm to the farm landscape,

Users of the 100’s 20 m Passing Low Low Medium public view footpath (walkers,)

The most sensitive visual receptors are the recreational users of the public footpath.

Tolehurst Farm

6.0 Identification and Assessment of Landscape Impact

The proposed development is considered to exhibit a neutral impact on the landscape.

Some of the most relevant inherent sensitivities of this landscape type are its strong rural character with its woodlands and hedged field boundaries. The proposed development has no implications for these landscape sensitivities and will only have a limited visibility in the wider landscape, with few visual receptors.

The development will also not result in the loss of any of the characteristic landscape features or detract from the wider rural landscape character.

The visual receptors, apart from the farm staff and their visitors, will include recreational users of the footpath north of the site who will have brief, passing views of the proposed buildings through gaps in the boundary hedgerow.

The overall importance of the effects caused by the proposals on visual amenity is neutral.

The demolition of the 2 existing rearing sheds will have a positive impact on the immediate local landscape as these buildings are closer to existing dwellings than the proposed buildings and therefore currently have a greater visual impact.

Tolehurst Farm

7.0 Significance of the Effects

The significance of the landscape effect depends largely on the scale of the effect, and the sensitivity of the location of the development.

The magnitude of the effect is limited by the siting for the proposed development, which is within an existing poultry farm, enclosed by a hedges and woodland, with few visual receptors.

The scale of the effect is also limited, as the proposed buildings are replacing existing buildings, and although the replacement buildings are larger, they are not out of scale with the other poultry buildings on the farm.

The other factors in addition to siting which limits the magnitude of the visual impact are the relatively low eaves and ridge heights of the proposed poultry buildings which will ensure that they do not project above the sky line and do not create a new focal point in the landscape. The use of suitably coloured external cladding and roofing materials will also help to minimise the visual impact.

On completion of the development, the change experienced is likely to be neutral and the overall impact of the development is likely to be neutral due to the limited visibility of the site.

No landscape mitigation is considered necessary, as the continuing management of the existing young woodland plantations, hedgerows, and hedgerow trees on farm, will ensure that these distinctive landscape features continue to provide adequate screening and strengthen the local landscape character.

Tolehurst Farm

Appendix A: Site Plan and Block Plan

Tolehurst Farm

Appendix B: Location Plan

Tolehurst Farm

Appendix C: Extent of Visibility

Tolehurst Farm

Appendix D Representative Viewpoints

5 4 6

7 3 2

8 1

Representative View Points 7

Tolehurst Farm

Appendix E: Photographs from Representative Viewpoints

Viewpoint 1 Existing rearing houses to be demolished

Viewpoint 2. Site of proposed rearing houses.

Tolehurst Farm

Viewpoint 3. From off the public footpath through a gap in the hedge.

Viewpoint 4. View into site obscured by boundary hedge along footpath.

Tolehurst Farm

Viewpoint 5. From off the footpath at the northern limit.

Viewpoint 6. Through hedge looking back to existing rearing houses

Tolehurst Farm

Viewpoint 7. Extent of visibility off footpath to west.

Viewpoint 8 Off internal farm track to west of site. Tolehurst Farm, Frittenden, Kent An Archaeological Desk Based Assessment

Hayley Roberts

CAMBRIDGE ARCHAEOLOGICAL UNIT UNIVERSITY OF CAMBRIDGE

Appendix 8

Landscape Assessment

Tolehurst Farm, Frittenden, Kent An Archaeological Desktop Assessment

Hayley Roberts Illustrations by Vicki Herring

Cambridge Archaeological Unit University of Cambridge

Site Code: TFF12 Report No. 1127 October 2012

i Summary

This Archaeological Desk Based Assessment was commissioned by Acorus on behalf of Fridays Ltd to assess the potential impact of four proposed poultry buildings at Tolehurst Farm, Frittenham, Kent. There is little archaeological potential within the study area apart from a potentially well preserved Roman Road, but even this may not be directly impacted upon by the proposed development.

ii

Contents

1. Introduction 1 2. Methodology 2 3. Baseline Conditions 3 Layout of Study Date 3 Geology and Topography 3 Past and Current Land use 3 The Archaeological Assessment 3 Sources 4 Known and Potential Archaeology 4 4. Aerial Photographic and Cartographic 6 Evidence 5. Discussion 7 6. Conclusion 8 7. References 9 8. Illustrations 10 9. Appendices 12 Planning Policy 12 Site and Finds Gazetteer 16

