Land at Woolley, Bradford on Avon Phase 1 Ecology Report

First issue: September 2014 Second issue: November 2016.

Second Issue with the following Addendum 1. Front cover corrected with name of author. Addendum 2. 2015 bat records for both Woolley fields as submitted to SWBRC. Sighting of barn owl 2016 added.

This Report has been produced by Niall Machin B.Sc an ecologist and Full Member of the Chartered Institute for Ecology and Environmental Management (CIEEM)

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1. Introduction

1.1. This report is an extended Phase 1 habitat survey of land between Woolley Street and Holt Road in Bradford on Avon, Wiltshire (hereafter referred to as ‘the Site’).

The Site 1.2. The Site stretches from grid reference ST83524 61338 off Woolley Street in the north, down to ST83595 60891 off Holt Road in the south and has an area of approximately 6.8 Hectares (ha). The Site consists of open pasture fields with mature hedgerows and includes an area of disused commercial greenhouses now overgrown into scrub woodland.

Development Proposals 1.3. The Site is subject to emerging development proposals for residential development, in at least two separate plots (hereafter referred to as the ‘proposed Developments’).

Aims and Objectives of this Assessment 1.4. The purpose/objective of this report is to:  Identify any significant ecological issues on Site ;  Make recommendations for further survey and assessment work, if required;  Assess the consequences of the Developments in relation to relevant planning policy and legislation; and  Identify opportunities for ecological mitigation and enhancements.

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2. Methodologies

2.1. This section summarises the methodology used for undertaking the Ecological Appraisal. The Ecological Appraisal comprised an ecological data search, an ‘Extended’ Phase 1 Habitat Survey and a ground based tree assessment for roosting bats. The basis for evaluating the ecological resources is also described in this section.

Ecological Appraisal

Ecological Data Search 2.2. The aim of an ecological data search is to collate existing ecological records for the Site and adjacent areas. Obtaining existing records is an important part of the evaluation process because it provides additional information that may not be apparent during a site survey. 2.3. This report makes use data from Defra’s MAGIC website in relation to important conservation sites located with 5km, in addition to utilising an ecological desk study undertaken in 2013 in connection with the preparation of the Bradford on Avon Neighbourhood Plan, during which all records of protected species, Habitats of Principal Importance (HoPI) and Species of Principal Importance (SoPI) under Section 41 (S41) of the NERC Act 20061, and / or other notable fauna and flora within the town were requested from the Wiltshire Council. 2.4. The results of the data search have been summarised within this report.

‘Extended’ Phase 1 Habitat Survey 2.5. A Phase 1 Habitat Survey of the Site was undertaken on 29th June 2014 by a Full Member of the Chartered Institute of Ecology and Environmental Management (CIEEM), using the Joint Nature Conservancy Council (JNCC, 2010)2 standard ‘Phase 1’ survey technique. The Phase 1 Habitat Survey methodology was ‘Extended’ by undertaking an assessment of the Site to support protected and notable faunal species. All habitat types within the Site were mapped (see Figure 1) with target notes (see Appendix A) where appropriate. 2.6. The survey was conducted in the optimal season for such an assessment being April to September when the majority of plant species are either in leaf/flower or above ground and visible.

Tree Surveys for Bat Roost Potential 2.7. A preliminary ground based visual inspection assessment of trees on the Site for bat roost potential was undertaken in combination with the ‘Extended’ Phase 1 Habitat Survey, guided by the current Bat Conservation Trust Guidelines3. 2.8. Binoculars were used to inspect the trees from the ground to the canopy to look for features indicative of bat roosts. These include:  Natural or woodpecker holes;  Cracks / splits in major limbs;  Loose bark;  Dense ivy; and

1 ODPM, Natural Environment and Rural Communities Act (2006). 2 JNCC (2010). Handbook for Phase 1 Habitat Survey. Nature Conservancy Council. 3 Bat Conservation Trust (2012). Bat Surveys – Good Practice Guidelines. Second Edition. Bat Conservation Trust, London.

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 Hollows / cavities. 2.9. Signs of bat use, such as droppings, staining from the fur or urine and scratches around the entry points were also inspected where applicable. 2.10. Following an external inspection, the trees were scored according to the criteria set out in Table 1 to determine their potential to support roosting bats. The survey was undertaken on 29th June 2014 which constitutes the optimum time for tree inspections according to Bat Conservation Trust Guidelines. Table 1: Bat Conservation Trust Tree Guidelines, 2012 Tree category Description

Known or Evidence of roosting bats within the tree. confirmed roost

Category 1* Trees with multiple, highly suitable features capable of supporting larger roosts.

Category 1 Trees with definite bat potential, supporting fewer suitable features than category 1* trees or with potential use by single bats.

Category 2 Trees with no obvious potential, although the tree is of a size and age that elevated surveys may result in cracks or crevices being found; or the tree supports some features which may have limited potential to support bats.

Category 3 Trees with no potential to support bat roosts.

