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KWT/3/A Proof of Evidence Kent Wildlife Trust Re: London Ashford Airport, Lydd, Romney Marsh, Kent Y06/1647/SH: Erection of a terminal building (capable of processing 500,000 passengers per annum) and 637 car parking spaces Y06/1648/SH: Construction of a 249m runway together with an additional 150m starter extension Planning Inspectorate Refs: APP/L2250/V/10/2131934 APP/L2250/V/10/2131936 Kent Wildlife Trust Proof of Evidence Page 1 of 48 KWT/3/A 1. Introduction 1.1. My name is Richard Moyse. I am the Head of Conservation and Policy for the Kent Wildlife Trust (KWT). I am appearing on behalf of KWT at this inquiry. 1.2. I was awarded an honours degree in Botany by the University of Wales in 1984 and have subsequently acquired 26 years professional experience in the field of natural history and nature conservation. I took up my current position in 2002. Prior to joining KWT, I worked for six years as an ecological consultant specialising in habitat survey and management planning, and prior to this I spent ten years working for the then Gillingham Borough Council as a countryside manager. 1.3. My ecological experience is focussed on the habitats of lowland Britain, particularly in Kent. I am an experienced field natural historian, specialising in botany, but also with entomological experience, especially in relation to Hymenoptera (bees, wasps and ants) and Orthoptera (grasshoppers, crickets and their allies). I authored a number of chapters of the Kent Red Data Book, including those relating to beetles and bugs. I have for some years been active on the Executive Committee of Kent Field Club (the natural history society of Kent), including a period as chair. 1.4. My current role includes responsibility for KWT’s involvement in planning issues, as well as work with private land-owners, and the identification and monitoring of Local Wildlife Sites in Kent and Medway. I am also the current chair of the Kent Biodiversity Partnership, which oversees the development and delivery of the Kent Biodiversity Action Plan. 1.5. KWT was established in 1958 as a naturalists’ trust and is now one of the 47 Wildlife Trusts across the United Kingdom which manage land for nature conservation and give advice on conservation management. KWT represents over 30,000 members, and manages 60 nature reserves. Kent Wildlife Trust Proof of Evidence Page 2 of 48 KWT/3/A 2. The importance of Dungeness 2.1. Dungeness has long been recognised as one of the most significant areas of the UK for biodiversity. As a result it has been the subject of a number of studies and publications 2.2. A two-day conference in 1988, jointly hosted by the Linnaean Society of London and the British Ecological Society, is reported in Ferry et al (1989). One of the papers from this conference, by P. Doody, then of the Nature Conservancy Council’s Chief Scientist Directorate, is included in Appendix 1 as useful background on the nature conservation significance of the site; this paper includes the observations (Appendix 1, page 7) that ‘neither [at Orfordness] nor at Chesil Beach do extensive transitions to stable acid grassland occur, which is one of the most significant communities at Dungeness … Dungeness remains … the single largest area of vegetated shingle in Great Britain.’ He further states that ‘The shingle flora is not only important in its own right, but also for the associated invertebrate fauna … The cyclical phases of the vegetation development, particularly the “Cytisus cycle” is also important, the plant providing a habitat for a rich and nationally important invertebrate fauna.’ 2.3. Philp and McLean (1985), in a paper included in Appendix 2 express the view that the invertebrate fauna at Dungeness is ‘without parallel in Britain, and of great significance in a European context’ (Appendix 2, page 14). They state (page 1) that: ‘Dungeness has the justified reputation among entomologists and zoologists for possessing one of the most unusual assemblages of insects, and other invertebrates, to be found in the British Isles. It is not surprising that those species which are specialists adapted to living on stabilized coastal shingle, are better represented at Dungeness than at the five or six other superficially similar British shingle locations which are smaller and less varied in their habitat conditions. Some species are not known from elsewhere in Britain, and there are even subspecies known from nowhere Kent Wildlife Trust Proof of Evidence Page 3 of 48 KWT/3/A else in the world. It is thus regarded as being a top national site for several invertebrate orders, and indeed can fairly be stated to have an international importance, because no other European country has a comparable area of habitat.’ 2.4. The designation of a very substantial area as a Special Area of Conservation (SAC) clearly reinforces the very high nature conservation significance of Dungeness. The area is designated in part for the presence of Perennial vegetation of stony banks, which is defined on the European Environment Agency website thus: “Perennial vegetation of the upper beaches of great shingle banks, formed by Crambe maritima, Honkenya peploides and other perennial species. A wide range of vegetation types may be found on large shingle structures inland of the upper beach. On more mature, stable, shingle coastal forms of grassland, heath and scrub vegetation may develop. Some areas of unusual vegetation dominated by lichens and bryophytes are found on more mature shingle.” (http://eunis.eea.europa.eu/habitats/10013/general; see Appendix 3). 2.5. The Joint Nature Conservation Committee (JNCC) website notes that “There are only a few extensive examples of Perennial vegetation of stony banks in Europe, and the UK hosts a significant part of the European resource of this habitat.” (http://www.jncc.gov.uk/protectedsites/sacselection/habitat.asp?FeatureInt Code=H1220; see Appendix 4). 2.6. At a county scale, the shingle habitats of Dungeness probably represent the single most important Kent site for biodiversity. While there are a number of other sites of international importance within the county, covering a range of habitats, Dungeness is the only Kent site of which I am aware which supports an animal species not found anywhere else in the world. In addition to this, there are, as set out in the Philp and McLean (1985) (Appendix 2), a substantial number of invertebrate species for which Kent Wildlife Trust Proof of Evidence Page 4 of 48 KWT/3/A Dungeness is the only UK site or the only Kent site as well as a substantial number of species listed as Notable (i.e. nationally scarce). 3. The planning context 3.1. PPS1 states that the aims of sustainable development should be ‘pursued in an integrated way through a sustainable, innovative and productive economy that delivers high levels of employment, and a just society that promotes social inclusion, sustainable communities and personal well being, in ways that protect and enhance the physical environment and optimise resource and energy use.’ (My italics). 3.2. The supplement to PPS1 which deals with climate change adds to this, stating that: ‘To deliver sustainable development, and in doing so a full and appropriate response on climate change, regional planning bodies and all planning authorities should prepare, and manage the delivery of, spatial strategies that … secure new development and shape places that minimise vulnerability, and provide resilience, to climate change; and in ways that are consistent with social cohesion and inclusion; [and] conserve and enhance biodiversity, recognising that the distribution of habitats and species will be affected by climate change’. 3.3. PPS9 sets out a series of Key Principles, which include the following: ‘Development plan policies and planning decisions should be based upon up-to-date information about the environmental characteristics of their areas. These characteristics should include the relevant biodiversity and geological resources of the area. In reviewing environmental characteristics local authorities should assess the potential to sustain and enhance those resources’. Kent Wildlife Trust Proof of Evidence Page 5 of 48 KWT/3/A ‘Plan policies and planning decisions should aim to maintain, and enhance, restore or add to biodiversity and geological conservation interests [my italics]. In taking decisions, local planning authorities should ensure that appropriate weight is attached to designated sites of international, national and local importance; protected species; and to biodiversity and geological interests within the wider environment’. 3.4. Thus protection and enhancement, or at the very least, no loss, is the key principle to be followed when dealing with the biodiversity. Further, the potential impact of climate change on biodiversity is also to be considered, and it is important to minimize vulnerability to climate change not just of developments themselves, but of the places shaped by planning. 4. Adaptation to climate change 4.1. Minimizing vulnerability to climate change is effectively the same as, or at least includes, adaptation to climate change, which is defined in the climate change supplement to PPS1 as action which ‘Involves adjustments to natural or human systems in response to actual or expected climatic stimuli or their effects, which moderates harm or exploits beneficial opportunities.’ 