Tables and Figures

Table 4.1 List of aerial photographs and historic maps 6

Figure 1 Location and Gazetteer map 10 Figure 2 Illustrations showing date of lake formation 11

iii 1. Introduction

1.1 The archaeological desk based assessment was commissioned by Acorus, on behalf of Fridays Ltd, to assess the potential impact of four proposed poultry buildings at Tolehurst Farm, Frittenden Kent (Figure 1 a ,b & c). Two of the buildings are located close together and considered one PDA (a). This assessment considers a study area centred on grid reference TQ 787 401, with a radius of 1km (which includes the Proposed Development Areas; PDA). The study area is located within the Parish of Frittenden, although close to the boundary with the parishes of Staplehurst and Cranbrook and within the Low Weald National Character Area and the former Low Weald SLA. It is within local character area 12: Frittenden Lowland Pasture.

1.2 The principle aim of this document is to establish the presence/absence and potential condition of any archaeological remains and assess the impact upon them as a result of the proposed development area (PDA).

1.3 Archaeology is covered by both local and national policy. The relevant sections from both are reproduced in Appendix 1. Nationally the relevant primary policies are the National Planning Policy Framework (NPPF March 2012) and legacy planning provisions valid until March 2013. The aim of the NPPF is that action required as part of the planning process is appropriate and proportionate. The South East Research Framework is still under construction, although in the research agenda phase. The research agenda will enable the creation of a research strategy for investigation and interpretation of the historic environment of the South East. Notes from public seminars held as part of the consultation have been published online and it is these that have been used to inform this document.

1

2. Methodology

2.1 This assessment has been written using the guidelines provided by the Institute for Archaeologists (IfA) Standard and Guidance for Archaeological Desk- based Assessment 2001. The Cambridge Archaeological Unit is a Registered Archaeological Organisation of the IfA.

2.2 The Archaeological Baseline has been established through a Desk Top Assessment.

2.3 The methodology comprises assessment of the known or potential archaeological resource within the study area in order to characterise the likely type, extent, quality and worth of the resource within a local, regional, national or international context as appropriate. The assessment is based on existing sources of data from the Kent Historic Environment Record (KHER), including aerial photographs, historic and modern maps. Published and unpublished archaeological reports, the National Archives and the Victoria County History were also consulted.

3. Baseline Conditions Layout of study data

3.1 The archaeological desk based assessment was commissioned by Acorus, on behalf of Fridays Ltd, to assess the potential impact of four proposed poultry buildings at Tolehurst Farm, Kent. Two of the buildings are located close together and considered one PDA (a). A study area, encompassing these proposed buildings has been created, centred on grid reference TQ 787 401, and with a radius of 1km (figure 1).

3.2 The study area is located within the Hundred of Cranbooke and the modern parish of Frittenden although close to the boundary with Staplehurst and Cranbrook parishes. It is located within agricultural land.

Geology and Topography

3.3 The underlying geology is Weald Clay Formation, a mud stone, with localised superficial deposits of river terrace gravels (BGS GeoIndex accessed 9th October 2012). The area is described as ‘a flat to gently undulating small-scale, lowland clay vale landscape, visually contained and enclosed by the wooded ridge of the High Weald to the south and the Greensand ridge forming a prominent feature to the north’ (TWBLCAA 2002). The height of the study area is 38m OD.

Past and Current Land Use

3.4 The study area is characterised as Frittenden lowland pasture within Low Weald farmland. A landscape of permanent pasture, with some larger arable fields, the area is studded with numerous small fields, ponds and water-filled

2 ditches set within a framework of mature remnant hedgerow trees and derelict hedgerows (TWBLCAA 2002).

3.5 In the centre of the area stands a small lake (Figure 1; D) surrounded by agricultural fields as well as small areas of potentially ancient woodland. Tolehurst Farm and associated buildings (including oast houses) are located to the east of the lake. In the late 19th century an orchard was planted, extending across several fields to the south and east of the farm buildings, but since the 1970s the land has been returned to agriculture and is currently used as an active poultry farm. The A229 runs north-south bypassing Tolehurst Farm.

