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Design and Access Statement Sywell Shooting Ground, Sywell, Northamptonshire The application is for an extension to the existing permitted use for the temporary siting of a mobile crusher and screen to separate soils and recycled aggregates and allow them to be taken off-site. The site already benefits from a consent which involves the importation of waste material for the construction of other parts of the shooting grounds. The imported material is screened and material crushed. This provides suitable material to be used in the construction of the permitted go-kart track and also subject to consent being granted the handling, storage and processing of inert material which will, once processed, go off-site again. Amount The amount of development proposed in relation to the extension to the shooting ground is 1.39 hectares. In terms of volume, if permitted the amount of material to be processed will not exceed 50,000 tonnes per annum. This proposal allows for the recovery of inert material which will be carries out on the above area. This screening and crushing of material is already permitted on this part of the site under reference 10/00005/WAS and dated 21 April 2010. The area will comprise both the machinery and stockpiles inert material awaiting processing and material that has been processed, waiting collection. The site is located behind the existing mounding around the edge of the applicant’s land. This will mean the development will not be seen from any public vantage points and within the site will assimilate into the larger boundary mounds. Layout The principal access routes are already in place onto the site and as such will remain as existing so as to cause minimum disruption to other users on the site. The site is within a 15 minute drive time of Northampton and is well located on the A43, Northampton to Kettering road. In terms of crime prevention, as this is an entirely private site we do not consider this as an issue. The wider site has only one access from the A43 which is kept locked out of hours and when open staff are on site. J:\james\Muttock\Recycling Application September 2010\Design and Access Statement.doc

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Page 1: Design and Access Statement...Design and Access Statement Sywell Shooting Ground, Sywell, Northamptonshire The application is for an extension to the existing permitted use for the

Design and Access Statement

Sywell Shooting Ground, Sywell, Northamptonshire The application is for an extension to the existing permitted use for the temporary siting of a mobile crusher and screen to separate soils and recycled aggregates and allow them to be taken off-site. The site already benefits from a consent which involves the importation of waste material for the construction of other parts of the shooting grounds. The imported material is screened and material crushed. This provides suitable material to be used in the construction of the permitted go-kart track and also subject to consent being granted the handling, storage and processing of inert material which will, once processed, go off-site again. Amount The amount of development proposed in relation to the extension to the shooting ground is 1.39 hectares. In terms of volume, if permitted the amount of material to be processed will not exceed 50,000 tonnes per annum. This proposal allows for the recovery of inert material which will be carries out on the above area. This screening and crushing of material is already permitted on this part of the site under reference 10/00005/WAS and dated 21 April 2010. The area will comprise both the machinery and stockpiles inert material awaiting processing and material that has been processed, waiting collection. The site is located behind the existing mounding around the edge of the applicant’s land. This will mean the development will not be seen from any public vantage points and within the site will assimilate into the larger boundary mounds. Layout The principal access routes are already in place onto the site and as such will remain as existing so as to cause minimum disruption to other users on the site. The site is within a 15 minute drive time of Northampton and is well located on the A43, Northampton to Kettering road. In terms of crime prevention, as this is an entirely private site we do not consider this as an issue. The wider site has only one access from the A43 which is kept locked out of hours and when open staff are on site.

J:\james\Muttock\Recycling Application September 2010\Design and Access Statement.doc

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Scale The scale of the storage and recovery area is on average 205 metres long by 65 metres wide. The material will be stockpiled depending on material, grade and quality and should not exceed 2 metres in height and in event will be protected from public view by the mounding around the site perimeter. Landscaping Landscaping was discussed at length with the County Council as part of the previous application with a condition applied to the permission. As such it is considered there is no further condition required for this application. Appearance The appearance of the existing area is already large mounds surrounding the shooting ground. The proposal will mean there will be stockpiles of material that will be transient in nature. The general appearance will therefore change throughout the lifetime of the consent. There is no lighting proposed with this application. Access Direct access to the wider site is from the A43, Northampton to Kettering Road. Although the speed limit along this part of the road is 60 mph there is still good visibility in each direction. The site already benefits from a good number of off road parking spaces and more than adequate turning areas. Within the site there is an existing haul road of approximately 700 metres which will serve this development. A level pathway approach from the parking spaces will ensure easy access for all people including those with disabilities. Hardcore will form the base of the recycling area and will be generated from inert material brought onto site.

J:\james\Muttock\Recycling Application September 2010\Design and Access Statement.doc

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NORTHAMPTON SHOOTING GROUND SYWELL FLOOD RISK ASSESSMENT FOR JOHN DRAKE AND CO ON BEHALF OF THE NORTHAMPTON SHOOTING GROUND November 2013

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CONTENTS

1.0 Introduction 2.0 Aim Of The Study 3.0 Methodology 4.0 Catchment Description 5.0 Site Description Of Existing Site 6.0 Qualitative Assessment of Potential Impacts from

Re-Contouring 7.0 Flood Risk 8.0 Proposed Flood Reduction Measures 9.0 Additional Considerations 10.0 Conclusion References

Figure 01: Local Catchment Boundary Figure 02: Existing Drainage Figure 03: Potential Flood Areas

(for information only) Figure 04: Water Management Proposals

Report: Ref No: J14.09b

Author: Hilary R Ludlow MSc CMLI MCIEEM CEnv

Scientific check:

Hilary R Ludlow MSc CMLI MCIEEM CEnv

Presentation check: Zoe Lewis BA (Hons)

Date: November 2013

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1.0 Introduction

Landscape Science Consultancy Ltd was commissioned by John Drake and Co on behalf of the Northampton Shooting Ground to update the flood risk assessment of a proposed development at Sywell Shooting Range, Northampton that had previously been completed as a requirement by the local authority under Planning Policy Statement PPS 25. PPS 25 has been replaced by the National Planning Policy Framework 2012 but the technical requirements for a flood risk assessment are similar to those of the previous PPS 25. The location of the application site is shown on Figure 01 and is owned by the applicant company. The proposals are to re-contour an area of approximately 1.65 ha to create an undulating plateau rising 9m above the adjacent ground to the north east. To the west, the ground would integrate with the existing perimeter acoustic bund. An additional bund is proposed on the north side of the boundary hedge. Collation and evaluation of available data indicates that the proposed development site near Sywell falls within Zone 1 where there is low risk of flooding and there are no constraints to development due to river flooding. According to the NPPF Sequential Test, the proposed type of development, outdoor recreation, falls under the Water Compatible Development. Within Zone 1 such a development is appropriate and no Exception Test is required. The NPPF recommends that any developer ensures that the rate of flow off the site from flash flooding is controlled and does not impact downstream. To this end, proposals for maintenance and a storage area to control sediments and flow adjacent to the downstream end of the on-site section of stream are put forward.

2.0 Aim of the Study

The following Flood Risk Assessment (FRA) report is considered to be in proportion to the risk and appropriate to the scale, nature and location of the proposed development. The report describes the existing sources of water and the existing risk of flooding; and existing and recommended control measures. The aims of the FRA process are drawn from CIRIA (2004) as being: to assess the flood risk to the proposed development and to demonstrate

the feasibility of the development design such that any residual flood risk is acceptable;

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to assess the potential impact of the proposed development on flood risk elsewhere and to demonstrate the feasibility of the development design such that it would not increase flood risk elsewhere; and

to satisfy the requirements of national planning policy guidance. Relevant policies in the Nene Catchment Flood Management Plan and the Northampton Borough Council Strategic Flood Risk Assessment have been considered. The Flood Risk Assessment below follows the guidance in the NPPF FRA Technical Guidance Note.

3.0 Methodology 3.1 Legislation

The Town and Country Planning (Flooding) (England) Directive 2007 came into force on the 1st January 2007. The accompanying Department for Communities and Local Government (DCLG) Circular 04/2006 states that proposals that fall within the category requiring a flood risk assessment (FRA) are those that are: (a) non-residential development with a site area of more than 1 hectare; or (b) located on land that is within Flood Zones 2 or 3. The site falls within the first category.