4.2. The Defra document ‘Conserving biodiversity in a changing climate: guidance on building capacity to adapt’ (see Appendix 20) addresses this question in relation to biodiversity and presents six guiding principles: 1 Conserve existing biodiversity 1a Conserve Protected Areas and other high-quality wildlife habitats 1b Conserve range and ecological variability of habitats and species 2 Reduce sources of harm not linked to climate 3 Develop ecologically resilient and varied landscapes 3a Conserve and enhance local variation within sites and habitats 3b Make space for the natural development of rivers and coasts Kent Wildlife Trust Proof of Evidence Page 6 of 48 KWT/3/A 4 Establish ecological networks through habitat protection, restoration and creation 5 Make sound decisions based on analysis 5a Thoroughly analyse causes of change 5b Respond to changing conservation priorities 6 Integrate adaptation and mitigation measures into conservation management, planning and practice 4.3. In respect of principle 1, ‘Conserve existing biodiversity’, the guidance states: ‘The importance of protecting existing biodiversity cannot be overemphasised. Future biodiversity will adapt and evolve from the richness of the biodiversity conserved in the 20th century and from the extent of semi-natural habitats that will be protected, restored and created in the 21st century … Two important functions of Protected Areas and other high-quality wildlife habitats will be as core areas for biodiversity and as connecting habitats within ecological networks … The early success of an ecological network will depend upon the persistence of large populations of as many species as possible in the core areas, capable of producing a supply of offspring to colonise new areas.’ 4.4. In respect of principle 2, ‘Reduce sources of harm not linked to climate’, the guidance states that ‘Climate change is only one of many sources of stress to biodiversity in the UK. Like climate change, many of these stress factors have gradual but persistent impacts upon wildlife. Unless these threats are reduced or removed, action to combat the impacts of climate change is likely to be less successful’. Included in a list of potential sources of harm are abandonment of traditional management, over grazing, nutrient enrichment, introductions and spread of non-native species, intensification of farming practices, over abstraction of water, aerial pollutants, and a historical legacy of habitat loss and fragmentation. 5. Threatened species in planning policy Kent Wildlife Trust Proof of Evidence Page 7 of 48 KWT/3/A 5.1. PPS9 also specifically considers species identified as being of principal importance for conservation. These species, which are those identified as requiring action under the UK Biodiversity Action Plan, are those included in the Section 41 list of Species of Principal Importance in England drawn up under the Natural Environment and Rural Communities (NERC) Act 2006. This list is available at http://www.naturalengland.org.uk/Images/section%2041%20nerc%20act% 20-%20species%20(Aug%202010)_tcm6-21417.doc and a copy is provided in Appendix 5. 5.2. In respect of these species, PPS9 states that they ‘have been identified as requiring conservation action as species of principal importance for the conservation of biodiversity in England. Local authorities should take measures to protect the habitats of these species from further decline through policies in local development documents. Planning authorities should ensure that these species are protected from the adverse effects of development, where appropriate, by using planning conditions or obligations. Planning authorities should refuse permission where harm to the species or their habitats would result unless the need for, and benefits of, the development clearly outweigh that harm.’ 5.3. As an addition to this, it should be noted that the Convention on Biological Diversity, to which the UK is a signatory, defines ‘Biological diversity’ as meaning the variability among living organisms from all sources including, inter alia, terrestrial, marine and other aquatic ecosystems and the ecological complexes of which they are part; this includes diversity within species, between species and of ecosystems. While species are referred to specifically in PPS9, protection of biodiversity also includes, inter alia, protection of infraspecific taxa such as subspecies, forms and varieties. Kent Wildlife Trust Proof of Evidence Page 8 of 48 KWT/3/A 6. Regional planning policy 6.1. Regional planning policy reiterates and reinforces the need for protection and enhancement of biodiversity assets set out in PPS9. In Policy NRM5, it states that: ‘Local planning authorities and other bodies shall avoid a net loss of biodiversity, and actively pursue opportunities to achieve a net gain across the region. ‘i. They must give the highest level of protection to sites of international nature conservation importance (European sites). Plans or projects implementing policies in this RSS are subject to the Habitats Directive. Where a likely significant effect of a plan or project on European sites cannot be excluded, an appropriate assessment in line with the Habitats Directive and associated regulations will be required … ‘iv. They shall avoid damage to nationally important sites of special scientific interest and seek to ensure that damage to county wildlife sites and locally important wildlife and geological sites is avoided, including additional areas outside the boundaries of European sites where these support the species for which that site has been selected. ‘v. They shall ensure appropriate access to areas of wildlife importance, identifying areas of opportunity for biodiversity improvement and setting targets reflecting those in the table headed ‘Regional Biodiversity Targets Summary for 2010 and 2026’ below. Opportunities for biodiversity improvement, including connection of sites, large-scale habitat restoration, enhancement and re-creation in the areas of strategic opportunity for biodiversity improvement (Diagram NRM3) should be pursued’. 6.2. Climate change adaptation is also addressed in the South East Plan, in Policy CC2: Kent Wildlife Trust Proof of Evidence Page 9 of 48 KWT/3/A ‘Measures to mitigate and adapt to current and forecast effects of climate change will be implemented through application of local planning policy and other mechanisms … ‘Adaptation to risks and opportunities will be achieved through … ensuring that opportunities and options for sustainable flood management and migration of habitats and species are actively promoted.’ 6.3. The sub-regional policies relating to East Kent and Ashford further reinforce the importance of biodiversity conservation. Policy EKA1 states that ‘The unique heritage and environment will be protected and promoted for its own sake’, while EKA7 states that the development, management and use of the coastal zone will be co-ordinated through a joint policy framework which ‘will include the conservation and enhancement of the most valuable habitats (including Natura 2000 and Ramsar sites) and environments (natural and built)’. 7. Local planning policy 7.1. In respect of local planning policy, there are two documents which need to be taken into account. 7.2. The adopted Shepway Local Plan includes a number of saved policies which are relevant: ‘POLICY CO9 The District Planning Authority will not permit development in or near Sites of Special Scientific Interest or the Dungeness National Nature Reserves, which would adversely affect their wildlife or scientific interest unless; ‘there is an exceptional need for the development which overrides the national or regional value of the designation and Kent Wildlife Trust Proof of Evidence Page 10 of 48 KWT/3/A measures will be taken to minimise impacts and fully compensate for remaining adverse effects. ‘POLICY CO10 The District Planning Authority will not permit development in or near Wildlife Sites or (proposed) Local Nature Reserves where such development would be detrimental to the nature conservation and / or scientific interest unless; ‘it can be shown that there is an exceptional need for the development which overrides the value of the local nature conservation resource and measures will be taken to minimise impacts and fully compensate for remaining adverse effects. ‘POLICY CO11 The District Planning Authority will not give permission for development if it is likely to endanger plant or animal life (or its habitat) protected under law and/or identified as a UK Biodiversity Action Plan priority species or cause the loss of, or damage to, habitats and landscape features of importance for nature conservation, unless; ‘there is a need for development which outweighs these nature conservation considerations and ‘measures will be taken to minimise impacts and fully compensate for remaining adverse affects.’ 7.3. In addition, the draft Shepway Core Strategy is also a material consideration. It contains the following descriptions of its preferred options relating to the natural environment: ‘The Preferred Option (Green) ‘The preferred option (SO3) is for the Core Strategy to place the impact of climate change and environmental sustainability at the heart of its proposed policies by: Kent Wildlife Trust Proof of Evidence Page 11 of 48 KWT/3/A ‘Renewing and shaping the places and spaces where people live, work and play by securing the highest viable natural resource (especially land, water and energy) efficiency practicable and delivering a reduction in carbon emissions when providing the homes, jobs, services, open spaces and other infrastructure needed by communities. ‘Conserving and enhancing biodiversity especially as a collective system across the ‘natural network’ of Shepway and stretching into adjoining districts in line with SE Plan policy CC8. This recognises that the distribution of habitats and species will be affected by climate change and placing a greater emphasis on conserving, enhancing and managing our diverse and high quality landscape resources (and in accordance with national policy e.g. PPS9 and PPS7). ‘Securing new development and shaping places that minimise vulnerability and provide resilience to climate change; both in rural areas and through urban green space and without exacerbating social inequalities. ‘GS1 - Green Infrastructure ‘The preferred option is for the Core Strategy to take an integrated approach to Green Infrastructure, in addition to specific preventative measure to tackle climate change. Further work will be undertaken to ensure the Core Strategy sets out a holistic framework for the enhancement and protection of strategic landscapes (possibly including the urban-rural fringe), biodiversity opportunities for new habitats and improvements of linkages to mitigate against ‘coastal squeeze’ processes, and the network of open spaces. ‘The Core Strategy will establish a clear commitment to plan for green infrastructure, and identify broad opportunities to further develop in the LDF (future Local Development Document). For example, this could involve continuing to define local landscape areas in future (additional Kent Wildlife Trust Proof of Evidence Page 12 of 48 KWT/3/A areas to the Kent Downs), and ensuring strategic areas of change contribute to habitat connectivity. The Core Strategy will aim to identify and protect key sites, habitats and species, both in their own right and where they form part of an existing or potential wildlife corridor, including with regard to cross-boundary habitats. The preferred option is to identify broad pathways for large-scale habitat preservation and restoration and the enhancement and/or establishment of stepping stones or wildlife corridors, in order to create a coherent ecological network which addresses strategic biodiversity conservation priorities and issues, such as the implications of sea level rises on coastal environments.’ 