Limitations 2.11. It was not possible to access all parts of the site. The following were not accessed:  The disused greenhouses;  The barn/farm outbuilding in the northern field;  The sheds/shacks just south of Cemetery Lane in the ‘Spitfire Field’.

Evaluation 2.12. The habitat and species evaluations are based on published guidance from the Institute of Ecology and Environmental Management (IEEM, 2006)4. The value of specific ecological receptors is assigned using a geographic frame of reference, i.e. international value being the most important, followed by national, regional, county, district, local and lastly, within the boundary of the Application Site only. A negligible value is assigned where the habitat offers no or limited value to wildlife. 2.13. Value judgements are based on various characteristics that can be used to identify ecological resources or features likely to be important in terms of biodiversity. These include site designations (such as SSSIs), or for undesignated features, the size, conservation status (locally, nationally or internationally), and the quality of the ecological resource. In terms of the latter, ‘quality’ can refer to habitats (for instance if they are particularly diverse, or a good example of a specific habitat type), other features (such as wildlife corridors or mosaics of habitats) or species populations or assemblages.

4 Institute of Ecology and Environmental Management (2006). Guidelines for Baseline Ecological Assessment in the United Kingdom. E & F.N. Spon, Chapman & Hall, London.

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2.14. Value judgements are also based on the ecologist’s academic and professional qualifications, in addition to past experience of undertaking similar assessments.

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3. Legislation and Policy

Legislation 3.1. Specific habitats and species of relevance to the Site receive legal protection in the UK under various European and domestic legislative provisions, including:  The Conservation of Habitats and Species Regulations 20105 (as amended);  The Wildlife and Countryside Act (WCA)1981 (as amended)6;  The Countryside and Rights of Way (CRoW) Act 20007;  The Hedgerow Regulations (1997); and  The Natural Environment and Rural Communities (NERC) Act 2006;

Planning Policy

National Planning Policy

National Planning Policy Framework, 2012 3.2. The National Planning Policy Framework8 (NPPF) was published in March 2012. Section 11 (outlined below) of the NPPF, ‘Conserving and Enhancing the Natural Environment’, effectively replaces former Planning Policy Statement 9: Biodiversity and Geological Conservation. However, Government Circular 06/20059 - Biodiversity and Geological Conservation: Statutory Obligations and Their Impact within the Planning System, remains valid and is referenced within the NPPF. 3.3. The NPPF encourages the planning system to contribute to and enhance the natural and local environment. This should be achieved by:  “Protecting and enhancing valued landscapes, geological conservation interests and soils;  Recognising the wider benefits of ecosystem services;  Minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the government’s commitment to halt the overall decline in biodiversity, including by establishing ecological networks that are more resilient to current and future pressures;  Preventing both new and existing development from contributing to or being put at an unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and  Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate”. 3.4. The NPPF also stipulates that Local Planning Authorities (LPAs), when determining planning applications, should seek to conserve and enhance biodiversity, by applying the following principles:  “Development proposals where the primary objective is to conserve or enhance biodiversity should be permitted;  Opportunities to incorporate biodiversity in and around developments should be encouraged; and

5 HMSO, 2010 ‘The Conservation of Habitats and Species Regulations’ (as amended). 6 HMSO, 1981 ‘The Wildlife and Countryside Act (WCA) (as amended). 7 HMSO, 2000, ‘The Countryside and Rights of Way (CRoW) Act’. 8 Department of Communities and Local Government (March 2012) ‘National Planning Policy Framework, 2012’. 9 ODPM Circular 06/2005: Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System. Office of the Deputy Prime Minister.

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 Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss.”

Local Planning Policy

Wiltshire Core Strategy 3.5. The Wiltshire Core Strategy (WCS) is due to be adopted in July 2014. Core Policy 50 ‘Biodiversity and geodiversity’ 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.

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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 include securing management measures for designated features of , 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. Targets: No net loss of biodiversity through development. 3.6. The WCS also states that ‘Wiltshire Council is developing guidance for development surrounding the Bath and Bradford Bats SAC and associated roost sites. This will include guidance for developers and planners, and a procedure to ensure that any likely significant effects upon the SAC are identified and assessed at the application stage. 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’. This guidance ‘Bat Special Areas of Conservation: Planning Guidance for Wiltshire’ (draft 23 March 2013), creates a Consultation Zone around the SAC (which includes the Site), within which ‘there will be a strong requirement for survey information, mitigation and compensation for bats in order to demonstrate that development proposals will not impact on the designated bat populations. The guidance applies to all types of development that are subject to planning control’.