3.2 Legislation and Policy

Town and Country Planning (Flooding) (England) Direction 2007 came into force on the 1st January 2007. The accompanying Department for Communities and Local Government (DCLG) Circular 04/2006 states that proposals that fall within the category requiring a flood risk assessment (FRA) are those that are (a) non-residential development with a site area of more than 1 hectare and (b) located on land is within Flood Zones 2 or 3. The site meets the first criteria and thus requires the completion of a FRA. The National Planning Policy Framework Technical Guidance Note 2012 on Flood Risk Assessment adopts many of the parameters set out in the previous Planning Policy Statement 25: Development and Flood Risk (PPS 25). The 2012 guidance note outlines a risk-based approach to ensure that development is safe and not exposed unnecessarily to flooding. The guidance also requires that a development should not increase flood risk elsewhere in the catchment, and that development must not constrain the natural function of the flood plain, either by impeding flood flow or reducing storage capacity. Areas of possible flood risk are categorised into four zones:

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Zone 1 – Low probability - Little or No Risk = < 0.1% Zone 2 – Medium probability - Low to Medium Risk = > 0.1% but < 1% Zone 3a – High Probability - High Risk = > 1% Zone 3b – Functional Floodplain – where water flows in time of flood. The site falls within Zone 1.

3.3 Consultation The following statutory bodies were consulted: Environment Agency (EA)

Anglian Water Board

Northampton Borough Council Information was also drawn from the following documents: NPPF FRA Technical Note 2012

EA Flood Risk Standing Advice

CIRIA Development and Flood Risk: Guidance for the Construction Industry

EA Flood Risk Strategy

DEFRA Making Space for Water

River Nene Catchment Flood Management Plan

Northampton Borough Council Strategic Flood Risk Assessment

Geological information sourced from British Geological Survey (BGS) Sheet and the relevant memoir BGS Geology of the country around

3.4 Assessment Level

The initial Level 1 FRA has been undertaken and achieved by a screening study to:

confirm whether the site is likely to be in a “little or no risk”, “low to

medium” or “high” flood risk zone

produce a preliminary qualitative assessment of the potential impact of, and constraints to, the proposed development

develop an understanding of the potential development design that may be employed at the site

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4.0 Catchment Description

Figure 01

4.1 Catchment The overall site of the Northamptonshire Shooting Ground is typical of outdoor recreation with swathes of amenity grass, mixed age planting and disturbed ground. The site sits amongst agricultural land at the top of a minor tributary to the River Nene. The upper reaches of the stream cross undulating ground, sloping to the south west. There are no main rivers in this minor catchment. The geology for this area of the catchment is a capping of boulder clay, several metres thick, over the Jurassic sedimentary beds.

4.2 Land Use The land use over the upper reaches of the catchment of the unnamed tributary to the River Nene is mainly agricultural with residential further downstream. The land use, particularly the agriculture, is relevant to the hydrology and hydrogeology in that it influences evapo-transpiration and therefore the water balance of the catchment. The Shooting Ground is used for outdoor recreation and is mainly amenity grass and extensive perimeter earth bunds. The site, therefore, responds to rainfall as a greenfield site.

4.3 Surface Water Runoff

Figure 02 The boulder clay soils have limited permeability and surface water drains from the catchment in a typical pattern following the contours. The boulder clay will prevent rainfall entering the soils quickly and runoff will be rapid. On site the drainage is based on a natural stream and a system of ditches and culverted drains (Section 5).

4.4 Flooding Figure 03 The upper reaches of the minor tributary are not shown as experiencing flooding. The water flow in the stream course on site is ephemeral. Flooding occurs downstream as the stream passes through a narrow valley at the Cowpasture Spinney down into the residential areas of north east Northampton. Flooding may also occur approximately 3km downstream as the waters pass through the lake at Overstone Park. The lake is artificially

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constrained by a road on the downstream side. Further flooding along the tributary can occur as the stream passes through the industrial and residential areas on the outskirts of Northampton.

4.5 Aquifer Recharge

The boulder clay capping will prevent rapid aquifer recharge from the site.

4.6 Abstractions No major aquifer units immediately underlie the catchment and there are no public water supply licences in the area.

5.0 Site Description of Existing Site

In the context of the overall sub-catchment of the minor tributary that flows into the River Nene, the site lies in the upper reaches of the tributary, close the source issues. The proposed development area covers approximately 1.65 hectares within the overall grounds of the Northamptonshire Shooting Ground.

Photograph 1. Showing the survey site and approximate red line boundary The surface water drainage system is typical of recreational land in the countryside with an interconnecting system of a natural stream and field drains, Figure 02. The site responds to rainfall as a greenfield site.

5.1 Stream A small ephemeral stream rises offsite to the north east from issues in Sywell Woods. The stream course runs across the site in a south westerly direction in a straightened line, with vertical banks that deepen towards the south east to approximately 1.75m depth. The width at the south eastern end is

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approximately 4m bank top to bank top and the base of the channel is approximately 0.5m. The stream is well-vegetated by tall ruderals and a few aquatics.

Photograph 2. Showing the overgrown stream course

5.2 Pond Upstream of the proposed development site, the stream flow passes through a pond. The flow of water into the pond is relatively minimal and at times of storm the pond depth can vary up to 18 inches, well within the capacity. No silting in the pond occurs due to the slow rate of flow and the water remains clear with no stagnation. The pond is not at capacity and provides an additional storage capacity for any excess flow from upstream of the site.

Photograph 3. Pond

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5.3 Culverts Where the stream leaves the pond, goes under an access track and exits the site under the perimeter bund, there are culverts with constructed headwalls. Culvert 1 includes a length of concrete to control the flow and a mesh screen to prevent blockages by debris.

Photograph 4. Culvert 1 Culvert 2 is a simple structure. The culvert headwall, where the water flows under the perimeter bund, is not protected by any mesh to prevent blockages by debris.

Photograph 5. Stream culvert 2 The stream exits the site from Culvert 3 under the acoustic perimeter mound. There is no headwall on this pipe.

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Photograph 6. Stream culvert 3

5.4 Ditches and Drains The natural overland flow drainage pattern of the area has been constrained and developed by the system of field ditches that drain the catchment towards the stream. The field ditches are often dry in the winter and during the drier summer months. On site, the ditches have been adapted to meet the requirements of the site layout and are culverted under the flat amenity grass.

5.5 Record of Flooding There has been no history of flooding and no flood data recorded. There are no flood protection systems in place. The current owners have not recorded an instance of the capacity of the stream course and the drains being exceeded during intense storms over the past 36 years.

6.0 Qualitative Assessment of Potential Impacts from Re-Contouring

Two areas of re-contouring would occur: in the main site area and also by the addition of the bund on the north side of the hedge. The latter would be drained by toe drains which would connect to the existing drains in the locality.

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The re-contouring of the main site area would result in an insignificant minor increase in the surface area as a result of the surface runoff contribution from the increased surface area of the slopes. The re-contouring would result in an area of clay soils overlying a minor aquifer being further capped. No reliance is currently placed on these areas as a source of water supply and no impact would occur on groundwater abstractions elsewhere in the catchment. The mound would be built up using clay soils and the permeability would be as for the existing site; that is, slow and limited with the majority of rainwater running off as surface flow. The existing pattern of drains and the stream would be retained. New drains at the base of the new bund would be created. The site would remain as greenfield and the existing performance of the site would not change.

7.0 Flood Risk 7.1 Mechanism of Potential Existing Flood Risk Hazards

Site The Indicative Flood Map sourced from the Environment Agency is shown in Figure 03. The Indicative Flood Map for the area shows the site falls within Zone 1 and is outside the functional flood plain. Zone 1 is designated as Low Probability which includes land assessed as having a less that 1 in 1000 annual probability of river flooding in any year. The site is not shown as having any flood risk from fluvial flooding. Risk of Flooding Arising from Development The causes of local flooding on this site are potentially when the flow exceeds the system’s capacity caused by severe convection storms; or the free flow of water is impeded by blockages. The main sources of potential flood risk are A failure of the infrastructure of the ditches and stream that occur within

and near to the site. Flooding would occur if culverts were blocked by debris.