The Archaeological Assessment

3.6 The objective of the study is to collate and assess existing information relating to the archaeology and history of the study area and relevant sites of interest from the wider landscape environs. This data will be used to assess both PDAs for archaeological potential and determine the likely survival of any such remains.

3.7 Within the three PDAs there is no known archaeological evidence. Within the study area the known archaeology is limited to three periods, Romano-British, Medieval and post-Medieval. A total of nine archaeological sites, listed buildings and finds spots are known within the study area. These are listed in the Gazetteer, Figure 1.

Sources

3.8 Principle sources consulted for this study were:

• Kent Historic Environment Record • Heritage Gateway • Portable Antiquities Scheme online resource • British Geological Survey online geology maps • Historic OS map series from 1873- present

Known and Potential Archaeology in the study area

Early Prehistoric

3.9 Although no evidence for activity from early prehistory has been found within the study area it should still be considered to have potential. As part of the ongoing consultations for the Regional Framework it has been suggested that the Weald is ‘an area that needs considerably more focussed study and understanding’ for this period, although the methodologies for this need to be considered carefully (Garwood 2007).

3 Late Prehistoric and Romano British

3.10 In both the Later Prehistoric and Romano-British periods settlement in the Weald was comparatively rare, even taking into consideration the gap in evidence created by the unsuitable conditions for crop marks, as well as the lack of developer funded excavations. In later prehistory the Weald was known for its iron working, and this continued into the Roman period (Cunliffe 2005: 176; Taylor 2007: 50-51).

3.11 The Roman road (identified as Margray 13) is well documented and linked the Roman centres of Rochester, Maidstone and Hastings with the iron mining areas of the Weald (Detsicas 1987: 37). The line of this road passes through the study area, although its projection does not pass directly through the PDAs (1). In 2001 a section of this road was excavated to the south of the study area, near the boundary between Sandhurst and Bodiam, where a substantial metalled iron slag surface was exposed, with earlier drainage ditches beneath. This programme of works also found a large scattering of iron slag in the area adjacent to the road and suggests high potential for the preservation of the road and associated activity (KHER ref. MKE75620). The only other Romano-British discovery was a possible copper alloy toggle. KHER No MKE75620, probably a casual loss (2).

Medieval

3.12 About 500m north of PDA ‘A’ is Scheduled Ancient Monument 1013147; Castle Bank (3). Although previously interpreted as a Norman motte this has now been identified as a well preserved moot mound and surrounding ditch and is of high archaeological significance, ‘Moots were open-air meeting places set aside for use by courts and other bodies who were responsible for the administration and organisation of the countryside in Anglo-Saxon and medieval England’ (KHER ref: TQ 74 SE 1).

3.13 The Priory of Mottenden and the Priory of Leeds both owned land in the Parish of Frittenden, although the exact locations and use of the land are currently unknown, although it is presumed they were agricultural (Page 1926).

Post-Medieval to present day

3.14 Within the study area are several listed buildings. Tolehurst Farmhouse (4) is the most relevant to this assessment. This is a timber framed house with an earliest known construction date in the 17th century. The farmyard associated with it contains old oast houses as well as several other buildings. Saunders Farmhouse (5), 3 Paley Lane (6) and Rock Farm House (7) are also listed buildings of this date within the study area. As these are unaffected by the proposal these are not considered further.

4 Undated

3.15 Two undated find spots are recorded within the study area, a copper alloy mould (8) and a copper alloy pin (9). Although undated these finds spots hint at potential metal working in the local area.

5 4. Aerial Photographic and Cartographic Evidence

4.1 Three aerial photographs are available for viewing through the KHER. These were taken in 1946, 1961 and 1990 and none show any crop marks; however, these and the early edition OS maps do illustrate changing land use within the study area.

