9 historic environment - kemsley kemsley generating station – power upgrade: peir chapter 9 march...

WTI Kemsley Generating Station – Power Upgrade: PEIR Chapter 9

March 2017 9-1

9 Historic Environment

Introduction

9.1 This chapter considers the direct and indirect effects of the Project (which includes the proposed

generating station, related development and the Incinerator Bottom Ash Recycling Facility) on the

historic environment of the area, including buried archaeological sites, historic buildings and

historic landscapes. It aims to identify all effects on these heritage assets - in terms of the

potential for direct physical disturbance and indirect visual effects on setting - and to assess the

overall effect and significance of these predicted effects.

9.2 The chapter reports on studies, including a combination of field surveys and desktop research, to

describe, classify and evaluate the existing resource. The likely impacts are assessed during the

construction, operational and decommissioning phases of the proposed development. Full details

of the development proposed are presented in Chapter 2 and accompanying figures, which set

the basis against which this assessment has been conducted.

Assessment Methodology

Relevant Legislation

9.3 Listed buildings are protected under the provisions 54(i) of the Town and Country Planning Act

(1971), as amended by the Planning (Listed Buildings and Conservation Areas) Act (1990) which

empowers the Secretary of State for the Department of Culture, Media and Sport (DCMS) to

maintain a list of built structures of historic or architectural significance.

9.4 Scheduled monuments are protected through the Ancient Monuments and Archaeological Areas

Act (1979), which had been updated in the National Heritage Act (1983). Scheduled monuments

are maintained on a list held by the Secretary of State for DCMS. Any alterations or works to a

scheduled monument (including archaeological investigation) requires scheduled monument

consent (SMC).

Planning Policy Context

9.5 As part of establishing the existing baseline environment, the assessment reviewed and

considered a range of relevant national policies.

9.6 In July 2011 the Secretary of State for Energy and Climate Change designated the six National

Policy Statements for Energy (NPSs) under the Planning Act 2008. These NPSs set out national

policy against which proposals for major energy schemes will be assessed and determined by the

Infrastructure Planning Commission (IPC) and its successor bodies.

9.7 The NPSs which are relevant to the application for the proposed development are the:

Overarching National Policy Statement for Energy (NPS EN-1) (Department of Energy and

Climate Change (DECC), 2011a);

Renewable Energy Infrastructure National Policy Statement (NPS EN-3) (DECC, 2011b);

and


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Renewable Energy Infrastructure National Policy Statement (NPS EN-5); Department of

Energy and Climate Change (DECC, 2011c);

9.8 NPS EN-1 responds to the guidance provided in the NPPF (set out below). The applicant has to

ensure that the extent of the impact of the proposed development on the significance of any

heritage assets affected can be adequately understood from the application documents (NPS EN-

1: paragraph 5.8.10).

9.9 NPS EN-1 advises that harmful impacts on the significance of heritage assets should be weighed

against the public benefit of the proposed development, also that where a development may

affect the setting of a heritage asset the IPC and its successor bodies should treat more

favourably applications that preserve those elements of the setting that make a positive

contribution to the significance of the asset.

9.10 NPS EN1 at paragraph 5.5.8 notes that applicants should provide a description of the significance

of the heritage assets affected by the proposed development and the contribution of their setting

to that significance. The level of detail should be proportionate to the importance of the heritage

assets and no more than is sufficient to understand the potential impact of the proposal on the

significance of the heritage asset.

9.11 NPS EN1 at paragraph 5.5.8 goes on to note that as a minimum the applicant should have

consulted the relevant Historic Environment Record (or, where the development is in English or

Welsh waters, EH or Cadw) and assessed the heritage assets themselves using expertise where

necessary according to the proposed development’s impact.

9.12 NPS EN1 at paragraph 5.8.9 notes that where a development site includes, or the available

evidence suggests it has the potential to include, heritage assets with an archaeological interest,

the applicant should carry out an appropriate desk based assessment (DBA) and, where such

desk-based research is insufficient to properly assess the interest, a field evaluation.

9.13 NPS EN1 at paragraph 5.8.9 goes on to note that where proposed development will affect the

setting of a heritage asset, representative visualisations may be necessary to explain the impact

9.14 NPS EN3 does not provide specific guidance on potential impacts on the historic environment

resulting from the development of biomass and waste combustion.

9.15 NPS EN-5 does not provide specific guidance on potential impacts on the historic environment

resulting from the development of electricity network infrastructure. NPS EN-5 notes, however, at

section 2.2.6 that developers will be influenced by Schedule 9 to the Electricity Act 1989, which

places a duty on all transmission and distribution licence holders, in formulating proposals for new

electricity networks infrastructure, to have regard to the desirability of protecting sites, buildings

and objects of architectural, historic or archaeological interest.

9.16 The National Planning Policy Framework (NPPF) (Department of Communities and Local

Government (DCLG), 2012) provides guidance to planning authorities regarding the protection of

heritage assets within the planning process. The NPPF deals with all types of heritage in a single

document. It takes an integrated approach to the historic environment and heritage assets,

moving beyond a distinction between buildings, landscapes and archaeological remains.


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9.17 A heritage asset is defined in the NPPF at page 52 as a building, monument, site, place, area or

landscape identified as having a degree of significance meriting consideration in planning

decisions, because of its heritage interest. Heritage assets include designated heritage assets

and assets identified by the local planning authority (including local listing).

9.18 ‘Setting of a heritage asset’ is defined in the NPPF at page 56 as the surroundings in which a

heritage asset is experienced. Its extent is not fixed and may change as the asset and its

surroundings evolve. Elements of a setting may make a positive or negative contribution to the

significance of an asset, may affect the ability to appreciate that significance or may be neutral.

Relevant Guidance

9.19 The assessment has conformed to the relevant guidance, including:

Overarching Energy National Policy Statement (NPS EN-1); Department of Energy and

Climate Change (DECC) ( 2011a);


Energy and Climate Change (DECC) ( 2011b);


Energy and Climate Change (DECC) ( 2011c);

National Planning Policy Framework (NPPF) Department of Communities and Local

Government (DCLG) (March 2012);

Conservation Principles Policies and Guidance for the Sustainable Management of the

Historic Environment Historic England (2008).

The Setting of Heritage Assets Historic England (2015) Code of Conduct Chartered Institute

for Archaeologists (2014);

Standard and Guidance for Historic Environment Desk Based Assessment Chartered

Institute for Archaeologists (2014); and

Historic Environment Good Practice in Planning Note 3: The Setting of Heritage Assets

Historic England (2015)

Study Area

9.20 The study area is based upon recent experience of similar developments, the site visit and

consideration of the landscape study, including the zone of theoretical visibility (ZTV) that has

been defined for the Landscape, Townscape and Visual Resources assessment (Chapter 5).

This chapter, for the purpose of buried archaeology, focuses on a study area of 1km around the

assessment boundary. For the purpose of the settings of heritage assets, this chapter focuses on

a study area of 3km around the assessment boundary while taking into consideration evidence

from a wider area if appropriate.

9.21 With respect to the settings of heritage assets, only those assets which lie within the ZTV are

assessed, using the guidance prepared by Historic England in their document “The Setting of


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Heritage Assets”(Historic England, 2015) along with “Conservation Principles”.(Historic England

2008).

Baseline Methodology

9.22 A baseline desk assessment and site walkover survey has been undertaken.

9.23 The desk assessment comprised, in the first instance, consultation with the Kent County

Archaeology Advisory Service and their Historic Environment Record (HER). Data on scheduled

monuments, registered parks and gardens and registered battlefields was obtained from English

Heritage. A review of relevant documentary and archival material held in libraries and archives

was undertaken. An iterative approach was adopted during this process to determine the scope of

the above consultations/searches.

9.24 A site visit was undertaken in December 2016 to establish the presence of above ground

archaeology, whether or not previously recorded and to verify the settings of the heritage assets

surrounding the proposed development site.

Consultation

9.25 Table 9.1 below details the consultation undertaken as part of the DCO process to date which is

of relevance to this chapter.

Table 9.1: Consultation Responses Relevant to this Chapter

Date Consultee and Issues Raised How/ Where Addressed

16th

January 2017

Historic England – Consultation Response to Scoping Report This development could, potentially, have an impact upon designated heritage assets and their settings in the area around the site. We would draw your attention, in particular, to the following: • Castle Rough scheduled monument (National Heritage List no 1013368), a medieval moated manor site which lies c.500m south-south west of the proposed development site, and which may be inter-visible with the proposed buildings. We would also expect the Environmental Statement to consider the potential impacts on non-designated features of historic, architectural, archaeological or artistic interest, since these can also be of national importance and make an important contribution to the character and local distinctiveness of an area and its sense of place. We would expect the assessment to clearly demonstrate that the extent of the proposed study area is of the appropriate

This is addressed throughout this PEIR chapter, in particular at paragraph 9.135 et seq This is addressed in particular at paragraph 9.135 et seq This is addressed throughout the PEIR, in particular at paragraph 9.125 et seq This is addressed through the


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Date Consultee and Issues Raised How/ Where Addressed

size to ensure that all heritage assets likely to be affected by this development have been included and can be properly assessed. We judge the parameters identified in the Historic Environment chapter of the EIA Scoping report to be sufficient for this purpose. It is important that the assessment is designed to ensure that all impacts are fully understood. Section drawings and techniques such as photomontages are a useful part of this. Consideration should also be given to undertaking a practical exercise with either a crane or balloons erected at the height of the proposed building and chimneys so that all parties are better able to understand the landscape impact of the proposals. The assessment should also take account of the potential impact which associated activities (such as construction, servicing and maintenance, and associated traffic) might have upon perceptions, understanding and appreciation of the heritage assets in the area. The assessment should also consider, where appropriate, the likelihood of alterations to drainage patterns that might lead to in situ decomposition or destruction of below ground archaeological remains and deposits.

adoption of an appropriate study area, as proposed in the scoping report, approved by Historic England in their letter of 16

th January 2017

and utilised within the PEIR. This is addressed throughout the PEIR. The baseline section (paragraph 9.72 et seq) considers those assets likely to be affected by the proposed development. A series of photomontages will be produced primarily to support the LVIA but which will also allow all parties better to understand the landscape impact of the proposals. Given the industrial nature of the area of the proposed development, a crane or balloons erected at the height of the proposed building and chimneys is not considered necessary. This is addressed throughout the PEIR, in particular at paragraph 9.125 et seq

Assessment Criteria and Impact Assessment Methodology

9.26 The significance of predicted impacts likely to occur during construction, operation and

decommissioning phases of the proposed development has been determined by consideration of

the importance of assets that may be affected and the magnitude of the predicted impact.

