PEIR Appendix 11-1 · PEIR Appendix 11-1 17/06/2020 1 Introduction This report is designed to...

Proposed Extension to the Existing Allington Integrated Waste Management Facility PEIR Appendix 11-1 Preliminary Ecological Appraisal

Prepared for FCC

Kevin Honour MSc MCIEEM

Version 1.0 / Ref. 19-024-11_1

17/06/2020

Proposed Extension to the Existing Allington Integrated Waste Management Facility PEIR Appendix 11-1

Issue Prepared by Checked by Approved by Status Date

V1 Kevin Honour MSc

MCIEEM

Paul Lupton MSc Claire Gilchrist MSc DRAFT 17/06/2020

All Argus Ecology Ltd. staff subscribe to the Chartered Institute of Ecology and Environmental

Managements (CIEEM) code of professional conduct in their work.

This report has been prepared in accordance with CIEEM’s Guidelines for Ecological Report

Writing.

This report is not to be used for contractual purposes unless this approval sheet is signed and designated

as ‘FINAL’.

This report has been prepared by Argus Ecology Ltd. in its professional capacity as Ecological Consultants.

Its contents reflect the conditions that prevailed and the information available or supplied at the time of

preparation. The report, and the information contained therein, is provided by Argus Ecology Ltd. solely

for the use and reliance by the Client in performance of Argus Ecology Ltd.’s duties and liabilities under

its contract with the client. The contents of the report do not, in any way purport to include any manner

of legal advice or opinion.

Report Reference Ref. 19-024-11_1

Date 17/06/2020

Date of survey/s 16/05/2019, 11-12/06/2019

Proposed Extension to the Existing Allington Integrated Waste Management Facility 2

Argus Ecology Ltd. PEIR Appendix 11-1 17/06/2020

Contents

1 Introduction 3

2 Methodology 4

2.1 Data search 4 2.2 Survey methodology 4 2.3 Assessment Methodology 5 2.4 Personnel 5

3 Results 6

3.1 Statutory and locally designated sites 6 3.2 Species records 9 3.3 Habitats and vegetation 11 3.3 Fauna 11

4 Preliminary evaluation of important ecological features 13

4.1 Sensitivity of ecological receptors to air quality effects 13 4.2 Evaluation of habitats 14 4.3 Faunal habitat quality 14

5 Preliminary Conclusions and Recommendations 16

5.1 Preliminary conclusions 16 5.2 Recommendations for further survey works 16 Fig. A11.1.1: European designated sites within 10km 17 Fig. A11.1.2: SSSIs, LNRs, non-statutory sites and ancient woodlands 18 18



1 Introduction

This report is designed to provide a Technical Appendix to the Preliminary

Environmental Information Report (PEIR) for the Proposed Extension to the Allington

Integrated Waste Management Facility (IWMF), Kent.

It provides a Preliminary Ecological Appraisal (PEA) of the Proposed Extension, with

the following objectives:

• To collate and gather ecological data on the Site, providing a preliminary

evaluation of the Site’s ecological features;

• Identify and characterise sensitive ecological receptors to inform the

production of the Stack Height Assessment and Emissions Modelling

Assessment; and

• Identify additional ecological surveys which may be necessary to fully assess

ecological effects of the Proposed Extension.

An Extended Phase 1 Habitat Survey with identification of National Vegetation

Classification (NVC) communities, and UK Habitat Classification Survey (UKHC) with

calculation of biodiversity interest is included in Technical Appendix 11-2.

Note that because of seasonal timing, breeding bird surveys and habitat quality

assessment / environmental DNA surveys for great crested newts commenced as a

precautionary measure before the PEA surveys were complete. The potential

requirement for these surveys, therefore, did not require assessment in the PEA.