Biodiversity Action Plans

UK Post-2010 Biodiversity Framework 3.7. The Environment Departments of all four governments in the UK work together through the Four Countries Biodiversity Group. Together they have agreed, and Ministers have signed, a framework of priorities for UK-level work for the Convention on Biological Diversity. Published on 17 July 2012, the 'UK Post-2010 Biodiversity Framework'10 covers the period from 2011 to 2020. This now supersedes the UK Biodiversity Action Plan (UK BAP)11. However, many of the tools developed under UK BAP remain of use, for example, background information about the lists of priority habitats and species. The lists of priority species and habitats agreed under UK BAP still form the basis of much biodiversity work in the countries. 3.8. Although the UK Post-2010 Biodiversity Framework does not confer any statutory legal protection, in practice many of the species listed already receive statutory legal protection under UK and / or European legislation. In addition, the majority of Priority national (English) BAP habitats and species are now those listed as Habitats of Principal Importance (HoPI) and Species of Principal Importance (SoPI) in England ((listed under Section 41 (S41) of the NERC Act 2006)). For the purpose of this report, habitats and species listed under Section 41 of the NERC Act are referred to as having superseded the UK BAP. All public bodies have a legal obligation or ‘biodiversity duty’ under Section 40 of the NERC Act 2006 to conserve biodiversity by having particular regard to those species and habitats listed under Section 41. 3.9. From the findings of the ‘Extended’ Phase 1 Habitat Survey, it is assessed that no HoPI and SoPI listed under S41 are of relevance to the Site.

10 JNCC and DEFRA (on behalf of the Four Countries’ Biodiversity Group). 2012. UK Post-2010 Biodiversity Framework. July 2012. Available from: http://jncc.defra.gov.uk/page-6189. 11 HMSO (1994) Biodiversity The UK Action Plan

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Local Biodiversity Action Plans 3.10. In accordance with the NERC Act, local Biodiversity Action Plans have been produced for most parts of the UK. The Site is covered by the Wiltshire Biodiversity Action Plan 12 (WBAP). The WBAP was originally produced in 2002 and was updated in 2008. It describes how the wildlife of Wiltshire is going to be enhanced and protected until March 2013 when an updated version of the Plan is due (however at the time of writing this report this updated plan was not available on the Council’s Website). It contains Habitat Action Plans (HAPs) and Species Action Plans (SAPs). The following WBAP HAPs and SAPs are considered to be relevant to the Site:

 Farmland Habitats  Ancient and Species Rich Hedgerows

 Bats

12 Wiltshire Biodiversity Action Plan, 2008 [Accessed on-line on 14/07/2014]

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4. Results

Designated Sites

Statutory Sites 4.1. The Site itself is not subject to a statutory designation, however 6 statutory sites are present within 5km of the Site, these are detailed in Table 2 below. Table 2: Statutory Sites within 5km of the Site Designation Distance from Details site (km) Bath and Bradford on Avon Bats The closest part Includes the hibernation sites for SAC of the SAC, several Annex II bat species, Winsley Mines, including those associated with 15% are 3.9km away of the UK greater horseshoe bat to the west. population and is selected on the basis of the importance of this The Site lies with exceptionally large overwintering the SAC population. Small numbers of Consultation Bechstein’s bats have been recorded Zone for bats. hibernating in abandoned mines in this area, though maternity sites remain unknown. Lesser horseshoe bat are a qualifying feature but not a primary reason for site selection. The main habitats are mines and on the surface small scale quarries overlain with heath, scrub, maquis and garrigue, Phygrana (4%), broad- leaved deciduous woodland (41%), and other land (including towns, villages, roads, waste places, mines, industrial sites) (55%). Winsley Mines SSSI SSSI is 3.9km to The two old stone mines on this site, the west. The Murhill Quarry and Winsley Rift Mine, Site lies within are important hibernation sites for the the SSSI impact rare and endangered greater risk zone. horseshoe bat Rhinolophus ferrumequinum. Up to 100 bats have been recorded in these mines during the winter, the majority using Murhill Quarry. Gripwood Quarry Geological SSSI 1.3km W Geological SSSI.

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Cotswolds AONB 1km W The area is a rich mosaic of historical, social, economic, cultural, geological, geomorphological and ecological features. Inwood, Warleigh SSSI 3.3km NW Inwood is a structurally varied and botanically rich example of southern calcareous ash-wych elm and dry ash-maple woodland. Iford Manor SSSI 4km SW Iford Manor consists of a large country house and gardens situated on the Avon/Wiltshire border alongside the River Frome and surrounded by water meadow, permanent pasture and hedgerows leading up into nearby woodland. The roof voids of the Iford Manor barn and Iford Manor mill are used as a summer maternity roost by a colony of greater horseshoe bats Rhinolophus ferrumequinum.

Non-statutory Sites 4.2. The Site itself is not subject to a non-statutory designation, however 3 non-statutory sites are present within 1km of the Site and these are detailed in Table 3 below. Table 3: Statutory Sites within 1km of the Site Designation Distance from Details site (km) Great Bradford Wood County 0.8km to SE Woodland with heronry. Wildlife Site (CWS) River Avon CWS 390m to south. River with important aquatic flora and dragonflies. Kennet and Avon Canal CWS 1km to south Canal with interesting flora, invertebrates and birdlife.

