ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7 ECOLOGY AND NATURE CONSERVATION

7.1 Introduction

7.1.1 This chapter of the ES considers the likely significant effects of the Proposed Developments on ecology and nature conservation interests at the Application Site, as defined by the Parameters Plans (see Figures 3.1 to 3.4 in Chapter 3 of this ES). The chapter describes the methods used to assess the effects and determines the baseline conditions currently existing at the Application Site. Mitigation measures are detailed, where required, to prevent, reduce or offset the effects.

7.2 Assessment Approach

7.2.1 The methodology utilised for the survey work is split into three main areas: a desktop study, habitat survey and faunal survey, which are described in more detail below.

Methodology: Desktop Study

7.2.2 In order to compile background information on the wider site (defined by the red line on Figure 7.2), and its immediate surroundings, the and Swindon Biological Records Centre and the Wiltshire Badger Group were contacted with a request for ecological data. Where relevant information has been received, this is discussed within this report and reproduced at Appendix 7.1 and on Figure 7.1, where appropriate.

7.2.3 Information on statutory designated sites was obtained from the online Multi-Agency Geographic Information for the Countryside (MAGIC) database, which utilises data provided by Natural England, and Natural England’s website (www.natureonthemap.org.uk). This information is reproduced at Appendix 7.1, and where appropriate on Figure 7.1.

7.2.4 The National Biodiversity Network (NBN) database was also searched for any relevant biological records of nature conservation interest within the locality, with relevant information discussed within this report, where appropriate.1

Methodology: Habitat Survey

7.2.5 The Application Site was surveyed in August 2012 and again in October 2012 in order to ascertain the general ecological value of the land and to identify the main habitats present. This follows on from survey work undertaken by previous consultants to inform the 2005 ES.

7.2.6 The Application Site was surveyed based on extended Phase 1 survey methodology (Joint Nature Conservation Committee, 20102), as recommended by Natural England, whereby the habitat types present are identified and mapped, together with an assessment of the species composition of each habitat. This technique provides an inventory of the basic habitat types present and allows identification of areas of greater potential which require further survey. Any such areas identified can then be examined in more detail.

7.2.7 Using the above method, the Application Site were classified into areas of similar botanical community types, and mapped accordingly (see Figure 7.2), with a representative species list compiled for each habitat identified. All of the species that occur in each habitat would not necessarily be detectable during survey work carried out at any given time of the year, since different species are apparent at different seasons. The surveys were undertaken during the optimal seasonal period for botanical work, allowing a robust assessment of the intrinsic ecological interest of the Application Site to be made.

1 Please note that the data provider, the original recorder of the data, and the NBN Trust bear no responsibility for any further analysis or interpretation of that material, data and/or information. 2 JNCC (2010) “Handbook for Phase 1 habitat survey: A technique for environmental audit”.

CIR.P.0625 Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Methodology: Faunal Surveys

7.2.8 General faunal activity, such as mammals or birds observed visually or by call during the course of the surveys was recorded. Attention was also paid to the potential presence of any protected, rare or notable species, and specific survey work was undertaken for Badger and bats.

Mammals: Badger3

7.2.9 Specific surveys for Badger Meles meles were undertaken in conjunction with the Phase 1 survey work in August and October 2012.

7.2.10 The survey comprises two main elements. Firstly, searching thoroughly for evidence of Badger setts. For any setts that were encountered, each sett entrance was noted even if the entrance appeared disused. The following information was recorded:

• The number and location of well used or very active entrances; these are clear from any debris or vegetation and are obviously in regular use and may, or may not, have been excavated recently.

• The number and location of inactive entrances; these are not in regular use and have debris such as leaves and twigs in the entrance or have plants growing in or around the edge of the entrance.

• The number of disused entrances; these have not been in use for some time, are partly or completely blocked and cannot be used without considerable clearance. If the entrance has been disused for some time all that may be visible is a depression in the ground where the hole used to be and the remains of the spoil heap.

7.2.11 Secondly, Badger activity such as well-worn paths and push-throughs, snagged hair, footprints, latrines and foraging signs were recorded so as to build up a picture of the use of the Application Site by Badgers.

Mammals: Bats4

7.2.12 Building/Tree Inspections. There are no buildings within the Application Site. An examination of the trees within the Application Site was undertaken in August and October 2012 to search for the presence of features which could provide roosting potential for bats (such as splits, cracks, rot holes, coverings of ivy, peeling bark or similar). The potential for the trees to support roosting bats has been ranked in accordance with the criteria set out in the Bat Conservation Trust (BCT, 2007) guidelines, and these trees are mapped accordingly on Figure 7.2:

• Category 1 – confirmed bat roost tree with field evidence of the presence of bats (e.g. droppings, scratch marks, grease marks or urine staining).

• Category 2a – trees that have a high potential to support bat roosts. This includes trees displaying extensive splits, cavities, rot/woodpecker holes, large areas of peeling bark, dense Ivy cover and or a combination of those features listed above which may also be uncommon in the local area.

• Category 2b – trees with a moderate/low potential to support bat roosts. This includes trees with a small number of features offering shelter for roosting bats, such as splits, cavities, rot/woodpecker holes, Ivy cover or peeling bark. Such features may be less substantial or extensive than on high potential trees, and more exposed to the elements.

3 Based on: Mammal Society (1989) “Occasional Publication No. 9 – Surveying Badgers” 4 Surveys based on: English Nature (2004) “Bat Mitigation Guidelines” & Bat Conservation Trust (2007, 2012) “Bat Surveys – Good Practice Guidelines”

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

• Category 3 – trees with negligible potential to support bat roosts, often immature trees, displaying no suitable features.

7.2.13 Activity Surveys. In order to ascertain the current status of bat activity and use of the Application Site by foraging/commuting bats, static Anabat SD2 detectors were deployed at key locations (see Figure 7.3) and left in situ for up to six days to record the level of bat activity and help identity the bat species passing through these locations. The bat activity monitoring was carried out during broadly suitable weather conditions, i.e. no heavy rain or strong winds, and temperatures above 7oC, as set out in Table 7.1.

7.2.14 Data Analysis. The data captured by the Anabat SD2 recorders was analysed using AnalookW (version 3.7.23, 2009). All ultrasound captured was analysed by a suitably experienced ecologist. Using Analook, individual files were labelled up where bat species could be identified with reasonable certainty. Calls that appeared to have been produced by bats but could not reliably be attributed to a species were labelled with a “?” or similar identifier. The “Count Label” tool was then used to export the data into tables displaying counts per 24 hour period, and the data were then summarised (see Appendix 7.2).

Table 7.1: Dates and weather conditions for static bat detector surveys

Sunrise Sunset Static Bat Detector Survey Date Weather Conditions Time Time Locations 06 September 2012 - 19.42 Area 10; MOD land Dry, BF 0-3, 13-15°C 07 September 2012 06.29 19.40 Area 10; MOD land Dry, BF 0-3, 10-15°C 08 September 2012 06.31 19.37 Area 10; MOD land Dry, BF 0-3, 9-14°C 09 September 2012 06.32 19.35 Area 10; MOD land Dry, BF 0-3, 9-14°C 10 September 2012 06.34 19.33 Area 10; MOD land Some drizzle, BF 3-4, 14-16°C 11 September 2012 06.35 19.30 Area 10; MOD land Some drizzle at dawn, BF 2, 9-13°C 12 September 2012 06.37 - Area 10; MOD land Dry, BF 0-3, 7-9°C 14 September 2012 - 19.24 Mixed Use Land Dry, BF 2-3, 9-14°C 15 September 2012 06.42 - Mixed Use Land Dry, BF 1-2, 9-11°C

Limitations to the Assessment

7.2.15 Surveyors were able to access all areas within the Application Site during the survey work conducted, except working construction areas where rubble and other materials are being stored. The surveys were conducted throughout the optimal season for botanical and Badger work, and it is therefore considered that a robust assessment of the ecological interest of the site to be made. The bat activity survey work was conducted just outside of the optimal survey period of June - August, but given that bat commuting activity is often elevated during the transitional month of September, and given that the weather conditions were broadly suitable during the surveys conducted, this is not considered to represent a constraint to the analysis of the results.

Principles of Ecological Evaluation

7.2.16 The evaluation of ecological features and resources should be based on sound professional judgement whilst also drawing on the latest available industry guidance and research. The approach taken in this report is based on that described in IEEM’s ‘Guidelines for Ecological Impact Assessment in the United Kingdom’5. In evaluating ecological features and resources the following key factors are taken into account:

7.2.17 Geographic Frame of Reference. The value of an ecological feature or resource is determined within a defined geographical context using the following frame of reference:

5 Institute of Ecology and Environmental Management. (2006). “Guidelines for Ecological Impact Assessment in the United Kingdom” (version 7 July 2006).

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

• International • National • Regional • County (or Metropolitan) • District (or Unitary Authority, City or Borough) • Local (or Parish) • At the Site level only

7.2.18 Within this frame of reference, certain sites may carry a statutory ecological designation, e.g. Special Area of Conservation (SAC) for internationally important sites, or Site of Special Scientific Interest (SSSI) for sites of national importance.

7.2.19 Sites of more localised nature conservation importance do not receive statutory protection but may be designated by Local Planning Authorities or other bodies, e.g. Wildlife Trusts. Such non-statutory designations or “Local Sites”6 include County Wildlife Sites (CWSs) and Sites of Nature Conservation Interest (SNCIs), for example.

7.2.20 Biodiversity Value: Habitats. In certain cases, the value of a habitat can be measured against known selection criteria, e.g. SAC selection criteria, “Guidelines for the selection of biological SSSIs” and the Hedgerows Regulations 1997. However, for the majority of commonly encountered sites, the most relevant habitat evaluation will be at a more localised level and based on relevant factors such as antiquity, size, species-diversity, potential, naturalness, rarity, fragility and typicalness (Ratcliffe, 1977). The ability to restore or re-create the habitat can also be an important consideration, for example in the case of ancient woodland.

7.2.21 Regard should also be given to habitats listed as priorities for conservation under the UK Biodiversity Action Plan (BAP) in accordance with Section 41 of the NERC Act 2006, so called “Habitats of Principal Importance”, as the likely effect of a development on such habitats is a potential material consideration within the planning process. Certain habitats may also be listed within more regionally or locally specific BAPs, albeit the listing of a particular habitat under a BAP does not in itself imply any specific level of importance.

7.2.22 Biodiversity Value: Species. The assessment of the value of a species is based on factors including distribution, status, historical trends, population size and rarity. With respect to rarity, this can apply across the geographic frame of reference and particular regard is given to populations where the UK holds a large or significant proportion of the international population of a species. For certain species groups, e.g. waterfowl, there are established criteria that can be used for defining nationally and internationally important populations.

7.2.23 Regard should also be given to species listed as priorities for conservation under the UK BAP in accordance with Section 41 of the NERC Act 2006, so called “Species of Principal Importance”. Certain species may also be listed within more regionally or locally specific BAPs, albeit as with habitats the listing of a particular species under a BAP does not in itself imply any specific level of importance.

7.2.24 Secondary or Supporting Value. Some habitats or features that are of no intrinsic biodiversity value may nonetheless perform an ecological function, e.g. as a buffer. In addition, certain features of the landscape which by virtue of their linear or continuous nature (e.g. rivers) or their function as “stepping stones” (e.g. small woods) may be of value for the migration, dispersal and genetic exchange of wild species.

7.2.25 Other Value. Other tertiary factors may also be relevant in evaluating the value of a particular ecological receptor including social and economic factors.

Assessing Ecological Effects, Mitigation & Enhancements

6 DEFRA (2006) “Local Sites – Guidance on their Identification, Selection and Management”

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.2.26 Standard methods and definitions are used in the assessment of ecological value, context and the level of importance of any effect on a given site, area or species. This assessment is set in the context of the value of the given site, habitat or species, as outlined within the ‘Principles of Ecological Evaluation’ section above.

7.2.27 The IEEM publication ‘Guidelines for Ecological Impact Assessment in the United Kingdom’ (2006) sets out the methodology that was followed in conducting the Ecological Impact Assessment, and this can be summarised as follows.

7.2.28 Any effects should be assessed within their relevant frame of geographical reference, in terms of the levels of ‘international, national, regional, county (or metropolitan), district (or unitary authority, city of borough), local (or parish) or at the site level’.

7.2.29 Against this reference frame, the magnitude of any given effect can be assessed and categorised either quantitatively or under the headings in Table 7.2.

Table 7.2: Determination of magnitude of ecological effects

Magnitude of effect Determination of magnitude

Major The magnitude of any given effect is determined taking into account the geographic frame of reference and the effects on the integrity of a Moderate site or habitat or the conservation status of a species in terms of the Minor duration (permanent or temporary), reversibility, extent, timing, frequency and certainty (e.g. certain, probable or unlikely) of the Negligible/Neutral potential effect.

7.2.30 The magnitude of any effect is in turn used in conjunction with ‘conservation status’ to determine whether an effect on a habitat or species is likely to be ecologically significant. Conservation status is defined as:

• For habitats – The sum of the influences acting on the habitat and its typical species, that may affect its long-term distribution, structure and functions as well as the long-term survival of its typical species within a given geographical area; and

• For species – The sum of the influences acting on the species concerned that may affect the long-term distribution and abundance of its populations within a given geographical area.

7.2.31 Effects can be positive, negative or neutral in nature. A seven point scale has been used to record likely significant effects as follows:

7.2.32 Where the integrity of the favourable conservation status of a habitat or species is undermined, the effect could be negative and significant (major adverse). A significant positive (major beneficial) effect could be defined as one that prevented or slowed an existing decline in the integrity of the favourable conservation status of a habitat or population as much as one that permitted a population or habitat area to increase.

The Five Point Approach

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.2.33 The National Planning Policy Framework (NPPF)7 describes the Government’s national policies on the protection of biodiversity [and geological] conservation through the planning system. The NPPF emphasises the need for planning authorities to ensure that the potential effects of planning decisions on biodiversity conservation are fully considered.

7.2.34 A five-point best practice approach8,9,10 to the assessment of such effects within the development control process is recommended:

1. Information – gathering a sufficient evidence base on which to make sound planning decisions;

2. Avoidance – adverse effects on habitats and species should be avoided where possible;

3. Mitigation – where it is unavoidable, mitigation measures should be employed to minimise adverse effects;

4. Compensation – where residual effects remain after mitigation it may be necessary to provide compensation to offset any harm; and

5. New benefits – many planning decisions present the opportunity to deliver enhancements for habitats or species.

7.2.35 The assessment of ecological effects set out within this report are based on the above five-point approach, where appropriate.

7.2.36 In terms of new benefits, the National Planning Policy Framework (NPPF) sets out that the planning system should enhance the natural environment by providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity. The NPPF specifically states that opportunities to incorporate biodiversity in and around developments should be encouraged.

7.3 Policy Framework

7.3.1 The planning policy framework that relates to nature conservation issues in Old Sarum is issued at three main administrative levels – nationally through the ‘National Planning Policy Framework’; regionally through the ‘South West Regional Spatial Strategy 2006–2026’; and locally through the ‘South Wiltshire Core Strategy’ (adopted 07 February 2012) and the ‘Wiltshire Core Strategy Pre-submission Document, February 2012’. Any proposed development will be judged in relation to the policies contained in these planning documents.

National Policy: ‘The National Planning Policy Framework’

7.3.2 The National Planning Policy Framework (NPPF), which was published on 27th March 2012, confirms the Government's commitment to conserving and enhancing the natural and local environment through the planning system, including specific reference to maintenance and enhancement of biodiversity.

7.3.3 The NPPF requires Local Authorities to fully consider the effect of planning decisions on biodiversity and geodiversity, and ensure that appropriate weight is attached to statutory nature conservation designations, protected species and biodiversity and geological interests within the wider environment. It also considers the potential biodiversity and geological conservation gains which can be secured within developments, including the use of planning obligations.

7 Department for Communities and Local Government (2012) “National Planning Policy Framework” 8 Royal Town Planning Institute (1999) “Planning for Biodiversity – Good Practice Guide” 9 ODPM (2006) “Planning for Biodiversity and Geological Conservation – A Guide to Good Practice” 10 PAS (2010) “Planning to Halt the Loss of Biodiversity, Biodiversity Conservation Standards for Planning in the United Kingdom – Code of Practice.”

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.3.4 National Policy therefore implicitly recognises the importance of biodiversity and that with sensitive planning and design, development and conservation of the natural heritage can co-exist and benefits can, in certain circumstances, be obtained.

Regional Planning Policy: ‘RSS for the South West’

7.3.5 Relevant planning policy is provided at the regional level by the draft ‘Regional Spatial Strategy [RSS] for the South West 2006 –2026’. Within this document, two policies are relevant to ecology and nature conservation considerations.

7.3.6 Policy ENV1 is concerned with ‘Protecting and Enhancing the Region’s Natural and Historic Environment’ and states:

“The quality, character, diversity and local distinctiveness of the natural and historic environment in the South West will be protected and enhanced, and developments which support their management will be encouraged. Where development and changes in land use are planned which would affect these assets, local authorities will first seek to avoid loss or damage to the assets, then mitigate any unavoidable damage, and compensate for loss or damage through offsetting actions. Priority will be given to preserving and enhancing sites of international or national landscape, nature conservation, geological, archaeological or historic importance. Tools such as characterisation and surveys will be used to enhance local sites, features and distinctiveness through development, including the setting of settlements and buildings within the landscape and contributing to the regeneration and restoration of the area.”

7.3.7 Policy ENV4 is concerned with ‘Nature Conservation’ and states:

“The distinctive habitats and species of the South West will be maintained and enhanced in line with national targets and the South West Regional Biodiversity Action Plan. Local authorities should use the Nature Map to help map local opportunities for biodiversity enhancement in LDDs, taking into account the local distribution of habitats and species, and protecting these sites and features from harmful development. Priority will be given to meeting targets for maintenance, restoration and recreation of priority habitats and species set out in Appendix 1, focusing on the nature Map areas identified in Map 7.3. Proposals which provide opportunities for the beneficial management of these areas and habitats and species generally, should be supported, including linking habitats to create more functional units which are more resilient to climate change.”

7.3.8 Map 7.3 of the RSS indicates the presence of ‘Principal River Networks’ and ‘Chalk Downland’ in the local area, while Appendix 1 to the RSS provides a list of South West Regional Biodiversity Targets, of which one (namely ‘Hedgerows’) is potentially relevant to the Application Site. The RSS states that “Quantifiable targets could not be set with existing data for [hedgerows]. Retaining the existing extent of these habitats and realising opportunities for their expansion is highly important.”

Local Policy

7.3.9 Relevant planning policy at the local level is principally provided by two main planning documents, the ‘South Wiltshire Core Strategy’ (adopted 7th February 2012) and the ‘Wiltshire Core Strategy Pre- submission Document, February 2012’, with adoption of the Wiltshire Core Strategy expected to take place in autumn 2012.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

South Wiltshire Core Strategy (adopted 7th February 2012)

7.3.10 The ‘South Wiltshire Core Strategy’ includes a number of policies potentially relevant to the Application Site and possible ecological effects of the Proposed Development, which are reproduced below:

7.3.11 Core Policy 19: ‘Water Efficiency and the River Avon Special Area of Conservation’

“In order to protect the River Avon Special Area of Conservation [SAC], all new residential development will be required to incorporate water efficiency measures to a minimum standard equivalent to Level 3 of the ‘Code for Sustainable Homes’.