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Flooding could also result from a derogation of the carrying capacity of the drains from high intensity rainfall events, particularly at times when the ground is already saturated.

Overtopping of levels at the soakaways along the A43 could contribute to waters also on the site, given the slope of the ground from the A43 towards the site.

There are no historical records of flooding on the site. Downstream Flooding is recorded downstream in Cowpasture Spinney where the flood envelope is narrow, shown as limited to approx 50m either side of the stream course at Cowpasture Spinney; and to the south where the tributary enters the Overstone Park, approximately 3km away. Downstream, the tributary is rated as high risk of flooding, Flood Zone 3 from Cowpasture Spinney downstream through to Northampton and into the River Nene, (Sheet 4 Strategic Northampton Flood Risk Assessment). No proposed developments areas on the west side of the town would be affected. The potential for increased flooding in the downstream parts of the valley would not be significantly increased by the proposals but are considered in respect of the requirements under the NPPF Technical Note.

7.2 Existing Flood Reduction Measures

Drainage System The agricultural land surrounding the site is gently undulating and drained by a network of drainage ditches, many of which are ephemeral during any year. Given that the stream flow and ditches are ephemeral and the water level in the pond is normally well below capacity level, the stream, pond and the surface drains on the site have the capacity to store and contain a degree of storm water in times of high flows. Existing Management of Drains and Stream The length of stream course that crosses the site is monitored on a regular basis and ditching takes place every 6 years. The length of stream is due for ditching this autumn when the foliage has died down. Two sump holes in the pond are cleared every 3 years and were last cleared in 2008. Where the water exits the pond via a short culvert, Culvert 1, the mesh screen is regularly monitored and cleared as necessary.

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No problems of overflow have been experienced in the last 36 years. The management of the surface water drainage on site would be the responsibility of the owners of the Shooting Ground.

7.3 Impacts to the Development Site

No buildings would permanently occupy the proposed development area of the site and therefore any changes in the existing localised runoff from structures and hard standing would be nil. The development would result in a minor insignificant increase in surface area with an equivalent greenfield runoff rate.

7.4 Impacts from the Development Construction Phase During the construction phase, the existing vegetation would be removed and storm runoff would be more rapid than that which would occur under the current surface vegetation. As a result of the earth moving, there would be an increase in unconsolidated, un-vegetated soil material on site and consequently a potential increase in sediment flow into the stream and potentially through the culvert, Culvert 3. Operational Phase The pre-development pattern of drainage would be amended by drains at the toes of the bunds. The existing surface drainage system, with additional drains in the vicinity, is considered to be adequate for the development provided that it is managed. In the long term, the proposals would not alter the hydraulics of the local drainage system. The vegetation would be re-instated and the development would not change the ability of water to soak into the site. No increase in flood risk would result from the works. The site is not at risk of flooding from the watercourse, the groundwater, overland flow or the artificial drainage system.

7.5 Sequential and Exception Test

The Sequential Risk based test is passed. The proposed development, under Flood Risk Vulnerability, sits in the low risk category Zone 1. The use of the site for outdoor recreation is compatible to the flood zone category. The proposed

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development is, therefore, appropriate. There is no requirement for an Exception Test.

8.0 Proposed Flood Reduction Measures Figure 04

8.1 The FRA is required to demonstrate that any potential flood risk to others as a result of the proposed development is managed now and takes climate change into account. The potential flood risk from the site is low but is considered in the context of exacerbating the existing potential local flooding downstream. In addition, as flooding is unpredictable, the interaction of the effects of a high flow from the site on downstream areas of potential flooding are considered. The runoff within the catchment of this minor tributary can cause flooding further downstream and to avoid contribution from the site to excess flow during storm periods, as a precautionary and preventative measure, appropriate surface water drainage features and management regimes would be put in place to manage surface water. The reduction of potential flood risk in the future is based on three elements: Management of the existing and new system of drains

Control of silt and sediment

Location of a storage area by the stream

8.2 During Construction Prior to earth moving, the existing stream would be cleared of vegetation to maximise flow capacity. During the construction phase, best practice guidelines issued by the Environment Agency to control the flow of silt and sediments into the water course as a result of construction, would be followed. It is recommended that a headwall is constructed at Culvert 3 with a mesh protection and vegetation is regularly cleared to avoid blockages.

8.3 During Operation

Management of Existing Ditches, Stream and Culverts

Potentially, the risk of flooding could occur if the capacity of the piped flow and/or the ditches is exceeded or a blockage of the culverts occurs. The

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management of the stream, ditches and culverts to maintain free flow is essential. A management plan for the stream, culverts and ditches is in operation and will be extended to include all new ditches and drains and will be monitored and maintained on a regular basis. In addition it is recommended that the entrance of Culvert 3 is protected by a mesh screen to avoid debris flowing in to the culvert under the perimeter mound and causing a blockage. Management of Flow Offsite The aim would be to maintain any rapid, excess flow on site within a storage location to prevent nuisance and damage downstream. This would include both water flow and control of sediments. The proposed attenuation area would delay the transmission of water offsite and allow the settlement of sediments. The storage area would be located between the stream and the toe of the bund and created by the lowering of the existing surface to be 0.25m below the existing bank height to the toe of the existing bund. This would provide an additional storage area of 488 square metres with an increase in potential storage volume on site of 122 cubic metres. An inflow point would be created by lowering the bank top at a point 5m below the upstream culvert.

9.0 Additional Considerations 9.1 Effects of Climate Change

NPPF also requires consideration of the effects of climate change on the risk of flooding at the development site. Sensitivity ranges up to the year 2115 are provided in the Technical Note that may provide an appropriate precautionary response to the uncertainty about climate change impacts on rainfall intensities and river flow. According to the Technical Note, the predicted increase in peak rainfall intensity ranges from 5% by 2025 to 30% by 2115. Therefore, the probability of flooding at the site from surface run-off may increase and the potential impacts and reduction measures have been considered against this shift. Given the existing site conditions and low risk of flooding, the proposals to increase the on-site storage should be sufficient to accommodate the risk from climate change.

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9.2 Residual Risk NPPF requires that any residual risks after mitigation be safely managed and that the flood risk assessment demonstrates that the residual risk is acceptable for the development. The amount residual risk is acceptable for the type of land use. No residual flood risks are predicted from the re-contouring development.

10.0 Conclusion A Level 1 and Level 2 Flood Risk Assessment has been carried out for development at the Northamptonshire Shooting Ground, Sywell. The site lies within the catchment of the River Nene but lies in the upper reaches of a minor tributary sub-catchment. The National Planning Policy Guidance Technical Note 2012 outlines a risk-based approach to ensure that proposed development is safe and not exposed unnecessarily to flooding. The statement also requires that a development should not increase flood risk elsewhere in the catchment. The NPPF classifies areas of possible flood risk into four zones. The site falls within Zone 1, the zone of Low probability with little or no risk, <0.1%, of flooding. The development is considered to be a Water-Compatible Development and therefore is Appropriate in Zone 1. Based on this assessment it is determined that the development would be acceptable in terms of flood risk and that a Level 3 FRA is not required. The water board has reported that no records exist of flooding from drains or water-logging in the area. No flood risk impacts are predicted to result from the operational phase either on the site or within the surrounding catchment area. The potential for increased rainfall over the next 100 years due to climate change would not significantly affect the flood risk. As a precautionary measure, mitigation to control the flow of excess water from the site is proposed.