8. Nationally significant plant species affected by the proposals 8.1. It is clear that a large number of plant and invertebrate species of high conservation significance occur, in association with shingle habitats, including vegetated shingle and scrub, at Dungeness. A list of those which I have been able to identify from existing data sources is included in Appendix 6. 8.2. It has proved extremely difficult to identify which of these species (or other plant species) might be affected by the proposals, since the plant survey work undertaken in support of the planning application has been extremely limited and does not cover in detail every area likely to undergo direct change, or to be subject to other pressures, such as nitrogen deposition. 8.3. Only two terrestrial plant surveys appear to have been carried out: 8.3.1. An extended Phase 1 habitat survey which listed some plant species within target notes, and which was carried out in June 2005 (Section 10.2A of the appendices to the original Environmental Statements); and Kent Wildlife Trust Proof of Evidence Page 13 of 48 KWT/3/A 8.3.2. A more detailed survey of habitats within a 200m radius of the main pond, undertaken in June 2005 (Section 10.2B of the appendices to the original Environmental Statements). 8.4. Although the original Environment Statement refers (in 10.3.5) to other targeted botanical surveys, I have been unable to find the results of these within the appendices or subsequently submitted documents. These surveys are said to include: 8.4.1. Ditches located to the south-east of the runway which provide potential habitat for uncommon species such as Divided Sedge, Yellow Vetch and Marsh Mallow; 8.4.2. Vegetated shingle to the south and east of the runway which could support interesting ecological assemblages including Cladonia lichens; and 8.4.3. 8.5. Open ponds across the eastern part of the site. The approximate area covered by the detailed survey within 200m of the pond is shown in Figure 1. This is clearly only a small proportion of the area of potential interest identified in the Phase 1 survey. Other information suggests that the Phase 1 survey itself failed to cover a sufficient area. For example, it appears to have excluded land at Lydd Ripe, which supports an acid grassland community of county importance, which includes Shepherd’s Cress and Annual Knawel, and which would apparently be impacted by increased nitrogen deposition (figure 7 of the LAA Nitrogen Depositions Assessment of December 2009 shows that at least half of Lydd Ripe, and probably more than half of the existing grassland on the site, would receive at least an extra 0.1kg of nitrogen each year as a result of the proposals). Kent Wildlife Trust Proof of Evidence Page 14 of 48 KWT/3/A Figure 1 Approximate area covered by botanical survey which accompanied the original Environmental Statement, as described in the relevant report. Base map is the Phase 1 survey target map from the original Environmental Statement. Kent Wildlife Trust Proof of Evidence Page 15 of 48 KWT/3/A 8.6. The planning proposals include direct loss of over 1000m of existing ditches. However, the only survey carried out was a version of the Environment Agency’s River Habitat Survey methodology, and specifically did not include compilation of an inventory of plant species (Section 10.2E of the appendices to the original Environmental Statements). Submerged plants, for example, do not appear to have been searched for, and full identification of some floating species was not carried out. For example, for section 18 of the ditches surveyed, the report notes: ‘Channel Vegetation Floating Potamogeton pond-weeds and occasional Water Plantain submerged oxygenating vegetation (not specifically identified) ‘Amount of Floating Vegetation (mainly duckweed) Small amounts seen’ 8.7. It is not clear whether the ‘Vegetation species list’ included in the report of the ditch survey includes all species encountered, or just a selection of the most easily noted species. That no greater attention was paid to identifying the species occurring in the ditches likely to be affected by the proposals is surprising, given that they all fall within a SSSI which is specifically designated, inter alia, for its wetland habitats and its rare and scarce plants. 8.8. Therefore, what can be said for certain is that the following nationally important plant species occur in areas likely to be directly and indirectly affected by the proposals: 8.8.1. Divided Sedge, Carex divisa. Recorded as occurring on vegetated shingle around ‘the pond’ in Section 10.2B of the appendices to the original Environmental Statements. It therefore appears likely to occur in areas which would be affected by the establishment and/or maintenance of the area to be cleared for the instrument Kent Wildlife Trust Proof of Evidence Page 16 of 48 KWT/3/A landing system; however, this is slightly unclear from the survey data. Divided Sedge is a section 41 species of principal importance for the conservation of biodiversity in England. It is classified as Vulnerable in the UK Red List: a taxon is Vulnerable when it is considered to be facing a high risk of extinction in the wild, based on best available evidence and assessment against identified criteria. 8.8.2. Dodder, Cuscuta epithymenum. Recorded as occurring on vegetated shingle around ‘the pond’ in Section 10.2B of the appendices to the original Environmental Statements. It appears likely to occur in areas which would be affected by the establishment and/or maintenance of the area to be cleared for the instrument landing system; however, this is slightly unclear from the survey data, though this species is noted as being ‘very abundant in the survey area on wood sage in the vegetated shingle areas’ in the plant survey (Appendix 10.2B of the original Environmental Statement). Dodder is classified as Vulnerable in the UK Red List. Dodder is also one of the 100 plant species noted in the New Atlas of the British and Irish Flora (Preston et al, 2002) as having undergone the greatest relative decline: see Appendix 7. Dodder is the foodplant of the nationally rare weevil Smicronyx coecus which in Kent occurs only at Dungeness. 8.8.3. Nottingham Catchfly, Silene nutans. Although not recorded in the plant survey undertaken to support the original planning submission, this species is known to occur close to the airport. For example, Morris & Parsons (1993) (see Appendix 8) present a map showing use of this species by Coleophora galbulipenella (C. otitae) on sites close to the existing runway. The species is also mentioned in the target notes of the Phase 1 habitat survey (Appendix 10.2A of the original Environmental Statement). It appears to occur in areas which would be affected by the establishment and/or maintenance of the area to be cleared for the Kent Wildlife Trust Proof of Evidence Page 17 of 48 KWT/3/A instrument landing system. Nottingham Catchfly is classified as ‘Near Threatened’ in the UK Red List: a taxon is Near Threatened when it has been evaluated against the criteria but does not qualify for Critically Endangered, Endangered or Vulnerable now, but is close to qualifying for or is likely to qualify for a threatened category in the near future. Nottingham Catchfly is the only host plant for the nationally endangered moth Coleophora galbulipenella, which in the UK is only known from Dungeness and Hythe Ranges, and the nationally rare and UK BAP Priority White Spot moth. 8.8.4. Shepherd's Cress, Teesdalia nudicaulis. Noted during the plant survey (Section 10.2B of the appendices to the original Environmental Statements). It therefore appears likely to occur in areas which would be affected by the establishment and/or maintenance of the area to be cleared for the instrument landing system; however, this is slightly unclear from the survey data. It is classified as ‘Near Threatened’ in the UK Red List. Shepherd’s Cress is a host of the nationally scarce weevil Ceutorhynchus pumilio. 8.8.5. Annual Knawel, Scleranthus annuus. This species was not found during the survey work undertaken to inform the planning applications; however, it is known to occur within acid grassland at Lydd Ripe, where I have observed it. It is a section 41 species of principal importance for the conservation of biodiversity in England. Annual Knawel is classified as ‘Endangered’ in the UK Red List: a taxon is Endangered when it is considered to be facing a very high risk of extinction in the wild, based on best available evidence and assessment against identified criteria. Annual Knawel is also one of the 100 plant species noted in the New Atlas of the British and Irish Flora (Preston et al, 2002) as having undergone the greatest relative decline (see Appendix 7); in fact it is actually within the top twenty in this list. Kent Wildlife Trust Proof of Evidence Page 18 of 48 KWT/3/A 8.9. It is possible that a number of other significant species would have been discovered had more detailed plant survey been undertaken. These include: 8.9.1. Yellow Vetch, Vicia lutea. Target note TN48 of the Phase 1 habitat survey notes the presence of ‘yellow vetch (possibly)’ in an area close to the existing runway, where it may be vulnerable to works associated with the planning proposals. This species is classified as ‘Near Threatened’ in the UK Red List. 8.9.2. Red Hemp-nettle, Galeopsis angustifolia. An annual which occurs on the shingle at Dungeness. It flowers from July onwards and mature plants may be small, so that it could have been overlooked in the Phase 1 habitat survey. It is a section 41 species of principal importance for the conservation of biodiversity in England. Red Hemp-nettle is classified as ‘Critically Endangered’ in the UK Red List: a taxon is Critically Endangered when it is considered to be facing an extremely high risk of extinction in the wild, based on best available evidence and assessment against identified criteria. It is also one of the 100 plant species noted in the New Atlas of the British and Irish Flora (Preston et al, 2002) as having undergone the greatest relative decline (see Appendix 7); like Annual Knawel, it is within the top twenty in this list. Red Hemp-nettle is the host of the nationally endangered leaf-beetle Dibolia cynoglossi. 