Non-residential development will be required to incorporate water energy efficiency measures. Developers will be expected to submit details of how water efficiency has been taken into account during the design of proposals.”

7.3.12 Core Policy 20: ‘Pollution and Phosphate levels in the Water Environment’

“In order to protect groundwater and surface water quality and to avoid and reduce the potential environmental effects on water quality in the River Avon Special Area of Conservation, development will need to incorporate measures during construction and operation that avoid and prevent pollution and mitigate potential disturbance effects. This may include appropriate schemes of mitigation, including consideration of suitable buffer zones along watercourses, habitat enhancements and river access management measures. All developments identified in this Core Strategy should submit a Construction Management Plan to the Local Planning Authority to ensure measures proposed during construction are satisfactory.

All developments identified in this Core Strategy will be required to demonstrate that their proposals will include the implementation of effective mitigation measures to ensure that their development will not cause detriment to watercourses through the unmitigated addition of phosphates to local watercourses. The [sic] may be by means such as an appropriate financial contribution to a Management Plan or the implementation by the developer of on or near site mitigation measures to be agreed by the Local Planning Authority.”

7.3.13 Core Policy 22: ‘Green Infrastructure and Habitat Networks’

“Proposals for development shall make provision for the retention and enhancement of existing Green Infrastructure. Where development is permitted the Local Planning Authority will require developers to:

• Contribute towards the implementation of the Wiltshire Green Infrastructure Plan.

• Provide for any suitable alternative natural greenspace provision, access or quality improvements improved linkages between greenspaces, site habitat management measures, and visitor access management measures to ensure there is no negative impact on the and N2K [Natura 2000] sites.

• Put measures in place to ensure appropriate future management of Green Infrastructure.

• Retain and enhance existing on site Green Infrastructure and create new or replacement Green Infrastructure equal to or above the current ecological value of the existing if damage or loss is unavoidable.

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• Maintain the integrity of the existing Green Infrastructure network and prevent habitat fragmentation.

• Identify opportunities to enhance and improve linkages between the natural and historic landscapes of south Wiltshire.

A development that would adversely affect the integrity and value of the existing Green Infrastructure network, or prejudice the implementation of the Wiltshire Green Infrastructure Plan will not be permitted.”

Wiltshire Core Strategy Pre-submission Document, February 2012

7.3.14 The Wiltshire Core Strategy Pre-submission Document contains a number of policies relating to ecology and nature conservation that largely accord with the South Wiltshire Core Strategy and these are reproduced below.

7.3.15 Core Policy 50: ‘Biodiversity and Geodiversity’. This sets out the need to avoid harm to local sites, protect features of nature conservation value, enhance biodiversity, and offset impacts on Special Protection Areas (SPAs). It states:

“Local sites. Sustainable development will avoid direct and indirect impacts upon local sites through sensitive site location and layout, and by maintaining sufficient buffers and ecological connectivity with the wider environment. Damage or disturbance to local sites will generally be unacceptable, other than in exceptional circumstances where it has been demonstrated that such impacts:

i. cannot reasonably be avoided ii. are reduced as far as possible iii. are outweighed by other planning considerations in the public interest and iv. where appropriate compensation measures can be secured through planning obligations or agreements.

Development proposals affecting local sites must contribute to their favourable management in the long- term.

Protection. Development proposals must demonstrate how they protect, and where possible enhance, features of nature conservation and geological value as part of the design rational. There is an expectation that such features shall be retained, buffered, and managed favourably in order to maintain their ecological value, connectivity and functionality in the long-term. Where it has been demonstrated that such features cannot be retained, removal or damage shall only be acceptable in circumstances where the anticipated ecological impacts have been mitigated as far as possible and appropriate compensatory measures can be secured to ensure no net loss of the local biodiversity resource, and secure the integrity of local ecological networks and provision of ecosystem services.

Biodiversity enhancement. All development should seek opportunities to enhance biodiversity. Major development in particular must include measures to deliver biodiversity gains through opportunities to restore, enhance and create valuable habitats, ecological networks and ecosystem services. Such enhancement measures will contribute to the objectives and targets of the Biodiversity Action Plan (BAP), particularly through landscape scale projects, and be relevant to the local landscape character.

Disturbance. All development proposals shall incorporate appropriate measures to avoid and reduce disturbance of sensitive wildlife species and habitats throughout the lifetime of the development.

Development likely to increase recreational pressure on Special Protection Areas (SPAs) will be required to deliver an appropriate level of mitigation to offset any potential impacts. Suitable mitigation strategies will

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

include securing management measures for designated features of Salisbury Plain, New Forest National Park and surrounding areas. Designated features include Habitats Directive Annex I habitats and Annex II species. Provision of an appropriate area of Suitable Alternative Natural Greenspace to deter public use of Natura 2000 sites will only be acceptable in exceptional circumstances.

Such measures shall be secured through reasonable and proportionate planning obligations and agreements.”

7.3.16 The supporting information relating to Core Policy 50 goes on to consider mitigation for potential recreational effects of development on the ‘Salisbury Plain’ Special Protection Area (SPA) and ‘New Forest’ SPA. It identifies that suitable compensation for increased recreational disturbance at SPAs will be achieved through securing management in those as follows:

i. For development within 15km of the Salisbury Plain SPA this will best be achieved through the Wessex Stone Curlew Project (WSCP), which delivers targeted advice to the Ministry of Defence and private tenants on the location and management of Stone Curlew nest sites.

ii. For development within 7km of the New Forest SPA mitigation will be best addressed through the Recreation Management Strategy (RMS) for the area.

iii. Proportionate developer contributions toward implementation of the WSCP and the RMS will be sought in line with Core Policy 3 (infrastructure) and the Infrastructure Delivery Plan. The use of Suitable Alternative Natural Greenspace (SANGs) is unlikely to be successful for attracting people away from these sites given their high intrinsic appeal and unique characteristics, and would only be acceptable in cases where a particularly large or high quality SANGs can be secured. However in most cases this is unlikely to be cost effective. Any development that would have an adverse effect on the integrity of a European nature conservation site will not be in accordance with the Core Strategy.

7.3.17 Core Policy 52: ‘Green Infrastructure’. This states that proposals that contribute to the delivery of a high quality and highly valued multi-functional infrastructure network in accordance with the objectives of the Wiltshire Green infrastructure Strategy will be supported.

7.3.18 Core Policy 55: ‘Air Quality’. This policy states that where development proposals which by virtue of their scale, nature or location are likely to exacerbate existing areas of poor air quality, will need to demonstrate that measures can be taken to effectively mitigate emission levels in order to protect environmental quality. The supporting information relating to Core Policy 55 also states that:

“Core Policy 55 … requires that all development which either because of the size, nature or location will have the potential to exacerbate known areas of poor air quality, is required to overcome this barrier to development by demonstrating the measures they will take to help mitigate these impacts. … Development which could potentially impact upon Natura 2000 sites through contributions to aerial deposition e.g. industrial process within 10km of a SAC, will require an assessment of the likely impacts in accordance with published guidance. Where mitigation is required this may be delivered through a local emissions strategy.”

7.3.19 Core Policy 69: ‘Protection of the River Avon SAC’. This requires new development to put mitigation in place to avoid adverse effects on this designation.

“In order to avoid and reduce potential environmental effects on the River Avon SAC, development will need to incorporate measures during construction and operation to avoid and prevent pollution and mitigate potential disturbance effects; appropriate schemes of mitigation may include consideration of suitable buffer

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

zones along watercourses, habitat enhancements and river access management measures. All development within 20m of the river banks should submit a Construction Management Plan to the Local Planning Authority to ensure measures proposed during construction are satisfactory.

Where additional sewage discharges to a STW cannot be accommodated without measures to offset phosphate loading, development will be required to undertake proportionate mitigation measures to demonstrate that the proposals would have no likely significant effects upon the SAC.”

7.3.20 The supporting information relating to Core Policy 69 also states that:

“Development in close proximity to the river has the potential to have a detrimental effect upon its qualifying features through direct damage, sedimentation, pollution, disturbance, or changes to its hydrological regime. Most of these impacts can be avoided or mitigated through the use of buffer zones, access management, habitat management and construction method statements, and Wiltshire Council has developed a standard procedure for dealing with most of these issues in association with the River Avon Planning Forum.

Currently, phosphate concentrations exceed the appropriate targets required in the Conservation Objectives for the River Avon SAC over a number of reaches, and the HRA of the core strategy (and that of the RSS) has highlighted the potential for likely significant effects upon the River Avon SAC through elevated phosphate levels from additional sewage discharges in the catchment. Whilst significant improvements have recently been made to a number of Sewage Treatment Works (STWs), in parts of the catchment sewage discharges remain a significant source of phosphorus to the River Avon and these improvements will not be sufficient on their own to achieve full compliance with SAC water quality targets for all STWs.

To ensure compliance with the requirements of the Habitats Regulations and Water Framework Directive, new development around the River Avon SAC catchment must not (alone or in combination) result in non- compliance with SAC water quality targets or compound existing problems of target exceedance in those parts of the catchment already failing SAC standards. Furthermore, new development must not preclude achievement of conservation objectives for the SAC over the long term. Compliance with the appropriate targets will generally be attained through the Environmental Permitting regime, however where this is not possible, compliance may be achieved through the implementation of a long term Nutrient Management Plan (NMP).To this end, a NMP is being developed to provide an agreed strategy for reducing key pollution sources across the Avon.

Developer led measures or financial contributions to help implement the NMP could be secured through Section 106 or CIL contributions for implementing the relevant NMP, or through on or near site measures to be agreed by the LPA (in consultation with the EA and local utility providers as necessary).The NMP will be used to calculate reasonable and proportionate developer contributions and will clearly set out how these will be spent to deliver the required level of long-term P reduction across the catchment. An important principle is that developers are only required to offset the P arising from proposed new development and contributions would not be used to reduce historic pollution. Where development would discharge to an existing environmental permit which the EA has confirmed as being Habitats Regulations compliant without the need for phosphate offsetting, no contribution or mitigation measures would be necessary.”

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.4 Scoping

7.4.1 Wiltshire Council has highlighted, in an email dated 5th October 2012 (reproduced at Appendix 7.3), the need to consider Badgers, bats and reptiles in particular. It notes that the application should demonstrate how these protected species have been accommodated, and mitigation / ecological enhancement proposals put forward. The Council has also stated that there will be a need for the Applicant to demonstrate that there will be no impacts on the hydrological regime of the River Avon SAC. It notes that “this application may require HRA, depending on whether it can still apply SUDS [Sustainable Urban Drainage Systems] techniques for dealing with surface water run-off”.

7.4.2 Wiltshire Council goes on to state that “Currently the authority is not collecting developer contributions towards a phosphate management plan for the River Avon because we believe mitigation for phosphate contributed by all development contained in the Core Strategy has already been delivered through upgrades to sewage treatment works.” Wiltshire Council has also provided a River Avon SAC procedure document, which has been completed as part of the assessment below, and is presented at Appendix 7.4.

7.4.3 The Environment Agency provided a screening and scoping response, dated 6th November 2012 (reproduced at Appendix 7.3), which relates to the potential requirement for an updated Flood Risk Assessment to assess the provision of development within Area 11 in the place of the formerly-proposed swale. No comments have been made by the Environment Agency in relation to the River Avon SAC, or any other such designation.

7.4.4 No formal response has been received to date from Natural England, or any other relevant nature conservation body.

7.4.5 The ecological assessment has been based on a full ecological appraisal of the Application Site including, but not restricted to: Phase I survey, Badger survey, and a habitat suitability appraisal for reptiles. Background records for the area have been sought from relevant data holders including the Wiltshire and Swindon Biological Records Centre (WSBRC) and the Wiltshire Badger Group.

7.4.6 The assessment below details the habitats, protected and priority species present within the area likely to be affected by the Proposed Development. Effects on priority habitats are quantified, and effects on protected species and other priority species are identified. The ES identifies how the Proposed Development complies with the requirement of the NPPF to deliver a net gain for biodiversity.

7.4.7 In addition, ecological effects of the Proposed Development beyond the boundaries of the Application Site are considered, in particular in respect of the River Avon SAC.

7.5 Baseline Conditions: Nature Conservation Designations

7.5.1 The Application Site is not subject to any statutory or non-statutory nature conservation designations. There are, however, a number of ecological designations in the wider area, and these are illustrated on Figure 7.1, and summarised within Table 7.3 below in order of distance from the site as a whole.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Table 7.3: Statutory & Non-statutory Designations within the vicinity of the Application Site

Approx. Distance Site Name Designation Brief Description & Direction from Application Site

Statutory Designations

The SAC is designated for the Annex I habitat ‘Water courses of plain to montane levels with Ranunculion fluitans & Callitricho-Batrachion River Avon SAC vegetation’ and for five Annex II species: Brook Lamprey, Atlantic Salmon, Sea Lamprey, 1.2km SE Desmoulin`s Whorl Snail & Bullhead. The SSSI is notified as a rich chalk stream with over 180 species of aquatic plant recorded, one of SSSI the most diverse fish faunas in Britain and a wide range of aquatic invertebrates.

Avon river valley with marshy vegetation, Willow Avon Valley LNR 2.3km SW wood, grassland, earth bank and reedbeds. Includes one of the last two actively-managed Lower Woodford water-meadow systems in Wiltshire, and possibly SSSI 2.4km W Water Meadows in Britain. The sward is grass dominated and is of particular importance for its grass hybrids. A mosaic of botanically-rich chalk grassland & Bracknell Croft SSSI 2.4km E developing Juniper Juniperus communis scrub.

Botanically rich chalk grassland with two nationally restricted plant species, eight orchid species and a Cockey Down SSSI 2.4km SE wide range of grasses. It also supports a range of butterfly & snail species, and a rare robber fly. Botanically-rich chalk downland, rich in plants SSSI characteristic of South Wiltshire chalk grassland, 2.6km W including spp. of nationally restricted distribution. The SAC is designated for a number of Annex I Salisbury Plain SAC habitats including calcareous grassland, and the Annex II butterfly species Marsh Fritillary.

This SPA is designated for its important population 3.7km E of breeding Stone Curlew. It is notified as a SSSI

for its unimproved calcicolous grassland (publically accessible communities, including outstanding assemblages Porton Down SPA/SSSI area is 8.0km N) of lower plants (lichens), vascular plants and

invertebrates. It is also notified for its breeding

population of Stone Curlew, and breeding bird

community of grassland, woodland & scrub.

This SPA is designated for its important population Salisbury Plain SPA of breeding Stone Curlew and over-wintering Hen 8.0km N Harrier. The site is designated for the presence of 13 Annex I habitats including various heathland & SAC/SSSI 14.4km S woodland habitats, together with the Annex II species Southern Damselfly & Stag Beetle. New Forest The designation relates to the presence of internationally important numbers of breeding SPA 15.1km S Dartford Warbler, Honey Buzzard, Nightjar, Woodlark & overwintering Hen Harrier.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Approx. Distance Site Name Designation Brief Description & Direction from Application Site Notified as an area of semi-natural vegetation of high ecological quality and diversity including Ramsar 15.1km S valley mires, fens, wet heath, ponds & streams, within uncultivated and undeveloped catchments. Non-statutory Designations

Winterbourne Earls Former water meadow supporting a mosaic of LWS 1.1km E Meadow neutral grassland and fen communities. Hill fort with Roman & Norman archaeology with unimproved calcareous grassland on grazed Old Sarum LWS ramparts, neutral grassland on mown areas within 1.2km SW & rank mesotrophic grassland, scrub and scrub- woodland elsewhere. A highly unusual urban park with semi-improved Bishopdown LWS 1.7km S calcareous grassland. Unimproved calcareous grassland on a low, west- North Hill Down LWS facing chalk bank with a larger area of improved 1.8km W grassland above.

Statutory Designations

7.5.2 River Avon SAC / River Avon System SSSI. The nearest statutory designations to the Application Site are the ‘River Avon’ Special Area of Conservation (SAC) and ‘River Avon System’ Site of Special Scientific Interest (SSSI). These are located approximately 1.2km to the east and are separated from the Application Site by existing commercial and residential development, the main Portway road, and an expanse of arable fields. An additional stretch of the ‘River Avon’ SAC and ‘River Avon System’ SSSI designations is located approximately 2.1km to the west of the Application Site, where it is separated by further areas of residential development and an expanse of arable fields.

7.5.3 The ‘River Avon’ SAC is designated for the presence of the following Annex I habitat, and five Annex II species:

• Water courses of plain to montane levels with Ranunculion fluitans & Callitricho-Batrachion vegetation • Desmoulin`s Whorl Snail Vertigo moulinsiana • Sea Lamprey Petromyzon marinus • Brook Lamprey Lampetra planeri • Atlantic Salmon Salmo salar • Bullhead Cottus gobio.

7.5.4 The rich flora of the River, the invertebrate and fish fauna, and the habitats for breeding, wintering and migrating birds, are cited as reasons for the designation of ‘River Avon System’ SSSI. The SSSI citation also notes that the water quality of the River Avon and northern tributaries are affected by high levels of phosphates and nitrates, which appear to adversely affect the flora, especially downstream of sewage discharges.

7.5.5 Avon Valley LNR. The ‘Avon Valley’ Local Nature Reserve (LNR) is the next nearest statutory designation, being located approximately 2.3km from the Application Site. It comprises a river valley with marshy vegetation, Willow wood, grassland, earth bank and reedbeds.

7.5.6 Lower Woodford Water Meadows SSSI. This SSSI is located approximately 2.4km from the Application Site. It incorporates one of the last two actively-managed water-meadow systems in Wiltshire,

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

and has a diverse but grass-dominated sward, of particular importance for its hybrids between Fescues and Perennial Rye-grass.

7.5.7 Bracknell Croft SSSI; Cockey Down SSSI; Camp Down SSSI. These SSSIs, all of which comprise botanically-rich chalk grassland, are the next nearest statutory designations to the Application Site, being located at a distance of approximately 2.4km, 2.4km and 2.6km respectively.

7.5.8 Salisbury Plain SAC / SPA; Porton Down SPA / SSSI. The ‘Porton Down’ SPA and SSSI form part of the ‘Salisbury Plain’ SAC, the nearest boundary of which is located approximately 3.7km north-east of the Application Site. The ‘Salisbury Plain’ SAC also incorporates the ‘Salisbury Plain’ SPA, but at a distance of approximately 8.0km from the Application Site.

7.5.9 The ‘Salisbury Plain’ SAC is designated for the presence of the following Annex I habitats and Annex II species:

• Juniperus communis formations on heaths or calcareous grasslands • Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia) • Marsh Fritillary butterfly Euphydryas aurinia

7.5.10 The ‘Porton Down’ SPA qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance of the Annex I species Stone Curlew Burhinus oedicnemus during the breeding season.

