Download 1 - Shepway District Council

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
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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.
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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
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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
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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’.
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‘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
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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
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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.
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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:
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‘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
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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:
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‘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
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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
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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).
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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.
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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
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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
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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.
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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.
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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
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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
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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:
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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.
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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).
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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).
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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
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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
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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
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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.
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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.
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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,
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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
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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
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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).’
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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:
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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
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(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.
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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,
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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:
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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
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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.
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