8.9.3. Rootless duckweed, Wolffia arrhiza. It is noted in the SSSI schedule and known to occur in ditches in the Romney Marsh area. It is a small plant (the UK’s smallest flowering plant), and, given that, during the ditch survey, floating vegetation does not appear to have been closely searched or identified to species, it may have been overlooked. It is classified as Vulnerable in the UK Red List. Kent Wildlife Trust Proof of Evidence Page 19 of 48 KWT/3/A 9. The pressures on these plants 9.1. There are three potential vectors of impact upon the plant species listed above arising from the development proposals. These are: 9.1.1. Direct loss of habitat. 9.1.2. Competitive disadvantage arising from increased nutrient deposition from aerial sources or from run-off. 9.1.3. 9.2. Other pollution of water bodies. In respect of direct loss of habitat, and pollution of water bodies, there is potential for impact on rootless duckweed, since this species may occur in the ditches directly or potentially indirectly affected by the proposals. No survey has been carried out which would allow this potential impact to be assessed. 9.3. In respect of the potential impacts of nitrogen deposition, it is notable that the list of important plant species set out above includes a suite of species associated with soils of low fertility. 9.4. To understand this, it is possible to use Ellenberg Indicator Values, which provide an assessment, for a very wide range of species, of the sensitivity of those species to certain environmental values, including, for example, available nitrogen (equivalent to soil fertility), light, soil moisture, etc. For this purpose, I have used outputs from the ECOFACT project, which provides updated Ellenberg values more appropriate to the British situation (see Appendix 9). 9.5. The scale for nitrogen is as below: 1 – Indicator of extremely infertile sites 2 – Between 1 and 3 Kent Wildlife Trust Proof of Evidence Page 20 of 48 KWT/3/A 3 – Indicator of more or less infertile sites 4 – Between 3 and 5 5 – Indicator of sites of intermediate fertility 6 – Between 5 and 7 7 – Plant often found in richly fertile places 8 – Between 7 and 9 9 – Indicator of extremely rich situations, such as cattle resting places or near polluted rivers 9.6. Of the species listed above, Annual Knawel, Red Hemp-nettle and Nottingham Catchfly have a score of 4; and Dodder and Shepherd’s Cress have a score of 2. These plants would therefore be considered to be vulnerable to increased nitrogen deposition arising from the airport proposals. 9.7. Nationally, increased nitrogen levels in soils is recognised as one of the most important drivers in change in populations of wild plants. In Preston et al (2002), it is noted that ‘If the tiny sample of species in the category N9 is ignored, the species which have been most successful are those with the highest nutrient requirements (N8), and the species with relatively high nutrient requirements (N5-8) all have a positive change index. By contrast, the species which tend to occur in areas with low levels of nutrients (N1-4) all show a relative decline.’ (See Appendix 7a). 9.8. That nutrient enrichment is a significant concern for the conservation of wild plants is reinforced in the Change in the British Flora 1987 – 2004 (Braithwaite et al, 2006). This book reports a statistical study which used a repeated sampling method to establish absolute change in plant distributions. The executive summary (see Appendix 10) notes that there has been a loss of species of infertile habitats, and that reasons for this include eutrophication. 9.9. For the plant species listed above, there are no established critical loads for deposition of nitrogen. The Centre for Ecology and Hydrology website is Kent Wildlife Trust Proof of Evidence Page 21 of 48 KWT/3/A clear that the critical loads established for habitats cannot be applied to species occurring within those habitats See Appendix 11. It states (http://critloads.ceh.ac.uk/caveats.htm): ‘Critical load maps have been developed to give a national picture of the relative sensitivity of soils, selected broad habitats and freshwaters, to acidification and/or eutrophication. ‘National critical load maps and data sets were never intended for small, local scale, or site-specific assessments of risk. ‘In general, dose-response relationships have not been developed in the UK for the application of critical load models to specific individual species … ‘Empirical critical loads of nutrient nitrogen have been set on the basis of observed and published changes in structure or function of ecosystems using experimental (field) data, field observations and/or dynamic ecosystem models. However, the critical load values will not necessarily protect all habitats/species within each ecosystem, since data are not available for all habitats/species.’ 9.10. Of the plants listed above, Shepherd’s Cress, Dodder, Red Hemp-nettle and Nottingham Catchfly are particularly associated with vegetated shingle at Dungeness. There is a total of 609ha of vegetated shingle within the Dungeness, Romney Marsh and Rye Bay SSSI. However, of this, only 318ha is within areas of the SSSI which are considered to be in favourable condition, much of the remainder having been damaged by past activities, including, for example, military operations on the Lydd Ranges. 9.11. The area of vegetated shingle which would be affected by the proposals is as follows; although some of the figures (though by no means all) appear small in absolute terms, they are nonetheless significant given the importance of the site and the species it supports: Kent Wildlife Trust Proof of Evidence Page 22 of 48 KWT/3/A 9.11.1. The runway instrument strip includes approximately 3ha of vegetated shingle (0.5% of all vegetated shingle, 0.9% of shingle in favourable condition). 9.11.2. With 300,000 passenger movements a year, approximately 8.7ha of vegetated shingle (1.4% of all vegetated shingle, 2.7% of shingle in favourable condition) would receive an additional 0.1 kg/ha/yr of nitrogen depostition. 9.11.3. With 500,000 passenger movements a year, approximately 13.4ha of vegetated shingle (2.2% of all vegetated shingle, 4.2% of shingle in favourable condition) would receive an additional 0.1 kg/ha/yr of nitrogen deposition, and approximately 5.2ha (0.8% of all vegetated shingle, 1.6% of shingle in favourable condition) would receive an additional 0.2 kg/ha/yr of nitrogen deposition. 10. Nationally significant invertebrate species affected by the proposals 10.1. J. W. & B. Ismay, in their Comments on the planning applications (Y06/1647/SH and Y06/1648/SH) for Lydd Airport, and subsequent submissions submitted in support of representations by Lydd Airport Action Group (see Appendix 21a-c), note that 421 invertebrate species of conservation concern were noted by certain authors as occurring on shingle at Dungeness. These included species listed in the UK Red Data Books or considered nationally scarce. The Trust has carried out its own desk-top search, using records held by Kent and Medway Biological Records Centre, documents associated with the SSSI citation, and information provided as part of the planning proposals for Lydd Airport. Kent Wildlife Trust Proof of Evidence Page 23 of 48 KWT/3/A 10.2. The documents authored by the Ismays provide a thorough critique of the invertebrate surveys carried out to inform the planning proposals. In particular: 10.2.1. The area covered by invertebrate survey was limited in extent and excluded areas potentially of significant interest for invertebrate species, either because of the nature of the habitat or the presence of host plant species. 10.2.2. Only a limited range of taxa were covered by the surveys, with specimens of Diptera (flies) and Hymenoptera (bees, wasps and ants), which are both important groups at Dungeness, being collected but not identified. The survey does not appear to have targeted spiders, another highly important group at Dungeness. 10.2.3. Only three days of field work were spent on the survey. Natural England’s guidance is for three to five field days for a site of 10 to 50 hectares. The area directly affected by the planning proposals is considerably larger than this at more than 80ha, while the total area which might be directly or indirectly affected is larger still. 10.3. The following species are known to occur in areas likely to be affected by the planning proposals: 10.3.1. Dungeness Pigmy Footman moth, Eilema pygmaeola ssp pallifrons. This subspecies (some authors have suggested that it it as form rather than a subspecies) of the Pigmy Footman moth is known only from Dungeness and does not appear to have been found anywhere else in the world. It feeds on lichens and was recorded during the moth survey carried out in July 2008 (Appendix 1 of the Supplementary Environmental Information of August 2008). Red Listed (under the pre 1994 IUCN Guidelines) as Endangered (RDB1). Kent Wildlife Trust Proof of Evidence Page 24 of 48 KWT/3/A 10.3.2. Coleophora galbulipenella (C. otitae). A case-bearing moth which, in the UK, is only known from Dungeness and Hythe Ranges. Its larva feeds on Nottingham Catchfly, and it occurs close to the existing runway at Lydd Airport (Morris & Parsons, 1993, Appendix 8). Red Listed (under the pre 1994 IUCN Guidelines) as Endangered (RDB1). 