7.5.11 The ‘Porton Down’ SSSI is notified for its unimproved calcicolous grassland communities, including outstanding assemblages of lower plants (lichens), vascular plants and invertebrates. It is also notified for its breeding population of Stone Curlew, and breeding bird community of grassland, woodland and scrub.

7.5.12 The ‘Salisbury Plain’ SPA qualifies as under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance the Annex I species:

• Stone Curlew Burhinus oedicnemus during the breeding season; and • Hen Harrier Circus cyaneus over winter.

7.5.13 New Forest SSSI/SAC/SPA/Ramsar. The New Forest incorporates large areas of lowland heath, valley and seepage step mire, or fen, and ancient pasture woodland, including riparian and bog woodland. Nowhere else do these habitats occur in combination and on so large a scale. This complex of designations is located at least 14.4km from the Application Site. The Ramsar and SSSI designations are conferred on account of the habitat quality/diversity supported, and the exceptional assemblages of species present.

7.5.14 The New Forest SAC is designated for the presence of the following Annex I habitats:

• Oligotrophic waters containing very few minerals of sandy plains (Littorelletalia uniflorae) • Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorae and/or of the Isoëto-Nanojuncetea • Northern Atlantic wet heaths with Erica tetralix • European dry heaths • Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae) • Depressions on peat substrates of the Rhynchosporion • Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion) • Asperulo-Fagetum beech forests • Old acidophilous oak woods with Quercus robur on sandy plains

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• Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) • Bog woodland

7.5.15 The New Forest SAC is also designated for the presence of two Annex II species:

• Southern damselfly Coenagrion mercurial • Stag beetle Lucanus cervus

7.5.16 This site qualifies as a SPA under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance of the following Annex I species during the breeding season:

• Dartford Warbler Sylvia undata • Honey Buzzard Pernis apivorus • Nightjar Caprimulgus europaeus • Woodlark Lullula arborea

7.5.17 The SPA is also designated for the presence of the following Annex I species during over winter:

• Hen Harrier Circus cyaneus

Non-statutory Designations

7.5.18 Winterbourne Earls Meadow CWS. The nearest non-statutory designation is the ‘Winterbourne Earls Meadow’ County Wildlife Site (CWS), which is located approximately 1.1km east of the Application Site. It is a former water meadow which supports a mosaic of neutral grassland and fen communities.

7.5.19 Old Sarum CWS. The ‘Old Sarum’ CWS is the next nearest non-statutory designation. It is located approximately 1.2km south-west of the Application Site, and is designated primarily for the unimproved calcareous and neutral grassland it supports.

7.5.20 Ancient Woodland. There are no areas of ancient woodland situated within or adjacent to the Application Site. The nearest scheduled ancient woodland is a woodland complex known as the ‘Clarendon Park Copses’, located approximately 4.5km south-east of the Application Site.

7.6 Baseline Conditions: Habitats & Ecological Features

7.6.1 The wider site as a whole is dominated by new (predominantly residential) development, with associated hard- and soft-landscaping, which has either been relatively recently completed, or is currently under construction. However, the land parcels subject to the Proposed Developments (i.e. Area 9a, 9b, 10, 11 and 12, the MOD land, and Mixed Use land) were seen to support the following habitats/ecological features at the time of survey:

• Hard-standing • Re-colonising vegetation • Short-mown amenity grassland • Grassland developing over former arable land • Scattered scrub & hedgerows • Planted row of young to semi-mature trees

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.6.2 The locations of these habitat types and features are represented on Figure 7.2, and the composition and structure of each habitat is summarised below, with an account of the representative plant species present where appropriate.

7.6.3 In addition, the habitats are assessed and evaluated in terms of ecological value. None of the habitats within the Application Site are considered to be of value at the national or county level, and therefore the assessment of habitats set out below is given based upon the relative value of each habitat within the context of the local area or the site itself.

7.6.4 Background Records. Information returned from WSBRC includes a number of Nationally Scarce and UK BAP species, including Pheasant’s-eye Adonis annua, the closest record of which is located approximately 0.9km north-west of the wider site. There are also records for the IUCN Near Threatened species Dwarf Spurge Euphorbia exigua, and the Wiltshire County Notable species Corn Parsley Petroselinum segetum and Rough Poppy Papaver hybridum within 0.3km of the wider site.

Area 9a: re-colonising vegetation over rubble and disturbed ground

7.6.5 Habitat Description. Area 9a is dominated by hard-standing and disturbed ground with piles of rubble and stored material (see Photograph 7.1). There are patches of sparse re-colonising vegetation and these incorporate species present elsewhere within the wider site, including Black Medick Medicago lupulina, Creeping Buttercup Ranunculus repens, Creeping Thistle Cirsium arvense, Perennial Sow- thistle Sonchus arvensis, Prickly Lettuce Lactuca serriola, Smooth Hawk's-beard Crepis capillaris, Spear Thistle Cirsium vulgare, Weld Reseda luteola, and a single specimen of Wild Mignonette Reseda lutea.

7.6.6 Habitat Evaluation. These habitats support only very limited vegetation and are considered to be of negligible inherent ecological value at the site level.

Area 9b: developing post-arable grassland and hedgerow H1

7.6.7 Habitat Description. Area 9b supports a grassland sward, which is understood to have developed over arable land since the previous surveys were conducted in 2005 (see Photograph 7.2). The grasses are dominated by tussocks of Cock’s-foot Dactylis glomerata and Red Fescue Festuca rubra, with prostrate Ivy Hedera helix at the base of the adjacent hedgerow, and a patchy cover of broadleaved forbs such as American Willowherb Epilobium ciliata, Scentless Mayweed Tripleurospermum inodorum, Spear Thistle, Mugwort Artemisia vulgaris and White Dead-nettle Lamium album.

7.6.8 The adjacent hedgerow (shown as H1 on Figure 7.2) is approximately 1-2m high and wide, and is dominated by suckering Blackthorn Prunus spinosa in the south and Elm Ulmus sp. to the north. It also incorporates a large mature Beech Fagus sylvatica tree at the northern-most end. Other more occasional species comprise Buckthorn Rhamnus cathartica, Elder Sambucus nigra, Hawthorn Crataegus monogyna and a wild Rose Rosa sp. (see Photograph 7.2).

7.6.9 Habitat Evaluation. The grassland is of recent origin, species-poor and readily re-creatable. Accordingly it is of low-negligible ecological value at the site level.

7.6.10 The hedgerow is also species-poor in terms of both the woody and ground flora component. It does, however, incorporate a mature native Beech tree; and as the hedgerow comprises solely native species, it meets the definition of the UK BAP Priority Habitat type ‘Hedgerows’. As such, this short section of hedgerow is considered to be of some moderate value at the site level.

Area 10: developing post-arable grassland, with scattered scrub at the fence-line

7.6.11 Habitat Description. Area 10 is dominated by grassland, which also appears to be developing over former arable land, as above (see Photograph 7.3). The south of this land parcel appears to have been subject to relatively recent disturbance and supports a range of sparsely-distributed grasses, including Barren Brome Anisantha sterilis, Cock's-foot, False Oat-grass Arrhenatherum elatius, Oat Avena sp., Perennial Rye-grass Lolium perenne, Rough Meadow-grass Poa trivialis and Timothy Phleum pratense. The broadleaved component to the sward is relatively diverse as a result of this disturbance and

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

incorporates dense patches of American Willowherb, Black Medick and Common Ragwort Senecio jacobaea, as well as Broad-leaved Dock Rumex obtusifolius, Common Poppy Papaver rhoeas, Dandelion Taraxacum offinale agg., Dove's-foot Crane's-bill Geranium molle, Fox-and-cubs Pilosella aurantiaca, Mugwort, Petty Spurge Euphorbia peplus, Perennial Sow-thistle, Ploughman's-spikenard Inula conyza, Prickly Lettuce, Prickly Sow-thistle Sonchus asper, Ribwort Plantain Plantago lanceolata, Scentless Mayweed, Wall Lettuce Mycelis muralis, Weld, Wild Teasel Dipsacus fullonum, White Campion Silene latifolia, White Clover Trifolium repens and Yarrow Achillea millefolium. In addition, there are occasional specimens of Bittersweet Solanum dulcamara, Blue Fleabane Erigeron acris, Common Toadflax Linaria vulgaris and Wild Marjoram Origanum vulgare within the sward, as well as saplings of Sycamore Acer pseudoplatanus and Dogwood Cornus sanguinea. There is also a small mound of spoil within the site, supporting a cover of dense tall ruderal species, predominantly Broad-leaved Dock, Perennial Sow- thistle, Prickly Lettuce and Spear Thistle.

7.6.12 To the north, the grassland is more established, and grasses such as False Oat-grass have become more dominant, thereby reducing overall species diversity here. Other more frequent species in this area include Common Nettle Urtica dioica, Common Ragwort, Creeping Thistle, Field Bindweed Convolvulus arvensis, Hogweed Heracleum sphondylium and Mugwort. This area also contains a site compound with site office containers, car parking and storage (see Photograph 7.4).

7.6.13 There is no hedgerow at the south-western boundary of Area 10, but a small number of shrubs (comprising mainly Elder, Hawthorn and wild Rose Rosa sp.) have colonised along the fence line.

7.6.14 Habitat Evaluation. As above, the grassland is of recent origin, and although there are areas of moderate species-richness, the relative diversity of broad-leaved forbs present is a reflection of the disturbed nature of the habitat, and this community would not therefore be expected to persist for any length of time. Indeed, the patches of more established grasses within Area 10 are far less diverse in composition. Furthermore, the scattered shrubs along the fence-line incorporate only a small number of species and would therefore be readily re-creatable. Accordingly, these habitats are of no more than low ecological value at the site level.

Area 11: developing post-arable grassland, and hard-standing with rubble piles

7.6.15 Habitat Description. The developing grassland described under Area 9b above is more-or-less continuous with that in the north-east of Area 11, and supports tussocks of Cock’s-foot, Common Bent Agrostis capillaris, False Oat-grass and Red Fescue, with patches of American Willowherb, Common Ragwort and Dandelion.

7.6.16 To the south-west, the habitat is continuous with Area 9a, and contains large heaps of tipped rubble, which are essentially un-vegetated (seen in the right of Photograph 7.5).

7.6.17 Beyond Area 11, at the north-western boundary of the wider site, is a line of trees/shrubs and grassland which has been fenced off to protect it during construction. The mature trees at this boundary are predominantly Beech, with Elm being the dominant shrub species among more occasional Elder, Hawthorn and wild Rose (see Photograph 7.5).

7.6.18 Habitat Evaluation. The habitats within Area 11 support only very limited vegetation and are considered to be of negligible inherent ecological value at the site level. The retained boundary trees and shrubs to the north are of relatively high ecological value at the site level but are well outside of the Application Site boundary of Area 11.

Area 12: developing post-arable grassland, with scattered scrub at the fence-line

7.6.19 Habitat Description. Area 12 is dominated by developing post-arable grassland, which is more established towards the north-eastern boundary where it appears to have colonised out from the former arable field boundary. Here, False Oat-grass dominates, with patches of Cock’s-foot, Common Bent and Common Couch Elytrigia repens. Broadleaved herbs include Common Nettle, Creeping Buttercup, Creeping Thistle, Dandelion and White Dead-nettle, as well as extensive patches of American Willowherb (see Photograph 7.6).

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.6.20 To the south and west, where Area 12 abuts the development which is currently undergoing construction, it appears to have been more recently disturbed and contains far fewer grasses. Here there are patches of bare soil and the vegetation is dominated by broadleaved species such as Black Medick, Common Field Speedwell Veronica persica, Common Whitlowgrass Erophila verna agg., Greater Plantain Plantago major, Mugwort, Prickly Lettuce, Prickly Sow-thistle, Scentless Mayweed, Smooth Sow-thistle, Spear Thistle, Red Clover Trifolium pratense and Weld as well as occasional Barren-brome and Bent- grass Agrostis sp.

7.6.21 Along the fence line at the north-eastern boundary there are scattered shrubs of Elder, Hawthorn and wild Rose, but these appear to have colonised naturally along the boundary and are not considered to represent relics of a former hedgerow (see Photograph 7.6).

7.6.22 Habitat Evaluation. As above, the grassland and scattered shrubs are species-poor, of relatively recent origin, and are readily re-creatable. Accordingly these habitats are of low ecological value at the site level.

Mixed Use Area: developing post-arable grassland

7.6.23 Habitat Description. The proposed Mixed Use Area supports developing post-arable grassland similar to that described above, and contains Barren Brome, Common Bent, False Oat-grass and Perennial Rye-grass, with American Willowherb, Black Medick, Common Mallow Malva sylvestris, Common Ragwort, Creeping Buttercup, Creeping Thistle, Dandelion, Dove's-foot Crane's-bill, Field Bindweed, a Hawkbit Leontodon sp., Mugwort, Perennial Sow-thistle, Ribwort Plantain, Spear Thistle, White Clover, Yarrow and a single plant of Field Scabious Knautia arvensis (see Photograph 7.7). At the eastern boundary is an off-site hedgerow (shown as H2 on Figure 7.2) dominated by Blackthorn.

7.6.24 Habitat Evaluation. The grassland within the proposed Mixed Use Area is relatively species-poor, of recent origin, and is readily re-creatable. Accordingly these habitats are of low ecological value at the site level. The hedgerow is of some ecological value as it comprises native species and thus qualifies as a BAP habitat, but it should be noted that this is outside of the Application Site boundary.

MOD Area: short-mown amenity grassland, with hedgerow H3 and row of trees

7.6.25 Habitat Description. The MOD Area is dominated by amenity grassland which is maintained as a sports pitch and is therefore kept mown short (see Photograph 7.8). Species present within the sward include Cock’s-foot, Common Bent, Perennial Rye-grass, Red Fescue, Daisy Bellis perennis, Dandelion, Lesser Trefoil Trifolium dubium, White Clover and occasional Smooth Hawk's-beard.

7.6.26 At the northern boundary of the MOD area is a line of young to semi-mature Norway Maple Acer platanoides and Lime Tilia x europaea trees (see Photograph 7.8). There is also a hedgerow (shown as H3 on Figure 7.2) at the western boundary of the MoD Land, which is over 3m high and wide, with Common Nettle at the base. The hedgerow is relatively diverse and contains Blackthorn, Bramble Rubus fruticosus agg., Dogwood, Elder, Hawthorn, Privet Ligustrum sp., Wayfaring-tree Viburnum lantana and a wild Rose Rosa sp.

7.6.27 Habitat Evaluation. The amenity grassland is extremely species-poor and readily re-creatable, and as such is of negligible ecological value at the site level. The hedgerow is well-established and moderately diverse in terms of its woody component, and is therefore considered to be of moderate ecological value at the site level. The row of trees, however, comprise planted non-native specimens which are of no great age, and are therefore of low ecological value at the site level.

Invasive Non-native Species

7.6.28 Legislation. It is an offence to cause to grow in the wild any plant listed under Schedule 9 Part II of the Wildlife and Countryside Act 1981 (as amended). As such, all relevant precautions should be taken when carrying out actions that could potentially spread these plants.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.6.29 Habitat Description. No evidence of any non-native invasive Schedule 9 plant species was recorded during the site surveys conducted.

7.6.30 Habitat Evaluation. The surveys were conducted within the active growing season for species such as Japanese Knotweed Fallopia japonica and Giant Hogweed Heracleum mantegazzianum, but no such species were recorded. It is therefore considered highly unlikely that any Schedule 9 species are present within the Application Site boundary.

7.7 Baseline Conditions: Faunal Use of the Application Site

7.7.1 General observations were made during the surveys of any faunal use of the Application Site. In addition, specific surveys were conducted in respect of Badger and bats. Below, the presence or potential presence of these species within the Application Site is evaluated.

Badger

7.7.2 Legislation. In the UK the relevant legislation pertaining to Badger Meles meles is the Protection of Badgers Act 1992. The legislation aims to protect the species from persecution, rather than being a response to an unfavourable conservation status, as the species is in fact common over most of Britain. It should be noted that the legislation is not intended to prevent properly authorised development. It is the duty of planning authorities to consider the conservation and welfare effects of development upon Badger and issue permissions accordingly. Planning authorities are, therefore, obliged to consult the appropriate Statutory Nature Conservation Organisation (SNCO) over any planning application that is likely to adversely affect Badger. The SNCO for England is Natural England.

7.7.3 Under the Protection of Badgers Act it is an offence to:

• Willfully kill, injure, take, possess or cruelly ill-treat* a Badger, or attempt to do so; # • To intentionally or recklessly interfere with a sett (this includes disturbing Badgers whilst they are occupying a sett, as well as damaging or destroying a sett or obstructing access to it).

∗ The intentional elimination of sufficient foraging area to support a known social group of Badgers may, in certain circumstances, be construed as an offence by constituting “cruel ill treatment” of a Badger.

∗ A sett is defined as “any structure or place which displays signs indicating current use by a Badger”. Advice issued by Natural England (June 2009) is that a sett is protected as long as such signs remain present, which in practice could potentially be for some time after the last actual occupation by Badger.

7.7.4 Licences can be obtained from the SNCO for development activities that would otherwise be unlawful under the legislation. Guidance on the types of activity that should be licensed is laid out in the publications “Badgers and Development” (English Nature, 2002) and “Badgers and Development: A Guide to Best Practice and Licensing. Interim Guidance Document” (Natural England, 2011). For example, excavation work or use of heavy machinery within 20m of any entrance to an active Badger sett may require a licence.

7.7.5 Background Records. Information obtained from WSBRC returned several records for Badger, the closest of which is located within the same 1x1km grid-square as the site, and dates to 2004. However, no more specific location information has been provided. The Wiltshire Badger Group was not able to provide any relevant data.

7.7.6 Survey Findings. No Badger setts were recorded within the site during the survey work conducted. However, a small sett was identified just off-site, approximately 2m from the boundary of Area 9b, within a hedgerow connected to H1, which extends off-site to the north-east (see Figure 7.2). This comprises a single active entrance, in addition to two inactive entrances and two disused entrances. The single active entrance is well-used, with a large mound of fresh spoil and several Badger hairs found at the entrance. It

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

is considered that this represents a subsidiary sett (or possibly an outlying sett) with no evidence to suggest that there is a linked main sett close by. In addition, there are smaller burrow entrances in the vicinity which appear to be used by Rabbit Oryctolagus cuniculus.

7.7.7 There is a multi-pit latrine adjacent to the sett within the hedgerow, and a single Badger dropping was noted close by within the grassland of Area 9b. In addition, there are limited foraging signs in the form of snuffle marks in the grassland near to the aforementioned sett. There are occasional mammal pathways throughout the site, albeit these are likely due in part to Fox Vulpes vulpes, Rabbit, deer and dog-walkers, as well as Badger, evidence of all of which was recorded within or adjacent to the site.