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References

British Geological Survey 1977. Hydrogeological Map of England and Wales British Geological Survey. England and Wales Sheet 185 Northampton Solid and Drift Edition British Geological Survey 1989. British Regional Geology Central England Centre for Ecology and Hydrology 2008. Flood Estimation Handbook CIRIA Report 113 Control of Groundwater for Temporary Works CIRIA 2004 Development and Flood Risk Guidance for the Construction Industry. CIRIA Report C624 DCLG 2012. National Planning Policy Framework Technical Note DEFRA 2005. Making Space for water: A New Government Strategy for Flood and Coastal Erosion Control Risk Management in England – Sustainable Drainage Systems a Summary of Issues DEFRA circular. Preliminary Rainfall Runoff Management for Development Interim Procedure Circular DEFRA W5 – 074/A Environment Agency Nene Valley Catchment Management Plan European Flood Action Programme 2006 Best Practice on Flood Prevention, Protection and Mitigation HMSO 2006. Circular 04/2006 The Town and Country (Flooding) (England) Direction 2007. The Stationery Office Northampton Borough Council 2004. Strategic Flood Risk Assessment

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NORTHAMPTON SHOOTING GROUND SYWELL, NORTHAMPTONSHIRE UPDATED PHASE 1 HABITAT SURVEY FOR JOHN DRAKE AND CO ON BEHALF OF MR AND MRS MUTTOCK November 2013

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CONTENTS

1.0 Introduction 2.0 Site Description 3.0 Legislation and Policy 4.0 Methodology 5.0 Results 6.0 Impacts 7.0 Recommendations 8.0 Conclusion

References Figure 01A: Phase 1 Habitat Survey Appendix 1: Target Notes

Report Ref No: J14.09a

Author: Hilary Ludlow MSc MCIEEM CMLI CEnv

Scientific check:

Hilary Ludlow MSc MCIEEM CMLI CEnv

Presentation check: Zoe Lewis BA (Hons)

Date: November 2013

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1.0 Introduction 1.1 Landscape Science Consultancy Ltd (LSC Ltd) was commissioned by John Drake

and Co to update a previous ecological assessment dated 2009 on an area of land at the Northamptonshire Shooting Ground, Sywell, Northamptonshire. The survey was carried out in respect of a proposed application for an extension of a planning application. The baseline ecological assessment of site conditions has been updated and recommendations for ecological enhancement have been made.

1.2 The aim of the ecological survey was to identify all relevant aspects of ecology

on the development site and assess their relative importance, as well as determining the likely scale and magnitude of ecological impact from the development proposals. A background data search was undertaken in 2009.

1.3 An extended Phase 1 Habitat Survey of the site was undertaken on 21st

November 2013 by principal ecologist Hilary R Ludlow MSc CMLI MCIEEM CEnv. This included an examination of key habitats and all potential ecological constraints present on the site, including the presence and potential presence of protected species.

1.4 The impacts of the development proposals are discussed and recommendations

made for mitigation and enhancement. 2.0 Site Description 2.1 The site is located to the south of the A43 main trunk road, at Sywell,

Northamptonshire. The surrounding landscape is rural with arable and pasture fields. There are direct links from the site to the wider landscape through the hedgerows that line the A43 and demarcate the field boundaries.

2.2 The majority of the survey area is managed amenity grassland with mature and

semi-mature trees in hedge lines along some of the boundaries and tall bunds with rough grassland forming the remaining boundaries. Throughout the site there are scattered groups of planted trees and groups of self seeded shrubs and saplings. A stream runs from the north east of the overall site boundary into a balancing pond to the immediate north east of the survey area. The outflow from the pond runs along the southern boundary of the survey area into a culvert which takes the water offsite.

2.3 The site is enclosed on the south, north and west by high acoustic mounds. 2.4 The location of the site is shown in Map 1 and an aerial photograph with the

extent of the area surveyed is shown in Map 2.

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Map 1. Showing the location of the site (indicated by the red circle)

Map 2. Showing the site in the context of surrounding habitats in the wider landscape

(indicated by the red line)

N

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3.0 Legislation and Policy

The potentially relevant legislation is summarised below.

3.1 Statutory Legislation

The Conservation of Habitats and Species Regulations 2010 The Conservation of Habitats and Species Regulations 2010, or the ‘Habitat Regulations 2010’, transposes European Directives into English and Welsh legislation. Under these regulations, wild animals of a European Protected Species and their breeding sites or resting places are protected under Regulation 41. Such wild animals of a European Protected Species include great crested newts, otters, dormice and all species of bat. It is an offence to deliberately capture, injure or kill any such wild animal and in the case of great crested newts, deliberately take or destroy their eggs. It is also an offence to deliberately damage or destroy a breeding site or resting place of any such wild animal. Wild animals of a European Protected Species are also protected from disturbance under Regulation 41. Disturbance of such wild animals includes in particular any disturbance which is likely:

(a) To impair their ability -

to survive, to breed or reproduce, or to rear or nurture their young; or in the case of animals of a hibernating or migratory species, to

hibernate or migrate; or (b) To affect significantly the local distribution or abundance of the species to

which they belong.

The Wildlife and Countryside Act 1981 (as amended) The Wildlife and Countryside Act 1981 (as amended) affords protection to wild birds in England and Wales under Part 1. It is an offence to intentionally kill, injure or take any wild bird. It is also an offence to intentionally take, damage or destroy the nest of any wild bird whilst it is in use or being built, or intentionally take or destroy their eggs. If the wild bird is included on the Schedule 1 of the Wildlife and Countryside Act 1981 (as amended), it is additionally an offence to intentionally or recklessly disturb the wild bird whilst on the nest during the breeding season. Certain species of animal, such as the water vole, are offered ‘full protection’ under the Wildlife and Countryside Act 1981 (as amended) by being included in Schedule 5 in respect of certain offences under Section 9. Such offences include:

9(1) Intentional killing, injuring or taking of a Schedule 5 animal;

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9(4a) Intentional or reckless damage to, destruction of or obstruction of any

structure or place used by a Schedule 5 animal for shelter or protection; 9(4b) Intentional or reckless disturbance of a Schedule 5 animal occupying such a

structure or place.

Widespread species of native reptiles occurring within England and Wales such as the adder or common lizard are protected against intentional killing and injuring under the Wildlife and Countryside Act 1981 (as amended) only. Animals of a European Protected Species are now only protected under offences 9(4a) and 9(4b) of Section 9, the main legislative tool covering such animals is under the ‘Habitats Directive 2010’. The Protection of Badgers Act 1992 Badgers are primarily protected by The Protection of Badgers Act 1992, under which it is an offence to wilfully kill, injure, take, possess or cruelly ill-treat a badger, or to attempt to do so and to intentionally or recklessly interfere with a sett. Sett interference includes disturbing badgers whilst they are occupying a sett, as well as damaging or destroying a sett or obstructing access to it.

3.2 Planning Policy

The National Planning Policy Framework (‘the Framework’) sets out the Government’s planning policies for England and how these are expected to be applied (DfCLG, 2012). Local Planning Authorities have an obligation to prepare their Local Plans “consistent with the principals and policies set out within the Framework, including a presumption in favour of sustainable development (Para 151)”. Planning decisions must be undertaken in accordance with the Local Plan unless material considerations indicate otherwise. The Framework requires Local Planning Authorities to set out a strategic approach for conserving and enhancing the natural environment, thereby “planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure (Para 114)”. When determining planning applications, the Framework outlines that “if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused (Para 118)”.

3.3 Biodiversity Action Plans

The UK Biodiversity Action Plans (BAPs) were drafted for ‘Priority’ species and habitats in which specific conservation targets were set and are regularly reviewed. BAP features do not receive any legal protection but have

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biodiversity value within a national context. The UK BAPs also serve as a framework for local biodiversity conservation efforts. The Biodiversity Plan for Northamptonshire lists the local priority habitats and species for which conservation targets have been developed. There are no habitats or species listed in the Plan that are of potential relevance to this site.

4.0 Methodology 4.1 Desktop Study

Natural England’s ‘Nature on the Map’ and the ‘MAGIC’ websites were accessed for locations of statutory nature conservation sites within 1km of the survey site. Northamptonshire Biological Records Centre was consulted with regard to protected species and statutory and non-statutory nature conservation sites within a 1km radius of the survey area.