Asset Significance and Importance

9.27 In order to reach an understanding of the likely effect that a project may have on a heritage asset,

it is necessary to understand the significance and importance of that asset.

9.28 Establishing the importance of a heritage asset is principally a means of identifying the extent to

which the asset should be valued. For example, is it important at a national level or at a local

level?

9.29 Significance can primarily be understood through examination of why a structure, site or area

should be considered as a heritage asset. In the NPPF the significance of an asset is defined as:

‘The value of a heritage asset to this and future generations because of its heritage interest. That

interest may be archaeological, architectural, artistic or historic. Significance derives not only from


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a heritage asset’s physical presence, but also from its setting.’ (DCLG, 2012) Annex 2 and cross-

referenced in National Policy Statement EN-1).

9.30 These levels of interest broadly tie in with previous guidance from English Heritage (EH)

expressed in the document Conservation Principles, Policies and Guidance for the Sustainable

Management of the Historic Environment (English Heritage, 2008). This provides guidance on

understanding heritage values and also included a section (Section 6) advising on how to assess

heritage significance.

9.31 According to the guidance published by EH (2008), heritage values fall into four inter-related

groups:

Evidential value – the potential of a place to yield evidence about past human activity;

Historical value - this derives from the ways in which past people, events and aspects of life

can be connected through a place to the present. This value tends to be illustrative (providing

insights into past communities and their activities) or associative (association with a notable

family, person, event or movement);

Aesthetic value – this derives from the ways in which people draw sensory and intellectual

stimulation from a place; and

Communal value – this derives from the meanings of a place for the people who relate to it,

or for whom it figures in their collective experience or memory.

Assessment of Asset Importance - Archaeological Assets

9.32 There are no national government guidelines for evaluating the importance of heritage assets. For

archaeological assets, the Department of Culture, Media and Sport (DCMS) has adopted a series

of recommended (i.e. non-statutory) criteria for use in the determination of national importance

when scheduling ancient monuments. These are expressed in the document Scheduled

Monuments - Identifying, Protecting, Conserving and Investigating Nationally Important

Archaeological Sites under the Ancient Monuments and Archaeological Areas Act 1979 (DCMS,

2010).

9.33 The criteria include period, rarity, documentation, group value, survival/condition,

fragility/vulnerability, diversity and potential, and can be used as a basis for the assessment of the

importance of historic remains and archaeological sites. However, the document also states that

these criteria ‘should not be regarded as definitive; but as indicators which contribute to a wider

judgement based on the individual circumstances of a case.'

9.34 The criteria described above may also be used as a basis for the assessment of the importance

of archaeological assets of less than national importance. However, the categories of regional

and district/local importance are less clearly established than that of national and implicitly relate

to local, district and regional priorities, which themselves vary within and between regions. Where

available, local, district and regional research agenda, and local or structure plans may assist in

this process.


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9.35 It is noted that a high degree of professional judgement is required in the identification of

importance for archaeological assets and this approach has been applied to this assessment,

guided by acknowledged standards, designations and priorities. It is also important to recognise

that buried archaeological remains may not always be well-understood at the time of assessment

and can therefore be of uncertain importance.

9.36 The most recent guidance from any national agency regarding cultural heritage and EIA is from

the Highways Agency and is expressed in Guidance Note 208/07 (August 2007) that now forms

part of the Design Manual for Roads and Bridges, Volume 11, Section 3, Part 2 (HA 208/7)

(Highways Agency et al., 2007).

9.37 The following table (Table 9.2) is primarily based on HA 208/07 and has been used to inform the

assessment.

Table 9.2: Example Definitions of Importance or Value (Archaeological Assets)

Value / Importance

Typical Descriptors

Assets of the highest significance

World Heritage Sites. Assets of acknowledged international importance. Assets that can contribute significantly to acknowledged international research objectives. Scheduled Monuments. Undesignated assets of schedulable quality and importance.

High Assets that can contribute significantly to acknowledged national research objectives.

Medium Designated or undesignated heritage assets that contribute to regional research objectives.

Low Undesignated heritage assets of local importance. Assets compromised by poor preservation and/or poor survival of contextual associations. Assets of limited value, but with potential to contribute to local research objectives.

Negligible Assets with very little or no surviving archaeological interest.

Unknown The importance of the resource cannot be ascertained.

Assessment of Asset Importance - Historic Buildings

9.38 For historic buildings, assessment of importance is usually based on the designations used in the

Listed Building process. Where historic buildings are not listed, or where the listing grade may be

in need of updating, professional judgement has been used.

9.39 The criteria used in establishing the importance of historic buildings within the Listed Building

process include architectural interest, historic interest, close historic association (with nationally

important people or events) and group value. Age and rarity are also taken into account. In

general (where surviving in original or near-original condition), all buildings of pre-1700 date are

listed, most of 1700 to 1840 date are listed, those of 1840 to 1914 date are more selectively

listed, and thereafter even more selectively. Specific criteria have been developed for buildings of

20th century date. At a local level, buildings may be valued for their association with local events

and people or for their role in the community.

9.40 HA 208/07 provides a basis for the following table (Table 9.3), as a guide for establishing the

importance of historic buildings. This has been used to inform the current assessment.


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Table 9.3: Example Definitions of Importance or Value (Historic Buildings)

Value / Importance

Typical Descriptors


Standing buildings inscribed as of universal importance as World Heritage Sites. Other buildings of recognised international importance. Scheduled Monuments with standing remains. Grade I and II* listed buildings. Other listed buildings that can be shown to have exceptional qualities in their fabric or historical association not adequately reflected in the listing grade. Conservation Areas containing very important buildings. Undesignated structures of clear national importance.

High Grade II listed buildings. Historic (unlisted) buildings that can be shown to have exceptional qualities in their fabric or historical association. Conservation Areas containing important buildings.

Medium Historic Townscape or built-up areas with historic integrity in their buildings, or built settings (e.g. including street furniture and other structures).

Low 'Locally listed' buildings. Historic (unlisted) buildings of modest quality in their fabric or historical association. Historic Townscape or built-up areas of limited historic integrity in their buildings, or built settings (e.g. including street furniture and other structures).

Negligible Buildings of no architectural or historic note; buildings of an intrusive character.

Assessment of Asset Importance - Historic Landscapes

9.41 The sub-topic of Historic Landscape is recognised as having significant overlaps with other topics,

such as landscape and townscape and therefore a multi-disciplinary approach to assessment has

been adopted. This is to avoid double counting and duplication of effort. There are also significant

overlaps with the other cultural heritage sub-topics of archaeological remains and historic

buildings. The elements that are considered within those two sub-topics can make significant

contributions to the historic landscape. This latter sub-topic has therefore concentrated on the

overall Historic Landscape Character (HLC) and its value, rather than the individual elements

within it.

9.42 All landscapes have some level of historic significance, as the present whole appearance of the

urban and rural parts of England is the result of human or human-influenced activities overlain on

the physical parameters of climate, geography and geology

9.43 A number of designations can apply to historic landscapes, including World Heritage Sites

(inscribed for their historic landscape value), Registered Parks and Gardens, Registered

Battlefields and Conservation Areas. Some local plans include locally designated Historic

Landscape Areas and Historic Parks and Gardens (or similar).

9.44 A model has been produced by the Council for British Archaeology (Rippon, 2004), whereby the

historic landscape can be divided up into units that are scaled from smallest to largest, as follows:

Elements - individual features such as earthworks, structures, hedges, woods etc.;

Parcels - elements combined to produce, for example farmsteads or fields;


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Components - larger agglomerations of parcels, such as dispersed settlements or straight-

sided field systems;

Types - distinctive and repeated combinations of components defining generic historic

landscapes such as ancient woodlands or parliamentary enclosure;

Zones - characteristic combinations of types, such as Anciently Enclosed Land or Moorland

and Rough Grazing;

Sub-regions - distinguished on the basis of their unique combination of interrelated

components, types and zones; and

Regions - areas sharing an overall consistency over large geographical tracts.

9.45 The model described above can be used as the principal art of the overall assessment usually

known as Historic Landscape Characterisation (HLC). However, although HLC has been

undertaken for much of England, there is no specific guidance or advice regarding the attribution

of importance or significance to identified HLC types.