Date Description 1873 1st Ed OS County Series 1:10560 Grid Tile TQ73 & 74 1898 1st Review County Series1:1250 Grid Tile TQ73 & 74 1898 1st Review 1:10560 Grid Tile TQ73 & 74 1908 2nd Revision County Series 1:2500 Grid Tile TQ73 & 74 1909 2nd Revision County Series 1:10560 Grid Tile TQ73 & 74 1938 3rd Revision County Series 1:2500 Grid Tile TQ73 & 74 1938 3rd Revision County Series 1:10560 Grid Tile TQ73 & 74 1946 Black and White Aerial Photo. KHER r47 No. 3209 1961 National Grid 1:10560 Grid Tile TQ73 & 74 1961 Black and white Aerial photo KHER r25 No. 7193 1970 National Grid 1:2500 Grid Tile TQ73 & 74 1972 National Grid 1:10000 Grid TileTQ73 & 74 1984 National Grid 10000 Grid Tile TQ74 1990 Colour Aerial Photo KHER 200? 1:25000 Scale Explorer 2011

4.2 The 1st to 4th editions of the OS maps and the aerial photos indicate that since at least the late 19th century the land within the study area has been predominantly used for agricultural. Towards the centre of the study area Tolehurst Wood has been wooded with small ponds since at least 1873. The origin of these ponds could be localised clay extraction or natural formation. The lake that now dominates the farm is not recorded as a large feature until 1970 (D, Figure 2). This is most likely to have been created by quarrying clay, possibly for brick making, but there is also a small, albeit speculative, possibility it may have been related to metalworking in the area.

4.3 On the modern map two buildings are named Great Water Barn and Great Water House (E). Great Water Barn is a modern building, built after the 1990 aerial photograph was taken, but Great Water House has an earlier history; it appears to be marked on the 1st and 2nd edition OS maps as several plots. The reason and date of naming is unknown, but is likely to be relatively modern and relate to the modern lake or the smaller ponds closer to the farmyard. The presence of small ponds is not unexpected within this landscape; they contribute to the character of the Frittenden Lowland Pasture (TWBLCAA 2002). It has been suggested that many of them may relate to 14th-15th century iron ore extraction or, as already mentioned, clay extraction.

4.4 The southwestern PDA (B) appears to cross a parish boundary. These boundaries can be important historically, although are usually unmarked. Therefore the proposed building should not impact upon anything of archaeological significance related to the boundary.

4.5 A Voluntary Firing Range (F) is marked on all the historic maps in the southern part of the study area. It is presumed that the targets were located at

6 the southwestern end (marked ‘Butts’ on the OS maps). By the 1960s the range is no longer visible on the maps or photographs other than where it has been incorporated into a field boundary.

4.6 Aerial photographs and maps are useful tools when trying to understand landscapes; however, as with all forms of evidence, these have limitations. Old edition OS maps, although accurate may not be precise in relation to modern maps. The majority of aerial photographs were originally taken as reconnaissance photos and, although they can be an extremely useful resource, often the conditions were not suitable to enable visible archaeological crop marks. This is especially relevant when the underlying geology is clay or fields were free of crops (Palmer & Cox 1993).

5. Discussion

5.1 This document illustrates that there is no recorded archaeology within the designated PDAs and that within the study area archaeological activity is limited to the scheduled monument and Roman Road and the occasional finds spot. This is also reflected within the immediate surrounding landscape where the only discoveries of note are the Iron Age smelting site at Knoxbridge Farm, Staplehurst (Network Archaeology 2001) and two Roman urns discovered in 1858 within a ritual shaft at Leggs Wood, about 1km east of the study area (HER No TQ 84 SW 3).

5.2 Although this apparent scarcity of archaeology may have been caused partly by the lack of development within the Weald, the area is thought to have been a focus for industry and metalworking, rather than settlement during the Late Prehistoric and the Roman periods. The archaeological character of the area and lack of finds spots makes it unlikely that major archaeology will be found within the PDA, although the possibility of metal working sites, especially related to or close the Roman road, cannot be entirely ruled out.

5.3 Although the Roman road appears not to pass directly through the PDAs, if the predicted alignment is inaccurate or the remains of any roadside settlements or activities exist then both the northern and southeastern PDAs (A & C) have potential to contain limited but well preserved archaeology. The impact on the potential archaeology will depend upon the proposed construction methods and exact location of the road. The southwestern development area (b) is the furthest away from the route of the roman road and is therefore the least likely to contain archaeological remains.

5.4 During the Medieval period, although it is almost certain that people were living and working within the study area, they were probably ‘influencing the landscape in ways more subtle than in the more heavily farmed central England belt’ (Flatman 2007). The field boundaries and character of the study area may well have been formed during the Medieval period, but this will not leave a significant (or even possibly detectable) archaeological footprint.

