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SOUTH CANTERBURY Environmental Statement
Non-Technical Summary
David Lock Associates
on behalf ofCorinthian Mountfi eld Ltd
March 2016
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
1
CONTENTS
1. INTRODUCTION ............................................................................................................ 3
2. THE APPLICATION SITE AND THE PROPOSED DEVELOPMENT ........................... 4
3. PLANNING POLICY CONTEXT .................................................................................. 10
4. SOCIO-ECONOMIC EFFECTS .................................................................................... 10
5. TRANSPORT................................................................................................................ 11
6. AIR QUALITY ............................................................................................................... 12
7. NOISE AND VIBRATION ............................................................................................. 12
8. LANDSCAPE AND VISUAL EFFECTS ....................................................................... 13
9. ECOLOGY .................................................................................................................... 14
10. CULTURAL HERITAGE ............................................................................................... 15
11. AGRICULTURE AND SOIL RESOURCES ................................................................. 16
12. WATER RESOURCES ................................................................................................ 17
13. GROUND CONDITIONS .............................................................................................. 18
14. UTILITIES ..................................................................................................................... 18
15. CONCLUSION .............................................................................................................. 19
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
2
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
3
1. INTRODUCTION
1.1 This document summarises the findings of an Environmental Impact Assessment (“EIA”)
of the proposed South Canterbury development (the “Proposed Development”).
1.2 The purpose of an EIA is to assess the likely significant environmental effects of a
development proposal. These effects have been assessed as “adverse” or “beneficial”;
and of “major”, “moderate”, “minor” or “negligible” significance, in accordance with
recognised EIA methodology and applying professional judgement.
1.3 The “significance” of each effect takes into account the “magnitude” of the predicted
“impact” and the “sensitivity” of the “receptor” affected. For example, an impact of “large”
magnitude affecting a receptor of “high” sensitivity would generally result in an effect of
“major” significance. Conversely, a change of “small” magnitude affecting a receptor of
“low” sensitivity would generally result in an effect of “minor” significance.
1.4 The scope of this EIA has been agreed by Canterbury City Council through its adoption of
a formal Scoping Opinion in January 2015. That Scoping Opinion takes account of a
Scoping Report submitted on behalf of the development promoter in December 2014 and
containing a proposed scope for the EIA.
1.5 The full findings of this EIA are reported in an Environmental Statement (ES). The ES is
available on Canterbury City Council’s website (www.canterbury.gov.uk) and can also be
obtained on request from David Lock Associates at 50 North Thirteenth Street, Central
Milton Keynes, Bucks. MK9 3BP ([email protected]; 01908 666276).
1.6 This concise document summarises the main findings of the ES in non-technical
language, for a wide readership.
1.7 The ES supports a planning application to Canterbury City Council for the Proposed
Development. Comments on it should therefore be directed to the Council, as part of its
consideration of the planning application.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
4
2. THE APPLICATION SITE AND THE PROPOSED DEVELOPMENT
2.1 The Application Site, which extends to some 233 hectares (around 575 acres), lies on the
southern edge of Canterbury, bounded generally by Nackington Road to the west, the A2
to the south and the Canterbury to Dover railway line to the north. The A2050 (New
Dover Road) bisects the Site. The Site predominantly consists of gently undulating
arable farmland, with small areas of orchard and the New Dover Road Park & Ride site.
2.2 The Proposed Development comprises, in summary:
up to 4,000 homes;
two primary schools;
a Community Hub and an additional Local Centre, containing local shopping facilities,
business premises, residential care accommodation, local health services,
community facilities and indoor sports provision;
land reserved for a potential relocation of the Kent and Canterbury Hospital, to be
developed for business, hotel and conference centre uses if not required for that
purpose;
access infrastructure, including a replacement A2 interchange near Bridge, relocation
of the New Dover Road Park & Ride site to land adjacent to that interchange and its
enlargement to provide 1,000 car parking spaces;
green infrastructure, including open space, play areas, outdoor sports facilities and
allotments/community orchards; and
drainage and utilities infrastructure, including diversion of the 132kV overhead
electricity transmission lines traversing the Site and removal of seven pairs of pylons.