7.7.8 Evaluation. The off-site sett was not recorded during the previous surveys undertaken to inform the 2005 ES, nor was it recorded during recent ecological surveys of the adjacent land undertaken by Aspect Ecology in June 2011. Accordingly it is considered that the sett is not likely to be long-established, and indeed that use of this sett may be sporadic and linked to the exploitation of a local seasonal food resource, such as ripe grain. Based on the limited levels of activity seen at the sett, and the relatively small volume of spoil which was seen to have been excavated from it, it is considered unlikely that there is an extensive network of tunnels extending into the adjacent Application Site (i.e. Area 9b), particularly as the sett is located on a slight bank, with any tunnels likely therefore to extend in an off-site direction under the higher ground. Nonetheless, there is the potential for a tunnel (and possibly, although less likely, a chamber) to extend under the Application Site, within Area 9b.

Bats

7.7.9 Legislation. All British bats are classed as European Protected Species and therefore receive protection under the Conservation of Habitats and Species Regulations 2010 (as amended), making it an offence inter alia to:

• Deliberately kill, injure or capture a bat; • Deliberately disturb bats, including in particular any disturbance which is likely to impair their ability to survive, to reproduce or to rear or nurture their young, or their ability to hibernate or migrate, or which is likely to affect significantly their local distribution or abundance; • Damage or destroy a breeding site or resting place of a bat.

7.7.10 In addition, all British bats are also listed under Schedule 5 of the Wildlife and Countryside Act 1981 (as amended) which contains further provisions making it an offence to intentionally or recklessly:

• Damage or destroy, or obstruct access to, any structure or place which any bat uses for shelter or protection; or • Disturb bats while occupying a structure or place that it uses for that purpose.

7.7.11 If proposed development work is likely to result in an offence a licence will need to be obtained from Natural England which would be subject to appropriate measures to safeguard bats.

7.7.12 There are at least 17 breeding bat species in Britain. Many of them are considered threatened due to a variety of factors including habitat loss and disturbance/damage to roosts. Of these 17 species, a number regularly use buildings and trees as roost sites.

7.7.13 Background Records. Information obtained from WSBRC does not include any records of bats from within the site itself. The closest confirmed roost records relate to Serotine Eptesicus serotinus and Brown Long-eared bat Plecotus auritus, and are located approximately 1km south-east of the site. In addition, there is a record for a Pipistrelle Pipistrellus sp. roost located approximately 1.2km to the south- west of the site. There are also records for the presence of Brandt’s/Whiskered bat Myotis brandtii/mystacinus, Greater Horseshoe bat Rhinolophus ferrumequinum and Noctule Nyctalus noctula within the wider search area, but these records date to the 1950’s and 1960’s and are therefore considered to be historical in nature.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.7.14 Tree Assessment Survey: Results. A number of semi-mature and mature trees are present within the wider site. These trees were assessed for their potential to support roosting bats and rated according to the 2007 BCT guidelines as either Category 1 – a confirmed roost, Category 2a – high potential, Category 2b – moderate/low potential, or Category 3 – negligible potential.

7.7.15 In summary, there are no trees with potential to support roosting bats within the Application Site. However, there are a small number of potentially suitable trees beyond the Application Site boundary, and these are shown on Figure 7.2 for completeness.

7.7.16 Activity Transect Surveys: Results. The Application Site affords some potential to foraging/commuting bats in the form of the boundary hedgerows and tree lines. However, the relatively disturbed nature of the land (development within the wider site being under construction at the time of survey) is likely to reduce its attractiveness to bats. In order to assess current levels of bat activity in relation to the Application Site, a fixed-point automated bat activity survey was conducted, with static bat detectors being affixed to trees/shrubs at the boundaries for a period of several nights (see Table 7.1 above for details).

7.7.17 The results of the September 2012 bat activity survey work are shown on Figure 7.3. In summary, the vast majority of activity recorded can be attributed to Common Pipistrelle Pipistrellus pipistrellus and Soprano Pipistrelle Pipistrellus pygmaeus bats, with very much lower levels of activity detected from the woodland bat species Barbastelle Barbastella barbastellus (a peak of five passes in a single 24-hour period), as well as Noctule Nyctalus noctula (a peak of three passes in a single 24-hour period) and Myotis sp. (a peak of one pass in a single 24-hour period). In addition, a single Nathusius’ Pipistrelle Pipistrellus nathusii and Serotine/Leisler Eptesicus serotinus/Nyctalus leisleri pass was recorded on one occasion only, in the MOD land and Area 10, respectively.

7.7.18 Activity Transect Surveys: Evaluation. The levels of Pipistrelle activity recorded correspond to a level that would be typically expected within a rural-edge site of this nature, and the low number of passes from Noctule within Area 10 and the MOD land may represent limited commuting activity by this large bat to more suitable off-site habitat (for example, the numerous riverside meadows within 1-2km of the site). The very low number of passes by Myotis sp., Nathusius’ Pipistrelle and Serotine/Leisler appear to be representative of very occasional / sporadic use of the site by these species of bat, and as such the site is not considered to be of any elevated importance for these species.

7.7.19 Barbastelle is a woodland-dependant species of bat, and the identification of this species at the boundary of Area 10 is therefore suggestive of commuting (rather than foraging) behaviour. However, the nearest substantial blocks of woodland are Clarendon Park approximately 4.5km to the south-east, and Grovely Wood approximately 6km to the west, with no obvious natural linear features (such as river corridors or tree belts) connecting these or any other blocks of woodland to the Application Site. As such, given that this Barbastelle activity was identified in September, it may be indicative of landscape-scale commuting, with very low numbers of bats taking this route (among others) to a mating or hibernation site within the wider area. This theory is supported by the temporal spread of Barbastelle passes, with no concentration of passes at the beginning or end of a night, as might be expected if a bat was using a route to regularly travel to and from a regular roost site. In conclusion, a review of the local topography indicates that there are a number of similar or more suitable commuting routes available for this species within the local area, and as such the site does not appear to offer unique opportunities for this (or any other) bat species.

Other Mammals

7.7.20 Background Records. Information obtained from WSBRC returned records for a number UK BAP species, the closest is for Brown Hare Lepus europaeus located within the field adjacent to the north- eastern boundary of the wider site. There are also numerous historical records for Hedgehog Erinaceus europaeus within the local area, although the closest record (located approximately 0.3km south-west of the site) is more recent and dates to 2002. In addition, WSBRC provided records of the riparian species Water Vole Arvicola amphibius and Otter Lutra lutra, the closest of which are associated with the River

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Bourne, approximately 1.2km east of the Application Site. The closest record for Dormouse Muscardinus avellanarius provided by the NBN is located approximately 6km to the south-east.11

7.7.21 Survey Findings. The Application Site lacks aquatic habitat that could be of value for Water Vole and Otter. It also lacks dense, well-established woody vegetation that could be of value for Dormouse, and given the absence of records for this species within the local area, it is considered highly likely that this species is absent. Furthermore, in the time that has elapsed since the survey work was undertaken for the 2005 ES, the extent of open habitat across the wider site has been drastically reduced, such that the Application Site is no longer likely to be of potential value to Brown Hare. No evidence of Hedgehog was seen within the Application Site during the general surveys undertaken, albeit the grassland offers potential foraging opportunities for this species.

7.7.22 A small number of Short-tailed Field Vole Microtus agrestis were seen under a refugium within the tall grassland at the far eastern boundary of Area 9. In addition, evidence of Rabbit and Fox was recorded within areas of taller grassland throughout the site, and there are what appear to be deer lie-ups in the field margins of the arable field to the north-east of the wider site. It is also likely that the Application Site supports a number of other common small mammals, such as Brown Rat Rattus norvegicus and Wood Mouse Apodemus sylvaticus.

7.7.23 Evaluation. The other mammal species recorded within the Application Site are of limited conservation interest, being common both locally and nationally.

Reptiles

7.7.24 Legislation. All six species of British reptile are listed under Schedule 5 of the Wildlife and Countryside Act 1981 (as amended). However, a higher level of protection is afforded to Sand Lizard Lacerta agilis and Smooth Snake Coronella austriaca than to Adder Vipera berus, Grass Snake Natrix natrix, Slow-worm Anguis fragilis and Common Lizard Lacerta vivipara.

7.7.25 For all British reptile species, Section 9 of the Wildlife and Countryside Act 1981 (as amended) contains provisions making it an offence to intentionally:

• Kill or injure; or to • Sell, offer for sale or trade any British reptile.

7.7.26 Because Slow-worm, Common Lizard, Grass Snake and Adder are relatively widespread British species, their habitat is not directly protected. Nevertheless, because of their partial protection, disturbing or destroying their habitat whilst they are present may lead to an offence.

7.7.27 Background Records. Information obtained from WSBRC returned a single recent record (dating to 1997) of Common Lizard Zootoca vivipara, located 1.2km south-west of the Application Site, where it is associated with the ‘Old Sarum’ CWS. There are also a number of historical records for Slow-worm Anguis fragilis within the same 1x1km squares that contain the site, but these date to the 1950’s. In addition, there is a single historical record for Grass Snake Natrix natrix located within a 1x1km grid- square 0.7km north of the site.

7.7.28 Survey Findings. Reptile surveys were previously undertaken to inform the 2005 ES, but these did not identify the presence of any reptiles within or adjacent to any of the Application Site. The site as a whole has been subject to a considerable level of disturbance since that point, with parts of Area 9a and Area 11 subsequently being given over to hard-standing and rubble. However, the more established and ranker areas of grassland within parts of the Application Site provide a habitat structure that offers potentially suitable (albeit sub-optimal) opportunities for common reptile species. In particular, there are potentially suitable areas of grassland located towards the boundaries of Area 9b, Area 10, Area 11 and Area 12, albeit these areas of grassland are limited in size and the vegetation has only relatively recently

11 The information used here was sourced through the NBN Gateway website and included the following resources. WSBRC. "Wiltshire & Swindon Site-based Survey Records". Updated 31/05/2012. http://data.nbn.org.uk/ Accessed 30 Oct. 2012). The data providers & NBN Trust bear no responsibility for the further analysis or interpretation of this material, data and/or information.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

become established following its former arable use, and some subsequent disturbance. Whilst allowed to grow tall during the summer, the Mixed Use Area had been mown by October 2012 and given its isolated nature, it is not therefore considered to represent opportunities for reptiles. The amenity grassland within the MOD Area is very regularly mown so as to render it entirely unsuitable for this species group.

7.7.29 Evaluation. No reptiles were recorded within the site as a whole during the 2005 ES survey work. The nearest known extant population of reptiles is located over 1km from the wider site at the ‘Old Sarum’ CWS, or more specifically, 1.9km from the nearest area of suitable habitat within the Application Site (Area 10), and is separated from it by the busy A345 main road.

7.7.30 Accordingly, whilst there is scope for reptiles to have colonised the wider site by travelling from an off-site population, along the field margins of the surrounding arable land and into the habitat at the Application Site margins, it is considered that this is reasonably unlikely in the time that has elapsed since the previous surveys, particularly given the disturbed nature of the Application Site land. Furthermore, in the unlikely event that any reptiles have reached the Application Site, given the level of disturbance they are regularly subject to, it is considered that their presence would be very occasional or transient in nature, involving very low numbers or individuals only. In summary, it is considered extremely unlikely that the Application Site supports any resident populations of reptiles, albeit it is possible that individual reptiles may, on occasion, pass through or adjacent to the boundary of the Application Site.

Amphibians

7.7.31 Legislation. All British amphibian species receive a degree of protection under the 1981 Wildlife and Countryside Act (as amended). The level of protection varies from protection from sale or trade only, as is the case with Smooth/Palmate Newts Lissotriton spp., Common Frog Rana temporaria and Common Toad Bufo bufo; to the more rigorous protection afforded to species such as the Great Crested Newt Triturus cristatus.

7.7.32 Although Great Crested Newts are regularly encountered throughout much of lowland England and Wales, the UK holds a large percentage of the world population of the species. As such, the UK has an international obligation to conserve the species and it receives full protection under domestic and European legislation. Specifically, Great Crested Newt is classified as a European Protected Species and therefore receives protection under the Conservation of Habitats and Species Regulations 2010 (as amended), making it an offence inter alia to:

• Deliberately kill, injure or capture a Great Crested Newt; • Deliberately disturb Great Crested Newts, including in particular any disturbance which is likely to impair their ability to survive, to reproduce or to hibernate, or migrate, or which is likely to affect significantly their local distribution or abundance; • Deliberately take or destroy the eggs of a Great Crested Newt; • Damage or destroy a breeding site or resting place of a Great Crested Newt.

7.7.33 In addition, the Great Crested Newt is also listed under Schedule 5 of the Wildlife and Countryside Act 1981 (as amended) which contains further provisions making it an offence to intentionally or recklessly:

• Damage or destroy, or obstruct access to, any structure or place which any Great Crested Newt uses for shelter or protection; or • Disturb any Great Crested Newt while occupying a structure or place which it uses for that purpose.

7.7.34 If proposed development work is likely to result in an offence a licence may need to be obtained from Natural England which would be subject to appropriate measures to safeguard Great Crested Newt.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.7.35 Background Records. Information obtained from WSBRC did not include any records for the protected species Great Crested Newt, but the data did include a single record for the UK BAP species Common Toad Bufo bufo, located in a 1x1km grid-square 2km west of the wider site. The closest Great Crested Newt records provided by the NBN Gateway are located approximately 7km south-east of the site, and date to 198112.

7.7.36 Survey Findings. Whilst there are some limited areas of suitable (albeit sub-optimal) terrestrial habitat within parts of the Application Site (i.e. Area 9b, Area 10, Area 11 and Area 12), there are no water bodies suitable for breeding amphibians (such as ponds or ditches) within or adjacent to the wider site. Indeed, the nearest pond shown on the 1:25,000 OS mapping of the local area is located over 1.1km south-east of the site, being separated from it by the main Portway road and the Old Sarum Business Park.

7.7.37 Evaluation. Typically Great Crested Newts use terrestrial habitats within 0.25km of their breeding ponds and occasionally range as far as 0.5km, although in rare cases Newts may disperse 1km or more. Given the degree of separation between the closest record and the Application Site, and indeed, the distance of the nearest pond, it is considered extremely unlikely that this species is present within the Application Site or the adjacent land.

Birds

7.7.38 Legislation. Section 1 of the Wildlife & Countryside Act 1981 (as amended) is concerned with the protection of wild birds. With certain exceptions, all wild birds are protected such that it is an offence to intentionally:

• Kill, injure or take any wild bird; • Take, damage or destroy the nest of any wild bird whilst in use* or being built; • Take or destroy an egg of any wild bird. ∗ The nests of birds that re-use their nests as listed under Schedule ZA1, e.g. Golden Eagle, are protected against taking, damage or destruction irrespective of whether they are in use or not.

7.7.39 Species listed under Schedule 1 of the Act receive greater protection such that they are also protected against intentional or reckless disturbance whilst building a nest or whilst they are in, on or near a nest containing eggs or young. The dependent young of Schedule 1 birds are also protected against intentional or reckless disturbance. Offences in respect of Schedule 1 species are subject to special, i.e. greater, penalties.

7.7.40 Conservation Status. The RSPB categorise British bird species in terms of conservation importance based on a number of criteria including the level of threat to a species’ population status13. Species are listed as Green, Amber or Red. Red Listed species are considered to be of the highest conservation concern being either globally threatened and or experiencing a high/rapid level of population decline (∃50% over the past 25 years).

7.7.41 Background Records. Information obtained from WSBRC returned records for a number of bird species of conservation concern within the locality. These include records for the Schedule 1 species Redwing Turdus iliacus and the RSPB Red listed bird species Cuckoo Cuculus canorus, House Sparrow Passer domesticus, Skylark Alauda arvensis, Starling Sturnus vulgaris and Yellowhammer Emberiza citrinella, as well as Lapwing Vanellus vanellus which is the closest, the record being located approximately 0.3km west of the site.

7.7.42 Survey Findings. Parts of the Application Site (i.e. Area 9b, Area 10, Area 12, the MOD land and the Mixed Use land) offer limited opportunities for breeding birds, in the form of the hedgerows, and boundary scrub and trees. Several birds were recorded within the site during the survey work undertaken

12 The information used here was sourced through the NBN Gateway website and included the following resources. Biological Records Centre. "Reptiles and Amphibians Dataset". Updated 30/11/2009. http://data.nbn.org.uk/ Accessed 30 Oct. 2012). The data providers & NBN Trust bear no responsibility for the further analysis or interpretation of this material, data and/or information. 13 RSPB “The population status of birds in the UK - Birds of Conservation Concern: 2009”

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

including the Amber list species Dunnock Prunella modularis and House Martin Delichon urbica, and the Red List species House Sparrow; as well as Blackbird Turdus merula, Blue Tit Cyanistes caeruleus, Carrion Crow Corvus corone, Goldfinch Carduelis carduelis, Greenfinch Carduelis chloris, Magpie Pica pica, Pheasant Phasianus colchicus, Robin Erithacus rubecula, and Wood-pigeon Columba palumbus. In addition, the RSPB Red List species Herring Gull Larus argentatus and occasional Skylark Alauda arvensis were recorded in association with the off-site fields adjacent to the east. Of the species recorded within the site, it is expected that a proportion would nest within the aforementioned parts of the Application Site, making use of the hedgerows and boundary scrub/trees in particular.

7.7.43 Evaluation. The conservation status of the birds recorded during the surveys is set out below within Table 6.16. None of the species recorded from within or adjacent to the wider site are listed on Schedule 1 of the Wildlife and Countryside Act 1981 (as amended). Most of the birds recorded within/adjacent to the Application Site do not have any special conservation status; although Herring Gull, House Sparrow, Lapwing and Skylark are included on the RSPB Red list, and Dunnock and House Martin are included on the RSPB Amber list as a result of declines in UK breeding populations. However, these species are still common and widespread, both locally and nationally, and there is no reason to suggest that any parts of the Application Site are of critical significance for these species.

Table 6.16: Status of birds recorded within/adjacent to the Application Site

BAP Priority Species/ Wildlife & Countryside RSPB RSPB Species Species of Principal Act 1981 Schedule 1 Red List Amber List Importance Dunnock Τ Herring Gull Τ Τ House Martin Τ House Sparrow Τ Τ Lapwing Τ Τ Skylark Τ Τ

Invertebrates

7.7.44 Background Records. Information obtained from WSBRC returned records for a number of invertebrate species of conservation concern, the closest of these being the protected species White- clawed Crayfish Austropotamobius pallipes and the Red Data List species Desmoulin's Whorl Snail Vertigo moulinsiana, both of which are aquatic species and are associated with the River Bourne approximately 1.2km east of the site. In addition, there are several records of the Schedule 5 protected species Marsh Fritillary Euphydryas aurinia located approximately 1-2km north-west of the site. However, in the absence of any suitable habitat within the Application Site, it is considered highly unlikely that any of these species is present.