2 Methodology

2.1 Data search

The PEA has been informed by a desktop study including:

• a web-based data search for statutory sites, ancient woodlands and priority

habitats using the Multi-agency Geographic Information for the Countryside

(MAGIC) database; and

• a data search from the local environmental records centre (Kent and Medway

Biological Records Centre (KMBRC)) for protected and priority species, and

non-statutory designated sites within 2km of the Site boundary.

2.2 Survey methodology

Phase 1 Habitat Survey

The habitat survey conformed to Phase 1 methodology (IEA, 19951), with

identification of National Vegetation Classification (NVC) plant communities. Further

details are given in Appendix 11.2.

Protected species walkover and risk assessment

A walkover survey of the whole Site was carried out by Paul Lupton MSc MCIEEM, a

licensed and experienced protected species specialist. Signs of use by terrestrial

protected species were searched for in the field, including badger across the whole

Site and water vole and otter likely to be more closely associated with the existing

waterbodies on the Site.

The survey was undertaken on 15th May 2019, which is early enough in the season to

identify tracks, trails and other signs of activity before rank vegetation obscures field

signs. There were no constraints imposed by weather conditions, and with the

exception of some small areas of impenetrable scrub, access was possible to all parts

of the Site.

Table 2.1: Protected species survey timing and weather

Date Time on site Weather

15/05/2019 09:00 – 15:00 140C, lightNE winds, CC 3/8, sun / partial cloud

1 Institute for Environmental Assessment (1995). Guidelines for baseline ecological assessment. E & FN Spon



Bat roost risk assessment

Trees and any other structures were assessed to determine the risk of occupancy by

bats, with the survey equivalent in terms of current Bat Conservation Trust guidance

(Collins (ed.), 2016)2 to a preliminary ecological appraisal.

2.3 Assessment Methodology

The report scope and assessment methodology are based on CIEEM Guidelines for

Preliminary Ecological Appraisal (CIEEM, 2013)3. The identification of important

ecological receptors follows CIEEM Guidelines for Ecological Impact Assessment

(CIEEM, 2016)4.

2.4 Personnel

PEA report

The PEA report was authored by Kevin Honour MSc MCIEEM, a Director of Argus

Ecology Ltd. with over 27 years of ecological survey experience; he has extensive

experience in ecological impact assessment of a range of developments, with a

particular emphasis on waste to energy projects involving assessment of air quality

effects on ecological receptors.

Protected species surveys

Protected species and bat risk assessments were undertaken by Paul Lupton MSc

MCIEEM, a Director of Argus Ecology Ltd. He holds Natural England great created

newt, bat roost visitor and bat survey licences (2015-19597-CLS-CLS, 2015-14703-CLS-

CLS and 2015-14704-CLS-CLS) and has over twenty years’ experience in carrying out

protected species surveys.

2 Collins, J. (ed.) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd edn). The Bat Conservation Trust, London 3 CIEEM (2013). Guidelines for Preliminary Ecological Appraisal. Chartered Institute of Ecology and Environmental Management, Winchester 4 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



3 Results

3.1 Statutory and locally designated sites

European / internationally designated sites

There are three Special Areas of Conservation (SAC) within the 10km area of search:

• North Downs Woodlands SAC (2.7km NE of Site at closest point);

• Peter’s Pit SAC (5km NW); and

• Queendown Warren SAC (9.6km NE).

There are no Special Protection Areas (SPA) or Ramsar Sites within the 10km search

radius. Medway Estuary and Marshes SPA is located in the lower Medway Estuary,

outside the 10km area of search. SACs are designated, and SPAs classified under the

Conservation of Habitats and Species Regulations 2017.

Locations of SAC sites relative to the Proposed Extension are shown on Figure

A11.1.1. Qualifying features are tabulated below.

