Guestling Green Wastewater Treatment Works - Installation of 1No

Guestling Green Wastewater Treatment Works - Installation of 1No. Ferric Dosing Kiosk

Planning Statement

Planning Portal Reference: PP-06377948

September 2017 Guestling Green Wastewater Treatment Works - Installation of 1No. Ferric Dosing Kiosk

Planning Statement

Planning Portal Reference: PP-06377948

September 2017

Issue and Revision Record

Revision Date Originator Approver A September Luke Mosson Les Kelly 2017 MRTPI 1 INTRODUCTION This document is in support of a Planning Application relating to the proposed erection of 1No. Ferric Dosing Plant Kiosk at the existing Guestling Green Wastewater Treatment Works (WTW), Church Lane, Guestling Green, East Sussex, TN35 4HT.

This scheme forms part of Southern Waters’ Asset Management Plan 6 (AMP 6) Programme. This is a major programme of refurbishment and upgrading of various existing wastewater treatment works and associated sewer infrastructure required by the water industry regulator OFWAT (Office of Water Services), and the Environment Agency, to be put in place between 2015 and 2020. Each of the schemes must be completed by dates specified by the Environment Agency and OFWAT.

2 SCHEME DRIVER Southern Water is to carry out development works at Guestling Green WTW. The development is required to prepare the works to comply with the new Water Framework Directive (WFD) for tighter determinants for Ammonia (5mg/l UT) and Phosphorus (0.5mg/l) to meet the regulatory output dates are in March 2018 and March 2020 respectively.

Guestling Green WTW is a conventional filter works in Sussex serving a population equivalent of 1,082.

As a sewerage undertaker, Southern Water is obliged to provide the appropriate facilities for the treatment of wastewater to the required standard by the Water Resources Act 1991 and the Urban Wastewater Treatment Regulations 1994.

3 CHARACTERISTICS OF THE DEVELOPMENT

3.1 Site Location The proposed development is located within the operational site at Guestling Green Wastewater Treatment Works (WTW), Church Lane, Guestling Green, East Sussex, TN35 4HT.

Guestling Green WTW is located in a rural location approximately 0.6km north east of the Guestling Green itself.

The site is accessed from Church Lane via a single track road owned by Southern Water (SWS). The context of the site can seen below in Figure 1.

Figure 1: Map showing the context of the site [Extract from GoogleMaps].

The majority of the site consists of short mown grassland, scrubland, concrete structures including inlet works, dosing plant, primary settlement, trickling filters,

humus tanks, clarifiyer tanks, sand filters, sludge beds and associated control buildings and areas of hard standing.

The nearest properties to the site are located on Church Lane to the south west of the site, some 200m away.

The site is surrounded by a mixture of agricultural land and woodland. A mature tree line and dense woodland lies to the north, east and south of the site, this area being classified as ancient woodland. A further band of hedgerow and trees lines the western boundary and provides screening of the site from Church Lane, beyond this lies agricultural land.

The proposed development will be located entirely within the confines of the existing operational site.

The site falls within the local authority area of Rother District Council. In planning terms the site falls outside of any settlement boundary and within the countryside.

3.2 Existing WTW development The existing WTW serves Guestling Green and surrounding area, serving a population of approximately 1,082.

The wider WTW has an area of approximately 0.45ha and currently includes the following operational infrastructure:

· inlet works · dosing plant · primary settlement · trickling filters · humus tanks · clarifiyer tanks · sand filters · sludge beds · control buildings

3.3 Extent of Proposed Development The works proposed will allow for necessary upgrades to be made to the existing works to ensure that the site can continue to operate effectively and meet the regulatory outputs required to ensure compliance with levels of Phosphorus and Ammonia.

The following works are proposed (shown on drawing JN.639170.0Z0703): 1. Install new dosing kiosk 2. Installation of interceptor chamber 3. Installation of 2No. flow control chambers 4. Installation of air scour blower 5. Installation of lamella 6. Installation of MCC kiosk 7. Installation of emergency shower and eye bath

A temporary compound area will be created during the construction period, this will allow for the appropriate storage of materials and parking of vehicles during the construction phase. This will constructed on an existing area of hardstanding. The area will be returned to its existing condition upon completion of temporary construction activities.