Habitats 4.3. The following habitat types, described in more detail below, were identified on the Site during the ‘Extended’ Phase 1 Habitat Survey:  Semi-improved grassland;  Arable;

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 Pond and wet areas;  Buildings and lanes:  Tall herbs;  Woodland; and  Hedgerows 4.4. The habitat descriptions given below should be read in conjunction with Figure 1, the Target Notes presented in Appendix A and the photographs (Plates) presented in Appendix B.

Semi-improved grassland 4.5. The majority of the Site comprises fields of semi-improved grassland (see Plates 1). Some are cut for hay, whilst others are grazed by cattle (Plate 2, e.g. Target Note 1). These pastures support a range of common grass species, with occasional broad-leaved dock Rumex obtusifolius and other common forbs. 4.6. The field edges support a few more wildflowers including bird’s foot trefoil Lotus corniculatus, ragwort sp Scenecio sp, and hedge woundwort Stachys palustris (e.g. Target Note 2, south eastern corner of Spitfire Field). 4.7. This habitat is likely to support a range of common bird and invertebrate species. However, it also provides a foraging resource for bat species which use the nearby SAC (see bat section) and forms part of the SAC bat ‘Core Area’. The grasslands on Site are therefore of considered of local/County value.

Arable 4.8. A large field on the eastern boundary of the Site comprises arable crops, recently harvested on the site visit. A damp area with wet ditches and tall herbs is located in the southern half of the field. Apart from this wet area, the field has limited ecological value, but would be likely to support a range of wintering bird species and is of value within the boundary of the Site.

Buildings and lanes 4.9. The Site includes: disused greenhouses (Plate 3); disused and overgrown sheds (Plate 4); a barn (Plate 2); and is dissected by Cemetery Lane, a dark wooded green corridor. 4.10. The sheds (on the Spitfire Field, Target Note 3) on Site have potential for roosting bats. The barn (Target Note 4) has potential for roosting bats and barn owl. The overgrown disused greenhouses (Target Note 5) have potential for breeding birds and possibly bats. 4.11. Cemetery Lane, given its dark and wooded nature has value for breeding birds and commuting and foraging bats (including SAC species of horseshoe bats) and is discussed later in the species section. 4.12. The buildings and lane on Site are considered to be of local/County value, given their potential for bats and barn owl.

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Tall herbs 4.13. Small areas of tall herbs occur at some of the field margins, e.g. along the northern edge of the Spitfire Field (Target Note 2) comprising nettle Urtica dioica, thistles Cirsium sp, curled dock Rumex crispus and cocksfoot Dactylus glomerata. 4.14. This habitat is considered to provide opportunities for common bird and invertebrate species and foraging opportunity for bats and therefore is of ecological value within the boundary of the Site.

Woodland 4.15. An area of woodland occurs around the former greenhouses and adjacent gardens. Species here include ash Fraxinus excelsior, hazel Corylus avellana, hawthorn Crateagus monogyna, lime Tilia sp and sweet chestnut Castanea sativa. 4.16. This woodland supports a variety of birds, including potentially breeding blackcap, chiffchaff, song thrush, goldfinch, wren and blackbird (all singing on the survey visit). 4.17. Part of this woodland is shown on the Defra MAGIC map as UK BAP deciduous woodland priority habitat. The supports woodland nesting bird species as well as providing foraging opportunities for bats (including SAC species), animal and invertebrate species. The woodland edges also provide commuting routes for SAC bats. The woodland on site is considered to be of Local/County value.

Hedgerows 4.18. The Site supports numerous mature tree lined hedgerows (e.g. Plate 5). Many of these are species rich and may be considered ecologically important under the Hedgerow Regulations (e.g. hedges A, B and E). Hedges are numbered on Figure 1 and set out in the table below: Table 4. Hedgerows on Site. Hedge Description /Species A: Extending south from Woolley Road. Mature gappy hedge with ash, hawthorn, elder, dog rose, bramble, elm, hazel. 120m long. B: Recently cut gappy hedge with blackthorn, elder, hawthorn, dogwood, bramble, elm. Mature London plane on corner of A and B. Wild arum. 100m long. C. Gappy hedge with elm, hawthorn, elder and ash. 65m long. D. Mature hedge with hawthorn, ash, oak and field maple. Great spotted woodpecker in hedge. Oak and field maple with bat roost potential. 135m long. E. Either side of Cemetery Lane. Mature wooded hedges, with mature ash, oak, field maple, hawthorn, blackthorn, dogwood, hazel. Mature oak and ask with bat roost

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potential. 260m (north side) and 315m (south side) long. F. Along Holt Road. Intact mature hedge, hawthorn, ash. 263m long.

4.19. The hedgerows provide commuting, roosting and foraging opportunities for bats (including SAC species), opportunities for nesting and foraging birds as well as foraging opportunities for invertebrate species. The field edge/ hedgerow habitat also provides potential for reptiles. The network of hedgerows are considered to be of Local/County value.