2.3 Plans showing the Site and the Proposed Development are presented on the following
pages. These plans have formed the basis for the EIA. The detailed design of the
Proposed Development would be in accordance with those plans. This would be secured
by conditions attached to any grant of planning permission.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
5
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
6
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
7
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
8
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
9
2.4 Four indicative strategic phases of development are proposed. Within the first of those
strategic phases, an initial phase of 140 homes on the north east side of New Dover
Road immediately adjacent to the existing edge of the city is the subject of detailed
proposals as part of this planning application.
2.5 The EIA assumes construction of the Proposed Development will commence in 2017 and
be complete in 2031. A Construction Environmental Management Plan (CEMP), which
would be approved by Canterbury City Council following any grant of planning permission
for the Proposed Development, would minimise environmental impacts during
construction.
2.6 The EIA Regulations require any alternatives to the Proposed Development that have
been studied by the Applicant to be outlined and the reasons for their rejection set out.
Alternative sites for the Proposed Development have not been considered, due to the
advanced stage of production of Canterbury City Council’s emerging new Local Plan,
which allocates the Site for the Proposed Development. For the same reason and given
the specificity of that Plan’s proposals for the Site, alternative land uses to those
proposed have not been studied. Alternative designs are limited by a range of physical
and environmental considerations, as detailed in Chapter 2 of the ES.
2.7 The EIA includes an assessment of the likely environmental effects of the Proposed
Development in combination with other nearby reasonably foreseeable development
proposals, including that for 310 homes on land at Ridlands Farm and Langton Field to
the west of Nackington Road, as proposed in the emerging Local Plan. The transport, air
quality and noise assessments have taken account of a wider range of other
development proposals, including those for other sites identified in the emerging Local
Plan.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
10
3. PLANNING POLICY CONTEXT
3.1 The planning application is being submitted against the backdrop of strong support for
increased housing delivery and economic growth in the Government’s National Planning
Policy Framework (NPPF; March 2012), as well as the allocation of the Site for the
Proposed Development in Canterbury City Council’s emerging new Local Plan, which is
at an advanced stage of production.
3.2 The planning application and the EIA have also had regard to relevant saved policies of
Canterbury City Council’s current Local Plan (adopted in 2006), as well as relevant
Supplementary Planning Documents/Guidance adopted by the Council.
4. SOCIO-ECONOMIC EFFECTS
4.1 The scope of the socio-economic assessment of the Proposed Development has
included its likely effects on population, housing, the economy, retail, and social and
community infrastructure, including education, health, recreation, adult social care,
community learning, libraries and youth services.
4.2 No significant adverse socio-economic effects are predicted, taking into account the
timely provision of supporting facilities as the Proposed Development is built out. This
would be secured by conditions and legal obligations attached to any grant of planning
permission.
4.3 The delivery of up to 4,000 homes by around 2031 has been assessed as a major
beneficial effect of the Proposed Development, in making a substantial contribution to
meeting housing needs arising in the area and to improving housing affordability.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
11
4.4 Several moderate beneficial socio-economic effects have also been predicted through
the socio-economic assessment. These are: the provision of around 3,700 jobs within
the Proposed Development, helping to strengthen and diversify the local economy; the
annual generation of some £2.6m in business rates; the provision of around 550
construction-based jobs during the assumed 14-year construction period; and payments
from the Government’s New Homes Bonus to Canterbury City Council and Kent County
Council totaling some £35.8m during that period.
5. TRANSPORT
5.1 The assessment of the environmental effects of the Proposed Development in respect of
transport has covered the following specific matters, in accordance with established
guidance: driver severance; driver delay; pedestrian and cyclist severance and delay;
pedestrian and cyclist amenity; pedestrian and cyclist fear and intimidation; accidents and
safety; and hazardous loads.
5.2 A comprehensive Transport Assessment has also been undertaken and an Overarching
Travel Plan for the Proposed Development has been produced, setting out a framework
for managing the demand for travel arising from the Proposed Development and
encouraging movement by modes other than the private car.