7 5.5 Castle Bank Moot is the exception to this (3). The location of Castle Bank close to the modern parish boundaries of Frittenden, Staplehurst and Cranbrook (which formed the Hundred of Cranbrooke and over which the moot had jurisdiction) is significant. Although decisions made at these places may have had implications for people living and working within the study area it is unlikely that a significant archaeological ‘presence’ will have spread beyond the ditch and bank. There is a small possibility, however, that there may be associated ‘spot finds’, artefacts dropped by people travelling to and from the Moot.

5.6 The earliest standing buildings within the study area date from the post- Medieval period and these will not be affected by the proposed development. It is from this point on that the landscape is recorded as gradually being altered with the planting of orchards, and in the very modern period the probable quarrying and creation of the lake (D).

5.7 At Tolehurst Farm itself, there is little evidence to indicate that any potential archaeological remains will have been damaged by later activity, other than by agriculture or the planting of orchards. In the 1998 Heritage at Risk Survey Darvill identified arable cultivation as the greatest threat to archaeological remains and historic landscape features; however, the historic land-use of the area has been characterised as pasture (TWBLCAA 2002). Bioturbation caused by either plants or animals is also always a serious risk to archaeological sites and as such may have significantly damage or totally destroyed any evidence of past activity.

6. Conclusion

6.1 This document illustrates that there is no recorded archaeology within the designated PDAs and that within the study area archaeological activity is limited to the scheduled to Castle Bank Moot, the Roman Road and the occasional finds spot. The majority of the dominating features within the landscape are post-Medieval and modern, and whilst this does not detract from their local importance, tracing their history is more secure. There is a small possibility that the proposed poultry sheds may impact upon the Roman road if the predicted alignment is inaccurate or the remains of any roadside settlements or activities exist, depending on the proposed construction methods of the poultry sheds.

8 7. References

Alridge, N. 2009. Letter from Neil Aldridge with details of sites from the Bulletin of the Wealden Iron Research Group. Kent Historic Environment Record. No. TQ 74 SE 36. Unpublished document

TWBLCAA. 2002. Tunbridge Wells Borough Landscape Character Area Assessment nd 2002. 2 Edition. www2.tunbridgewells.gov.uk/ accessed 5/10/2012

Detsicas, A. 1987. Peoples of Roman Britain: The Cantiaci. Great Britain: Alan Sutton

Darvil, T. 1998. Heritage at Risk Survey. Great Britain: English Heritage

Garwood, P. 2007. Discussion notes The South-East Research Framework Public Seminar on the Neolithic to early Bronze Age (08/12/07) Kent County Council www.kent.gov.uk/leisure_and_culture/heritage/south_east_research_framework.aspx accessed 08/10/2012

Flatman (2007). Some thoughts on the medieval south east. Notes on the South-East Research Framework public seminar on the medieval period (03/11/07) Kent County Council.1

Margary, I.D. 1956. Roman Roads in Britain. London: Phoenix House Ltd.

Network Archaeology Ltd. 2001. Hadlow to High Halden Natural Gas Pipeline. Archaeological watching brief. Unpublished document HER No. TQ 74 SE 104

Palmer, R & Cox, C. 1993. Uses of aerial photography in archaeological evaluations. Great Britain: Institute for Archaeologists

Page, W. 1926. The Victoria History of the County of Kent Vol. II. http://www.british-history.ac.uk/report.aspx?compid=38227&strquery=frittenden Date accessed: 09 October 2012.

Roberts, B. & Wrathmell, S. 1994. The Monuments Protection Programme: Medieval Settlements Project. Medieval Settlement Research Group: annual report no 1 (1986)

Taylor, J. 2007. An Atlas of Roman Rural Settlement in England. CBA Research Report 151. York: Council for British Archaeology:

1 Accessed October 2012: www.kent.gov.uk/leisure_and_culture/heritage/south_east_research_framework.aspx accessed 08/10/2012 accessed 8/10/2012