4.2 Field Surveys

Extended Phase 1 Habitat Survey

Based on the JNCC (2007) guidelines, a walkover of the site was undertaken on 21st November 2013 to update the records for the macro-habitats present and note target points of interest. This method provided an overview of existing communities and associations within the site and points of ecological interest which can then be incorporated into recommendations for the future, developing linkages, reducing fragmentation and strengthening existing habitats. Species lists for the main habitat areas were compiled. Plant nomenclature follows Stace (1997). The UK priority Species/Red Data book/locally important species lists were used to establish national, regional and local status of any rarer plants, animals or invertebrates recorded during the survey. The ecological survey of the site considered all relevant aspects of ecology in order to provide sufficient detail to: identify and assess the overall habitat pattern of the site and associated

linkages relevant to the proposals, highlighting the terrestrial habitats present;

assess the current ecological status and sensitivity, particularly in relation to any statutory designations;

identify presence or possible presence of protected species; identify constraints to development; identify any notifiable weeds; provide recommendations if mitigation is necessary.

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4.3 Assessment of Ecological Value and Potential Impacts

The ecological value and potential impacts of the development proposals to site receptors are determined using a standardised methodology based on guidance provided by the Institute of Ecology and Environmental Management (IEEM, 2011) and the Design Manual for Roads and Bridges (DfT, 2008). The guidelines propose an approach to ecological impact assessment that involves professional judgement based on available guidance and information.

The methodology used to determine the ecological value and potential impacts to site receptors are given in Tables 01, 02 and 03, below:

Table 01: The criteria used for determining the ecological value of site receptors, based on a geographical form of reference (Source: IEEM 2011).

Ecological Value Geographical Frame of Reference

Very High International and European Value

High National and Regional Value

Medium County or District Value

Low Parish (or Local) Value or within the Zone of Influence

only

Negligible Slight or no Value

Table 02: The criteria used for determining the magnitude of impacts to site receptors (Source: IEEM 2011 & DfT 2008).

Magnitude Criteria

Major

Loss of resource and/or quality and integrity; severe damage to key characteristics, features or elements (Adverse).

Large scale or major improvement of resource quality; extensive restoration or enhancement; major improvement of attribute quality (Beneficial).

Moderate

Significant impact on the resource, but not adversely affecting the integrity; partial loss of/damage to key characteristics, features or elements (Adverse).

Benefit to, or addition of, key characteristics, features or elements; improvement of attribute quality (Beneficial).

Minor

Some measurable change in attributes quality or vulnerability; minor loss of, or alteration to, one (maybe more) key characteristics, features or elements (Adverse).

Minor benefit to, or addition of, one (maybe more) key characteristics, features or elements; some beneficial impact on attribute or a reduced risk of negative impact occurring (Beneficial).

Negligible

Very minor loss or detrimental alteration to one or more characteristics, features or elements (Adverse).

Very minor benefit to or positive addition of one or more characteristics, features or elements (Beneficial).

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Magnitude Criteria

No change No loss or alteration of characteristics, features or elements; no

observable impact in either direction.

Table 03: The criteria used for determining the significance of impacts to site receptors (Source: IEEM 2011 & DfT 2008).

MAGNITUDE OF IMPACT

ECOLOGICAL VALUE OF RECEPTOR

Negligible Low Medium High Very High

No Change Neutral Neutral Neutral Neutral Neutral

Negligible Neutral Neutral to Slight

Neutral to Slight Slight Slight

Minor Neutral to Slight

Neutral to Slight Slight Slight to

Moderate Moderate to

Large

Moderate Neutral to Slight Slight Moderate Moderate to

Large Large to

Very Large

Major Slight Slight to Moderate

Moderate to Large

Large or Very Large Very Large

5.0 Results 5.1 Desktop Study 5.1.1 Statutory Sites of Nature Conservation Interest

There are no statutory sites of nature conservation interest within 1km radius of the survey area.

5.1.2 Non-Statutory Sites of Nature Conservation Interest There is one non-statutory site of nature conservation interest within 1km of the survey site. This is the Sywell Wood Potential Wildlife Site (pWS) to the south west of the site.

5.1.3 Protected Species

Records exist for protected species within the 1km search radius. Badgers have historically been recorded along the A43 route corridor.

5.2 Habitats

5.2.1 Bunds The area at TN1 is an acoustic bund to the south of the shooting ground. The bund demarcates the survey area, but also extends to the east, marking the southern boundary of the rifle range. The dominant habitat on the bund is developing rough grassland with a closed grassland sward. Grass species

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include rye (Lolium perenne), cocks foot (Dactylis glomerata), false oat grass (Arrhenatherum elatius), rough meadow grass (Poa trivialis), timothy (Phleum pratense), creeping bent (Agrostis stolonifera), red fescue (Festuca rubra) and tall fescue (Festuca arundinacea). Herbaceous species within the sward include sow thistle (Sonchus asper), creeping cinquefoil (Potentilla reptans), dock (Rumex sp), hairy willowherb (Epilobium hirsutum), hogweed (Heracleum sphondylium), ribwort plantain (Plantago lanceolata), ox-eye daisy (Leucanthemum vulgaris) and creeping thistle (Cirsium arvense). Species of recently disturbed ground occurred at the base of the bund by the track including teasel (Dipsacus fullonum), scentless mayweed (Tripleurospermum inodorum). Scrub species encroaching into the rough grass include seedlings of hawthorn (Crataegus monogyna), dogwood (Cornus sanguinea) and elder (Sambucus nigra).

Photograph 1. Bund to south of survey area

5.2.2 Disturbed Ground TN2 is an area of disturbed ground situated between the track and the stream that runs along the southern boundary of the survey area. Grass species include rye (Lolium perenne), sterile brome (Anisantha sterilis) false oat grass (Arrhenatherum elatius), rough meadow grass (Poa trivialis), timothy (Phleum pratense), creeping bent (Agrostis stolonifera) and tall fescue (Festuca arundinacea). Herbaceous species within the sward include sow thistle (Sonchus asper), creeping cinquefoil (Potentilla reptans), dock (Rumex sp), hairy willowherb (Epilobium hirsutum), spear thistle (Cirsium vulgare) and creeping thistle. Scrub species encroaching include hawthorn and elder (Sambucus nigra). Other species synonymous with disturbed ground include teasel, groundsel (Senecio vulgaris), plantain (Plantago media and P. lanceolata), nipplewort, (Lapsana communis), mullein (Verbascum thapsus), mugwort (Artemisia vulgaris), field speedwell (Veronica persica), spurge (Euphorbia sp), common mallow (Malva sylvestris) and nettle (Urtica dioica).

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Photograph 2. Area of disturbed ground adjacent to the track

5.2.3 Stream A stream flows from the balancing pond at TN11 and forms a boundary of the site. The stream has a width of ~4m from bank-top to bank-top. The banks are steep and the bottom 0.5m is almost vertical. The stream channel has a depth of ~2m.

The stream course is overgrown except at the entrance to the culvert. The bank tops are vegetated with tall ruderals including hairy willow herb, nettle, bramble (Rubus fruticosus agg), smooth sow-thistle (Sonchus oleraceus), spear thistle, hogweed, fleabane (Pulicaria dysenterica), tufted hair grass (Deschampsia cespitosa) and meadowsweet (Filipendula ulmaria).

The banks are dominated by mature hawthorn stands with occasional goat willow (Salix caprea) and young ash (Fraxinus excelsior) and oak (Quercus robur), some of which reach up to 8m in height. Other species present include dog rose (Rosa canina).

Photograph 3. Culvert of stream at TN3

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Photograph 4. Stream (TN3) overgrown with vegetation The stream course is heavily shaded by the dense vegetation. Where the light penetrates small patches of watercress (Rorippa nasturtium-aquatica) have established with clumps of rush (Juncus sp).

Photograph 5. Showing vegetation in the stream course A stand of Portuguese laurel (Prunus lusitanica) has been planted and become well-established at the north-eastern end of the stream, near to the culvert from the balancing pond.

5.2.4 Amenity Grass An area of amenity grass dominates the survey area. The sward is actively managed with a regular mowing regime, maintaining a short sward height. Species present within the sward include clover (Trifolium sp), red fescue (Festuca rubra), rye (Lolium perenne), creeping thistle (Cirsium arvense), creeping buttercup (Ranunculus repens), dandelion (Taraxacum officinale) and cocks foot (Dactylis glomerata).