5.3 Taking into account the future CEMP (para. 2.5), which would regulate the routeing of
construction traffic, no significant effects in relation to the specific transport matters
assessed are predicted to arise during the construction of the Proposed Development.
5.4 Taking account of proposed improvements to particular junctions and to conditions for
bus users, cyclists and pedestrians between the Site and Canterbury city centre, which
would be delivered in association with the Proposed Development, no significant effects
in relation to those matters are predicted to arise following its completion.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
12
6. AIR QUALITY
6.1 The air quality assessment has involved computer modelling of nitrogen dioxide and
particulate matter concentrations arising from changes in road traffic levels predicted by
the Transport Assessment for the Proposed Development, as well as a qualitative
analysis of the likely effects arising from dust and finer particulate matter generated
during its construction.
6.2 Given the scope through the CEMP (para. 2.5) to limit dust and particulate matter
generated during the construction of the Proposed Development, no significant effects on
air quality are predicted at that stage.
6.3 Following completion of the Proposed Development and taking account of the likely
reduction in pollutant emission levels from vehicle exhausts in the future, the computer
modelling predicts no significant effects on air quality, including within the designated Air
Quality Management Area (AQMA) in Canterbury city centre.
6.4 A worst-case scenario of no future reduction in vehicle exhaust emissions was also
modelled, as a sensitivity test. In that scenario, certain significant adverse effects on air
quality within the AQMA were predicted. However, that scenario would be very unlikely
to arise in practice, given the high likelihood of reduced exhaust emissions in future.
7. NOISE AND VIBRATION
7.1 The noise and vibration assessment has involved monitoring noise levels close to the A2,
New Dover Road (A2050) and the Canterbury-Dover railway line, monitoring vibration
levels close to that railway line, modelling predicted noise and vibration levels during the
construction of the Proposed Development and following its completion, and assessing
whether the future noise climate at the Site is suitable for the Proposed Development.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
13
7.2 Taking account of measures to be included in the CEMP (para. 2.5), only in a worst-case
scenario of construction plant operating adjacent to sensitive receptors are significant
effects on noise levels predicted during the construction stage. In the average-case
scenario of plant operating at a greater distance from those receptors, no significant
effects on noise levels at those receptors are predicted.
7.3 Again, taking account of measures to be included in the CEMP, vibration generated by
construction plant would not be significant at sensitive receptors, while monitoring of
vibration generated by trains using the railway line has determined that vibration levels
within those parts of the Proposed Development closest to the railway line would not be
significant.
7.4 Measures to be included within the CEMP would ensure the effect of construction traffic
on local noise levels would not be significant, while wider changes in traffic levels up to
and beyond the completion of the Proposed Development would not significantly increase
noise.
7.5 The site suitability assessment has found the likely future noise climate at the Site to be
suitable for the Proposed Development, subject to the detailed design of development
close to the A2 and New Dover Road (A2050) incorporating appropriate measures to
minimise noise from these sources. Such measures can be secured through conditions
on any grant of planning permission requiring their deployment at detailed design stage.
8. LANDSCAPE AND VISUAL EFFECTS
8.1 The assessment of the landscape and visual effects of the Proposed Development has
considered its effects on landscape character and visual amenity, both during the
daytime and after dark, given that artificial lighting would need to be introduced to areas
that are currently unlit.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
14
8.2 The effects of the Proposed Development on the landscape character of the Site itself, on
views from within the part of the Site south west of New Dover Road and on the
Canterbury Area of High Landscape Value (an extensive area around the city, which
washes over the Site) have been assessed as major adverse.
8.3 Major-moderate adverse effects have been predicted in relation to views from within that
part of the Site north east of New Dover Road, views of the proposed replacement A2
junction, views from the Old Gate Inn and the landscape character of areas neighbouring
the Site.
8.4 The effects of the Proposed Development on general visual amenity during the
construction stage and on views from the Spring Lane, Little Barton Farm, Pond Cottages
and New Dover Road areas into the longer term have been assessed as moderate
adverse.