3.4 Requirement for EIA Screening It is considered that the proposed works do not constitute schedule 1 development.

The proposed development area of the development falls below the size threshold of 1000m2 where in accordance with Paragraph 11 (c) of Schedule 2 of the Town and Country Planning (Environmental Impact Assessment (EIA) Regulations (2011).

A preliminary assessment has been conducted by a qualified ecologist, which has not highlighted any significant issues. They have provided a range of basic advice to be followed during construction.

An assessment of the construction phase in terms of vehicle movements has also been undertaken, which concluded that the number of movements are relatively low and only temporary in nature and will be effectively managed.

It is not considered that either of these aspects will have any significant temporary or permanent environmental impacts on the site or surrounding area.

The proposed kiosk has been positioned, as far as technically possible, adjacent to existing structures and in a position which is well screened from wider view. This will assist in reducing the visual impact on the views into the site, which are considered to be limited.

The proposed development is not considered to have any significant effects on the environment by virtue of the proposals size, very limited increase in built form and given its nature, location and the existing use of the land. Due to the relatively minor nature of the works within a large operational wastewater treatment works, it is assessed that the proposed development would not be classed as EIA development.

3.5 Planning Requirement Table 1 lists the proposed new structures and development and provides details of their external material and finish.

The development of the dosing kiosk will require planning permission as an above ground structure, which can be interpreted as buildings and being over 29 cubic meters in volume. As the other parts of the permanent development are on operational land and fall within the necessary parameters, they benefit from Southern Water’s Permitted Development rights as a Statutory Undertaker and do not therefore require planning permission.

The kiosk will be constructed in Glass Reinforced Plastic (GRP) coloured dark green to BS 4800 ref. 14C39.

3.6 Permitted Development It is assessed that the rest of the works required constitute Permitted Development under the Town and Country Planning (General Permitted Development) (England) Order 2015 (GPDO).

The following works fall under the GPDO: 1. Installation of interceptor chamber 2. Installation of 2No. flow control chambers 3. Installation of air scour blower 4. Installation of lamella 5. Installation of MCC kiosk 6. Installation of emergency shower and eye bath 7. Formation of hardstanding

A temporary contractor’s compound is required for the duration of the construction period and will consist of site cabins, material storage areas and welfare and storage facilities. The compound will cover an area of approximately 570m2 and will be set up on an area of agricultural land adjoining the site.

It is considered that the compound is Permitted Development under Class A of Part 4 (Temporary Buildings and Uses) of Schedule 2 of the Town and Country Planning GPDO (2015) which states that:

“The provision on land of buildings, moveable structures, works, plant or machinery required temporarily in connection with and for the duration of operations being or to be carried out on, in, under or over that land or on land adjoining that land.”

All other works will fall under Part 13 Water and Sewerage Class B development by or on behalf of sewerage undertakers, paragraph f of Schedule 2 of the GDPO which states:

“any other development in, on, over or under their operational land, other than the provision of a building but including the extension or alteration of a building.”