7.7.45 In addition, there are records within the wider search area for Cinnabar Tyria jacobaeae, Dingy Skipper Erynnis tages, Duke of Burgundy Hamearis lucina, Grizzled Skipper Pyrgus malvae, Pearl- bordered Fritillary Boloria euphrosyne, Pretty Chalk Carpet Melanthia procellata, Silver-studded Blue Plebejus argus, Small Emerald Hemistola chrysoprasaria, Small Heath Coenonympha pamphilus, Wall Lasiommata megera and White Ermine Spilosoma lubricipeda, all of which are listed under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006, as species of Principal Importance for the conservation of biodiversity in England.

7.7.46 Survey Findings. The Application Site is expected to support a limited range of common invertebrate species, and indeed Honeybee Apis mellifera, Meadow Brown Maniola jurtina, Garden Snail Helix aspersa were recorded during the general survey work undertaken.

7.7.47 Evaluation. The developing grassland and hedgerows are likely to be of some limited value for invertebrates. However, given the absence of any areas of vertical exposed soil/cliffs, free-draining soils, ant-hills, fibrous animal dung, substantial patchy scrub, wetland/aquatic habitat, or extensive areas of

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

established/ancient trees/woodland, it is considered highly unlikely that any protected, rare or notable invertebrate species inhabit any of the Application Site.

7.8 Likely Significant Effects

7.8.1 The methodology set out above describes how the types and degrees of effect, together with their appropriate level of significance are assessed in terms of potential effects on existing habitats and species within the Application Site and on ecological designations in the vicinity. These effects are further described in the following discussion.

Effects on Statutory Ecological Designations

7.8.2 There are a number of nature conservation designations within the vicinity of the Application Site, as shown on Figure 7.1, of which none are located within or adjacent to the Application Site boundary.

7.8.3 River Avon SAC & River Avon System SSSI. The nearest statutory ecological designations are the ‘River Avon’ SAC‘ and the River Avon System’ SSSI, which are situated approximately 1.2km south-east of the Application Site and are separated from them by the main Portway road and an expanse of arable fields. The SAC is designated for the presence of a single Annex I habitat (Water courses of plain to montane levels with Ranunculion fluitans and Callitricho-Batrachion vegetation) and five Annex II species (Brook Lamprey, Atlantic Salmon, Sea Lamprey, Bullhead and Desmoulin`s Whorl Snail).

Effects: This suite of designations is separated from the wider site by the main Portway road and an expanse of arable fields, and as such no direct effects on the River itself are anticipated as a result of the Proposed Developments. Furthermore, as the site is not within flood zone 3 and does not contain any wetland habitats, no direct impacts are anticipated on the Annex II species Desmoulin`s Whorl Snail, or indeed any of the fish for which the SAC is designated.

Construction Effects. There is potential for minor insignificant indirect effects to arise during the construction phase. The strata underlying the site is chalk (a major aquifer), and as such, any major spillages of fuel or other chemicals could potentially soak into groundwater and out into the River Avon. However, by following standard Pollution Prevention Guidelines (PPG)14 as set out within the Drainage chapter, potential pollution effects will essentially be reduced to nil. In addition, there is the potential for indirect effects to arise as a result of the operational phase, and these are considered below.

Operational Run-off. If roof water down-pipes and road drains were not sealed against pollutants entering the system, then groundwater could become polluted, and this could potentially feed into the River Avon. However, the use of suitably designed infiltration devices to discharge surface water run-off from the Proposed Developments to ground, in line with Environment Agency guidance15, will ensure that no new pathways are created for pollutants to reach groundwater. The infiltration devices include the provision of a series of linked infiltration basins and

14 Accessed from: http://www.environment-agency.gov.uk/business/topics/pollution/39083.aspx 15 Environment Agency, (2008). ‘Groundwater protection: policy and practice’.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

swales along the north-western boundary and the provision of traditional soakaways. Run-off from roads is conveyed to the infiltration basins and run-off from roofs and other private areas is conveyed either to traditional soakaways or to the infiltration basins. Pollution control measures are also incorporated in the design of the drainage arrangements. These include infiltration devices in the form of soakaways, pervious pavements and infiltration basins, which can improve the quality of the run-off, and the use of deep trapped gullies and bypass separators/petrol interceptors where required. With the implementation of the above pollution control measures it is considered any risk of pollution to groundwater would be minimised such that the proposed development would have no likely significant impact on groundwater.

Phosphate Discharge. Potential hydrological impacts on the River Avon SAC were identified in the Habitats Regulations Assessment (HRA) report published by Wiltshire County Council in June 2009 and updated in February 2012. The River Avon SAC and ground water sources are particularly vulnerable to the effects of pollution, specifically elevated phosphate levels (P) from additional sewage discharges to the local Sewage Treatment Works (STW) during the operational phase. This could result in ecological damage to the River Avon due to excessive algal growth. However, the foul water pumping station designed and installed as part of the consented scheme for the wider site has sufficient capacity to accommodate the foul flows from the additional Application Site, and will pump effluent via a rising main to the gravity foul sewerage system which discharges to the Petersfinger STW. This STW currently has sufficient capacity to accommodate the additional effluent, and as Wessex Water has a statutory duty to comply with the discharge standards set by the Environment Agency, it is considered that the Proposed Development would have no likely significant effects upon the River Avon SAC in terms of Phosphate discharge.

Sedimentation. Diffuse pollution, in the form of sedimentation resulting from road verge erosion on a minor road running from Stoford to Middle Woodford, has also been identified in the HRA of the South Wiltshire Core Strategy as having a potential adverse effect on River Avon SAC. An assessment of anticipated usage of this road indicates that traffic from the Proposed Developments will not result in a significant increase in traffic flows along this route. Accordingly, there will be no significant effect on the River Avon SAC in terms of increased sedimentation.

Abstraction. Greater demand on water resources from the increased residential population within the Avon catchment could result in a requirement for higher levels of water abstraction, potentially impinging on river flows and water quality within the River Avon SAC.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

The above assessment has been used to complete Appendix 2 and 3 of Wiltshire County Council’s ‘River Avon SAC Procedure: Test of Likely Significance’ document, which is presented at Appendix 7.4. In summary, prior to mitigation, effects of the Proposed Development on the River Avon SAC are limited to operational effects resulting from increased water demand within the Avon catchment.

Prior to mitigation, effects are at the international level and of minor adverse significance.

7.8.4 Avon Valley LNR. The next nearest statutory designation is the ‘Avon Valley’ LNR, a publicly accessible reserve with marshy vegetation, willow wood, grassland, earth bank and reedbeds.

Effects: This designation is considered to be sufficiently well separated from the whole of the Application Site such that no direct effects from the Proposed Development are anticipated, during construction or operation.

Furthermore, the site’s designation as a LNR is a reflection of its resilience to recreation effects, and therefore no direct significant adverse effects are anticipated from any increase in recreational pressure. As such, no further assessment is required.

Prior to mitigation, effects are at the county level and not significant.

7.8.5 Lower Woodford Water Meadows, Bracknell Croft, Cockey Down & Camp Down SSSIs. The next nearest statutory designations are four SSSIs located between 2.4km and 2.6km from the Application Site, which have been designated for their botanical interest, namely ‘Lower Woodford Water Meadows’, ‘Bracknell Croft’, ‘Cockey Down’ and ‘Camp Down’ SSSIs.

Effects: These designations are considered to be sufficiently well separated from the whole of the Application Site such that no direct effects from the Proposed Development are anticipated, during construction or operation.

There is potential for increased recreational access to these SSSIs as a result of operation of the Proposed Development, which could give rise to potentially adverse effects in the form of increased trampling of vegetation. However, as any obvious route a walker, cyclist or motorist might take from the Application Site to reach these relatively small designations is over 3km in length, it is considered likely that any additional recreational visits to these designations will be minimal, and not significant in terms of effects on the botanical value of the grasslands.

Prior to mitigation, effects are at the national level and not significant.

7.8.6 Salisbury Plain SAC/SPA & Porton Down SPA/SSSI. The next nearest significant complex of statutory ecological designations is the ‘Salisbury Plain’ SAC/SPA and the ‘Porton Down’ SPA (and SSSI). The ‘Salisbury Plain’ SAC and Porton Down’ SPA/SSSI is located approximately 3.7km east of the wider site, whilst the Salisbury Plain SPA is located at a distance of approximately 8.0km. The ‘Salisbury

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Plain’ SPA is designated for the internationally important breeding population of Stone Curlew, together with internationally important numbers of wintering Hen Harrier; whereas the ‘Salisbury Plain’ SAC is designated for its semi-natural calcareous grasslands, scrubland facies, Juniper formations and large population of Marsh Fritillary butterflies.

Effects: These designations are considered to be sufficiently well separated from the whole of the Application Site such that no direct effects from the Proposed Development are anticipated, during construction or operation. Furthermore, no indirect effects are anticipated as a result of the construction phase of the Proposed Developments.

Recreational disturbance at Salisbury Plain SPA. The South Wiltshire Proposed Submission Core Strategy HRA gives consideration to potential impacts on the Salisbury Plain SPA and highlights the link between Stone Curlew breeding success and disturbance by people and dogs. Research shows that nesting birds are vulnerable to disturbance by dog walkers, and that this may increase as a result of residential development within 15km of the SPA.

The Application Site is located 8.0km from the relevant part of the SPA and as a result of the operational phase of the Proposed Development, there may be a minor increase in recreational visits to areas of the SPA used by breeding Stone Curlew.

Recreational disturbance at Salisbury Plain SAC. The South Wiltshire Proposed Submission Core Strategy HRA considers that physical disturbance (e.g. abrasion of habitats due to trampling) at Salisbury Plain SAC, as a result of the increase in visitor pressure predicted under the Core Strategy, is unlikely to significantly affect the integrity of the SAC. Accordingly, no further assessment is required in respect of this site.

Recreational disturbance at Porton Down SPA. There is normally no public access to Porton Down. As such, no significant effect on breeding Stone Curlew is anticipated, and no further assessment is required in respect of this site.

Prior to mitigation, effects are at the international level and of minor adverse significance.

7.8.7 New Forest SSSI/SAC/SPA/Ramsar. The other statutory ecological designations identified in the wider area by the Wiltshire and South Wiltshire Core Strategy HRA as being potentially sensitive are the ‘New Forest’ SSSI/SAC/SPA/Ramsar, the SAC/SSSI being located at a distance of approximately 14.4km, and the SPA/Ramsar being 15.1km to the south of the Application Site. The SAC is designated for the presence of eleven Annex I habitats (incorporating wetland, heathland and woodland) and two Annex II species (Stag Beetle and Southern Damselfly); whilst the SPA is designated for supporting populations of four Annex I bird species during the breeding season (Dartford Warbler, Honey Buzzard, Nightjar and Woodlark) and the Annex I species Hen Harrier over winter. The Ramsar and SSSI designations are conferred on account of the habitat quality and exceptional assemblages of species present.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Effects: These designations are considered to be sufficiently well separated from the whole of the Application Site such that no direct effects from the Proposed Development are anticipated, during construction or operation. Furthermore, no indirect effects are anticipated as a result of the construction phase of the Proposed Development.

Recreational disturbance at New Forest SPA. Visitor studies within the New Forest are discussed in Appendix 13 of the HRA of the South Wiltshire Core Strategy. The Appendix notes that there is currently no evidence base for the effects of disturbance on Annex I species of birds within the New Forest SPA, although it also notes that disturbance has been shown to adversely affect populations of Woodlarks elsewhere. The document concludes that only 3.2% of all visits to the New Forest originate from the area covered by the South Wiltshire Core Strategy, with 89% of these being generated by settlements located within 8.0km of the New Forest. Thus, the proposed South Wiltshire developments located more than 8.0km from the New Forest would have a combined effect amounting to approximately 0.1% of current levels of visitor numbers. Given that the Proposed Developments are located in excess of 15km from the nearest part of the SPA designation, it is considered that the development will not make a significant contribution, and therefore will have no significant effect, alone or in combination with other developments, on any recreational disturbance to key bird species within the New Forest SPA. Accordingly, no further assessment is required in respect of this site.

Air Quality Effects on New Forest SAC. Although there are no relevant air quality policies, potential effects from increased traffic volumes associated with development are discussed in the HRA of the South Wiltshire Core Strategy. The underlying concern is that emissions of oxides of nitrogen (NOx) as a result of development, principally from increased volumes of road traffic associated with new residential development, will result in damaging increases in levels of nitrogen deposition within internationally designated sites.

The transport and access assessment concludes that given the considerable distance (14.4km) from the New Forest SAC, there can be confidence that any increase in traffic volume on the A36 (or any other road) in the vicinity of the SAC during the operational phases of the Proposed Development will be below the 1000 AADT threshold identified in the DMRB16, and there will not therefore be a significant increase in NOx deposition within the SAC. Therefore, it can be concluded that there will be no significant effect on the New Forest SAC, alone or

16 Highways Agency (2009). ’Design Manual for Roads and Bridges’

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

in combination with other developments, and accordingly no further assessment is required in respect of this site.

Prior to mitigation, effects are at the international level and not significant.

Effects on Non-statutory Ecological Designations.

7.8.8 Winterbourne Earls Meadow & Old Sarum CWSs. There are no non-statutory nature conservation designations within or adjacent to the Application Site, the nearest such designation being the ‘Winterbourne Earls Meadow’ CWS, a former water meadow located approximately 1.1km to the east. ‘Old Sarum’ CWS is the next nearest designation, which is located approximately 1.2km south-west of the Application Site, and is designated for the unimproved grassland it supports. The nearest scheduled ancient woodland is located at a distance of approximately 4.5km.

Effects: All non-statutory nature conservation designations and scheduled ancient woodland is separated from the proposals by some distance, the closest such designations being separated by existing main roads and expanses of farmland. As such no direct effects from the Proposed Development are anticipated.

Potential construction effects on designations in the vicinity of the Application Site are restricted to noise, visual disturbance and the potential for pollution in the form of dust generated by the construction processes. These and other, more distant ecological designations are all considered to be sufficiently well separated from the Application Site such that no significant effects are anticipated.

During the operational phase of the Proposed Developments, there is potential for increased recreational access to the ‘Old Sarum’ CWS in particular, which could give rise to potentially adverse effects in the form of increased trampling of vegetation. However, chalk grassland is recognised as a resilient habitat with respect to recreational pressures and it is therefore anticipated to be relatively robust in terms of recreational effects.

Prior to mitigation, effects are at the county level and of minor adverse significance.

Effects on Habitats & Ecological Features

7.8.9 The habitats within the boundaries of the Application Site have been assessed as being of limited ecological interest, both in the local and national context. The impact assessment has been undertaken against this background.

7.8.10 Hard-standing & re-colonising vegetation. Area 9a and the south-western portion of Area 11 comprise re-colonising vegetation over rubble and disturbed ground. The sparse vegetation present incorporates common and widespread species, and this habitat is therefore considered to be of negligible ecological value at the site level.

Effects: The Proposed Development will result in the loss of this sparse re-colonising vegetation.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Prior to mitigation, effects are at the site level and not significant.

7.8.11 Amenity Grassland. The MOD land comprises short-mown amenity grassland which is managed as a sports pitch. It is species-poor and very readily re-creatable, and this habitat is therefore considered to be of negligible ecological value at the site level.

Effects: The Proposed Development will result in the loss of this area of amenity grassland.

Prior to mitigation, effects are at the site level and not significant.

7.8.12 Grassland developing over former arable land. Area 9b, Area 10, the north-eastern portion of Area 11, Area 12 and the Mixed Use land comprise grassland which has relatively recently developed over former arable land. The grassland is of recent origin, readily re-creatable, and is in general relatively species-poor (with the exception of parts of Area 10, which supports a moderate diversity of species within the more disturbed areas). Accordingly this habitat is of no more that low ecological value at the site level.

Effects: The Proposed Development will result in the permanent loss of this developing grassland.

Prior to mitigation, effects are at the site level and of minor adverse significance.

7.8.13 Scattered Scrub & Hedgerows. There are three hedgerows within or immediately adjacent to the Application Site: hedgerow H1 forms one of the boundaries to Area 9b, hedgerow H2 forms a boundary to the Mixed Use Area (albeit this is off-site), and a small section of hedgerow H3 forms one of the boundaries of the MOD land. As the hedgerows comprise over 80% native species, they meet the definition of the UK BAP Priority Habitat type ‘Hedgerows’, and are therefore considered to be of some ecological value. Hedgerow H3 in particular supports at least seven native woody species along its full length and is therefore considered to be relatively species-rich (albeit only a short stretch falls within the Application Site itself). Hedgerow H1 is dominated by just two species but incorporates a mature Beech tree. In summary, these hedgerows are considered to be of up to moderate ecological value at the site level. The scattered scrub at the fence-line forming a boundary to Area 10 and Area 12 is species poor and of low ecological interest in the context of the site.

Effects: During construction there is potential for damage to retained hedgerows from dust generation, soil compaction and incursion into hedgerow and tree root zones. Post-development, hedgerow H1 (including the mature Beech tree) and H2 will be retained as part of the Proposed Development of Area 9b and the Mixed Use Area, but that the more species-rich hedgerow H3 will be lost at least in part to the development of the MOD Land. The scattered scrub at the boundary of Area 10 and Area 12 will be partially retained within the proposed landscaping schemes.

Prior to mitigation, effects are at the site level and of moderate adverse significance.

7.8.14 Planted Row of Trees. The MOD land contains a planted row of young to semi-mature Common Lime and Norway Maple trees. These trees are non-native and of no great age, and are therefore considered to be of relatively low ecological value at the site level. Beyond Area 11 to the north is a line of trees/shrubs which contains a number of mature Beech trees.

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Effects: All of these trees are to be retained as part of the Proposed Developments. Nonetheless, during construction there is potential for damage to retained trees from dust generation, soil compaction and incursion into root zones.

Prior to mitigation, effects are at the site level and of minor adverse significance.

Effects on Protected Faunal Species

7.8.15 Badger. A small active Badger sett (likely a subsidiary sett) has been identified just outside the boundary of Area 9b. In addition, there was some limited evidence of Badger foraging/commuting activity noted within the Application Site (the field signs being predominantly recorded within Area 9b and Area 11).

Effects: During the construction phase, there is potential for damage to any tunnels/chambers which may extend from the off-site sett into the construction zone of Area 9b. The proposed layout of Area 9b shows that there will be new hard- and soft-landscaping within 10m of the sett, but it appears that the 10m buffer does not make an incursion into the footprint of any proposed buildings. In addition, there is potential for disturbance to any Badgers that may be using the sett whilst works are undertaken close by (i.e. within 20m of the sett).

There is also the possibility that potential construction site hazards could result in death or injury to a Badger. These actions could result in an offence under The Protection of Badgers Act 1992. In addition, there will also be minor losses of limited areas of Badger foraging and commuting habitats. However, Badgers are highly adaptable in their foraging behaviour and are considered unlikely to be significantly adversely affected by this minor loss.

During the operational phase, there is minor potential for increased disturbance of setts and potentially of foraging Badgers, although it is not considered that this would be significant, since Badgers have proved capable of colonising even areas of urban development. There is also potential for increased mortality within the local Badger population through increased road traffic in the vicinity of Area 9b. The effect of increased road traffic in terms of collisions with Badgers is somewhat uncertain but the limited evidence of existing usage of the Application Site by Badgers suggests that potential effects would be no more than minor.