8.5 Other landscape and visual effects of the Proposed Development have been assessed as
of minor or negligible significance, including its effects on the landscape character and
visual amenity of the Kent Downs Area of Outstanding Natural Beauty and its effects on
key views across Canterbury from the other side of the city.
9. ECOLOGY
9.1 The ecological impact assessment has considered the effects of the Proposed
Development on nearby wildlife sites, local wildlife habitats and particular species.
Extensive survey work has supplemented desk study.
9.2 The loss of arable farmland within the Site to the Proposed Development would give rise
to minor adverse effects on skylarks and yellowhammers, but the new habitats created
through the Proposed Development would result in minor beneficial effects on other bird
species, including song thrush, dunnock, house sparrow and starling.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
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9.3 Application of measures in the CEMP (para. 2.5) and in a future Ecology Management
Plan, the approval of which would also be secured by a condition on any grant of
planning permission, would avoid any other significant effects on wildlife sites, habitats
and species.
9.4 Extensive new woodland planting (amounting to 23.65 hectares or some 58.4 acres)
and other habitat creation associated with the Proposed Development would mitigate for
the loss of existing dormouse and reptile habitat within the Site to the Proposed
Development.
10. CULTURAL HERITAGE 10.1 The assessment of the effects of the Proposed Development on cultural heritage has
included an analysis of its effects on below ground archaeology and on the built heritage.
10.2 The archaeological assessment has involved desk-based study, a geophysical survey of
the Site and targeted trial trenching. Two late Iron Age or very early Roman rural
settlements near the north east corner of the Site and in its central eastern area have
been identified through this assessment. These would be excavated and recorded in
association with the Proposed Development, thereby mitigating the significant adverse
effect that would arise if they were not preserved by record.
10.3 The built heritage assessment has identified major adverse effects on the settings of two
Grade II Listed Buildings adjacent to the Site: the Old Gate Inn on New Dover Road; and
- during construction - Little Barton Farm Cottages on the southern edge of Barton
Business Park, to the north of the Site.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
16
10.4 The built heritage assessment has also identified moderate adverse effects on the setting
of Little Barton Farm Cottages following the construction of the Proposed Development,
as well as on the settings of two further Grade II Listed Buildings: Milestone Farmhouse,
to the south east of the Site; and – during construction – Winter’s Farmhouse, to its south
west. Moderate adverse effects on the setting of the Renville Farm and Bridge Railway
Station Conservation Area, to the south of the A2, have also been assessed.
10.5 No significant effects on other heritage assets have been identified, including notably on
the settings of the Grade I Listed Canterbury cathedral and of the World Heritage Site of
which the cathedral forms a part.
11. AGRICULTURE AND SOIL RESOURCES
11.1 The scope of this part of the EIA has included assessments of the effects of the
Proposed Development on agricultural land, agricultural users and soil functions.
11.2 The Proposed Development would result in the loss of some 215.5 hectares (532.3
acres) of agricultural land, of which some 182 hectares (450 acres) was determined
through a soil survey of the Site as being “best and most versatile” land (grades 1, 2 and
3a). Of those 182 hectares (450 acres), 21.9 hectares (54 acres) is Grade 1, 103.5
hectares (256 acres) is Grade 2 and the remaining 56.7 hectares (140 acres) is Grade
3a. This extent of loss of best and most versatile agricultural land has been assessed as
a major adverse effect.
11.3 Effects on agricultural businesses using the Site are assessed as beneficial in the case of
the principal operator, which would benefit from the sale of the land; and minor adverse in
the case of the business farming the south west of the Site, in the light of the short term
tenancy arrangements pertaining there.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
17
11.4 The approval of a Soil Resources Management Plan following any grant of planning
permission would limit the adverse effects of the Proposed Development on soil functions
to moderate levels, including by protecting soil within those parts of the Site that would
remain open and undeveloped.