Table 1: Proposed items for the Guestling Green WTW development

Height (m) Foundation Planning (Above Item Item of Width Length Depth Description Requirement Local Material Finish No. Development (m) (m) (approx) Ground (m) Level) Dosing Kiosk to provide Glass Holly Planning storage, electrical control Reinforced Green 1 Dosing Kiosk Permission 3 3.7 7.1 1 equipment and dosing Plastic 14C39 to Required equipment. (GRP) BS4800 Interceptor Surface water / chemical Permitted 2 0.2 3 3 Concrete Unfinished 1 Chamber capture from delivery area. Development Metal Exposed Shower and Emergency shower and eye Permitted structure metal. 3 3.5 1 1 0.5 eye bath bath Development with GRP Various surround GRP. Glass Holly Electric control equipment Permitted Reinforced Green 4 MCC Kiosk 2.5 2 1 1 for Development Plastic 14C39 to (GRP) BS4800 Stainless Permitted Steel Tanks 5 Lamella Phosphorus removal 5.5 7 8 Unfinished 1 Development with GRP flooring Flow Control Permitted 6 Control for recirculation flow 0.2 2 3 Concrete Unfinished 1.5 Chambers Development Glass Holly Air mixing at chemical Permitted Reinforced Green 7 Air Blowers 1 1 2 1 dosing Development Plastic 14C39 to (GRP) BS4800 The compound will consist of Temporary cabins for contractor’s Permitted The compound area will take up an area of approximately 570m2 within the WTW 8 Contractors welfare facilities, storage Development boundary located to the north of the proposed development. Compound cabins and parking / material storage areas.

8 3.7 Construction Programme Construction activities will be limited to between 07:00 to 18:00, Mondays to Fridays and 07:00 to 13:00 on Saturdays. There will be no work on Sunday or bank holidays.

In the event that longer working hours are necessary it would be appreciated if the grant of planning permission would allow a variation in working times with the agreement in writing of the Planning Authority.

The scheme will be completed in stages as shown in Table 2.

Time Project Task Programmed Commencement of site mobilisation: Setting up site compounds June 2018 (Two and storage areas and topsoil stripping. weeks) Commencement of construction phase - to include new June 2018 excavation and construction of new structures

Completion of commissioning of new works May 2019 Completion of site demobilisation and reinstatement of May 2019 compound. Table 2: Proposed construction programme

3.8 Materials Management Detailed matters concerning construction waste will be addressed at the implementation stage by the Applicant with their appointed contractors as part of the site management organisation. The development process will seek to ensure that the creation of waste is minimised and that every effort is made to avoid needless waste generation.

Surplus materials will be taken off site under the appropriate waste classification by a licensed waste carrier and disposed of at a licensed waste facility.

Any waste materials from the proposed development will be managed in accordance with the Environmental Protection Act (1990) and the waste handling procedures under the contractor’s project environmental plans.

3.9 Hazardous Materials Hazardous materials associated with the proposed kiosks will be kept in secure locked areas as with the existing materials kept on site.

9 Diesel is stored in bunds on areas of hard standing in accordance with guidance detailed in The Control of Pollution (Oil Storage) (England) Regulations (2001) and/or EA Pollution Prevention Guidelines (PPG 2) 2004 Above Ground Oil Storage Tanks and PPG 26 (2011) Drums and intermediate bulk containers.

Spill kits are kept on site and members of staff trained in their use.

3.10 Traffic Management and Access Existing Traffic Movements There are currently traffic movements to and from the site associated with the operation of the WTW. These traffic movements consist of cars, light vans and tankers. It is not proposed that the number of vehicles will increase as a result of the works.

All site traffic accesses the site from the existing access into the WTW off of Church Lane.

Traffic Movements During Construction During the mobilisation phase of construction (circa two weeks), there will be approximately 10-12 two way Heavy Goods Vehicle (HGV) visits per week. There will be approximately 10 (5 in - out) light van/vehicle movements a day for construction staff. These movements are associated with setting up of the site compound and delivery of plant and equipment.

In the construction phase, vehicle movements will consist of daily access to the site from site personnel and delivery of plant, machinery and equipment. The maximum movements will be 30 light vehicle movements and 10 HGV movements per week.

Parking for the vehicles will be accommodated within the WTW site where sufficient space can be provided for loading, storage and turning along with parking space for site operatives and visitors.

There will be no construction traffic associated with the scheme on Sundays (unless otherwise agreed with the Planning Authority) or Bank Holidays. Traffic movements will be managed in accordance with best practice and incorporated within the contractor's project environmental plan.