10.3.3. Cynaeda dentalis (a moth). The best known site for this moth is Dungeness, where it extends to Lydd Ranges and Greatstone. The larvae feed in the stems of Viper's Bugloss. Recorded during the 2008 moth survey carried out to provide data for the planning proposals (Appendix 1 of the Supplementary Environmental Information of August 2008). Red Listed (under the pre 1994 IUCN Guidelines) as Rare (RDB3). 10.3.4. Hydrochus elongatus (a beetle). Found during the ditch invertebrate survey of 2007. Red Listed (under the pre 1994 IUCN Guidelines) as Rare (RDB3). 10.3.5. Great Silver Water Beetle, Hydrophilus piceus. Found during the ditch invertebrate survey of 2007. Red Listed (under the pre 1994 IUCN Guidelines) as Rare (RDB3). 10.3.6. Graptodytes bilineatus (a water beetle). Found during the ditch invertebrate survey of 2007. Since 1970, it has been found only at Dungeness and in West Suffolk. Red Listed (under the pre 1994 IUCN Guidelines) as Rare (RDB3). 10.3.7. Enochrus isotae (a water beetle). Found during the ditch invertebrate survey of 2007. Red Listed (under the pre 1994 IUCN Guidelines) as Rare (RDB3). Kent Wildlife Trust Proof of Evidence Page 25 of 48 KWT/3/A 10.3.8. Odontomyia ornata (a fly). Found during the ditch invertebrate survey of 2007. Red Listed (under the pre 1994 IUCN Guidelines) as Vulnerable (RDB2). 10.3.9. Brown-Banded Carder Bee, Bombus humilis. One of a number of threatened bumblebee species for which Dungeness is important. Vunerable to loss and fragmentation of suitable habitat. Noted as present during the invertebrate survey of 2005. This is a priority species under the UK Biodiversity Action Plan, and identified as being of principal importance for the conservation of biodiversity under the Natural Environment and Rural Communities Act 2006. 10.3.10. Moss Carder Bee Bombus muscorum. One of a number of threatened bumblebee species for which Dungeness is important. Vunerable to loss and fragmentation of suitable habitat. Noted as present during the invertebrate survey of 2005. This is a priority species under the UK Biodiversity Action Plan, and identified as being of principal importance for the conservation of biodiversity under the Natural Environment and Rural Communities Act 2006. 10.4. In addition, available data suggests that the species listed in 10.5 to 10.9, below, may occur in areas potentially affected by the planning proposals. A list of those which I have been able to identify from existing data sources is included in Appendix 6. 10.5. Endemic species, unknown from any other location on the planet, but listed as Insufficiently Known (RDBK) under pre 1994 Red List guidelines: 10.5.1. Aphrodes duffieldi (a leafhopper). This species was first found at Dungeness. It has been suggested that it is conspecific with (i.e. is the same species as) a European species called Aphrodes Kent Wildlife Trust Proof of Evidence Page 26 of 48 KWT/3/A alpinus. However, Mr John Badmin, the prominent Homopteran specialist who has probably done most work on this species, believes that this is not the case, and has written in a personal communication to me that ‘The [Royal Entomological Society] Handbook suggests A. duffieldi might be synonymous with A. alpinus but it clearly isn’t. I’ve looked at the original description of alpinus in [the Natural History Museum, London] and although the illustration is challenging, [it] isn’t the same species’. It is therefore clearly most appropriate to treat this species as endemic, with its known world distribution being confined to the vegetated shingle ridges of Dungeness. Maps of the distribution of A. duffieldi, as recorded during a survey in 2000 by Mr Badmin, are included in Appendix 12. They show the nearest confirmed records as being just over 1000m from the existing Lydd Airport runway, and that A. duffieldi was recorded in 4 of the 55 pit-fall traps placed on the site as well as occurring closer to the shore. 10.5.2. Pale Grass Eggar moth, Lasiocampa trifolii ssp flava. The larvae are polyphagous on low growing herbs and small shrubs. The subspecies flava (some authors regard it as a form rather than a subspecies) is confined to the shingle. Because many of the host plants occur close to or within the existing airport boundary, there is every reason to believe that this insect may occur here. Adults fly in August and September, and therefore would have been missed by the moth survey. 10.6. Priority species under the UK Biodiversity Action Plan, and identified as being of principal importance for the conservation of biodiversity under the Natural Environment and Rural Communities Act 2006: 10.6.1. Dark Guest Ant, Anergates atratulus. In Britain, this species appears to be confined to the heaths of Dorset, the New Forest, the coast of south Devon, Dungeness, and Surrey. It is a parasite Kent Wildlife Trust Proof of Evidence Page 27 of 48 KWT/3/A of the ant Tetramorium caespitum, which occurs widely on Dungeness, and there are therefore grounds to suspect it may occur in or around the airport. Also listed as Rare (RDB3) in the UK Red List under pre 1994 guidelines. 10.6.2. Temnothorax interruptus (a slender-bodied ant), known only from heathland in Dorset and the New Forest, from Hayling Island and from Dungeness. It nests under moss, lichens or small stones, or amongst plant roots, in warm dry open areas with sparse vegetation, and may therefore occur at or near the airport. Also listed as Rare (RDB3) in the UK Red List under pre 1994 guidelines. 10.6.3. Red-shanked Carder Bee Bombus ruderarius. One of a number of threatened bumblebee species for which Dungeness is important. Vunerable to loss and fragmentation of suitable habitat. Dungeness is likely to remain an important site for this species. 10.6.4. Large Garden Bumble Bee Bombus ruderatus. One of a number of threatened bumblebee species for which Dungeness is important. Vunerable to loss and fragmentation of suitable habitat. Dungeness is likely to remain an important site for this species. 10.6.5. Shrill Carder Bee Bombus sylvarum. One of a number of threatened bumblebee species for which Dungeness is important. Vunerable to loss and fragmentation of suitable habitat. It has been recorded at Dungeness during 2010. 10.6.6. White Spot moth, Hadena albimacula. The best known UK colony is at Dungeness; there are others at Dover and Hythe Ranges; it is confined to sites on the south coast where its larval host plant, Nottingham Catchfly, grows. Listed as Rare (RDB3) in the UK Red List under pre 1994 guidelines. Although this Kent Wildlife Trust Proof of Evidence Page 28 of 48 KWT/3/A species will come to light traps, its flight period ends at the time the moth surveys were carried out, with peak numbers flying in May. It could therefore have easily been overlooked. 10.6.7. Sandwich Click Beetle Melanotus punctolineatus. During the 20th Century, this species has been regularly taken only from the east Kent coast between Sandwich Bay and Littlestone. Larvae are found at the roots of Marram Grass, which occurs on Lydd Ripe. Listed as Endangered (RDB1) in the UK Red List under pre 1994 guidelines. 10.7. Species listed as Endangered (RDB1) in the UK Red List under pre 1994 guidelines: 10.7.1. Tinagma balteolella. A moth which in the UK is restricted to the extreme south-east of England. It is found at Dungeness, Greatstone and Sandwich. It occurs on coastal sand dunes and shingle where the larvae feed on Viper's Bugloss, a commonly occurring plant. 10.7.2. Polyodaspis sulcicollis. A grass fly which in the UK has been found only at Dungeness. 10.7.3. Apostenus fuscus, a spider occurring on thinly vegetated shingle at Dungeness and not from any other sites in the UK. 10.7.4. Pellenes tripunctatus, a jumping spider occurring on sparsely vegetated shingle at Dungeness and otherwise in the UK only from Folkestone. 10.7.5. Dibolia cynoglossi, a flea beetle found in only a few locations in the UK; at Dungeness it is associated with Red Hemp-nettle, on which its larvae feed. Kent Wildlife Trust Proof of Evidence Page 29 of 48 KWT/3/A 10.7.6. Pilophorus confusus, a true bug associated with Creeping Willow; as this plant was found during surveys carried out in association with the planning proposals, the bug may also occur close to the development site. Dungeness is one of only two known UK sites for this species. 10.7.7. Evagetes pectinipes, a spider-hunting wasp which is restricted in the UK to Dungeness and the Sandwich/Deal coast. 10.7.8. Nomada ferruginata, a cuckoo bee which is still formally Red Listed under pre 1994 IUCN Guidelines as Endangered (RDB1), but which has undergone a recent increase in distribution. However, in Kent, it is only known from Dungeness. 10.8. Species listed as Vulnerable (RDB2) in the UK Red List under pre 1994 guidelines: 10.8.1. Tachydromia terricola (a fly). The citation document for the SSSI notes that Dungeness is the only locality for this species in the UK. It was added to the UK list from specimens taken at Lydd in the early 1970s. 10.8.2. Gelechia muscosella (a moth). Dungeness is one of the few sites in the UK where this species occurs. Its larvae are thought to feed on catkins of Sallow species. 10.8.3. Trichonchus affinis (a spider). A spider that is found on shingle, amongst the roots of sparse vegetation. 10.8.4. Trichopterna cito (a spider). In Kent this species is found only at Sandwich Bay and Dungeness. Also known from northern and eastern Essex. It has been found to occur among moss and grass on old sand dunes and among sparse vegetation on sandy shingle. Kent Wildlife Trust Proof of Evidence Page 30 of 48 KWT/3/A 10.8.5. Ethmia bipunctella (a moth). Found on shingle, where the larvae feed on Viper’s Bugloss, a common plant at Dungeness. Common at Dungeness, Greatstone, Lydd & Sandwich. 10.8.6. Ethmia terminella (a moth). Another species which uses Viper’s Bugloss on shingle sites, and found at Dungeness, Lydd and Folkestone Warren, where it is fairly common. 