9.46 The following Table (9.4) is based on the guidance provided in HA 208/07 with regard to

evaluating the importance of historic landscape character units and has been used to inform the

current assessment.

Table 9.4: Example Definitions of Importance or Value (historic landscape character units)

Value / Importance

Typical Descriptors


World Heritage Sites inscribed for their historic landscape qualities. Historic landscape of international sensitivity, whether designated or not. Extremely well-preserved historic landscapes with exceptional coherence, time-depth, or other critical factor(s).

High Designated historic landscapes of outstanding interest. Undesignated landscapes of outstanding interest. Undesignated landscapes of high quality and importance, and of demonstrable national sensitivity. Well-preserved historic landscapes exhibiting exceptional coherence, time-depth, or other critical factor(s).

Medium Designated special historic landscapes. Undesignated historic landscapes that would justify special historic landscape designation, landscapes of regional sensitivity. Averagely well preserved historic landscapes with reasonable coherence, time-depth, or other critical factor(s).

Low Robust undesignated historic landscapes. Historic landscapes with specific and substantial importance to local interest groups, but with limited sensitivity. Historic landscapes whose sensitivity is limited by poor preservation and/or poor survival of contextual associations.

Negligible Landscapes with little or no significant historical interest.

Assessment of Impact Magnitude – Archaeological Assets

9.47 The magnitude of an impact is assessed without regard to the value of the heritage asset. In

considering the magnitude of impact, the principle established in section 12 of the NPPF that

preservation of the asset is preferred, and that total physical loss of the asset is least preferred,

has been taken into account.


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9.48 It is not always possible to assess the physical impact in terms of percentage loss and therefore it

can be important in such cases to try to assess the capacity of the heritage asset to retain its

character and significance following any impact. Similarly, impacts resulting from changes within

the settings of buried archaeological assets may also be more difficult to assess as they do not

involve physical loss of the resource and may be reversible.

9.49 The magnitude of the predicted impact is assessed using the criteria expressed in Table 9.5

below. These are primarily based on the guidance provided in HA 208/07.

Table 9.5: Example Definitions of Impact Magnitude – Archaeological Assets

Magnitude Typical Descriptors

High Change to most or all key archaeological elements, such that the asset is totally altered and much of its significance is lost. Substantial change within the setting leading to considerable loss of significance of the asset.

Medium Changes to many key archaeological elements, such that the asset is clearly modified and there is some loss of significance. Change within the setting leading to some loss of significance of the asset.

Low Changes to key archaeological elements, such that the asset is slightly altered and there is a slight loss of significance. Slight change within the setting leading to a slight loss of significance of the asset.

Negligible Very minor changes to key archaeological elements or within the setting that hardly affect the significance of the asset.

None No substantive change to key archaeological elements or within the setting.

Assessment of Impact Magnitude – Historic Buildings

9.50 As for archaeological assets, the magnitude of impact in relation to historic buildings is assessed

without regard to the importance of the asset, so the total destruction of an insignificant historic

building has the same degree of magnitude of impact as the total loss of a high value historic

building. Determination of the magnitude of impact is based on the principle that preservation of

the asset and its setting is preferred and that total physical loss of the asset and/or its setting is

the least preferred.

9.51 Changes within the settings of historic buildings may result from vibration, noise and lighting

issues as well as visual impacts, and may be reversible. Additional methodology regarding the

assessment of effects resulting from changes within settings is provided below.

9.52 The magnitude of the predicted impact is assessed using the criteria expressed in ( )Table 9.6


Table 9.6: Example Definitions of Magnitude – Historic Buildings


High Change to key historic building elements, such that the asset is totally altered and much of its significance is lost. Substantial change within the setting of an historic building leading to considerable loss of significance of the asset.

Medium Change to many key historic building elements, such that the asset is clearly modified and there is some loss of significance. Change within the setting of an historic building leading to some loss of significance of the asset.

Low Changes to key historic building elements, such that the asset is slightly altered and there is some loss of significance. Change within the setting of an historic building leading to a slight loss of significance of the asset.

Negligible Slight changes to historic building elements or within its setting that hardly affect the significance of the asset.

None No substantive change to fabric or within the setting.


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Assessment of Impact Magnitude – Historic Landscapes

9.53 Historic landscapes cannot be destroyed or damaged but impacts on them can change their

character. Impacts are assessed using evaluated HLC units, not the

elements/parcels/components that contribute towards the character. There may be impacts

resulting from changes within the settings of identified units, especially with regard to designated

historic landscapes. Additional methodology regarding the assessment of effects resulting from

changes within settings is provided at paragraph 9.63 et seq below.

9.54 The magnitude of the predicted impact is assessed using the criteria expressed in Table 9.7


Table 9.7: Example Definitions of Impact Magnitude – Historic Landscapes


High Change to most or all key historic landscape elements, parcels or components; extreme visual effects; gross change of noise or change to sound quality; fundamental changes to use or access; resulting in total change to HLC unit and complete loss of significance.

Medium Changes to many key historic landscape elements, parcels or components; visual change to many key aspects of the historic landscape; noticeable differences in noise or sound quality; considerable changes to use or access; resulting in moderate changes to HLC and some loss of significance.

Low Changes to few key historic landscape elements, parcels or components; slight visual changes to few key aspects of historic landscape; limited changes to noise levels or sound quality; slight changes to use or access; resulting in limited changes to HLC and slight loss of significance.

Negligible Very minor changes to key historic landscape elements, parcels or components; virtually unchanged visual effects; very slight changes in noise levels or sound quality; very slight changes to use or access; resulting in a very small change to HLC and very little loss of significance.

Significance of Effects

9.55 The significance of an effect is a combination of the importance of the heritage asset and the

magnitude of impact on that asset.

9.56 The significance of any effect on a heritage asset is clearly different from the significance of the

asset itself.

9.57 Effects can be adverse or beneficial. Beneficial effects are those that mitigate existing impacts

and help to restore or enhance heritage assets, therefore allowing for greater understanding and

appreciation. Based on the approach in HA 208/07, the following matrix has been used for the

assessment of archaeological remains, historic buildings and historic landscapes.

Table 9.8: Assessment Matrix

Value / Importance

Magnitude of Impact

None Negligible Low Medium High

Negligible No change Negligible Negligible or Minor

Negligible or Minor

Minor

Low No change Negligible or Minor

Negligible or Minor

Minor Minor or Moderate

Medium No change Negligible or Minor

Minor Moderate Moderate or Major

High No change Minor Minor or Moderate

Moderate or Major

Major or Substantial


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Value / Importance

Magnitude of Impact

None Negligible Low Medium High

Very high (Assets of the Highest Significance)

No change Minor Moderate or Major

Major or Substantial

Substantial

9.58 Impacts can be either favourable or adverse; however, to avoid confusion; the default position of

any effect recorded in this chapter is understood to be adverse unless stated otherwise.

9.59 Where the matrix provides a split in the level of effects, e.g. moderate/minor, the assessor has

exercised professional judgement in determining which of the levels is more appropriate.

9.60 For consistency between disciplines the overall significance of an effect is expressed as

Negligible, Minor, Moderate, Major or Substantial based on the definitions below:

Substantial: Only adverse effects are normally assigned this level of significance. They

represent key factors in the decision-making process. These effects are generally, but not

exclusively, associated with sites or features of international, national or regional importance

that are likely to suffer a most damaging impact and loss of resource integrity. However, a

major change in a site or feature of local importance may also enter this category.

Major: These beneficial or adverse effects are considered to be very important

considerations and are likely to be material in the decision-making process.

Moderate: These beneficial or adverse effects may be important, but are not likely to be key

decision-making factors. The cumulative effects of such factors may influence decision-

making if they lead to an increase in the overall adverse effect on a particular resource or

receptor.

Minor: These beneficial or adverse effects may be raised as local factors. They are unlikely

to be critical in the decision-making process, but are important in enhancing the subsequent

design of the project.

Negligible: No effects or those that are beneath levels of perception, within normal bounds of

variation or within the margin of forecasting error.

9.61 For the purposes of this assessment, any effect that is moderate, major or substantial is

considered to be significant in EIA terms. Any effect that is minor or below is not significant.

9.62 The duration of the effect is indicated where known using the following terminology.

Short term: A period of months, up to one year;

Medium term: A period of more than one year, up to five years;

Long term: A period of greater than five years.


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Settings

9.63 In 2015, HE published a document entitled ‘Historic Environment Good Practice Advice’ in

‘Planning Note 3: The Settings of Heritage Assets’ (Historic England, 2015). This guidance

provides further advice on the definition of setting and the general principles of setting in the

context of strategic planning and development control.

9.64 Paragraph 2 of the HE advice document in particular deals with the issue of setting and

development control. It advises applicants that the information required in support of applications

for planning permission and listed building consents should be no more than is necessary to

reach an informed decision, and those activities to conserve or invest need to be proportionate to

the significance of the heritage assets affected and the impact on the significance of those

heritage assets.

9.65 Paragraph 12 of the HE advice document provides the following broad approach to assessment,

undertaken as a series of steps that apply proportionately to complex or more straightforward

cases.

Step 1: identify which heritage assets and their settings are affected.

Step 2: assess whether, how and to what degree these settings make a contribution to the

significance of the heritage asset(s).

Step 3: assess the effects of the proposed development, whether beneficial or harmful, on

that significance.

Step 4: explore the way to maximise enhancement and avoid or minimise harm.