Construction traffic will access the site from the existing access into the WTW off of Church Lane as the only access to the site, no alterations to the junction are required. The additional HGV traffic can easily be accommodated by the access during the construction period. A

10 practical approach to vehicles entering and leaving the site will be implemented by the contractor to avoid any delays occurring outside the site and in line with the existing site entrance/exit policies.

Every reasonable effort will be used to ensure that deliveries take place outside of school drop-off and pick-up times and outside of peak traffic hours. A degree of flexibility with these time bands will be required should there be an unplanned event (such as late delivery of concrete) or an emergency situation that would require site presence and activity beyond those times. This would however be exceptional. If the Council considers that an hours of use condition is required, it is requested that this makes allowance for unplanned and emergency use.

Traffic Movements During Operation On completion, operational traffic movements to the WTW will not increase beyond existing levels and would be purely for operational and maintenance operatives.

3.11 Construction Management The contractor's project environmental plan will be prepared as part of the proposed development to be used on site to manage and minimise the potential environmental impacts of construction activities. The plan is compiled by the site construction manager with inputs from the planning, public relations and environmental teams.

Good working practices will be stipulated in the plan that will form part of the contract with the civil engineering contractor and will be audited and enforced by Southern Water.

3.12 Wheel washing facilities This will be provided within the site in accordance with standard contractors practice if required.

3.13 Site Lighting Temporary lighting to assist during the construction period (namely during the shorter day winter mornings and evenings) will be used. This will include temporary task lighting and flood lighting. These will only be used within the hours of construction and turned off when not required.

11 Permanent external lighting at the site will be required during its operation to surround the kiosk and illuminate the immediate surrounding area, this will be low level task lighting only and will only be used when necessary during the shorter winter days and turned off when not in use. Existing lighting exists on the site already and there have been no complaints.

Lighting units/luminaries will be selected that are appropriate for their location to reduce light spill and glare to a minimum as per recommendations specified in the Institution of Lighting Engineers (ILE) Guidance Notes (GN) for the reduction of obtrusive light (GN01) (ILE, 2011).

Specifically designed lighting equipment shall be selected that minimises the upward spread of light near to and above the horizontal to reduce any wider light pollution.

All Lighting shall comprise low energy LED Luminaires, with day-light sensing control. Lux levels shall be in accordance with the Chartered Institute of Building Services Engineers (CIBSE) Lighting Guide (LG) 01 (2012) and LG7. Lighting circuits shall be sourced from a dedicated lighting distribution boards.

The external lighting will be internally focused and low level within the site and will only be used where necessary to facilitate operation staff, It is not considered that it will have any adverse impact on the surrounding area given the mitigation measure and operating procedures put in place.

3.14 Site Restoration All areas temporarily impacted by the proposed development will be reinstated to their existing condition upon completion of the development.

12 4 POTENTIAL IMPACTS ON THE ENVIRONMENT

A qualified Southern Water ecologist carried out a Preliminary Ecological Appraisal (PEA) of the site and its surrounds to identify any ecological constraints associated with the proposed development activities. The site visit identified the habitats and features of ecological interest, including any evidence of protected species or their habitats. In addition to the site visit, a desk study was conducted to determine any known ecological constraints within or close to the site. A search of the MAGIC (Multi-Agency Geographic Information for the Countryside)1 website and Southern Waters GIS constraints mapping tool was undertaken to obtain information on any non-statutory designated sites and protected species close to the site.

The preliminary ecological appraisal is based on drawings JN.639170.0Z0702, JN.639170.0Z0703 and JN.639170.0Z0704.

4.1 Site description The site is a medium sized Water Treatment Works (WTW) within a rural area near the village of Guestling Green, East Sussex. The site contains operational facilities, which include concrete, brick structures and areas of hardstand and managed amenity grassland. The site is bordered by an area of Ancient Woodland to the east and south.

4.2 Designated sites The site is bordered by an area of Ancient Woodland to the east and south.

4.3 Habitats of Principal Importance

Guestling/Fairlight Woods Deciduous Woodland UK Habitat of Principle Importance borders the WTW site to the north, east and south. The branches of the trees from this area overhang the WTW and may therefore be affected by any works within the WTW site. Works within the WTW site may also affect the roots of the trees from this woodland. Works will be undertaken in accordance with BS5837 and NJUG Volume 4 Guidelines when working close to trees.