10.9. Species listed as Rare (RDB3) in the UK Red List under pre 1994 guidelines: 10.9.1. Euophrys browningi (a jumping spider). A species of shingle habitats which has been recorded at Lydd Ranges. 10.9.2. Apion rubiginosum (a weevil). This weevil is found on disturbed ground, grassland and coastal shingle, where the larvae occur in galls on the roots of Sheep’s Sorrel. 10.9.3. Cantharis fusca (a soldier beetle). There are records for Lydd Ranges and Dungeness from the 1980s. This species has been found in fens, on wood edges, on coastal shingle. 10.9.4. Ceutorhynchus verrucatus (a weevil). Found at, or inside, the roots of Yellow Horned Poppy on coastal shingle. It has been found on Lydd Ranges and at West Ripe on Dungeness. 10.9.5. Dromius vectensis (a ground beetle). A species which inhabits vegetated, dry sand and shingle and has been found at the roots of grasses, under litter on wet, saline mud and under old broom bushes. 10.9.6. Dryophilus anobioides (a beetle). This beetle is found on healthland, scrub, coastal shingle, road verges and disturbed ground, where larvae develop in the dead stems of Broom and, Kent Wildlife Trust Proof of Evidence Page 31 of 48 KWT/3/A very rarely, Bramble. The species usually occurs in exposed, sandy locations. 10.9.7. Hylaeus euryscapus (H. spilotus) (a yellow-faced bee). Records are almost exclusively confined to southern coastal areas including Dorset, Hampshire, Sussex, Kent and Suffolk. Records in Kent are concentrated around the Dungeness area, with several other records in the Deal and Sandwich Bay areas. 10.9.8. Minettia flaviventris (a fly). Recorded from Dungeness as recently as 1988. Adults fly in July and August in unimproved meadows, wood edges and marshes. 10.9.9. Monosynamma maritima (a true bug). Sandwich Bay and Dungeness are the only confirmed British sites for this species. It occurs on Creeping Willow (which was recorded close to the airport in the plant survey reported in Section 10.2B of the appendices to the original Environmental Statements) on sand and shingle. 10.9.10. Passaloecus clypealis (a solitary wasp). Associated with common reed beds in fens and in the ditches and reedbeds of coastal marshes. 10.9.11. Phlegra fasciata (a jumping spider). Known from Lydd Ranges, Dungeness and Sandwich Bay. Found on dunes and on vegetated and open shingle. Has been taken from under Broom bushes. 10.9.12. Smicronyx coecus (a weevil). Recorded recently from Dungeness and the Lydd Ranges, where it was noted as common on a few patches of Dodder. This host plant was noted during the plant survey reported in Section 10.2B of the appendices to the original Environmental Statements. S. coecus only occurs on Dodder and Kent Wildlife Trust Proof of Evidence Page 32 of 48 KWT/3/A the closely related Greater Dodder, though the latter species does not occur in Kent; S. coecus is not found elsewhere in Kent. 10.9.13. Lathys stigmatisata (a spider). A species found among low vegetation and Willow scrub on shingle. In Kent occurs only at Dungeness, but also found at a few sites in East Sussex and the West Country. 10.9.14. Toadflax Brocade, Calophasia lunula. Until recently restricted to the south-east and central southern coasts of England, but now apparently spreading. In Kent, it has been found at Dungeness and along the coast to Folkestone, with records from Dover, Kingsdown and Sandwich. Larvae feed on Common Toadflax, a widespread species. Listed as Rare (RDB3) in the UK Red List under pre 1994 guidelines. The moth surveys fell between the flight periods of the two annual generations of this moth, and it could therefore have easily been overlooked. 10.10. Of the invertebrate species listed above, 21 are specifically associated with shingle or with plant species growing on shingle at Dungeness. The areas of shingle potentially affected by the proposals are set out above in paragraph 9.11. 10.11. Of the invertebrate species set out above, eighteen are herbivorous. These are: Aphrodes duffieldi Ethmia bipunctella Apion rubiginosum Ethmia terminella Calophasia lunula Hadena albimacula Ceutorhynchus verrucatus Lasiocampa trifolii ssp flava. Coleophora galbulipenella Monosynamma maritima Cynaeda dentalis Smicronyx coecus Dibolia cynoglossi Tinagma balteolella Eilema pygmaeola ssp pallifrons Kent Wildlife Trust Proof of Evidence Page 33 of 48 KWT/3/A 10.12. These species could therefore be impacted by increased nitrogen deposition where this is damaging to the structure of plant communities, or where this has an impact on the availability of their host plants. I have already seen that some of these species, such as Dodder, are highly sensitive to soil fertility, and that critical load values do not necessarily protect all species within habitats for which such values are available. It is therefore not reasonable to assume that the occurrence of a particular plant species within a habitat will be unaffected provided that the critical load for that habitat is not exceeded. 10.13. In the case of herbivorous invertebrates, the matter is further complicated by the fact that the availability of nitrogen to a plant can affect the relationship between that plant and its predators. Most research on this subject appears to relate to the influence of available soil nitrogen on agricultural and forestry pest species, and generally deals with high nitrogen levels associated with such practices. However, Throop and Lerdau (2004) provide a useful review on the effects of nitrogen deposition on insect herbivory (Appendix 12a). Although the authors note that in most cases studies have shown positive impacts on insect populations from increased nitrogen uptake by their host plants, they also note that in some cases herbivorous insects experience higher rates of predation under higher rates of nitrogen deposition. In addition, they note (Appendix 12a, page 6) that ‘there appears to be an optimal N concentration in host foliage for most insects, and decreased performance is likely when tissue N exceeds this level … The optimal foliar N concentration seems to differ greatly among different insect herbivores. For example, in an experiment where common ragweed (Ambrosia artemisiifolia) was grown under varying N levels, cabbage looper (Trichoplusia ni) larvae had greatest survival under the highest foliar N (6.76% N), whereas the survival rates of larvae of a leaf beetle, Ophraella communa, declined as foliar N rose above the lowest foliar N concentration (2.20% N).’ Kent Wildlife Trust Proof of Evidence Page 34 of 48 KWT/3/A 10.14. They also note (Appendix 12a, page 15) that ‘Insect feeding guilds or individual herbivore species may respond differently to deposition-induced changes in the quality of the host plant, leading to changes in the relative abundance of herbivore species.’ This change in relative abundance is separate to changes arising due to nitrogen-induced change in the composition of vegetation 10.15. Prestidge (1982) reports research on the responses of four different species of leafhoppers (the group of bugs to which Aphrodes duffieldi belongs); see Appendix 12b). He notes in his abstract that ‘Each species reached maximum nitrogen utilization efficiencies at different plant nitrogen levels. This suggests that leafhopper species may be associated with a particular nitrogen concentration in the grasses.’ 10.16. It is clear from this that increased nitrogen availability is therefore not necessarily beneficial to plant-feeding invertebrates. All that can be said with certainty is that increased nitrogen availability may mean changes in plant-predator interactions and that these may be positive or negative for individual species of invertebrate, and that species adapted to low nitrogen availability may decline in performance as nitrogen availability increases. 10.17. I have been able to find no research which suggests that critical loads for nitrogen deposition can be used to judge when changes may or may not occur in plant-predator interactions. Throop and Lerdau specifically note (p127) that ‘Many questions remain regarding how individual insects will respond to N deposition. In particular, studies using multiyear low-level treatments (for example, 5–30 kg N ha-1 y-1) would increase our knowledge of how chronic low-level deposition affects insect herbivory and the different ways in which insects respond to atmospheric N deposition versus agricultural-level N fertilization.’ 10.18. Of the species on invertebrate listed above, the following eleven are moth species which are known to be attracted to light: Kent Wildlife Trust Proof of Evidence Page 35 of 48 KWT/3/A Eilema pygmaeola ssp pallifrons (Pigmy Footman) Cynaeda dentalis Lasiocampa trifolii ssp flava (Pale Grass Eggar) Hadena albimacula (White Spot) Calophasia lunula (Toadflax Brocade) Coleophora galbulipennella Gelechia muscosella Ethmia bipunctella Ethmia terminella 10.19. It is well established that a very large proportion of moth species have undergone substantial population declines over recent decades. Fox et al (in Maclean (ed) 2010) (see Appendix 13) discuss this, and identify light pollution as a potentially serious problem for moths. Frank (1988) provides an important review of the potential impacts of artificial light upon moths (see Appendix 14), and notes that impacts may be particularly damaging where populations of a species are small and localised. 10.20. Authors on this subject, including Frank, have suggested that impacts upon moth populations from artificial lighting might be ameliorated by use of low-pressure sodium lamps. However, more recent information (see the post-2003 publication by Butterfly Conservation on Light Pollution and Moths, Appendix 15) suggests that low pressure sodium lamps may also have negative impacts by preventing moths from flying. The Lighting Impact Assessment provided as part of the Supplementary Information of August 2008 notes that ‘research to date suggests a link between light pollution and falling nocturnal invertebrate populations’. 