Step 5: make and document the decision and monitor outcomes.

9.66 Although assessments of changes within the settings of heritage assets can involve non-visual

issues such as noise, it is more often the visual aspects of a development that form the major part

of the assessment. To this end the ZTV is a useful tool in assessing in general terms the assets

which are likely to be impacted by the proposed development likely level (HE 2015: paragraph

14).

9.67 An assessment of visual impacts on the heritage assets and their settings needs to take into

account a wide variety of factors. These include the location of the asset within the physical

landscape, its relationship with contemporary and non-contemporary features within that

landscape and the location, size and character of the project in relation to these factors. The

assessment then needs to balance the impact of these various considerations on the basis of

informed professional judgment.

9.68 Assessment of the visual effects of the project has been undertaken in accordance with the

procedures expressed in the Guidelines for Landscape and Visual Impact Assessment (The

Landscape Institute and the Institute of Environmental Management and Assessment 2013). The

findings of the landscape and visual assessment are presented in Chapter 5: Landscape,

Townscape and Visual Resources. These findings have been taken into account in considering

the impact on settings in this chapter. Where there is the potential for changes within the setting


March 2017 9-14

of heritage assets due to noise or other impacts, these have been considered within this chapter

using appropriate procedures.

9.69 There should also be consideration of the sensitivity to change of the setting of a heritage asset.

This requires examination of the current setting with regard to identifying elements that contribute

to the significance of the asset, elements that make a neutral contribution to the significance of

the asset and elements that make a negative contribution (i.e. detract from) the significance of the

asset.

9.70 Once the impact on the heritage asset has been examined, this has been related to the impact

scales defined above for each type of heritage asset. The level of impact has been considered

against the importance of the heritage asset in the matrix provided in Table 9.8, above to reach a

conclusion regarding the overall significance of effect. The effects on heritage assets resulting

from change within their settings may be adverse or beneficial.

Limitations of the Assessment

9.71 A comprehensive desk assessment has been undertaken using all available relevant sources. On

this basis there are no major data limitations that would compromise the robustness of the

assessment.

Baseline Environment

Current Baseline Conditions

Introduction

9.72 Figure 9.1 shows heritage assets located within approximately 1 km of the proposed

development, while Figure 9.2 shows the designated assets within 3 km of the proposed

development. Historic Environment Record Entries and Ordnance Survey maps are contained

within Appendix 9.1.

9.73 Recorded archaeological remains in the wider area range in date from the prehistoric to the post

medieval period.

Prehistoric and Roman

9.74 The proposed development is located at the junction of the higher ground of the Kemsley Ridge,

which lies on London Clay, and the alluvial floodplain, underlying the proposed development site

and which in general has the potential to contain deposits of palaeo-environmental significance.

9.75 The wider area saw extensive activity from early times, with remains of ritual, settlement and

agricultural origin being recorded on the mainland and on Sheppey. At least part of the higher

ground of the Kemsley Ridge is known to have been used for occupation activity during the

prehistoric and Roman periods, while the alluvial floodplain would have been marshland and

would have been exploited for a number of purposes, including salt making and pottery

manufacture as well as hunting and fishing.

9.76 A Neolithic settlement is recorded at Grovehurst, approximately 1 kilometre (km) west of the

proposed development site (HER number TQ96NW6).


March 2017 9-15

9.77 A prehistoric log boat was found in 1924, apparently during river drainage in Milton Creek, while a

greenstone celt found in the vicinity was apparently a separate find (HER number TQ96NW12).

9.78 Remains dating from the Late Bronze Age/Early Iron Age, indicating some form of marshside

settlement at Kemsley between the 2nd and 1st millennia BC were found during excavations at

Kemsley Fields, approximately 1 km to the southwest of the access road for the proposed

development. Major activity on site dated from the middle Bronze Age to Late Bronze Age, with

limited activity in the Iron Age and Roman periods (HER number TQ96NW1004).

9.79 Further evidence of prehistoric, Roman and medieval settlement was found at Kemsley fields

including Neolithic pottery and flint, late Bronze Age artifacts, as well as various finds from the

Mid to Late Iron Age and Roman periods including a four-post structure, ditches, hearth and a

possible cremation burial (HER number TQ96NW116).

9.80 The area of prehistoric activity is extensive. Remains dating to the Neolithic and/ or Bronze Age

were recorded during an archaeological evaluation to the north of Ridham Avenue, some 700 m

west of the proposed development site. The remains comprised ditches gullies pits and postholes

in an area approximately 300 m in length (HER numbers TQ96NW96 & 97). On the slightly higher

ground to the south, two intercutting features of mid to late Bronze Age date were revealed (HER

number TW96NW98). The remains were interpreted as being an extension of the known

settlement activity to the south (TQ96NW99).

9.81 Salt making was a major activity locally during the later prehistoric and Roman periods and later.

The remains of two salterns are located some 700 m and 800 m from the proposed development

site, and finds including briquetage, pottery, burnt flint and animal bone have been made (HER

numbersTQ96NW1108 & TQ961110).

9.82 The wider area was heavily Romanised with the line of Roman Watling Street leading from

London to the coast running rather less than 3 km to the south of the proposed development site.

9.83 Three ditches of Roman date were recorded during an archaeological evaluation to the north of

Ridham Avenue, some 700 m from the proposed development site (HER number TQ96NW98).

Medieval

9.84 There is relatively little physical evidence of an Anglo-Saxon presence in the area, although

several local place names appear in early records. The place name Milton first appears in the

Anglo Saxon Chronicle in 893. Its derivation indicates that it was the meeting place for the

Hundred of Milton and it would have been located at its centre (Wallenberg: 254). The adjacent

parish of Tonge is first mentioned in the Domesday Book of 1086 and probably derives from its

topographical location on a projection of land (Wallenberg: 266). The place name Kemsley seems

to be post Norman Conquest in origin (Wallenberg: 255), while Sittingbourne first appears in 1200

(Wallenberg 264).

9.85 A possible Anglo Saxon site of unknown type is recorded as being located some 200 m south of

the proposed development site. The source is antiquarian and the site type and location

uncertain, although it may be based on place name evidence (HER number TQ96NW13).


March 2017 9-16

9.86 There is documentary evidence for oyster beds in the area being exploited from the end of the

12th century onwards. The oyster grounds probably included Milton Creek and a stretch of the

Swale (HER number TQ96NW1007).

9.87 A moated site, Castle Rough, is located some 450 m southwest of the proposed development

site. The site is located below the 5 metre contour, overlooks Milton Creek and comprises a

rectangular earthwork island surrounded on four sides by a moat. Excavations during the early

1970s indicated that the site was constructed during the 13th or 14th century. Numerous earlier

artefacts were recovered dating from the Mesolithic and Roman periods. These were interpreted

by the excavators as having been brought in with material from elsewhere. It is not entirely clear

from the available material whether material was imported from some distance away or whether

the dumped material represents upcast from the moat (HER number TQ96NW10, list entry

number 1013368).

9.88 The parish church of the Holy Trinity at Milton, located some 1.5 km southwest of the proposed

development site, is flint-faced with Stone Quoins. The roof is of the 14th century, while the south

porch is of the 15th century. The church was subject to restoration during the 1880s. The building

is listed at grade I (list entry number 1061036).

Post-medieval and Modern

9.89 There are numerous remains of timber structures and vessels recorded along the foreshore. The

vast majority of these are probably post medieval in origin and when recognisable this seems to

be the case, although some remains may be earlier.

9.90 The remains of a number of barges or other hulked vessels are recorded in Milton Creek, to the

east of the proposed development site (HER numbers TQ96NW33, TQ96NW37, TQ96NW39,

TQ96NW42, TQ96NW43, TQ96NW55, TQ96NW59, TQ96NW60, TQ96NW61 and

TQ96NW1119). Of these, one (HER number TQ96NW60) lies within the proposal site and

comprises a number of small vessels seen on an aerial photographic survey from 1961. On later

surveys the area is indistinct but may contain vessel remains.

9.91 There are a number of recorded assets connected with wharfs and slipways to the southeast of

the proposed development site. The slipway (HER number TQ96NW1147) is of concrete and

timber, while the remainder are apparently of timber. The visible remains are likely to be relatively

late in origin, although this does not rule out an early origin for such use of these areas (HER

numbers TQ96NW1147, TQ96NW1148, TQ96NW1149 and TQ96NW1150

9.92 The dryland part of the proposed development site itself appears to have been used for

agricultural purposes until the 19th century, although nearby fields were used for brick making

and other industries.

9.93 Little Murston Farmhouse, located some 1.4 kms southeast of the proposed development site is a

farmhouse of the 18th century or earlier. It is of two storeys in brown brick, now partly pebble-

dashed. The building has a hipped tiled roof with one chimney stack. The building is listed at

Grade II (list entry number 1061035).

9.94 The earliest detailed map of the area is probably William Barlow's Map of the hundreds of Milton

and Teynham of 1800, published in Halstead’s Topographical Survey of Kent. This map shows


March 2017 9-17

the wider area as being divided in to three zones, which seem to represent water, marshland and

dry land. The settlement of Milton with its parish church is located within the latter, while the

proposed development site and Castle Rough are located in the marsh.

9.95 William Mudge’s Map of Kent of 1801 shows Milton as being a rather larger settlement than

Sittingbourne. Castle Rough (perhaps shown located slightly south of its true position), is shown

with a drain into Milton Creek. The proposed development site is shown being located in enclosed

fields to the south of the Coldharbour Fleet, which is shown but not named.