Table A11.1.1: Qualifying features of European designated sites

Site Qualifying features

(* = priority feature)

North Downs Woodlands

SAC

9130 Asperulo-Fagetum beech forests

91J0 Taxus baccata woods of the British Isles*

6210 Semi-natural dry grasslands and scrubland facies on

calcareous substrates (Festuco-Brometalia)

Peter’s Pit SAC 1166 Great crested newt (Triturus cristatus)

Queendown Warren SAC 6210 Semi-natural dry grasslands and scrubland facies on

calcareous substrates (Festuco-Brometalia)* (*important

orchid sites)

UK statutory designated sites

Sites of Special Scientific Interest

There are two Sites of Special Scientific Interest (SSSI) within the 2km search buffer:

• Allington Quarry SSSI (0.37km SE); and

• Aylesford Pit SSSI (1.8km NW).



Notified features of these sites are tabulated below.

Table A11.1.2: Notified features of SSSIs

Site Notified features

Allington Quarry SSSI Quaternary of South East England

Aylesford Pit SSSI Quaternary of the Thames

SSSIs are designated under Section 28 of the Wildlife and Countryside Act 1981;

designation can be on the basis of the special interest of flora, fauna, geological or

physiographic features.

Allington Quarry and Aylesford Pit are both designated for their geological interest,

and not considered further as SSSIs in terms of potential ecological effects. Locations

of SSSIs and other sites considered within 2km are shown on Figure A11.1.2.

Marine Conservation Zones

There is one Marine Conservation Zone (MCZ) within the 2km search area, Medway

MCZ. This is designated under Section 116 of the Marine and Coastal Access Act 2009.

MCZs are designated for the conservation of marine flora and fauna; marine habitats;

and features of geological or geomorphological interest.

Medway MCZ is an inshore site covering a total area of 60km2, encompassing the

Medway estuary together with an area of marine habitat between Sheerness and the

Isle of Grain. It is designated for the following features:

• Estuarine rocky habitats;

• Intertidal mixed sediments;

• Intertidal mud and muddy sand;

• Low energy intertidal rock;

• Peat and clay exposures;

• Smelt (Osmerus eperlanus);

• Subtidal coarse sediment;

• Subtidal mud;

• Subtidal sand; and

• Tentacled lagoon-worm (Alkmaria romijni).



Local Nature Reserves

There is one Local Nature Reserve (LNR) within the 2km search area, Ditton Quarry.

LNRs are designated under Section 21 of the National Parks and Access to the

Countryside Act 1949.

Ditton Quarry LNR is described on the Natural England website as a restored ragstone

quarry with limestone grassland and scrub5.

Non-statutory designated sites

The following Local Wildlife Sites are located within the 2km search radius.

Table A11.1.3: Local Wildlife Sites

Site Location Features of interest

Aylesford Old Pit LWS 1.5km NW Calcareous grassland

Cuckoo Wood LWS 1.9km E Beech woodland

Blue Bell Hill Banks and Verges LWS 1.9km NE Calcareous grassland

There are a number of additional sites within the search data supplied by KMBRC, but

outside of the 2km radius from the emissions source used in air quality modelling;

these include the following:

• Oaken Wood, Barming – 2.2km SW of nearest Site boundary; and

• Eccles Old Pits – 2.4km NW of nearest Site boundary.

These are not considered further in the assessment.

Ancient woodland sites

There is a total of 18 ancient woodland sites within 2km of the Site boundary.

Locations of these are shown on Fig. A11.1.2. All of these are classed as Ancient

Semi-natural Woodland sites (ASNW); there are some Plantations on Ancient

Woodlands (PAWS) sites outside of the 2km search area.