1 www.magic.gov.uk

13 4.4 Protected species A PEA was undertaken in 2016 to identify potentially sensitive ecological features which may be affected by the proposed development. Ecological features identified during the PEA are detailed below.

4.5 Reptiles The species-rich hedgerow, broadleaved woodland and running water provide suitable habitat for reptiles. The PEA revealed the presence of reptiles within the woodland adjacent to the WTW site. Due to the limited extent of vegetation removal required the vegetation removal will be undertaken under the supervision of a suitably experienced ecologist.

4.6 Dormouse The species-rich hedgerow and broadleaved woodland adjacent to the WTW site provide optimal habitat for dormouse. The PEA identified the presence of dormouse in the woodland adjacent. The branches of the species-rich hedgerow and broadleaved woodland may be affected by works within the WTW site. Due to the limited extent of vegetation removal required the vegetation removal will be undertaken under the supervision of a suitably qualified ecologist. If dormice are encountered during works then works will cease and a Natural England Mitigation License may be required.

4.7 Bats The trees overhanging the WTW site are classed as low suitability as per the Bat Surveys Good Practice Guidelines (Collins, 2016) as they have some potential for roosting bats. These trees may be affected by works within the WTW site. As per the Guidelines (Collins, 2016) vegetation removal will be undertaken under the supervision of a suitably qualified ecologist. If bats are encountered during works then works will cease and a Natural England Mitigation License may be required.

4.8 Breeding Birds The species-rich hedgerow and broadleaved woodland provide suitable habitat for breeding birds. Breeding birds may be affected by works within the WTW site. If vegetation clearance/disturbance is required then this shall be undertaken between September and February (inclusive). If works are required between March and August (Inclusive), nesting bird surveys must be undertaken to assess if any nesting activity is taking place. If active nest are identified, a 5m protection zone must be placed around the nest until the birds have fledged.

14 4.9 Great Crested Newts The ponds surrounding the scheme were subject to a HSI (Habitat Suitability Index) survey and subsequent presence/absence survey in 2015. The surveys found that a low population of great crested newts are present within a pond which is approximately 200m from the WTW site and connected to the WTW site by a species-rich hedgerow. The risk of encountering great crested newts during works within the WTW site is low however as the habitat within the WTW site is amenity grassland which is unsuitable for this species.

4.10 Badgers The habitat adjacent to the WTW site provides optimal habitat for badgers. No evidence of badger was identified adjacent to the WTW site during the field survey. A pre-construction badger check will be undertaken to ascertain the presence of badger activity.

4.11 Invasive Plants No invasive plant species were identified during the field survey.

4.12 Other habitats/species All protected species have been assessed for this site. The survey revealed no other habitats or features that were considered likely to be of significant ecological value or to support protected species.

4.13 Assessment

The site’s ecological value has been evaluated broadly following guidance issued by the Chartered Institute of Ecology and Environmental Management (CIEEM 2013)2, which ranks the nature conservation value of a site according to geographic scale of reference: international, national, regional, county/metropolitan, district/borough, local/parish or of value at the site scale. In evaluating the nature conservation value of the site the following factors were considered: nature conservation designations, species/habitat rarity, naturalness, fragility and connectivity to other habitats.

2 Guidelines for Ecological Impact Assessment in the UK (2013). Chartered Institute of Ecology and Environmental Management

15 The WTW is not subject to any nature conservation designations and none will be affected by proposed development activities.

The majority of the WTW contains habitats that have limited potential to support protected species, for example, hardstand and mown grass. The potential for the proposed development activities to affect protected species is low.

The habitats and species affected by the proposed development activities within Guestling Green WTW site are of value within the immediate vicinity of the site only as it contains common habitats of lower ecological value.