Ponds and wet areas 4.20. A dry pond situated in a small hawthorn copse is located in the ‘Spitfire Field’ (Target Note 6). This may have been wet earlier in the year and has potential for great crested newt. Another pond exists in the eastern corner of the field to the east of the Spitfire field (across Cemetery Lane). 4.21. An area of wet flushes and ditches has been created in the arable field to the north (Target Note 7). Species here include rushes Juncus sp, and willowherb Epilobium sp. These wet ditches have potential for amphibians including great crested newt. A further pond is located to the north (Target Note 8): this also has great crested newt potential. 4.22. Pending any further surveys for great crested newt, the ponds on Site are considered to be of value within the boundary of the Site only.

Fauna

Bats 4.23. Thirteen species of bat were returned from the data search (see Table 5). All thirteen species were recorded adjacent to the Site along Holt Road (from surveys in 2010 and 2011 by Engain in connection with the development to the south of Holt Road at Kingston Farm). These include the following European protected species13: barbastelle; Bechstein’s; greater horseshoe; and lesser horseshoe. All of the Bechstein’s (3) and barbastelle (1) records within 2km were from the Holt Road, adjacent to the Site. Table 5: Record of bat species within 2km of the Site Species Approx. Number of records within 2km of the Site

Greater horseshoe Rhinolophus ferrumequinum 32

Lesser horseshoe Rhinolophus hipposideros 37

Noctule bat Nyctalus noctula 3

Common pipistrelle Pipistrellus pipistrellus 27

Soprano pipistrelle Pipistrellus pygmaeus 11

Brown long-eared bat Plecotus auritus 5

13 listed on Annex II of the EC Habitats Directive

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Species Approx. Number of records within 2km of the Site

Barbastelle Barbastella barbastellus 1

Brandt’s bat Myotis brandtii 3

Daubenton’s bat Myotis daubentonii 8

Whiskered Myotis mystacinus 8

Natterers Myotis nattereri 11

Serotine Eptesicus serotinus 13

Bechtein’s Myotis bechsteinii 3

4.24. A number of mature trees on site had moderate to high bat roost potential (see Target Notes 9 and 10), including oak, ash and field maple along Cemetery Lane, the ash in the southern part of the Spitfire Field (Target Note 10,Plate 6) and trees within the woodland/disused greenhouse area. 4.25. A number of buildings also had moderate to high bat roost potential: the barn in the cow grazed field south of Woolley (Target Note 4) and the disused sheds and buildings in the Spitfire Field south of Cemetery Lane (Target Note 3). 4.26. Known bat roosts occur on Woolley Street, in houses immediately adjacent to the south west boundary of the Spitfire Field (a serotine and brown long-eared roost, Target Note 11) and on the Moulton Estate to the south of Holt Road. 4.27. Bat detectors were used to record bats on the evening of the Phase 1 survey. Bat were recorded commuting along Woolley Road (common pipistrelle; Myotis sp), Cemetery Lane (greater horseshoe, common pipistrelle) and the intervening fields and hedges (serotine). 4.28. In July 2014, SM2 automated bat detectors were placed adjacent to the northern field (cow grazed), and on the edge of the Spitfire Field. On Sept 30th 2015 an SM2 was again placed on edge of the Spitfire Field and on Oct 20th 2015 an SM2 was again placed adjacent to the northern field14. The results are shown in Table 6 below. Species Northern field Spitfire Field Lesser horseshoe  (both years)  (both years) Greater horseshoe  (both years) Serotine  (2014)  (both years) Natterers  (2014) Brown long eared owl  (2014)  (2014) Long eared sp  (2015) Common pipistrelle  (both years)  (both years) Soprano pipistrelle  (both years)  (both years) Noctule  (both years)  (both years)

Whiskered/Brandts  (2014)

14 Addendum November 2016. Bat records from 30.09.15 and 20.10.15 submitted to SWBRC

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Myotis sp  (2015)  (2015) Daubentons  (2014) Barbastelle  (2015)

4.29. The above information shows that the grassland, hedgerows and woodland on Site is part of a valuable feeding and commuting area for a wide range of bat species. Known roosts occur nearby and there are trees and buildings on site with bat roost potential that require further survey. 4.30. It is therefore considered that the Site is of County/Regional importance for bats. Given the proximity to the SAC, and the importance of protected habitat for bats of European importance, the Site could be said to contribute as a foraging and commuting habitat to an area of national importance for bats.

Birds 4.31. Several bird species were returned from the data search, including barn owl Tyto alba (WCA Schedule 1 Rare Breeding Species) recorded at Woolley Street. Barn owls are known to feed on Site and potential breeding sites occur on Site (barn; mature trees) and were recorded on a Site visit in September 2014. A barn owl was seen and photographed in the northern field in 2016. 4.32. During the survey, the following birds were recorded (16 species): Species Notes Blackbird 1 pair+ Blackcap 1 pair, greenhouse wood Blue tit 1 pair Buzzard 1 bird Chiffchaff 1 pair, greenhouse wood Goldfinch 1 pair Great spotted woodpecker 1 pair Greenfinch 1 pair Jackdaw 30 birds Long tailed tit 1 pair Mistle thrush 1 pair. RSPB Amber List. Robin 1 pair Song thrush 2 pairs. RSPB Red List. NERC Priority Species. Swallow 3 pairs. RSPB Amber List. Wood pigeon Several pairs

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Wren 2 pairs

4.33. The Site provides nesting opportunities for a range of woodland/farmland bird species owing to the presence of trees and hedgerows. Some of the species present are declining and are listed on the RSPB’s Birds of Conservation Concern Red and Amber Lists. 4.34. The Site is considered of Local value to bird species.