5 https://designatedsites.naturalengland.org.uk/SiteLNRDetail.aspx?SiteCode=L1452178&SiteName=&countyCode=24&responsiblePerson=&SeaArea=&IFCAArea=

https://designatedsites.naturalengland.org.uk/SiteLNRDetail.aspx?SiteCode=L1452178&SiteName=&countyCode=24&responsiblePerson=&SeaArea=&IFCAArea

https://designatedsites.naturalengland.org.uk/SiteLNRDetail.aspx?SiteCode=L1452178&SiteName=&countyCode=24&responsiblePerson=&SeaArea=&IFCAArea



3.2 Species records

Protected species records

Great crested newt

Records of great crested newt (Triturus cristatus; GCN) returned from the 2km data

search included the following:

Table A11.1.4: Great crested newt records (selected closest)

Location Grid ref. Distance Date

M20 junction 6 TQ7531558723 1.1km NE 2006

Aylesford Old Pit TQ7338859122 1.1km NW 2012

Other protected amphibians

There is a very old (1954) record of natterjack toad (Epidalea calamita) from Sandling,

approximately 1.5km east of the nearest Site boundary.

Otter

The data search only returned one otter record, for grid square TQ7555, and dating

from 1987. This OS 1km grid square includes the section of the River Medway in

central Maidstone, outside the 2km data search radius.

Bats

The following bat species records were returned by the data search. Records were

accompanied by a map of known roost locations, using data supplied to KMBRC by

Kent Bat Group.

• Serotine Eptesicus serotinus;

• Daubenton’s bat Myotis daubentonii;

• Whiskered bat Myotis mystacinus;

• Natterer’s bat Myotis nattereri;

• Leisler’s bat Nyctalus leisleri;

• Common pipistrelle Pipistrellus pipistrellus;

• Soprano pipistrelle Pipistrellus pygmaeus; and

• Brown long-eared bat Plecotus auritus.



The nearest roost record is approximately 220m south-west of the nearest Site

boundary, associated with a settlement to the south of the A20. There are also a

number of roost records associated with Allington Castle, approximately 1.2km east

of the nearest Site boundary.

Water vole

There are a number of records of water voles dating from 1964 – 2016; however, the

only recent (21st century) records are localised to Rochester Road, Aylesford, OS

100m grid reference TQ735595. This is approximately 1.4km north of the nearest Site

boundary; it is also to the north of the M20 and River Medway.

Hazel dormouse

The only recent (2010) records of hazel dormouse (Muscardinus avellanarius) are

located in the Cossington area. This is around 1.4km north of the nearest Site

boundary, to the north of the M20 and River Medway.

Reptiles

There are quite a large number of records of the four commoner reptile species –

grass snake (Natrix natrix), adder (Vipera berus), slow-worm (Anguis fragilis) and

common lizard (Zootoca vivipara).

There are two records localised to the Allington area. One is a 2012 slow-worm record

from Bridge Nursery, Allington (TQ738574), approximately 100m south of the nearest

Site boundary, and separated from it by the Maidstone to London rail line. The

second is a 1989 adder record from Allington, localised to the 1km OS grid square

TQ7458. This encompasses the far north-eastern corner of the Site, the adjoining

20/20 Business Park, woodland and other habitats alongside the River Medway.

Priority species records

Plants

Priority plant species listed in Section 41 of the Natural Environment and Rural

Communities Act 2006 include the following orchid species:

• White helleborine Cephalanthera damasonium;

• Narrow-leaved helleborine Cephalanthera longifolium;

• Musk orchid Herminium monorchis;

• Man orchid Orchis anthropophora;



• Burnt orchid Neotinea ustulata; and

• Fly orchid Ophrys insectifera.

None of the records were localised in close proximity to the Site.

Invertebrate records

Section 41 invertebrate records include depressed river mussel (Pseudanodonta

complanata), located in the River Medway around 1.5km SW of the nearest Site

boundary. This is a globally threatened species (IUCN Vulnerable category).

Insect records included stag beetle (Lucanus cervus) and noble chafer (Gnorimis

nobilis), as well as a wide variety of Lepidoptera (moth and butterfly) records. None

of these are localised to the Site or its immediate surroundings.

Fish records

Records of Section 41 fish species include European eel (Anguilla anguilla), smelt

(Osmerus eperlanus) and brown / sea trout (Salmo trutta). All have records including

the Allington reach of the River Medway.