9.96 The Milton Next Sittingbourne Tithe Map of 1838 shows the proposed development site and much

of the surrounding area as being owned by William Marshall. The area was being used for

pasture, with parcels occasionally being recorded as ‘pasture and water’. Castle Rough is shown

and is recorded as being recorded as ‘wood’ at that time.

9.97 The first edition six inch to the mile Ordnance Survey map of 1869 shows the proposed

development site as being in fields with a sheepfold on its north eastern boundary. The proposed

development site is indicated as being located within Kemsley Down and Kemsley Marshes. The

project site is divided into two by a field boundary and is crossed by a north-south running

tramway. A further tramway runs roughly east to west approximately 200 m south of the proposed

development site and connects with that running through the proposed development site. A brick

field is marked immediately south of New Milton. In the wider area a large duck decoy is marked

950 m to the northwest of the proposed development site.

9.98 The OS six inch edition of 1898 shows a number of brick works established in the area, including

buildings constructed on the brick field marked on the OS edition of 1869 (paragraph 9.97,

above). Along the shore line, saltings and a disused oyster pond are marked. At the northern part

of the proposed development site, where the access road exits it, a tramway had been

constructed from a wharf on Milton Creek in the east, west past Decoy House to a brickworks. By

the time of the OS edition of 1909, the brickworks immediately south of New Milton were disused

and the Govehurst Dock had been excavated (HER number TQ96NW1003).

9.99 A narrow gauge mineral railway, the Sittingbourne and Kemsley Light Railway was laid by the

Bowater Paper Company in 1906 to connect their mills at Sittingbourne and Kemsley with their

dock on the Swale (HER number TQ 96NW22). When Grovehurst Dock became too small a

larger facility was constructed at Ridham and the railway extended in 1919.

9.100 The post First World War shortage of wood pulp and an increased demand for paper led Frank

Lloyd, the owner of the Sittingbourne paper mill to expand the operation and build a new paper

mill at Kemsley. Construction began in 1923 and the mill was in operation in 1924. The mill was

coal powered and featured an aerial ropeway from Ridham Dock, which brought in logs for

grinding. Kemsley village was constructed for the paper mill workers. Of the planned 750 houses,

188 had been completed by the summer of 1927 (Bellingham1996: 67-69). The 1938 edition of

the OS shows these buildings.

9.101 The mill was supplied from Ridham Dock by the earlier tramway. The tramway expanded after the

opening of Lloyd's Kemsley Mill in 1924 and from Sittingbourne to the south acted as a passenger

railway, bringing workers to and from the mill.


March 2017 9-18

9.102 The line was taken over by Bowater's in 1948 and operated until 1968. The maintenance depot is

situated at the original end of the line, Kemsley Down.

9.103 In 1969 the railway was handed over to the Locomotive Club of Great Britain's Light Railway

Section which became the Sittingbourne & Kemsley Light Railway. The southern half of the

railway, south of the proposed development site, continues in use as a preserved railway, while

the section of the northern part which lies within the boundary of the proposed development site

has been replaced by the perimeter road around the paper mill and the northern access road to

the proposed development site.

9.104 An aerial photograph taken in 1945 shows the paper mill with conical mounds of material to its

north. Most of that part of the proposed development site proposed to contain the buildings, in

particular the western half, has material piled upon it. The northern access road runs to the west

of the railway line. The OS edition of 1950 indicates a similar disposition. The OS edition of 1979

indicates that material has been deposited on the eastern half of that part of the proposed

development site proposed to contain the buildings.

9.105 The site visit undertaken in December 2016 followed that undertaken in June 2009 for the

consented Wheelabrator Kemsley Generating Station. The recent site visit indicated that the

Project site (see paragraph 9.1 is located within the perimeter fence of the paper mill, but lies

outside the perimeter road around the main paper mill buildings. Within the assessment boundary

(see Figures 9.1 and 9.2), the northern access road and associated development, including the

pond to its east, have been constructed recently and are in operation. The significant tipping of

arisings from excavations and building material to a depth of c. 1.8 m in places, which covers

over half of that part of the proposed development site proposed to contain the buildings has

been levelled for the construction of the Wheelabrator Kemsley Generating Station. The ground

has been prepared, with piling around the bunker completed. The IBA area has been prepared

and is in use as a contractor’s compound. No archaeological features were observed or finds

made during the site visit.

Historic Landscapes

9.106 The HER indicates that the proposed development site is located within HLC type 12.3 Industrial

complexes and factories. This HLC type has a high ability to withstand change.

Geotechnical and Archaeological Fieldwork

9.107 A Phase Two geotechnical site investigation was undertaken by RPS in 2009 (Appendix 9.1).

Intrusive works comprised 3 cable percussion boreholes, 15 trial pits and 8 window sample

boreholes. Interventions were undertaken from the base of any arisings.

9.108 The survey revealed made ground across the whole of the site, comprising brown grey gravelly

sands and clays with frequent infill materials including bricks, plastics, and wood, with peat and

gravels of coal dust, ash and clinker noted as being present in places level. These infill

materials were more commonly found in locations within the northern and western site areas such

as Trial Pits TP10, TP11 and TP13. The made ground extended to depths of between 0.9 m and

4.6 m below current ground level


March 2017 9-19

9.109 Peat was occasionally present within Made Ground in the north and east of the site and was

encountered as a peaty silt / clay layer within the made ground at 1.6 to 1.8 m below current

ground level in boreholes WS3 and WS5 or as occasional pockets in the made ground in Trial

Pits TP1 and TP14.

9.110 Superficial Deposits were encountered directly beneath the Made Ground in the majority of the

borehole and trial pit locations. The superficial deposits typically comprised grey brown orange

mottled firm to stiff clays and appear to be Alluvium, as mapped in the area by the BGS. These

were sandy, gravelly and friable in places. Below the made ground the borehole logs from WS1

and WS3 indicate the possible presence of organic matter.

9.111 Further geotechnical investigation, including a series of trial pits, was undertaken by RPS on the

proposed site of the IBA area to the north of the generating station (Appendix 9.1). This revealed

that there was made ground of a minimum thickness of 0.9 m and up to in excess of 4.2 m over

the whole area, underlain by alluvium.

9.112 An archaeological watching brief was undertaken during geotechnical works which were carried

out on the consented site following the grant of planning permission (see Appendix 9.1). The

watching brief comprised constant archaeological supervision during the excavation of nine trial

pits and eight window samples. The fieldwork took place between May and June 2011. Evidence

for buried topsoil was encountered within WS10 at a depth of 4.6 m below ground level but no

features, deposits or artefacts of archaeological or palaeoenvironmental significance were

encountered within the trial pits or window samples (Mounce and Norcott 2011).

9.113 An archaeological trial trenching evaluation was undertaken within and immediately west of the

northern part of the proposed development site following the grant of planning permission for the

formation of a new rear access road and extension to trailer park to serve Kemsley Paper Mill and

ancillary development including attenuation pond, security kiosk and weighbridges (see Appendix

9.1). The evaluation comprised the excavation of a single trial trench measuring 30 m in length by

approximately 2 m wide.

9.114 The full length of the trench was excavated to c.1 m depth, however, due to water egress, it was

necessary to excavate the lower levels, to a depth of 2 m, within a series of four smaller test pits

along its length. The stratigraphic sequence encountered comprised topsoil of up to 0.5 m

overlying a layer of made ground which was up to 0.8 m thick, this overlying the natural alluvial

subsoil. No finds or features of archaeological interest were encountered during the evaluation.

Designated Assets

9.115 There are a number of designated assets in the area around the proposed development site.

9.116 There are no World Heritage Sites, Protected Wrecks, registered battlefields or registered parks

and gardens located within 3 km of the proposed development site.

9.117 There are no listed buildings or conservation areas located within 1 km of the proposed

development site.

9.118 There is one SM located within 1 km of the proposed development site. This is `Castle Rough'

Medieval moated site (list entry number 1013368).


March 2017 9-20

9.119 There is one SM (Murston Old Church, Sittingbourne, list entry number 1011768) and 11 listed

buildings between 1 km and 2 km of the proposed development site. Of these, 9 are listed at

Grade II and two, the Church of the Holy Trinity (list entry number 1061036) and the Church of all

Saints (list entry number 1069380), are listed at Grade I. The listed buildings are shown in Table

9.9, below.

Table 9.9: Listed Buildings located between 1 km and 2 km of the proposed development

site

List Entry Number

Name Grade

1061036 Parish Church of the Holy Trinity I

1069380 Church of All Saints I

1031356 Meres Court, with Cottage Attached II

1031364 66, North Street II

1057685 Great Grovehurst Farmhouse II

1061035 Little Murston Farmhouse II

1061040 Bramblefield Farmhouse (Excluding Outbuildings) II

1116219 Ivy Cottage II

1243080 Barn Adjoining Cattle Shed Immediately north of Kings Hill Farmhouse II

1258073 Kingshill Farmhouse II

1390604 Traditional Agricultural Barn II

9.120 There is one SM (World War II Heavy Anti-aircraft gunsite (TS2), 300 m east of Chetney

Cottages, list entry number 1020389) and 59 listed buildings located between 2 km and 3 km of

the proposed development site. Of these, 57 are listed at Grade II, one The Court House (list

entry number 1344240), listed at Grade II* and one, the Church of St Giles (list entry number

1322821) listed at Grade I. Of the total, two Grade II listed buildings are located within the Tonge

conservation area (just over 3 km form the proposal site) and one Grade II* and 37 Grade II listed

buildings are located within the Milton Regis High Street conservation area. Sittingbourne High

Street Conservation Area is located some 2.9 km south of the proposed development site. There

are no listed buildings within the Conservation Area and within 3 km of the proposed development

site. The listed buildings are shown in Table 9.10 below.