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At TN5, on the right hand side of the grassland sward, are four newly planted saplings.

Photograph 6. Planted saplings at TN5 TN6 is a small earth mound within the amenity sward. The mound has a height of approximately 1.75m and is vegetated by tall ruderals including creeping thistle, nettle, hogweed, teasel, cocksfoot, false oat grass, tufted hair grass and dock.

Evidence of rabbit activity was noted within the mound, with several holes present.

Photograph 7. Earth mound at TN6 with scrub and ruderal vegetation at the base

5.2.5 North West Perimeters Seven Leyland cypress (Cupressocyparis leylandii) at the entrance to the site, with three on one side and four on the other. Adjacent to the Leylandii lies a small, uncultivated mound with rough grass, ruderals and three saplings; two horse chestnut (Aesculus hippocastanum) saplings approximately between 2 –

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3.5m high and one ash sapling with a height of approximately 5m. Evidence of rabbit activity was noted within the mound, with several holes present.

Photograph 8. Bund with Leyland cypress at the entrance to the survey site

5.2.6 Perimeter Bund – North East TN 8 is an earth bund approximately 6 – 7m in height. On the southern (site) side, the bund is vegetated by tall ruderals, dominated by nettle and creeping thistle with similar ruderals to the bund at TN1. Two eucalyptus saplings and a damaged horse chestnut sapling occur towards the base of the bund.

Photograph 9. Earth bund at TN8

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Photograph 10. North west end of bund The earth mound at TN9 meets TN8 in the north western corner of the survey site. The earth mound supports tall ruderal vegetation, although some areas of the mound show evidence of recent disturbance. Scrub is beginning to naturally regenerate with species present including elder, dog rose, ash, grey willow (Salix cinerea), eared willow (Salix aurita) and stands of hawthorn (Crataegus monogyna). The scrub has reached a height of approximately 8m.

Photograph 11. TN9

5.2.7 Hedge TN10 is an unmanaged, mature hawthorn and blackthorn (Prunus spinosa) dominated hedge line. The hedge is comprised of a triple row of planting over a ditch with a width at the southern end of approximately 10m and a height that varies along its length. Where the shade is dense, little undergrowth occurs. Where light penetrates, the understorey comprises ruderals and bramble scrub with self-set eared willow and ash saplings. The hedgerow shows evidence of having been laid at some time in the past. A number of ash trees are present along its length with occasional young oak (Quercus robur) stands.

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Photographs 12. Mature hedge

Photograph 13. Hedge and understorey at TN10 At the north east end the hedge narrows and becomes a double row with additional sycamore (Acer pseudoplatanus).

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Photograph 14. Hedge with sycamore stands Adjacent to the hedge is an area of amenity grass with a length of earth mound, approximately 4m high, vegetated by tall ruderals, TN12 and TN13. A number of saplings have been planted in the grass by the bund.

5.2.8 Offsite Pond TN11 is an offsite balancing pond present to the south east corner of the survey area. The pond is fed by a stream that flows along the southern boundary of the rifle range. The pond in turn then flows into the stream at TN3. The pond has water lilies present on its surface and fish have been recorded in the pond.

Photograph 15. Pond at TN11 The amenity grass habitats are of negligible biodiversity value. The remaining habitats on site are of low local biodiversity value.

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5.3 Species

No evidence of protected species, such as badger, was noted on site at the time of survey. The pond immediately offsite from the development proposals had coarse fish present and was unlikely to support a successful breeding population of great crested newt. The habitats on site, such as the amenity grassland, are sub-optimal habitat for the terrestrial phase of the newt. The rough grass and tall ruderals on the bunds that are to be removed could provide foraging habitat for newts. There are no records of meta-populations of GCNs in the area. The stream course was examined for a potential water vole population. The water level in the stream is regularly very low and the stream would provide sub-optimal habitat for water vole. No evidence of water vole was found at the time of survey. There are no habitats suitable for grass snake on site and no trees sufficiently mature to support bat roosts. A number of rabbit warrens were noted within the bunds on site.

6.0 Impacts

In the area of amenity grass, the proposals are to create an undulating area for clay pigeon shooting within the grassland, with inert waste material used to create an elevated plateau. The proposals would result in the removal of the amenity turf and existing low perimeter bunds. In the amenity grass area of TN13 the existing bund would be extended and raised. The bund would not encroach on the mature hedge, with a 5m wide access track maintained for any works required. The removal of the amenity sward, re-contouring of the perimeter bunds, recently planted saplings and the rank grass with tall ruderals would have a negligible impact on the local biodiversity of the site as a whole. The mature hedge along the ephemeral ditch and the stream on the opposite boundary would be retained, giving a neutral impact to these habitats. The overall magnitude of the impact of the proposals on the local biodiversity is, therefore assessed, from Table 3, as being neutral. The new elevated plateau would be planted with native indigenous trees and shrubs which would enhance the biodiversity of the proposed development area and would increase the contribution of this area to the wider site.

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In the long term, the proposals would have a positive beneficial impact on the site’s biodiversity.

7.0 Recommendations 7.1 Habitats 7.1.1 The mature hedge line with semi-mature trees is an important feature on the

site. Although the proposal is to retain that hedge line, the new bunds would be built up close to the hedge. Compaction of soil within the root zone of the hedge by heavy machinery is therefore a potential risk. In order to avoid any impacts on the retained hedge the following recommendation is made: Recommendation: In all cases consideration should be given to ensuring site works are as far away as possible from retained trees and shrubs within, and along, the development site boundaries. In any instance British Standard (BS) 5837 ‘Guide for Trees in Relation to Construction’ (British Standards Institute 2012) should be followed with regards to working nearby retained trees. Work within a Root Protection Area should be avoided to prevent damage to the root structure of each tree. The protected zone should be clearly demarcated by visible Netlon fencing before work commences. If work must take place within this area it should be undertaken carefully by hand following BS 5837.

7.1.2 The retained stream should be regularly cleared on a five year cycle to control the vegetation growth. An unmanaged buffer of uncut vegetation, of at least 1m width, should be retained along the stream bank in order to maximise the ecological value of the water course.

7.1.3 In respect of habitat enhancement, the re-contouring of the ground offers

potential for planting a mix of native indigenous trees and shrubs. The planting could be extended up the west facing side of the perimeter acoustic bunds. To ensure that the height of the planting does not exceed requirements from the airport in respect of flight lines, the canopy trees should be planted towards the base of the bunds. Recommendations: i) Following the re-contouring, areas of disturbed ground along the margins and

bunding should be planted with native indigenous shrubs at staggered spacing 2m apart including:

Trees Ash Fraxinus excelsior Aspen Populus tremula Field maple Acer campestre Crab apple Malus sylvestris

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Goat willow Salix caprea Whitebeam Sorbus aria

Shrubs

Hawthorn Crataegus monogyna Midland Hawthorn Crataegus laevigata Dogwood Cornus sanguinea Wild privet Ligustrum vulgare Holly Ilex aquifolium Blackthorn Prunus spinosa Buckthorn Rhamnus catharticus

ii) To allow for the natural development of a diverse ground flora unplanted

areas should be allowed to re-vegetate naturally which would result in a diverse flora suited to the ground conditions.

iii) Where grass seeding is necessary a wild flower mix could be used that would

respond to close mowing.

7.2 Species

7.2.1 The hedgeline, small trees and areas of scrub have the potential to support breeding birds. Recommendation: To avoid negative impacts to nesting birds any clearance works on site should be conducted outside the bird breeding season (March-September). If works are conducted between March and September a nesting bird survey must be carried out by a qualified ecologist prior to clearance. Any located nests must then be identified and left undisturbed until the young have left the nest.

7.2.2 No evidence of any other protected species was noted on site at the time of survey.

8.0 Conclusion

The proposed development would result in the loss of areas of amenity grassland and alteration of bunds vegetated by common widespread tall grasses, tall ruderals, occasional shrubs and conifer trees. Young tree saplings would also be removed. The ecological value of the habitats to be removed is negligible. The area would be re-contoured with a plateau of raised topography. Recommendations are made for the consideration of trees retained on site, landscaping to enhance the biodiversity of the site, stream management to

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maximize the ecological value of the water course and protection of breeding birds during the works stage.