9 8. Illustrations

LONDON Southend-on-Sea

Margate

Croydon Ramsgate

578000 Maidstone Reigate Kent Royal Tolehurst Farm Ashford Tunbridge Dover Crawley Wells Folkestone Cranbrook Horsham

Lovehurst Manor Worthing Hastings Brighton Eastbourne 0 50 km

141000 141000

1

3 Roman Road A

Paley Lane, Farmstead 7

D 6 E 4 140000 140000

B C

Firing Range (disused)

Study Area 2 8 5 9 Hartridge House

139000 139000

2 Gazetteer point A Northern PDA B Southwestern PDA 0 1 C Southeastern PDA kilometres D Tolehurst wood and lake 578000 579000 E Location of Great Water Barn and House

Figure 1. Location of the Proposed Development Areas (PDA) and Gazetteer points A

D

B C

A

D

B C

Figure 2. Aerial photo from 1961 (top) and 1970 Ordnance Survey map (below). 9. Appendices

Appendix 1. Planning Policy

National Legislation and Policy

National Planning Policy Framework, March 2012

The heritage section of the NPPF incorporates, and streamlines, the existing policies contained in PPS5. It does not alter those policies or create new ones. One policy - HE5 (Monitoring Indicators) - from PPS5 has not been incorporated as a specific policy within the Framework. All other PPS5 policies have been condensed and are included within the heritage section or incorporated elsewhere within the NPPF. Transitional arrangements are provided within the NPPF to ensure that existing plans and submissions are not unduly delayed and reflect previous planning policy and guidelines, even where earlier guidance comes into potential conflict with the NPPF (Appendix 1).

While the NPPF is to be read as a whole in the context of archaeology the NPPF states at Section 17 that the Government’s objective is ’to conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations’. To achieve this paragraph 126 states:

Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account:

● the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; ● the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; ● the desirability of new development making a positive contribution to local character and distinctiveness; and ● opportunities to draw on the contribution.

Paragraph 128 states that in determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where an application site includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.

12

In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the presumption in favour of sustainable development, the scale of any harm or loss and the significance of the heritage asset.

Paragraph 141 notes states that Local planning authorities should make information about the significance of the historic environment gathered as part of plan-making or development management publicly accessible. They should also require developers to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence (and any archive generated) publicly accessible17. However, the ability to record, evidence of our past should not be a factor in deciding whether such loss should be permitted”.

Regional Policy

The South East Research Framework is still under construction although in the research agenda phase which has included the South East Research Framework Research Agenda Conference. Notes from public seminars have been published online and it is these that have been used to inform this document. They may viewed at: http://www.kent.gov.uk/leisure_and_culture/heritage/south_east_research_framework /serf_seminar_notes_docs.aspx.

Local Policy

Tunbridge Wells Borough Local Plan (March 2006)

A number of saved policies have been retained from the above document that relate to the historic environment and are reproduced below:

OTHER SITES OF ARCHAEOLOGICAL INTEREST

4.80 These areas are based on the Kent County Council Sites and Monument Record (SMR), a proportion of which have been identified as having archaeological potential and are marked on the Borough Council constraints map.

4.81 In considering planning applications which may affect an archaeological site, prospective developers should consult the Local Planning Authority and the County Archaeologist at an early stage, ideally prior to submitting a formal planning application, in order to establish the possible archaeological implications of any proposals. Within areas of potential archaeological importance developers will need to demonstrate, prior to the determination of the application, that the archaeological implications of the development have been properly assessed. An appropriately detailed written archaeological assessment may be required as part of the documentation to complete a planning application and an archaeological evaluation may be requested to a specification and standard approved by the Local

13 Planning Authority. Planning permission may be refused without adequate assessment of the archaeological implications.

4.82 The Local Planning Authority will generally seek to avoid development on archaeological sites, whether of national, regional or local importance, so as to preserve sites in situ. Where development is acceptable the Local Planning Authority will endeavour to mitigate damage to archaeological remains by seeking sympathetic foundation design and careful location of open space. Where preservation of archaeological remains in situ is not appropriate and development is permitted, an appropriate level of archaeological investigation will be required in advance of, or during, development so as to ensure „preservation by record. This may be ensured through planning agreements or the use of conditions.

4.83 Wherever practicable, the Borough Council will encourage the enhancement of sites of archaeological interest and their settings and in judging the enhancement value of proposals the Council will pay particular regard to the likely benefits to education, leisure and tourism.