10.21. Longcore (2004) (see Appendix 16) refers to ecological light pollution, in order to differentiate between light pollution as perceived by humans and light pollution which has impacts on other species. Kent Wildlife Trust Proof of Evidence Page 36 of 48 KWT/3/A 11. Potential impacts in the absence of mitigation measures 11.1. It is impossible to fully assess the impact of the proposed developments in the absence of full survey data. However, it appears that there will be: 11.1.1. Loss of or disturbance to vegetated shingle through works to establish the instrument landing strip. This requires removal of obstructions, which may include host plants of rare or threatened invertebrate species, including the bugs Monosynamma maritima and Pilophorus confusus, and the moth Gelechia muscosella (a moth). The removal of obstructions may also prevent the development of the late growth stages of broom, which is identified in (for example) Philp and McLean as important for a number of scarce invertebrate species. 11.1.2. Loss of ditch habitat supporting some important invertebrate species, and also potentially supporting rare plants. 11.1.3. Additional deposition of nitrogen in areas supporting rare or threatened species known to be vulnerable to increased nitrogen availability, and potentially affecting interactions between plants and the invertebrates which feed on them. Particularly vulnerable are Dodder and Shepherd’s Cress and their associated invertebrates. If nitrogen levels are sufficient to affect interactions between plants and the invertebrates which feed on them, then there is a potential risk to the only populations on the planet of one bug species and two moth subspecies. 11.1.4. Increased lighting during the works and as a result of operation of the new terminal building in an area supporting a suite of rare and threatened moth species which are known to be attracted to light. Kent Wildlife Trust Proof of Evidence Page 37 of 48 KWT/3/A 11.2. The areas affected by these impacts are significant. For example, over 4% of the vegetated shingle in favourable condition is predicted to receive additional nitrogen deposition at a rate of more than 1% above the predicted baseline (i.e. over this area, the operation of the airport would contribute an additional 0.1 kg/ha/yr of nitrogen to produce a total deposition rate of 9 kg/ha/yr). 11.3. These impacts cannot be considered in isolation. Doody (1989) (Appendix 1) refers to the fact that some 60% of Dungeness’s shingle and its vegetation had already been destroyed by that time. The paper by Fuller (1985), from which this figure is drawn, is included in Appendix 17. Fuller’s paper shows that: 11.3.1. By 1958, 42.1% of the shingle vegetation present in 1946 had been destroyed. 11.3.2. By 1962, 44.6% of the shingle vegetation present in 1946 had been destroyed. 11.3.3. By 1984, 57.5% of the shingle vegetation present in 1946 had been destroyed. By this time, a further 19.8% of the original shingle vegetation was also damaged, and 42.5% of the shingle ridges themselves had been either destroyed or built on. 11.4. At present, a comparison of Natural England’s assessment of the condition of SSSI units at Dungeness with data from the Kent Habitat Survey shows that only 318ha of vegetated shingle out of a total of 609ha (i.e. 52%) is within units in favourable condition. 11.5. In addition, there has been loss of other important shingle habitat in Southern England which has increased the pressure on rare and threatened species. As noted in Philp and McLean (1985), the destruction of The Crumbles in Eastbourne (a former shingle bank now lost to built development) resulted in the loss of the only UK population of Sussex Kent Wildlife Trust Proof of Evidence Page 38 of 48 KWT/3/A Emerald outside Dungeness and the loss of the only population anywhere in the world outside Dungeness of Pale Grass Eggar. (The Sussex Emerald population at Dungeness occurs within the power station grounds. Mark Parsons of Butterfly Conservation, in a personal communication to me, notes that second, small UK colony of Sussex Emerald has apparently very recently been found at Deal on a site threatened by development). 11.6. It is not sufficient to argue that because Dungeness continues to support the rare and threatened species listed above, then it must still be in good condition despite past losses and ongoing pressures. For most species, it is simply the case that there has been no ongoing, quantitative work which would allow an assessment of past change in populations. 11.7. Such information as Kent Wildlife Trust has been able to find suggests that there may be ongoing declines in rare and threatened species. Data obtained from regular moth trapping and included in a report compiled by local expert Keith Redshaw (see Appendix 18) suggests that there have been declines in the total numbers of moths caught at Dungeness. For the rare and threatened species listed in this report, the following changes in numbers caught each year are reported: 11.7.1. Eilema pygmaeola ssp pallifrons (Dungeness Pigmy Footman). No change at Greatstone, down at Dungeness 11.7.2. Hadena albimacula (White Spot). Down at both Greatstone and Dungeness 11.7.3. Calophasia lunula (Toadflax Brocade). No change at Greatstone, down at Dungeness 11.8. Data on changes in the distribution of plants is available in the Atlas of the Kent Flora (Philp, 1982) and A New Atlas of the Kent Flora (Philp, 2010). Extracts from these publications giving distribution data for the following rare and threatened species is presented in Appendix 19. Kent Wildlife Trust Proof of Evidence Page 39 of 48 KWT/3/A 11.9. The two atlases are based on tetrad survey. That is, the recording unit is a 2km by 2km square of the UK National Grid. Only presence is noted, and no estimate is given of population size or extent within each tetrad. In both cases, every tetrad in Kent was visited. 11.10. The absence of a positive record for a tetrad does not necessarily mean that the plant is confirmed as absent. However, the surveys which provided the data for each atlas both involved considerable effort over a number of years (1971-1980 in the case of the 1982 atlas, and 1991-2005 in the case of the 2010 atlas). 11.11. In summary, the data in Appendix 19 is as follows: 11.11.1. Divided Sedge, Carex divisa. Appears to be declining in Kent, but relatively stable around Dungeness. 11.11.2. Dodder, Cuscuta epithymenum. Was recorded in 9 tetrads at and around Dungeness. Now it is present in only 7 tetrads. 11.11.3. Nottingham Catchfly, Silene nutans. Was recorded in 8 tetrads at and around Dungeness. Now it is present in only 6 tetrads. 11.11.4. Shepherd's Cress, Teesdalia nudicaulis. Stable at Dungeness, but apparently lost from sites at Hythe. 11.11.5. Annual Knawel, Scleranthus annuus. Apparently still present in sites at Dungeness and St Mary’s Bay where previously recorded, though it has undergone a massive decline in the rest of Kent. 11.11.6. Yellow Vetch, Vicia lutea. Was recorded from 6 tetrads at Dungeness and Lydd. Now it is only found in one. Kent Wildlife Trust Proof of Evidence Page 40 of 48 KWT/3/A 11.11.7. Red Hemp-nettle, Galeopsis angustifolia. Previously recorded in 6 tetrads at and around Dungeness. Now it is present only in 4, and apparently lost from all other Kent sites. 11.11.8. Rootless Duckweed, Wolffia arrhiza. Previous recorded from 18 tetrads on the Romney Marshes. Now it is only recorded from 6. 11.12. Tetrad data has to be used with care to assess population change, as populations can decrease or increase massively within a tetrad without this showing up in a survey of this kind. However, combined with what is known about the national status of these species, it is reasonable to assume that, at the very least, the apparent declines of species listed above warrant further investigation and that the greatest of care would need to be exercised in consideration of any proposals which might exacerbate decline. 11.13. On the basis of available data on moths and vascular plants, it does not appear to be safe to conclude that existing activities or environmental pressures at Dungeness have not had or are not having a negative impact. 11.14. Tables are provided in the Ecology Chapters of the respective Environmental Statements (tables 10.3 and 10.4 in each case) in order to explain how the significance of ecological impacts was assessed. Whatever the pedigree of thee tables, they do not seem useful, as they (a) rely on measures of relative change to extent and quality of habitats or populations of species, rather than absolute conservation status of habitats or species, and (b) set the bar at what appears to be a high level. 11.15. So, for example, the loss of 50% of a nationally important population would only be considered a moderate impact, while up to 19% of an internationally important habitat could be lost and only be assessed as a moderate impact. Given that some of the species occurring at Dungeness are found nowhere else in the UK, it would seem reasonable to regard the loss of half the local population as more than just a moderate impact. Kent Wildlife Trust Proof of Evidence Page 41 of 48 KWT/3/A 11.16. This method of assessing impacts also fails because it does not take account of cumulative impacts over time. After all, it might only take three consecutive, ‘moderate’ impacts to reduce a population to one-eighth of its original size. None of the impacts would in themselves be judged substantial, but it would not take long for a series of ‘moderate’ impacts to reduce a population to below its viable size and thus consign the population to extinction. There would come a time when even a ‘negligible’ loss of 5% of the population would be sufficient to reduce a population to below its minimum viable size. At Dungeness, there is the risk that we are already at that point, given the past habitat losses (which cumulatively have destroyed 60% of the previously existing vegetated shingle, and which have not subsequently been reversed) and the apparently on-going declines in at least some of the rare and threatened species of the site. 12. Proposed mitigation 12.1. It is not possible to make effective judgements about the proposed mitigation, as insufficient survey has been carried out to allow mitigation for all potential impacts to be formulated, and because some mitigation measures (such as light and air quality management) have yet to be drawn up and the Airfield Biodiversity Action Plan (ABAP) has not been finalised. 