Amphibian records

There are numerous records of common toad (Bufo bufo) in the data search, although

none are localised to the Allington area.

Mammal records

Section 41 terrestrial mammal records include hedgehog (Erinaceus europaeus) and

brown hare (Lepus europaeus); none are localised to the Allington area.

There are a number of records of common seal (Phoca vitulina) from Allington Lock

on the River Medway.

3.3 Habitats and vegetation

See Appendix 11.2 for a full description of habitats and vegetation on site, including a

Phase 1 Habitat Survey, UK Habitat Classification Survey and discussion of National

Vegetation Classification (NVC) plant communities present on Site.

3.3 Fauna

Protected species walkover survey

The whole of the survey site was ‘walked’ and there were no significant access

constraints. In particular the potential use of the Site by badgers, otter and water vole



was investigated. A close inspection was made of the banksides of the on-site water

bodies (pond and attenuation lagoon) and no signs were found. This is not entirely

unexpected as the pond and lagoon are not hydrologically connected to any other

water body and the whole site has poor connectivity with other wetland habitats.

Neither water body has suitable bankside for burrowing animals and no otter signs

such as spraint or couches were observed.

A thorough search of the peripheral woodland was carried out for badger signs such

as setts, latrines, or feeding signs. The scrubby woodlands to the north east and

eastern boundary had numerous rabbit holes and these were thoroughly inspected

for signs of badger occupancy; none were found. Along the eastern boundary was a

hole that had the appearance of a badger sett but it was long disused (access blocked

by leaves and twigs) and there were no badger signs around it. The plantation

woodland along the southern boundary was also inspected and there were few

mammal signs found other than signs of fox.

Mammal signs observed were limited to fox (including a breeding female with four

cubs), grey squirrel and rabbit.

Bat roost inspection

All trees on the Site were inspected from the ground using binoculars in order to

identify any trees that may have potential roosting features (PRFs). The majority of

trees on the Site were in semi-mature plantation woodland or were young trees that

had been planted relatively recently as part of habitat creation to the west of the

Existing Station. There are a few mature trees along the eastern boundary and along

the boundary with the M20 but inspection from the ground revealed few PRFs.



4 Preliminary evaluation of important ecological features

4.1 Sensitivity of ecological receptors to air quality effects

European designated sites

The following environmental quality standards (Critical Levels and Critical Loads) have

been applied to qualifying features of European designated sites. They are derived

from the Site Relevant Critical Loads section of the Air Pollution Information Service

(APIS) website6.

Table A11.1.5: Site Relevant Critical Levels and Critical Loads

Site Qualifying feature

CL NH3

(µg/m3)

CL N dep.

kg N/ha/yr

(value used for screening)

CL acid dep.

(CLmaxN)

(keq H+/ha/yr)

North Downs Woodlands SAC 9130 Asperulo-Fagetum

beech forests

Site-specific advice

10 – 20 (10) 1.983 – 11.171

North Downs Woodlands SAC

91J0 Taxus baccata woods of the British Isles*

3 5 – 15 (10) 1.983 – 11.171

North Downs Woodlands SAC

6210 Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia)

1 15 – 25 (15) 4.856

Peter’s Pit SAC

1166 Great crested newt (Triturus cristatus)

3 Site specific (dependent on N or P limitation)

No critical load assigned

Queendown Warren SAC 6210 Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia)*

1 15 – 25 (15) 4.856

Locally designated sites

The following critical levels and critical loads have been set for locally designated

sites, based on APIS recommended values for the habitats known to represent the

reasons for selection of each site.