POLICY EN10

Proposals for development affecting sites of archaeological interest, other than those covered by POLICY EN9, will be determined having regard to the desirability of preserving archaeological remains and the setting of visible remains and according to all of the following criteria:

1 The intrinsic archaeological and historical value of the remains; 2 The design, layout and opportunities to minimise damage to remains and their setting, preferably through preservation in their original location; 3 The need for the development; 4 The availability of suitable alternative sites; and 5 The potential benefits of the proposals, particularly to education, recreation or tourism.

Where permission is to be granted for development resulting in the damage or destruction of archaeological remains and the developer has not entered into a planning agreement, or made equivalent arrangements, for the excavation and recording of the remains and the publication of the results, conditions will be attached to the permission to ensure that no development takes place until this work has been carried out.

Tunbridge Wells Borough Local Development Framework (June 2010)

Core Policy 4

The Borough’s built and natural environments are rich in heritage assets, landscape value and biodiversity, which combine to create a unique and distinctive local character much prized by residents and visitors alike. This locally distinctive sense of place and character will be conserved and enhanced as follows:

14

1. The Borough’s urban and rural landscapes, including the designated High Weald Area of Outstanding Natural Beauty, will be conserved and enhanced 2. The Borough Landscape Character Assessment 2002 will be utilised to manage, conserve and enhance the landscape as a whole 3. A hierarchical approach to nature conservation and the protection of biodiversity and geodivisity will be applied across the sites of national, regional and local importance within the Borough. The objective will be to avoid the net loss of biodiversity and geodiversity across the Borough as a whole 4. Opportunities and locations for biodiversity enhancements will be identified and pursued by the creation, protection, enhancement, extension and management of green corridors and through the development of green infrastructure networks in urban and rural areas to improve connectivity between habitats 5. The Borough’s heritage assets, including Listed Buildings, Conservation Areas, Scheduled Ancient Monuments, archaeological sites and Historic Parks and Gardens will be conserved and enhanced and special regard will be had to their setting 6. The positive management of heritage assets through partnership approaches and measures will be encourage, including by the use of Conservation Area Management Plans

Local Heritage Assets – Supplementary Planning Document (Adopted June 2012)

This documents sets out and specifies the Borough’s position on Local Heritage Assets, designation and inclusion of archaeological sites and buildings that are not scheduled or listed, but are considered to be of sufficient merit for designation as important local heritage assets. The reader is referred to the document for the full text with only selected text reproduced below.

Planning Policy Context

12 The compilation of a list of locally significant heritage assets is supported and encouraged by English Heritage and by guidance policies at both a national and local government scale.

Local Guidance: The adopted Tunbridge Wells Borough Core Strategy Development Plan Document (June 2010), at Core Policy 4, already recognises the importance of heritage assets. Additionally, as new information becomes available, it may be necessary to identify and designate additional features of merit. This SPD provides guidance on how to implement Core Strategy policy in respect of unlisted heritage assets.

Tunbridge Wells Borough has some of the highest numbers of heritage assets in the South East, including listed buildings, conservation areas and historic parks and gardens. Together with local heritage assets, they provide a resource that contributes to creating a sense of place, which should be passed on to future generations. Conservation and enhancement of heritage assets, of which

15 statutorily designated sites are a small fraction of the overall heritage resource, will therefore be central to the Borough Council’s approach to the environment.

