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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
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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
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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.
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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
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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
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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).
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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).
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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=
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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.
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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;
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• 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
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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.
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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
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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
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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.
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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.
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Fig. A11.1.1: European designated sites within 10km
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Fig. A11.1.2: SSSIs, LNRs, non-statutory sites and ancient woodlands
AWS = Ancient Semi-Natural Woodland Sites PAWS = Plantation of Ancient Woodland Site