12. WATER RESOURCES
12.1 The effects of the Proposed Development on flood risk, sewerage capacity, water
resource capacity and the quality of groundwater and surface water have been assessed,
with a Flood Risk and Drainage Impact Assessment having been undertaken.
12.2 It has been found that the detailed design of drainage infrastructure, including the
provision of Sustainable Urban Drainage Systems (SuDS), would ensure the Proposed
Development does not increase flood risk.
12.3 As has been agreed with Southern Water, a new foul sewer would connect the Proposed
Development directly to the existing Canterbury Waste Water Treatment Works (WWTW)
on Sturry Road via a route to the east of the city’s built-up area. The effects of that sewer
connection have been assessed through this EIA, including a detailed assessment of its
ecological effects. Taking account of appropriate mitigation measures, no significant
environmental effects are anticipated.
12.4 Prior to the delivery of that sewer connection, sewage would be stored on Site and
transported by tanker to the WWTW. Again, this temporary proposal has been taken into
account in this EIA, including through its assessment of transport effects, with no
significant effects anticipated.
12.5 The Proposed Development has been taken into account by the responsible water
companies as part of their water resource planning processes. As such, no significant
adverse effects on water resource capacity are anticipated.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
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12.6 Significant effects on the quality of surface water and groundwater would be avoided
during the construction stage by measures in the CEMP (para. 2.5) and in the longer
term through appropriate detailed design of drainage infrastructure.
13. GROUND CONDITIONS
13.1 This element of the EIA has included an assessment of the effects of the Proposed
Development in respect of land contamination, ground stability, mineral resources and
unexploded ordnance, given the bombing of the Canterbury area during World War 2.
13.2 Risks in respect of contamination and instability have been assessed as generally low,
while those risks would be further minimised by measures within the CEMP (para. 2.5),
ensuring no significant adverse effects in these respects.
13.3 The Proposed Development has been assessed as not affecting any viable mineral
deposits currently or foreseeably in demand, such that no mineral sterilisation would
occur.
13.4 The risk of unexploded ordnance within the Site has been assessed as generally low, but
with a higher risk of such ordnance being present in two localised areas in the north east
and north west of the Site. Good practice techniques would be applied to avoid any such
ordnance during construction.
14. UTILITIES
14.1 Taking account of measures within the CEMP (para. 2.5), as well as careful planning and
execution of required supply reinforcements and diversions of existing utility
infrastructure, no significant environmental effects are predicted.
14.2 The potential for the Proposed Development to be readily supplied by high speed
broadband is assessed as a minor beneficial effect.
South Canterbury Hybrid Planning Application
Environmental Statement: Non-Technical Summary Corinthian Mountfield Ltd.
DAVID LOCK ASSOCIATES in association with REGENERIS RGP WATER ENVIRONMENT WSP LLOYD BORE CGMS LAND RESEARCH ASSOCIATES TRICONNEX
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15. CONCLUSION
15.1 Housing delivery arising from the Proposed Development is assessed as a major
beneficial effect, with job provision, business rate generation and New Homes Bonus
receipts being assessed as moderate beneficial effects.
15.2 Major and moderate adverse effects are assessed as being limited to local landscape
character and visual amenity; the settings of an adjacent Conservation Area and Listed
Buildings; and agricultural land and soil functions within the Site.
15.3 These effects result from the relatively high sensitivity of the receptors affected coupled
with the large magnitude of impact that would arise from the Proposed Development by
virtue of its large scale. Importantly, however, all three areas of assessed significant
adverse effects (landscape, heritage and agriculture) have been taken into account in the
allocation of the Site for the Proposed Development in the emerging Local Plan.
15.4 All other effects have been assessed as either minor (whether beneficial or adverse) or
negligible, taking into account the mitigation measures that are proposed.
15.5 No significant effects of the Proposed Development in combination with other
development proposals are predicted. Any such cumulative effects are predicted to be
not materially different to the effects of the Proposed Development when assessed in
isolation.
15.6 Similarly, no significant interactive effects of the Proposed Development are predicted,
including mitigation measures proposed to address specific potential effects significantly
affecting any other receptors.