Invertebrates 4.35. The Site is considered to support a range of invertebrate species. 4.36. The Site is therefore considered to be of value within the boundary of the Application Site only to common invertebrate species.

Reptiles 4.37. The data search reported records of slow worm (43 records, including from Woolley), grass snake (17), adder (3) and common lizard (5) from within 2km. Habitats on site, including the field edges and hedgerow edges provide suitable habitat for reptiles. 4.38. The Site is considered to be of value within the boundary of the Site for reptiles (pending a survey).

Great crested newt 4.39. The data search reported 11 records of great crested newt within 2km of the Site including a recent record (2010) from gardens in Woolley adjacent to the Site. 4.40. The waterbody on site (Spitfire Field) and the two waterbodies to the north all have the potential to support great crested newt. Another pond exists in eastern corner of the field to the east of the Spitfire field (across Cemetery Lane). The Site is considered to be of value within the boundary of the Site for great crested newt (pending a survey).

Badger 4.41. The data search reported 33 records of badger within 2km of the Site, including two records for Woolley and a main sett recorded near the Holt Road. The Site provides potential habitat for badgers and a badger sett was known to occur on the Spitfire Field close to Cemetery Lane. 4.42. The Site is considered to be of value within the boundary of the Site for badgers (pending a survey).

Other Protected / Notable Species 4.43. The Site is not considered to provide habitat for any other protected or notable species.

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5. Discussion and Recommendations

Designated Sites 5.1. Although the Site does not include any statutory or non-statutory designated sites, it does lie within the Bath and Bradford on Avon Bats SAC Consultation Zone and ‘Core Roost’ area15. The WCS Guidance states: ‘In order to maintain the integrity of the SACs, it is important to protect the network of ‘sensitive features’ used by the designated bat populations (as set out in 3.1). These species can be highly mobile and although individual bats are known to occasionally migrate tens of kilometres between roost sites, there are a number of roosts where large numbers of these bats are known to regularly hibernate and breed; these have been identified as ‘Core Roosts’ for the purposes of this guidance. Core Roosts must support qualifying species and meet the relevant SSSI criteria as follows:  breeding or winter roosts containing 50+ adult greater horseshoe bats; and/or,  breeding roosts containing 100+, or winter roosts containing 50+ adult lesser horseshoe bats; and/or,  any traditional breeding roosts of barbastelle and Bechstein’s bats. In addition to the above criteria, a Core Roost must: a) be a component site of an SAC designation; or, b) have an established demographic connection with a SAC population;4 or, c) be judged as having a likely demographic connection with a SAC population based on proximity, landscape connectivity and expert opinion. The landscapes surrounding these Core Roosts which are used regularly for foraging and commuting are also of particular importance and have been identified as ‘Core Areas’. The size of these Core Areas is dependent upon the typical ranging behaviour of the species involved. For the purposes of this guidance, the Core Areas have been defined as:  4km surrounding greater horseshoe Core Roosts;  2km surrounding lesser horseshoe Core Roosts;  1.5km surrounding Bechsteins Core Roosts;  6km surrounding barbastelle Core Roosts (except at Mottisfont, where local evidence justifies a requirement for a 7.5km radius). 5.2. The network of significant roosts includes sites that are not covered by any statutory designation, such as the breeding colonies of Bechstein’s bats at Biss Wood and Green Lane Woods, a pair of ancient woodlands to the east of Trowbridge. This colony is known to hibernate at SSSI and uses the intervening landscape to commute between these sites. The Site lies in this intervening landscape. 5.3. Where development affects roosts, foraging areas or commuting routes, the Guidance states: Early Engagement and Survey Requirements. If any of the above potential impacts are likely, a licensed bat ecologist should be commissioned to carry out a preliminary visit to assess the risk and the need for further survey work. All survey work should be carried out in general accordance with published best practice, although exact survey requirements will need to reflect the sensitivity of the site, and the nature and scale of the proposals. The bat ecologist should advise on the detailed requirements following a preliminary site assessment and desk study. If the survey protocol will not meet best practice requirements, this should be agreed in writing with one Wiltshire Council’s

ecologists prior to submission of the application. Also, if evidence of one of the SAC species is