Prior to mitigation, effects are at the local level and of moderate adverse significance.

7.8.16 Bats. In terms of potential for roosting bats, there are no buildings within the site, and furthermore there are no trees with roost potential within any part of the Application Site (albeit there are a small number of potentially suitable trees beyond the Application Site boundary). The bat activity surveys have identified that the boundary vegetation within the wider site is used by foraging/commuting bats (including the scattered scrub at the boundary of Area 10, hedgerow H2 at the boundary of the Mixed Use land, and hedgerow H3 at the boundary of the MOD land), predominantly Common and Soprano Pipistrelle. In

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

addition, there is evidence of very limited use by small numbers (or individuals) of Noctule, Myotis sp., Nathusius’ Pipistrelle, Serotine/Leisler and Barbastelle.

Effects: There will be no loss of any known or potential bat roosts during the construction or operational stages of the Proposed Development. However, there is potential during the construction phases for minor disturbance to bats commuting through or foraging within the Application Site, and for disturbance to bats which could potentially be roosting within off-site trees as indicated on Figure 7.2, through any lighting of the construction site.

In addition, post-development, there will be some minor truncation or loss of boundary vegetation, (namely the loss of hedgerow H3 within the MOD land, and the loss of scattered scrub at the boundary of Area 10), which will result in the permanent loss of minor foraging/commuting habitat for bats, with effects predominantly on Common and Soprano Pipistrelle. Furthermore, lighting associated with the operational phase has the potential to disrupt use of retained foraging/commuting routes.

Prior to mitigation, effects are at the local level and of moderate adverse significance.

7.8.17 Reptiles. No reptiles were recorded within the site as a whole during the 2005 ES survey work. The nearest known extant population of reptiles is located 1.9km from the nearest area of potentially suitable grassland habitat within the Application Site, and is separated from it by the busy A345 main road. Accordingly, given the recent and disturbed nature of the grasslands within the Application Site, it is considered that any use of the habitat (i.e. within Area 9b, Area 10, Area 11 or Area 12) would be very occasional or transient in nature, involving very low numbers or individual reptiles only.

Effects: Grassland clearance in these areas during the construction phase could result in killing or injury of very low numbers of or individual common reptiles, which could constitute an offence under the Wildlife and Countryside Act 1981 (as amended). During the operational phase, the loss of this habitat to the Proposed Development would result in the permanent loss of very limited areas of potentially suitable habitat.

Prior to mitigation, effects are at the local level and of minor adverse significance.

7.8.18 Birds. Most of the birds recorded within/adjacent to the Application Site do not have any special conservation status, although Herring Gull, House Sparrow, Lapwing and Skylark are included on the RSPB Red list, and Dunnock and House Martin are included on the RSPB Amber list. Parts of the Application Site (i.e. Area 9b, Area 10, Area 12, the MOD land and the Mixed Use land) offer limited opportunities for breeding birds (including some of those listed above), in the form of the hedgerows, and boundary scrub and trees. However, the areas of grassland within the Application Site appear to be too small in size to be suitable for ground-nesting birds such as Skylark and Lapwing.

Effects: Potential effects on birds during the construction phase largely relate to direct loss of active nests during site preparation works (which could constitute an offence under the Wildlife and Countryside Act 1981 (as amended)), and to noise

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and visual disturbance to nesting birds in close proximity to construction areas. These effects are anticipated to be highly localised, particularly in relation to nest destruction, in view of the very minor losses of nesting habitat that will result from the proposals.

During the operational phase, the loss of limited small areas of scrub, trees or hedgerows would result in the permanent loss of small areas of potential breeding habitat for common species. Increased levels of predation of birds, particularly nesting birds, is considered likely due to increased numbers of domestic cats anticipated to be present within the Proposed Developments compared with the current situation. Conversely, domestic gardens are likely to provide increased foraging opportunities and possibly nesting opportunities for a range of common and widespread species.

Prior to mitigation, effects are at the local level and of minor adverse significance.

7.8.19 Other Protected Faunal Species. On the basis of the survey work conducted, the ecological assessment considered that it is extremely unlikely that other protected species such as Dormouse, Otter, Water Vole or Great Crested Newt are present within or adjacent to the Application Site.

Effects: No direct or indirect effects anticipated on these or any other protected species as a result of the Proposed Development.

Prior to mitigation, effects are at the site level and not significant.

Effects on Other Faunal Species

7.8.20 Other Mammals. Other mammal species identified within the Application Site include deer, Rabbit, Fox and Short-tailed Field Vole, and it is likely that other small mammals (such as Brown Rat and Wood Mouse) are also present. It is considered that the Application Site is not likely to be of value to Brown Hare, but there is some limited scope for Hedgehog (a UK BAP Priority Species) to use the site for foraging.

Effects: The Proposed Development will result in disturbance and loss of habitat for common species, particularly during the construction phase. However, the post- development network of gardens will be of enhanced value to a number of these species (particularly Fox, Hedgehog and a range of small mammals), and although these species will be displaced during the construction period, the majority will re-colonise following the completion of the proposals.

Prior to mitigation, effects are at the local level and not significant.

7.8.21 Invertebrates. The invertebrates recorded within the Application Site are common in nature with no rare or notable species identified. Furthermore, none of the species identified within the wider area as part of the data search are considered likely to be present within the Application Site themselves. Although the common invertebrate species present will be displaced during the construction period, many of these are expected to re-colonise following completion of the Proposed Development.

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Effects: The Proposed Development will result in loss of habitat for common species, particularly during the construction phase.

Prior to mitigation, effects are at the site level and of minor adverse significance.

7.9 Mitigation and Enhancement

7.9.1 Where practicable, likely significant adverse effects identified in the previous section needs to be accounted for in terms of a mitigation strategy and through the measures incorporated within the Proposed Development. The following section describes the mitigation prescribed and how it will be implemented. It then goes on to assess the likely consequences of implementing the proposed mitigation, in terms of reduction in the likely scale of effect, along with the degree of significance post-mitigation by way of indication of likely residual effects.

Statutory Ecological Designations: Mitigation & Enhancement

7.9.2 River Avon SAC. The River Avon SAC is designated for its high quality habitat and five Annex II species. It is located approximately 1.2km from the Application Site and is particularly vulnerable to the effects of pollution.

Mitigation: Construction Environmental Management Plan (CEMP). No significant effects of construction activities are predicted. Nonetheless, in compliance with Core Policy 20 of the South Wiltshire Core Strategy, a CEMP will be prepared, which will include a range of environmental protection measures such as minimisation of dust production, and avoidance of fuel/chemical spills which could contaminate groundwater flowing into the SAC.

Developer Contribution to Nutrient Management Plan. During the operational phase, there is potential for effects upon the River Avon SAC via elevated phosphate levels (P) from additional discharges from the local sewage treatment works, resulting in excessive algal growth within the River. Core Policy 20 of the South Wiltshire Core Strategy states that new development must “not cause detriment to watercourses through the unmitigated addition of phosphates to local watercourses”; and Core Policy 69 of the Wiltshire Core Strategy Pre- submission document states that “Where additional sewage discharges to a STW [Sewage Treatment Works] cannot be accommodated without measures to offset phosphate loading, development will be required to undertake proportionate mitigation measures to demonstrate that the proposals would have no likely significant effects upon the SAC.”

The HRA for the Wiltshire Core Strategy sets out that “following the completion of significant upgrades to the sewage treatment infrastructure last year, the Environment Agency has concluded that sewage discharges projected by the Core Strategy will be compliant with the Habitats Regulations, provided that a Nutrient Management Plan (NMP) is put in place to bring down phosphate levels.

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The Environment Agency and Natural England are currently working on the Nutrient Management Plan. The plan will identify works that are required to reduce river phosphate levels and the funding required for these. At that stage it will be appropriate for Wiltshire Council to consider whether it is appropriate for development to contribute to the implementation of the plan.”

As set out at paragraph 7.4.2 above, Wiltshire Council has considered whether it is appropriate for the Proposed Developments to contribute to the implementation of the plan and concludes that “Currently the authority is not collecting developer contributions towards a phosphate management plan for the River Avon because we believe mitigation for phosphate contributed by all development contained in the Core Strategy has already been delivered through upgrades to sewage treatment works”.

Furthermore, given that the relevant waste water treatment works (Petersfinger STW) already has sufficient capacity to avoid potential impacts on the SAC, effects from phosphate discharges are not considered to be a potential issue, and as such there is no need for the Proposed Development to provide mitigation in this respect.

CSH Level 3 Water Efficiency. During the operational phase, there is potential for effects upon the River Avon SAC through increased water abstraction. In order to comply with Core Policy 19 of the South Wiltshire Core Strategy, residential developments will incorporate water efficiency measures to a minimum standard equivalent to Level 3 of the Code for Sustainable Homes (CSH).

The above measures (in compliance with Core Policies 19, 20 and 69) will ensure that the water quality, and consequently the interest features, of the River Avon SAC are maintained.

Appendix 2 and 3 of Wiltshire Council’s ‘River Avon SAC Procedure: Test of Likely Significance’ document have been completed and presented at Appendix 7.4. When all the above factors are considered as part of the Test of Likely Significance, it can be concluded that, after mitigation, the Proposed Development is not expected to give rise to a likely significant effect under any of the criteria (1-7), and accordingly, no further assessment is required.

Following mitigation, effects are at the international level and not significant.

7.9.3 Salisbury Plain SPA. This designation is located at a distance of approximately 8.0km from the Application Site, and is designated for the internationally important breeding population of Stone Curlew, together with internationally important numbers of wintering Hen Harrier. Research shows that nesting

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Stone Curlew are vulnerable to disturbance by dog walkers, and that this may increase as a result of residential development within 15km from the SPA.

Mitigation: Wessex Stone Curlew Project (WSTP) contribution. Core Policy 50 of the Wiltshire Core Strategy Pre-submission Document states that “Development likely to increase recreational pressure on Special Protection Areas (SPAs) will be required to deliver an appropriate level of mitigation to offset any potential impacts.” It then goes on to set out that for development within 15km of the Salisbury Plain SPA this will best be achieved through the Wessex Stone Curlew Project (WSCP), which delivers targeted advice to the Ministry of Defence and private tenants on the location and management of Stone Curlew nest sites.

In view of the location of the Application Site 8.0km from a part of the SPA open to public access, it is considered that the Proposed Development would potentially result in increased recreational access to the SPA and associated disturbance of breeding Stone Curlew, a European interest feature of the designation. While this would not be significant in isolation, cumulatively with other development proposed within the South Wiltshire Core Strategy, a significant adverse effect is predicted.

The basis for the WSCP developer contribution is set out in a draft paper entitled ‘Evidence Base for Developer Contributions to Deliver Mitigation Measures for Development around Salisbury Plain SPA’ prepared by Wiltshire Council. This paper proposed that, within the identified 15km ‘zone of influence’ of the SPA, a tariff would be placed upon new dwellings, at two rates dependent on the distance of the development from the SPA. For new dwellings within 4 – 15km of the SPA, in which zone the Proposed Development would be located, the proposed tariff is £9.97 per dwelling. The funds raised would be used to fund the continuation of the Wessex Stone Curlew Project, which would monitor nesting attempts and provide management advice to land managers. While this proposal has yet to be formally agreed by all relevant parties, it provides a strategic and pragmatic solution to this issue. As such, subject to its formal adoption if required, the Proposed Development could contribute at the appropriate level.

It is considered that this developer contribution to the Wessex Stone Curlew Project would adequately mitigate any adverse effect on Stone Curlew that could potentially occur through increased recreational pressure on the designation from the Proposed Development. Therefore, by contributing to this project it is considered that there will be no residual significant effect on the designation.

Following mitigation, effects are at the international level and not significant.

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7.9.4 Other Statutory Designations: No likely significant effects of the Proposed Development have been identified in respect of any other statutory designations.

Non-statutory Ecological Designations: Mitigation & Enhancement

7.9.5 Winterbourne Earls Meadow CWS & Old Sarum CWS. Minor recreational effects on the ‘Winterbourne Earls Meadow’ CWS (a former water meadow located approximately 1.1km to the east) and the ‘Old Sarum’ CWS (a chalk grassland located approximately 1.2km to the south-west) have been identified as potentially resulting from the Proposed Developments.

Mitigation: Mitigation for potentially damaging levels of recreational access to these CWS designations will be achieved through the creation of areas of public open space adjacent to the Proposed Development, which will include areas of high quality semi-natural greenspace. The creation of this green infrastructure, together with a network of pedestrian and cycle routes will encourage public use of semi- natural greenspace within the Proposed Development, thus effectively mitigating potential effects on the Winterbourne Earls Meadow’ and ‘Old Sarum’ CWSs, as well as other non-statutory designations in the vicinity.

Following mitigation, effects are at the county level and not significant.

Habitats & Ecological Features: Mitigation & Enhancement

7.9.6 Hard-standing & re-colonising vegetation. The Proposed Development will result in the loss of sparse re-colonising vegetation within Area 9a and the south-western portion of Area 11, which is considered to be of negligible ecological value at the site level.

Mitigation: No mitigation is required, but it is anticipated that new re-colonising vegetation will develop within the Application Site post-development in any case.

Following development, effects are at the site level and of neutral significance.

7.9.7 Amenity Grassland. The Proposed Developments will result in the loss of short-mown amenity grassland within the MOD land, which is considered to be of negligible ecological value.

Mitigation: No mitigation is required, but new amenity grassland will nonetheless be provided as part of the Proposed Development of this area.

Following development, effects are at the site level and of neutral significance.

7.9.8 Grassland developing over former arable land. The Proposed Development will result in the permanent loss of grassland which has relatively recently developed over former arable land (within Area 9b, Area 10, Area 11, Area 12 and the Mixed Use land), which is of no more than low ecological value at the site level.

Mitigation: Whilst it is not considered necessary to provide mitigation within the Proposed Development of the Application Site, it is understood that an area of more established semi-improved grassland has been retained within the wider site, and this will be managed according to ecological principles (i.e. annual mowing in

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late summer once wildflowers have set seed, and removal of the grass cuttings from the grassland itself) in order to maximise its potential ecological value.

Following mitigation and enhancement, effects are at the site level and of neutral significance.

7.9.9 Scattered Scrub & Hedgerows. During construction there is potential for damage to retained hedgerows from dust generation, soil compaction and incursion into hedgerow and tree root zones. Post- development, it appears that hedgerows H1 and H2 will be retained, but that the more species-rich hedgerow H3 will be lost entirely to the development of the MOD Land. The scattered scrub at the boundary of Area 10 and Area 12 is partially retained.

Mitigation: Hedgerows and scrub will be retained where possible, and there will be provision of new native trees and shrubs as part of the landscape planting scheme for the Application Site. Standard mitigation measures will be put in place during the construction phase, including damping down potential dust sources, and the retained hedgerows will be protected using standard tree protection fencing (in accordance with BS 5837:2012).

Following mitigation and enhancement, effects are at the site level and not significant.

7.9.10 Row of Trees. The MOD land contains a planted row of young to semi-mature Common Lime and Norway Maple trees, which are considered to be of low ecological value. In addition, there is a mature line of trees/shrubs Beyond Area 11 to the north, which is of higher relative value. Both features could be damaged during construction by dust generation, soil compaction and incursion into root zones.

Mitigation: Standard mitigation measures will be put in place during the construction phase, including damping down potential dust sources; and these trees will be retained and protected (using standard tree protection fencing in accordance with BS 5837:2012) as part of the overall landscape scheme. In addition, there will be provision of new native trees as part of the landscape planting scheme for the Application Site.

Following mitigation and enhancement, effects are at the site level and of moderate beneficial significance.

Protected Faunal Species

7.9.11 Badger. There are no Badger setts within the development footprint of the Application Site. However, there is an off-site sett located approximately 2m from the boundary of Area 9b that may incorporate tunnels/chambers which extend a short distance under the site. The proposed layout of Area 9b shows that there will be new hard- and soft-landscaping within 10m of the sett, but it appears that the 10m buffer does not make an incursion into the footprint of any proposed buildings.

Mitigation: In the event that the any built form / hard-landscaping is within a 10m radius of the active entrance, then the sett will be fenced off and may be subject to a licenced exclusion exercise to ensure that Badgers are safeguarded during the adjacent construction works. In a worst-case scenario, this would result in the permanent loss of a small subsidiary sett.

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Furthermore, as there is a possibility that Badgers may enter the construction areas, a range of general construction site safeguards for Badger will be followed during the construction process including:

• All contractors will be briefed as to the possible presence of Badgers within the Application Site, with particular reference to the implications of legislation and licensing;

• Any trenches or deep pits within the Application Site that are to be left open overnight will be provided with a means of escape should a Badger enter. This could simply be in the form of a roughened plank of wood placed in the trench as a ramp to the surface. This is particularly important if the trench fills with water;

• Any trenches/pits will be inspected each morning to ensure no Badgers have become trapped overnight. Should a Badger become trapped in a trench it will likely attempt to dig itself into the side of the trench, forming a temporary sett. Should a trapped Badger be encountered a suitably qualified ecologist will be contacted immediately for further advice;

• The storage of topsoil or other ‘soft’ building materials in the Application Site will be given careful consideration. Badgers will readily adopt such mounds as setts. So as to avoid the adoption of any mounds, these will be kept to a minimum and any essential mounds subject to daily inspections with consideration given to temporarily fencing any such mounds to exclude Badgers;

• The storage of any chemicals at the Application Site will be contained in such a way that they cannot be accessed or knocked over by any roaming Badgers;

• No fires will be permitted on site; and

• Food and litter will not be left within the working area overnight.

In terms of operational effects, there is the potential for increased mortality from Road Traffic Accidents (RTAs) due to increased traffic levels associated with the Proposed Developments. However, provision of new areas of landscape planting with fruit bearing species should increase local foraging opportunities for Badger, thereby reducing the need for individuals to cross the main Portway road. Traffic speeds will be low within residential areas and the structural planting will in any event encourage Badgers to keep to the periphery of the development, minimising contact with roads.

Following mitigation and enhancement, effects are at the local level and of minor adverse significance.

7.9.12 Bats. No bat roosts or potential roosts have been identified within the site. The bat activity surveys have identified that the boundary vegetation which forms part of the Application Site is used by foraging/commuting bats, predominantly Common and Soprano Pipistrelle, as well as very occasional use by less common bats. Minor truncation / loss of this boundary vegetation will result in the permanent loss

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

of foraging/commuting habitat for bats. In addition, there is potential during the construction phases for minor disturbance to bats commuting through / foraging within the Application Site, and for minor disturbance to bats which could potentially be roosting within off-site trees through the lighting of the construction site. Furthermore, lighting associated with the operational phase may disrupt use of retained foraging/commuting routes.

Mitigation: The provision of new landscape planting will strengthen potential commuting routes and provides linkages to other linear features within the site to produce a more effective network of routes for bats to follow. To reduce the potential effects of any lighting within the construction zone, the lighting will be positioned and directed so as to minimise light spill on to potential bat foraging/commuting features such as hedgerows and tree lines. The amount of lighting used overall will be kept to the minimum required, and where practicable any night-time works will be minimised during periods of darkness, when bats might be expected to be active (i.e. after sunset during the core active season of April/May – August/September).