Table 9.10: Listed Buildings located between 2 km and 3 km of the proposed development

site

List Entry Number

Name Grade

1322821 Church of St Giles I

1025893 Quinton Farmhouse II

1061037 Murston House II

1061041 Church of All Saints II

1061042 Bayford Court II

1061046 151, East Street II

1061047 Pheasant Farmhouse II

1061054 Yew Tree House II

1069266 West Tonge Farm II

1069270 Tonge Corner Farmhouse II

1069379 Culnells II

1069420 The White House II

1116241 Coleshall Farmhouse II

1121527 Fox Cottage II

1299595 Upper Toes II


March 2017 9-21

List Entry Number

Name Grade

1338157 Stables 30 yards east of West Tonge Farmhouse II

1343861 Pheasants Farmhouse II

1343866 Nether Toes II

1343948 Cheke Court II

1343949 Granary 20 yards south of West Tonge Farmhouse II

1344246 East Hall II

1344247 Quinton Cottage II

Listed Buildings within Milton Regis High Street Conservation Area

1344240 The Court House II*

1038333 80, High Street II

1038339 90 and 92, High Street II


1039099 The White Hart Inn II

1039103 95 and 95a, High Street II


1039122 The High House II



1061018 104a, High Street II

1061043 5, Crown Road II




1061051 83-87 and 87a, High Street II






1061058 82-86, High Street II




1344215 The Three Hats Inn II

1344216 99 And 99a, High Street II

1344217 Backs House II

1344218 Hinds House II




1344239 Jay's House II

1345556 No 65, Including The Building (Former Stables) Adjoining on the South West II




Future Baseline Conditions

9.121 Within and immediately surrounding the proposed development site, it is unlikely that there would

be any significant potential future changes in baseline conditions when the project is likely to

become operational in 2019 due to foreseeable change.


March 2017 9-22

9.122 The future baseline conditions that would potentially exist in 2019, when the proposed

development becomes operational, include cumulative schemes which have been granted a

planning consent. These schemes are as follows;

Kemsley Mill baling plant

Land of Kemsley Fields Business Park energy facility

Land south of Kemsley Mill office development

Kemsley Mill car park

Ridham Dock rail sidings

Ridham Dock wood storage area

East Hall Farm residential development (68 units)

Countryside Recycling hypsum recycling plant

Land north of DS Smith Paper Mill anaerobic digester

9.123 The majority of these schemes are industrial or commercial in nature and would be located within

the industrial and commercial part of Sittingbourne, within which the proposal site is also located.

The immediate context of the operational Generating Station on the fringes of Sittingbourne would

be more intensively developed in 2019 than 2017, if the future baseline schemes are constructed

during that time period. Less natural landscape, vacant land or previously used land would be

present, this being replaced by energy infrastructure, industry or commercial development.

Consented Future Baseline Conditions

9.124 As the access track, generating station and IBA recycling facility are already consented by Kent

County Council, it is assumed that they can be considered as part of the future baseline for 2019.

In addition, there will be forthcoming non-material amendments to the design and layout of the

generating station and a forthcoming planning application for the discharge outfall of the

generating station, that are likely to be consented and constructed by 2019. As such, there would

be no physical difference between what is consented through Kent County Council and for which

consent is sought through the DCO process.

Mitigation Measures Adopted as Part of the Proposed Development

9.125 The location (on previously developed land), nature and design (i.e. an industrial development of

appropriate scale and massing) of the proposed development is intended to help mitigate any

effects on the setting of designated assets.

9.126 The remaining boundary alignments around the proposed development site would be preserved

in situ and the landscape pattern in terms of the industrial character of the area would remain

unchanged.


March 2017 9-23

Assessment of Construction Effects of the Proposed Development

Buried Archaeological Remains

9.127 The proposed development site lies within a wider landscape which generally has high potential

to contain remains of all dates from the prehistoric onwards.

9.128 Recent archaeological work on the Sittingbourne Northern Relief Road has indicated that the

higher ground of the Kemsley Ridge has the potential to contain remains from the prehistoric

through to the medieval periods, with further activity taking place in the lower lying marshlands

now represented by areas of alluvium.

9.129 Site visits, however, have indicated that there has been significant tipping of arisings from

excavations and building material within the proposed development site.

9.130 Both the nature of the 20th century land-use at the site and the associated ground disturbance

suggests that the potential for the survival of previously unidentified sub-surface archaeological

remains of national importance, or of sufficient importance to warrant preservation in situ, is

unlikely. In addition there is no evidence for a surviving soil horizon beneath the Made Ground, it

is likely that any archaeological deposits have been damaged or removed and that the potential

for the survival of archaeological remains immediately below the former land surface is low.

9.131 The dryland part of the proposed development site is now of low archaeological potential, with the

possible exception of very deeply buried deposits under alluvium. It is noted that the proposed

development, with the exception of the fuel storage pit (which has already been constructed), lies

on top of and within the area of Made Ground and an additional layer of general fill to be imported

as part of the proposed development. No remains are reported to have been found during

construction.

9.132 The heritage values of any deeply buried assets within the proposed development site are as

follows:

Evidential and Historical – The value derives from any deeply (i.e. below the formation level

of the proposed development) buried remains. The historical value is illustrative.

Aesthetic - The value is unlikely to apply to these remains.

Communal – The value of any remains would derive from their symbolic value as part of the

local community.

9.133 Any buried remains are likely to be of low significance. There would be no physical impact on

these remains. The impact magnitude on any surviving remains is assessed as being none. The

effect of the proposed development on buried remains would be no change.

9.134 Within the intertidal zone, a number of small vessels have been recorded within the proposal site.

The impact on these sites will be assessed in the final Environmental Statement.


March 2017 9-24

Designated Assets located within 1 km of the Proposal Site

9.135 The nearest designated asset is Castle Rough, a scheduled monument (list entry number

1013368). The scheduled monument is located some 450 m southwest of the proposed

development site.

9.136 The heritage values of the scheduled monument are as follows:

Evidential and Historical – The value derives primarily from the earthworks and buried

remains of the scheduled monument. The historical value is largely illustrative.

Aesthetic - The value derives from the earthwork remains of the scheduled monument.

Communal – The value of the scheduled monument derives from its symbolic value as part

of the local community.

9.137 The scheduled monument is of highest significance. There would be no physical impact upon the

scheduled monument from the proposed development and any impact would be on the setting of

the designated asset.

9.138 Setting makes a contribution to the significance of the scheduled monument mainly in the sense

that it has not entirely lost its rural location, although the setting of the scheduled monument is

now against the background of an industrial landscape.

9.139 The scheduled monument itself is low lying and not visible from any distance away. Its position in

the landscape is indicated by trees. Perhaps the clearest view of the scheduled monument and

the proposed development site is obtained from the southwest. From here, the scheduled

monument itself is not visible but the trees growing on it are visible against a background of the

existing paper mill buildings.

9.140 Given the location and scale of the existing paper mill buildings, the impact magnitude on the

setting of the scheduled monument is assessed as being negligible. The effect of the proposed

development on the scheduled monument would be low adverse, and this would be an indirect

effect. The effect would be long term.

Designated Assets located between 1 km and 2 km of the Proposal Site

Scheduled Monuments

9.141 Murston Old Church, Sittingbourne is a scheduled monument (list entry number 1011768). The

scheduled area includes both the above ground and buried remains of the church building and

encompasses the churchyard.

9.142 The scheduled monument is located some 1.6 km south of the proposed development site. The

heritage values of the scheduled monument are as follows:

Evidential and Historical – The value derives primarily from the fabric of the church and the

buried remains of the scheduled monument. The historical value is largely illustrative,

although there are associations with known individuals.


March 2017 9-25

Aesthetic - The value derives from the ruins of the church building and the churchyard.



9.143 The scheduled monument is of highest significance. Setting makes a relatively minor contribution

to the significance of the scheduled monument because it is bounded on all sides by roads and/

or modern development. On its north side the scheduled monument is bounded by modern

business/ industrial units which provide an effective northern boundary to the setting of the

scheduled monument.

9.144 There would be no physical impact upon the scheduled monument from the proposed

development and any impact would be on the setting of the scheduled monument. The impact

magnitude on the site is assessed as being ‘no change’. The effect of the proposed development

on the scheduled monument would be ‘no change’.

Listed Buildings

9.145 Little Murston Farmhouse, listed at Grade II is located some 1.4 km southwest of the proposed

development site.

9.146 The heritage values of the listed building is as follows:

Evidential and Historical – The evidential value derives primarily from the fabric of the listed

building and the potential for associated buried archaeological remains. The historical value

is largely illustrative.

Aesthetic - The value derives from the design value of the listed building in terms of its

expression of the local vernacular.

Communal – The value of the listed building derives from its symbolic value as part of the

local community.

9.147 The listed building is of high significance. There would be no physical impact upon the listed

buildings from the proposed development and any impact would be on their setting.