12.2. Some crucial elements of the proposed mitigation are of unproven efficacy. For example, the ABAP proposes a programme to foster Aphrodes duffieldi, ‘together with an appropriate methodology for the programme,’ without any indication of whether such a programme might be either affordable or practically possible. The same applies to other proposed measures for insects in the ABAP. Kent Wildlife Trust Proof of Evidence Page 42 of 48 KWT/3/A 13. Air quality matters 13.1. The air quality modelling undertaken by the applicants shows that at least 4% of the vegetated shingle in favourable condition would receive elevated levels of nitrogen deposition as a result of operation of the airport at 500,000 passenger movements a year. The applicants have argued that this is acceptable because the background levels of nitrogen deposition are predicted to decline over time, so that the total deposition over this area would be below the lower end of the agreed critical load for habitats at Dungeness. 13.2. However, there are still concerns: 13.2.1. Critical loads apply only to habitats, and not to the species using those habitats. As stated above, the Centre for Ecology and Hydrology website clearly states that ‘critical load values will not necessarily protect all habitats/species within each ecosystem, since data are not available for all habitats/species.’ 13.2.2. For the rare and threatened species found at Dungeness, there is no information which indicates the level of nitrogen deposition below which plant-predator interactions are unaffected. 13.2.3. A review of literature presented as part in the lichen survey undertaken by Dr Brian Ferry for Kent Wildlife Trust shows that changes in lichen-dominated plant communities have been observed at levels of nitrogen deposition considerably below that predicted for Dungeness (Appendix 21). The loss of Usnea lichens reported by Dr Ferry may be a result of past nitrogen deposition, as this genus is known to be especially susceptible to air pollution. 13.2.4. Even if the continued decline in background nitrogen deposition does occur as predicted in the applicant’s air quality modelling Kent Wildlife Trust Proof of Evidence Page 43 of 48 KWT/3/A (and it is a matter of quite considerable concern that this relies on changes which the applicant is unable to influence), then operation of the airport will still be responsible for an elevated level of nitrogen deposition (compared with the ambient) on a site which supports species known to be extremely sensitive to this nutrient. 14. What can be concluded? 14.1. Dungeness is of international importance for nature conservation, while many of the species associated with its vegetated shingle and wetland features are of at least national importance, being nationally rare or threatened, and, in a number of cases, included in the UK Biodiversity Action Plan. In the case of the endemic species and subspecies, the populations at Dungeness are globally important. 14.2. Past development has led to significant loss of habitats, and a range of factors mean that many of the species associated with Dungeness are apparently undergoing declines at national and probably also county level. In the cases of some invertebrates, historic habitat loss (such as the development of The Crumbles, Eastbourne) has resulted in Dungeness becoming the only remaining UK site for these species. 14.3. The rare and threatened species at Dungeness are variously vulnerable to loss of or disturbance to habitat, loss of food plants, changes in soil nutrient status, and/or ecological light pollution. 14.4. The importance of the communities of plant and invertebrate species at Dungeness is such that even proportionately small losses may be of considerable significance. Potential future impacts need to be viewed in the light of past impacts at Dungeness and also in the light of impacts elsewhere in the UK upon species considered nationally rare and/or threatened. Kent Wildlife Trust Proof of Evidence Page 44 of 48 KWT/3/A 14.5. National planning policy states that ‘planning decisions should aim to maintain, and enhance, restore or add to biodiversity and geological conservation interests’. Planning should ‘secure new development and shape places that minimise vulnerability, and provide resilience, to climate change’. Defra guidance is clear that, to minimize vulnerability to climate change, we must reduce sources of harm not linked to climate, which include nutrient enrichment. Critical load data can only help so far in this respect; the scientific literature suggests that changes to habitats and populations of species may occur well below established critical loads for Dungeness. 14.6. National planning policy states that ‘Development plan policies and planning decisions should be based upon up-to-date information about the environmental characteristics of their areas. These characteristics should include the relevant biodiversity and geological resources of the area. In reviewing environmental characteristics local authorities should assess the potential to sustain and enhance those resources’. In the case of the current proposals, there is a lack of biological survey data, including for areas which may, or are known to, support rare and threatened species. This lack of data means that: 14.6.1. There is an increased risk of impacts through lack of appropriate information; 14.6.2. The full impact of the development proposals cannot be properly examined, and, in particular, it is not possible to ‘assess the potential to sustain and enhance’ biodiversity resources; and 14.6.3. 14.7. Appropriate mitigation cannot be developed. The proposed mitigation is unproven and not based on full biological information. There is therefore a risk that should the proposals go ahead, there will be loss of or damage to populations of rare or threatened species, Kent Wildlife Trust Proof of Evidence Page 45 of 48 KWT/3/A and this loss or damage may affect the potential for those species to continue to maintain national, or in some cases, global populations. The level of risk is unclear, but could potentially be high and if misjudged could have national or global consequences. 14.8. Past habitat losses at Dungeness, the large number of rare and threatened species associated with area, and the on-going declines in populations of these species demonstrate that there is a need for a substantial reduction in the pressures affecting the area and particularly its vegetated shingle habitats, rather than the exertion of further pressure through increased development. This would align more closely with planning policy which seeks to enhance biodiversity, including PPS9, the South East Plan and the Shepway Core Strategy Preferred Options. 14.9. The planning policy which directly supports expansion of aviation at London Ashford (Lydd) Airport is limited to Policy TR15 of the current Shepway Local Plan. Airport development can, therefore, only be seen as being of local significance. 14.10. Some have argued in the case of the proposed developments, that ‘people should come before wildlife’, and therefore that the need for local employment should override nature conservation concerns. However, national planning policy takes the view that Sustainable Development should be the driver of planning policy and decisions. However you choose to define ‘sustainable development’, the principle remains that it must refer to development that can be sustained, i.e. it is a form of development which can be pursued indefinitely. Any process of basing planning decisions on trading off economic gain against environmental losses cannot be sustained indefinitely, since there will necessarily come a point where such decisions will lead to irrevocable environmental damage. 14.11. The planning proposals are therefore not in accordance with PPS1, because: Kent Wildlife Trust Proof of Evidence Page 46 of 48 KWT/3/A 14.11.1. They fail to protect and enhance the natural environment; and 14.11.2. The would reduce the resilience of the natural habitats of Dungeness to predicted climate change. 14.12. The planning proposals are not in accordance with PPS9, because: 14.12.1. They are not properly based on information on relevant biodiversity resources of the area; 14.12.2. They will not maintain, and enhance, restore or add to biodiversity, but rather pose a significant threat to biodiversity; and 14.12.3. They fail to protect from the adverse effects of development species of principal importance for the conservation of biodiversity in England. Because the species concerned are of national or international significance, this is not outweighed by the scale or significance of any benefits which might arise from the proposals. 14.13. The planning proposals are contrary to Policies CO9 and CO11 of the current Shepway Local Plan, because: 14.13.1. There is a significant risk of impact to the wildlife interest of the Dungeness National Nature Reserve and to UKBAP priority species, and the need for the development is not so exceptional that it outweighs this biodiversity interest. 14.14. The planning proposals are not in accordance with the emerging policies of the Shepway Core Strategy, because: 14.14.1. They are not consistent with placing a greater emphasis on conserving, enhancing and managing the district’s diverse and Kent Wildlife Trust Proof of Evidence Page 47 of 48 KWT/3/A high quality landscape resources, nor with recognition species will be affected by climate change; and 14.14.2. They fail to protect key species. 14.15. Although KWT’s case does not directly relate to impacts upon nationally or internationally designated sites, it is clear that if the proposals fail to accord with the above principles and policies, then they also fail the tests set out in PPS9 relating to developments affecting SSSIs and the tests in the Habitats Regulations relating to development likely to have an impact upon Natura 2000 sites. Kent Wildlife Trust Proof of Evidence Page 48 of 48