Mitigation of adverse effects from permanent lighting during the operational phase will be achieved by careful design to, as far as possible, avoid light spill on features likely to be of value to commuting, foraging or roosting bats. In addition, a number of bat roost features will be incorporated into the Proposed Development in the form of bat boxes within the retained line of trees/shrubs to the north of Area 11. These will also serve to contribute towards the aims of the Wiltshire Bat BAP, which covers all the species of bat present within the county.

Following mitigation and enhancement, effects are at the local level and of neutral significance.

7.9.13 Reptiles. No reptiles were recorded within the site as a whole during the 2005 ES survey work, and given the recent and disturbed nature of the grasslands within the Application Site, it is considered that any use of the habitat (i.e. within Area 9b, Area 10, Area 11 or Area 12) would be very occasional or transient in nature, involving very low numbers or individual reptiles only.

Mitigation: Proportional mitigation would take the form of a habitat manipulation exercise, whereby potentially suitable habitat within the Application Site would be subject to a programme of controlled strimming to a height of 100mm, under supervision from a suitably qualified ecologist, and the arisings then carefully raked off. These areas should be left for 24 hours to allow any reptiles that may be present to disperse into suitable off-site habitat, after which ground clearance will commence under a watching brief for reptiles. This will safeguard reptiles from killing and injury, and will ensure that the local reptile conservation status is maintained.

In the longer term, as the residential gardens that form part of the Proposed Development become more established, these will provide replacement opportunities for reptiles. In addition, the grass cuttings taken from the retained

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

line of trees/shrubs to the north of Area 11 will be placed in piles at the base of the boundary vegetation here to create potential reptile shelter opportunities with a south-facing aspect.

Following mitigation and enhancement, effects are at the local level and of neutral significance.

7.9.14 Birds. Potential effects during the construction phase are considered to relate primarily to the direct loss of active nests during site preparation works and to noise and visual disturbance to nesting birds in close proximity to construction areas.

Mitigation: The potential loss of active nests during construction will be mitigated by either undertaking clearance of potential bird nesting habitat, including areas of arable land, outside the bird nesting season (March to August inclusive) or, if necessary, preceding any clearance by an inspection by a professional Ecologist. Any nests found will be cordoned off and protected until they cease to be active. Disturbance from noise will be minimised by the adoption of good working practice, such as noise-reducing construction measures.

7.9.15 Adverse effects during the operational phase comprise the loss of small areas of potential breeding habitat for common species (in the form of scrub and hedgerows), and increased levels of predation due to increased numbers of domestic cats.

Mitigation: Mitigation will be provided by the extensive habitat creation, including new landscape planting. In addition, the provision of bird nesting boxes within the Proposed Development will provide increased nesting opportunities for a range of common species. In addition to generic bird boxes suitable for a range of species, specific bird boxes such as the Schwegler 1SP Sparrow Terrace and 3S Starling Nest Box will be used to provide opportunities for the UK BAP species House Sparrow and Starling.

Following mitigation and enhancements, effects are at the local level and of minor beneficial significance.

Other Faunal Species: Mitigation & Enhancement

7.9.16 Other Mammals. No significant effects on other mammals have been identified and no specific mitigation measures are proposed. Nonetheless, new landscape planting will create new habitats for a variety of species.

Following enhancements, effects are at the site level and of minor beneficial significance.

7.9.17 Invertebrates. No significant effects on invertebrates have been identified and no specific mitigation measures are proposed. Nonetheless, the habitat creation measures associated with the Proposed Development will significantly enhance opportunities for invertebrates.

Following enhancements, effects are at the site level and not significant.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.9.18 Summary. Overall, the Proposed Development seeks to ensure that the majority of habitats of interest in nature conservation terms, most notably the hedgerows and trees, are retained and enhanced. Where protected species are present, these are safeguarded. The Proposed Development plans include a number of habitat enhancement and creation opportunities that will lead to gains, particularly in terms of furthering the aims and objectives of the Wiltshire and UK Biodiversity Action Plans.

Overall, effects are at the local level and are of negligible beneficial significance.

7.10 Cumulative Effects

7.10.1 A number of other committed developments have been identified within the vicinity of the Application Site, which have been considered in terms of potential for cumulative or interactive effects, as identified within the EIA scoping process. These include existing mixed use (but predominantly residential) development within the wider Old Sarum site to the north of the Portway road. A further development, known as Longhedge and comprising 450 homes and 8ha employment, has been allocated on land immediately adjoining the wider site to the north.

7.10.2 Cumulative effects with regard to European level ecological designations, namely the River Avon SAC, Salisbury Plain SPA and New Forest SAC/SPA, have been considered within the sections above. In respect of the New Forest designations it was concluded that there would be no significant effect, alone or in combination with other developments, while for the River Avon SAC and Salisbury Plain SPA it is considered that, following mitigation, there are no residual significant effects. Therefore it is concluded in respect of European designations that the Proposed Development in combination with other permitted developments are unlikely to give rise to significant adverse effects.

7.10.3 There is potential for local non-statutory ecological designations within the vicinity of the Application Site to be affected by cumulative increases in recreational use. However, the provision of alternative public open greenspace, within the Proposed Development and the adjacent Longhedge site, will mitigate to a degree any adverse effects of increased recreational usage, while the ‘Old Sarum’ CWS designation is in any event considered relatively robust in terms of recreational effects. Accordingly, it is considered that there will be no significant, adverse ‘in-combination’ effects resulting from the Proposed Development on national or local ecological designations.

7.10.4 The habitats at Longhedge are dominated by intensively cultivated arable fields, which are considered unlikely to be of particular ecological value. Other habitats recorded within the site include hedgerows, a number of trees, and a very small area of rank unimproved grassland, which are likely to offer some limited ecological value in the context of the site. The majority of these features are retained and protected under the proposals for the Longhedge site, with new planting, including native species, along with incorporation of SUDS, will provide new habitat and maximise opportunities for biodiversity within the adjacent site. As such, it is therefore considered unlikely that habitats or faunal species of value within the Application Site would be affected by cumulative or interactive effects with other developments.

7.11 Summary

7.11.1 Overall, the Application Site is considered to be of no more than low ecological value at the local level. Effects of new residential development on ecologically designated sites are mitigated by compliance with key planning policies and by the creation of a new network of publically accessible greenspace. Minor effects of the Proposed Development on habitats and fauna are compensated by habitat creation works within this green infrastructure. No adverse residual or cumulative effects are identified. In relation to habitats and species within the Application Site, it is considered that the Proposed Development would bring forward ecological enhancements including a number that would contribute to UK Biodiversity Action plans.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

7.12 Glossary

Biodiversity Action Plan (BAP) Action plans detailing provisions to aid the recovery of threatened species and habitats within the UK County Wildlife Site (CWS) Selected by the local authority as being of county importance to wildlife and conservation. These sites receive no statutory protection. Local Nature Reserve (LNR) Protected under the National Parks and Countryside Act 1949 and aimed at conserving nature with opportunities for research and education. Special Area of Conservation (SAC) European protected sites designated under the EC Habitats Directive aimed at conserving the habitats and species listed under Annex I and II of the directive.

Special Protection Area (SPA) European protected sites designated under Article 4 of the EC Birds Directive aimed at conserving rare and vulnerable birds listed on Annex I of the directive.

Site of Special Scientific Interest (SSSI) Sites which receive statutory protection under the Wildlife and Countryside Act 1981(as amended) and provide the best examples of the UK's flora and fauna.

Ramsar site Wetlands of international importance, designated under the Ramsar Convention in 1971. Phase I Survey A type of survey used to identify habitats and ecological features within a site. Phase II Survey More comprehensive survey type which focuses on a particular species or group of species in greater detail. Species of Principal Importance Species listed under Section 41 of the Natural Environment and Rural Communities (NERC) act (2006) which are of Principal Importance to Nature Conservation within the UK.

UK Red List of Birds of Conservation Concern Bird species which are considered to be of the highest conservation concern under RSPB criteria. Ecological Designations Sites designated as meeting specific criteria that aim to identify areas of particular ecological interest.

CIR.P.0625 Old Sarum Additional Housing ES 2012 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Figure 7.1

Ecological Designations

CIR.P.0625 Old Sarum Additional Housing ES 2012 SALISBURY PLAIN SPA/SAC/SSSI (ACCESSIBLE AREA) 8.0km NORTH OF SITE

PORTON MEADOWS SSSI

RIVER AVON SYSTEM FIELDS SSSI

RIVER AVON SAC, RIVER AVON SYSTEM SSSI

PORTON DOWN SPA/SSSI NORTH HILL DOWN LWS FIGSBURY RING SSSI

BRACKNELL CROFT SSSI CAMP DOWN SSSI OLD SARUM LWS

SALISBURY PLAIN SAC BISHOPDOWN LWS

AVON VALLEY LNR

COCKEY DOWN SSSI

RIVER AVON SYSTEM FIELDS SSSI

NEW FOREST SAC/SSSI 14.4km SOUTH OF SITE & SPA/RAMSAR 15.1km SOUTE OF SITE

KEY: OVERALL SITE BOUNDARY (”THE WIDER SITE”)

APPLICATION SITE BOUNDARIES Aspect Ecology Limited - West Court - Hardwick Business Park Noral Way - Banbury - Oxfordshire - OX16 2AF 01295 276066 - [email protected] - www.aspect-ecology.com SPECIAL PROTECTION AREA (SPA)

SPECIAL AREA OF CONSERVATION (SAC) OLD SARUM II, SALISBURY, PROJECT WILTSHIRE SITE OF SPECIAL SCIENTIFIC INTEREST (SSSI) ECOLOGICAL DESIGNATIONS TITLE LOCAL NATURE RESERVE (LNR)

DRAWING LOCAL WILDLIFE SITE (LWS) FIGURE 7.1 NO. N A REV. DECEMBER 2012 DATE

Based upon the Ordnance Survey map with permission of the Controller of Her Majesty’s Stationery Office, © Crown Copyright. Aspect Ecology Ltd, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, OX16 2AF. Licence No. 100045262 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Figure 7.2

Habitats and Ecological Designations

CIR.P.0625 Old Sarum Additional Housing ES 2012 KEY: OVERALL SITE BOUNDARY H4 (“THE WIDER SITE”) L BADGER SETT COMPRISING ONE ACTIVE ENTRANCE, APPLICATION SITE BOUNDARIES S TWO INACTIVE AND TWO DISUSED RECOLONISING VEGETATION OVER HARDSTANDING/RUBBLE GRASSLAND DEVELOPING OVER AREA 7.2 H1 FORMER ARABLE LAND 9b SHORT-MOWN AMENITY AREA GRASSLAND 11 X X X X SCRUB 7.5 XX AREA XX 9a X HEDGEROW X AREA X 12 X TREE 7.6 7.1 TREE WITH BAT POTENTIAL CATEGORY 2a - HIGH POTENTIAL TREE WITH BAT POTENTIAL CATEGORY 2b - MODERATE TO LOW POTENTIAL 7.8 S BADGER SETT XX L BADGER LATRINE 7.4 X AREA X 10 7.3 XX 10m RADIUS FROM SETT X MOD XX LAND 20m RADIUS FROM SETT

H3 1 PHOTOGRAPH LOCATION

H2

7.7

MIXED USE

OLD SARUM II, SALISBURY, PROJECT WILTSHIRE

HABITATS AND ECOLOGICAL TITLE FEATURES

DRAWING FIGURE 7.2 NO.

A REV. N DECEMBER 2012 DATE

Aspect Ecology Limited - West Court - Hardwick Business Park Noral Way - Banbury - Oxfordshire - OX16 2AF 01295 276066 - [email protected] - www.aspect-ecology.com

Based upon the Ordnance Survey map with permission of the Controller of Her Majesty’s Stationery Office, © Crown Copyright. Aspect Ecology Ltd, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, OX16 2AF. Licence No. 100045262 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Figure 7.3

Bat Activity Summary

CIR.P.0625 Old Sarum Additional Housing ES 2012 KEY: OVERALL SITE BOUNDARY H4 (“THE WIDER SITE”) APPLICATION SITE BOUNDARIES 30 RECOLONISING VEGETATION OVER HARDSTANDING/RUBBLE 25 GRASSLAND DEVELOPING OVER FORMER ARABLE LAND 20 AREA 7.2 H1 SHORT-MOWN AMENITY 9b GRASSLAND 15 AREA X SCRUB 11 X X 10 X HEDGEROW 7.5 XX AREA XX 5 9a X TREE X AREA X TREE WITH BAT ROOST POTENTIAL 0 12 X 7.6 CATEGORY 2a - HIGH Average Number of Passes per Night Common Soprano Noctule Nathusius 7.1 TREE WITH BAT ROOST POTENTIAL Pipistrelle Pipistrelle Pipistrelle CATEGORY 2b - MODERATE-LOW Species Recorded STATIC DETECTOR LOCATION

Static detector position: “MOD land” 1 PHOTOGRAPH LOCATION 7.8

XX

AREA 7.4 X 10 X 7.3 XX XX MOD X LAND Bat Activity Index* Static detector position: “Area 10” 0 H3 1 - 20 12 21 - 40 10

8 41 - 60

H2 6 * Bat Activity Index - Average number of bat passes

4 7.7

MIXED 2 USE Average Number of Passes per Night

0 Common Soprano Barbastelle Noctule Myotis Serotine/Leisler OLD SARUM II, SALISBURY, PROJECT Pipistrelle Pipistrelle Static detector position: “Mixed Use land” Species Recorded WILTSHIRE

BAT ACTIVITY SUMMARY TITLE 6

5 DRAWING FIGURE 7.3 NO. 4 A REV.

3 N DECEMBER 2012 DATE

2 Aspect Ecology Limited - West Court - Hardwick Business Park Noral Way - Banbury - Oxfordshire - OX16 2AF 01295 276066 - [email protected] - www.aspect-ecology.com 1 Average Number of Passes per Night

0 Common Pipistrelle Soprano Pipistrelle Species Recorded

Based upon the Ordnance Survey map with permission of the Controller of Her Majesty’s Stationery Office, © Crown Copyright. Aspect Ecology Ltd, West Court, Hardwick Business Park, Noral Way, Banbury, Oxfordshire, OX16 2AF. Licence No. 100045262 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Appendix 7.1

Data Search Results

CIR.P.0625 Old Sarum Additional Housing ES 2012 Statutory Designations - Local

© Crown Copyright and database right 2012. Ordnance Survey Licence number 100022021. © Crown copyright. Licence number 100022432. © Natural England 2012. This page was produced from the Nature on the Map website at 17/08/2012 11:35:24 Statutory Designations - National

© Crown Copyright and database right 2012. Ordnance Survey Licence number 100022021. © Crown copyright. Licence number 100022432. © Natural England 2012. This page was produced from the Nature on the Map website at 17/08/2012 11:31:39 Statutory Designations - European

© Crown Copyright and database right 2012. Ordnance Survey Licence number 100022021. © Crown copyright. Licence number 100022432. © Natural England 2012. This page was produced from the Nature on the Map website at 17/08/2012 11:34:09 ECO 3001 Designated Sites ECO3001 Inernational Designations Site Check Report Report generated on July 12 2012.

You clicked on the point: Grid Ref: SU150338 Full Grid Ref: 415000 , 133800

The following features have been found within 5,000 metres of your search point:

Counties, Metropolitan Districts and Unitary Authorities (GB) Name Geographic Level WILTSHIRE UNITARY AUTHORITY

NUTS1 - Government Office Regions (GB) Name Reference Hotlink SOUTH WEST UKK http://www.ons.gov.uk/ons/guide-method/geography/beginner-s-guide/european/south-west/index.html

Ancient Woodland (England) Grid Reference Wood Name Theme ID Theme Name su192311 CLARENDON PARK COPSES 1110697 ANCIENT & SEMI-NATURAL WOODLAND su190306 CLARENDON PARK COPSES 1110697 ANCIENT & SEMI-NATURAL WOODLAND su196313 CLARENDON PARK COPSES 1110697 ANCIENT & SEMI-NATURAL WOODLAND su186304 CLARENDON PARK COPSES 1110697 ANCIENT & SEMI-NATURAL WOODLAND su185299 CLARENDON PARK COPSES 1110697 ANCIENT REPLANTED WOODLAND su197303 CLARENDON PARK COPSES 1110697 ANCIENT REPLANTED WOODLAND su139388 THE TERRACE WOOD 1110696 ANCIENT & SEMI-NATURAL WOODLAND

Local Nature Reserves (England) Reference Name 1084812 BEMERTON HEATH & BARNARD'S FOLLY 1008753 AVON VALLEY

National Nature Reserves (England) There are no features within your search area.

Ramsar Sites (England) There are no features within your search area.

Special Protection Areas (England) Reference Name UK9011101 PORTON DOWN

Special Areas of Conservation (England) Reference Name UK0013016 RIVER AVON UK0012683 SALISBURY PLAIN

Sites of Special Scientific Interest Units (England) Reference Name Citation Site Unit Condition 1070071 PORTON MEADOWS 1028186 UNFAVOURABLE RECOVERING 1070194 FIGSBURY RING 1008032 FAVOURABLE 1070075 PORTON MEADOWS 1007924 FAVOURABLE 1070493 RIVER AVON SYSTEM 1025246 UNFAVOURABLE NO CHANGE 1070464 EAST HARNHAM MEADOWS 1015659 UNFAVOURABLE RECOVERING 1082452 RIVER AVON SYSTEM 1027049 UNFAVOURABLE DECLINING 1070247 LOWER WOODFORD WATER MEADOWS 1008009 FAVOURABLE 1084660 RIVER AVON SYSTEM 1028722 FAVOURABLE 1070076 PORTON MEADOWS 1007919 UNFAVOURABLE RECOVERING 1070270 BRACKNELL CROFT 1008200 FAVOURABLE 1070167 COCKEY DOWN 1008166 FAVOURABLE 1070465 EAST HARNHAM MEADOWS 1016681 UNFAVOURABLE RECOVERING 1070072 PORTON MEADOWS 1028187 UNFAVOURABLE RECOVERING 1070490 RIVER AVON SYSTEM 1027036 UNFAVOURABLE DECLINING 1070248 LOWER WOODFORD WATER MEADOWS 1008010 FAVOURABLE 1070250 LOWER WOODFORD WATER MEADOWS 1018329 UNFAVOURABLE RECOVERING 1070062 PORTON DOWN 1025962 UNFAVOURABLE RECOVERING 1070146 CAMP DOWN 1008118 UNFAVOURABLE RECOVERING 1084662 RIVER AVON SYSTEM 1028724 UNFAVOURABLE RECOVERING 1070489 RIVER AVON SYSTEM 1025236 UNFAVOURABLE RECOVERING 1070073 PORTON MEADOWS 1007940 UNFAVOURABLE RECOVERING 1070078 PORTON MEADOWS 1007920 UNFAVOURABLE DECLINING 1070168 COCKEY DOWN 1020832 UNFAVOURABLE RECOVERING 1070271 BRACKNELL CROFT 1023941 UNFAVOURABLE NO CHANGE 1070069 PORTON MEADOWS 1007916 UNFAVOURABLE NO CHANGE 1070473 RIVER AVON SYSTEM 1025261 UNFAVOURABLE NO CHANGE 1084661 RIVER AVON SYSTEM 1028723 UNFAVOURABLE RECOVERING 1070503 RIVER AVON SYSTEM 1025265 UNFAVOURABLE NO CHANGE 1070501 RIVER AVON SYSTEM 1025259 UNFAVOURABLE NO CHANGE 1070491 RIVER AVON SYSTEM 1016395 UNFAVOURABLE NO CHANGE 1070467 EAST HARNHAM MEADOWS 1015662 UNFAVOURABLE NO CHANGE 1070079 PORTON MEADOWS 1007917 UNFAVOURABLE RECOVERING 1084658 RIVER AVON SYSTEM 1028720 UNFAVOURABLE RECOVERING 1070074 PORTON MEADOWS 1007939 UNFAVOURABLE DECLINING 1070498 RIVER AVON SYSTEM 1025253 UNFAVOURABLE NO CHANGE 1084659 RIVER AVON SYSTEM 1028721 FAVOURABLE

Sites of Special Scientific Interest (England) Reference Name Citation 1000674 PORTON MEADOWS 1003914 1000833 CAMP DOWN 1002448 1000658 PORTON DOWN 1003140 1000848 FIGSBURY RING 1003480 1006597 RIVER AVON SYSTEM 2000183 1000842 COCKEY DOWN 1003265 1000879 BRACKNELL CROFT 1001857 1006203 EAST HARNHAM MEADOWS 2000175 1000869 LOWER WOODFORD WATER MEADOWS 1000015

To save the report, select "Save" or "Save As" from the File menu. You should save the file with a .html extension and give it a name of your choice. You can then open your report using your web browser software.