9.148 The setting of the listed building comprises the surrounding fields, those to the west having been

subject to gravel extraction. The setting of the listed building is now rather degraded and setting

makes a relatively minor contribution to the setting of the listed building.

9.149 There is currently no intervisibility with the proposed development site. Much of the proposed

development would lie on a line of sight between the listed building and the existing paper mill

and would be located adjacent to the latter.

9.150 The proposed development is taller than the adjacent buildings and although partly screened by

the adjacent restored landfill, part of the body of the proposed development would be visible from

the listed building.

9.151 The impact magnitude on the site is assessed as being low adverse. The effect of the proposed

development on the site would be minor adverse, and this would be an indirect effect.


March 2017 9-26

9.152 The medieval parish church of the Holy Trinity, Milton, located some 1.5 km southwest of the

proposed development site. church is listed at grade I (list entry number 1061036).

9.153 The heritage values of the listed building are as follows:


and associated buried remains. The historical value is largely illustrative, although there are

associations with known individuals.


expression of medieval and later religious architecture.


local community.

9.154 The listed building is of highest significance. Development, including existing paper mill buildings

and stacks, is located between the listed building and the proposed development site and the

housing development on the west, north and east side of the listed building effectively limits its

setting. Setting, other than its location within its churchyard, makes a relatively minor contribution

to the significance of the listed building

9.155 There would be little intervisibility between the proposed development and the listed building.

There would be no physical impact upon the listed building from the proposed development. Any

effect would be on its setting. The magnitude of impact is assessed as being negligible. The effect

of the proposed development on the setting of the listed building would be minor adverse.

9.156 Kingshill Farmhouse and the barn adjoining the cattleshed immediately north of Kingshill

Farmhouse are located some 1.9 km northeast of the proposed development site on the Island of

Sheppey and are listed at Grade II (list entry numbers 1258073 and 1243080).

9.157 The heritage values of the listed buildings are as follows:


buildings and the potential for associated buried archaeological remains. The historical value


Aesthetic - The value derives from the design value of the listed buildings in terms of their


Communal – The value of the listed buildings derives from their symbolic value as part of the

local farming community.

9.158 The listed buildings are of high significance. There would be no physical impact upon the listed

buildings from the proposed development and any impact would be on their setting.

9.159 Each listed building and the space between them forms the primary setting of the other. The

setting of the listed buildings also comprises the surrounding fields and setting makes a

contribution to the significance of the listed buildings in that they retain their rural location. The


March 2017 9-27

proposed development site is visible from the listed buildings but the proposed development

would be seen against a background of the existing paper mill buildings.

9.160 The impact magnitude on the listed buildings is assessed as being negligible. The effect of the

proposed development on the listed buildings would be minor adverse.

9.161 The church of All Saints, Iwade is located approximately 1.8 km north west of the nearest part of

the proposed development site and some 2.4 km from its built development. The building is listed

at Grade I (list entry number 1069380)



associated buried remains. The historical value is largely illustrative, although there are





local community.

9.163 The listed building is of highest significance. The church is located within a surrounding

churchyard which forms its primary setting. The eastern side of the churchyard is bordered by

agricultural fields which form a secondary setting. Setting, other than its location within its

churchyard, makes a relatively minor contribution to the significance of the listed building.

9.164 There has been considerable large scale development on the Kemsley Ridge to the northwest of

the proposed development site. This development provides a partial visual barrier. The proposed

development would fit into this area and would add little visible mass to the view in this direction

from the listed building.

9.165 There would be no physical impact upon the listed building from the proposed development and

any impact would be on the setting of the site.

9.166 The impact magnitude on the site is assessed as being no change. The effect of the proposed

development on the site would be neutral.

Designated Assets located between 2 km and 3 km of the Proposal Site

9.167 A World War II Heavy anti-aircraft gunsite (known as Thames South 2), is located 300 m west of

Chetney Cottages, some 3 km northwest of the proposed development site and is a Scheduled

Monument (list entry number 1020389). The heritage values of the SM are as follows:

Evidential and Historical – The value derives primarily from the buried and upstanding

remains of the scheduled monument. The historical value is largely illustrative, although

there are associations with known organisations and individuals.

Aesthetic - The value derives from the earthwork remains of the scheduled monument.


March 2017 9-28



9.168 The scheduled monument is of highest significance. The scheduling description indicates that the

site was chosen to defend the industrial and military targets in the Lower Thames and Medway

areas from high flying strategic bombers approaching from the south and east. The site

overlooks the River Medway and the Chetney Marshes. On this basis, setting makes a

contribution to the significance of the scheduled monument.

9.169 The setting of the scheduled monument is dependent on its defensive purpose and is wide

ranging. The paper mill at Kemsley would have been in existence during the period of use of the

scheduled monument and would presumably have been an area for the guns to avoid, assuming

they could be depressed that far. There has been considerable large scale development on the

Kemsley Ridge to the northwest of the proposed development site. This new development

provides a partial visual barrier and means that the original paper mill is not the landscape feature

that it would have been during the period of use of the scheduled monument. In addition, there

has been significant new development at the paper mill. The proposed development would fit into

this area and would add little visible mass.

9.170 There would be no physical impact upon the scheduled monument from the proposed

development and any impact would be on the setting of the scheduled monument. The impact

magnitude on the site is assessed as being no change. The effect of the proposed development

on the SM would be neutral.

9.171 Tonge Corner Farmhouse is located some 2.1 km south east of the proposed development site

and is listed at Grade II (list entry number 1069270).

9.172 The heritage values of the listed building is as follows:


building and the potential for associated buried archaeological remains. The historical value





local community.

9.173 The listed building is of high significance. There would be no physical impact upon the listed

building from the proposed development and any impact would be on its setting.

9.174 The setting of the listed building comprises the surrounding fields and setting makes a

contribution to the significance of the listed buildings in that they retain their rural location. There

is currently little or no intervisibility with the proposed development site, although the stacks of the

existing paper mill are likely to be visible from the listed building. The proposed development is


March 2017 9-29

likely to be only partly visible from the listed building, being screened by the high ground of the

adjacent land fill site and existing farm buildings.

9.175 The magnitude of impact on setting would be low adverse and the effect of the proposed

development on the listed building would be minor adverse.

9.176 The church of St Giles is located some 2.9 km southeast of the proposed development site and is

listed at Grade I (list entry number 1322821).



and associated buried remains. The historical value is largely illustrative, although there are





local community.

9.178 The listed building is of highest significance. There would be no physical impact upon the listed

building from the proposed development.

9.179 The setting of the listed building comprises its churchyard, the road to its west and the

surrounding fields. Although nominally within the ZTV, the proposed development would not be

visible from the listed building. The magnitude of impact on setting would be ‘no change’ and the

effect of the proposed development on the listed building would be ’no change’.

9.180 There are further Grade II listed buildings at 66 North Street, Kemsley 2 km south west of the

proposed development site and to the west of Kemsley, Pheasants Cottage and Bramblefield

Farmhouse, 2.25 km and 1.9 km west of the proposed development site respectively. These

buildings are of high value. In each case their settings have been rather degraded. Any view of

the proposed development from the listed buildings would be through Kemsley and the existing

paper mill buildings. The magnitude of impact would be ‘no change’ and the effect of the

proposed development on these listed buildings would be ‘no change’.

9.181 Mere Court and East Hall, both listed at Grade II are located some 2 km and 2.35 km south of the

proposed development site respectively. Development, including recent industrial development,

as well as the existing paper mill buildings and stacks, is located between the listed building and

the proposed development site. There would be little intervisibility between the proposed

development and the listed buildings. There would be no physical impact upon the listed buildings

from the proposed development. Any effect would be on their setting. The magnitude of impact on

setting would be negligible and the effect of the proposed development on the listed buildings

would be minor adverse.

9.182 The nearest Conservation Area is Milton Regis High Street, located some 2.5 km south west of

the proposed development site. The Conservation Area contains a number of listed buildings


March 2017 9-30

which are assessed as part of the Conservation Area. The heritage values of the conservation

area are as follows:

Evidential and Historical – The evidential value derives primarily from the fabric of the

buildings, listed and otherwise, structures and streetscape within the conservation area and

the potential for below ground remains. The historical value is largely illustrative.

Aesthetic - The value derives from the design value of the conservation area in terms of its

expression of settlement architecture.

Communal – The value of the conservation area derives from its symbolic value as part of

the local community.

9.183 The conservation area is of high significance. There would be no physical impact upon the

Conservation Area from the proposed development.

9.184 The conservation area is inward looking and on its eastern side, much of it is bounded by trees in

back gardens of houses and its setting to the east is thus limited. Views of the proposed

development site were not obtained from any part of the Conservation Area within the public

realm and it is unlikely that the proposed development would be visible from the Conservation

Area. Setting makes a minor contribution to the significance of the conservation area.

9.185 At most, only the stack of the proposed development would be visible from the Conservation

Area. Any impact would be on the setting of the Conservation Area. The impact magnitude on the

Conservation Area is assessed as being negligible. The effect of the proposed development on

the site would be minor adverse, and this would be an indirect effect.

9.186 Sittingbourne High Street Conservation Area is located some 2.9 km south of the proposed

development site. The Conservation Area contains a number of listed buildings which are

assessed as part of the Conservation Area. The heritage values of the conservation area are as

follows:








9.187 The conservation area is of high significance. There would be no physical impact upon the

Conservation Area from the proposed development.