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References BCT (2012) Bat Surveys – Good Practice Guidelines. Bat Conservation Trust, London British Standards Institute (BSI) (2012). BS 5837 ‘Guide for Trees in Relation to Construction – Recommendations’ DfCLG (2012). National Planning Policy Framework, DfCLG, London. HMSO (1981). Wildlife and Countryside Act. HMSO, London HMSO (2010). Conservation and Natural Habitats Regulations. HMSO, London HMSO (2000). Countryside and Rights of Way (CRoW) Act. HMSO, London HMSO (2006). Natural Environment and Rural Communities Act 2006. HMSO, London. JNCC (2007). Handbook for Phase 1 Habitat Survey. Peterborough Stace, C. (1999). Field Flora of the British Isles. Cambridge University Press

Websites: MAGIC www.magic.gov.uk Natural England www.naturalengland.org.uk Northamptonshire Biodiversity Action Plan

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APPENDIX 1

TARGET NOTES

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Target Note Description

TN1

Acoustic bunding dominated by closed grassland sward. Grass species include rye (Lolium perenne), sterile brome (Anisantha sterilis), cocks foot (Dactylis glomerata), false oat grass (Arrhenatherum elatius), rough meadow grass (Poa trivialis), timothy (Phleum pratense), creeping bent (Agrostis stolonifera), red fescue (Festuca rubra) and tall fescue (Festuca arundinacea). Herbaceous species within the sward include sow thistle (Sonchus asper), creeping cinquefoil (Potentilla reptans), dock (Rumex sp), hairy willowherb (Epilobium hirsutum), hogweed (Heracleum sphondylium), ribwort plantain (Plantago lanceolata), ox-eye daisy (Leucanthemum vulgaris) and creeping thistle (Cirsium arvense). Species of recently disturbed ground occurred at the base of the bund by the track including teasel (Dipsacus fullonum), scentless mayweed (Tripleurospermum inodorum). Scrub species encroaching into the rough grass include seedlings of hawthorn (Crataegus monogyna), dogwood (Cornus sanguinea) and elder (Sambucus nigra).

TN2

An area of disturbed ground between the track and the line of the stream. Grass species include rye (Lolium perenne), sterile brome (Anisantha sterilis) false oat grass (Arrhenatherum elatius), rough meadow grass (Poa trivialis), timothy (Phleum pratense), creeping bent (Agrostis stolonifera) and tall fescue (Festuca arundinacea). Herbaceous species within the sward include, sow thistle (Sonchus asper), creeping cinquefoil (Potentilla reptans), dock (Rumex sp), hairy willowherb (Epilobium hirsutum), spear thistle (Cirsium vulgare) and creeping thistle. Scrub species encroaching include hawthorn and elder (Sambucus nigra). Other species synonymous with disturbed ground include teasel, groundsel (Senecio vulgaris), plantain (Plantago media and P. lanceolata), nipplewort, (Lapsana communis), mullein (Verbascum thapsus), mugwort (Artemisia vulgaris), field speedwell (Veronica persica), spurge (Euphorbia sp), common mallow (Malva sylvestris) and nettle (Urtica dioica).

TN3

Stream that flows from the balancing pond at TN11. The stream has a width of ~4m from bank-top to bank-top. The banks are steep and the bottom 0.5m is almost vertical. The stream channel has a depth of ~2m. The stream course is overgrown except at the entrance to the culvert. The bank tops are vegetated with tall ruderals including hairy willow herb, nettle, bramble (Rubus fruticosus agg), smooth sow-thistle (Sonchus oleraceus), spear thistle, hogweed, fleabane (Pulicaria dysenterica), tufted hair grass (Deschampsia cespitosa) and meadowsweet (Filipendula ulmaria). The banks are dominated by mature hawthorn stands with occasional goat willow (Salix caprea) and young ash (Fraxinus excelsior) and oak (Quercus robur), some of which reach up to 8m in height. Other species present include dog rose (Rosa canina). The stream course is heavily shaded by the dense vegetation. Where the light penetrates small patches of watercress (Rorippa nasturtium-aquatica) have established with clumps of rush (Juncus sp).

A stand of Portuguese laurel (Prunus lusitanica) has been planted and become well-established at the north-eastern end of the stream, near to the culvert from the balancing pond.

TN4

An area of amenity grass that dominates the survey area. The sward is actively managed with a regular mowing regime, maintaining a short sward height. Species present within the sward include clover (Trifolium sp), red fescue (Festuca rubra), rye (Lolium perenne), creeping thistle (Cirsium arvense), creeping buttercup (Ranunculus repens), dandelion (Taraxacum officinale) and cocks foot (Dactylis glomerata).

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Target Note Description

TN5 Four newly planted saplings on the right hand side of the grassland sward.

TN6

Small earth mound within the amenity sward. The mound has a height of approximately 1.75m and is vegetated by tall ruderals including creeping thistle, nettle, hogweed, teasel, cocksfoot, false oat grass, tufted hair grass and dock. Evidence of rabbit activity was noted within the mound, with several holes present.

TN7

Seven Leyland cypress (Cupressocyparis leylandii) at the entrance to the site, with three on one side and four on the other. Adjacent to the Leylandii a small uncultivated mound with rough grass, ruderals and three saplings: two horse chestnut (Aesculus hippocastanum) saplings approximately between 2 – 3.5m high and one ash sapling with a height of approximately 5m. Evidence of rabbit activity was noted within the mound, with several holes present.

TN8

Earth bund approximately 6 – 7m in height, On the southern (site) side, the bund is vegetated by tall ruderals, dominated by nettle and creeping thistle with similar ruderals to the bund at TN1. Two eucalyptus saplings and a damaged horse chestnut sapling occur towards the base of the bund.

TN9

Earth mound that meets TN8 in the north western corner of the survey site. The earth mound supports tall ruderal vegetation, although some areas of the mound show evidence of recent disturbance. Scrub is beginning to naturally regenerate with species present including elder, dog rose, ash, grey willow (Salix cinerea), eared willow (Salix aurita) and stands of hawthorn (Crataegus monogyna). The scrub has reached a height of approximately 8m.

TN10

An unmanaged, mature hawthorn and blackthorn (Prunus spinosa) dominated hedge line. A triple row of planting over a ditch with a width at the southern end of approximately 10m and a height that varies along its length. Where the shade is dense little undergrowth occurs. Where light penetrates the understorey comprises ruderals and bramble scrub with self-set eared willow and ash saplings. The hedgerow shows evidence of having been laid at some time in the past. A number of ash trees are present along its length with occasional young oak (Quercus robur) stands. At the north east end the hedge narrows and becomes a double row with additional sycamore (Acer pseudoplatanus).

TN11

An offsite balancing pond present to the south east corner of the survey area. The pond is fed by a stream that flows along the southern boundary of the rifle range. The pond in turn then flows into the stream at TN3. The pond has water lilies present on its surface and fish were noted within the pond at the time of survey.

TN12 An earth mound approximately 4m high vegetated by tall ruderals.

TN13 Amenity grass with a similar mix as TN4.

TN14 Offsite rubble pile with occasional areas vegetated by tall ruderals, buddlea seedlings and valerian.