Print Report | Close Window Site Check Report Report generated on July 12 2012.

You clicked on the point: Grid Ref: SU150338 Full Grid Ref: 415000 , 133800

The following features have been found within 20,000 metres of your search point:

Counties, Metropolitan Districts and Unitary Authorities (GB) Name Geographic Level WILTSHIRE UNITARY AUTHORITY DORSET COUNTY COUNTY

NUTS1 - Government Office Regions (GB) Name Reference Hotlink SOUTH EAST UKJ http://www.ons.gov.uk/ons/guide-method/geography/beginner-s-guide/european/south-east/index.html SOUTH WEST UKK http://www.ons.gov.uk/ons/guide-method/geography/beginner-s-guide/european/south-west/index.html

Special Areas of Conservation (England) Reference Name UK0013016 RIVER AVON UK0012683 SALISBURY PLAIN UK0012770 UK0016373 UK0030334 UK0012553 UK0012557 THE NEW FOREST

Special Protection Areas (England) Reference Name UK9011031 NEW FOREST UK9011102 SALISBURY PLAIN UK9011101 PORTON DOWN

To save the report, select "Save" or "Save As" from the File menu. You should save the file with a .html extension and give it a name of your choice. You can then open your report using your web browser software.

Print Report | Close Window ECO3001 Priority Habitats

© Crown Copyright and database right 2012. Ordnance Survey Licence number 100022021. © Crown copyright. Licence number 100022432. © Natural England 2012. This page was produced from the Nature on the Map website at 12/07/2012 11:07:45 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Appendix 7.2

Summary of Raw Bat Data

CIR.P.0625 Old Sarum Additional Housing ES 2012 Table 1: Summary of Bat Activity Recorded at Area 10 Common Soprano Noctule Serotine/ Barbastelle Myotis Pipistrelle Pipistrelle Leisler 06.09.2012 3920 20 07.09.2012 11 8 1 0 0 1 08.09.2012 12 10 3 0 1 0 09.09.2012 33 23 1 1 1 1

Area 10 10.09.2012 7 13 0 0 5 1 11.09.2012 6910 30 12.09.2012 1010 00

Table 2: Summary of Bat Activity Recorded at the MOD land Common Soprano Nathusius Noctule Pipistrelle Pipistrelle Pipistrelle

06.09.2012 36 33 0 5 07.09.2012 18 30 0 1 08.09.2012 26 21 0 2 09.09.2012 37 35 0 1 10.09.2012 49 11 0 0 MOD land 11.09.2012 11 5 1 1 12.09.2012 5200

Table 3: Summary of Bat Activity Recorded at the Mixed Use Land Common Soprano Pipistrelle Pipistrelle Mixed Use Land 14.09.2012 5 2 ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Appendix 7.3

Screening Responses

CIR.P.0625 Old Sarum Additional Housing ES 2012 Rebecca Read

From: Alison Smith Sent: 05 October 2012 11:17 To: Rebecca Read Cc: Dan Simpson; Glenn Godwin Subject: FW: old sarum additional housing screening opinion/scoping request Attachments: Appendix 2 and 3 River Avon SAC procedure JULY 2012.DOCX

Hi Rebecca,

Please see attached for review and action. Let me know if this raises any concerns.

Kind regards,

Alison

Alison Smith Associate Environmental Planner

Pegasus Group Planning | Environmental | Retail | Urban Design | Renewables | Landscape Design | Graphic Design | Consultation | Sustainability

Pegasus Group is the trading name of Pegasus Planning Group (07277000) registered in England and Wales. This email and any associated files, is intended for the exclusive use of the addressee only. If you are not the intended recipient you should not use the contents nor disclose them to any other person. If you have received this message in error please notify us immediately. Please consider the environment before printing this email and any attachments.

From: Hughes, Richard [mailto:[email protected]] Sent: 05 October 2012 11:05 To: Alison Smith; Glenn Godwin Subject: FW: old sarum additional housing screening opinion/scoping request

Alison/glen

Further to your EIA request email, I have received the attached and the email response below from the Council’s ecologist. I will obviously reiterate this in any final response I send, but I thought it would be handy for you to see her response as soon as possible.

From: Kilgallen, Louisa Sent: 05 October 2012 10:56 To: Hughes, Richard Subject: RE: old sarum additional housing screening opinion request

Richard

I visited this site on 8 Feb 2012, and provided feedback on PE/11/0518. I seemed that areas 9b, 11, 9a and 6c were already occupied by the construction works. However I couldn’t get within the construction compound to see the extent to which the works affected the old hedge that forms the northern boundary of the site. The hedge and the adjacent fields could have / perhaps still do, support badgers, bats and reptiles. Any revised application should demonstrate how these protected species have been accommodated. An existing phase 1 map should be included for the site area affected by the new application and mitigation / ecological enhancement proposals put forward.

Regarding the swales, the applicant will need to demonstrate that there will be no impacts of the proposed development on the hydrological regime of the River Avon SAC. Recently we have revised the River Avon SAC Procedure and this reduces the number of applications that we need to conduct HRA for at the application stage. I

1 have attached Appendix 2. This application may require HRA, depending on whether it can still apply SUDS techniques for dealing with surface water runoff.

Currently the authority is not collecting developer contributions towards a phosphate management plan for the River Avon because we believe mitigation for phosphate contributed by all development contained in the core strategy has already been delivered through upgrades to sewage treatment works. However, the EA has indicated for two large applications that mitigation for phosphate should be provided and we are trying to resolve the basis of their concerns. I’d be grateful therefore if the EA raises phosphate in relation to this inquiry.

Louisa Kilgallen MIEEM CEnv Senior Ecologist Wiltshire Council ______Tel: 01225 713303 Fax: 01225 713437 Email: [email protected]

Please note I work part time, generally Tuesdays, Wednesdays and Fridays

From: Alison Smith [mailto:[email protected]] Sent: 03 October 2012 11:49 To: Hughes, Richard; Glenn Godwin Subject: RE: old sarum additional housing screening opinion request Importance: High

Richard,

Thanks you for your email – Please find attached our Screening Request of 28th September and attachments.

Please call or drop me a line if you need any additional information or if I may be of further assistance.

Regards,

Alison

Alison Smith Associate Environmental Planner

Pegasus Group Planning | Environmental | Retail | Urban Design | Renewables | Landscape Design | Graphic Design | Consultation | Sustainability

Pegasus Group is the trading name of Pegasus Planning Group (07277000) registered in England and Wales. This email and any associated files, is intended for the exclusive use of the addressee only. If you are not the intended recipient you should not use the contents nor disclose them to any other person. If you have received this message in error please notify us immediately. Please consider the environment before printing this email and any attachments.

From: Hughes, Richard [mailto:[email protected]] Sent: 02 October 2012 16:15 To: Glenn Godwin; Alison Smith Subject: old sarum additional housing screening opinion request

Alison (Glen)

In order to expedite this matter and speed up consultation, is it possible you could email your screening request and plans/info etc to me please ?

Richard Hughes

2

Mr Richard Hughes Our ref: WX/2012/122390/02-L01 Planning Department (PO Box 2281) Your ref: PE/2011/0158 Salisbury Wiltshire Date: 06 November 2012 SP2 2HX

Dear Mr Hughes

ALTERATION OF AGREED DRAINAGE AREA - SCREENING AND SCOPING REQUEST - 194 ADDITIONAL HOMES (TOTAL 866 DWELLINGS)

THE PORTWAY, OLD SARUM, SALISBURY, WILTSHIRE

I write following my letter of 24 October 2012 concerning the above site.

Thank you for highlighting the issue of the proposal to reduce the size of the existing swales which serve the development.

We have some concerns about the proposal to develop the parcel of land originally set aside for swales (area 11). The 2004 master-plan included a corridor of land specifically set aside for infiltration swales and associated surface water drainage features. The strip of land lies along the natural valley bottom. It was identified for this use because surface water run-off naturally drains toward the area. This will occur under greenfield run-off conditions and post-development where, under exceedance events, overland flows will be directed toward the lower lying land (natural valley bottom).

Included within the submission from Pegasus Planning Group (26 September 2012) is a section detailing Flood Risk and Drainage. It confirms the intention to revise and update the original Flood Risk Assessment (FRA) to demonstrate to the LPA that the existing swales (already built) have sufficient capacity to deal with both the approved development and the additional parcels of land now proposed for dwellings. However, this has not yet been carried out and therefore we advise you not to accept the principle of development within an area originally set aside for swales prior to receiving details of a revised strategy for the management of surface water run-off.

We strongly recommend that you request the developer to submit sufficient information, in the form of a FRA to include the results of full surface water run-off modelling in accordance with current best practice, and based on the latest revised master-plan,

Environment Agency, Rivers House, Sunrise Business Park, Higher Shaftesbury Road, Blandford, Dorset, DT11 8ST. Customer services line: 08708 506 506 Email: [email protected] www.environment-agency.gov.uk prior to agreeing the principle of development of Area 11. Given the scale of development at the site (existing and proposed) it is advisable to require a full appraisal of all existing surface water drainage infrastructure, including as-built surveys of the existing swales etc, to be included within an updated FRA. It is important that the FRA covers the whole site, including all existing and proposed development. This will ensure that the approved surface water drainage system will function successfully once the whole site is developed. The FRA should also include an appraisal of all neighbouring land, should any be proposed for development in the future. We note that, in particular, land to the north of the site is set aside for future possible development (Land at Longhedge, Old Sarum).

You may wish to request that the FRA is undertaken as part of the EIA and appended to the Environmental Statement.

I hope you find the above helpful.

Yours sincerely

MS ELLIE CHALLANS Planning Liaison Officer

Direct dial 01258 483321 Direct e-mail [email protected]

End 2

ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Appendix 7.4

River Avon SAC Protocol

CIR.P.0625 Old Sarum Additional Housing ES 2012 APPENDIX 2 of the River Avon SAC Procedure: Test of Likely significance

The assessment in Appendix 2 should be completed for all applications in the River Avon catchment meeting at least one of the criteria below and any other application where there is doubt.

a). Applications which could lead to pollution of groundwater or surface water. Likely applications include those where one or more of the following apply:

 lie within flood zone 3  have direct linkage routes to the SAC such as roads, surface water drains or ditches and tributaries to the SAC rivers  affect contaminated land  affect steeply sloping land

(NB. Appendix 2 does not need to be completed for applications where potential pollution issues relate solely to the construction period and a construction method statement is submitted with the application. Under CP 69 All applications within 20m of the River Avon SAC must submit a construction method statement)

b). Major applications that could lead to large scale increased recreational use along the River Avon SAC

c). Applications not linked to main sewer and lying within 50m of the SAC (for ground water discharge) or 500m of the SAC (for surface water discharge).

d). Large Scale Major developments (100 dwellings or more) that cannot apply SUDS techniques.

e). Applications for 100 or more dwellings discharging to Warminster STW

f). Applications for poultry rearing units

APPENDIX 2 of the River Avon SAC Procedure: Test of Likely significance

Application No: Date of assessment:

Application meets Yes or No Examples of potential significant effects to consider Development If effects are one or more of the could give rise to unlikely alone, following criteria likely significant could it cause effects alone? effects in (yes or no) combination with other plans and projects? 1. Application lies No. Where application boundary impinges on SAC boundary, direct No. The Application No. within flood zone 3 or Application physical damage could occur to: Sites are over 1km within 20m of a River is in flood  Bank side vegetation supporting Desmoulins whorl snail from the River Avon which is part of the SAC zone 1. SAC, so no direct  River bed supporting fish spawning habitat and nursery effects are grounds. anticipated. Lighting, noise and vibration could also lead to impacts. Desmoulins whorl snail requires wetland conditions found in flood No. There are no No. zone 3. The SAC could be affected even if the application affects wetland habitats wetland habitat outside the SAC boundary. Examples of impact within Application could be trampling, direct loss, land drainage, grazing etc. Sites. Reduction in floodplain area could affect the river’s flow regime. This No change in No. will only be significant for the largest applications and should have River’s flow regime been assessed in DPDs. Check application is consistent with HRA anticipated. for relevant DPD. Alterations to groundwater flows could occur where developments No alteration to No. require deep excavations, extensive piling, or water abstraction. groundwater flows Unlikely to be relevant to household or minor applications. EA anticipated. response may indicate potential for significant effects since it is responsible for permits for water abstraction and any works within 8m of a main river.

APPENDIX 2 of the River Avon SAC Procedure: Test of Likely significance

Application meets Yes or No Examples of potential significant effects to consider Development If effects are one or more of the could give rise to unlikely alone, following criteria likely significant could it cause effects alone? effects in (yes or no) combination with other plans and projects? Is there a risk of discharges which do not fall under the EA No. Pollution No. regulation system e.g. use of detergents, oil storage etc in Prevention agricultural apps? Guidance will be implemented to eliminate any risk. CONSTRUCTION phase impacts e.g. surface run-off, solid debris No. The Application In combination falling into river, damage to banks, water abstraction, soil Sites are over 1km impacts dealt with in disturbance, spread of invasive non-native plants. All applications from the River Avon HRA for Wiltshire within 20m of the SAC to submit a Construction Management Plan. SAC, so no such CS effects are anticipated. 2. Major applications No. This risk was identified in the HRA for the Wiltshire Core Strategy. No. No significant In combination which could lead to Applications which could lead to damage of river banks and river increase in impacts dealt with in large scale increased bed in upper reaches where fish spawning beds and nurseries occur recreational activity HRA for Wiltshire recreational use along are those most likely to present a risk, e.g. campsites, activity is anticipated. CS the River Avon SAC centres etc. 3. Applications not No. Effluent from septic tanks or package treatment plants may cause No. Application In combination linked to main sewer pollution to the SAC if it is within 50m of the SAC if it is discharging Sites are linked to impacts dealt with in and lying within 50m of to groundwater and within 500m of the SAC if it is discharging main sewer. HRA for Wiltshire SAC (for ground water directly to a watercourse. CS discharge) or 500m of Consider the EAs response and whether it will be feasible for the SAC (for surface water development to meet EA requirements. discharge).

APPENDIX 2 of the River Avon SAC Procedure: Test of Likely significance

Application meets Yes or No Examples of potential significant effects to consider Development If effects are one or more of the could give rise to unlikely alone, following criteria likely significant could it cause effects alone? effects in (yes or no) combination with other plans and projects? 4. Large scale major No. Where SUDS are not practical, ensure water lost to the system is No. In order to In combination developments (100 minimised. Ensure EA requirements are met. comply with Core impacts dealt with in houses or more) that Policy 19 of the HRA for Wiltshire cannot apply SUDS South Wiltshire CS techniques Core Strategy, residential developments will incorporate water efficiency measures as standard. 5. Applications affecting No. Redevelopment of brown field sites may mobilise existing No. None of the No. contaminated land contaminants leading to direct pollution of the SAC or indirect Application Sites pollution through groundwater flow. Ensure EA requirements can be comprise brownfield met. land and thus contaminated land is not an issue.

APPENDIX 2 of the River Avon SAC Procedure: Test of Likely significance

Application meets Yes or No Examples of potential significant effects to consider Development If effects are one or more of the could give rise to unlikely alone, following criteria likely significant could it cause effects alone? effects in (yes or no) combination with other plans and projects? 6. Applications for 100 No. Until a Nutrient Management Plan (NMP) has been produced and No. The LPA has No. or more dwellings Application Wiltshire Council has considered whether it is appropriate to support advised that it is not discharging to Sites will the plan with developer contributions, consult Natural England over collecting developer Warminster STW discharge development of 100 dwellings or more which would discharge into contributions to the Warminster STW. towards a NMP at Petersfinger present because Sewage mitigation for Treatment phosphate Works. contributed by all development contained in the Core Strategy has already been delivered through upgrades to sewage treatment works. 7. Applications for No. For units above a certain size threshold, EA will issue permits for No. The Proposed No. poultry rearing units ammonia emissions and treatment of waste. Below this threshold, Development does assume likely significant effects and consider further. not include any poultry rearing units.

APPENDIX 3 of the River Avon SAC Procedure: Test of Likely significance

APPLICATION REF:

DATE:

TITLE OF PROJECT:

This is a record of the judgment made by Wiltshire Council as required by Regulation 61 of the Conservation of Species and Habitats Regulations 2010 following an assessment of the above project. The assessment and mitigation proposals submitted with the project have been considered, and it is ascertained that: a) The project as proposed alone would / would not* have a significant effect on the site. b) The project as proposed, in combination with other plans/ projects, would / would not* have a significant effect on the site. c) Taking the above into account, a further appropriate assessment will / will not* be undertaken d) Conditions and / or obligations will / will not* be used to secure mitigation to protect the special interests

*Delete as appropriate

COMPLETED BY: Wiltshire Council Officer (name)…………………………………………..(Signature)…………………………………………..

AUTHORISED BY: Wiltshire Council Manager (name)…………………………………………(Signature)…………………………………………….

FOR AND ON BEHALF OF WILTSHIRE COUNCIL

ENVIRONMENTAL STATEMENT Ecology and Nature Conservation

Appendix 7.5

Photosheets

CIR.P.0625 Old Sarum Additional Housing ES 2012