6 http://www.apis.ac.uk/srcl

http://www.apis.ac.uk/srcl



Table A11.1.6: Critical Levels and Critical Loads for Locally Designated Sites

Site Interest feature

(EUNIS habitat)

CL NH3

(µg/m3)

CL N dep.

kg N/ha/yr

(value used for screening)

Ditton Quarry LNR Sub-atlantic semi-dry calcareous grassland (E1.26)

1 15 – 25 (15)

Aylesford Old Pit LWS Sub-atlantic semi-dry calcareous grassland (E1.26)

1 15 – 25 (15)

Cuckoo Wood LWS Fagus woodland (beech) (G1.6) 1 10 – 20 (10)

Blue Bell Hill Banks and Verges LWS

Sub-atlantic semi-dry calcareous grassland (E1.26)

1 15 – 25 (15)

Acid deposition critical loads are taken from the Air Pollution Information System

(APIS) Query by Location tool7 for the relevant habitat.

Ancient woodlands

In the absence of detailed available information with respect to woodland plant

communities present, a precautionary approach has been taken to assigning critical

loads and levels. The following principles have been applied:

• It is assumed all woodlands support important lichen or bryophyte

communities – the lower critical level for ammonia of 1µg/m3 has therefore

been used for screening purposes;

• The precautionary critical load for nitrogen deposition for broadleaved and

mixed woodland broad habitat of 10kg N/ha/yr has been applied for screening

purposes; and

• Acid deposition critical loads have been taken from the APIS Query by Location

tool, applied to broadleaved, mixed and yew woodland priority habitat.

4.2 Evaluation of habitats

See Appendix 11.2 for an evaluation of habitats present, measured against Priority

Habitat criteria and quantified in accordance with Biodiversity Metric 2.0.

4.3 Faunal habitat quality

Habitat quality for foraging bats is moderate with areas such as scrub and pond

offering good feeding opportunities but with large areas of lower habitat quality.

There are strong commuting corridors around the Site, however there are few PRFs as

7 http://www.apis.ac.uk/search-location

http://www.apis.ac.uk/search-location



the trees are largely immature and buildings are of negligible value. Given the

foraging habitat available, a combination of remote detectors and transects to assess

species composition and distribution is recommended.

There are few dormouse records in the vicinity of the Site and the relative isolation of

the Site and the immature vegetation over much of the development plot suggests

that there is a negligible risk of impacting on this species.

Reptiles were not observed within the walkover survey but the habitat quality is good

with cover, bare ground, and two water bodies being present. The relatively ‘new’

habitats and the lack of connectivity could be seen as contra-indicators but surveys

are recommended.

Most habitats within the Site are newly created and as such are likely to be

developing a pioneer community. The Site has a mix of habitats and woodland,

grassland, scattered scrub and water bodies which may support good species

diversity. An invertebrate survey focusing on groups for which there is extensive

distribution data is therefore recommended.



5 Preliminary Conclusions and Recommendations

5.1 Preliminary conclusions

The data search identified a number of protected sites and ancient woodlands which

should be considered as sensitive receptors with respect to consideration of

emissions to air.

Protected species records suggested some reptile records in relatively close proximity

to the Site, but no records of known great crested newt populations within 1km.

With respect to habitat quality on Site, the results of the Phase 1 and UKHC surveys

are evaluated in Appendix 11-2.

The protected species walkover survey did not identify any signs of use by badger,

otter or water vole. Bat roosting opportunities within the Site are very limited;

foraging habitat quality was quite good in terms of habitat structure but may be

restricted by the Site’s relative degree of isolation by proximity to the major road

network.

5.2 Recommendations for further survey works

Following the initial assessment reported in this PEA, the following further survey

works were recommended, and included in the Scoping Report:

• Bat activity surveys (transect surveys / automated monitoring);

• Invertebrate surveys (freshwater & terrestrial); and

• Reptile surveys.

As noted in Section 1, breeding bird surveys and great crested newt habitat suitability

assessment and eDNA surveys had already commenced.



Fig. A11.1.1: European designated sites within 10km



Fig. A11.1.2: SSSIs, LNRs, non-statutory sites and ancient woodlands

AWS = Ancient Semi-Natural Woodland Sites PAWS = Plantation of Ancient Woodland Site

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