15 Bat Special Areas of Conservation: Planning Guidance for Wiltshire

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recorded at the site during the surveys, it is strongly recommended that any need for further survey and mitigation measures be agreed with a Wiltshire Council ecologist at an early stage, prior submission of the application. Please note that surveys for European protected species cannot normally be conditioned. Early support from a consultant ecologist and engagement with Wiltshire Council (where necessary) will ensure that adequate survey data has been gathered and appropriate mitigation measures are incorporated into the project. Failure to provide the necessary information to support an application is likely to result in delays in determination, amendments to the scheme and potentially the need to temporarily withdraw the application to resolve these issues. If insufficient information is submitted to fully assess the application in accordance with the Habitats Regulations10, the local authority will have no legal option but to refuse the application. The Planning Inspectorate will be required to apply the same legal tests to any appeal applications. It is worth noting that bat surveys are seasonally constrained. A substantial suite of surveys may take up to 12 months to complete and should therefore be programmed into the project delivery plan at an early stage to avoid delays. 5.4. Foraging areas used by the bats vary between species and throughout the year, and include a wide range of habitats which support their invertebrate prey including woodland, hedgerows and scrub, unimproved rough grassland, intensively grazed pastures and watercourses and wetland features. 5.5. Commuting routes include hedgerows, tree lines and woodland edges. 5.6. The Site supports both foraging areas and commuting routes for SAC bats, both of which would be impacted by use of the land for residential development. All 4 SAC bat species are known to occur in the area and use the landscape of fields and hedges. 5.7. The Bat Surveys Good Practice Guidelines (Hundt 2012) state that ‘if an Annex II Habitats Directive species is likely to be present … then a greater level of survey effort is likely to be required’. It also states (page 43), that if a site is larger than 1ha or within 4km of a greater horseshoe roost, then dusk emergence surveys must last for at least 3 hours. 5.8. English Nature’s Bat Mitigation Guidelines (2004) includes an example of appropriate survey methodology for greater horseshoe which includes:  Surveys should pay particular attention to known greater horseshoe bat feeding habitat such as hedgerows, coppice, woodland fringe, tree lines and areas of scrub and pasture, and linear landscape features such as ditches, rhynes, walls, hedges etc that may provide flight lines.  Surveys should be carried out on two separate evenings each month from May to September, as the bats’ favoured foraging areas may alter across the summer period.  Surveys should be carried out on warm (>10 °C but >15°C in late summer), still evenings that provide optimal conditions for foraging (insect activity is significantly reduced at low temperatures). Details of temperature and weather conditions during surveys should be included in final report.  Surveys should cover the period of peak activity for bats from sunset for at least the next 3 hrs. 5.9. Therefore, there is likely to be a negative impact on the SAC Core Area for SAC bats and any proposed development must adopt best practice in terms of bat survey and mitigation.

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Habitats 5.10. The Site comprises of habitats considered to be of either of value within the boundary of the Boundary of the Site only (ponds and wet areas; arable; tall herbs) or of Local/County value (hedgerows; woodland; buildings and lanes; and semi-improved grassland). 5.11. The habitats of local/County value are those that contribute to the SAC bat ‘Core Area’ in terms of providing foraging areas and commuting routes for SAC bats. 5.12. In line with NPPF, any development should aim for a net gain for biodiversity, including the conservation and enhancement of the local/county value habitats present on site.

Fauna

Bats 5.13. The grassland, hedgerows and woodland on Site provides foraging areas and commuting routes for a range of bat species including at least 2 and probably all 4 SAC species (both horseshoes, barbastelle and Bechstein’s). The Site lies in the SAC bat ‘Core Area’ and Consultation Zone. 5.14. Various trees and structures on Site have moderate/high potential for bat roosts. Known bat roosts occur on the edge of the Site. 5.15. It is recommended that best practice guidance (Hundt, 2012) is followed in relation to bat surveys with a greater level of survey required due to the proximity of the SAC. As a minimum, the following would be required:  Upfront liaison with Natural England (NE) and Wiltshire Council Ecologists to agree survey methodology, given the site lies in Core Zone for SAC;  Collation and tabulation of bat data from 10km of Site;  Bat activity surveys (transects) each month from April to September, including use of automated bat detectors placed at appropriate locations (including centre of fields as well as hedgerows);  Ground based inspections of trees and buildings (internal and external) for bat roost potential;  Emergence surveys (dusk/dawn) for any trees and buildings with identified bat roost potential (up to 3 visits during May to August), of at least 3 hours. 5.16. The above surveys are required before any planning application can be determined and before any mitigation can be discussed. Depending on the outcome of these surveys, the following mitigation and enhancement measures could be considered:  To enhance commuting and foraging habitat for bats it is recommended that feeding areas such as open pasture, plus linear features such as treelines, hedgerows and woodland edges are retained and enhanced;  Retention of dark corridors including Cemetery Lane for commuting bat species;  Any identified bat roosts on or adjacent to the Site should be retained. If these are impacted upon, a licence will be required from NE with appropriate mitigation;

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 Sensitive lighting is essential adjacent to the habitats with potential to support commuting and/or foraging bats in order to minimise any associated negative impacts on bats; and  Planting native plant species or plants of value to wildlife would provide additional foraging habitat for bats.