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Planning Statement Sywell Shooting Ground, Sywell, Northamptonshire

The application is for an extension of the time conditions to the existing permitted use for the operation of a recycled inert waste export facility under Northamptonshire County Council reference 10/00074/WAS. The site is located on the A43 approximately 4 miles North of Northampton, 7 miles South of Kettering and 5 miles West of Wellingborough. The site already benefits from a consent which involves the importation of waste material for the construction of other parts of the shooting grounds and there is an additional application for an extension of the time limits in relation to this. The imported material is screened and material crushed. This provides suitable material to be used in the construction of the permitted go-kart track and mounding. Material that is not suitable is then transported off site to be recycled in alternative uses within the local vicinity. The delay in the building of the already permitted go kart track and mounding to which this application compliments has been due to the uneconomical conditions which meant it has not been possible to operate the waste management site. In addition to this there has been complications in relation to the movement of the overhead power lines which has been an extremely long drawn out process but is now resolved. With the recent improvement in the UK economy, increased drive in sustainable development and with the recently agreed solution in respect of the overhead power lines, the operations to complete the works are set to commence although an extension of the time limits is required in order to complete them. With regard to planning policy, PPS10 considers sustainable waste management. The waste hierarchy shows the reuse and recycling of materials as a key means of moving towards a more sustainable waste management system. In terms of the waste hierarchy apart from reduction, which is clearly not in the applicant’s control, there is no better use. As it is inert material it will not cause damage to the environment. Hardcore inert material will be used again off site in other development schemes, thereby meeting the objectives of the waste hierarchy.

The PPS10 also considers identifying suitable sites and areas and states“…waste planning authorities should consider…looking for opportunities to collocate facilities together and with complementary activities”.

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The site has been operating as a waste management site since the early 1990’s with the granting of consent for the construction of sound attenuation screens. Inert material was being imported on to the site in accordance with a consent dated 18 November 1998 for the construction of a 600m rifle range with safety bunding. The design however was altered with consent granted for mounding in April 2010 and to which the use of the mobile crusher and screen forms an integral part. The supply comes principally from the nearby towns within Northamptonshire. There is no reason why this would change if an extension to the consent were granted. Clearly this proposal is a complementary activity in so far as the export facility complements the works needed to complete the already permitted go kart track and also the mounding but principally enabling the recycling of the waste that is not suitable for use on site may be used within alternative uses within the local vicinity. PPS10 goes on to state that planning authorities should assess their suitability for development against “the extent to which they support the policies in this PPS” further to which the proposal does so in so far that it looks to address waste as a resource, enabling the creation of the go kart track and as such meets the key planning objectives set out in PPS10. Further criteria consists of the assessment of “the physical and environmental constraints on development, including existing and proposed neighbouring land uses” and concerns the following points:

a) Protection of water resources

As with the original consent, the material being used is inert therefore posing no risk to the water resources and has no effect on flooding as confirmed by the Flood Risk Assessment.

b) Land instability

The land is stable and there has been no subsequent movements in so far as we are aware.

c) Visual intrusion

Consent has already been granted in respect of the works and consideration already made towards the impact they may have. But for clarification the site is not within any designation and the works will fit in with the existing land use, in so doing minimising any impact they may have.

d) Nature conservation

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No adverse effects have arisen from previous works carried out under the original consent and the Habitat Survey confirms that there is no present risk in respect of continued works should an extension of the time conditions be granted.

e) Historic environment and built heritage

The works have not and will not have any effect as there is none in the vicinity in so far as we are aware.

f) Traffic and access

Consent has already been granted therefore consideration will have already been made to the levels of traffic resulting from the works and the extension of the time conditions will not have any effect on traffic movement or numbers. Should an extension be granted then the vehicles that would normally be leaving empty could remove recycled material to be used elsewhere, thereby reducing the carbon footprint.

g) Air emissions, including dust.

There will be no change in relation to emissions and dust, with the site continuing to conduct measures to prevent dust in accordance with the original consent.

h) Odours

The material is inert and so no odours will be produced.

i) Vermin and birds

The material is inert and so it is unlikely that that either of the above will become an issue for consideration.

j) Noise and vibration

The level of noise will have duly have been considered when consent was granted for the shooting ground and other works. The subsequent construction of the shooting ground has resulted in several noise attenuation bunds which mitigate the impact of noise.

k) Litter

The material is inert but never the less this does not negate the possibility of some littler being transported to the site and the site will continue to address this within its normal practices under the original consent.

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l) Potential land use conflict As consent has already been granted there is little likelihood of land use conflict should an extension be granted as it will merely allow the completion of works.

Clearly this proposal meets the requirements set out under PPS10 but further to this consideration has to be made to the Northamptonshire Minerals and Waste Development Framework forming part of The Core Strategy which was adopted in May 2010. Objective 1 of the Northamptonshire Minerals and Waste Development Framework concentrates on “Developing sustainable communities” through means of “… a modern network of sustainable waste management facilities which contributes towards achieving regional self-sufficiency” and this application supports this by allowing materials not suitable for onsite projects to be exported off site to be used locally. Objective 10 concerns ‘Conserving and enhancing Northamptonshire’s built and natural environment’. This is done via “…sensitive workings and where necessary high standards of mitigation”. In light of this and the environmental factors a Habitat Survey and Flood Risk assessment have been previously carried out on the site which included consideration of the type of activity proposed. Both reports concluded that there were no flood risks and the effect on ecological factors were negligible. Further to this, additional update assessments have been recently carried out which form part of this application, with the conclusions remaining as originally described in the first assessments. Objective 12 focuses on the “Safe and healthy communities” particularly the preservation of residential amenity and promote recreation opportunities. The current use has no effect on local amenity. There are no residential dwellings in the immediate area. The materials are inert and therefore cause no harm to the environment. There is no issue with noise and in fact any noise created is very much secondary to the adjacent airfield. The operation would allow for the expansion of the shooting ground and the completion of the already permitted go kart track and in doing so supports objective 12 by providing additional recreation opportunities. Policy CS1 considers Northamptonshire’s waste management capacity. The policy requires the growth of a network of facilities to meet capacities during the Plan period.

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To achieve this growth the provision will come “from a mix of extensions to existing sites, intensification or re-development of existing sites and new sites, providing they meet the spatial strategy for waste management and are assessed as meeting environmental, amenity and other requirements.” The site already carries out waste management activities and as such this proposals falls squarely into the intensification element of it albeit it will not be intensification in terms of vehicle movements. Although there has been factors beyond the control of the applicant that have resulted in a delay, now that these have been resolved the operations are set to re-commence in order to complete the works and there has be significant interest in the use of the site by external operators. With regards to the environmental amenity, this has been addressed by the supplementary Habitat Assessment report that found the effect of the site on environmental issues was negligible. Policy CS2 considers the spatial strategy for waste management. Facilities within Northamptonshire’s waste management network should be focused within the central spine. The central spine runs from Northampton to Corby and encompasses Wellingborough and Kettering. This site is therefore extremely well located within the spine area. Policy CS14 requires that the impact of the proposed development be addressed.

• Minimising environmental impact and protecting Northamptonshire’s key environmental designations.

Until recently and due to factors beyond individual control a significant waste management process was ongoing at the site which involved a number of vehicle movements each day. This extension will allow the completion of the works but will not result in any change other than what was previously acceptable.

• Protecting natural resources or ensuring that any unavoidable loss or reduction is mitigated. The proposal will not use up any natural resources.

• Ensuring built development is of a design and layout that has regard to its visual appearance in the context of the defining characteristics of the local area

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There is no built development proposed.

• Ensuring access is sustainable, safe and environmentally acceptable The site is immediately off the A43, within the central spine. The access is safe and the proposal will not create any more traffic movements than are already permitted.

• Ensuring that local amenity is protected The proposed use has no effect on local amenity. There are no residential dwellings in the immediate area. The materials are inert and therefore cause no harm to the environment. There is no issue with noise in fact any noise created is very much secondary to the adjacent airfield. Turing briefly to the Control and Management of Development DPD, Policy CMD3 Development criteria for inert waste disposal and recovery specifies that “… where this does not relate to the restoration of a site identified in the Location for Mineral DPD, must demonstrate that: there is clear engineering, agricultural, landscape or recreation amenity justification for the development”. In view of this statement the original proposal meets this requirement and the extension of the time limit would allow its completion. Policy CMD5 states that preference for the development of this type of facility should be in locations within amongst others “Existing, permitted or allocated waste management / disposal facilities (including temporary facilities) where this accords with the type of waste management / disposal use at that location.” As detailed throughout the above the current process already fit in with the policies under the relevant material. The reasons behind the delay have been beyond the control of the applicant but never the less there remains a willingness to see the project through to completion on the basis that an extension to the proposal is granted.