16 Appendix 2. Site and Finds Gazetteer

Gaz Grid Period Description KHER No. reference number 1 Centroid TQ Roman Line of Roman Road TQ 74 SE 36 7836 4023 Refs. Unpublished document: Neil Aldridge. 2009. Letter from Neil Aldridge with details of sites (MBR: 7565m from the Bulletin. of the Wealden Iron Research Group. (3) Unpublished document: Neil by 55884m Aldridge. 2005. Archaeological Notes from the Weald. (4) Unpublished document: Staveley, D.. 2010. A Geophysical Survey of the Roman Road between Bodiam and Sandhurst Cross, 2010. 2 TQ 78900 Roman Find Spot- copper toggle MKE75620 39400 3 TQ 7842 4067 Medieval Castle Bank Moot mound and surrounding ditch. TQ 74 SE 1 Refs. (1) Unpublished document: OS Card / NAR index entry. OS 6" 1961. (2) Unpublished document: OS Card / NAR index entry. VCH Kent 1 (1908) 408 (Illust) I C Gould. (3) Unpublished document: OS Card / NAR index entry. Arch Cant 13 (1880) 492-3 (? C Roach Smith). (4) Unpublished document: OS Card / NAR index entry. MOW List of Anc Mon in Eng & Wales 1958 46 ANG 8.9.61 (5) Unpublished document: OS Card / NAR index entry. F1 ASP 01-DEC-61. (6) Unpublished document: OS Card / NAR index entry. F2 GA 06-FEB-64. Unpublished document: OS Card / NAR index entry. Moated Site Research Group 6 1979 (ed C J Bond) 47. (7). (8) Unpublished document: OS Card / NAR index entry. Arch Cant 93 1977 222 (T Tatton-Brown). (9) Unpublished document: OS Card / NAR index entry. DOE (IAM) AMs Eng 2 1978 112. (10) Bibliographic reference: Field report for monument TQ 74 SE 1 - December, 1961. (11) Bibliographic reference: Field report for monument TQ 74 SE 1 - February, 1964. (10)Unpublished document: OS Card / NAR index entry. English Heritage Schedule copy MPP AA 51053/1 30 JUL-1991 4 TQ 7874 4007 Post Med Listed building. Tolehurst Farm House. TQ 74 SE 226 5 TQ 7898 3923 Late C16th/ post Listed Building. Saunders Farm House. TQ 73 NE 113 medieval 6 TQ 7776 4004 C17th/post Listed Building. 3 Paley Lane. TQ 74 SE 224 medieval 7 TQ 7913 4028 C1700/post Listed Building. Rock Farm House TQ 74 SE 228 medieval

17 8 TQ 78950 Undated Find Spot. Copper Alloy Mould MKE74585 39330 9 TQ 79080 Undated Find Spot. Copper Alloy Pin MKE74586 39220

18 OASIS FORM - Print view

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OASIS ID: cambridg3-135310

Project details Project name Tolehurst Farm, Frittenden, Kent. A Desktop assessment Short description of the project This Archaeological Desk Based Assessment was commissioned by Acorus on behalf of Fridays Ltd to assess the potential impact of three proposed poultry buildings at Tolehurst Farm, Frittenham, Kent. There is little archaeological potential within the study area apart from a potentially well preserved Roman Road, but even this may not be directly impacted upon by the proposed development. Project dates Start: 09-10-2012 End: 09-10-2012 Previous/future work No / Not known Any associated project reference TFF12 - Sitecode codes Type of project Desk based assessment Site status None Current Land use Cultivated Land 1 - Minimal cultivation Monument type ROAD Roman Significant Finds COPPER SPOT FINDS Roman Methods & techniques ''Aerial Photography - interpretation'',''Documentary Search'' Development type Farm infrastructure (e.g. barns, grain stores, equipment stores, etc.) Prompt Planning condition

Project location Country England Site location KENT TUNBRIDGE WELLS FRITTENDEN Tolehurst Farm, Frittenden, Kent Postcode TN17 2DA Study area 1.00 Kilometres Site coordinates TQ 787 401 51 0 51 07 54 N 000 33 15 E Point

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Height OD / Depth Min: 38.00m Max: 38.00m

Project creators Name of Organisation Cambridge Archaeological Unit Project brief originator Consultant Project design originator Emma Beadsmoore Project director/manager Emma Beadsmoore Project supervisor Grahame Appleby Type of sponsor/funding body Developer Name of sponsor/funding body Acorus, on behalf of Fridays Ltd

Project archives Physical Archive Exists? No Digital Archive recipient Cambridge Archaeological Unit Digital Archive ID TFF12 Digital Contents ''none'' Digital Media available ''Images raster / digital photography'',''Text'' Paper Archive Exists? No

Project bibliography 1 Grey literature (unpublished document/manuscript) Publication type Title Tolhurst Farm, Frittenden, Kent. An archaeological Desktop Assessment Author(s)/Editor(s) Roberts, H. Other bibliographic details Report No 1227 Date 2012 Issuer or publisher CAU Place of issue or publication Cambridge Description Thin wire bound document

Entered by Hayley Roberts ([email protected]) Entered on 9 October 2012

OASIS:

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