4.14 Landscape and Visual Assessment Guestling Green WTW is located in a largely rural setting with agricultural land and woodland to all boundaries.

The site benefits from screening on all aspects, this is notably dense on the northern, eastern and southern boundaries which prevent views into the site. Views into the site from the west and Church Lane are again well screened by existing trees adjacent to the access track and entrance and given the distance between the site and the highway.

The proposed location of the kiosk, in the southern section of the site is adjacent to existing operational plant and set against an area of dense woodland which sit between the site and the nearest viewpoints. The views from which the kiosk will be seen are very limited and it is not considered that the kiosk will have any detrimental impact in visual terms. The size of the kiosk has been kept as small as is technically possible to reduce any impact on the surrounding area.

A dark green finish has been specified for the kiosk, in keeping with the surrounding landscape and preferred in the rural setting when largely set against a mature treeline.

Therefore, given the lack of available viewpoints, existing screening, and the scale of development in the context of the existing structures, it is assessed there will be no adverse visual impact on the landscape.

16 4.15 Odour and Dust The site currently has no odour problems and the proposed kiosks are not odour generating, there will therefore be no issues in relation to odour at the site.

During construction there is a risk of nuisance dust emissions which are associated with the excavation and handling of materials. The nearest property is located approximately 300m from the site boundary and main construction activities. Normal site practise of dust control by wetting dust generating activities or areas, covering stockpiles of excavated material and wheel washing practices will be carried out if required in line with the construction management plan. After the construction has been completed there will be no increase in odour and dust from the site.

4.16 Noise The WTW is located in a rural area with minimal noise receptors located in the vicinity. The nearest residential properties being located some 200m away on Church Lane.

The proposed kiosk will not generate any notable level of noise, the switchgear will all be enclosed within the kiosk itself and will not have any impact on surrounding sensitive receptors by virtue of the low level of noise generated and the distance to the nearest properties.

4.17 Controlled Waters Groundwater The proposed development is not located within a groundwater source protection zone (SPZ).

The construction works will be carried out in accordance with the contractor's project environmental plan to ensure no pollutants enter the groundwater system.

Surface Water There are no surface water bodies located in close proximity to the proposed development. Run-off or spillages from construction activities will be avoided through careful site management guided by the contractor's project environmental plan which will follow EA pollution control guidelines.

Flood Risk The works proposed under this application are situated outside of any flood zones.

17 4.18 Contamination The site is not highlighted on the EA or Magic mapping systems as an area impacted by historic contamination, such as a landfill.

If unexpected contamination were to be uncovered during the works, the works would stop in the immediate area and a contaminated land specialist would be contacted to provide further advice.

Site wastes will be managed in accordance with relevant waste legislation.

4.19 Local Disturbance No impact is envisaged from the operation of the WTW site, local residents may be subject to minor noise disturbance during construction from machinery and vehicle movements. This will be minimised by good working practices such as avoidance of night-time and weekend working.

Due to the nature of work being carried out and the available site access, no disturbance to local road users is expected during construction within the WTW.

18 5 CONCLUSION

The proposed development at Guestling Green WTW is required to prepare the works to comply with the new Water Framework Directive (WFD) for tighter determinants for Phosphorus and Ammonia.

It is assessed that the proposed development is in keeping with the existing site and setting of the WTW and that the proposed development will not materially impact any surrounding sensitive receptors, notably the nearest residential properties, throughout either the construction or operational phases.

There are no significant impacts associated with the proposed development. The construction and operational phases will pay due regard to the purposes of the ecological constraints affecting the site. As such, it is considered that the proposed development does not constitute an EIA development.

In consideration of the development not constituting an EIA development and having regard to the provisions of the development and all material considerations, planning permission should be granted for the proposed kiosk.

Good working practices and careful supervision during construction will ensure that potential risks to identified sensitive receptors will be minimised and impacts prevented.

These practices will be stipulated and addressed in the contractor's project environmental plan. Southern Water processes also ensure good site management during operation and compliance with existing environmental permits, licences and consents.