Birds 5.17. The Site supports a range of woodland and farmland bird species. Barn owls are known to use the Site and suitable breeding sites exist in barns, buildings and trees. A barn owl survey is therefore recommended and suitable mitigation employed, if required. 5.18. Depending on the outcome of the survey, the following mitigation and enhancement measures could be considered:  Any trees or hedgerows requiring removal should be undertaken outside of the breeding bird season (March to August inclusive). However, if works cannot be undertaken outside the breeding bird season an ecologist will inspect any trees or hedgerows to be felled. An experienced ecologist will be deployed to carry out an inspection at least within 24 hours prior to the clearance. If an occupied nest is detected, a buffer zone will be created around the nest, and clearance of this area delayed until the young have fledged. Similarly, a check will be made for ground nesting birds by an ecologist prior to site clearance if this is carried out during the bird breeding season;  It is recommended that the trees and hedgerows are retained on the Site where possible, to retain the interest for nesting and foraging birds;  The use of native plants species as recommended above would provide additional foraging habitat for local bird species.

Invertebrates 5.19. Only common UK invertebrate species are considered to utilise the Site. 5.20. Opportunities at the Site for invertebrates could be enhanced through new landscape planting. The use of native plants species, as recommended above would provide increased opportunities for a range of invertebrates.

Reptiles 5.21. The Site contains potential reptile habitat. A reptile survey is recommended: this should follow best practice and be undertaken during the optimal survey period for reptiles, i.e. in April/May or in September, under suitable weather conditions. 5.22. Any mitigation would depend on the size of the reptile population found on Site.

Great crested newt 5.23. The pond in the Spitfire Field and the wet area and pond to the north of the Site all have potential for great crested newt (GCN): the data search reported recent GCN records adjacent to the Site. The pond in the field to the east of Spitfire Field has unknown GCN potential. The Site supports potential GCN terrestrial habitat in hedges, woodland, grassland and tall herbs.

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5.24. Therefore a GCN survey is recommended. This should follow best practice and be undertaken between March and June (4 to 6 visits, with 2 between mid April and mid May). 5.25. Any mitigation would depend on the size of the GCN population recorded.

Badger 5.26. Badgers are known to use the Site and a main sett is located in the area. A badger survey is recommended which could be undertaken at any time of year, with appropriate mitigation employed.

Other Protected / Notable Species 5.27. The Site is not considered to be of value to any other protected/notable species. As such, no further survey work other than that detailed above is considered necessary.

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6. Conclusions

6.1. The Site lies in the SAC bat ‘Core Area’ and is used by a number of bat species, including probably all 4 SAC species. Best practice bat surveys (see above) are required and any impact on bat roosting, foraging and commuting habitats (grassland, hedges, woodland edges) should be avoided. Full and timely consultation with NE and WCC is required to agree survey methodology and mitigation. 6.2. Any development of the Site is likely to impact on the ability of the Site to support bats and therefore impact on the SAC Core Area. 6.3. The Site comprises of habitats considered to be between of value within the boundary of the Site only and of Local/County value, the latter in relation to bat foraging and commuting areas. 6.4. The Site has existing value and/or potential for barn owl, reptiles, great crested newt and badger and surveys for these species/groups are required. 6.5. Any proposed development should retain and enhance bat roosting, foraging and commuting habitat. A sensitive lighting strategy would also be required to protect bat foraging, roosting and commuting routes.

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Figures

Figure 1: Phase 1 Habitat Survey Plan

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Target Notes

Target Note Notes

1 Grazed pasture alongside houses off Woolley Road. Potential for commuting and foraging bats including greater and lesser horseshoe and serotine. 2 Wildflower edge to Spitfire Field, supporting birdsfoot trefoil and hedge woundwort. 3 Sheds and buildings on Spitfire Field, south of Cemetery Lane with bat roost potential. 4 Barn in grazed pasture with bat roost and barn owl potential.

5 Area of woodland containing disused greenhouses. Bat and breeding bird potential. 6 Pond in Spitfire Field (dry in July 2014, but previously wet). GCN potential.

7 Created area of wet ditches and flushes in arable field to north of Site. GCN potential 8 Pond to north of Site with GCN potential.

9 Oak, ash and field maple on Cemetery Lane and in adjacent hedgerows with moderate to high bat roost potential. 10 Ash tree in south of Spitfire Field (just north of Holt Road) with high bat roost potential (Plate 6). 11 Maternity bat roost (serotine, brown long-eared bats) in attic of house adjacent to west boundary of Spitfire Field.

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Photographs Plate 1. Semi improved grassland (Spitfire Field, looking south towards Holt Road.

Plate 2. Grazed pasture with barn (latter with bat and barn owl potential)

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Plate 3 Disused greenhouses now emerging woodland

Plate 4 Disused sheds and outhouses in Spitfire Field to south of Cemetery Lane, with bat and bird potential.

Plate 5 Mature hedgerows on site

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Plate 6 Ash in south of Spitfire Field near Holt Road with high bat roost potential

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