9.188 The conservation area is inward looking and its setting is therefore very limited. Setting makes a

minor contribution to the significance of the conservation area. Views of the proposed

development site, or of the proposed location of the stack were not obtained from any part of the


March 2017 9-31

Conservation Area within the public realm. Views to or from the proposed development would be

difficult to obtain in relation to most if not all of the conservation area.

9.189 At most only the stack of the proposed development would be visible from the Conservation Area.

Any impact would be on the setting of the Conservation Area. There would be slight changes to

the setting of the conservation area that hardly affect it and the magnitude of impact is assessed

as being negligible. The effect of the proposed development on the conservation area is

assessed as being minor adverse, and this would be an indirect effect.

9.190 The Tonge Conservation Area is located some 3 km south west of the proposed development

site. The heritage values of the conservation area are as follows:








9.191 The conservation area is of high significance. Setting makes a significant contribution to the

significance of the conservation area.

9.192 The Conservation Area Character Appraisal (paragraph 18) notes that the railway embankment,

aligned east-west along the northern edge of Tonge, is an important feature in the local

landscape, especially where the banks are covered with tree growth. This embankment has, in

effect, severed Tonge visually from the wide sweep of low lying land to the north including the

marshes so that it now forms a well-defined northern edge to the settlement. The trees now

comprise an important background to Tonge when viewed from the south.

9.193 This defined edge limits the setting of the Conservation Area to the north. It is likely that part of

the stack of the proposed development would be visible from the Conservation Area. There would

be no physical impact upon the Conservation Area from the proposed development. Any impact

would be on the setting of the Conservation Area. The impact magnitude on the Conservation

Area is assessed as being negligible. The effect of the proposed development on the

Conservation Area would be minor adverse, and this would be an indirect effect.

Historic Parks and Gardens and Historic Battlefields

9.194 The nearest Registered Park and Garden is Doddington Place, some 9 km to the south of the

proposed development site. There would be no physical impact upon the Registered Park and

Garden from the proposed development and no effect on its setting.

9.195 There are no registered battlefields within 15 km of the proposed development site and there

would be no effect on any registered battlefield or its setting arising from the proposed

development.


March 2017 9-32

Historic Landscapes

9.196 The HER indicates that the proposed development site is located within HLC type 12.3 Industrial

complexes and factories. This HLC type has a high ability to withstand change. The proposed

development would introduce further large built development of an industrial nature and would be

consistent with the existing historic landscape character.

9.197 The heritage values of the HLC Area are as follows:

Evidential and Historical – The evidential value derives primarily from the fabric of the road,

buildings and land divisions within the HLC area and the potential for below ground remains.

The historical value is largely illustrative.

Aesthetic - The value derives from the design value of the HLC area in terms of its

expression of industrial architecture.

Communal – The value of the HLC area derives from its symbolic value as part of the local

community.

9.198 The HLC area is of low significance. Given the existing development in the area, the impact

magnitude on the HLC area is assessed as being none. Overall, the effect on the historic

landscape is considered to be ’no change’.

9.199 The nature of the proposed development and its location within an area already containing an

industrial complexes means that there would be no impact on any other HLC.

Further Mitigation

9.200 Mitigation would be complete by the time of the completion of the construction of the proposed

development and no future mitigation is proposed or necessary.

Future Monitoring

9.201 Monitoring would be complete by the time of the completion of the construction of the proposed

development and no future monitoring is proposed or necessary.

Assessment of Operational Effects of the Project

9.202 All effects will be at their maximum at the end of the construction phase. The nature of the

operation is likely to be similar to that of construction, i.e. lorry movements, noise, etc and on this

basis, no further operational effects on heritage assets are likely.

Further Mitigation

9.203 No significant effects were identified therefore no future mitigation is proposed or necessary.

Future Monitoring

9.204 No future monitoring is proposed or necessary.


March 2017 9-33

Assessment of Operational Effects of the Project against the Consented

Future Baseline

9.205 There would be no physical difference between what is already and anticipated to be consented

through Kent County Council by 2019 and the proposed development for which a DCO is sought.

When the proposed development is assessed against a baseline scenario that includes the

development as permitted by Kent County Council under the TCPA, the resulting effect of an

impact of ‘no change’ on all receptors would be ‘no change’.

Further Mitigation

9.206 No future mitigation is proposed or necessary.

Future Monitoring

9.207 No future monitoring is proposed or necessary.

Assessment of Decommissioning Effects of the Project

9.208 [Awaiting details from client on the lifetime of the project and any decommissioning plan].

Include an assessment of the likely environmental effects of the project during the

decommissioning phase.

Assessment of Cumulative Effects of the Proposed Development

9.209 A full cumulative assessment will be included in the final Environmental Statement, once a list of

schemes is consulted on.

Inter-relationships

9.210 The chief inter-relationship with heritage is landscape and this has been considered during the

assessment.

Summary of Effects

9.211 The assessment has found that there are no designated sites (e.g. Scheduled Monuments, Listed

Buildings) within the proposed development site.

9.212 There are a number of designated assets in the wider area. A comparison of these against the

ZTV has been undertaken and a detailed assessment has been carried out to assess the effects,

if any, on these assets as a consequence of the proposed development.

9.213 There are no statutorily designated sites (e.g. Scheduled Monuments, Listed Buildings) within the

application site. The closest designated asset is Castle Rough, a Scheduled Monument (HER

number TQ96NW10, list entry number 1013368). The SM is located some 500 m south of the

proposed development site. It is low lying and not visible from any distance away. Little Murston

Farmhouse is located some 1.4 km southeast of the proposed development site, is the closest

listed building to the proposed development site and is listed at Grade II (list entry number

1061035). There are a number of other designated assets within the study area. There is no

evidence that the proposed development would have a significant effect on any of them.


March 2017 9-34

9.214 It is concluded that the proposed development site is located within a landscape that has high

potential to contain remains of all dates. However, there is considerable evidence for ground

disturbance. The proposed development site has low potential for the survival of below-ground

archaeological remains.

9.215 The nature of the 20th century land-use at the proposed development site, the associated ground

disturbance and recent ground investigation and archaeological work suggest that the potential

for the survival of previously unidentified sub-surface archaeological remains of national

importance, or of sufficient importance to warrant preservation in situ, is unlikely. It is likely that

any archaeological deposits within the proposed construction footprint, with the possible

exception of the bunker, have been damaged or removed and that the potential for the survival of

archaeological remains immediately below the former land surface is low.

References

Bellingham, P (1996) Sittingbourne and Milton: An Illustrated History Sittingbourne: Sawd Books

Beresford, M and Finberg, H.P.R., (1973). English Medieval Boroughs: A Hand-list. Newton

Abbot: David & Charles.

Brabner, J.H.F. ed., (c1893). The Comprehensive Gazetteer of England and Wales. London:

William Mackenzie.

Cantor, L, (1983). The Medieval Parks of England: A Gazetteer. Loughborough: Loughborough

University of Technology.

Ekwall, E (1960). The Concise Oxford Dictionary of English Place Names Oxford

Lewis, S (1845) Topographical Dictionary of England London

Margarey, I.D. (1955) Roman Roads in Britain Volume 1, South of the Fosse Way-Bristol Channel

London: Phoenix House.

Meaney, A., (1964). A Gazetteer of Early Anglo-Saxon Burial Sites. London: George Allen &

Unwin.

Sawyer, P.H. (1968). Anglo-Saxon Charters: an Annotated List and Bibliography. London: Royal

Historical Society.

Tate, W.E. & Turner, M.E., (1978). A Domesday of English Enclosure Acts and Awards. Reading:

University of Reading.

Wallenberg J.K., (1934). The Place-Names of Kent. Uppsala: Appelbergs Boktryckeriaktiebolag

Williams, A. & Martin, G.H. (eds), (1992). Domesday Book London: Penguin.

Mounce, S and Norcott, D (2011) Kemsley Paper Mill, Sittingbourne, Kent: Archaeological

Watching Brief Report on Geotechnical Works Wessex Archaeology unpublished client report

no:78250.01

Munnery, T (2015) Archaeological Evaluation Report Land at Northern Access Road Kemsley

Paper Mill, Ridham Avenue Sittingbourne, Kent Archaeology South East unpublished client report

no: 2015448

WTI Kemsley Generating Station – Power Upgrade: Environmental Statement Chapter 9

March 2017 2-35

Table 2.6: Summary of Likely Environmental Effects on Historic Environment

Activity Value / Importance of receptor

Description of impact

Short / medium / long term

Magnitude of impact

Significance of effect

Significant / Not significant

Notes

Construction phase

Below Ground Archaeology within the proposal site

Low Removal of archaeological remains (direct impact)

Long Term

High Minor adverse Not significant Groundworks have been completed and on this basis mitigation is designed in

Historic Landscape Low Damage to elements of historic landscape (direct / indirect impact)

Long Term Low Minor adverse Not significant Groundworks have been completed and on this basis mitigation is designed in

Designated assets High to Very High

Effect on setting (indirect impact)

Long Term No change - Low

No change - Minor adverse

Not significant The proposed development, is located within a previously developed industrial landscape and on this basis mitigation is designed in

Operational phase

Historic Landscape Low Damage to elements of historic landscape (direct / indirect impact)

Long Term Low Minor adverse Not significant Mitigation is designed in

Designated assets High to Very High

Effect on setting (indirect impact)

Long Term Low Minor adverse Not significant Mitigation is designed in

9 historic environment - kemsley kemsley generating station – power upgrade: peir chapter 9 march...

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